Key data
| Regulation | Commission Implementing Regulation (EU) 2026/1869 of 27 July 2026 |
|---|---|
| Modified rule | Implementing Regulation (EU) 2020/194 |
| Publication | 28 July 2026 (EU Official Journal) |
| Entry into force | Not specified in the published regulation |
| Affected parties | E-commerce companies, marketplaces and digital service providers selling to EU consumers (B2C) |
| Category | Tax News |
| Year | 2026 |
| Official reference | OJ:L_202601869 |
If your company sells products or digital services to consumers in other EU countries and uses the OSS or IOSS system to simplify VAT declaration, this regulation directly affects you. The Implementing Regulation (EU) 2026/1869, published on 28 July 2026, amends Regulation 2020/194, which is precisely the technical regulation that governs how these special regimes work in practice.
This is not a change in VAT rates or billing thresholds. The impact is procedural: how you register, how you declare and how you communicate with tax authorities through these systems. Ignoring it can result in formal non-compliance with consequences in tax inspections by any Member State where you operate.
What does this regulation establish?
The OSS (One Stop Shop) and IOSS (Import One Stop Shop) system allows companies selling in several EU countries to declare and pay VAT for all those sales from a single registration point, rather than registering in each country separately. This affects three types of operations:
| Type of operation | Applicable regime | Recipient |
|---|---|---|
| Provision of services to final consumers | OSS (Union or non-Union regime) | B2C consumers in the EU |
| Distance sales of goods within the EU | OSS (Union regime) | B2C consumers in the EU |
| Certain domestic deliveries of goods | OSS (Union regime) | B2C consumers in the EU |
Regulation 2020/194, which is now being amended, establishes the technical and procedural provisions that develop how these regimes work: what data must be included in the registration, how declarations are submitted, what information must be communicated to tax authorities and in what formats. The new Regulation 2026/1869 updates those provisions.
The amendment is framed within Council Regulation (EU) No 904/2010, which is the basic rule on administrative cooperation in VAT matters between Member States.
Economic and operational impact
The impact is not tariff-related and does not involve new taxes. The real cost to companies is operational and compliance-related:
- Review of internal systems: Tax management and ERP platforms that automate OSS/IOSS declarations will need to be updated to comply with new procedural requirements. Depending on the software provider, this may involve update or adaptation costs.
- Review of registration processes: Companies that are not yet registered in OSS or IOSS, or that have outdated data, will need to review their situation with the tax authority of their identification Member State.
- Risk of formal non-compliance: Failure to adapt procedures to new requirements can generate discrepancies in declarations that result in information requests or inspections in any of the Member States where sales have been made.
- Advisory cost: Companies with complex operations in multiple countries will need to review with their tax advisor the specific impact of procedural changes on their current operations.
The greatest risk is assumed by companies operating in multiple Member States simultaneously and that have automated declaration processes, as any misalignment between their systems and new requirements can multiply in each declaration submitted.
Who does it affect?
- Online stores (e-commerce) that sell physical products to consumers in other EU countries and use the OSS regime to declare VAT.
- Marketplaces and digital platforms that facilitate cross-border B2C sales within the EU and are responsible for VAT collection.
- Digital service providers (software, streaming, apps, digital content, SaaS) that provide services to final consumers in the EU from any country.
- Companies not established in the EU that sell to European consumers and use the non-Union OSS regime or IOSS for low-value imports.
- Tax compliance managers (CFOs, tax managers) of any company with cross-border B2C sales in the EU.
- Tax advisors and consultants who manage OSS/IOSS declarations for their clients.
Practical example
A Spanish online clothing sales company that uses the OSS regime to declare VAT on its sales to consumers in France, Germany, Italy and Portugal currently has an automated process: its ERP generates the OSS declaration quarterly with sales data by country and sends it through the Electronic Headquarters of the AEAT (its identification Member State).
With the entry into force of Regulation 2026/1869, the procedural requirements of that declaration change. If your ERP is not updated in time, the declaration could be submitted with incorrect or incomplete fields according to the new standards. This not only affects Spain: any of the four countries where you sell could detect the discrepancy and request additional information or initiate a review.
The immediate action is to contact your tax management software provider to confirm that the update to the new format will be available before the next OSS declaration.
What should companies do now?
- Identify if you use OSS or IOSS: Confirm with your tax advisor whether your company is registered in any of these regimes and in which identification Member State. If you are not sure, this is the first step.
- Review current registration and declaration procedures: Document how your OSS/IOSS declarations are currently generated: what system does it, who supervises it and what data it includes.
- Contact your tax software provider: Explicitly ask whether their platform already incorporates the changes of Regulation 2026/1869 or when it will. Do not assume that the update is automatic.
- Consult with your tax advisor specializing in European VAT: The changes are procedural and technical. A specialist in cross-border VAT can identify what specific aspects of your operations need adjustment.
- Monitor the application date: The regulation does not specify an entry into force date in the published data. Stay alert to communications from the AEAT or the tax authority of your OSS/IOSS registration country about adaptation deadlines.
- Update registration data if necessary: If there are changes in your company (new headquarters, change of activity, new sales countries), check that your OSS/IOSS registration is up to date before the new requirements come into force.
Frequently asked questions
What is the OSS and IOSS system and why does it change in 2026?
OSS (One Stop Shop) and IOSS (Import One Stop Shop) are simplified regimes that allow companies to declare and pay VAT on their B2C sales in multiple EU countries from a single registration point. Implementing Regulation (EU) 2026/1869, published on 28 July 2026, amends Regulation 2020/194, which regulates the technical and procedural aspects of these systems: how companies register, how declarations are submitted and how they communicate with tax authorities.
When does Regulation 2026/1869 come into force and what is the deadline for adaptation?
The regulation was published on 28 July 2026, but the exact date of entry into force is not specified in the data published so far. It is essential to monitor communications from the tax authority of your identification Member State (in Spain, the AEAT) to know the specific deadline for adaptation.
Which companies are required to comply with the new OSS requirements?
All companies that use the OSS or IOSS regime to declare VAT on their cross-border B2C sales in the EU are affected: online stores selling physical goods to consumers in other Member States, digital service providers (SaaS, streaming, apps), marketplaces managing VAT for third-party sellers, and companies not established in the EU that sell to European consumers.
What happens if my company does not update its OSS/IOSS procedures in time?
Failure to adapt procedures to new procedural requirements can result in declarations with incorrect or incomplete data. This can result in information requests from tax authorities in any Member State where sales have been made, or tax audits. The risk is greater for companies operating in multiple countries simultaneously with automated processes.
Does this change affect VAT rates or distance sales thresholds?
No. Regulation 2026/1869 exclusively modifies the procedural aspects of the OSS and IOSS system: registration, declaration and communication with tax authorities. It does not modify the VAT rates applicable in each Member State or the distance sales thresholds (currently set at 10,000 euros per year for the Union regime).
Official source
View complete regulation in official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601869