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HMRC's guidance on invoices in currencies other than GBP, found at https://www.gov.uk/guidance/foreign-currency-transactions-vat-and-tour-operators lists specific requirements that need to be met when creating an invoice in a currency other than GBP, namely:
1. "the total net value of goods and services at each VAT rate" needs to be shown in GBP (as well as in the foreign currency)"
2. "the amount of VAT, if any, at each rate" needs to be shown in GBP (as well as in the foreign currency)"
3. the currency conversion for VAT purposes needs to be calculated in one of the following two ways:
- "UK market selling rate at the time of the supply. The rates published in national newspapers are acceptable."
- "Exchange rates published by HM Revenue and Customs (HMRC). This is known as the ‘period rate of exchange’. The advantage of this method is that you can use the same rate for an entire period, usually a calendar month, but you should check to see if there have been any adjustments within the period."

While requirement 2. appears to be currently met when creating invoices in Xero, as it stands requirements 1. and 3. aren't, because:
- "the total net value of goods and services at each VAT rate" in GBP is not shown when generating invoices in foreign currencies
- The rate conversion in the VAT value is calculated from rates coming from XE, which is not one of the HMRC-approved standard methods of currency conversion, as detailed above.

As generating invoices and being compliant with HMRC's requirements is a core functionality of Xero, it feels like making invoices in foreign currencies generated by Xero compliant with HMRC's guidance should be a top priority for the product.