Yes, you can invoice a client without being VAT registered, and below the £90,000 registration threshold that is exactly what you should do. Your invoice simply shows no VAT. The lines you cannot cross: charging VAT when you are not registered, or writing ’VAT included’ on an invoice that has none in it.
- Below £90,000 taxable turnover, invoice without VAT, entirely legal.
- You must not charge VAT or say 'VAT included' unless registered.
- A non-VAT invoice is still a valid, enforceable invoice.
- Register within 30 days of crossing the threshold, it backdates.
- Reverse charge only applies between VAT-registered businesses.
Invoicing without VAT registration
A valid UK invoice does not require VAT registration. What it requires is the standard fields: see the required fields and worked examples, and, where you are not registered, simply no VAT line:
| Field | VAT-registered invoice | Non-registered invoice |
|---|---|---|
| Unique invoice number | Yes | Yes |
| Your business name and address | Yes | Yes |
| Customer name and address | Yes | Yes |
| Description, date, amount | Yes | Yes |
| VAT amount and rate | Yes | No VAT shown at all |
| Your VAT registration number | Yes | Must not appear: you have none |
The one deliberate difference: a non-registered invoice must not use the words ’VAT invoice’ and must not imply VAT is included. An invoice headed ’VAT Invoice’ with no VAT number on it is the mistake that gets sole traders letters from HMRC.
The £90,000 threshold, briefly
You must register for VAT when your VAT-taxable turnover exceeds £90,000 in a rolling 12-month period: not a tax year, a rolling window. When that happens:
- You must register with HMRC within 30 days of the end of the month you crossed the threshold.
- Registration takes effect from the date you crossed it, not the date you apply, so invoices that should have carried VAT need reissuing from that date.
- Until registered, keep monitoring the rolling total; most invoicing software can track it from your invoice values.
Below the threshold there is no requirement to register at all, voluntary registration is a choice (usually made to reclaim input VAT or to work with large contractors), not a duty.
What changes when you become registered
The transition is the part that catches people:
- From the effective date of registration, every standard-rate invoice must show 20% VAT and your registration number.
- Invoices issued before registration but after the effective date must be corrected: you reissue them with VAT, and the customer pays the extra.
- The reverse charge becomes possible. Construction services between VAT-registered, CIS-registered businesses move under the domestic reverse charge rules, which only ever apply between registered businesses. While you were unregistered, your customers’ reverse-charge treatment never touched you.
- Your pricing decision changes. £90,000 net becomes £90,000 plus VAT once registered, unless you absorb the VAT or join a scheme such as the flat rate scheme.
Common mistakes to avoid
- Charging ’VAT’ while unregistered. It is not your money, it is an offence, and the money is recoverable by HMRC.
- Writing ’VAT included’ on a non-registered invoice to sound bigger. Same problem, same exposure.
- Ignoring the rolling threshold because ’the year isn’t over’. The window rolls monthly; a strong spring can trigger registration by summer.
- Assuming no VAT means no obligations. Records are still required, and CIS deductions still apply on construction work: see the CIS invoice template.
Related questions
Can I charge VAT before my registration takes effect?
Only from the effective date of registration, which backdates to the point you crossed the threshold. You cannot choose to charge VAT before that date, and you must charge it from it.
Does the reverse charge apply to me if I’m not VAT registered?
No. The domestic reverse charge only operates between VAT-registered businesses. As an unregistered subcontractor you invoice net of VAT, and the customer’s reverse-charge obligations sit elsewhere in the chain.
Do CIS deductions change because I’m not VAT registered?
The deduction is calculated on the labour element after VAT is removed, and if there is no VAT, it is calculated on the labour figure as invoiced. How CIS interacts with VAT is the same question in the other direction.
FAQ
Can I invoice a client without being VAT registered?
Yes. Below the £90,000 taxable turnover threshold you invoice with no VAT shown and no VAT number. The invoice is fully valid and enforceable: it just must not claim to include VAT.
What happens if I charge VAT without being registered?
You must not. Charging VAT while unregistered is an offence, and any VAT you charge is recoverable by HMRC. Reissue the invoice without VAT and refund anything collected.
When must I register for VAT?
When your VAT-taxable turnover exceeds £90,000 in a rolling 12-month period. You must register within 30 days of the end of the month in which you crossed the threshold, and registration backdates to the date you crossed it.
Do I need to show anything special on a non-VAT invoice?
No, just the standard fields: unique number, your details, the customer’s details, description, date and amount. Do not use the phrase 'VAT invoice' or 'VAT included'.
Can a client refuse to pay because I’m not VAT registered?
No. The agreed price is owed with or without VAT. Some large businesses ask suppliers to register for cash-flow reasons, but that is a commercial preference, not a legal requirement.
Is invoicing without VAT the same as zero-rated?
No. Zero-rated is a VAT treatment for registered businesses: 0% VAT, recoverable input tax. An unregistered invoice is simply outside VAT: no VAT, no VAT boxes, no reclaim position.
One last thing
The cheapest VAT problem is the one prevented by a saved invoice template: one version without VAT for now, and the day you register, a second version with the 20% line and your number. Businesses that get caught out are the ones still sending the old template two months after the threshold: the invoices were valid, and then they were not.