UK guidance sets no threshold for overseas digital sellers

The workload

A business with no UK establishment that sells digital services to UK consumers has to decide, sale by sale, whether UK VAT is due, and if so, register for it. Verified: the UK government's own guidance on digital-services VAT, retrieved 16 September 2026, states that if a business is making supplies of digital services to UK consumers, those supplies are liable to UK VAT, and that a business based outside the UK must register if its supplies are liable. No minimum sales figure appears in that instruction: the workload begins at the first liable sale, not after crossing a revenue line.

What the documents show

Verified: HMRC's own VAT Notice 700/1, first published 30 June 2016 and updated since, states that a non-established taxable person who makes taxable UK supplies regardless of their value and including supplies of digital services must register for VAT — confirming the zero-threshold rule names digital services specifically, not only goods. Verified: the same digital-services guidance separately instructs a UK-based business selling into the EU to register for the Non-Union VAT MOSS scheme in an EU member state, or register in each EU country individually — a different mechanism, run by the EU, not HMRC. The two regimes sit side by side under similar names, but a UK seller into the EU and a non-UK seller into the UK answer to different governments.

The operating cost

Neither page states a registration fee; UK VAT registration itself is free. Verified: the general VAT registration guidance states the standard UK threshold as £90,000 of taxable turnover for a UK-based business, then separately requires registration regardless of taxable turnover for a business based outside the UK that supplies any goods or services here. The real operating cost for an overseas digital seller is therefore the 20% standard VAT rate charged from the first UK consumer sale, not a threshold to plan around.

The stop condition

The guidance names the trigger for the obligation but not an exit from it: a non-established seller's registration duty continues for as long as it makes any liable supply to a UK consumer. The pages reviewed here describe no lower bound at which the obligation lapses, so any UK consumer sale of digital services is reason enough to check registration status.

• Is the seller established outside the UK, and does it make any digital-services sale to a UK consumer, however small?
• Is the separate EU non-Union VAT MOSS obligation being confused with the UK's own zero-threshold registration rule?
• Has UK VAT registration been checked independently of any EU OSS or MOSS registration, since the two are not interchangeable?

The UK's departure from the EU VAT area did not remove a founder's compliance burden in either market; it split one familiar mechanism into two separate ones that happen to share some vocabulary.