The digital links rule
The digital links rule means data must move between your records and HMRC through an unbroken electronic chain. HMRC accepts linked spreadsheet cells, CSV import and export, API transfer, and emailing a spreadsheet for import into another product. HMRC does not accept manual retyping, copy and paste, or printing and re-keying. VAT Notice 700/22 sets out the principles that apply to MTD record-keeping.
- 1Source records
- 2Digital record system
- 3Linked spreadsheet or CSV
- 4Bridging software
- 5HMRC via API
Check your route
Tap a step to see whether HMRC treats it as a digital link.
What this means in practice
Once a figure is in your digital records, any later transfer, recapture, or change to that figure must stay digital if it remains part of your electronic account. HMRC describes this as each piece of software being digitally linked to the next, so the data follows a clear digital journey. For bridging software, the crucial point is that the submission to HMRC must be through an API.
In plain English
Think of it like a sealed chain of custody for numbers. If a figure leaves one system and enters another, the handover must be electronic, not manual. If someone has to read, type, copy, or re-key the figure, the chain is broken.
Allowed vs not allowed
| HMRC accepts | HMRC does not accept |
|---|---|
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How bridging software fits
Bridging software is a digital tool that uses the relevant MTD APIs to connect your records to HMRC. It is not manual filing with a digital wrapper — it is a digital reporting chain, and the links in that chain matter.
- Data can come from spreadsheets, ledgers, or accounting software.
- The transfer into the submission file must stay digital.
- The final submission to HMRC must happen by API.
Worked examples
Compliant: CSV into bridging software
A bookkeeper exports totals from accounting software into a CSV, imports that file into a linked spreadsheet, then files through bridging software by API. The data moves electronically through the chain.
Compliant: formula-linked workbook
Source data sits on one tab; formula-linked cells populate the return tab; bridging software submits by API. The spreadsheet cells are digitally linked and the submission is digital.
Not compliant: printout and re-keying
A business prints a spreadsheet, marks changes on paper, then types totals into return software. Manual re-keying breaks the digital link.
Penalty risk
HMRC can apply penalties manually where digital records are not kept correctly or digital links are broken — up to £3,000 per failure for record-keeping or broken links, and daily penalties of £5 to £15 in some cases under the compliance factsheet. These are not automatic system fines; HMRC assesses them in a compliance check. Read the MTD penalties factsheet.
Important nuance
The rule applies to records that form part of the electronic account. Not every file or note in the wider business needs a digital link forever. HMRC also says that records not used to maintain the electronic account do not need a digital link when transferred into it. The rule is narrower and more useful than “every document must be digitally linked”.
FAQ
Is emailing a spreadsheet allowed?
Yes. HMRC accepts emailing a spreadsheet containing digital records so it can be imported into another product, provided the import stays electronic.
Is copy and paste allowed if I use a computer?
No. HMRC specifically says copy and paste is not a digital link.
Do I need one single system?
No. The electronic account can be maintained across more than one piece of software, as long as the products are digitally linked.
Does the final submission have to be API-based?
Yes. HMRC says submission of information to HMRC must always be through an API.
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