If you run a hospitality business in the UK, your point-of-sale system is currently an ordinary piece of commercial software. You buy it, you configure it, and nobody outside your business has any say in how it works.
That may be about to change.
On 23 June 2026 HMRC opened a consultation on introducing mandatory software standards for EPOS and MPOS systems in the UK. It closes on 18 August 2026. Most operators have not heard of it, because it has been discussed almost entirely between HMRC, software vendors and accountants — in language written for accountants.
Here is what it actually proposes, in operator English.
What is being proposed
The consultation sets out several measures. The significant ones:
An unalterable transaction log. Every transaction and every adjustment would be recorded in a standard format — the OECD Standard Audit File for Tax, SAF-T — with each record cryptographically linked to the one before it in an encrypted chain. In practice, a till record you cannot retrospectively edit without the edit being visible.
A national register of POS systems. HMRC is exploring a register of every EPOS and MPOS system sold, transferred or used in the UK, together with a certification process confirming that a given system meets the standard. Options under discussion include manufacturer certification, manufacturer self-certification, and supplier registration at the point of sale.
Compulsory use in named sectors. The consultation states that the government “is considering mandating that businesses that operate in sectors most exposed to ESS are required to use a compliant EPOS/MPOS system to record all of their sales” — and names small retail, takeaway and hospitality as the sectors where it believes suppression is most common. It also asks for views on mandatory receipting for all transactions, possibly above a threshold such as £35.
QR codes on till reports. This is the proposal operators should pay closest attention to. An officer could arrive unannounced, ask for a till report, scan the QR code to verify the integrity of the system and the summary figures, and — if everything reconciles — close the check and leave. HMRC’s own estimate is thirty minutes, against traditional investigations that can run for months or years.
Why HMRC is doing this
The target is Electronic Sales Suppression: software and devices that alter till records to hide sales. HMRC has stated it believes ESS is most prevalent in small retail, takeaway and hospitality.
The wider context matters too. In June 2026 HMRC announced more than 30,000 high-street interventions for 2026–27 — a spectrum from warning letters through compliance checks to unannounced visits and criminal investigations. That campaign is aimed principally at high-street tax crime and money laundering rather than at hospitality specifically, but till fraud is a named strand of it, targeting both the providers and the users of sales suppression tools.
Separately, and more relevant to most operators, HMRC has been steadily increasing routine VAT compliance checks in hospitality — with a stated focus on whether businesses correctly distinguish standard-rated from zero-rated elements of their supplies.
And there is precedent — considerable precedent. 16 of the 37 OECD countries have already mandated the use of POS systems to generate and preserve sales data for tax purposes, and five of those require the data to be transmitted to the tax authority automatically.
Germany mandates technical certification with digitally signed transactions. Norway requires POS systems to be registered with the tax authority and audited at setup, with SAF-T mandatory and receipts digitally signed. Austria requires individual rather than batch recording of sales, plus mandatory receipting. The Netherlands runs a voluntary quality mark.
The UK would not be inventing anything here. It would be catching up.
The part that matters if you are honest
Here is the thing worth sitting with.
If these proposals become policy, your till stops being a private commercial tool and becomes something closer to a regulated instrument — one whose output HMRC can verify on the spot, in half an hour, without warning.
If you are deliberately suppressing sales, that is a serious problem and no article is going to help you.
But most operators reading this are not suppressing anything. And for them the risk is different, quieter, and much more likely:
Verification does not distinguish between fraud and misconfiguration.
A till that has been mapping takeaway items to the wrong tax group since 2022 is not committing fraud. Nobody chose it. In most cases the person who set it up has long since left the business. But when a report can be scanned, verified and reconciled against your declared VAT in thirty minutes, “we never checked” becomes a much harder position to be in than it is today — and a much easier discrepancy to find.
Right now, configuration errors are effectively invisible. Nothing breaks. Nothing errors. The tills work fine. You over-declare or under-declare quietly, every day, for years, and nobody notices.
Faster, automated verification makes invisible errors visible. That is the actual change for the honest operator.
What to do before the deadline
If you want to respond to the consultation: responses go to ESSpolicy@hmrc.gov.uk by 18 August 2026. If you run a small or independent operation, your view genuinely matters here — the consultation is explicitly seeking input from sole traders and SMEs in retail and hospitality, and those voices are usually drowned out by vendors. The full document and questions are on gov.uk.
Whether or not you respond, three things are worth doing regardless of what HMRC eventually decides:
- Find out when your tax groups were last reviewed. Not installed — reviewed. If the honest answer is “at install”, that is worth knowing now rather than during a check.
- Check whether your POS can produce a complete, unedited transaction log. Not a summary report. Every transaction, every void, every adjustment, exportable. If it cannot, that is a conversation to have with your vendor early rather than late.
- Reconcile what your POS reports against what you actually declared, for one full period. Most operators have never done this. The gap, if there is one, is usually a configuration issue rather than an accounting one — and it is cheaper to find yourself.
None of that requires the consultation to become law. It is good practice today. It just becomes considerably more urgent if it does.
Where this is heading
The direction of travel across Europe is one way. Germany, Norway, Austria, Italy and Portugal have already regulated point-of-sale software. The UK is one of the last major economies where a till is just a till.
The operators who come out of this well will not be the ones who scramble when it becomes law. They will be the ones whose systems were already configured correctly, whose reports already reconcile, and for whom a thirty-minute check is a mild inconvenience rather than the start of something worse.
That is a two-week piece of work today. It is a much bigger problem later.
These proposals are at consultation stage. They are not law, and may change substantially or not proceed. This article explains what is being proposed and is not tax advice — for your own VAT position, speak to your accountant.
Open Data Sphere reviews POS configuration for UK hospitality operators — how your system is actually set up versus how your business actually trades. If you would like to know what your transaction log and tax groups would look like under scrutiny, get in touch.