Regulatory updates - European Union

The Regulation (EU) 2026/2108, which entered into force on September 20, 2026, introduces a more centralized, data-driven approach to customs supervision. It is supported by the new EU Customs Data Hub and the European Union Customs Authority (EUCA), based in Lille, France, which will begin operations in 2027. The Data Hub will serve as the central platform for importers and exporters to interact with EU customs and will give EUCA access to relevant import and export data for EU-level risk analysis and controls.

Among the key changes are:

• New customs data model: The EU Customs Data Hub will gradually become the central platform for customs information, replacing the fragmented network of national customs IT systems.
• New obligations for e-commerce: For distance sales of goods imported into the EU, sellers or platforms facilitating such sales will assume the role of “importer for distance sales”, shifting responsibility for customs formalities and payment of customs duties away from the final consumer.
• Stronger EU-wide controls: The EUCA will use data available through the Data Hub to support EU-level risk analysis, identify priority control areas and coordinate customs crisis management.
• New trusted trader framework: The new “Trust and Check” (T&C) status will simplify customs procedures for highly transparent and reliable businesses that provide comprehensive information about their goods and compliance. Eligible traders may, for example, release goods without active customs intervention.
• Stronger e-commerce enforcement: The Regulation introduces specific penalties for systematic non-compliance by e-commerce operators involved in distance sales. Serious violations may result in fines, loss of customs privileges, and, in some cases, restricted access to online platforms.

Implementation timeline

The reform will be introduced progressively, with its main provisions being generally applicable from September 21, 2027.  For the EU Customs Data Hub, it will be operational by June 1, 2028, and become available for e-commerce and IOSS-related use from July 1, 2028, with broader voluntary access from March 1, 2031 and mandatory use by all economic operators from March 1, 2034.

Businesses facilitating the cross-border e-commerce involved in the movement of goods into or out of the EU will need to follow the phased implementation of the new framework, while e-commerce sellers and platforms will face some of the earliest and most significant changes through the new “importer for distance sales” concept and the introduction of the EU Customs Data Hub.

The optional RCM and QRM would remain in force until the central VIES system becomes operational on July 1, 2030, in line with the VAT in the Digital Age (ViDA) package. Central VIES is intended to improve cross-border digital reporting and taxpayer identification, helping combat Missing Trader Intra-Community (MTIC) fraud.

The Council shall adopt the proposal by the end of 2026, before the mechanisms under Articles 199a and 199b of Directive 2006/112/EC expire on December 31, 2026.

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.