What is a merchant of record for EU digital sales?
A merchant of record is the company that legally sells to the buyer. It is named on the invoice, it takes the payment, it charges and remits VAT, and it is the party the consumer has rights against.
When you sell through a merchant of record you are not the seller in that transaction. You license your content to the merchant of record, and it sells that content to the buyer in its own name.
Why selling digital products into the EU raises the question
VAT on digital products sold to EU consumers is charged where the buyer is, not where you are. Three things follow from that.
Your product is probably an electronically supplied service
A pre-recorded course, an ebook, a template file: delivered automatically, with minimal human intervention. Live teaching is treated differently.
The rate is the buyer's rate
Twenty-seven member states, each with its own VAT rate. The rate that applies is the one where the buyer belongs, not where you are established.
You have to prove where the buyer is
Two pieces of non-contradictory location evidence, typically the billing address and the IP address, kept as part of the transaction record.
Registering for VAT in every member state is impractical, which is why the One Stop Shop exists: one registration, one quarterly return, covering sales into all member states. You still have to register, file on time, hold the location evidence and keep the records for as long as the law requires.
What a merchant of record takes on
- Being the named seller on the invoice
- Registering for VAT, charging the correct rate, and filing the returns
- Payment processing, and the cost of it
- Refunds, disputes and chargebacks
- Consumer-rights obligations, including the right of withdrawal on digital content
- Retaining the transaction records
What stays with you
- Your content, and your copyright in it. You license it, you do not sell it
- Your pricing, at or above the minimum net price
- Buyers who have already paid keep their access, even if you later leave the platform
What a merchant of record is not
It is not a marketplace. It does not bring you an audience and it does not market your product. You bring the buyer. It handles the transaction and the compliance that comes with it.
How Click2Pop does it
Click2Pop OÜ is an Estonian company, and the Merchant of Record and sole legal seller in every transaction. Buyers contract with Click2Pop, never with you. You license your content to Click2Pop and are paid a licensing fee: the net sale price less the Click2Pop margin of 7%. You never contract with the buyer and never receive buyer funds.
That 7% is all-in. No flat fee per sale, no setup fee, no subscription, no listing fee, no VAT filing surcharge. The processing cost is on us. It is already factored into our 7% margin. The only amount ever withheld beyond the 7% is the reversal of a sale that was later refunded.
Buyers may request a refund within 14 days of purchase, the EU legal minimum. Click2Pop alone decides every refund, and sellers cannot approve or refuse one. An approved refund revokes buyer access immediately.
Applying to sell takes 3 to 5 business days from application to active. The minimum product price is EUR 99 net, meaning the buyer price excluding VAT.
See the full pricing or apply to sell with Click2Pop.
Last updated: September 2026
What is a merchant of record for EU digital sales?
A merchant of record is the company that legally sells to the buyer. It is named on the invoice, it takes the payment, it charges and remits VAT, and it is the party the consumer has rights against.
When you sell through a merchant of record you are not the seller in that transaction. You license your content to the merchant of record, and it sells that content to the buyer in its own name.
Why selling digital products into the EU raises the question
VAT on digital products sold to EU consumers is charged where the buyer is, not where you are. Three things follow from that.
Your product is probably an electronically supplied service
A pre-recorded course, an ebook, a template file: delivered automatically, with minimal human intervention. Live teaching is treated differently.
The rate is the buyer's rate
Twenty-seven member states, each with its own VAT rate. The rate that applies is the one where the buyer belongs, not where you are established.
You have to prove where the buyer is
Two pieces of non-contradictory location evidence, typically the billing address and the IP address, kept as part of the transaction record.
Registering for VAT in every member state is impractical, which is why the One Stop Shop exists: one registration, one quarterly return, covering sales into all member states. You still have to register, file on time, hold the location evidence and keep the records for as long as the law requires.
What a merchant of record takes on
- Being the named seller on the invoice
- Registering for VAT, charging the correct rate, and filing the returns
- Payment processing, and the cost of it
- Refunds, disputes and chargebacks
- Consumer-rights obligations, including the right of withdrawal on digital content
- Retaining the transaction records
What stays with you
- Your content, and your copyright in it. You license it, you do not sell it
- Your pricing, at or above the minimum net price
- Buyers who have already paid keep their access, even if you later leave the platform
What a merchant of record is not
It is not a marketplace. It does not bring you an audience and it does not market your product. You bring the buyer. It handles the transaction and the compliance that comes with it.
How Click2Pop does it
Click2Pop OÜ is an Estonian company, and the Merchant of Record and sole legal seller in every transaction. Buyers contract with Click2Pop, never with you. You license your content to Click2Pop and are paid a licensing fee: the net sale price less the Click2Pop margin of 7%. You never contract with the buyer and never receive buyer funds.
That 7% is all-in. No flat fee per sale, no setup fee, no subscription, no listing fee, no VAT filing surcharge. The processing cost is on us. It is already factored into our 7% margin. The only amount ever withheld beyond the 7% is the reversal of a sale that was later refunded.
Buyers may request a refund within 14 days of purchase, the EU legal minimum. Click2Pop alone decides every refund, and sellers cannot approve or refuse one. An approved refund revokes buyer access immediately.
Applying to sell takes 3 to 5 business days from application to active. The minimum product price is EUR 99 net, meaning the buyer price excluding VAT.
See the full pricing or apply to sell with Click2Pop.
Last updated: September 2026