Cross-border e-commerce is no longer optional for German shops in 2026. Anyone shipping B2C from Germany to other EU member states may keep charging the German VAT rate up to an EU-wide net annual turnover of EUR 10,000 (Section 3c UStG); above that limit the destination country rate applies. For consignments from third countries the Import-One-Stop-Shop draws the line at an intrinsic value of EUR 150 (Section 18k UStG), and the EU-wide scheme for small enterprises ends at EUR 100,000 in annual turnover across all member states (EU Commission). Three limits, three procedures - and no way past OSS, IOSS, the DATEV interface and the ViDA reform. This article focuses on the tax side - we covered language and UX internationalisation separately.
OSS, IOSS, Non-Union: three schemes explained
Since 1 July 2021, the EU has extended the original MOSS (Mini-One-Stop-Shop), previously limited to electronically supplied services, to all distance sales to private customers (EU Commission). MOSS became OSS, complemented by IOSS for shipments from third countries. Three schemes are available - the choice depends on where the merchant is established and where the goods are stocked.
| Feature | Union OSS | Non-Union OSS | IOSS |
|---|---|---|---|
| Scope | Intra-EU B2C distance sales + EU-internal TBE services | Services by non-EU traders to EU customers | Imports from third countries ≤ EUR 150 value |
| Registration | Member state of establishment (DE: BZSt) | Any EU member state | One EU state or via intermediary |
| Tax period | Calendar quarter | Calendar quarter | Calendar month |
| Deadline | One month after quarter end | One month after quarter end | One month after month end |
| Legal basis | Section 18j UStG | Section 18i UStG | Section 18k UStG |
Union OSS covers the standard German case: a Shopware shop with a warehouse in Lower Saxony shipping to consumers in France, Italy, Poland and 24 other member states. The tax period is the calendar quarter (Section 16(1d) UStG), and the return must be filed within one month of the end of that quarter (Section 18j UStG). IOSS registrations are particularly relevant for merchants with stock in Switzerland, the UK or Asia; the marketplace integration often routes this constellation via the platform model.
The Non-Union scheme typically does not play a direct role for German merchants but is relevant for parent-subsidiary structures with British or Swiss entities: since 2021 they can register in any EU member state and bill EU-wide digital services without being registered in every country. Practically, this means that a UK subsidiary selling SaaS licences to EU consumers gets by with a single EU registration; the company itself decides which member state to register in (Section 18i UStG).
The EUR 10,000 threshold in practice
Up to a distance-sales threshold of EUR 10,000 net per year, a German shop can continue to invoice cross-border B2C sales with the German VAT rate and report them in the standard German VAT return (Section 3c UStG). Be careful: the threshold is cumulative across all EU cross-border B2C turnover including TBE services - not per country, and it counts for both the preceding and the current calendar year. Anyone exceeding the threshold in May must charge the destination country VAT rate from the next sale and either register locally or use OSS.
In practice this means: for every order with a destination in the EU, the net value must be tracked in a running annual counter. As soon as the counter exceeds EUR 10,000, the system automatically switches to the foreign VAT rate and reports via OSS. The DATEV interface should provide separate accounts per destination country for this - otherwise the quarterly return turns into detective work.
BZSt registration step by step
- Check prerequisites - the shop needs a German VAT identification number (USt-IdNr.) and must exceed the EUR 10,000 EU threshold or voluntarily waive it.
- Set up BZStOnline portal access - register via ELSTER-BOP (Business Online Portal) with an organisational certificate; alternatively via Mein-ELSTER linked to BZStOnline.
- Submit the 'osseureg' application - in the BZStOnline portal complete the registration form for the Union OSS scheme; mandatory data are VAT-ID, email, bank details and intended start quarter.
- Appoint an authorised recipient - if established outside Germany; German shops can optionally enter their tax adviser or our consulting team.
- Wait for confirmation - the BZSt reviews the application and notifies the start quarter (typically the quarter following submission).
- Prepare the first return - once registration is effective, reporting begins: four quarterly returns per year, each due by the last day of the following month.
Quarterly return: extracting data from Shopware
The OSS quarterly return submitted to the BZSt is a structured XML file with revenue per destination country and VAT rate. It must be filed within one month of the end of the tax period (Section 18j UStG). Anyone running Shopware must aggregate gross and net values per country and per VAT rate from the order data. A properly configured order export route - typically through the DATEV interface - delivers the required fields for the return.
{
"reporting_period": {
"year": 2026,
"quarter": 2
},
"taxable_supplies": [
{
"country_of_consumption": "FR",
"vat_rate_type": "standard",
"vat_rate": 20.0,
"taxable_amount_eur": 48250.00,
"vat_amount_eur": 9650.00
},
{
"country_of_consumption": "IT",
"vat_rate_type": "standard",
"vat_rate": 22.0,
"taxable_amount_eur": 31790.00,
"vat_amount_eur": 6993.80
},
{
"country_of_consumption": "AT",
"vat_rate_type": "standard",
"vat_rate": 20.0,
"taxable_amount_eur": 12480.00,
"vat_amount_eur": 2496.00
}
],
"total_vat_due_eur": 19139.80
}The example shows a simplified data structure for the OSS return Q2/2026. Important: each country can have multiple VAT rates - the EU framework allows a standard rate of at least 15 percent plus up to two reduced rates as low as 5 percent for the categories listed in Annex III of the VAT Directive (EU Commission). In the Shopware backend, country-specific tax rules must therefore be configured for every product category.
On a quarterly basis, depending on assortment breadth, this data produces between 30 and 200 booking entries - a mid-size merchant with 12 EU destination countries and three VAT rates per country quickly accumulates over 350 data points. The interfaces between shop, ERP and DATEV must reliably pass this volume of data. Experience shows that manual preparation costs 4-12 hours per quarter; an automated pipeline reduces the effort to roughly 30 minutes of plausibility checking.
Marketplace deemed-supplier rule
Since 1 July 2021, the EU applies the deemed-supplier rule (marketplace facilitation): where a trader uses an electronic interface to facilitate the supply of goods by a trader not established in the Community to a consumer, that trader is treated as having received and supplied the goods themselves (Section 3(3a) UStG) - the marketplace then owes the VAT. Anyone planning the marketplace integration should map the deemed-supplier rule cleanly in the books and separate platform turnover from their own.
| Constellation | Who owes VAT? | Procedure |
|---|---|---|
| B2C, EU merchant, own shop | Merchant | Union OSS or local registration |
| B2C, EU merchant, EU marketplace | Merchant (marketplace not deemed supplier) | Union OSS |
| B2C, non-EU merchant, EU marketplace | Marketplace (deemed supplier) | Platform reports |
| Import ≤ EUR 150 via marketplace | Marketplace (deemed supplier) | IOSS via platform |
| Import > EUR 150 | Importer / end customer | Standard customs, no IOSS |
IOSS for imports ≤ EUR 150
IOSS applies to consignments from third countries with an intrinsic value of no more than EUR 150 (Section 18k UStG). On import, the system collects the VAT of the destination country; the end customer pays gross and faces no surcharges at customs. The tax period is the calendar month (Section 16(1e) UStG) - IOSS therefore files twelve times a year, Union OSS four times.
- Scope - all B2C imports with an intrinsic value above EUR 150 fall outside IOSS and follow the standard customs procedure (Section 18k UStG).
- Intermediary requirement - non-EU merchants need an IOSS intermediary (established in the EU); EU merchants can register directly.
- Monthly filing - unlike the quarterly Union OSS, IOSS must be filed monthly.
- Abolition of the EUR 150 threshold - under the ViDA reform package the threshold will eventually be removed (exact date pending); all imports become subject to customs duty. What this means for shops in practice is covered in the article on the EU customs reform 2026.
ViDA: the three pillars 2025-2030
The VAT in the Digital Age reform (ViDA) was adopted by the Council on 11 March 2025, published in the Official Journal on 25 March 2025 and entered into force twenty days later (EUR-Lex). It modernises the VAT system in three pillars with different effective dates up to 2030. All three pillars are relevant to online shops - preparation starts in 2026.
- Pillar 1 - Digital Reporting Requirements (DRR) - mandatory structured e-invoicing and real-time reporting for all intra-EU B2B transactions from 1 July 2030. The format aligns with EN 16931 and complements the German rules from the e-invoicing obligation package and ZUGFeRD credit notes.
- Pillar 2 - Platform Economy - extension of the deemed-supplier rule to short-term accommodation rental and passenger transport; member states apply the rules from 1 July 2028 at the earliest and 1 January 2030 at the latest (EUR-Lex). Online shops in travel/mobility must adapt their platform architecture accordingly.
- Pillar 3 - Single VAT Registration (SVR) - extension of OSS to additional B2C constellations, stock transfers (call-off stock) and mandatory reverse charge for B2B by non-established suppliers; updates from 1 January 2027, full rollout 1 July 2028.
- Staged timetable of the directive - the amendments to the VAT Directive take effect in four stages, from 1 January 2027, 1 July 2028, 1 July 2029 and 1 July 2030 (EUR-Lex).
- 1 January 2027 - OSS extension to electricity/gas/heat - the Union OSS scope is extended to supplies of electricity, gas and heating/cooling (EUR-Lex).
Single VAT Registration from 1 July 2028
The SVR pillar drastically reduces the need for local VAT registrations. Anyone today operating warehouses in five EU member states typically needs five registrations plus OSS - from 1 July 2028, one registration in the country of establishment plus the extended OSS suffices. In particular, the treatment of stock transfers (transferring own goods to other EU warehouses) is simplified; the previously required call-off-stock process is dropped (EUR-Lex).
Practically relevant for shops with multi-country fulfilment: warehouses in NL, FR and PL can be reported through a single German OSS registration from 2028 onwards. Also, B2B supplies by non-established suppliers move to a mandatory reverse charge - the German bookkeeping must be able to separate B2B-RC from B2C-OSS. The DATEV interface thus gains additional mandatory fields.
BZSt procedure: deadlines and corrections
The theoretical efficiency of OSS meets hard deadlines in practice. The return must be filed within one month of the end of the tax period; corrections to a return already filed must be reported within three years of the last day of that period, in a later return stating the tax period being corrected (Section 18j UStG). Anyone starting cross-border in 2026 should plan status enquiries, change requests and refunds with lead time and build the correction path into the bookkeeping process from day one.
Corrections of an already submitted OSS return must be reported in a later return stating the tax period being corrected, not by cancelling the previous one; this is possible within three years of the last day of the period concerned (Section 18j UStG). Refunds for over-reported VAT are paid directly by the destination state to the merchant - processing times differ considerably between member states.
DATEV/Lexware integration for OSS
The standard in German e-commerce bookkeeping is DATEV or Lexware. Both systems offer dedicated OSS accounts and support exporting the required data to the BZStOnline portal. The prerequisite is a chart-of-accounts split by destination country and VAT rate: in the standard SKR04 chart of accounts, accounts 4315-4350 are reserved for EU OSS revenue per VAT rate. A clean DATEV interface in Shopware writes every order directly into the matching account and avoids manual rework.
In practice, the following setup has proven itself: for each order, Shopware writes a line with country, VAT rate and net/gross into a mapping table. Based on this mapping, the DATEV interface automatically posts to the correct OSS account. At quarter-end, an evaluation script generates the OSS return in structured format and submits it to the BZStOnline portal. Changes to the account mapping (e.g. new reduced rates) are maintained centrally - the Shopware configuration does not need to be touched.
Keeping VAT rates up to date within the EU framework
VAT rates change continuously, and the VAT Directive leaves member states room to manoeuvre: the standard rate must be no less than 15 percent and there is no maximum; in addition, up to two reduced rates as low as 5 percent are permitted for the categories listed in Annex III (EU Commission). Filing an OSS return with an outdated rate risks corrections and back-payments. Only the rates in force in the respective member state are binding - the table below shows the framework and the German rates as a starting point.
| Rate type | EU directive framework | Germany | Legal basis |
|---|---|---|---|
| Standard rate | no less than 15 %, no maximum | 19 % | Art. 97 VAT Directive / Section 12(1) UStG |
| Reduced rate | up to two rates as low as 5 % | 7 % | Annex III VAT Directive / Section 12(2) UStG |
| Scope | categories listed in Annex III | Annex 2 to the UStG | Annex III VAT Directive |
Since 2025, an EU-wide SME threshold of EUR 100,000 in cross-border turnover applies: small German enterprises can use the VAT exemption of other EU states as long as they stay below EUR 100,000 in EU-wide cross-border turnover (EU Commission). The application is filed in the country of establishment - in Germany via the BZSt. Note: the German domestic small-business threshold sits at EUR 25,000 in total turnover in the preceding calendar year and is separate from this (Section 19 UStG).
5-phase roadmap to a compliant cross-border setup
- Phase 1 - inventory (week 1-2) - determine cross-border volume per country for the past 12 months; check the threshold; map warehouse locations; inventory active marketplace integrations.
- Phase 2 - BZSt application and accounts (week 3-4) - submit 'osseureg' in the BZStOnline portal; set up SKR04 OSS accounts; create a mapping table country/VAT-rate/account in DATEV.
- Phase 3 - Shopware configuration (week 5-7) - configure country-specific tax rules per product category; activate the EUR 10,000 counter; convert the order data export to OSS format; configure the DATEV interface.
- Phase 4 - first quarterly return (next quarter) - dry run with a test return; plausibility checks of the country/rate mappings; live submission via the BZStOnline portal; payment to the BZSt account.
- Phase 5 - ViDA preparation (ongoing through 2028) - build the e-invoicing pipeline (Peppol, ZUGFeRD); review stock transfer constellations for SVR; maintain a watchlist for the DRR deadline 1 July 2030 with our e-commerce consulting team.
This article relies on publicly available primary sources: the German VAT Act (UStG) (Section 3(3a) on the deemed-supplier rule, Section 3c on the EUR 10,000 distance-sales threshold, Section 12 on the German VAT rates, Section 16(1d) and (1e) on the tax periods, Section 18j on Union OSS including filing deadline and corrections, Section 18k on IOSS and the EUR 150 intrinsic-value limit, Section 19 on the small business scheme), EUR-Lex (Council Directive (EU) 2025/516 of 11 March 2025 with the ViDA stages 2027, 2028, 2029 and 2030), the EU Commission (framework for VAT rates, EU-wide SME scheme with EUR 100,000) and the Federal Central Tax Office (BZSt) (BZStOnline portal, 'osseureg' procedure). Legal status as of 14 September 2026; VAT rates and effective dates may change.
OSS is voluntary - you can also register locally in each EU member state. In practice, the OSS variant is typically much simpler: one quarterly return in Germany instead of 27 local pre-filings. Only in very specific constellations (e.g. a substantial local warehouse with B2B focus) can local registration bring advantages. Our consulting helps with the trade-off analysis.
The threshold refers to the cumulative net turnover from EU cross-border B2C deliveries plus EU-internal TBE services in the current and preceding calendar year. As soon as the value exceeds EUR 10,000 in either of those years, the destination-country VAT rate applies from the next sale (Section 3c UStG). You can also voluntarily waive the threshold and use OSS immediately.
For B2C sales via an EU marketplace, the merchant typically owes VAT and reports through Union OSS - unless a deemed-supplier constellation applies (non-EU merchant or import ≤ EUR 150). In that case the platform reports. Marketplaces typically provide detailed reports from which the tax liability can be derived. More on this in our marketplace integration article.
The quarterly return must be submitted by the last day of the following month - for Q2/2026 therefore by 31 July 2026 (Section 18j UStG). If the deadline is missed repeatedly, exclusion from the scheme is possible; turnover then has to be declared in each destination country, which is significantly more expensive and laborious. Errors in a return already filed are not cancelled but corrected within three years in a later return stating the tax period concerned.
Most ViDA deadlines fall in 2027-2030, but the preparation effort is substantial. Anyone planning a Shopware modernisation today should incorporate e-invoicing capabilities (Peppol/ZUGFeRD) and design interfaces to pass structured invoice data in real time. The DATEV mapping table should also anticipate the SVR extension of 2027/2028 so that later adjustments are possible without code changes.
OSS (One-Stop-Shop) is for sales within the EU - typically from a German warehouse to consumers in other EU member states. IOSS (Import-One-Stop-Shop) is exclusively for imports from third countries with an intrinsic value of no more than EUR 150 (Section 18k UStG). Anyone shipping from China or the UK directly to EU consumers uses IOSS; anyone storing goods in Germany and selling into other EU states uses Union OSS. Both schemes can be operated in parallel if both EU warehousing and direct-import models exist.