The one-sentence answer
Once you're over €10,000 in combined cross-border EU sales, you don't automatically have to register for OSS and start charging destination-country VAT — if your total EU-wide turnover is under €100,000 and you stay under each destination country's own SME threshold (capped EU-wide at €85,000), you can instead get a single "EX" registration in your home country and keep selling VAT-exempt in those countries — no VAT collected, no OSS filing.
This is a self-check aid, not tax advice. See the disclaimer at the bottom, and verify anything before you register or invoice.
Two different answers to "I'm over €10,000, now what?"
Both routes exist for the same moment — the point where your cross-border sales exceed the OSS de-minimis — but they solve it in opposite ways: one charges VAT and centralises the filing, the other skips VAT collection altogether below a second, higher set of thresholds.
| Aspect | Union OSS | Cross-border SME exemption |
|---|---|---|
| What happens to VAT | You charge destination-country VAT and remit it | You charge no VAT at all — the sale is exempt |
| Threshold to qualify | Applies once you're over €10,000 combined cross-border EU turnover | Total EU-wide turnover under €100,000, and under each destination country's own threshold (max €85,000, set per country) |
| Registration | One OSS registration in your home country, covers all destination countries | One prior notification in your home country → single "EX" number, valid in every member state where you use it |
| Ongoing filing | Quarterly OSS return, VAT payment each quarter | Quarterly turnover report to your home country (no VAT payment, because there's no VAT to remit on exempt sales) |
| Who it fits | Sellers whose cross-border turnover has grown past small-scale — OSS is built to scale with volume | Small sellers who are over €10,000 cross-border but still genuinely small overall (under €100k EU-wide) — the exemption is capped, not built to scale past it |
| In force since | Union OSS: 1 July 2021 | Domestic SME exemptions: pre-existing; the cross-border extension: in force EU-wide from 1 January 2025, with cross-border access rolling out per member state (live in the Netherlands and most member states from 28 January 2026) |
They are not mutually exclusive across your whole business — you could run OSS for some destination countries and the SME exemption for others, though most sellers who qualify for the SME exemption use it everywhere they can, since it's strictly less filing than OSS.
How the cross-border SME exemption actually works
Every EU country already runs a domestic small-business VAT exemption for its own resident sellers. Until 2025, that exemption stopped at the border — a Dutch freelancer under the Dutch small-business scheme still had to charge French VAT (or use OSS) the moment they sold to a French consumer. Council Directive (EU) 2020/285 extended that domestic exemption across borders: a business established in one member state can now also apply the small-business exemption to sales made into other member states, not just its own.
Two thresholds gate it, both measured over the current and previous calendar year:
- €100,000 EU-wide — your total turnover across all 27 member states must stay under this to use the cross-border exemption anywhere.
- Each destination country's own national threshold — every member state sets its own small-business threshold, capped by the directive at a maximum of €85,000. You must also stay under that specific country's threshold to sell VAT-exempt into it — a lower national threshold in one country doesn't block you elsewhere.
If both hold, you file one prior notification with your own country's tax authority. It issues a single "EX" identification number valid in every member state where you use the exemption — you never register separately in each destination country. Ongoing compliance is a single quarterly turnover report to your home authority (not a VAT return, since there's no VAT collected on exempt sales); the whole registration process is meant to take no longer than 35 working days.
Which one am I likely looking at?
- Under €10,000 combined cross-border EU turnover? Neither — charge your home country's VAT rate. Use the calculator to watch the running total.
- Over €10,000, and your total EU-wide turnover is also under €100,000 (and under €85,000 in the specific countries you sell into)? You likely qualify for both — the SME exemption is usually the lighter-weight option (no VAT collected, no OSS return), but OSS remains available if you'd rather charge VAT than lose the input-VAT recovery the exemption gives up.
- Over €10,000, and your total EU-wide turnover is over €100,000 (or over €85,000 in a specific destination country)? The SME exemption isn't available to you there — OSS (or per-country VAT registration) is the route.
Worth knowing before you pick: the SME exemption means you can't reclaim input VAT on costs tied to those exempt sales, same trade-off as any domestic small-business VAT exemption. If you have significant EU cross-border input VAT to recover, OSS (which lets you charge and therefore reclaim) may work out better even when you qualify for the exemption.
Open the €10,000 threshold calculator → · Do I even need OSS? (6-question guide)
Next steps
- The €10,000 OSS threshold calculator — enter your cross-border transactions, see exactly where (if anywhere) you cross.
- Do I need to register for OSS? — a 6-question decision guide.
- OSS vs IOSS — a different fork: which scheme applies to which kind of sale.
- 3 worked examples of how the running total plays out, transaction by transaction.
- What changes on 1 January 2027 — the ViDA OSS threshold change.
- Official source: the European Commission's cross-border SME scheme page.
Disclaimer
This page and the calculator are a self-check aid, not tax advice or a filing system. The cross-border SME exemption has country-specific rollout dates, sector-specific thresholds in some member states, and registration mechanics this summary simplifies. Verify your own eligibility and the current threshold for each destination country against the EU Commission's SME VAT rules portal or an accountant before registering, invoicing, or relying on exempt status.