What is a VAT pre-registration verification check?

Before issuing a VAT number, HMRC sometimes wants proof you're a real business intending to make taxable supplies, rather than simply taking your application at face value.

This is more likely for brand new companies with no trading history, applications for voluntary registration where turnover is still below the threshold, or sectors HMRC associates with a higher risk of VAT fraud.

The check itself usually involves a letter asking for supporting evidence: a contract with a customer, sample invoices, proof of a trading bank account, or a business website showing genuine activity.

Schedule 1 VATA 1994 sets the conditions for registration, requiring HMRC to be satisfied you are making or intend to make taxable supplies as part of a genuine business.

Schedule 36 Finance Act 2008 gives HMRC the power to request the information it needs to verify this before completing the registration, rather than registering first and checking later.

There's no fixed statutory deadline for how long a pre-registration check should take, though HMRC's guidance sets indicative service standards for straightforward applications that pass verification without issue.

Without a confirmed VAT number, you can't issue valid VAT invoices, which can be a real problem if customers expect one before paying, or if contracts specify VAT-registered suppliers only.

You can still trade and invoice while waiting, but any VAT charged before your number is confirmed needs correcting once registration comes through, which can mean reissuing invoices.

Being ready with strong evidence at the point of application, rather than waiting for HMRC to ask, is the single most effective way to avoid a lengthy verification delay.

The direct cost is the delay itself: contracts stalled, invoices that can't show VAT correctly, and cash flow disruption while the number is pending.

There's no penalty for the check itself, but if it uncovers the application wasn't genuine, HMRC can refuse registration, and previously charged VAT can create separate correction problems.

Growth plan clients get free tax investigation insurance included, covering professional support if a verification check escalates into a formal refusal or dispute. See /fees for comparisons.

Don't submit a bare application for a brand-new company with no supporting evidence attached; it's one of the most common reasons for a verification check to start at all.

Don't charge VAT on invoices before your registration is confirmed. Wait for the number, or clearly mark invoices as VAT to follow if a customer needs to see one immediately.

Don't ignore HMRC's evidence request hoping the application processes anyway; it won't move forward until the officer is satisfied.

Provide strong evidence upfront: a signed contract, a business bank account already open, and any website or marketing material showing the business is trading or about to trade.

Respond to HMRC's request in full the first time. Partial responses tend to generate follow-up questions that add further delay to the timeline.

If the check runs well beyond HMRC's indicative service standard, chase for an update and, if necessary, use the complaints process to push for a decision.