Non-Union OSS: UK Digital Service Sales to the EU

If you are a UK business selling digital products — SaaS, ebooks, online courses, or software — to consumers in the EU, you have a VAT obligation starting from your first sale. Post-Brexit, the rules changed significantly for UK sellers. The Non-Union One Stop Shop (OSS) keeps you compliant without requiring 27 separate EU registrations.

For the full mechanics — what counts as a digital service, how to calculate what you owe, two-pieces-of-evidence for customer location, automated tools, and the Merchant of Record decision — see the shared guide:

Non-Union OSS for Digital Services 2026

Post-Brexit: The UK’s £90,000 Threshold Does Not Apply

This is the single biggest change for UK digital sellers post-Brexit, and the most common source of non-compliance.

Inside the UK, you have a £90,000 VAT registration threshold. Below that, you charge no UK VAT and have no UK filing obligations.

For EU digital sales, the threshold is €0 from your first sale. This applies regardless of your UK VAT status.

Before Brexit, UK digital sellers were inside the EU VAT system. They benefited from the EU’s €10,000 cross-border threshold for intra-EU sales. Since 1 January 2021, UK sellers are treated as non-EU sellers. Non-EU sellers have no threshold.

The practical impact: a UK developer who launched a £20/month SaaS tool in early 2021 and got their first French subscriber on day one has had an EU VAT obligation since that first subscription — regardless of whether they ever hit the UK’s £90,000 threshold. Many UK SaaS founders have discovered this years late, with significant back-liability.

Why Ireland Is the Right Registration Choice for UK Businesses

When you register for Non-Union OSS, you choose one EU member state as your “Member State of Identification.” You can choose any of the 27 — the choice has no effect on the rates you charge or which countries receive the VAT.

Ireland is the right choice for almost all UK businesses, for three practical reasons:

Language. Revenue.ie (the Irish tax authority) operates entirely in English. The registration process, portal, and support are all available in English without translation tools or language barriers.
Process. Revenue.ie has published clear guidance for non-Union OSS registrations. The process is well-documented and regularly updated.
Time zone and proximity. Support calls and correspondence with Revenue.ie operate in the same or near time zone as the UK. If you need to resolve a query, you can do it during normal UK working hours.

Choosing Germany or France means navigating German or French-language portals and correspondence. Unless you have a specific reason to register elsewhere (for example, an existing relationship with a German VAT agent), Ireland is the practical default for UK businesses.

How to Register with Revenue.ie

Go to Revenue.ie and search for “Non-Union OSS registration”
Create or log in to a myAccount or Revenue Online Service (ROS) account as a non-established trader
Complete the non-Union OSS registration form — you will need your business details, tax identification number from the UK, and the start date of your EU taxable activities (be honest about this date)
Once registered, Revenue.ie will issue you a VAT identification number for OSS filings (not the same as an Irish VAT number)
Configure your checkout to charge destination-country VAT (Stripe Tax or Quaderno make this automated)
File quarterly returns through the Revenue.ie OSS portal — due in April, July, October, and January

Late Registration as a UK Business

If you have been selling digital products to EU consumers since before or shortly after Brexit without registering, the voluntary disclosure approach is the right path. Revenue.ie is generally pragmatic with UK businesses that come forward voluntarily.

Key UK-specific notes:

HMRC is not involved — this is a disclosure to Revenue.ie (or whichever EU authority you register with)
You will be asked for the date your EU taxable digital service sales began — this is the date post-Brexit when you first sold to an EU consumer, not your UK registration date
Back-filing covers the periods from that start date to now

For the full action plan, see Late EU VAT Registration.

What You Cannot Do Through OSS

The OSS is an output-only scheme. As a UK business registered for Non-Union OSS in Ireland:

You cannot use your OSS return to reclaim VAT paid on EU business expenses (server subscriptions, contractor invoices, travel)
The 13th Directive is the route for that — see Reclaiming EU VAT on Expenses
Your OSS registration in Ireland does not give you a general Irish VAT number — it is a specific OSS registration for this scheme only