Regulatory updates - European Union

Body: The adoption of the Commission Implementing Regulation (EU) 2026/1869 introduces further measures aimed at simplifying VAT administrative processes, including the following:

• Introduction of the Transfer of Own Goods (TOOG) scheme to the One Stop Shop (OSS): Businesses will be able to report qualifying cross-border transfers of their own goods through a single Member State of Identification, reducing the need to register in every destination member state in case of cross-border movements of own stock.
• Mandatory pre-filling of registration data: Information already available to the tax authority will be pre-filled when businesses register for a special scheme. Businesses will, however, remain responsible for reviewing and confirming the accuracy of the submitted data.
• Revisions to VAT filing procedures: Businesses will be able to save VAT return information before submission. The regulation also clarifies when nil VAT returns must be submitted and introduces other adjustments to the filing procedures for special schemes.

How does this relate to the overall aim of Pillar III?

The aim of Pillar III, Single VAT Registration (SVR), is to reduce the need for businesses to register and file for VAT in multiple Member States. Under ViDA, the scope of transactions covered by the One Stop Shop will be expanded, alongside a broader mandatory application of the reverse charge mechanism for certain supplies made by non-established, non-VAT registered suppliers, as well as further simplification and harmonization of VAT procedures.

The new TOOG scheme further expands the One Stop-Shop framework by adding a fourth special VAT scheme alongside the three existing schemes (Non-Union OSS, the Union OSS and the Import One Stop Shop (IOSS)). Similar to the existing schemes, the TOOG scheme provides a simplified mechanism for fulfilling VAT obligations across multiple Member States, in this case for qualifying cross-border transfers of own goods.  

Timelines

• January 1, 2027: Minor legislative and administrative changes affecting the One-Stop-Shop (OSS) and IOSS schemes will apply.
• July 1, 2028: The new Transfer of Own Goods scheme and mandatory reverse charge for certain supplies made by non-established and non-VAT-identified persons under the Single VAT Registration reforms will apply.

The Council has reached a provisional agreement on new measures to strengthen the fight against VAT fraud across the EU. The framework aims to improve cooperation between member states and EU bodies, including the European Public Prosecutor’s Office (EPPO) and the European Anti‑Fraud Office (OLAF), by granting them more direct access to key VAT data.

Under the new rules, EPPO and OLAF will be able to access information on cross‑border business transactions, including data held by Eurofisc, the EU’s anti‑VAT fraud network. This will allow investigative bodies to obtain first‑hand information more quickly, accelerating investigations and improving coordination between authorities.

The measures specifically target cross‑border VAT fraud, including missing trader intra‑community fraud (carousel fraud), which continues to cause significant revenue losses across the EU. The enhanced access to data is expected to strengthen detection capabilities and support faster enforcement actions.

Impact

The improved cooperation framework is designed to reduce VAT fraud losses, which are estimated to amount to billions of euros annually, while ensuring a more level playing field for compliant businesses. By increasing transparency and enabling quicker investigations, the rules aim to enhance the overall effectiveness of VAT enforcement across the Union.

Next steps

The new rules are part of an amendment to Council Regulation 904/2010 on administrative cooperation and combating VAT fraud. Following the expected opinion of the European Parliament, the Council will proceed with formal adoption. The regulation will enter into force twenty days after publication in the Official Journal of the European Union.

ONESOURCE Pagero, an active contributor to the Peppol ViDA pilot, has reached the first milestone by successfully passing the initial conformity test for access points operating under the 5-corner model designed for ViDA compliance.

Under the ViDA package, adopted on March 11, 2025, mandatory intra-Community e-invoicing and digital reporting requirements (DRR) will take effect from July 1, 2030.

The Peppol ViDA pilot was officially launched in December 2024. It is designed to demonstrate how the 5-corner model can support compliance with intra-Community e-invoicing and DRR obligation.

More than 100 participants, including 20 Tax Administrations, Peppol authorities, service providers, and businesses, are involved in the pilot. Together, they are defining the e-invoicing and DRR architecture needed to support these obligations, as well as the specifications required to support them.

This conformance test demonstrated, among others, ONESOURCE Pagero’s ability to generate EN-compliant e-invoices, EN-compliant DRRs, exchange these in real-time with tax administrations and other service providers, as well as process response messages generated by all parties invoiced in a 5-corner exchange.

We look forward to real-life ViDA pilot testing, which is to be scheduled soon, and are ready to support those customers who would like to join the pilot together with us.