While there is no output tax due , would there be a fine or penalty for late registration.
There is a minimum penalty of GBP 50 and furthermore: If you registered
Then the penalty rate will be
Not more than 9 months late 5%
More than 9 months but not more than - 18 months late 10%
More than 18 months late. 15% . Full details are in VAT Notice 700/41.
However, an appeal against any penalty will almost certainly be successful as, in your trade in zero rated supplies, there is no loss of revenue for the Department as you have no output tax to pay.
Thank you for your support.