UK fulfilment house due diligence scheme (FHDDS)

Produced by Tolley

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

  • UK fulfilment house due diligence scheme (FHDDS)
  • Background
  • Who needs to register for the scheme?
  • Northern Ireland
  • End of the Brexit transition period
  • How do you register for the scheme?
  • Approval procedure
  • Are there any additional compliance requirements?
  • Record-keeping requirements
  • Checks
  • More...

UK fulfilment house due diligence scheme (FHDDS)


This guidance note has been updated to reflect the VAT position for fulfilment houses in Great Britain from 1 January 2021.

If a business stores goods in the UK for sellers established outside of the UK, it may need to apply for the fulfilment house due diligence scheme (FHDDS). Details of the scheme and how to apply can be found below.

Who needs to register for the scheme?

Businesses that store goods where the following criteria apply will be required to register under the scheme:

  1. where the goods are imported

  2. the goods are owned by, or stored on behalf of, a person established outside of the UK

  3. the goods are being offered for sale and have not been sold in the UK previously

  4. the goods have been released into free circulation after being stored under a customs regime

Apply for the Fulfilment House Due Diligence Scheme

HMRC emphasises that businesses should register if they meet the relevant criteria even if they do not consider that they are a fulfilment house or are registered with HMRC for other schemes that requires the business to undertake due diligence in respect of its customers.

Businesses that undertake the following activities are not required to register under the scheme:

  1. the goods stored are owned by that business

  2. the main business activities are transporting goods and those goods need to be stored temporarily as part of the overall transportation services

Fulfilment Businesses Regulations 2018, SI 2018/326

These rules are also not applicable to goods that are stored under a customs arrangement and are therefore not in free circulation in the UK. However, businesses will need to apply when the goods are released into free circulation if it continues to store those goods and they’re still offered for sale.

Fulfilment houses that are required to register for the scheme must apply before they start to trade. Failure to apply before commencing trade will result in the business being denied the right to trade

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