How SaaS companies outside the EU register for VAT OSS in 2026

A step-by-step guide to EU VAT OSS registration for non-EU SaaS companies, including eligibility, deadlines, quarterly filings, VAT rates, and records.

BY SANDRO ZWEIG

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The EU VAT One-Stop Shop (OSS) lets a SaaS business register in one EU member state, file one quarterly return and make one payment covering VAT on consumer sales in all 27 member states. EU-established sellers must charge destination-country VAT once cross-border B2C sales pass €10,000 a year and can report it through the Union scheme. Sellers with no EU establishment owe VAT from the first consumer sale and use the Non-Union scheme.

You sell a SaaS product. A customer in Germany subscribes, then one in France, then one in Portugal. Each country sets its own VAT rate and has its own tax authority. Without a simplification scheme, selling to consumers across the EU means a separate VAT registration and filing calendar in every member state where you have customers.

OSS replaces that with a single registration. You file one return each quarter, pay one amount, and the tax authorities distribute it between themselves.

This guide covers registration, filing and record-keeping in 2026 for sellers based inside and outside the EU.

What is the EU VAT OSS scheme?

The One-Stop Shop is an EU VAT simplification scheme that took effect on 1 July 2021. It replaced the Mini One-Stop Shop (MOSS), which had covered telecommunications, broadcasting and electronically supplied services since 2015, and extended it to all cross-border B2C services and to intra-EU distance sales of goods. A business registers in one member state, called the member state of identification, and declares the VAT due in every other member state through a single quarterly return.

Using OSS is optional. The alternative is a local VAT registration in each member state where you have consumers.

For a SaaS or digital product business, the supplies that go through OSS are electronically supplied services sold to consumers: SaaS subscriptions and cloud software access, software licences and API access, digital downloads and pre-recorded online courses.

OSS does not cover B2B sales, where the business customer accounts for VAT under the reverse-charge mechanism. Low-value goods imported from outside the EU go through a separate import scheme (IOSS).

Who needs to register?

EU-based SaaS companies

If your business is established in one EU member state and your cross-border B2C sales of digital services and distance-sold goods to other member states exceed €10,000 (excluding VAT) in the current or preceding calendar year, you must charge VAT at the rate of each customer's country. The Union scheme lets you report all of it through a single registration in your home member state.

Below €10,000, you can charge your home country rate and report the sales in your domestic return. The threshold only applies to businesses established in a single member state.

Non-EU SaaS companies

The threshold does not apply to you. If your business has no establishment in the EU and you sell digital services to EU consumers, VAT is due from the first sale. There is no minimum revenue exemption.

You use the Non-Union scheme. You register in any one EU member state of your choice, and that authority becomes your single point of contact for EU VAT on consumer sales.

Union OSS vs Non-Union OSS: which applies to you?


Union OSS

Non-Union OSS

Who it is for

Businesses established in the EU, including non-EU companies with an EU fixed establishment

Businesses with no business or fixed establishment in the EU

Where to register

Member state of establishment

Any one EU member state

Revenue threshold

€10,000 cross-border B2C, for businesses established in one member state

No threshold

Covers

Cross-border B2C services and intra-EU distance sales of goods

All B2C services supplied to EU consumers, SaaS included

Filing frequency

Quarterly

Quarterly

For SaaS founders based in the US, UK, Canada or elsewhere outside the EU, with no EU establishment, the Non-Union scheme is the relevant one.

Step-by-step: how to register for Non-Union OSS

Step 1: Choose your member state of identification

You can register in any EU member state, and you can only hold one Non-Union registration at a time. You need no physical presence there. Ireland is a frequent choice for English-speaking founders because Revenue publishes its guidance and runs its registration portal in English.

Step 2: Gather the documents you need

Have your legal business name and registered address ready, along with your country of establishment, your home country tax identification number, your website address, a description of the services you supply, and the date you made or expect to make your first taxable supply to an EU consumer. If you already hold any EU VAT registrations, list those too.

Step 3: Submit your registration

Registration is electronic and goes to the tax authority of your chosen member state. In Ireland, new non-EU applicants use Revenue's non-Union OSS registration portal. Revenue Online Service (ROS) is only the route for suppliers already registered for another OSS scheme in Ireland. In the Netherlands, you register with the Belastingdienst.

Once approved, you receive an individual VAT identification number in the format EUxxxyyyyyz. It can only be used for supplies declared under the Non-Union scheme.

Step 4: Get the start date right

By default, your registration takes effect on the first day of the calendar quarter after you apply.

If you make your first EU consumer sale before that date, the scheme can apply from the date of that first sale, provided you notify your member state of identification by the tenth day of the following month. A first sale on 12 August means notifying by 10 September. Miss that deadline and you must register and account for VAT directly in each member state where those customers are located.

VAT rates and how to apply them

Once registered, you charge VAT at the rate of each customer's country, whatever your member state of identification. Standard rates in 2026 run from 17% in Luxembourg to 27% in Hungary. Most member states sit between 20% and 25%, and Finland is at 25.5%. The European Commission publishes current rates in its Taxes in Europe Database.

You determine the customer's location using two items of non-contradictory evidence, such as billing address, IP address, bank details or the country code of the SIM card used. For most SaaS businesses, billing address and IP address are enough.

Your payment processor or billing platform should supply this data automatically. If it does not, fix that before you start filing.

Quarterly filing: deadlines and what to report

OSS returns are quarterly, and both the return and the payment are due by the last day of the month after the quarter ends. The deadline does not move if it falls on a weekend or public holiday.

Quarter

Period

Filing and payment deadline

Q1

January to March

30 April

Q2

April to June

31 July

Q3

July to September

31 October

Q4

October to December

31 January

For each member state where you had consumers, the return states the taxable amount and the VAT due, split by standard and reduced rate. You pay the total to your member state of identification, quoting the unique reference number of the return, and that authority distributes each country's share. Payment counts as made when it reaches the authority's bank account.

You must file a nil return for any quarter with no EU consumer sales. Corrections to an earlier quarter go into a later return, within three years of the original due date.

If a return is late, your member state of identification sends a reminder on the tenth day after the deadline. Penalties and interest are then set and collected by each member state of consumption under its own rules.

Record-keeping requirements

You must keep records of all OSS transactions for ten years from the end of the year in which the transaction took place. They must be made available electronically, on request, to your member state of identification and to any member state of consumption.

The records need to show the member state of consumption and the evidence used to determine it, the type of service, the date of supply, the taxable amount and currency, the VAT rate and amount, and any later adjustments or refunds.

Spreadsheets can satisfy this at low volume. As transactions grow, keeping ten years of auditable records by hand becomes an operational risk.

Common mistakes that lead to penalties

Using the wrong VAT rate

Applying your home country rate to every EU customer, instead of each customer's local rate, is a common filing error. Member states of consumption keep the power to audit OSS sales and recover underpaid VAT.

Ignoring reminders

A single late return triggers a reminder and whatever penalties the member states of consumption apply. Exclusion follows persistent failure: reminders for three consecutive quarters, each left unanswered for more than ten days. Exclusion for persistent failure carries a two-year ban from all OSS schemes, during which you must register locally in each country where you have consumers.

Insufficient location evidence

If you cannot show, with two non-contradictory items of evidence, where a customer is located, the sale can be challenged. Document your location logic.

Registering too late

For non-EU companies the obligation begins at the first sale, and OSS can only reach back to that sale if you notify the authority by the tenth day of the following month. Anything earlier has to be regularised directly with each member state concerned, which can involve penalties.

The alternative: using a Merchant of Record

OSS compliance is manageable, but it takes work. Registration, quarterly filing, record-keeping, rate maintenance and location evidence all carry ongoing accountability. For an early-stage SaaS company, that is time taken from the product.

The other path is selling through a Merchant of Record (MoR). Under this model, a third-party platform becomes the legal seller of your product to the end customer. Because the MoR is the seller, the obligation to charge, report and remit VAT on those consumer sales sits with the MoR. Your own sale becomes a business-to-business supply to the MoR, which has its own VAT treatment, so confirm the details with your adviser. Paddle, Stripe Managed Payments and tiun all operate on this model.

tiun operates as a Merchant of Record for SaaS and AI companies. It handles checkout, payments, billing and tax compliance, including EU VAT across all member states. Because tiun is the seller on the transaction, EU VAT obligations on those sales shift to tiun. tiun also includes authentication, customer data and analytics in the same system, so you are not wiring together separate tools for payments, auth and billing management.

The trade-off is cost and control. An MoR charges more per transaction than a payment processor, and the MoR's name appears as the seller on your customers' invoices.

The decision generally comes down to volume and team capacity. At low EU volume, DIY OSS is workable. As the EU customer base grows, filing correctly every quarter and keeping ten years of records audit-ready becomes harder to justify in-house.

Frequently asked questions

Does Stripe handle EU VAT compliance for me?

It depends on which Stripe product you use. On a standard Stripe integration you remain the legal seller, so the VAT obligation is yours. Stripe Tax, a separate product, calculates and collects VAT at checkout, can register non-EU digital businesses for the Non-Union OSS, and offers filing through Stripe or its filing partners. You are still the seller, and liability for the returns stays with your company.

Stripe Managed Payments works differently. For eligible digital product sales, Stripe becomes the merchant of record and takes on calculation, collection, filing and remittance in the countries it supports. Check Stripe's list of supported countries and product categories before relying on it for your whole customer base.

Do I need to register for OSS if all my EU customers are businesses?

No, for those sales. OSS covers B2C supplies only. When you sell to an EU business with a valid VAT number, the reverse-charge mechanism applies: the customer accounts for VAT in their own country, and you do not charge it. Collect and verify their VAT number and keep it on record.

A mixed customer base is harder. If EU businesses and EU consumers buy the same product, OSS applies to the consumer portion only. You need to establish each customer's status correctly at checkout, because treating a consumer as a business to avoid VAT is an audit risk. Most SaaS billing platforms can collect VAT numbers at checkout and apply the correct treatment.

What happens if I get excluded from the OSS scheme?

A member state of identification excludes a business that persistently fails to comply. That means reminders to file, or to pay, for three consecutive quarters with no return or full payment within ten days of each reminder (unpaid amounts under €100 per return do not count), or failing to hand over records within a month of being asked.

Exclusion for persistent failure brings a two-year quarantine from all three OSS schemes, in every member state. During that time you still owe VAT on EU consumer sales, and the only way to account for it is a local VAT registration in each member state where you have customers. For a SaaS company with consumers in ten or fifteen countries, that means ten or fifteen registrations, each with its own filing calendar. You can apply again once the quarantine ends.

Can I switch from DIY OSS filing to a Merchant of Record after I have registered?

Yes. When you move to an MoR, the MoR becomes the legal seller on new transactions from the point of integration. Once you no longer make direct B2C supplies to EU consumers, you can deregister from OSS by notifying your member state of identification at least 15 days before the end of the quarter. Deregistration takes effect on the first day of the next quarter, so leaving from 1 July means notifying by 15 June. There is no blocking period if you later need to register again.

You still file a final OSS return covering sales made before the switch, and you keep your transaction records for the full ten years. After that, VAT on new consumer sales is the MoR's responsibility.

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