Spain Introduces a New Guarantee Regime for Fuel Withdrawals from VAT Warehouses

New Regime for Fuel Release from VAT Warehouse

Spain has introduced a new VAT guarantee system for certain fuels released from VAT warehouses (in the local language referred as "depósito distinto del aduanero").The rules were published in December 2025 and will apply from 1 February 2026, significantly changing how VAT is secured in the Spanish fuel supply chain.

The measures implement amendments to the Spanish VAT Law and are particularly relevant for international fuel traders, energy groups and logistics operators active in Spain. Find here the new applicable regulation, based on the modified Appendix eleven of the Spanish VAT Law.

What Is Changing?

When petrol, diesel or biofuels leave a Spanish VAT warehouse, the last depositor must now ensure that the VAT due on the transaction is secured before the goods are released. This is done through a formal administrative authorisation process.

VAT can be secured in one of two ways:

• By providing a bank guarantee covering 110% of the VAT due on recent comparable transactions, or
• By making a VAT advance payment, also equal to 110% of the VAT, using the newly introduced form 319.

Without confirmation that one of these options has been fulfilled, the Spanish tax authorities will not authorise the release of the fuel.

Increased Responsibility for Warehouse Keepers

The reform places a significant compliance burden on VAT warehouse keepers, who must verify that the last depositor has provided sufficient security or is exempt from doing so. If fuel is released without proper authorisation, the warehouse keeper may become jointly liable for the VAT, calculated at 110% of the tax due.

Trusted Operator Status

Spain has also created a Trusted Operator Register. Operators included in this register are exempt from providinga VAT guarantee when fuel is withdrawn from a VAT warehouse.

Access to this status is limited to large-scale operators and is subject to strict conditions, including very high annual extraction volumes, a proven track record as a wholesale operator and strong financial solvency. This exemption will therefore only be available to a small number of major market players.

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These changes strengthen VAT controls in a sector traditionally exposed to fraud and cash-flow risks. International groups operating in Spain will need to assess whether they must provide guarantees, adjust their cash-flow planning and review contractual arrangements with Spanish warehouse keepers ahead of February 2026.