Fiscal representatives and EORI numbers for non-EU brands

An EU EORI number is needed to import, export or declare goods in the EU, and any UK brand doing that needs one. A fiscal representative is a separate requirement: some EU countries make a non-EU business appoint one for VAT, and which ones do, and under what conditions, varies by country.

Last checked: 7 November 2026. The country rules below are reported inconsistently even among advisers, so check directly with the relevant tax authority before you rely on one.

The pain points

• "Our accountant says we need a fiscal representative in one EU country and not in another, and I can't tell if that's the actual rule or just caution."

• "We registered for an EORI number and still got asked for a separate VAT registration in a different country."

• "I don't know if using IOSS gets us out of appointing a representative, or only for some of our sales."

• "A supplier told us the rules changed for 2026 and now I don't know what used to be true and what's current."

• "Nobody can tell me in plain English what a fiscal representative actually does, versus what our accountant already does."

What an EORI number is, and who needs one

An Economic Operators Registration and Identification (EORI) number is mandatory for customs operations in the EU customs territory, under European Commission guidance. An EU EORI is separate from a UK EORI, and you may need both if you trade both ways.

A UK company with no EU establishment registers for an EU EORI with the customs authority of the member state where it will first lodge a customs declaration, apply for a customs decision, or otherwise carry out its first customs operation, not a country of its own choosing. Once issued, the EU EORI works across every member state, the same number for a declaration lodged in any of them. Our guide to the EU's €3 customs duty on low-value parcels covers the related declaration types for low-value EU imports.

What a fiscal representative is, and why it isn't an EU-wide rule

The EU VAT Directive (2006/112/EC), Article 204, lets member states allow or require a non-established taxable person to appoint a tax representative as the person liable for the VAT. That's permissive at EU level, so each country sets its own rule rather than following one EU-wide requirement. Article 205 lets a member state make someone other than the primary VAT debtor jointly and severally liable for the VAT, which is the legal basis for a fiscal representative taking on joint liability for your VAT debt in that country.

This is different from "indirect representation" for customs declarations, a separate question about who may lodge a customs entry on your behalf, and from a plain accountant who files your returns without taking on the VAT debt themselves.

Why this differs by country

Exactly which EU countries require a fiscal representative for a UK business, and under what conditions, is hard to pin down from outside. Professional advisers disagree with each other on more than one country's rule, including whether the UK qualifies for an exemption in France, Spain or Poland, and even on the general requirement itself in the Netherlands and Poland. These rules have also changed more than once since 2021. Rather than repeat a claim that's disputed even among advisers, confirm your position directly with the relevant country's tax authority or a locally qualified VAT adviser before you register anywhere.

IOSS and when it changes the picture

IOSS lets you declare and pay import VAT once a month in one member state, for distance sales of goods valued €150 or less per consignment. A seller established outside the EU generally can't register for IOSS directly and needs an EU-established intermediary, who takes on the IOSS filing, and usually joint liability, on their behalf. That role is specific to IOSS and distance sales under the threshold, not a general fiscal representative covering everything you do in the EU.

UK sellers using IOSS must appoint an EU-established intermediary, the same as sellers from most other non-EU countries. Norway is the only non-EU country exempt from that requirement, through its VAT mutual assistance agreement with the EU. Either way, IOSS only ever covers the import VAT on qualifying low-value distance sales. Hold stock in an EU warehouse, sell B2B, or sell above €150 a consignment, and those activities sit outside IOSS and fall back on whichever member state's ordinary fiscal representative rule applies.

The 2026 customs reform doesn't change this, so far

Regulation (EU) 2026/2108 creates a new Union Customs Code and a European Union Customs Authority, in force from 20 September 2026 and applying generally from 21 September 2027, with the EU Customs Data Hub mandatory for ecommerce sellers from 1 July 2028. The European Commission's own reform guidance doesn't mention EORI, fiscal representation or IOSS changes, so don't assume the reform touches any of the rules above until that's confirmed otherwise.

What to ask a customs broker or tax adviser

• Do we need an EU EORI for what we're doing, and which member state should issue it?

• In each EU country where we hold stock, sell B2B, or sell above the IOSS threshold, does that country require a fiscal representative for a UK business?

• If a representative is required, what do they take on, and what stays our responsibility?

• Does our use of IOSS remove the need for a representative for our distance sales, or only for consignments under €150?

• How do we check this is still correct if a country's rule changes?

Our recommendation: check each country you trade in, not the EU as a whole

1. List every EU country where you hold stock, register for VAT, or sell above the IOSS threshold.

2. For each one, ask that country's tax authority or a locally qualified adviser directly whether a fiscal representative is required for a UK business in your situation.

3. Get an EU EORI number if you don't have one, from the member state where you'll first lodge a declaration.

4. If you use IOSS, confirm with your adviser whether you can register directly or need an EU-established intermediary.

5. Put a reminder in your calendar to recheck this each year, since more than one country's rule has moved recently.

What waiting costs

Appointing the wrong structure, or none, in a country that requires one can block your VAT registration, hold up stock at the border, or leave you jointly liable for a VAT bill you didn't expect.

These figures are made up to show the method. A brand holding stock in two EU countries pays a fiscal representative €150 a month in each, €3,600 a year, to stay compliant. Getting this wrong in just one of those countries, and having a VAT registration suspended for even a month while it's fixed, can hold up VAT recovery on a far larger value of stock than the representative ever cost. These figures are made up to show the method.

People Also Ask

Does every EU country require a fiscal representative for non-EU businesses?

No. EU law only gives member states the option to require one, under Article 204 of the VAT Directive, so each country sets its own rule. Some require it for any non-EU business registering for VAT, some only in specific situations, and this varies enough that you should check the specific country rather than assume one answer applies everywhere.

Is a UK company exempt from needing a fiscal representative because of the Brexit trade agreement?

Not as a blanket rule. A few countries report an exemption from their fiscal representative requirement for businesses from countries with a mutual-assistance arrangement, and advisers differ on whether the UK currently qualifies in each case. Confirm this with the specific country's tax authority rather than relying on a general assumption.

Does using IOSS mean I don't need a fiscal representative at all?

Only for the distance sales IOSS actually covers: consignments valued €150 or less, sold direct to consumers. If you hold stock in the EU, sell B2B, or sell above that threshold, those activities fall outside IOSS and are governed by the ordinary fiscal representative rule of whichever country you're trading in.

Finding the right EU fulfilment partner

Logan, FulfilQ's advisor on the website, matches brands to verified providers by order volume, product type and region. Tell Logan which EU countries you sell into or hold stock in, and you get a shortlist to ask about fiscal representation, EORI and IOSS before you commit. Start at fulfilq.com and Ask Logan, or Submit an RFP and verified providers come back to you. You can also browse the full provider directory.