ViDA Regulation 2026/1869: What OSS Users Need to Know

If you sell goods online from Estonia, Latvia or Lithuania, the Commission Implementing Regulation (EU) 2026/1869, which took effect on 17 August 2026, does not create any new e-invoicing obligation for your business. The European Commission adopted the regulation on 27 July 2026, and it spells out how ViDA (the VAT in the Digital Age package that brings EU VAT rules into the digital era) makes the Single VAT Registration system work behind OSS and IOSS, the schemes that let sellers report VAT on cross-border sales through one return instead of registering in every country they sell into. The first substantive changes land on 1 January 2027, and the main piece of the package, a new scheme for moving your own stock between member states, starts on 1 July 2028.

Does the Regulation That Took Effect on 17 August 2026 Create a New E-Invoicing Mandate?

Short answer: no. Regulation (EU) 2026/1869 is an implementing regulation: a technical instrument that fills in the operational detail behind a directive that’s already binding, rather than a law that adds duties of its own. Here, it fills in the detail behind Council Directive (EU) 2025/516, the ViDA directive adopted on 11 March 2025. It doesn’t hand your business any new obligation. The articles it amends, 47b, 47c, 47d and 47e of Implementing Regulation (EU) 2020/194, cover how tax authorities in different member states exchange information about the special VAT schemes. They say nothing about what you must send your buyers.

What Does Regulation (EU) 2026/1869 Actually Do?

It amends Implementing Regulation (EU) 2020/194, builds the administrative framework for the new own-goods transfer scheme, and lines up registration and reporting rules across the VAT special schemes. The changes come in two waves. Some registration data shifts on 1 January 2027. The core scheme-and-reporting rules follow on 1 July 2028.

What Changes in OSS and IOSS on 1 January 2027?

From that date, only distance sales that start from your own member state count toward the €10,000 small-business threshold. Sales shipped from a warehouse in another member state no longer count toward it. And member states lose the right to apply their own domestic rules on when VAT becomes chargeable to Union OSS and non-Union OSS transactions. The general EU rules take over instead.

How Will Moving Your Own Goods to Another EU Country Work From 1 July 2028?

From that date, member states must allow a voluntary scheme for transferring your own goods into another member state, known by its short name, TOOG, the transfer-of-own-goods scheme. Say an Estonian online seller ships stock to a fulfillment centre in Poland or Germany. TOOG covers every qualifying transfer of that seller’s own goods under a single registration, instead of forcing a separate VAT registration in the destination country. The scheme doesn’t apply where the destination country doesn’t grant full input VAT deduction on the goods in question.

What TOOG Doesn’t Solve, and What Still Needs Doing

TOOG doesn’t remove the need to register for activities the scheme doesn’t cover. And its VAT return can’t deduct VAT that arises in the origin or destination country; that still has to be claimed back separately, through the EU refund procedure. Every transfer needs an electronic record, kept for ten years counted from 31 December of the year the transfer happened, and produced on request.

Which Two Dates Apply to Call-Off Stock Arrangements?

New call-off stock arrangements can still be set up until 30 June 2028. Call-off stock means moving goods into another member state and selling them there later to a known buyer, without registering for VAT immediately. Arrangements started before that date keep running on their existing terms, but the provision disappears entirely on 30 June 2029.

A Checklist for Baltic Businesses, 2026–2028

• Map your warehouses: list every member state where you hold stock in a third-party warehouse or fulfillment centre.
• Separate B2C from B2B: TOOG only covers transfers of your own goods, not sales to end customers.
• Review existing call-off stock deals: check when each one started and when it runs out.
• Weigh TOOG against your input VAT position: the scheme won’t help if the destination country restricts deduction on your goods.
• Ask your accounting or OSS software provider: confirm they’re building for the 2027 and 2028 registration and reporting formats.

None of this brings mandatory e-invoicing to Estonia, or starts cross-border B2B digital reporting. That sits on a separate pillar of ViDA, resting on Directive (EU) 2025/516, and it runs on a later timeline than the OSS/IOSS technical setup covered here.