Compliance
Single VAT Registration & Special Scheme Reform: What VAT-Registered Sellers Need to Know
New EU rules under ViDA introduce a Single VAT Registration scheme and harmonised special scheme obligations—here’s how VAT-registered sellers, platforms and marketplaces should prepare by 2027-2028.
By NomadicTax Research Team • 5-8 min read • August 25, 2026
## Introduction
The European Commission adopted **Implementing Regulation (EU) 2026/1869** on 27 July 2026, amending Regulation 2020/194 to harmonize and expand special VAT schemes under the Single VAT Registration (SVR) pillar of ViDA. ([vat-one-stop-shop.ec.europa.eu](https://vat-one-stop-shop.ec.europa.eu/commission-implementing-regulation-eu-20261869-2026-07-28_en?utm_source=openai)) This affects electronic sellers of goods and service providers using marketplace or special VAT schemes across the EU.
## What’s New & When It Takes Effect
- **Transfer of Own Goods (TOG) scheme** introduced: suppliers moving goods among their own warehouses in different Member States will face new registration and reporting rules. ([vat-one-stop-shop.ec.europa.eu](https://vat-one-stop-shop.ec.europa.eu/commission-implementing-regulation-eu-20261869-2026-07-28_en?utm_source=openai))
- **Harmonised electronic reporting** across all special VAT schemes—platforms, OSS, IOSS—bringing consistent data fields and submission formats. ([vat-one-stop-shop.ec.europa.eu](https://vat-one-stop-shop.ec.europa.eu/commission-implementing-regulation-eu-20261869-2026-07-28_en?utm_source=openai))
- Effective from **1 January 2027**: adjustments to VAT registration data.
- Effective from **1 July 2028**: main rules around schemes and reporting obligations. Full implementation by that date. ([vat-one-stop-shop.ec.europa.eu](https://vat-one-stop-shop.ec.europa.eu/commission-implementing-regulation-eu-20261869-2026-07-28_en?utm_source=openai))
## Who’s Most Affected
- **Digital marketplaces**: intermediaries facilitating sales must ensure their sellers’ transactions are fully compliant under the harmonised reporting rules.
- **Cross-border sellers** using VAT special schemes (IOSS, OSS): need to adjust VAT registrations and understand the TOG scheme implications.
- **Logistics & warehousing entities** moving stock between EU countries under same ownership will now trigger special VAT treatment.
## Real-World Example
Imagine a small EU e-commerce business registered under OSS in Germany selling in France. Under new rules:
- It must ensure electronic sales through marketplace or its own platform are reported uniformly in Germany and France.
- If it holds inventory in France under its own name and moves goods from Germany, the TOG scheme may require VAT registration or reporting under French rules.
## Compliance Checklist
- Map out all warehouse and stock locations within the EU and current intra-group transfers; determine if TOG registration is needed.
- Update customer onboarding/social-seller checks through marketplaces to align with new reporting fields.
- Liaise with VAT advisors to adjust systems for harmonised reporting (e-invoicing, data fields, receipt formats).
- Review tech stack/ERP systems before 2027 to ensure full compliance by 2028 transition date.
## Why It Matters
These changes mark another step toward the EU’s goal of reducing cross-border VAT fraud, simplifying intra-EU trade, and improving digital value chain transparency. For businesses that sell via platforms or spread stock across borders, it can reduce surprises and mismatches in VAT liability and operations.
Underestimating or delaying compliance could lead to penalties, errors in VAT reclaim, or withheld business by platforms insisting on clean data.