VAT and excise module
Why your refund intermediary does not reclaim everything
Published: 2026-09-24
Written by Vytautas Natys, managing director of UAB NVGroup.
A haulier using an excise refund service usually makes one assumption: if the intermediary handles the refund, then everything is being reclaimed.
The assumption is wrong, and not through any fault of the intermediary.
What the intermediary sees
A fuel card provider processes its own card transactions. It sees the purchase, the litres, the station and the date, because all of it passes through its system.
What it does not see: fuel bought in cash, on another card, in another supplier's network, or drawn from your own tank at your own depot.
Those litres never enter the refund claim — not once. Not through error, but because they simply are not in the data.
The second place — rates move
Excise refund rates change often, and not always predictably.
In 2026, one country's rate stood at about €0.109 per litre in January and February, fell to roughly €0.046 in March, and in April and May was suspended entirely — zero. The cause was a fuel price shock.
In another country, over the same six months, the rate moved between roughly €0.05 and €0.2 per litre, changing every quarter.
A report prepared after the period has closed can apply the wrong figure. The error is small on a single receipt, but it repeats across the whole period.
The third — regions
In France, the weighted flat rate was abolished on 1 January 2026. The value now depends on the region where the fuel was bought.
That means a single country holds several rates, and each has to be tied to the actual place of purchase, not to the country.
How to check it
By reconciling two sets of documents: your own fuel receipts and the intermediary's refund report for the same period.
The eligible litres present in the receipts but absent from the report are the unclaimed amount.
It is tedious work by hand — hundreds of receipts against an aggregated report — but mechanically simple.
What this check does not mean
Not that the intermediary is doing a poor job. They deliver what was agreed, with the data they hold.
The difference appears where their field of view ends. Only the party holding every receipt can close that gap — the haulier.
Frequently asked questions
Does this mean I should switch intermediaries?
No. The intermediary files the claims; reconciliation checks whether every eligible litre was claimed. Two different functions, and the second does not replace the first.
What if I do not have the intermediary's reports?
Then there is nothing to reconcile against — the entire result is the difference between two sets. Intermediaries normally provide these reports on request.
Can a claim be made retroactively?
It depends on the country: each has its own claim window, and they are not all measured the same way. That is why unclaimed litres are worth spotting early rather than years later.