Wisconsin Eliminates Exemption Certificate Requirement for Bullion Sales

Under 2025 Wisconsin Act 124, purchasers are no longer required to provide a certificate proving sales-tax exemption for transactions qualifying under Wis. Stat. § 77.54(74). The change shifts Wisconsin’s bullion exemption framework to a product-based standard, in which taxability is determined solely by whether the item meets the statutory definition of “precious-metal bullion,” rather than by purchaser documentation.

The legislation resolves a compliance inconsistency that arose following Wisconsin’s original bullion exemption enacted under 2023 Wisconsin Act 149 (which was effective March 2024). While the statute exempted qualifying bullion, general administrative rules required sellers to substantiate exempt sales, generally through exemption certificates. In practice, this led many dealers to treat certificates as a de facto requirement for retail bullion transactions.

Act 124 clarifies that no exemption certificates are required for sales qualifying under § 77.54(74). However, sellers remain responsible for maintaining sufficient records to demonstrate that any items sold meet the statutory definition of “precious-metal bullion.”

Under Wisconsin law, “precious-metal bullion” is defined as coins, bars, rounds, or sheets containing at least 35 percent gold, silver, copper, platinum, or palladium and that are marked with weight, purity, and content, or that are minted by a government authority on the basis of weight, purity, and content. The exemption does not extend to jewelry, works of art, scrap metal, electronics, or other tangible personal property containing precious metals.

Industry observers note that the change brings Wisconsin in line with the broader national trend among bullion-friendly states, with exemption eligibility determined by the intrinsic nature of the product rather than purchaser-provided documentation.

NCBA has updated its dealer resources accordingly. The organization’s “State-By-State Guide” and “Sales-Tax Status & Economic Nexus Requirements by State” have been revised to reflect the new requirements. These resources are available exclusively to dealer-members through the NCBA website at ncbassoc.org under Resources > State-By-State Guide and Resources > Knowledgebase > Sales and Use Taxes > Files, respectively.

For additional information, dealers are encouraged to consult the full statutory text or guidance issued by the Wisconsin Department of Revenue.