What Is the EU's ViDA VAT Reform? From 2028, Fewer VAT Registrations Across Member States — What Cross-Border Sellers Need to Know Now

The Three Pillars of ViDA

ViDA is built on three pillars.

1. Digital reporting and e-invoicing: e-invoicing becomes mandatory for intra-EU B2B transactions, and transaction data is reported to tax authorities in near real time.
2. The platform economy: platforms facilitating short-term accommodation rental (up to 30 nights) and passenger transport by road become “deemed suppliers”, responsible in certain cases for collecting and remitting VAT. Holiday rentals and ride-sharing are the first sectors covered.
3. Single VAT Registration: through three mechanisms — an extended OSS (One Stop Shop), a broader mandatory B2B reverse charge, and a new scheme for transfers of own goods (TOOG) — it reduces the situations in which a business must register for VAT in other Member States.

For cross-border e-commerce sellers, the third pillar, Single VAT Registration, will have the greatest impact.

Implementation Timeline

ViDA was formally adopted by the Council of the EU on 11 March 2025 as Council Directive (EU) 2025/516 and takes effect in the following stages.

1. 1 July 2028: Single VAT Registration begins. The scope of the OSS is extended, and the mandatory B2B reverse charge and the transfer of own goods (TOOG) scheme also start. No new call-off stock arrangements* can be entered into from this date, and the simplification will be fully abolished on 1 July 2029. At this stage, applying the “deemed supplier” rule for short-term accommodation and passenger transport platforms is optional for Member States.
2. 1 January 2030: the platform “deemed supplier” rule becomes mandatory in all Member States.
3. 1 July 2030: e-invoicing and digital reporting become mandatory for intra-EU B2B transactions.

It may seem a long way off, but Member States are already preparing. It is wise to start thinking now about which country to register in and whether your accounting systems are ready.

*A call-off stock arrangement is a simplification that applies when goods are sent in advance to a warehouse in another Member State for a specific B2B customer.

How Things Work Today: the OSS and the Marketplace “Deemed Supplier” Rules

ViDA builds on the EU e-commerce VAT reform that took effect on 1 July 2021. Let’s start with two key features of the current system.

OSS (One Stop Shop): when a business sells goods to consumers in other Member States, it can file a single OSS return in its country of registration and pay the VAT due to each country in one go. There is no need to obtain a VAT number in each country of sale.

Marketplace “deemed supplier” rules: marketplaces such as Amazon become “deemed suppliers” that pay VAT on the seller’s behalf in two cases:

• sales to consumers of imported goods shipped from outside the EU in consignments of up to €150;
• sales to consumers by non-EU sellers from stock already in the EU (regardless of value).

In these cases the transaction takes the form “seller → Amazon (B2B) → consumer (B2C)”, and Amazon pays the VAT in the country of sale. The seller, meanwhile, must register for VAT in the country where its stock is held (for example, Italy) and report its sales to Amazon in its VAT return as VAT-exempt B2B supplies.

The challenge is that holding stock in several countries — as Pan-European FBA does by design — tends to require VAT registration and returns in each of them. Under ViDA, the scope of the OSS will widen and cross-border movements of a seller’s own stock, among other transactions, can be reported centrally in the country of registration, so the number of registrations needed is expected to fall.

What Changes with Single VAT Registration

Today, holding stock in several EU countries or making B2B sales to businesses in other Member States can require VAT registration and returns in each of those countries. Depending on the country, non-EU businesses may also have to appoint a fiscal representative. Repeating these procedures country by country has been a major cost of cross-border selling.

ViDA’s Single VAT Registration aims to reduce such local registrations through the three mechanisms below. It does not, however, create a single VAT number valid throughout the EU.

• Extension of the OSS: some sales to consumers in other Member States that cannot currently be declared through the OSS will be reportable centrally in the country of registration.
• Mandatory B2B reverse charge: when a business with neither an establishment nor a VAT registration in a country sells to a business registered for VAT there, the reverse charge — under which the buyer declares and pays the VAT — becomes mandatory in all Member States. The seller no longer needs a local VAT registration solely for that transaction.
• Transfer of own goods (TOOG) scheme: a new scheme allowing businesses to report, through the OSS, the movement of their own stock to a warehouse in another Member State before it is sold. This reduces local registrations triggered solely by stock movements. As a result, the existing call-off stock simplification will be abolished.

Take B2C sales as an example. Suppose that in one quarter you sell €10,000 to consumers within the EU — €3,000 in France, €2,000 in Germany, €3,000 in Italy and so on. Under the OSS, you enter the country-by-country breakdown in a single return and pay the VAT, calculated at each country’s rate, in one payment. There is no need to file a separate return in each country.

On the other hand, transactions outside these schemes, or a permanent establishment in another country, will still require local VAT registration. Non-EU businesses may also need to appoint a fiscal representative, depending on the country of registration. Because registration in the country where stock is held may still be required in some cases, an individual review by a professional is essential to determine which schemes apply to your transactions.

What Sellers Should Do Now

After ViDA, choosing where to register for VAT becomes less about “selling in that country” and more about “choosing a base for selling across the EU”. To prepare, we recommend three steps:

1. Map out where in the EU you sell, where your stock is held and where you are currently registered for VAT.
2. Compare candidate countries of registration for your base on speed of processing and the support available. Italy, with mandatory e-invoicing in place for years, is already close to the model ViDA is moving towards.
3. Check whether your accounting and invoicing systems can handle the e-invoicing requirements ahead.

Last year, Servix International supported around 20,000 non-EU sellers with Italian VAT and VIES registration. Italian VAT registration takes 4–6 weeks, and there is no need to set up a company in the EU: VAT registration alone lets you start selling. The steps are set out in our guide to Italian VAT and VIES registration, and the VIES side in VIES for non-EU companies. Our team speaks English, Hindi, Chinese, Spanish, French and Japanese.

For advice on EU VAT registration with ViDA in mind, please feel free to contact Servix International.

Sources: European Commission, DG Taxation and Customs Union, “VAT in the Digital Age (ViDA)” · Council Directive (EU) 2025/516, Official Journal of the EU (EUR-Lex).