How to Complete and Submit an EC Sales List
A guide to the EC Sales List, detailing the reporting process for Northern Ireland businesses supplying goods to VAT-registered customers in the EU.
An EC Sales List, or ESL, is a report filed by businesses in Northern Ireland that details the sale of goods to customers who are registered for Value Added Tax (VAT) in an EU member state. Its function is to provide EU tax authorities with the data needed to verify that VAT is correctly handled on goods moving between Northern Ireland and the EU. This reporting requirement is a specific outcome of post-Brexit arrangements, applying only to businesses supplying goods from Northern Ireland, not those in Great Britain.
Determining Your Filing Requirement
A business must file an ESL if it is registered for VAT in the UK and supplies goods from Northern Ireland to a business registered for VAT in an EU country. This obligation is triggered when the goods are physically dispatched from Northern Ireland to an EU member state and the customer has provided a valid EU VAT registration number. The requirement covers standard business-to-business sales and other specific movements of goods.
These reportable transactions include call-off stock arrangements, where you move goods to a customer’s location in the EU, but the sale only occurs when they use the stock. Another scenario is triangulation, which involves a supply chain where goods are shipped directly from a supplier to a customer, while your business in Northern Ireland acts as an intermediary. Issuing a credit note to an EU VAT-registered customer for a prior supply of goods also triggers a filing requirement for that period.
The frequency of ESL submissions depends on the value of your supplies. The default filing period is quarterly, but this changes to monthly if the total value of your goods supplied to the EU exceeds £35,000 in the current or any of the previous four quarters. The deadline for online submissions is the 21st day following the end of the reporting period, while paper submissions are due by the 14th day.
Information Required for Submission
To complete an ESL, you must gather the following details for each EU customer you supplied goods to during the reporting period:
- Your customer’s valid EU VAT registration number.
- The corresponding two-letter country code for the customer’s member state.
- The total net value of the goods supplied to each customer, converted to sterling and excluding VAT.
- An indicator code, such as ‘0’ for a standard supply of goods or ‘2’ for triangulated sales.
Deduct the value of any credit notes from the total supplies for that customer. If this results in a negative value, that figure should be entered.
Before filing, verify your customers’ VAT numbers using the European Commission’s VIES (VAT Information Exchange System) online tool. This helps prevent errors that could lead to inquiries from tax authorities.
How to Submit Your EC Sales List
The primary method for submitting your ESL is through HMRC’s online service. This platform allows for either direct manual entry of sales information for each customer or the upload of a file, such as a CSV. To use the online service, you must log in to your Government Gateway account and navigate to the EC Sales List section.
After entering or uploading your data, the system provides a summary for review before final submission. Once you confirm the details are correct, you will receive an online receipt as proof of filing for your records. The online method is mandatory for businesses with a high volume of transactions.
Businesses eligible to file by paper must first contact HMRC to request a paper form. Once completed, it is mailed to the appropriate HMRC address. This option is less common and has an earlier deadline than the online route.
Correcting a Submitted ESL
If you discover an error on an ESL after it has been filed, you are required to correct it. Corrections are necessary for mistakes such as reporting an incorrect value of supplies, using the wrong customer VAT number, or omitting a transaction. Promptly addressing these inaccuracies ensures your VAT reporting remains compliant and accurate.
The method for correcting an error depends on how the original list was filed. If you filed online, you can amend the submission on the online service within 21 days of the original filing date. For errors found after 21 days, or for corrections to a paper submission, you must complete and send Form VAT101B, the ‘EC Sales List correction sheet’, to HMRC.