European Commission Adopts New Regulation Amending the Administrative Rules for VAT Special Schemes

On 28 July 2026, the European Commission published Commission Implementing Regulation (EU) 2026/1869 in the Official Journal of the European Union. This Regulation amends the existing rules on VAT special schemes as part of the progressive rollout of Pillar III of the VAT in the Digital Age (ViDA) project.

The European Commission has adopted Commission Implementing Regulation (EU) 2026/1869, which amends Implementing Regulation (EU) 2020/194. This amendment introduces the technical and administrative framework needed to carry out the Pillar III reforms under ViDA (administrative and registration simplification), updating the rules on the scope of the special schemes, harmonizing electronic communication across all of them, and promoting their uniform application.

What are the main changes?

Among the most significant updates are:

• The introduction of the transfer of own goods scheme, alongside the existing non-Union, Union, and import schemes.
• Revised definitions reflecting the expanded scope of the Union scheme (OSS). In this sense, the Explanatory Notes and OSS guidelines have been reviewed.
• Updated electronic registration and VAT return formats, including the ability to save information before submitting it.
• Harmonized exchange of identification data between Member States through a central register or another trusted data-exchange tool.
• Mandatory pre-filling of registration data where the information is already available in national databases, although taxable persons remain responsible for its accuracy.

Make sure to read our e-commerce manual to learn all you need to know about special schemes in the EU.

Changes to the proposed definitions

Among the key changes due to enter into force are the amendments to the definitions of the schemes covered by the Regulation, including the expansion of the scope of the Union scheme - not only to intra-Community distance sales of goods, but also to certain domestic supplies - and the introduction of transfers of own goods between Member States as a new, distinct special scheme. Specifically, Article 1 introduces the following changes to the proposed definitions:

• "Union scheme": the special scheme for intra-Community distance sales of goods, for certain supplies of goods within a Member State made by a taxable person, and for certain services supplied by taxable persons established in the Community but not in the Member State of consumption, as set out in Title XII, Chapter 6, Section 3 of Directive 2006/112/EC.
• "Transfer of own goods scheme": the special scheme for transfers of own goods set out in Title XII, Chapter 6, Section 5 of Directive 2006/112/EC.

Changes to registration, identification, and returns

Articles 2 to 5 of Implementing Regulation (EU) 2020/194 are updated to integrate the new scheme into the electronic registration and return system: the required identification data and the column assignment are expanded (a new column G is added), the automatic exchange of data between Member States through a central register is reinforced, and an obligation is introduced to pre-fill registration data already available in national databases, although the taxable person remains responsible for its accuracy.

As regards the data transmission regime, it is clarified that where a taxable person makes no supplies of goods, no supplies of services, no transfers of own goods, no deduction adjustments under a special scheme in any Member State within a tax period, and has no amendments to make to previous VAT returns, that taxable person must submit a nil VAT return.

In addition, Annexes I, II and III are amended: Annex I updates the identification details required of taxable persons, Annex II standardizes the reasons for changing the status of a taxable person or intermediary in the register, and Annex III provides a complete breakdown of the new structure of VAT returns, incorporating the transfer of own goods scheme.

Conclusions and entry into force

Regulation (EU) 2026/1869 represents a significant update in terms of administrative simplification and reporting for VAT special schemes in the EU, aimed at harmonizing and improving the exchange of data between Member States and facilitating compliance for businesses operating in several countries of the Union. The Regulation enters into force 20 days after its publication in the Official Journal of the EU, although its most significant changes will not apply until 1 July 2028, so affected businesses should begin preparing in advance.