Understanding VAT verification requirements

European VAT law places the burden on suppliers to verify that their customers possess valid VAT registration before applying zero-rate treatment to cross-border goods shipments. This requirement stems from Council Directive 2006/112/EC and has been reinforced through European Court of Justice decisions establishing that businesses must exercise due diligence proportionate to the circumstances of each transaction. While no specific verification method is mandated, using the official VIES system or equivalent national services demonstrates reasonable care that tax authorities generally accept.

The consequences of inadequate verification can be severe. When a supplier cannot demonstrate that they verified a customer's VAT number and the customer turns out to be unregistered or involved in fraudulent activity, the supplier may lose the right to zero-rate the supply. This means retrospectively applying domestic VAT to transactions that were invoiced without tax, potentially turning profitable sales into loss-making ones when the customer refuses to pay the additional amount. In serious cases, tax authorities may also impose penalties and interest on the underpaid VAT.

The VIES validation system

The VAT Information Exchange System, commonly called VIES, provides the primary mechanism for verifying EU VAT numbers across member state borders. Maintained by the European Commission's Directorate-General for Taxation and Customs Union, VIES connects to the VAT registration databases of all 27 member states, allowing real-time queries against current registration status. The system is available through a web interface accessible to any user without registration or fees.

To perform a VIES validation, navigate to the official European Commission VIES portal. You will encounter a form requesting the member state and VAT number of the business you wish to verify. Select the appropriate country from the dropdown list and enter the VAT number without the country prefix, as the system adds this automatically based on your country selection. Some versions of the interface accept the full number including prefix, but consistency in entry method helps avoid errors.

After submitting the query and completing any security verification such as CAPTCHA challenges, VIES returns one of several possible responses. A valid result confirms that the VAT number is currently registered in that member state's database. Most countries also return the registered name and address associated with the number, though the level of detail varies. Germany, notably, does not provide name and address through VIES due to domestic data protection interpretations, requiring alternative verification methods for German VAT numbers.

An invalid result indicates that the number does not exist in the member state's database, has been cancelled, or was never issued. However, invalid results require careful interpretation. Technical synchronisation delays mean newly registered numbers may not appear immediately in VIES. Temporary database unavailability can cause false negative results. Some countries restrict VIES access during maintenance windows. Before concluding that a number is genuinely invalid, consider re-checking after 24-48 hours and contacting the customer to request confirmation directly from their tax authority.

Step-by-step VIES verification process

The following workflow represents best practice for VIES verification that satisfies most tax authority expectations for due diligence documentation:

First, obtain the complete VAT number from your customer in writing. This might come through a purchase order, registration form, or formal correspondence. Ensure you receive the two-letter country prefix along with the numeric or alphanumeric sequence. Common formatting issues include missing prefixes, incorrect prefixes not matching the country of the business, additional characters like spaces or hyphens that must be removed, and transcription errors in handwritten documents.

Second, check the format against known patterns for that member state before submitting to VIES. If a German number contains letters or has more than nine digits after the DE prefix, something is wrong before you even query the system. Our VAT formats reference provides the expected structure for each country.

Third, access the official VIES portal through the European Commission website. Avoid third-party verification services that may charge fees for what is freely available, may not provide legally sufficient confirmation, or may store and misuse the data you submit. The official URL is published by the European Commission and ends in the europa.eu domain.

Fourth, enter the VAT number carefully and submit the query. If verification is successful and returns name and address information, compare these details against what your customer has provided. Minor variations in address formatting are normal, but if the registered name is completely different from your customer's company name, investigate further before proceeding.

Fifth, document the verification. Save or print the VIES response page showing the result, date, and time of verification. Store this with your sales documentation for the transaction. Many businesses automate this process, using APIs to query VIES when creating invoices and storing results in their ERP systems.

When VIES verification fails

Receiving an invalid or unavailable result from VIES does not automatically mean your customer is fraudulent. Several legitimate explanations exist for verification failures, and understanding these helps distinguish genuine issues from system limitations.

New registrations may not yet appear in VIES. After a business completes VAT registration with their national tax authority, there can be a delay of days or even weeks before the number propagates to the central VIES database. If your customer claims recent registration, request a copy of their registration confirmation from the tax authority and check VIES again after a suitable interval.

Technical problems affect VIES periodically. The system depends on connections to 27 separate national databases, and outages in any member state make verification impossible for that country until service resumes. The VIES website displays current availability status for each member state. If the country you need shows as unavailable, wait and try again rather than proceeding without verification.

Some member states restrict VIES access during database updates. Germany, for instance, performs overnight maintenance that can cause queries to fail during certain hours. French numbers sometimes return errors during tax return processing periods. Understanding these patterns helps avoid unnecessary concern when encountering temporary failures.

Suspended or cancelled numbers also return invalid results. A business might have valid registration that was suspended for non-filing of returns or cancelled for cessation of activities. In these cases, the number genuinely should not be accepted for zero-rated supplies, and you should request an alternative valid number or treat the sale as domestic with VAT charged.

National verification alternatives

Several member states operate national VAT verification services that provide information beyond what VIES offers or serve as fallback options when VIES is unavailable. These national services often return more detailed information but typically require understanding the local language or navigation conventions.

Germany operates the Bundeszentralamt für Steuern confirmation service, which provides qualified confirmation of VAT numbers including the registered business name and address. Unlike VIES queries for German numbers, this service returns full identification details. The process requires submitting a request with your own VAT number and receiving a formal confirmation letter, which provides stronger documentation than standard VIES checks.

France maintains the service de vérification des numéros de TVA through the Direction générale des Finances publiques website. This service confirms registration status and displays the registered business name associated with the number. The interface is in French but straightforward to navigate.

Italy's Agenzia delle Entrate provides VAT number verification through its online services portal. Results include registration status and the fiscal code linked to the VAT number, useful for cross-referencing against other documentation.

Spain's Agencia Tributaria offers the sistema de información sobre IVA that verifies Spanish VAT numbers and returns basic registration information. The service integrates with the broader Spanish tax administration portal.

The Netherlands maintains the BTW-nummer check through the Belastingdienst website, providing confirmation of Dutch VAT registrations with associated business information from the Handelsregister commercial registry.

Poland's Ministerstwo Finansów operates the Wykaz podatników VAT, commonly called the White List, which not only confirms VAT registration but also displays bank account numbers that businesses must use when making payments to avoid losing input VAT deduction rights.

Documentation and record-keeping

Maintaining proper records of VAT verification serves two purposes: demonstrating due diligence if the transaction is later questioned by tax authorities, and supporting your own claims for input VAT deduction where you are the customer in cross-border purchases.

For each verification performed, records should include the VAT number checked, the date and time of the check, the result returned including any name and address information, the method used such as VIES or a specific national service, and identification of the person who performed the check. If using automated systems, ensure logs capture equivalent information with reliable timestamps.

Retention periods for VAT records vary by member state but typically range from five to ten years from the end of the tax period to which the transaction relates. Many businesses apply the longest applicable period across all jurisdictions where they operate, simplifying compliance at the cost of additional storage requirements.

When verification produces an unexpected result, document the follow-up actions taken. If you contacted the customer for clarification, record the communication and response. If you rechecked after a delay, document both the initial and subsequent results. If you obtained alternative confirmation through a national service, keep that documentation alongside the failed VIES check.

Common verification errors and solutions

Input format problems cause many verification failures. Ensure you remove all spaces, hyphens, and periods from VAT numbers before querying VIES. While some formats include letters that should be uppercase, VIES generally handles case conversion automatically. The country prefix should not be repeated if the interface adds it automatically based on country selection.

Country code confusion arises particularly with Greece, which uses EL in its VAT numbers rather than the ISO country code GR. Similarly, Northern Ireland VAT numbers for certain purposes use the XI prefix following Brexit, distinct from the GB prefix that applied to pre-departure UK numbers.

Transposition errors represent the most frequent human mistake in VAT number handling. The difference between DE123456789 and DE123456798 is easy to miss visually but produces completely different verification results. Double-checking numbers against original documentation before and after verification catches these errors.