UK fulfilment house due diligence scheme (FHDDS)

By Tolley

The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • UK fulfilment house due diligence scheme (FHDDS)
  • Background
  • Registering for the scheme
  • Compliance
  • List of approved entities


The Government announced in Budget 2016 that they were going to consult on introducing an FHDDS. The consultation has closed and the new legislation has been included in Finance (No 2) Act 2017 , cls 48–59, Sch 13. These clauses and Schedule set out an approval scheme for fulfilment businesses that store goods for persons who are not established in the EU and those goods have not been supplied in the UK and are offered for sale in the UK or elsewhere. The scheme does not affect businesses where the storage is ancillary to the transportation of those goods.

When the new legislation is introduced, a person may not operate a fulfilment business unless HMRC is satisfied that he is a ‘fit and proper person’ to carry on the business, and the business is included in a register of approved persons. HMRC has the power to lay down conditions and restrictions with regard to its approval.

Secondary legislation provides details of the records and due diligence checks that a fulfilment business will be required to maintain and carry out. HMRC announced that it has modified a number of aspects contained in the original consultation document regarding the record-keeping and due diligence requirements and they have been reduced to the minimum required in order to operate the scheme effectively.

Please use the following link to access a copy of the Fulfilment house due diligence scheme  consultation document and summary of responses.

HMRC has released a policy paper that provides details of the new scheme that came into effect in 2018 and details of the scheme are provided below.

The government has also published the relevant legislation that governs the due diligence scheme that has been implemented. A brief overview of the relevant legislation, together with a link has been provided below.

This SI states the detailed rules for operation

More on Registration: