Yes, provided the spreadsheet is digitally linked to bridging software rather than read by a human who then types the figures into HMRC. That is the whole test. Your spreadsheet is a perfectly valid digital record — VAT law never required you to buy a particular package — but the nine boxes have to reach HMRC through an API, not a keyboard. Bridging software sits on top of the spreadsheet, reads the cells, and files. In practice we find bridging works well for businesses with genuinely unusual VAT positions where a spreadsheet does something bespoke, and works badly for everyone else, because you keep all the manual data entry and gain none of the automation. It is a compliance fix, not an improvement.