EU VAT OSS for digital sales: when it applies, when it doesn't (2026)

Last updated: 12 June 2026 · Data verified: 12 June 2026 against the EC OSS portal. Note: EU VAT changes scheduled to take effect in January 2027 will alter how the €10,000 threshold is tracked in some scenarios — re-verify on the EC portal before relying on this page beyond 2026.

Selling a €15 PDF to a German consumer from your one-person Spanish business triggers a VAT obligation at the German rate, not the Spanish rate — once you are past the threshold. This rule applies from the first sale for non-EU sellers, and above €10,000/year net cross-border revenue for EU-established sellers. Knowing which side of the threshold you sit on determines whether you file quarterly OSS returns or just keep records. (OSS replaced the older, narrower MOSS scheme in July 2021 — if you last read up on "VAT MOSS", the threshold and scope have both changed.)

The three regimes

Union OSS — for EU-established sellers whose cross-border digital sales to EU consumers exceed €10,000/year net. Register in your home member state, file one quarterly return that splits revenue by destination country, pay one consolidated VAT bill; your home tax authority remits to the other member states. Below the threshold you may keep charging your home-country rate to all EU consumers.

Non-Union OSS — for non-EU sellers (UK, US, anywhere outside the EU-27) selling digital services to EU consumers. Applies from the first sale; no threshold. Register in one EU member state of your choice (Ireland is a common pick for English-language filings), file quarterly, remit consolidated.

Deemed-supplier platforms — Gumroad (merchant of record on all sales since January 2025), Lemon Squeezy, Paddle in MoR mode, Apple's App Store, Google Play, and similar handle VAT for you: the platform is the merchant of record, and you report platform payouts as your income rather than making B2C digital sales yourself. No OSS registration needed for sales through these platforms. You still need OSS for any direct Stripe / direct PayPal sales above your regime's threshold.

Edge cases that actually come up

B2B sales (reverse charge). If the buyer provides a valid VAT number — validate it via VIES at sale time — the sale is reverse-charged: you invoice VAT-exclusive with a "reverse charge" note and the buyer self-accounts. No OSS line item. An invalid number means you must treat it as a consumer sale and charge VAT.

Mixed catalog. Digital services and physical goods fall under different OSS schemes (digital-services rules vs distance-sales rules, separate since July 2021). Don't blend them in one threshold calculation.

UK after Brexit. The UK is outside OSS entirely. UK sellers are non-EU for OSS purposes (Non-Union OSS from the first EU sale). Selling digital services into the UK as a non-UK business has its own HMRC regime — non-established businesses get no registration threshold there, so check the current rules on gov.uk before your first UK consumer sale.

The threshold is net and EU-wide. The €10,000 counts all cross-border TBE (telecommunications, broadcasting, electronic) sales to EU consumers combined, net of VAT — not per-country, and not including your domestic sales.

Decision flow

1. Selling through a deemed-supplier platform (Gumroad, Lemon Squeezy, Paddle MoR, Apple, Google)? → Platform handles VAT. Done — for those sales.
2. EU-established and selling direct? → Under €10,000/year cross-border digital revenue: charge your home rate and keep records. Over it: register for Union OSS in your home state.
3. Non-EU and selling direct? → Non-Union OSS from the first sale, or move the catalog onto a deemed-supplier platform and make it their problem.
4. B2B buyer with a valid VAT number? → Reverse charge; invoice VAT-exclusive, no OSS entry.

Frequently asked questions

Does the €10,000 threshold apply per country?

No — it is one EU-wide figure: all your cross-border digital sales to consumers in other member states, combined, net of VAT, per calendar year. Crossing it anywhere flips ALL your cross-border consumer sales to buyer-country rates (with Union OSS as the single-filing mechanism). Verified 12 June 2026 against the EC OSS portal.

I sell only on Gumroad. Do I need any VAT registration?

For those sales, no OSS registration — Gumroad is the merchant of record (on all sales since January 2025) and handles consumer VAT itself. You account for the payouts as business income under your domestic rules. The moment you add a direct checkout (Stripe, PayPal) for the same products, the direct sales fall under the OSS rules above.

What records do I keep if I'm under the threshold?

Evidence of where your consumers are (billing country, payment-method country) and a running total of cross-border net revenue, so you can show you were entitled to charge the home rate — and so you notice the quarter you cross €10,000 rather than the audit that finds it. OSS schemes also carry a 10-year record-keeping expectation once registered.

Is a freelance project for a German company also under OSS?

No — that is a B2B service, not a consumer digital sale. With a valid VAT number (check it on VIES) it is reverse-charged: VAT-exclusive invoice, buyer self-accounts. OSS is about B2C digital sales. The day-rate guide covers the service-side pricing; this distinction is why the two guides exist separately.

Will these rules change?

Yes — EU VAT packages move. Changes scheduled for January 2027 will alter how the €10,000 threshold is tracked in some scenarios. This page's "Data verified" date tells you when it was last checked against the EC portal; past 30 days, treat it as a map, and the portal as the territory.

Can I just ignore this until I'm big?

The deemed-supplier route makes that almost true: platforms absorb the VAT problem at any size, which for a one-person business is often worth their fee by itself. Direct sales are where ignoring it bites — non-EU sellers owe from the FIRST sale, and EU sellers who cross €10,000 mid-year owe buyer-country VAT from the crossing point onward.