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, invoicing without VAT is 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 the end of the month you crossed the threshold.
- 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 first day of the second month after you crossed it, whenever you apply, so invoices from that date have to account for VAT.
- If you expect to go over £90,000 in the next 30 days alone, you must register by the end of those 30 days: that test looks forward, not back.
- Until registered, keep monitoring the rolling total of your invoice values month by month.
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 after the effective date but before your VAT number arrives still owe VAT. You can’t show VAT until you have the number, but you can reissue them as VAT invoices within 30 days of getting it. Whether the client pays the extra depends on what you agreed; if the price was fixed, the VAT comes out of it.
- The reverse charge becomes possible. Standard- and reduced-rated construction work for a VAT-registered customer who pays you under CIS moves 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 attracts a penalty, and HMRC can recover the money.
- 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?
No. You account for VAT from the effective date of registration, and you can’t show VAT on an invoice until HMRC has given you a VAT number. Invoices sent in between can be reissued as VAT invoices once it arrives.
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 without VAT, and there is nothing for the customer to reverse charge.
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 attracts a penalty, and HMRC can recover any VAT you charge. 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 takes effect from the first day of the second month after 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.
Sendinvo works the same way. Until you add a VAT number in Company, invoices carry no VAT and no VAT line. Add the number the day you register, and new invoices and quotes carry VAT at the rate you set, with a different rate on any line that needs one.