What must online marketplace operators do to verify VAT registration numbers under section 77E?

Under section 77E of the Value Added Tax Act 1994, online marketplace operators must take reasonable steps to check that any VAT registration number provided by or for a seller is valid. This includes verifying numbers supplied by the seller, third parties, or already displayed on the platform, ensuring the seller is genuinely VAT-registered with HMRC.

How long does an online marketplace have to display a valid VAT registration number?

The operator must display a valid VAT registration number within 10 days of receiving it. However, if the number is provided before the seller begins offering goods, the deadline is the later of the 10-day period or the end of the day the seller first offers goods for sale through the marketplace.

What happens when a displayed VAT registration number becomes invalid?

If an online marketplace operator becomes aware that a displayed VAT registration number is no longer valid—for example, because HMRC has cancelled the seller's registration—it must remove that number from the marketplace within 10 days of first becoming aware of the invalidity, regardless of how the number came to be displayed.

When is a VAT registration number considered valid under section 77E?

A VAT registration number is valid only if the seller is actually registered for VAT under the Value Added Tax Act 1994 and the number is the one genuinely allocated to that specific seller by HMRC. The number must be used in connection with the seller offering or proposing to offer goods through the marketplace.

Value Added Tax Act 1994 section 77E

Display of VAT registration numbers

Section 77E sets out the obligations on online marketplace operators to verify, display and remove VAT registration numbers of sellers using their platforms.

Online marketplace operators must take reasonable steps to check that any VAT registration number provided for a seller is valid and that any number displayed on the marketplace is valid.
A valid VAT registration number must be displayed on the marketplace within 10 days of receipt, or by the end of the day the seller first offers goods for sale, whichever is later.
If an operator discovers that a displayed VAT registration number is invalid, it must be removed from the marketplace within 10 days of the operator becoming aware of the problem.
A VAT registration number is only valid if the seller is registered under the VAT Act and the number is genuinely allocated to that seller by HMRC.

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