The new Fulfilment House Due Diligence Scheme (FHDDS) opened for online applications on 1 April 2018. The FHDDS is part of a package of measure to combat the abuse of VAT rules by online traders based outside the European Union.

Fulfilment houses that store any goods imported from outside the EU on behalf of others, need to apply for approval from HMRC. These businesses will be required to perform proper due diligence on the goods they fulfil and their overseas clients under the umbrella of the FHDDS.

Businesses that only store or fulfil goods that they own, or only store or fulfil goods that are not imported from outside the EU, are not required to register for the FHDDS. The deadline for applications from existing fulfilment businesses falling within the scope of the scheme is 30 June 2018. Businesses that start trading on or after 1 April to 30 June 2018, will need to apply on or before 30 September 2018. There are penalties for late applications.

Planning note

Businesses that meet the FHDDS criteria will not be allowed to trade as a fulfilment business from 1 April 2019, unless they are approved by HMRC and risk a £10,000 penalty and a criminal conviction if they do so.