Washington’s temporary International Remote Seller Voluntary Disclosure Program is open from February 1 through May 31, 2026. It is designed for qualifying businesses headquartered outside the United States and the District of Columbia that have no physical presence in Washington and make retail sales directly to consumers. The program can limit uncollected retail sales tax to a one-year lookback and waive applicable penalties, but eligibility is fact-specific and the application must be submitted before Washington contacts the business for enforcement purposes.
The program does not automatically cover every international seller with Washington customers. Existing Washington registration or tax reporting, an enforcement contact, an affiliated business’s Washington audit or compliance contact, Washington inventory, or a U.S.-based affiliate may affect eligibility. Before applying, review the company structure, sales channels, marketplace records, warehouse arrangements, prior filings, and communications from the Washington Department of Revenue. The exact position depends on your circumstances—confirm with the state, or talk to Sales Tax Compliance USA and we will check it for you.
Key takeaways
- Washington’s temporary international seller VDP is open through May 31, 2026.
- The program generally targets qualifying international businesses with no Washington physical presence.
- Uncollected retail sales tax may receive a one-year lookback; other taxes can use a different period.
- Marketplace sales count toward Washington’s nexus analysis even when the marketplace collects the tax.
- Warehouses, affiliates, prior registration, and department contacts can change eligibility.
What is Washington’s international seller VDP?
Washington’s International Remote Seller Voluntary Disclosure Program is a temporary route for qualifying international remote sellers and international marketplace facilitators to come forward and address Washington tax obligations. The Washington Department of Revenue describes an international business for this program as one headquartered outside the fifty United States and the District of Columbia that does not have a physical presence in Washington.
The program is narrower than ordinary voluntary disclosure. The qualifying business must make retail sales directly to consumers, satisfy the program’s eligibility conditions, and apply during the stated application window. Relief is provided through a voluntary disclosure agreement, not simply by submitting a registration application.
The practical benefit is that the department may limit the period reviewed for uncollected retail sales tax to one year and waive specified penalties. Other Washington taxes, including taxes reportable on the combined excise tax return, may be subject to a different lookback under the program. Sellers should not assume that the one-year rule applies to every tax category.
When does the international seller VDP close, and who qualifies?
Applications for Washington’s temporary international remote seller program are accepted from February 1 through May 31, 2026. May 31, 2026 is the published closing date for applications. An application submitted after that window may not qualify for the temporary international-seller terms, so a business considering the program should not wait until the final day to assemble its records.
Generally, the applicant must be an international remote seller or international marketplace facilitator headquartered outside the United States and the District of Columbia, have no physical presence in Washington, and make retail sales directly to consumers. The business must also meet the department’s voluntary disclosure eligibility requirements, including not having an active Washington registration or having reported Washington taxes during the relevant period and not having been contacted by the department for enforcement purposes.
Eligibility can be affected by related entities. Washington has treated contact with an affiliated entity as relevant to voluntary disclosure eligibility in at least one tax decision. If a U.S. affiliate, parent, subsidiary, or commonly controlled company has operated in Washington or has been audited or contacted, obtain a fact-specific review before filing.
How Washington nexus applies to international sellers
Being located outside the United States does not by itself prevent Washington from requiring registration and tax collection. Washington treats a seller as having nexus when it has physical presence in the state or meets the state’s economic-nexus rules. The Washington Department of Revenue states that an out-of-state business must register to report business and occupation tax and collect and submit applicable sales or use tax when it has Washington physical presence, more than $100,000 in combined gross receipts sourced or attributed to Washington in the current or prior year, or is organized or commercially domiciled in Washington.
For remote sellers, Washington’s receipt calculation includes Washington retail sales made through a seller’s own website and sales made through a marketplace facilitator. Exempt sales are also included when measuring the threshold. A marketplace facilitator has separate collection responsibilities, but marketplace sales may still matter when determining whether the seller has reached Washington’s registration threshold.
For a plain-language explanation of the state’s threshold and sourcing rules, see our article on Economic nexus in Washington. Because Washington taxes can include both retail sales tax obligations and business and occupation tax reporting, a seller should review the entire activity rather than looking only at the tax charged at checkout.
When must an international seller register?
An international seller generally must register when it has Washington nexus, including physical presence or more than $100,000 in combined gross receipts sourced or attributed to Washington in the current or prior year. Washington’s Department of Revenue says the threshold applies to all Washington income, including retailing, wholesaling, services, and other activities. Once the threshold is met, the seller must collect and report for the remainder of the current calendar year and the following calendar year.
If the seller did not meet the threshold in the prior year, the collection obligation begins on the first day of the first calendar month that is at least 30 days after the date the seller became required to collect. The exact start date should be calculated from the seller’s records and Washington’s rules rather than estimated.
Marketplace collection does not necessarily eliminate every registration or reporting question. A marketplace facilitator may collect Washington sales tax on facilitated transactions, but the seller may still need to evaluate B&O tax, direct website sales, inventory, wholesale activity, exempt sales, and other Washington-connected activity. The state’s treatment depends on the facts and the records available.
How the one-year lookback works
For a qualifying taxpayer, the temporary program’s one-year lookback for uncollected retail sales tax means that the liability may be limited to the 12 months preceding the end of the assessment period. The exact position here depends on your own facts, so it is worth confirming with the state directly or talking to us about your situation.
This is a limitation on the period for uncollected retail sales tax; it is not a blanket rule that every Washington tax is limited to 12 months. The program page states that taxes reportable on the combined excise tax return use a separate lookback of four years plus the current year. A seller therefore needs to separate retail sales tax from B&O tax and other reportable liabilities when estimating exposure.
The one-year treatment also does not mean that a seller can omit sales records. Washington may require transaction data, marketplace reports, invoices, exemption documentation, inventory information, and other records needed to calculate the liability and verify the agreement.
What penalties and interest can the VDP waive?
The international program can waive penalties of up to 39 percent of the tax due. The Washington Department of Revenue identifies the potential penalty components as a 29 percent late-returns penalty, a 5 percent unregistered penalty, and a 5 percent tax-assessment penalty. The agreement and the facts determine which penalties are applicable and whether they are waived.
The program information also describes relief from interest for qualifying applications, but sellers should read the proposed agreement carefully because the treatment can depend on the type of tax and the circumstances. Collected but unremitted retail sales tax is especially sensitive. Washington’s general voluntary disclosure information states that collected and unremitted retail sales tax can have an unlimited lookback and that the late-payment penalty applies to those collected amounts.
Voluntary disclosure does not erase the underlying tax. The seller generally must register, calculate the tax, file the required returns or reports, and pay the amount required by the agreement. If a seller has already charged customers Washington sales tax and retained it, do not assume the temporary program will provide the same relief as it may provide for tax that was never collected.
How to apply, and whether the application can be anonymous
Washington requires voluntary disclosure requests to be submitted through its online application. The application should accurately describe the business, ownership and affiliates, Washington activities, sales channels, tax types, relevant periods, and any prior communications with the department. Prepare the records before applying so the disclosure can be complete and consistent.
A seller may begin the voluntary disclosure process anonymously, but Washington will not approve the application until the business identity is disclosed. The department’s voluntary disclosure FAQ states that an anonymous applicant has 15 calendar days to disclose its identity. If identity is not disclosed within that period, the application will not be approved and the business must reapply.
After the department prepares the voluntary disclosure agreement, the applicant must sign and return it within 30 calendar days of the original application date. Failure to return the signed agreement on time can result in nonapproval, and the business may then face the ordinary exposure associated with a longer lookback and applicable penalties. Anonymous pre-application discussions can be useful, but anonymity is not a permanent condition of the program.
What if the business is already registered or has a U.S. affiliate?
If the business is already registered with Washington or has reported Washington taxes, it may not qualify for the full voluntary disclosure benefits. The department’s general eligibility criteria require that the business not have had an active registration with or reported taxes to the department during the applicable lookback period. Registration status must be checked for the actual legal entity and relevant periods.
A U.S. affiliate can also matter even when the international seller itself has never registered. Washington’s voluntary disclosure rules and tax decisions make affiliated-entity contact a material issue. An affiliate that has been audited, contacted about registration or reporting, or operated as part of the same business arrangement may affect whether the international seller qualifies.
Do not treat separate company names as conclusive. Review ownership, control, intercompany services, inventory, fulfillment, shared personnel, shared accounts, and prior Washington correspondence. If a related business has already been contacted, the safer approach is to disclose that fact in the application or obtain advice before applying.
How warehouses and marketplaces affect eligibility
Inventory stored in a Washington warehouse can create physical presence and therefore affect nexus. The international program is intended for a business that does not have physical presence in Washington. Inventory owned by the seller and stored in the state may therefore make the seller ineligible for the international remote seller terms, even if all customer orders are placed through an online marketplace.
The result can depend on who owns the inventory, who controls fulfillment, when title transfers, which entity contracts with the warehouse, and whether the warehouse arrangement is attributable to the seller. Marketplace fulfillment records should be reviewed alongside warehouse agreements and inventory reports. Do not assume that a marketplace’s collection of sales tax removes the seller’s physical-presence issue.
Marketplace sales still matter for Washington nexus calculations. Rather than give you a figure that may not apply to you, we would check this against the state’s current guidance for your specific setup — ask us and we will tell you exactly where you stand. A seller should reconcile direct sales, marketplace sales, returns, exempt transactions, and facilitator-collected tax before deciding whether registration or disclosure is required.
International sellers can also use the Free U.S. Sales Tax Nexus Calculator for International Sellers (2026) and review the Free Tools for International Ecommerce Sellers for initial issue-spotting. These resources do not replace a review of the Washington agreement, entity structure, and fulfillment facts.
What happens after approval—or if Washington rejects the application?
After approval, Washington and the seller proceed under a voluntary disclosure agreement. The seller generally completes registration, provides the requested records, files the required Washington returns or reports, calculates the liabilities covered by the agreement, and pays the approved amount. The department may review whether the seller complied with the agreement and whether the disclosed activity was complete and accurate.
If Washington rejects the application, the temporary program’s special terms are not secured. Rejection may result from ineligibility, a prior enforcement contact, an existing registration or filing history, an affiliated entity issue, Washington physical presence, incomplete disclosure, failure to identify the business, or failure to return the agreement within the required period.
Rejection is not necessarily the end of the compliance process. The seller may need to register normally, address back taxes through another available process, or clarify the facts with the department. Washington’s general voluntary disclosure information warns that a business discovered through normal audit or investigation procedures may face tax for seven years plus the current year and penalties of up to 39 percent, so a rejected applicant should obtain a clear next-step plan promptly.
Washington international seller voluntary disclosure: key situations and likely effect
| Situation | Why it matters | What to verify before acting |
|---|---|---|
| International business with no Washington physical presence and qualifying direct-to-consumer retail sales | May fit the temporary International Remote Seller Voluntary Disclosure Program if all other conditions are met. | Headquarters, ownership, sales channels, prior registration, tax reporting, and department contacts. |
| Washington sales above the economic-nexus threshold | Can create registration, reporting, and collection obligations even without a physical location. | Combined Washington gross receipts, including marketplace sales and exempt sales used in the threshold calculation. |
| Inventory owned by the seller in a Washington warehouse | May create physical presence and may conflict with the program’s no-physical-presence requirement. | Inventory ownership, warehouse contract, fulfillment entity, and dates inventory was stored in Washington. |
| Marketplace facilitator collects Washington sales tax | May satisfy collection for facilitated transactions but does not automatically resolve B&O tax, direct sales, nexus, or registration questions. | Facilitator reports, direct website sales, tax-collected records, and Washington gross receipts. |
| Business already registered or filing Washington returns | May prevent eligibility for full voluntary disclosure benefits. | Legal entity registration history, prior returns, and periods reported. |
| U.S. affiliate has received a Washington audit or compliance contact | May affect eligibility because affiliated-entity contact can be relevant to voluntary disclosure. | Ownership, control, shared operations, correspondence, and the scope of the affiliate’s contact. |
| This one varies by seller and by state, and it is the kind of detail we check for clients as part of the service — get in touch and we will confirm where you stand. | Preserves the opportunity to seek the temporary international-seller terms, subject to approval. | Submission confirmation, complete identity disclosure, and timely signed agreement. |
| Uncollected retail sales tax covered by an approved agreement | May receive the program’s one-year lookback treatment and applicable penalty relief. | Whether tax was uncollected or collected and unremitted, and which tax categories are included. |
| Collected but unremitted Washington sales tax | May receive different treatment, including an unlimited lookback for collected amounts under general Washington guidance. | Customer tax collections, remittances, returns, and separate accounting for collected tax. |
Frequently asked questions
When does Washington’s international seller VDP close?
The temporary International Remote Seller Voluntary Disclosure Program accepts applications from February 1 through May 31, 2026. May 31, 2026 is the published closing date. Applications should be submitted early enough to allow identity disclosure, department review, and execution of the agreement.
Who qualifies for Washington’s international seller VDP?
The program is for qualifying international remote sellers and international marketplace facilitators headquartered outside the United States and the District of Columbia, with no physical presence in Washington, that make retail sales directly to consumers. The business must also satisfy the program’s voluntary disclosure conditions, including the requirements concerning prior registration, reporting, and enforcement contact.
Can I apply before Washington contacts my business?
Yes. Applying before Washington contacts the business for enforcement purposes is central to voluntary disclosure eligibility. A seller should apply before an audit, investigation, or compliance contact concerning registration or reporting, while recognizing that a prior contact involving an affiliate may also require review.
Can I apply anonymously for voluntary disclosure?
You may begin anonymously, but Washington will not approve the application until the business identity is disclosed. The department’s FAQ states that an anonymous applicant has 15 calendar days to disclose its identity; otherwise the application will not be approved and the business must reapply.
What if my business is already registered in Washington?
Existing registration or prior Washington tax reporting may prevent the business from qualifying for the full voluntary disclosure benefits. Review the legal entity’s registration and filing history before applying. The exact result depends on what was registered, what was reported, and the relevant periods.
What if I have an affiliated business operating in the United States?
A U.S. affiliate can affect eligibility, particularly if it has Washington operations or has received an audit or compliance contact. Washington has treated contact with an affiliated entity as relevant in a voluntary disclosure matter. Disclose the relationship and obtain a fact-specific review rather than assuming separate legal names resolve the issue.
Does inventory stored in a Washington warehouse affect eligibility?
It can. Seller-owned inventory in Washington may create physical presence, which conflicts with the program’s requirement that the international business have no physical presence in Washington. Review inventory ownership, warehouse contracts, fulfillment arrangements, and the dates involved before applying.
What happens if Washington rejects my application?
The temporary program’s special terms are not secured if the application is rejected. The seller may need to register normally, address liabilities through another process, or clarify the facts with the department. Do not ignore the issue, because ordinary enforcement can involve a longer lookback and applicable penalties.
Official sources
- https://dor.wa.gov/open-business/apply-business-license/voluntary-disclosure-program/international-remote-seller-voluntary-disclosure-program/international-remote-seller-voluntary-disclosure-program-frequently-asked-questions
- https://dor.wa.gov/open-business/apply-business-license/voluntary-disclosure-program
- https://dor.wa.gov/open-business/apply-business-license/voluntary-disclosure-program/voluntary-disclosure-program-frequently-asked-questions
- https://dor.wa.gov/taxes-rates/retail-sales-tax/marketplace-fairness-leveling-playing-field/remote-sellers
- https://dor.wa.gov/education/industry-guides/out-state-businesses-reporting-thresholds-and-nexus
- https://app.leg.wa.gov/rcw/default.aspx?cite=82.04.067
Related reading
- Voluntary disclosure agreement in Alabama
- Voluntary disclosure agreement in Illinois
- Voluntary disclosure agreement in Texas
- Economic nexus in Washington
- Our sales tax compliance services
Getting this handled
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Reviewed by Paul le Roux, CA(SA). Sales Tax Compliance USA handles US sales tax registration, filing and remittance for cross-border and domestic ecommerce sellers as a fully managed service.
This article is general information for educational purposes and does not constitute legal or tax advice. Sales tax rules change and depend on your specific facts. Consult a qualified tax professional about your own position.