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ROI, VIES and EU VAT numbers

How to check a Spanish VAT number on VIES: guide for online sellers

Reviewed on 9 min readConsult GlobalLex team

VIES is the European register of operators where you verify your customer's VAT number before invoicing an exempt intra-community supply. The VIES response, obtained by consulting with your own VAT number, serves as evidence before the Spanish tax authorities. If the number is not valid, or you do not include the transaction in Form 349 (modelo 349), the supply is taxable and not exempt in Spain.

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The problem

When you sell goods to a business in another EU Member State and ship them out of Spain, you can invoice without Spanish VAT, but only if specific conditions are met. One of them is that your customer is a business or legal entity with a VAT number from another Member State and has given that number to you. That number is checked on VIES, and this is where many sellers go wrong: they invoice without VAT because they trust what the customer typed into a form or an email.

The consequence is serious. Under article 25 of the Spanish VAT Act (LIVA) and the Spanish tax authority (AEAT) page on identifying EU operators, if a valid VAT number is missing or you do not include the transaction in Form 349 (modelo 349), the supply is taxable and not exempt in Spain. In practice, that means charging the standard rate of 21%, or bearing it yourself if you have already invoiced without VAT.

There are three requirements for an exempt intra-community supply. First, the goods must be transported to another Member State. Second, the buyer must have a VAT number from another Member State and must have communicated it to you. Third, you must include the transaction in Form 349. A VIES check covers the second requirement and leaves you with documentation to defend it if anyone questions it.

The other side of the problem is your own number. For your European customers to validate you on VIES, you need a VAT number, which is your Spanish tax ID (NIF) with the prefix ES. You obtain it by registering in the Register of Intra-Community Operators (ROI, or Registro de Operadores Intracomunitarios). There is also a common confusion about the Canary Islands, because for VAT purposes they are not treated as EU territory. This guide explains how to run the check and what to do with the result.

Who is affected

  • Marketplace sellers with a company or a self-employed registration on the Spanish mainland or in the Balearic Islands who sell to businesses in other EU countries and want to invoice without Spanish VAT.
  • Foreign entrepreneurs with a company in Spain who buy from or sell to European business partners and need to validate their counterparties.
  • Businesses that need their own Spanish VAT number, with the ES prefix, to show as valid on VIES so they can trade with EU customers or suppliers.
  • Companies and self-employed people based in the Canary Islands who are unsure whether they need ROI registration, VIES or Form 349 for their transactions.

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Step by step

  1. Ask your customer for the full VAT number, in writing

    Before issuing the invoice, ask the customer for their full VAT number exactly as it appears in their registration, and keep that communication. The exemption requires the buyer to have communicated their number to you, so it is wise to keep a record that they did.

    If your customer is a final consumer or a business without a VAT number, this exemption route does not apply and you need to analyse the transaction under a different rule.

  2. Check the number on VIES

    Go to the European Commission VIES service and enter your customer's VAT number. Check that the result confirms the number and that it belongs to the business you are actually dealing with.

    If the result does not validate the number, do not invoice as an exempt intra-community supply until you have clarified it with the customer. Invoicing without VAT on an invalid number leaves the transaction taxable and not exempt.

  3. Keep evidence of the check

    The AEAT states that the VIES response, obtained by consulting with your own VAT number, serves as evidence before the tax authorities. In practice, it is sensible to store the result of each check alongside the invoice, with the date on which you ran it.

    It is also sensible to repeat the check from time to time if you have recurring customers, so that you do not keep invoicing without VAT to someone whose number is no longer in force.

  4. Invoice and report the transaction

    Once the number is validated and the transport to another Member State is documented, you issue the invoice as an exempt intra-community supply. You must then include the transaction in Form 349 (modelo 349), because without it you lose the exemption. In the VAT return, Form 303 (modelo 303), these supplies go in box 59.

    For the way Amazon fees work in the same returns, see Amazon seller fees reverse charge: Spain VAT return 303 and 349.

  5. Check your own VAT number too

    Your VAT number is your tax ID with the prefix ES, and it comes from registration in the ROI, which is requested with Form 036 (modelo 036), box 582, stating in box 584 the expected date of your first transaction. If your number does not show as valid on VIES, your European customers will not be able to verify you.

    If you are not registered yet, read Spanish intra-community VAT number: ROI registration step by step. If you are setting up a business from abroad, see Set up a company in Spain as a foreigner: requirements and steps.

  6. If your business runs through the Canary Islands, a different rule applies

    For VAT purposes the Canary Islands are third territory. A sale from the Canary Islands to the mainland is an export exempt from the Canary Islands general indirect tax (IGIC), and on the mainland it is an import with a customs declaration (DUA) and import VAT. It is not an intra-community transaction, so it is not reported in Form 349 and is not validated on VIES.

    If that is your situation, read Selling on Amazon from the Canary Islands: IGIC, Form 420, deadlines and Importing from China to Spain: import VAT, DUA and Form 303.

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Deadlines

Monthly Form 349 (intra-community supplies validated on VIES)
Within the first 20 calendar days of the following month; July, until 20 September. The last period of the year, until 30 January. · source
Quarterly Form 349 (if, neither in the quarter nor in the 4 preceding ones, intra-community supplies and services exceed €50,000)
Q3 2026: 20/10/2026. Q4 2025 was filed by 30/01/2026. · source
Decision on an application for ROI registration
3 months; without a decision, it may be treated as refused (negative administrative silence, not approval). · source
Issue of the intra-community operator tax certificate (procedure G312)
20 days; disagreement with its content: 10 days. · source

Common mistakes

Invoicing without VAT on the strength of the number the customer gave you, without checking it on VIES.

Validate the VAT number before issuing the invoice and keep the result. If a valid VAT number is missing, the supply is taxable and not exempt in Spain, at 21% VAT.

Having the number validated but forgetting to include the transaction in Form 349.

Include every exempt intra-community supply in the Form 349 for the relevant period. Without Form 349 the exemption is lost even if VIES confirms the number.

Treating sales between the Canary Islands and the mainland as intra-community supplies.

Remember that the Canary Islands are third territory for VAT. Those transactions are exports and imports with a DUA, and they never go in Form 349 or rely on VIES.

Assuming that once you have filed Form 036 you already have a VAT number and can start trading.

ROI registration can take up to 3 months and, if the AEAT does not decide, the application may be treated as refused. Confirm that your number validates on VIES before agreeing exempt transactions.

Keeping a ROI registration for years without using it.

If you have made no intra-community transactions in 12 months, you must request deregistration. The AEAT can also deregister you of its own motion in certain cases.

30-second mini diagnostic

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Do you sell to consumers in other EU countries?
Do you hold stock in warehouses outside Spain (e.g. FBA)?
Is your company in the Canary Islands?
Do you import goods from China?
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Indicative result based on general rules; it does not replace advice on your case.

Frequently asked questions

My own VAT number does not appear on VIES. What should I do?

Check whether you are registered in the ROI, which is requested with Form 036. If the application is still pending, the AEAT has 3 months to decide and its silence counts as a refusal. You can also request the intra-community operator certificate, which is issued within 20 days.

My EU supplier is under a small-business scheme and has no VAT number. Do I have to report the purchase as an intra-community acquisition?

According to the AEAT, a purchase from an EU supplier under a small-business scheme, with no VAT number, is not a taxable intra-community acquisition in Spain. Even so, it is sensible to keep documents that show the supplier's status.

I have a company in the Canary Islands. Do I need the ROI and VIES for purchases from European suppliers?

The ROI is intended for businesses established on the mainland and in the Balearic Islands. If you receive services from suppliers not established in the Canary Islands, you self-assess IGIC under the reverse charge in Form 420 (modelo 420) with the Canary Islands Tax Agency (ATC), with no Form 349. Before applying for the ROI, you should be able to justify which specific transaction you will carry out in the VAT territory.

Does VIES help me sell to private individuals in other EU countries?

No. The intra-community supply exemption requires the buyer to be a business or legal entity with a VAT number. Distance sales to consumers follow a different scheme, with a threshold of €10,000 a year across the whole EU. We explain it in EU distance selling threshold of 10,000 euro: Spain OSS guide.

When must I deregister from the ROI?

You must request deregistration if you have made no intra-community transactions in 12 months. It is requested with Form 036, box 583. The AEAT can also deregister you of its own motion, for example if it has been unable to notify you for more than 1 year after 3 attempts.

Official sources

Consult GlobalLex team

Tax, accounting and legal advisers for Amazon and marketplace sellers, foreign founders and Canary Islands companies in Spain. Registered social collaborator of the Spanish Tax Agency (AEAT) and Social Security (TGSS).

Drafted with AI assistance and checked, fact by fact, against the official sources cited. Reviewed on 21 October 2026.

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