Recapitulative Statement (ZM), OSS, and Intrastat in EU Trade

Anyone selling goods or services across borders to customers in other EU countries not only has to pay tax on it but also has to report it through several channels.

In short: companies with intra-Community supplies, other cross-border services, or distance sales to EU consumers must file the recapitulative statement (Zusammenfassende Meldung, ZM) under Section 18a UStG by the 25th of the following month. Anyone using the One Stop Shop (OSS) files quarterly. From incoming goods of 3 million euros or outgoing goods of 1 million euros, the Intrastat report is also required.

Who is required to file the recapitulative statement, OSS, or Intrastat?

In principle, any company carrying out intra-Community supplies, cross-border services to businesses in the EU, or distance sales to private customers in other EU countries is required to report. For the ZM, every tax-exempt intra-Community supply and every reportable B2B service counts. For the OSS, online retailers and service providers selling goods or digital services to consumers in several EU countries are especially relevant. Intrastat only applies to companies whose incoming goods from the EU exceed 3 million euros or whose outgoing goods to the EU exceed 1 million euros in the calendar year. In practice, this mainly affects manufacturing businesses, wholesalers, and growing online stores whose EU business goes beyond occasional individual deliveries.

What is the difference between the recapitulative statement and the OSS procedure?

The recapitulative statement covers exclusively B2B transactions, meaning intra-Community supplies and certain other services to businesses in other EU countries, and is filed with the BZSt without any VAT being paid as part of it. The OSS, by contrast, bundles the VAT on B2C distance sales: instead of registering for VAT separately in every EU destination country, the company reports and pays the tax due in each country centrally through a single quarterly OSS return. The two reporting channels are not mutually exclusive and can exist side by side if a company does both B2B and B2C business in the EU.

What exactly do you need to do?

First, you need to cleanly separate your EU sales by type: intra-Community supplies, other services, and distance sales to consumers belong in different reports. Before every tax-exempt supply, you should have your business partner's VAT ID qualifiedly confirmed through the Federal Central Tax Office (Bundeszentralamt für Steuern, BZSt), since that is the only way to keep the tax exemption legally secure. For ongoing practice, it is also advisable to use accounting software or an ERP system that automatically separates EU sales by destination country and type of service, so that ZM, OSS, and Intrastat do not have to be filtered out of the financial accounts by hand. A tool like Company Audit shows at a glance which of these obligations specifically apply to your company.

By when and how often do you need to report?

The recapitulative statement must be filed through the BZSt portal by the 25th day after the end of the reporting period, generally monthly. The OSS report for distance sales to consumers is filed quarterly through the BZSt OSS portal. The Intrastat report is due monthly as soon as the relevant threshold, incoming goods of 3 million euros or outgoing goods of 1 million euros, is exceeded, and must then be continued for the entire calendar year.

What are the consequences of non-compliance?

If the recapitulative statement is not filed, filed late, or filed incorrectly, fines are possible, along with the retroactive loss of the tax exemption for the affected supplies, with corresponding risks of input tax adjustments and back payments. An unverified or incorrect VAT ID for the customer can also cost the supply its tax exemption. For OSS and Intrastat, missed or incomplete reports likewise lead to fine proceedings, and in the case of OSS, also to exclusion from the procedure.

Overview of the EU reporting process

1. Record your EU sales and sort them into intra-Community supplies, other services, and distance sales.
2. Verify the VAT ID of your EU business partners (qualified confirmation through the BZSt).
3. File the recapitulative statement by the 25th of the following month through the BZSt portal.
4. File the OSS report for distance sales to consumers on a quarterly basis.
5. Monitor the Intrastat thresholds (incoming goods 3 million euros, outgoing goods 1 million euros) and report if applicable.

Frequently asked questions

What is the recapitulative statement?

The recapitulative statement (Zusammenfassende Meldung, ZM) is a report under Section 18a UStG with which companies inform the BZSt of their intra-Community supplies and certain cross-border services. It is a prerequisite for the tax exemption of these transactions.

Who has to use the One Stop Shop (OSS)?

The OSS is voluntary but relevant for anyone making distance sales to consumers in several EU countries. It saves you from separate VAT registrations in every destination country, since a single, quarterly report is enough.

From when does the Intrastat reporting obligation apply?

The Intrastat reporting obligation kicks in as soon as incoming goods from other EU countries exceed 3 million euros or outgoing goods to other EU countries exceed 1 million euros in the calendar year. The thresholds for incoming and outgoing goods are checked separately.

Can a company have to file the ZM, OSS, and Intrastat at the same time?

Yes. A company can be required to file the recapitulative statement, the OSS report, and the Intrastat report at the same time if it carries out both B2B supplies and distance sales to consumers and exceeds the Intrastat thresholds.

What happens if the customer's VAT ID is invalid?

If the VAT ID is no longer valid or was not qualifiedly confirmed, the tax office can retroactively deny the tax exemption of the supply. A check before every supply through the BZSt is therefore advisable.

Source: Section 18a UStG, OSS Regulation. This article is general information and does not replace legal advice in individual cases. As of: July 2026.