Guidance

Apply for the Fulfilment House Due Diligence Scheme (Notice FH1)

Find out if you need to be registered to store goods in the UK for sellers established outside the EU.

If you store goods in the UK for sellers established outside the EU, you may need to apply for the Fulfilment House Due Diligence Scheme.

Once you’re approved:

  • you’ll be put on a register
  • you must keep certain records
  • you must carry out checks on your overseas customers and the goods you store

You’ll be charged penalties if you do not apply and register at the right time.

Businesses that must be registered

You need to be registered if your business stores any goods where all of the following apply:

  • the goods were imported from a country outside the EU
  • the goods are owned by, or stored on behalf of, someone established outside the EU
  • the goods are being offered for sale and have not been sold in the UK before

Businesses that are registered with HMRC for other schemes that require due diligence on customers must also register for this scheme if they meet these criteria.

You may not think you’re a fulfilment business, but you should still register if you carry out these activities.

Businesses that must not register

Do not apply if:

  • you own the stored goods
  • your main business is transporting goods and you need to store those goods temporarily (for example, overnight) as part of your transport services

The goods are stored under a customs regime and are not in free circulation.

You’ll need to apply when the goods are released into free circulation if you continue to store those goods and they are still offered for sale.

When to apply

When you start trading When you need to apply
Before 1 April 2018 On or before 30 June 2018
From 1 April 2018 to 30 June 2018 On or before 30 September 2018
From 1 July 2018 Before 1 October 2018 or before the date you start trading (whichever is later)

If your application is late, HMRC can charge you a penalty of up to £500. This could increase by up to £500 each month your application is late, up to a maximum of £3,000.

If your business is covered by this scheme you must be registered before 1 April 2019. If you are not, you:

  • will not be allowed to trade as a fulfilment business
  • risk a £10,000 penalty and a criminal conviction

How to apply

Under Regulation 3(1) and 4(1)(a) of The Fulfilment Businesses Regulations 2018, the next 2 bullets have force of law:

  • you must submit your application using the online service for the Fulfilment House Due Diligence Scheme
  • you must enter all information required by the application as specified by HMRC

If you’re not a sole trader, limited company or ordinary business partnership, you’ll need to contact HMRC to apply. You can email: indirecttax.projectteam@hmrc.gsi.gov.uk.

You cannot use an agent to apply on behalf of your business.

What you’ll need

You’ll need an:

  • organisation account if you’re a limited company or ordinary business partnership
  • individual account if you’re a sole trader

To apply, you need a Government Gateway user ID and password. If you do not have a user ID, you can create one when you apply.

To check your business details we’ll try to match them to an HMRC record that holds your Unique Taxpayer Reference (UTR).

This will be your:

  • company UTR as a limited company
  • Self Assessment UTR for an ordinary business partnership
  • individual Self Assessment UTR as a sole trader

You’ll also need to know:

  • the names of all business directors, company secretaries or partners, and either their National Insurance number, or if they are a non-UK resident, their passport number or national ID number
  • approximately how many customers, that your business currently stores goods for, are established outside the EU
  • the addresses of any storage premises in the UK used to store third-party goods imported from outside the EU, and whether these premises are operated by third parties
  • how long you’ve operated at your main business address
  • any previous addresses the business has operated from in the last 3 years
  • your business’s company registration number and date of incorporation (if you’re applying as a limited company)
  • the business’s UK VAT registration number (if it has one)
  • the names, VAT registration numbers or company registration numbers of any company officers, if they’re a company rather than an individual
  • any EORI number that the business currently uses

Amend or withdraw your application

Under Regulation 3(1), 5(1) and 4(1)(b) of The Fulfilment Businesses Regulations 2018, the next 2 bullet points have force of law:

  • you can amend your application at any time before HMRC has given their decision
  • you must submit any amendments to your application using the online service for the Fulfilment House Due Diligence Scheme

Tell HMRC about a change to your application using the online service.

Amended applications are treated as being received by HMRC on the date they’re resubmitted.

Withdraw your application using the online service.

What happens next

HMRC will check your:

  • application against their records
  • partners, directors and other key people involved in your business to make sure:
    • they’ve not been involved in or connected to significant revenue non-compliance or fraud within the last 6 years
    • any relevant criminal convictions have been spent
    • they’ve complied with HMRC requirements

Check the progress of your application.

HMRC’s decision

Under Regulation 3(2) and Regulations 6(1), 6(2), 6(3), 6(4) and 6(6) of The Fulfilment Businesses Regulations 2018, this section has force of law.

HMRC may ask for more information, or for permission to inspect your premises, on or by a specified date, to help process your application. If you do not give this information or allow the premises to be inspected by the specified date, your application will be treated as having been withdrawn.

HMRC will make any requests and tell you if your application has been approved or rejected using the secure messaging facility in your business tax account.

If your application has been approved, you’ll receive confirmation from HMRC which will include:

  • the unique reference number allocated to the approved person
  • the date from which the approval begins
  • any conditions or restrictions imposed on the approved person
  • a reference to the obligations imposed on approved persons under the law

If your application has been rejected, HMRC will tell you why.

When you’re registered

From 1 April 2019, you must keep a record of:

  • your overseas customers’ names and contact details
  • your overseas customers’ VAT registration numbers or their VAT exemption reference numbers
  • the type and quantities of goods stored in your warehouse
  • import entry numbers
  • the country where the goods are delivered
  • notices that you’ll need to give your overseas customers, which explain their tax and duty obligations in the UK

You must keep these records for 6 years. You can be charged a penalty of up to £500 if you do not keep these records.

What you must check

You must check all your overseas customers’ VAT registration numbers.

If your overseas customer is not required to be VAT registered, you should check their HMRC VAT exemption reference number.

HMRC will give more information on how to check these before 1 April 2019.

If you suspect your overseas customer has not met any of its VAT or customs duty obligations, you:

  • should work with them to help make sure they do in the future
  • must notify HMRC
  • must stop working with them if they do not start to comply with their obligations

There are penalties of between £500 and £3,000 if you do not.

Changes once you’re registered

Under Regulation 3(2) and Regulations 12(1), 12(2) and 12(3) of The Fulfilment Businesses Regulations 2018, the next 2 bullet points have force of law:

  • once you’ve been approved by HMRC any changes to your registered details must be submitted using the online service for the Fulfilment House Due Diligence Scheme
  • HMRC has specified that the registered details are the application information required in the online service for the Fulfilment House Due Diligence Scheme

You must tell HMRC about any changes to your registered details by 30 April 2019 or within 30 days of the change, whichever is later.

Change your registered details using the online service.

When you stop trading as a fulfilment business

If you stop trading as a fulfilment business, you must tell HMRC within 30 days from the date you stop trading.

Under Regulations 3(2) and 13 of The Fulfilment Businesses Regulations 2018, the next 2 bullet points have force of law:

  • you must tell HMRC that you’ve stopped trading using the online service for the Fulfilment House Due Diligence Scheme
  • HMRC has specified the information required in the online service for the Fulfilment House Due Diligence Scheme

You’ll no longer be approved to trade as a fulfilment business from the date you tell HMRC.

Cancel your registration using the online service.

Problems with the service

Check if there are any current problems with the service, or times it will not be available.

Contact HMRC

Contact excise enquiries with any queries you have about the Fulfilment House Due Diligence Scheme.

Published 6 November 2017
Last updated 25 October 2018 + show all updates
  1. Guidance on how to apply for the Fulfilment House Due Diligence Scheme has been updated.
  2. You can now cancel your registration or change your registered details using the online service.
  3. Link to contact VAT general enquiries replaced with excise enquiries.
  4. Guidance under heading 'Businesses that must be registered' has been updated.
  5. Page updated with link to new application service and further information what information you'll need to apply to register.
  6. Page has been updated to include text that has force of law. 'When you're registered' section amended to give more information about the records you need to keep from 1 April 2019.
  7. First published.