Making Tax Digital ITSA → Software requirements
MTD ITSA Software Requirements — SI 2021/1076 Functional Compatible Software + HMRC-Recognised List
MTD ITSA mandates use of 'functional compatible software' (FCS) defined under the Income Tax (Digital Requirements) Regulations 2021 (SI 2021/1076). FCS must (a) record + preserve digital records of specified data; (b) submit quarterly updates + Final Declaration to HMRC via the API; and (c) receive information from HMRC via the API. There are three broad delivery models: full cloud-SaaS MTD products (FreeAgent, Xero, QuickBooks, Sage Business Cloud, etc — listed for categorical reference, no specific firm endorsement), spreadsheet + bridging software (the spreadsheet keeps digital records; bridging software submits to HMRC), and existing bookkeeping software with an MTD module. HMRC maintains a published list of recognised software at gov.uk. Typical retail-price spectrum: £10-30/month for small-business cloud SaaS; bridging software typically £20-100 one-off or low monthly. Digital record-keeping is mandatory — paper records do not satisfy the regulations.
Last reviewed:
Guidance, not advice. We explain the rules, we don't assess your situation. Always seek financial or tax advice from your accountant, or contact HMRC. Read our editorial scope →
In plain English
Three things your software must do to meet MTD ITSA rules: 1. KEEP DIGITAL RECORDS of your income + expenses by category. The regulations specify the data fields — date, amount, category, supplier/customer (where relevant). The software must preserve these digitally; paper receipts are fine as source documents but the data must be captured digitally. 2. SUBMIT QUARTERLY UPDATES + FINAL DECLARATION to HMRC via the API. The software talks directly to HMRC's systems — you (or your agent) authorise the connection once, then submissions happen from inside the software. 3. RECEIVE DATA FROM HMRC via the API — confirmations of submissions, calculations, notifications. Two-way digital communication is the core of MTD. Three ways to satisfy this: A. FULL CLOUD MTD SAAS (FreeAgent / Xero / QuickBooks / Sage Business Cloud / etc — categorical reference only; check the HMRC-recognised list for current eligible products). You enter transactions directly into the software (or import from bank feeds), it categorises, and it submits. Typical cost £10-30/month for a sole trader; £30-80/month if you have multiple businesses or properties. Best for taxpayers who do not already maintain detailed bookkeeping. B. SPREADSHEET + BRIDGING SOFTWARE. You continue using Excel / Google Sheets / etc as your digital record. Bridging software pulls the totals from the spreadsheet and submits them to HMRC. Bridging software typically £20-100/year. Suits taxpayers + accountants already organised on spreadsheets. CRITICAL: the chain from raw data → submission must be DIGITAL throughout — no manual re-typing into a submission interface, no copy-paste between disconnected files. 'Digital links' must connect every stage. C. EXISTING BOOKKEEPING SOFTWARE WITH MTD MODULE. If you already use a UK bookkeeping product, check whether it has added an MTD module (most have or are in the process). May be a free upgrade or a paid add-on. What HMRC's recognised list does NOT do: endorse one product over another. It only confirms the product technically meets the regulations. Pricing, ease of use, support quality, accounting feature depth — all up to you to evaluate. There is no 'official HMRC software' — HMRC provides only basic free tools for very small below-threshold voluntary participants. Anti-charlatan note: 'MTD software setup specialist £500' typically performs work the software vendor's own free onboarding wizard handles. Bank-feed connection is the longest step + the bank does that, not the specialist. If your business is complex enough to need genuine setup help, your existing accountant at their standard hourly rate is the right route — not a £500 fixed-fee 'specialist'.
How it works
Functional compatible software — the legal definition
SI 2021/1076 reg 3: software (or set of software programs) that can (a) record + preserve digital records of specified data; (b) provide HMRC with information + returns from the digital records via the API; (c) receive information from HMRC via the API. The word 'set' matters — you can combine multiple products (e.g. spreadsheet + bridging) provided the chain has DIGITAL LINKS throughout. A single piece of paper that is re-typed into the next stage breaks the digital chain.
Digital links + the soft-landing period
All data flow from raw entry → quarterly submission must be DIGITAL. Examples of acceptable digital links: bank-feed import; CSV upload; API connection between two software products; cell-reference formulas linking spreadsheet tabs. Examples that BREAK the digital chain: manual re-typing; cut-and-paste between unconnected files; printing then re-entering. HMRC has historically operated soft-landing periods in MTD VAT — comparable approach expected for MTD ITSA initial phases.
Three software pathways
(1) Full cloud MTD SaaS: bookkeeping + MTD submission integrated in one product. Examples include FreeAgent, Xero, QuickBooks, Sage Business Cloud (categorical reference — check HMRC-recognised list for current eligibility, not an endorsement). (2) Spreadsheet + bridging: you keep records in Excel / Google Sheets; bridging software pulls totals + submits. Bridging providers include 123 Sheets, Tax Calc, Absolute Accounting Software (categorical reference). (3) Existing bookkeeping software with an added MTD module — depends on vendor.
Categories of qualifying products (with no endorsement)
Full SaaS — FreeAgent (NatWest Group; free for NatWest/RBS business customers), Xero (NZ-listed), QuickBooks Online (Intuit), Sage Business Cloud (UK-listed), Crunch, Pandle, Coconut. Specialised property: Hammock, Landlord Vision, Arthur. Payroll-led: BrightPay, Moneysoft, IRIS — relevant where MTD overlaps with employer PAYE filings. Always check the HMRC-recognised list before committing — this is a fast-moving market with frequent additions.
Cost spectrum + decision framework
Single sole trader, single property, simple bank feed: £10-15/month full SaaS, or £20-50/year bridging if you prefer spreadsheets. Multi-property landlord (5+ properties): £20-40/month SaaS. Sole trader + landlord combined: typically same SaaS handles both income types. Multi-business sole trader (multiple SE activities): £30-80/month. Decision drivers: existing accountant's preferred stack; whether bank feed is critical (saves hours); language + interface preference; price.
Authorisation + agent access
MTD ITSA uses OAuth authorisation — you log in via Government Gateway + grant your chosen software (and optionally your accountant as 'agent') ongoing API access to file on your behalf. Authorisation is granted once + can be revoked from your Personal Tax Account at any time. Agents file under their own ASA (Agent Services Account) authorisation chain — separate from old SA agent authority.
Who this applies to + key conditions
- Any MTD-mandated taxpayer must use functional compatible software from commencement
- Voluntary pilot participants (below threshold) can also use any HMRC-recognised software
- Spreadsheet users must add bridging software with digital links — pure spreadsheet alone is not compliant
- Paper records may be retained as source documents but do not satisfy the digital record-keeping rule
- Existing bookkeeping software users should confirm with their vendor that an MTD module is available + activated
- Agents must establish an ASA (Agent Services Account) to file on behalf of taxpayers under MTD
Statute + manual references
Primary: SI 2021/1076 — Income Tax (Digital Requirements) Regulations 2021. Defines functional compatible software (reg 3), digital record-keeping (reg 5), quarterly update content (regs 8-10), and Final Declaration mechanics.
Related: Finance (No.2) Act 2017 ss.60-62 — enabling MTD framework; SI 2024/167 — Phase 1 commencement order; Income Tax Acts (ITA / ITTOIA / ITEPA / TCGA) — underlying income tax framework
HMRC manual: MTD ITSA collection at gov.uk/government/collections/making-tax-digital-for-income-tax; HMRC-recognised software list at gov.uk/guidance/find-software-thats-compatible-with-making-tax-digital-for-income-tax
Common mistakes + traps
- Believing that any spreadsheet alone satisfies MTD — you need bridging software with digital links
- Paying a 'MTD software setup specialist £500' for work the vendor's free onboarding wizard handles
- Choosing software based on price alone without checking the HMRC-recognised list
- Not establishing bank feeds — the single biggest time-saver in MTD bookkeeping
- Manually re-typing data between disconnected files — breaks the digital chain
- Forgetting to authorise the agent in the new ASA framework — old SA64-8 agent authority does not carry across
- Picking a property-specialist product when you also have substantial sole-trade income (or vice versa) — most general SaaS handles both
Worked example
Sam, Phase 1-caught sole-trader plumber (£35,000 turnover) + single rental property (£20,000 gross rent)
Sam was identified by HMRC as Phase 1-mandated for MTD ITSA from 6 April 2026 (combined gross £55,000). He has historically used a spreadsheet + his accountant prepares his SA return annually. He needs to decide on software before April 2026 + understand cost vs his current workflow.
- Step 1 — List Sam's actual needs. Single sole trade (plumbing). Single rental property. Bank feed from one business account. Mileage tracking (for AMAP). Existing accountant for Final Declaration. No payroll. No VAT registration.
- Step 2 — Compare three options. (A) Full SaaS — FreeAgent (free with NatWest business banking; otherwise £10-15/month), Xero (£15-32/month depending on tier), QuickBooks Self-Employed (£15-30/month). (B) Spreadsheet + bridging — keep current spreadsheet workflow + add bridging software £30-50/year. (C) Existing bookkeeping software (if any) — Sam has none.
- Step 3 — Decision factors. Sam values minimising change. His accountant is comfortable with FreeAgent + Xero. Bank-feed automation would save him 2-3 hours per quarter. Annualised cost difference between SaaS (£120-180/year) and bridging (£30-50/year) is ~£100/year — but the SaaS automation saves him ~8 hours per year of data entry.
- Step 4 — Recommendation: full SaaS with bank-feed. If Sam banks with NatWest / RBS, FreeAgent is free. Otherwise FreeAgent or Xero starter tier ~£15/month is appropriate.
- Step 5 — Setup pathway. Use vendor's free onboarding wizard (typically 2-4 hours self-serve). Connect bank feed. Enter opening balances. Add property as separate income source. Add accountant as authorised agent under ASA framework. Do a dry-run quarterly update during the voluntary pilot period if possible.
- Step 6 — Anti-charlatan note. A 'MTD setup specialist £500' is not needed for this fact pattern. If Sam wants paid help, his existing accountant at their normal hourly rate (1-2 hours of setup support typically £100-200) is the right route — not a specialist markup.
Outcome: FreeAgent or Xero starter tier ~£15/month with bank feed. Self-serve setup using vendor's free wizard + existing accountant's standard support if needed. No specialist retainer warranted.
How this connects to the rest of the framework
Software is the submission vehicle for Q1-Q4 quarterly updates — choose software that automates as much as possible.
Final Declaration also submitted via the same software (post-EOPS-removal pathway).
Software adoption is part of the transition pathway — start in pilot if possible, before April 2026.
Digital exclusion exemption is the route for those genuinely unable to use any software — narrow grounds.
Non-MTD income (employment / dividends / etc.) continues to be reported via Final Declaration — software must handle both.
Frequently asked questions
What happens if I miss the Self Assessment deadline?+
Do I need an accountant or can I file Self Assessment myself?+
How do payments on account work?+
Is there free HMRC software for MTD ITSA?+
Can I use one piece of software for SE + property income?+
What happens if my chosen software is removed from the HMRC list mid-year?+
Can I share access with my accountant?+
Free + regulated-body resources
- HMRC-recognised software list →
Maintained list of recognised MTD ITSA software
- SI 2021/1076 — full regulations text →
Statutory definition of functional compatible software + digital records
- Agent Services Account (ASA) sign-up →
For accountants supporting MTD ITSA clients
- MoneyHelper — free + impartial guidance →
Government-backed free guidance on tax + financial matters
- LITRG — free MTD ITSA guidance →
Low Incomes Tax Reform Group — free guidance for low-income taxpayers
Last reviewed: