VAT Recapitulative Statement: a complete guide for 2026

The recapitulative statement (also known as an EC Sales List or VIES return) is a mandatory form that VAT-registered businesses must file in connection with certain transactions carried out with trading partners in other EU member states. It is one of the control mechanisms within the EU VAT system, allowing tax authorities in each member state to verify the accuracy of reported transactions.

Although the recapitulative statement applies to a relatively specific group of businesses, failure to file it — or filing it incorrectly — can result in significant penalties. In this article, we explain who must file the recapitulative statement, which transactions must be reported, what the deadlines are, and how to submit it correctly via the EPO portal of the Czech Financial Administration.

What the recapitulative statement is and why it exists

The recapitulative statement is a form in which a VAT payer lists supplies made to persons registered for VAT in other EU member states. The legal basis is Section 102 of Act No. 235/2004 Coll., on Value Added Tax (hereinafter the "VAT Act").

Purpose of the recapitulative statement

The EU VAT system operates on the principle that the supply of goods or services between businesses in different member states is exempt from VAT in the country of origin (with the right to deduct input tax) and taxed in the country of the recipient. To enable tax authorities to verify that the recipient has actually declared and paid VAT in the destination country, there is an information-exchange system based on recapitulative statements — the VIES (VAT Information Exchange System).

Who must file the recapitulative statement

The obligation to file a recapitulative statement applies to a VAT payer registered in the Czech Republic who, during the relevant period, carried out any of the following transactions.

The obligation applies to a VAT payer who:

1. Supplied goods to another EU member state to a person registered for VAT in that state, where the supply is exempt from tax with the right to deduct (Section 64 of the VAT Act)

2. Transferred business assets to another EU member state for the purposes of their business (Section 13(6) of the VAT Act)

3. Supplied goods to a purchaser under a triangular transaction (the simplified procedure under Section 17 of the VAT Act), acting as the intermediary in that transaction

4. Provided a service with the place of supply in another member state under Section 9(1) of the VAT Act to a person registered for VAT in another member state, where the recipient is liable to declare and pay the tax

Who does not need to file the recapitulative statement

• VAT payers who trade exclusively within the Czech Republic
• VAT payers who supply goods or services to non-VAT-registered persons in other member states (e.g. end consumers — these are subject to the OSS scheme or local VAT rules)
• VAT payers who, during a given period, have not made any transactions that need to be reported in the recapitulative statement (a nil return is not required)

Which transactions are reported in the recapitulative statement

Let's take a closer look at the individual types of transactions that must be included in the recapitulative statement.

1. Supply of goods to another EU member state

This is the most common type of transaction reported in the recapitulative statement. It covers the supply of goods to a person registered for VAT in another member state, exempt from VAT under Section 64 of the VAT Act.

Conditions for the exemption:

• The customer is registered for VAT in another member state and has provided their VAT number
• The goods were physically transported from the Czech Republic to another member state
• The supplier holds evidence of transport (shipping documents, recipient confirmation)

What to include in the recapitulative statement:

• The customer's VAT number (including country code)
• The total value of goods supplied in CZK
• Transaction code: 0 (standard supply)

2. Transfer of business assets

The transfer of goods that form part of a VAT payer's business assets from the Czech Republic to another member state for the purposes of their business. This typically arises when a VAT payer moves their own stock to a warehouse in another member state.

What to include in the recapitulative statement:

• The VAT payer's own VAT number in the destination country (their own registration in another member state)
• The value of the transferred goods
• Transaction code: 1

3. Supply of goods under a triangular transaction

A triangular transaction (triangulation) is a simplified procedure for chain transactions where goods are delivered directly from the first supplier to the final recipient, while invoicing passes through an intermediary.

Example: A Czech company (acting as the intermediary) buys goods from a German company and sells them to a Polish company. The goods travel directly from Germany to Poland.

What to include in the recapitulative statement:

• The final recipient's VAT number
• The value of the supply to the final recipient
• Transaction code: 2

4. Provision of services to another member state

Services provided to a person registered for VAT in another member state, where the place of supply is determined under Section 9(1) of the VAT Act (i.e. in the recipient's country) and the recipient is liable to declare the tax (reverse charge).

Typical examples:

• Consulting services
• IT services and software development
• Advertising services
• Translation and interpretation
• Accounting and legal services

What to include in the recapitulative statement:

• The service recipient's VAT number
• The total value of services provided
• Transaction code: 3

Deadlines for filing the recapitulative statement

The deadlines for filing the recapitulative statement differ depending on the type of transactions being reported.

Monthly filing (by the 25th of the following month)

The recapitulative statement is filed monthly, by the 25th day of the month following the reporting period. This applies to VAT payers who, during the relevant period:

• Supplied goods to another member state
• Transferred business assets
• Supplied goods under a triangular transaction

Example: For January 2026, the filing deadline for the recapitulative statement is 25 February 2026.

Quarterly filing (exception for services)

A VAT payer who only provides services to other member states (code 3) and does not supply goods may file the recapitulative statement quarterly, by the 25th day after the end of the calendar quarter.

Please note: As soon as a VAT payer supplies goods in any given quarter, they must file monthly returns for the entire quarter (i.e. separately for each month).

Filing deadlines for 2026

How to file the recapitulative statement via the EPO portal

The recapitulative statement must be filed exclusively in electronic form via the EPO portal (Electronic Filing for the Financial Administration) at the Czech Financial Administration website. Here is a step-by-step guide.

Electronic filing options

The recapitulative statement can be filed:

1. Via a data mailbox — by sending an XML file through your data mailbox to the relevant tax office
2. Via the EPO portal with an electronic signature — by completing and submitting the form directly on the portal using a recognised electronic signature
3. Via the EPO portal with a verified identity — by logging in via the Identity Citizen gateway (NIA)

Practical tips for completing the form

Customer's VAT number:

• Always include the country code (e.g. DE123456789 for Germany, PL1234567890 for Poland)
• Before filing, verify the customer's VAT number in the VIES system
• An incorrect VAT number is one of the most common mistakes

Value of the supply:

• Enter the amount in whole Czech crowns (CZK)
• For supplies of goods, enter the total consideration (excluding VAT, since the supply is VAT-exempt)
• For services, enter the total value of the service provided

Currency conversion:

• If you invoice in euros or another currency, convert to CZK using the Czech National Bank (ČNB) exchange rate applicable on the date the taxable supply took place
• Alternatively, you may use a fixed exchange rate if one is set out in your internal accounting policy

Amended and subsequent recapitulative statements

If you discover an error in a submitted recapitulative statement, you can file either an amended or a subsequent return.

Amended recapitulative statement

You can file an amended statement if the deadline for the original filing has not yet passed (i.e. before the 25th of the relevant month). The amended statement completely replaces the originally filed return.

Subsequent recapitulative statement

You file a subsequent statement if you discover an error after the filing deadline has passed. In the subsequent statement, you only report the changes compared to the original — corrected or new lines.

Deadline for filing a subsequent statement: within 15 days of discovering the error.

Penalties for non-filing or late filing

The Financial Administration may impose penalties for breaches of obligations related to the recapitulative statement.

Penalties under the Tax Code

• Failure to file the recapitulative statement: a fine of up to CZK 50,000
• Late filing: a penalty under Section 250 of the Tax Code — 0.05% of the assessed tax per day of delay (for the recapitulative statement, the penalty is derived from the value of incorrectly reported supplies)
• Incorrect data: if inaccurate information causes a VAT shortfall in the destination country, international cooperation may be triggered and additional obligations may be assessed

Connection with other tax obligations

The recapitulative statement is just one of the tax forms a VAT payer is required to file. It is important to understand how it relates to other obligations.

VAT return

Transactions reported in the recapitulative statement must also be included in the VAT return:

• Supply of goods to the EU → line 20 of the VAT return
• Provision of services to the EU → line 21 of the VAT return

The figures in the recapitulative statement and in the VAT return must match.

VAT control statement

The VAT control statement (Sections 101c–101k of the VAT Act) covers domestic transactions. Intra-Community transactions reported in the recapitulative statement are not included in the control statement — they are explicitly excluded from it.

Intrastat

If the volume of goods supplied to other member states exceeds a set threshold (check the current limit for 2026 on the Czech Statistical Office website), you are required to submit Intrastat declarations. The data in your recapitulative statement and your Intrastat reports should be consistent with each other.

Practical examples

Example 1: Supply of goods to Germany

A Czech company (VAT payer, VAT number: CZ12345678) supplies goods worth EUR 5,000 to a German company (VAT number: DE987654321). The goods are transported from the Czech Republic to Germany.

Recapitulative statement:

• Country code: DE
• VAT number: 987654321
• Transaction code: 0
• Value: EUR 5,000 converted at the ČNB rate on the date of supply (e.g. at a rate of CZK 25.20/EUR = CZK 126,000)

Example 2: Provision of IT services to Austria

A Czech programmer (OSVČ, VAT payer) provides software development services to an Austrian company (VAT number: ATU12345678) for EUR 3,000.

Recapitulative statement:

• Country code: AT
• VAT number: U12345678
• Transaction code: 3
• Value: EUR 3,000 converted at the ČNB rate

Example 3: Triangular transaction

A Czech company purchases goods from a Polish company (VAT number: PL1111111111) for EUR 10,000 and sells them to a Slovak company (VAT number: SK2222222222) for EUR 12,000. The goods travel directly from Poland to Slovakia.

Recapitulative statement:

• Country code: SK
• VAT number: 2222222222
• Transaction code: 2
• Value: EUR 12,000 converted at the ČNB rate (the value of the supply to the final recipient)

Frequently asked questions (FAQ)

Do I need to file a recapitulative statement if I am an identified person?

Yes. If you are an identified person and have provided a service with the place of supply in another member state to a VAT-registered person, you must file a recapitulative statement. However, identified persons do not report supplies of goods, as these generally do not apply to them.

What if I have no EU transactions in a given month?

A nil recapitulative statement is not required. If you have not made any reportable transactions during a given period, you simply do not file.

How do I convert an invoiced amount in euros to CZK?

Use the ČNB exchange rate applicable on the date the taxable supply took place (the date of delivery of goods or provision of services). If your internal accounting policy sets a fixed exchange rate, you may use that instead. Round the amount to the nearest whole crown.

Do I need to include received services from EU businesses in the recapitulative statement?

No. The recapitulative statement is only used to report supplies you make (i.e. goods or services you provide to EU businesses). Services you receive from EU businesses are reported in your VAT return under reverse charge, but they are not included in the recapitulative statement.

What if my customer does not have a valid VAT number?

If your customer does not have a valid VAT number registered in VIES, you cannot apply the VAT exemption when supplying goods to the EU. In that case, you must charge Czech VAT on the invoice, and the transaction is not reported in the recapitulative statement — instead, it is included in your VAT return as a standard taxable supply.

How do I correct an error in an already filed recapitulative statement?

If the filing deadline has not yet passed (the 25th of the month), you file an amended statement, which completely replaces the original. If the deadline has already passed, you file a subsequent statement within 15 days of discovering the error, including only the corrected lines.

Does the recapitulative statement apply to services provided via the OSS (One Stop Shop) scheme?

No. Services that you account for through the OSS scheme are not reported in the recapitulative statement. The OSS scheme covers supplies of goods and services to end consumers (B2C) in other member states, whereas the recapitulative statement covers B2B transactions.

Where can I find the recapitulative statement form?

The form is available on the EPO portal of the Czech Financial Administration. Go to the Czech Financial Administration website, navigate to the Electronic Filing (EPO) section, and search for the form "Souhrnné hlášení" (Recapitulative Statement). You can fill it in directly online, or prepare it in your accounting software and upload it as an XML file.

Tips for filing the recapitulative statement without errors

1. Verify your customers' VAT numbers — before every transaction, check VAT number validity in VIES
2. Keep proof of transport — for goods supplies, retain shipping documents as evidence that the goods were physically transported
3. Check consistency with your VAT return — the figures in the recapitulative statement must match lines 20 and 21 of your VAT return
4. Set reminders for deadlines — the filing deadline of the 25th of the month cannot be extended
5. Use the correct exchange rates — the ČNB rate on the date of supply, not the date of invoicing
6. Enter the correct transaction codes — confusing codes 0, 1, 2, and 3 is a common mistake