EU & UK VAT registration guide (2026): which registrations you need, scenario by scenario

Definitions

• IOSS (Import One-Stop Shop): EU scheme for B2C goods of €150 or less that are located outside the EU at the time of sale. VAT is collected at checkout and filed monthly. Non-EU sellers must appoint an IOSS intermediary; EAS acts as intermediary.
• Union OSS: EU scheme for B2C sales shipped from stock located inside the EU to other EU countries.
• Non-Union OSS: EU scheme for digital goods and services sold B2C into the EU by non-EU businesses.
• Deemed supplier: when you sell through a marketplace (Amazon, eBay, Etsy, Apple, Google, Steam), the marketplace is treated as the seller for VAT purposes and collects the VAT itself. This applies only to orders sold through that marketplace, and only within the scope of the low-value schemes (see the marketplace rules below).
• Seller of record: the legal entity that sells to the consumer. Registrations belong to this entity, not to the store or the brand.
• DDP (Delivered Duty Paid): a delivery method for orders above the threshold. Requires a contract with a courier that offers DDP, and adjusting your store to collect the taxes and duties at checkout. The courier invoices you for the taxes, duties and fees; your customer only has to receive the parcel.
• DDU (Delivered Duty Unpaid): the import VAT, duties and courier handling fees are collected from your customer before delivery, usually as an unpleasant surprise.
• Thresholds: €150 per consignment for IOSS in the EU; £135 per consignment for UK VAT at point of sale.

Core rules (IF / THEN)

• IF your company is established inside the EU, THEN EAS cannot handle your EU VAT filing. You register for and file OSS yourself in your own member state. This applies regardless of platform or warehouse location.
• IF you are a non-EU business AND ship physical goods worth €150 or less from outside the EU to EU consumers via your own webshop, THEN you need your own IOSS number with EAS as intermediary. This applies even if you also sell the same goods on a marketplace: the marketplace's IOSS never covers your webshop orders.
• IF you sell to EU consumers only through a marketplace (no own-webshop sales), THEN for consignments of €150 or less the marketplace generally bears the VAT liability and provides you with its IOSS number to use on those shipments, and you do not need your own IOSS registration. Note that not all marketplaces are IOSS registered, so always check with your marketplace for their IOSS information. For shipments over €150/£135, check with your marketplace how those orders are handled; you may need to arrange DDP/DDU shipping yourself.
• IF you sell through a marketplace and your own webshop, THEN you need both: the marketplace's IOSS number for marketplace orders, and your own IOSS registration for webshop orders. Each channel is assessed separately.
• IF an order exceeds €150, THEN IOSS cannot be used for that order and full customs procedures apply. You generally do not need a local VAT registration; ship DDP (recommended) or DDU.
• IF you are a non-EU business with stock in an EU warehouse (own warehouse, 3PL, or FBA), THEN two things apply:
  • Union OSS for B2C sales from that stock to other EU countries. EAS can handle the registration and filing (registration is processed via Estonia and requires your local VAT number first).
  • Local VAT registration and filing in each country where stock is held. EAS can arrange this through its vetted network of trusted tax partners (email support@easproject.com). If the warehouse is in Estonia, EAS can handle the local VAT filing.
• IF all your EU orders are fulfilled from inside the EU, THEN you do not need IOSS at all; Union OSS (plus local VAT) covers those sales. Note: EU companies shipping intra-EU are liable for the VAT even when selling through a marketplace; for non-EU companies selling intra-EU via a marketplace, the liability lies with the marketplace.
• IF you sell digital goods B2C into the EU via your own webshop as a non-EU business, THEN you need Non-Union OSS (EAS handles registration and filing). There is no threshold. IF sold via a digital marketplace, THEN generally no registration is needed for that channel; check with your marketplace.
• IF you are a non-UK business selling goods of £135 or less to UK consumers via your own webshop, THEN you need a UK VAT registration; VAT is charged at checkout and filed to HMRC (EAS files via MTD; you pay HMRC directly). This applies even if you also sell on a marketplace.
• IF you sell via a marketplace into the UK at £135 or less, THEN the marketplace generally collects UK VAT for those orders; check with your marketplace for their UK VAT information. Above £135, check with your marketplace how those orders are handled.

Scenarios customers actually ask about

"I sell on Etsy AND my own website. Etsy collects the VAT. Do I still need IOSS?"

Yes. Selling on a marketplace does not remove the requirement for your own store: Etsy is deemed supplier for Etsy orders only, and orders from your own webshop need your own IOSS number. Use the marketplace's IOSS number only for marketplace orders, never for webshop orders.

"I only sell on Amazon/eBay. Can you get me an IOSS number for that?"

No, and as long as you sell exclusively through the marketplace, you generally don't need one for consignments of €150 or less: the marketplace is the deemed supplier and provides you with its IOSS number for those shipments. An own IOSS registration cannot be used for marketplace shipments. Three caveats: not all marketplaces are IOSS registered, so check with your marketplace for their IOSS information; for orders over €150, check with your marketplace how they are handled, as you may need to arrange DDP (or DDU) shipping yourself; and the moment you open your own webshop, those orders need your own IOSS. See How to become compliant when selling cross-border to EU through marketplace(s)?

"My company is based in the EU. Can EAS file my VAT?"

No. EU-established companies handle their own EU VAT filing through the OSS registration in their home member state. EAS's EU VAT filing services (IOSS intermediary, Union OSS, Non-Union OSS) are for non-EU businesses.

"We're a non-EU company shipping from a warehouse / fulfilment centre inside the EU."

IOSS does not apply (IOSS is only for goods located outside the EU at the time of sale). You need a local VAT registration in each country where stock is held. EAS can help with these registrations and the filing through our vetted network of trusted tax partners; email support@easproject.com to get started. If your warehouse is in Estonia, EAS can handle the local VAT filing. Once you have the local VAT number, EAS can register and file Union OSS (processed via Estonia) for your intra-EU B2C sales. This is the Fully Automated OSS service, priced separately from IOSS.

"My Shopify store is owned by our US company, but we have a UK company with a VAT number. Do we need to collect UK VAT?"

Registrations follow the seller of record. If the US entity is the seller on the store, the UK entity's VAT number cannot be used for those sales. Structures involving multiple related entities should be reviewed individually; contact support@easproject.com and our team will advise.

"My old IOSS number (from a previous provider or a lapsed registration) doesn't work. Can you reinstate it?"

Lapsed or deregistered IOSS numbers cannot be reinstated; a new registration is required. Note that EAS cannot look up the status of a previous IOSS number. The way to confirm it is terminated is to attempt the new registration.

"I'm switching to EAS from another intermediary. How does that work?"

Register with EAS and provide your existing IOSS number together with your current intermediary's details; the tax authorities require this. Notify your current provider to terminate their service. EAS does not deregister your old IOSS number. EAS then issues a new IOSS number under its own intermediation. Coordinate the timing with our team to keep your compliance continuous.

"We already made EU sales before registering. Can you regularise the VAT we owe?"

Possibly, but this is handled case by case and may involve penalties. Contact support@easproject.com.

"Orders over €150 / £135: who pays the duties?"

IOSS covers goods valued under €150 only; orders above that require full customs procedures, meaning import VAT and possibly customs duties are due at import. There are two ways to handle this. With DDU, the import VAT, duties and courier handling fees are collected from your customer before delivery. These costs come as a surprise, resulting in refused parcels, increased returns and lost repeat customers. With DDP, you need a contract with a courier that offers DDP and your store adjusted to collect the taxes and duties at checkout. The courier then invoices you for the taxes, duties and fees, and your customer only has to receive the shipment. DDP costs you more but is the recommended option. See How to handle orders over IOSS threshold 150€?

"Am I even liable? Why do I need this at all?"

Since July 2021 there is no minimum threshold for EU VAT on imported B2C goods; VAT is due from the first sale. Without IOSS, your customer pays import VAT plus courier handling fees on delivery. IOSS is technically optional; the customer experience is why it is effectively mandatory. See IOSS isn't mandatory, but here's why it's "mandatory" for your EU customers and your store.

"How does the money actually flow with IOSS?"

You collect the VAT from your customers at checkout. EAS invoices that VAT from you once a month, pays it to the EU tax authorities, and handles the filing. For where to find your IOSS number and how to give it to your carrier/3PL, see Where to check your registration status and find your IOSS or UK VAT number.

Summary table

Still not sure which registrations you need? Email us or book a meeting with our VAT experts.