This joint response draws on academic research, industry evidence and international best practice to show how five, tightly linked reforms can unlock substantial growth for the UK economy:

1. Leveraging the potential of e-invoicing

2. Easier SME access to trade finance - reforming the regulatory framework to

unlock the £22 billion SME working capital (trade finance) gap, providing a UK

trade registry (invoice marketplace)

3. Use of digital trade documents

4. Reducing fraud and tax evasion

5. Digital identities for cross border trade – Legal Entity Identifiers

All 5 reforms support the implementation of recommendations set out in the Roadmap to Digitalise UK Trade1, Plan for Growth2 and UK Trade Registry and Digital Identities for Cross Border Trade – latter two papers attached with submission. These 4 papers support the implementation of the global roadmap to digitalise world trade led by the ICC Digital Standards Initiative3 and World Trade Organization.

Although HMRC/DBT’s e-invoicing consultation and DBT’s call for evidence on SME finance are issued separately, they rely on the same digital infrastructure, standards and governance and support the wider digitalisation of the international trade ecosystem. Treating them together will deliver greater impact at lower cost for the UK.

We underline that digital trade reform is not a ‘nice-to-do’ or administrative exercise - it is central to making trade cheaper, faster and simpler which underpins national economic growth, competitiveness, productivity and supply-chain resilience.

Mandating e-invoicing for public procurement, in a market where fewer than one in five UK invoices is exchanged in structured digital form [1], linking invoices to the Electronic Trade Documents Act, and creating a national invoice registry will reduce VAT fraud and tax evasion, speed payments and generate the verifiable data that lenders need. Coupled with wider regulatory reform, digital legal-entity identifiers, streamlined KYC and the launch of an SME-centred trade-finance platform (piloted through the Teesside Digital Trade Testbed), these measures can help close the £22 billion trade finance gap and widen export participation.

To drive coherence and accountability we recommend the Minister for Exports leverage the Trade Digitalisation Taskforce (co-Chaired with ICC United Kingdom and Barclays) and International Centre for Digital Trade and Innovation (involving DBT, FCDO, DSIT, CO) to lead cross-government delivery. Co-creating the solution with industry and building on successful models from Singapore, India and UAE is essential to delivering a world-class, sustainable solution. Done together, these steps will ensure the UK trade and trade finance system are fit for the 21st century, reduce bureaucracy and border friction and position the UK as a global leader in digital trade.