Taking card payments in the UK: what a merchant actually has to do
There is no law in the United Kingdom that makes you accept cards, and no law that makes you accept cash either. What there is instead is a hard ban on charging customers extra for paying by card, a narrow set of rules on when you must issue a VAT invoice, and a timetable for keeping your records digitally. This page names the instrument behind each of those and links to it.
No, you do not have to accept cards — there is no general statutory duty in the UK, and you do not have to accept cash either. But if you do take cards, you must not add a surcharge to a consumer debit or credit card payment: that has been prohibited since 13 January 2018 by regulation 6A of the Consumer Rights (Payment Surcharges) Regulations 2012, inserted by the Payment Services Regulations 2017. Local licensing rules can override the freedom to refuse cards — every licensed London taxi has had to take them since 2016.
Is there any obligation to accept card payments?
No. There is no statute in the United Kingdom that requires a business to accept payment cards. A shop, a stall or a sole trader is free to decide what it takes, and the same freedom cuts the other way — the Bank of England's own explainer on legal tender confirms that a shopkeeper can choose what to accept, and that legal tender is a narrow doctrine about settling debts in court, not a rule about shopping.
Three real exceptions are worth knowing.
Licensing conditions. Transport for London requires every licensed London taxi to accept card and contactless payment; it has been a licensing requirement since 31 October 2016, and from 1 January 2017 the device has had to be fixed in the passenger compartment. A taxi that does not comply is issued with an unfit notice. Other councils attach similar conditions to hackney carriage licences, so check your own licensing authority rather than assuming.
What you have advertised. If you display a Visa or Mastercard sign, or state a payment method when the customer books, refusing it at the counter is a contract and consumer-protection problem, not a payments one.
Equality duties. Under the Equality Act 2010 a service provider must make reasonable adjustments for disabled customers. A card-only or cash-only policy that puts a disabled customer at a substantial disadvantage can engage that duty — a point the Government made expressly in its June 2025 response to the Treasury Committee on cash acceptance.
Receipts, and when a VAT invoice is actually required
There is no general legal duty to hand a customer a receipt for a purchase in the UK. What exists is a much narrower VAT obligation, and it is easy to confuse the two.
Three different pieces of paper get called a receipt. The first is the acquirer's card receipt your app emails out — proof the card transaction happened. It has no tax status of its own. The second is a till receipt, which is simply good practice and evidence of the sale. The third is a VAT invoice, which is a legal document.
Under regulation 13 of the Value Added Tax Regulations 1995, a VAT-registered person who makes a taxable supply to a taxable person must provide a VAT invoice, generally within 30 days of the supply. In other words: the duty bites when your customer is VAT-registered and buying for their business — not when a member of the public buys a coffee.
Regulation 16 softens this for retailers. A retailer is not required to issue a VAT invoice at all, except at the request of a customer who is a taxable person. Where the consideration does not exceed £250.00 including VAT, a simplified (less detailed) VAT invoice is enough: your name, address and VAT number, the time of supply, a description, the amount payable including VAT and the VAT rate.
If you are not VAT-registered you cannot issue a VAT invoice at all, and must not show VAT on anything you give a customer. The registration threshold is £90,000.00 of taxable turnover.
Records, software and how long to keep everything
There is no UK equivalent of a certified till: no fiscal memory, no mandatory technical security device, no type approval for your payment app. What HMRC regulates instead is the record, and increasingly the format.
VAT. Making Tax Digital for VAT applies to all VAT-registered businesses. Records and returns must be kept and filed in functional compatible software, and if you use a retail scheme you must keep a digital record of your daily gross takings. VAT records must generally be kept for 6 years.
Income tax. Making Tax Digital for Income Tax is live. Since 6 April 2026 it applies to sole traders and landlords whose qualifying income exceeded £50,000.00 in the 2024 to 2025 tax year: digital records, quarterly updates through compatible software, then the year-end return. The first quarterly deadline was 7 August 2026, covering 6 April to 5 July 2026. From 6 April 2027 the threshold drops to £30,000.00 (tested on 2025 to 2026 income) and from 6 April 2028 to £20,000.00. The Self Assessment deadline of 31 January is unchanged — quarterly updates do not replace the return.
How long to keep records. If you are self-employed, section 12B of the Taxes Management Act 1970 requires business records to be kept until the fifth anniversary of the 31 January following the tax year. For a company, section 388 of the Companies Act 2006 requires accounting records to be preserved for three years from the date they are made if it is a private company and six years if it is a public company — and HMRC's own corporation tax rules run to six years, so six is the safe number.
Can you add a surcharge for paying by card?
For an ordinary consumer card, no — the sharpest rule on this page.
Regulation 6A(1) of the Consumer Rights (Payment Surcharges) Regulations 2012 — inserted by the Payment Services Regulations 2017 and in force since 13 January 2018 — provides that a payee must not charge a payer any fee for using a non-commercial card-based payment instrument covered by Regulation (EU) 2015/751, an equivalent non-card instrument, or a SEPA credit transfer or direct debit. In plain terms: no card fee on a consumer Visa or Mastercard, and no fee dressed up as something else if only card payers pay it.
Regulation 6A(2) applies to every payment instrument, including those outside the ban: any fee must not exceed the cost you actually bear for it. Regulation 6B sets the geography, and it changed after Brexit: since 31 December 2020 the full ban applies only where both payment service providers are in the United Kingdom. Where only one is, the cost cap still applies but the ban does not — which is why some businesses surcharge cards issued overseas.
Still lawful: commercial cards, cards whose issuer sits outside the UK, and genuine booking or service fees that fall on everyone regardless of how they pay. Enforcement is by Trading Standards, by the Department for the Economy in Northern Ireland, and by the Competition and Markets Authority under Part 8 of the Enterprise Act 2002. Regulation 10 makes an unlawful surcharge unenforceable and repayable.
Where the sources disagree. The official BEIS guidance dates from 2018 and still describes the test as both providers being in the EEA, although regulation 6B was changed to the United Kingdom on 31 December 2020 — read the legislation, not the guidance. The guidance also frames the ban as covering "retail" but not "commercial" transactions, whereas regulation 6A(1) keys on the card being non-commercial rather than on who the buyer is. And neither names American Express or other three-party schemes, whose position under Regulation (EU) 2015/751 is genuinely unsettled. Until that is resolved, do not surcharge unless you can verify the card is commercial.
Do you have to accept cash?
No. There is no obligation on a business in the UK to accept cash, and "legal tender" does not create one. The Bank of England is unambiguous: legal tender only means that a debt offered in that form cannot be sued upon, and a shop owner can choose what to accept. Bank of England notes are legal tender in England and Wales only; in Scotland and Northern Ireland only Royal Mint coin is.
This was tested politically and the answer held. The Treasury Committee ran an Acceptance of Cash inquiry and the Government responded on 27 June 2025; the Committee published that response on 12 July 2025. The Government declined to mandate cash acceptance, while saying that "there may come a time in the future where it becomes necessary for HM Treasury to mandate cash acceptance if appropriate safeguards have not been implemented". It committed instead to monitoring payments data.
Two things to keep straight. A Committee recommendation is not law — and reporting at the time that suggested shops would be forced to take cash was describing a recommendation, not a rule. And the FCA's access to cash regime, in force since September 2024, is about keeping cash available through branches, ATMs and banking hubs; it does not oblige any retailer to take it.
The Equality Act 2010 point in section 1 above is the real constraint. A blanket card-only policy is lawful, but if it puts disabled customers at a substantial disadvantage the reasonable adjustments duty can bite.
What is changing in 2026 and 2027
Already happened — the contactless limit stopped being a fixed number. On 19 March 2026 the FCA instrument FCA 2025/62 removed the £100.00 single-payment and £300.00 cumulative thresholds from Article 11 of the Technical Standards on Strong Customer Authentication and replaced them with a risk-based exemption. Issuers with strong fraud controls may now set their own limits. The FCA stressed this is optional, so limits will differ from bank to bank and can move without notice.
Now — Making Tax Digital for Income Tax. Live since 6 April 2026 for qualifying income over £50,000.00. 6 April 2027 brings in the £30,000.00 band and 6 April 2028 the £20,000.00 band. If you are a sole trader taking card payments, this is the fixed date that will actually cost you time and software.
Announced but not yet law — e-invoicing. On 26 November 2025 the Government confirmed it will mandate electronic invoicing for all VAT invoices from 2029, covering B2B and business-to-government but not consumer sales, with an implementation roadmap promised at Budget 2026. No standard has been fixed and no legislation has been made — this is policy, not law.
Announced but not yet law — the Payment Systems Regulator. The Government confirmed it will consolidate the PSR's functions into the FCA. That needs primary legislation, none has been introduced, and no date has been given.
Ireland and Northern Ireland. Northern Ireland follows the same UK-wide surcharge, VAT and MTD rules; the difference is who enforces them — the Department for the Economy rather than a local authority Trading Standards service — and that Bank of England notes are not legal tender there. The Republic of Ireland is a separate legal system: the surcharge ban sits in the European Union (Payment Services) Regulations 2018 (S.I. No. 6 of 2018) rather than in UK law, and Ireland's National Payments Strategy requires government bodies to accept cash without imposing that duty on ordinary businesses.
The dates that matter
- 13 January 2018 — Surcharges on consumer debit and credit cards banned outright by regulation 6A of the Consumer Rights (Payment Surcharges) Regulations 2012, inserted by the Payment Services Regulations 2017.
- 31 December 2020 — After Brexit the geographic test in regulation 6B switches from the European Union to the United Kingdom: the full ban now needs both payment service providers to be in the UK.
- 19 March 2026 — FCA instrument FCA 2025/62 removes the £100.00 and £300.00 contactless thresholds from Article 11 of the SCA Technical Standards and replaces them with a risk-based exemption. Optional for issuers.
- 6 April 2026 — Making Tax Digital for Income Tax begins for sole traders and landlords with qualifying income over £50,000.00 in 2024 to 2025. Digital records and quarterly updates; the first update was due 7 August 2026.
- 7 November 2026 — Second quarterly update deadline of the first MTD year, covering 6 April to 5 October 2026. The 31 January Self Assessment deadline is unchanged.
- 6 April 2027 — The Making Tax Digital for Income Tax threshold drops to £30,000.00 of qualifying income, tested on the 2025 to 2026 tax year. It falls again to £20,000.00 on 6 April 2028.
- 2029 — Mandatory electronic invoicing for all VAT invoices, announced in the Government's consultation response of 26 November 2025 with a roadmap due at Budget 2026. Announced policy, not yet law.
The five questions, answered
| Question | Position in the UK | Named instrument |
|---|---|---|
| Must you accept cards? | No general duty. Exception: licensing conditions, for example every licensed London taxi since 31 October 2016. | No statute; TfL taxi licensing requirement |
| Must you give a receipt? | No general duty. A VAT invoice is required only when a VAT-registered customer buys for their business; simplified invoice up to £250.00. | VAT Regulations 1995, regs 13 and 16 |
| Can you surcharge a card? | Not on a consumer debit or credit card where both payment service providers are in the UK. Any other fee must not exceed your cost. | Consumer Rights (Payment Surcharges) Regulations 2012, regs 6A and 6B |
| How long must records be kept? | Self-employed: fifth anniversary of the 31 January following the tax year. Private company: three years. VAT: six years. | TMA 1970 s12B; Companies Act 2006 s388; VAT Notice 700/21 |
| Must you accept cash? | No. The Government declined to mandate acceptance in its response dated 27 June 2025, published 12 July 2025; legal tender does not oblige a shop to take cash. | Treasury Committee, Acceptance of Cash: Government Response |
Sources
- Consumer Rights (Payment Surcharges) Regulations 2012, regulation 6A
- Consumer Rights (Payment Surcharges) Regulations 2012, regulation 6B (UK geographic test)
- BEIS guidance: Payment Surcharges — guidance on the Consumer Rights (Payment Surcharges) Regulations 2012
- Chartered Trading Standards Institute, Business Companion: payment surcharges
- Value Added Tax Regulations 1995, regulation 13 (obligation to provide a VAT invoice)
- Value Added Tax Regulations 1995, regulation 16 (retailers; simplified invoice up to £250)
- HMRC, Record keeping (VAT Notice 700/21)
- HMRC, Find out if and when you need to use Making Tax Digital for Income Tax
- HMRC, Deadline approaches for first Making Tax Digital quarterly update
- Taxes Management Act 1970, section 12B (duty to keep and preserve records)
- Companies Act 2006, section 388 (where and for how long records are kept)
- HMRC, VAT registration thresholds
- Bank of England, What is legal tender?
- Treasury Committee, Acceptance of Cash: Government Response (27 June 2025)
- FCA, Greater flexibility to be given for setting future contactless limits
- FCA Handbook Notice 136 (instrument FCA 2025/62, in force 19 March 2026)
- FCA PS21/2, Amendments to single and cumulative transaction thresholds for contactless payments
- Transport for London, Accepting card payments (taxi licensing requirement)
- HM Treasury / HMRC, Promoting electronic invoicing across UK businesses and the public sector — consultation response
- HM Treasury, A Streamlined Approach to Payment Systems Regulation — consultation response
- European Union (Payment Services) Regulations 2018 (S.I. No. 6 of 2018), Ireland
- Department of Finance (Ireland), National Payments Strategy
Questions about the rules
Can I add 50p to card payments to cover my fees?
Not on a consumer debit or credit card. Regulation 6A(1) of the Consumer Rights (Payment Surcharges) Regulations 2012 bans it outright, and regulation 10 makes the charge unenforceable and repayable — the customer can simply claim it back. A genuine service or booking fee charged to everyone regardless of how they pay is a different thing and is outside the Regulations. Rebranding a card fee as a "service charge" that only card payers actually pay is not.
Can I set a minimum spend for card payments?
A minimum spend is not a surcharge, so the Payment Surcharges Regulations do not prohibit it, and there is no statute banning it. Your card scheme rules and your acquirer's contract are a different matter — Visa and Mastercard rules generally prohibit minimum transaction amounts, and breaching them is a contractual problem with your provider rather than a legal one. Check your merchant agreement.
Do I have to give every customer a receipt?
No. There is no general legal duty to issue a receipt in the UK. If you are VAT-registered, regulation 13 of the Value Added Tax Regulations 1995 requires a VAT invoice when you supply a taxable person, and regulation 16 lets a retailer issue one only on request from such a customer. Up to £250.00 a simplified VAT invoice is enough.
Does my payment app need to be certified for HMRC?
No. The UK has no certified-till regime — no fiscal memory, no technical security device, no type approval. What is regulated is the record. For VAT and, since 6 April 2026, for Making Tax Digital for Income Tax, your records must be kept in functional compatible software and filed from it. Check that your bookkeeping software is on HMRC's recognised list, not your card app.
Am I allowed to refuse cash?
Yes. Legal tender does not oblige a shop to accept cash, and the Government expressly declined to mandate cash acceptance in its response to the Treasury Committee dated 27 June 2025, published 12 July 2025. It did say a mandate could become necessary in future. The practical limit is the Equality Act 2010: reasonable adjustments may be needed if a card-only policy disadvantages disabled customers.
Are the rules different in Northern Ireland or Ireland?
Northern Ireland follows the same UK surcharge, VAT and Making Tax Digital rules; enforcement sits with the Department for the Economy rather than a local Trading Standards service, and Bank of England notes are not legal tender there. The Republic of Ireland is a separate system — the surcharge ban is in the European Union (Payment Services) Regulations 2018 (S.I. No. 6 of 2018), and Ireland's National Payments Strategy obliges government bodies, not shops, to accept cash.