Do I Need to Register for VAT? EU Thresholds 2026
VAT registration thresholds across the EU in 2026 — Germany, France, Ireland, Netherlands, Italy, Spain — plus the new cross-border SME scheme explained.
“Do I need to register for VAT?” is the question every freelancer asks — and the honest answer is it depends on your country and your turnover, because there is no single EU threshold. This page gives you the verified 2026 numbers and, just as importantly, flags where the rules recently changed or nearly changed.
New to the mechanics? Start with our plain-English guide to VAT.
Is there one EU-wide threshold? No.
Each EU country sets its own domestic registration (or exemption) threshold, and they range from zero to €85,000. Below a country's threshold you can usually choose a small-business exemption: you charge no VAT and file no VAT returns, but you also cannot reclaim input VAT. Above it, registration is mandatory.
2026 domestic thresholds at a glance
The table below shows verified 2026 domestic exemption thresholds for several major countries. All figures should be confirmed against the national tax authority before you rely on them, because they change and many have sector splits.
| Country | 2026 small-business exemption threshold | Source / note |
|---|---|---|
| Germany (Kleinunternehmer) | €25,000 prior year / €100,000 current year (net) | §19 UStG, since Jan 2025; hard cutoff |
| France (franchise en base) | €85,000 goods / €37,500 services | CGI Art. 293 B; tolerance €93,500 / €41,250 |
| Ireland | €85,000 goods / €42,500 services | Revenue.ie (updated 06 May 2026) |
| Netherlands (KOR) | €20,000 turnover | No traditional registration threshold |
| Italy (regime forfettario) | €85,000 | Immediate exit above €100,000 |
| Spain | No threshold | All businesses register from the first sale |
Germany: the €25k / €100k Kleinunternehmer trap
Since 1 January 2025 the Kleinunternehmer thresholds are €25,000 net in the previous year and €100,000 net in the current year, and the €100,000 limit is a hard mid-year cutoff. Under §19 UStG, the moment your running turnover crosses €100,000, the very invoice that breaches it must include VAT — there is no waiting until next year. The figures are now net (the old €22,000/€50,000 pair was gross). Kleinunternehmer no longer file an annual VAT return but must still be able to receive e-invoices.
France: the reform that didn't happen
France kept its existing franchise en base thresholds for 2026 after the proposed single €25,000 threshold was abandoned. Throughout 2025 the government floated lowering the threshold to €25,000 for all activities; after strong opposition it was suspended and then dropped, with a law of 3 November 2025 confirming the status quo. For 2026 the thresholds are €85,000 (goods, restaurants, accommodation) and €37,500 (services and liberal professions), with tolerance ceilings of €93,500 and €41,250 (CGI Art. 293 B). Exempt invoices must carry the mention “TVA non applicable, article 293 B du CGI”. Because this was politically volatile, confirm the current position on service-public.gouv.fr before relying on it.
The outliers: Netherlands and Spain
The Netherlands has no classic registration threshold — it has the optional KOR exemption capped at €20,000 turnover — while Spain has no threshold at all. Under the Dutch kleineondernemersregeling (KOR), a business established in the Netherlands with turnover up to €20,000 can opt out of charging VAT (you must apply; it is not automatic). In Spain, every business is in the VAT system from its first sale — Spain and Turkey are the only European countries with no exemption threshold.
The new cross-border SME scheme (from 2025)
Since 1 January 2025, a small business with total EU-wide turnover under €100,000 can use the local VAT exemption in other member states, not just at home. Introduced by Council Directive 2020/285, the scheme works like this:
- Your total EU-wide turnover must stay under €100,000 (current and previous year).
- In each country where you want the exemption, you must also stay under that country's national threshold (member states may set these no higher than €85,000).
- You register once in your home country and receive a VAT number with an “EX” suffix.
- You file a single quarterly report covering your turnover across all 27 member states.
This is a genuine simplification for freelancers who serve clients in several EU countries but stay small — it removes the old need to register in each one.
Voluntary registration: when paying VAT is the smart move
Even below a threshold you can usually register voluntarily, which makes sense when your clients are VAT-registered businesses or when you have large deductible purchases. If your customers are businesses that reclaim VAT, charging it costs them nothing and lets you reclaim input VAT on equipment and software. If you mostly sell to consumers, staying exempt keeps your prices lower. The right answer depends on your client mix — and on whether the reverse charge applies to your cross-border B2B work.
Frequently asked questions
Is there one VAT registration threshold for the whole EU?
No. Each EU country sets its own domestic threshold, and they vary widely — from no threshold at all in Spain to €85,000 in Ireland, Germany and Italy. There is, however, a separate EU-wide cross-border SME scheme from 2025 that lets qualifying businesses with under €100,000 total EU turnover use the local exemption in other member states.
What is the German Kleinunternehmer threshold in 2026?
Since 1 January 2025 the Kleinunternehmer thresholds are €25,000 net in the previous calendar year and €100,000 net in the current year (§19 UStG). The €100,000 current-year limit is a hard cutoff: the invoice that crosses it must itself include VAT, with no grace period until the next year.
Did France lower its VAT threshold to €25,000?
No. A proposal to introduce a single €25,000 franchise en base threshold was repeatedly suspended and then abandoned; a law of 3 November 2025 confirmed the existing thresholds. For 2026 the thresholds remain €85,000 for goods/accommodation and €37,500 for services (with tolerance ceilings of €93,500 and €41,250).
What is the new EU cross-border SME scheme?
From 1 January 2025, under Council Directive 2020/285, a small business with total EU-wide turnover under €100,000 can use the VAT exemption in other member states where it stays below each country's national threshold. You register once at home, receive a VAT number with an “EX” suffix, and file a single quarterly report covering all 27 member states.
What to read next
- What Is VAT? A Plain-English Guide for EU Freelancers
What VAT is, how output and input VAT work, and what changes when you register — explained for EU freelancers and small businesses in 2026.
- Reverse Charge: Cross-Border EU B2B VAT Explained
Why you charge 0% VAT on services to EU business clients, the Article 44 and 196 rules, VIES checks, and the exact invoice wording to use in 2026.