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What UK restaurants on Deliveroo, Uber Eats, and Just Eat need to know about HMRC's Digital Platform Reporting Rules — and how to protect yourself.
1. What Changed in January 2024
On 1 January 2024, the UK implemented the Digital Platform Reporting Rules (based on the OECD's Model Rules for Reporting by Platform Operators). These rules require digital platforms — including Deliveroo, Uber Eats, and Just Eat — to report seller income data directly to HMRC.
Key point: HMRC now receives order-level revenue data from every delivery platform. They know exactly how much you earned — and can compare it against what you declared on your tax return.
Previously, HMRC had to issue formal information requests to platforms (a slow, case-by-case process). Now, platforms report automatically, covering every active seller.
What platforms now report to HMRC:
- Your business name, trading name, and registered address
- Your VAT registration number (if registered)
- Total consideration (gross revenue) paid to you, broken down by quarter
- Number of transactions in each reporting period
- Any fees, commissions, or taxes withheld by the platform
- Your bank account details (for matching against deposits)
2. The Scale of Enforcement
4,000+
Restaurants flagged for
income discrepancies
(HMRC 2024-25)
30%
Of flagged cases resulted
in penalties or
tax adjustments
up to 100%
Penalty rate for
deliberate
underreporting
HMRC's compliance activity specifically targeting delivery platform sellers has increased since the reporting rules came into force. The most common issues found:
| Issue |
What Goes Wrong |
Typical Penalty |
| Gross vs net recording |
Recording net payouts as income instead of gross order values |
15-30% of underpaid tax |
| Missing platform income |
One or more platforms not included in accounts |
30-70% of underpaid tax |
| VAT on commissions |
Overclaiming input VAT on commission (partial exemption issue) |
Repayment + interest |
| Refund clawbacks |
Not tracking refunds deducted by platforms |
Overstated expenses |
| Cash sales gap |
In-store/walk-in sales not matching when platform income is accurate |
30-100% of underpaid tax |
The net vs gross trap: Deliveroo pays you a net amount (order value minus commission minus VAT on commission). If you record this net deposit as your income, you underreport revenue by 25-35%. HMRC has the gross figure — and will notice the difference.
3. Self-Audit Checklist
Use this checklist to assess your current compliance. Tick each item you can confirm — any unticked items are gaps that need addressing.
- Gross revenue recording: I record the full order value as income (not just the net payout from the platform).
- Commission as expense: Platform commissions are recorded as a separate expense, not netted off income.
- All platforms included: Every delivery platform I use (Deliveroo, Uber Eats, Just Eat) appears in my accounts.
- Weekly reconciliation: I reconcile platform payouts against order-level data at least weekly.
- VAT on commission: I have confirmed the correct VAT treatment of commissions with my accountant (partial exemption if I sell zero-rated food).
- Refund tracking: I track platform-initiated refunds separately and can identify disputed refunds.
- Bank deposit matching: I can match every platform deposit in my bank account to the corresponding platform payout report.
- Tax return consistency: The income figures on my tax return match (or reconcile to) the gross revenue that platforms report to HMRC.
- Record retention: I keep platform reports, payout summaries, and reconciliation records for at least 6 years.
- Accountant briefed: My accountant understands how delivery platform commissions work and has seen my platform reports.
4. The Penalty Framework
HMRC penalties for inaccurate returns depend on the level of culpability:
| Category |
Description |
Penalty Range |
| Careless |
Failed to take reasonable care (e.g. didn't check net vs gross) |
0-30% of underpaid tax |
| Deliberate |
Knew the return was wrong but submitted it anyway |
20-70% of underpaid tax |
| Deliberate + concealment |
Knew and took steps to hide the inaccuracy |
30-100% of underpaid tax |
Unprompted disclosure reduces penalties: If you identify and correct an error before HMRC contacts you, penalties are reduced significantly (often to 0% for careless errors). The self-audit checklist above helps you find and fix issues proactively.
5. What to Do Next
- Complete the self-audit checklist above. Any unticked items are compliance gaps.
- Download your platform reports. Get the latest quarterly reports from Deliveroo Partner Hub, Uber Eats Manager, and Just Eat Partner Centre.
- Reconcile against your accounts. Compare platform-reported gross revenue against what appears in your bookkeeping software (Xero, QuickBooks, or Sage).
- Brief your accountant. Share your platform reports and ask them to confirm: (a) gross revenue is correctly recorded, (b) commission VAT treatment is correct, (c) figures will match what HMRC receives.
- If you find errors: Consider a voluntary disclosure to HMRC before they contact you. This significantly reduces penalties. Your accountant can help with the process.
- Set up ongoing reconciliation. This is not a one-time exercise — reconcile weekly or at minimum monthly.
Stop reconciling manually
This guide helps you understand what HMRC expects. PayoutLedger automates the entire reconciliation workflow — upload platform CSVs, get VAT-correct journals, push to Xero. Join the waitlist at payoutledger.co.uk
Disclaimer: This guide provides general information about HMRC's Digital Platform Reporting Rules and is not financial, tax, or legal advice. The penalty figures and enforcement statistics cited are based on publicly available HMRC publications and GOV.UK guidance. Your specific circumstances may differ. Always consult a qualified accountant or tax adviser for advice on your individual situation. PayoutLedger is a product of Crocker Digital Ltd.