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    Management & Growth

    E-commerce VAT 2026: OSS, IOSS and the SME Regime

    2026-05-08 15 min reading

    In Short

    "How VAT works for online sales to EU consumers in 2026 — €10,000 threshold, OSS through the Bulgarian NRA, IOSS for imports up to €150, the new SME regime for small businesses. Quarterly filing, country rates, common mistakes."

    Table of Contents

    If you sell goods or digital services to consumers (B2C) in other EU countries, VAT is now charged based on the customer's location, not yours. The distance-sales threshold is €10,000 per year EU-wide. Above it you have two options — register for VAT in each member state separately, or use the OSS (One-Stop Shop) regime and declare everything through the Bulgarian NRA. This guide walks through exactly when, how, and what you need to do.

    OSS in brief

    • €10,000 threshold EU-wide (combined B2C goods sales + digital services to consumers in other member states).
    • Below the threshold: charge Bulgarian VAT (20%) and pay it in Bulgaria.
    • Above the threshold: VAT is charged at the customer's country rate — register OSS in Bulgaria OR register VAT in each country separately.
    • OSS return: a single combined return for the whole EU, filed quarterly through the NRA.
    • IOSS — a similar regime for goods up to €150 imported from outside the EU.
    • SME regime (new from 2026) — VAT exemption in other EU countries for small businesses with EU-wide turnover up to €100,000.

    1The €10,000 threshold — how it's calculated

    The threshold is EU-wide — not counted per country. Since 2021 the single threshold replaced the old per-country thresholds (€35,000 / €100,000).

    What counts toward the threshold

    • • Distance sales of goods to consumers (B2C) in other EU countries.
    • • Digital services (TBE — telecom, broadcasting, electronic) to consumers in other countries.
    • • Excluded: B2B sales (your customers are companies with valid VAT numbers), domestic Bulgarian sales, sales outside the EU.
    The threshold is hard

    The moment you exceed €10,000 in the current or previous calendar year, you must switch to destination VAT from the next sale. You can't wait until year-end — that's why many online shops register for OSS preventively from the start.

    2Distance sales of goods

    When you sell physical goods to a consumer in another EU country and the goods are shipped there:

    Below €10,000 (EU total)
    • • Charge Bulgarian VAT (20%) on all sales.
    • • Declare in your regular Bulgarian VAT return.
    • • No registration in other countries.
    • • OSS not needed.
    Above €10,000
    • • VAT is charged at the customer's country rate (Germany 19%, France 20%, Greece 24%, etc.).
    • • Register for OSS in Bulgaria or for VAT in each country.
    • • Declare and pay through the NRA (with OSS).
    • • Distance sales of goods don't count toward Bulgarian turnover when registered for OSS.

    3Digital services (TBE) to consumers

    TBE services (Telecom, Broadcasting, Electronic) include: SaaS, online courses, e-books, music, video, subscriptions, downloadable software, hosting, platform services.

    TBE rules

    • • Place of supply = customer's location from the first euro (under the €10,000 threshold combined with goods).
    • • Below €10,000 exception: you can charge Bulgarian VAT.
    • • Location evidence: IP address, billing address, country of bank card, phone number. At least 2 non-conflicting pieces required.
    • • For B2B services (customer has a valid VAT number) — reverse charge, OSS not used.

    4Registering for OSS in Bulgaria

    OSS registration is done electronically through the NRA portal using a KEP or PIC. Steps and timing:

    1

    Submit application

    File the Union scheme registration application via the NRA portal. You must already have Bulgarian VAT registration under Art. 96 VATA.

    2

    Effective date

    Registration takes effect from the first day of the next quarter. That's why most sellers register preventively.

    3

    Quarterly filing

    By the end of the month following the quarter, file a combined OSS return — sales and VAT broken down by country.

    4

    Pay in euro

    VAT for all countries is paid in euro to a single NRA account at BNB. The NRA distributes it to each member state.

    5

    10-year archive

    You must keep records of all OSS sales for 10 years, available to any member-state tax authority on audit.

    5IOSS — imports up to €150

    IOSS (Import One-Stop Shop) is a special regime for distance sales of goods imported from outside the EU with a value up to €150 per consignment.

    When IOSS is useful

    • • You import goods from China, the US, Turkey, etc. for direct sale to EU consumers.
    • • Consignment value is under €150 (excluding shipping and insurance).
    • • Without IOSS: VAT is collected by the courier/customs on delivery → friction for the customer.
    • • With IOSS: VAT is included in the website price; the customer receives the parcel without extra fees.
    • • Consignments over €150 follow the standard customs regime (declaration + VAT + duty).
    Marketplaces (Amazon, eBay, Etsy)

    When you sell through a marketplace that facilitates the sale (deemed supplier), the marketplace usually collects and pays VAT itselfin the destination country. Your invoice to them is B2B reverse charge. Check the specific platform's terms.

    6The new SME regime (from 2026)

    From 1 January 2026, a special SME regime under the new Art. 96-99 VATA lets small businesses opt out of VAT registration in other member states as long as their turnover stays below:

    National threshold

    For Bulgaria — under €51,130 turnover for the current and previous year (the same threshold as mandatory VAT registration). Other countries set their own up to €85,000.

    EU-wide threshold

    Under €100,000 total EU turnover for the current and previous year.

    Small sellers can choose SME instead of OSS — no obligation to charge VAT in countries where SME is accepted, until they cross the thresholds. Watch for official NRA guidance on the registration procedure.

    7Common mistakes

    1. Not tracking the €10,000 threshold

    The threshold accumulates from 1 January. Once you cross it, every following sale to an EU consumer is at the destination rate. Set up automatic monitoring in your accounting or shop platform.

    2. Wrong destination VAT rate

    Each EU country has its own standard rate (~16-27% — Luxembourg 16%, Hungary 27%). Wrong rate means under-paid tax or over-collecting from the customer. Use automatic VAT tools (Shopify Tax, Stripe Tax, Octobat, Quaderno).

    3. Including B2B sales in OSS

    OSS is B2C only. Sales to companies with valid VAT numbers are reverse-charged and don't go in the OSS return.

    4. Skipping the quarterly OSS return

    A return must be filed even with zero OSS sales. Skipping triggers penalties and risks expulsion from the regime.

    5. OSS without Bulgarian VAT

    You can't register for OSS without basic Bulgarian VAT registration under Art. 96. A frequently forgotten prerequisite.

    6. Goods over €150 via IOSS

    IOSS is only for shipments up to €150. Above that the parcel goes through standard customs — you can't "split" it into smaller shipments.

    Calculate VAT for your EU sales

    Use our calculators to compute distance-sales VAT, EU registration thresholds, and turnover.

    EU VAT CalculatorVAT RegistrationVAT Calculator

    Useful resources:

    • • NRA OSS portal: portal.nra.bg
    • • EU VAT rates (current): ec.europa.eu/taxation_customs
    • • Art. 96-99 VATA — registration and SME regime.
    • • Art. 156a-156g VATA — Union scheme (OSS).
    • • Platforms with automatic VAT: Shopify, Stripe Tax, Quaderno, Octobat.
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