ViDA Pillar 2 Platform Economy – businesses seek greater implementation clarity
The European Commission has circulated a second draft of its VAT in the Digital Age (ViDA) Explanatory Notes for the Platform Economy reforms, with Member States and business representatives welcoming the improvements while identifying several areas where additional clarification is still needed.
This includes focusing on the imposition of the (Deemed Supplier Mechanism DSM) on the platform economy. This Pillar becomes voluntary July 2028 and mandatory January 2030.
Focus shifts to practical implementation
With the Pillar 2 legislation now agreed, the latest discussions show that attention is turning to the practical operation of the new rules.
One of the key concerns raised was the obligation for underlying suppliers to provide a valid VAT registration number and declaration to platforms. Participants questioned whether the current guidance provides sufficient legal certainty and whether the requirement is fully supported by the VAT Directive.
Businesses also highlighted the practical challenge of validating VAT numbers across all 27 EU Member States. Many called for at least a 12-month implementation period for any new validation requirements unless a more harmonised EU-wide solution is introduced.
Further technical clarification requested for third draft
The second draft has prompted requests for additional guidance on several operational issues, including:
- The distinction between the existing intermediary rules under Article 28 and the new deemed supplier provisions in Article 28a.
- The application of the new Article 46a place-of-supply rules for platform facilitation services.
- Examples covering price reductions and SME scenarios.
- Which platform should be treated as the deemed supplier where multiple digital platforms participate in the same supply.
- Greater consistency in terminology throughout the explanatory notes.
The Commission is looking for further input, particularly around the interaction between Articles 28 and 28a, and invited businesses, platforms and other interested parties to submit further comments by the end of July 2026 before the next draft is prepared.
EU VAT in the Digital Age reforms
| EU VAT in the Digital Age | |
| 3 pillars to improve efficiency of VAT for all and reduce fraud | |
| 1. Digital Reporting Requirements; e-invoicing | Jul 2030-35: Mandatory digital reporting of intra-community transactions; obligation to be able to issue and receive intra-community e-invoices; member states free to impose own e-invoicing or real-time reporting but most conform to EU e-invoice standard EN 16931 |
| Read more about EU Digital Reporting Requirements (DRR) | |
| Structured e-invoices mandated for intra-community supplies | |
| EC Sales lists replaced by Digital Reporting Requirements | |
| 10-day e-invoicing deadline for intra-community sales | |
| 5-day e-reporting time limit intra-community purchases | |
| Withdrawal of EU permission requirements for e-invoicing | |
| Central VIES database launch | |
| 2 Platform economy | Jul 2028 / Jan 2030: Travel & accommodation sharing platforms to become deemed supplier / liable to users' VAT. New definitions of the roles of providers, users and platforms to avoid double and no-taxation (voluntary Jul 2028) |
| Read more - Travel & accommodation platforms deemed suppliers for EU VAT | |
| 3 Single VAT Registration; extension of OSS | July 2028: Following the 1 July 2021 introduction of the One Stop-Shop (OSS), extended to cover movement of own stocks prior to cross-border B2C to reduce the foreign, non-resident VAT registrations & returns. Plus to movements of own stock with ending of 'call-off' stock burden |
| January 2027 initial changes | |
| Transfer of own goods OSS extension | |
| Call-off stock VAT simplification ends | |
| Harmonisation of B2B Reverse Charge rules | |
| Creation of Single VAT Registration identiy | |
| Securing IOSS (Mar 2028) | |
