Briefing Document & Podcast: E-Invoicing & E-Reporting in Ireland

• Domestic B2B: Included. All domestic transactions between VAT-registered businesses will require e-invoices once the mandate is in effect for that business. Large companies must e-invoice domestic B2B sales starting Nov 2028, with smaller companies joining by Nov 2029 if they trade across EU borders. This means Irish suppliers must issue a compliant electronic invoice for any taxable B2B supply to another Irish business (or public body – see B2G below) once their phase kicks in. [bdo.ie]
• Domestic B2C: Not included in mandatory scope. There is currently no requirement for electronic invoicing in purely business-to-consumer sales. E-invoicing remains voluntary for B2C transactions – businesses may issue e-invoices to consumers by agreement, but it is not mandated by law. Consumers (private individuals) are generally not obliged to receive structured e-invoices. Regular till receipts or invoices can continue for B2C, and the mandate does not force electronic reporting of each B2C sale at this stage. (Retailers will still report aggregate B2C sales in their VAT returns as today.) [basware.com]
• Domestic B2G (Business-to-Government): Partially included. Since April 2019, Irish public bodies must be able to receive and process e-invoices in the European standard format (EN 16931), and this applies to central, regional, and local authorities. However, until now suppliers were not legally obliged to send electronic invoices to public bodies – it was voluntary for vendors. The new mandate does not explicitly single out B2G as a separate phase, but in practice B2G transactions will fall under the domestic B2B mandate. In other words, when a business is required to e-invoice its domestic B2B customers, this will include any public-sector customers as well. All Irish government agencies are already on the Peppol e-invoicing network and can receive e-invoices, so B2G invoicing will be facilitated by the same system. There is still no immediate obligation on all suppliers to government to e-invoice until the phased B2B rollout compels them (unless they choose to use e-invoicing earlier on a voluntary basis). [ec.europa.eu], [ec.europa.eu] [ec.europa.eu] [ey.com]
• Intra-EU B2B (Cross-border within EU): Included. Cross-border B2B transactions (intra-Community supplies and acquisitions) are a core focus of the mandate. From July 2030, any Irish business selling to or buying from VAT-registered businesses in other EU Member States must use structured e-invoices and real-time reporting for those sales. This is required under the EU “VAT in the Digital Age” (ViDA) Directive, which Ireland will implement fully by 2030. Notably, complying with the e-invoicing system will be a condition for maintaining the zero-rated VAT treatment on intra-EU supplies of goods – businesses that don’t issue the required e-invoice/report could lose the 0% VAT exemption on cross-border sales. (The VIES declaration of EU sales will be abolished once real-time invoice reporting is in place.) Phase 2 of Ireland’s plan (Nov 2029) already brings in all firms engaged in intra-EU trade, meaning by that date such firms must e-invoice all their domestic B2B transactions as a preparation for the EU-wide mandate. In summary, intra-Community B2B supplies and acquisitions are firmly in scope – Irish suppliers must issue e-invoices for sales to EU customers, and Irish buyers will similarly receive e-invoices for purchases from EU suppliers (with data reported to tax authorities in real time). [revenue.ie], [revenue.ie] [deloitte.com] [revenue.ie] [bdo.ie] [ey.com]
• Imports and Exports (Extra-EU): Currently out of scope of the mandate. The present initiative is driven by EU requirements and focuses on intra-EU trade and domestic transactions. There has been no announcement that exports to non-EU countries or imports from non-EU vendors must be reported in real time via e-invoicing. Exports of goods outside the EU will continue to be zero-rated under existing rules; Irish exporters will still need to issue invoices (or commercial documents) to foreign customers, but those are not yet mandated to be in EN16931 e-invoice format for Irish VAT purposes. Similarly, imports of goods will follow normal customs and VAT procedures (e.g. customs declarations, postponed VAT accounting), not an e-invoice from the foreign supplier. That said, Irish businesses may choose to use the same e-invoicing systems for consistency or efficiency even when dealing with non-EU partners, but these transactions are not subject to the compulsory real-time reporting in Ireland. The primary scope of mandatory reporting is EU-related trade; any extension of real-time reporting to imports/exports has not been detailed as of the latest legislation.

• Self-billing: Yes, included. Self-billing is when the customer, rather than the supplier, issues the invoice (common in certain industries and arrangements). Irish VAT law permits self-billing provided the supplier agrees in advance, certain content conditions are met, and the invoice is marked “self-billing”. Under the new system, self-billed invoices are expected to be treated like any other invoice – i.e. if the transaction itself is in scope (a B2B supply), the fact that the customer prepares the invoice does not exempt it from e-invoicing. The buyer-issued invoice would need to be in the required electronic format and submitted to the tax authority in real-time. In practice, the customer (as the self-biller) will have to use the e-invoice platform to issue the invoice to themselves and report it to Revenue. The same content rules (all mandatory fields) apply, plus the invoice must be endorsed with “self-billing” to indicate the arrangement. The supplier must explicitly accept the self-billed invoice for it to be valid, but once accepted, the Revenue considers it as if issued by the supplier. In summary, self-billing arrangements are not excluded from the mandate – they must be handled through the e-invoicing system, with proper notation and prior agreement as per current rules. [revenue.ie]
• Triangulation transactions and chain transactions: Yes, included. Triangulation refers to a three-party cross-border transaction (A sells to B, who sells to C, with goods shipped from A to C) that qualifies for a simplification under EU VAT law. These are essentially a subset of intra-EU B2B transactions, so they fall under the e-invoicing mandate. Each leg of the transaction requires an invoice, and under current law these invoices must include specific wording to claim the triangulation simplification. For example, an Irish supplier involved in a triangulation must indicate on the invoice “EU triangulation simplification – buyer liable for VAT” or similar. Under e-invoicing, such requirements remain; the structured invoice will have fields for VAT treatment, and the seller B’s invoice to C should explicitly reference the triangulation scenario. Tax authorities will receive the data from all three invoices across the involved countries in real time, improving their ability to detect any omissions. Similarly, more complex chain transactions (with multiple intermediaries) are treated as a series of B2B supplies – each taxable supply between VAT-registered parties in the chain would need an e-invoice if the parties are within scope (domestic or EU B2B). In short, triangulation and chain transactions are within scope. The e-invoice must contain the usual details (including the VAT numbers of buyer and seller and any required notations like “reverse charge” or “triangulation simplification” as applicable). The real-time reporting will capture these transactions, likely eliminating the separate EC Sales List reporting of triangulation today. There is no carve-out for chain transactions – they will be reported through the same system with appropriate indicators. [revenue.ie]
• Special VAT regimes (margin schemes, travel agents, etc.): Included (with existing invoice rules). The mandate does not exclude supplies under special VAT regimes, but such invoices must comply with the special content rules those regimes entail. For example, under the margin scheme (used for second-hand goods, art, collectibles, etc.), VAT is not shown on the invoice; instead the invoice must be endorsed with “margin scheme – second-hand goods” (or applicable category). Similarly, travel agents’ margin scheme invoices and auctioneer’s margin scheme invoices should be annotated appropriately and not show VAT amounts. These requirements will continue – the e-invoicing format will allow for indicating a special regime. Businesses using these regimes will still need to issue e-invoices (since they are taxable dealers issuing invoices to other businesses). The only difference is that the “VAT amount” field would be zero or blank (since VAT is not separately charged) and a note field would contain the required legend (e.g. “Margin scheme – travel services”). There is no suggestion that such transactions are exempt from reporting; on the contrary, they will be reported with the rest, ensuring visibility of margin scheme usage. [revenue.ie]
  Other special cases: If a supply is exempt from VAT, an invoice may or may not be required under current rules (many B2B exempt supplies do require invoices). If required, under e-invoicing it will still be issued (with VAT rate “0%” or “Exempt” indicated). If a special scheme like the flat-rate farmers scheme applies, the unregistered farmer doesn’t issue VAT invoices – instead, the purchaser issues a “flat-rate addition” invoice (a form of self-billing) showing the 5.4% flat-rate amount. Those purchaser-issued invoices too would fall under e-invoicing if the purchaser is within scope. In general, no specific exemptions from the mandate have been announced for particular sectors or regimes. Taxable persons who are required to issue invoices under VAT law will have to do so electronically once the system is live for them, regardless of the VAT treatment (standard rated, zero-rated, exempt, margin scheme, etc.). The content and format will accommodate the special notes (for example, an e-invoice can include a “reverse charge” notation or margin scheme note just as a paper invoice does). [legalblog.ie] [revenue.ie] [revenue.ie], [revenue.ie]

• Established entities (Irish-established businesses): In scope. All businesses established in Ireland that are registered for VAT will fall under the e-invoicing requirements according to the phased timeline. This includes companies, partnerships, sole traders, etc., that have an Irish VAT number (often referred to in Irish law as “accountable persons”). Under current rules, an accountable person must issue a VAT invoice for any taxable supply to another taxable person or certain other recipients. The mandate leverages this obligation: those invoices will need to be electronic and reported. Large Irish-established companies will be first in line (Phase 1), but eventually all Irish VAT-registered businesses making B2B supplies will be required to issue e-invoices and submit them to Revenue. There is no exclusion by industry sector – manufacturers, wholesalers, service providers, etc., are all included if they are VAT-registered and transacting with other businesses. Public sector entities that are VAT-registered (some government bodies or semi-states that have VAT numbers for their commercial activities) would also be treated as any other business when they act as suppliers. [revenue.ie] [kpmg.com]
• Non-established entities with Irish VAT registration: In scope. Foreign or non-resident businesses that are registered for Irish VAT (for example, a UK or US company that has an Irish VAT number for trading or via the distance selling/One Stop Shop rules) are subject to the same invoicing requirements for any transactions that fall under Irish VAT law. If such a business is the supplier in a B2B transaction that is subject to Irish VAT or requires an Irish VAT invoice, it will need to comply with e-invoicing. Notably, Phase 3 of the rollout (EU cross-border) will involve many foreign-established companies: for instance, a French company selling goods to Ireland (intra-EU supply) will have to issue an e-invoice to the Irish buyer to comply with the French implementation of ViDA, and the Irish buyer’s data will reach Irish Revenue via EU data sharing. Conversely, a non-established company that is directly registered in Ireland (e.g. via fiscal representative or direct VAT registration) and making domestic Irish B2B supplies or intra-EU supplies from Ireland is expected to use Ireland’s e-invoicing system for those invoices. In summary, having an Irish VAT registration puts a business in scope for the mandate, even if the business has no physical establishment in Ireland. [revenue.ie], [revenue.ie]
• Foreign entities without an Irish fixed establishment: If they are VAT-registered in Ireland, see above (they are treated like local taxpayers for their Irish activities). If a foreign entity is not registered or established in Ireland, then by definition it is not a “taxable person” in Ireland and is outside the direct scope of Irish domestic VAT invoicing rules. For example, a US company selling services to Irish consumers and not VAT-registered in Ireland has no Irish VAT obligations and thus no e-invoicing requirement in Ireland. However, foreign entities will feel the effects of the EU-wide aspects (for instance, an EU supplier to Ireland will use e-invoicing per their home country’s rules and that data will be shared with Ireland). Also, if a foreign entity without an establishment makes supplies that require Irish VAT registration (e.g. selling goods locally in Ireland), they typically must register; once registered they fall in scope.
• Small businesses below VAT registration threshold: Excluded by virtue of not being registered. Businesses that are not required to register for VAT (e.g. because their turnover is below the threshold of €37,500/€75,000, or they only make exempt supplies) are not “taxable persons” for VAT and do not issue VAT invoices. These entities are not directly subject to the e-invoicing mandate since they have no obligation to issue VAT invoices at all in B2B scenarios. The mandate does not force unregistered small businesses to start issuing invoices or to join the system. In practice, this means very small or exclusively exempt businesses remain outside the scope – preserving the current treatment. If such a business voluntarily registers for VAT, then it would become subject to the same rules as any other VAT registrant. For example, a micro-business below the threshold might choose to register for VAT; in doing so, they would by 2029–2030 have to comply with e-invoicing like others. But if they stay unregistered, they simply continue not charging VAT and not issuing VAT invoices, hence no e-invoicing requirement. There is no separate “exemption” from e-invoicing needed – the normal VAT registration threshold serves as a de facto exemption for the smallest businesses.
• Sector-specific rules/exemptions: There are no indications of sectors being exempted from the mandate. However, one can note that certain sectors where no VAT is charged will see minimal impact – e.g. businesses engaged wholly in exempt activities (like many financial or health services providers) typically don’t issue VAT invoices except on request. If they don’t issue VAT invoices now, the mandate doesn’t suddenly force them to; but if they do issue invoices (for example, an exempt business still must invoice a business customer on request or for record purposes), those would fall under e-invoicing once the customer is within scope. There has been no special carve-out for any industry (such as education, healthcare, etc.). Optional participation models are not formally delineated, but any business not yet mandated could opt to start e-invoicing voluntarily. For instance, between now and 2028, many businesses may choose to adopt e-invoicing early to streamline processes or in anticipation of the mandate. The government has indicated it will provide means for businesses to start preparing and even using the system ahead of time on a voluntary basis. This could include pilot programs or sandbox environments for software providers and early adopters, though details are to come. [revenue.ie], [revenue.ie] [revenue.ie]
• Public sector entities as issuers: Government departments and certain public bodies occasionally have to issue invoices (e.g. a state agency charging for a service). If a public body is an “accountable person” for VAT and issues an invoice, it will likewise need to follow the e-invoicing rules. The Office of Government Procurement (OGP) is overseeing public sector e-invoicing, and those systems (like the Health Service Executive’s finance system, etc.) are already aligned with EN16931 and Peppol. So in effect, the mandate covers all VAT-registered persons, whether private or public sector. [ec.europa.eu], [ec.europa.eu]

3. Implementation Timeline

• 2023 – Consultation and Planning: In late 2023, Irish Revenue opened a public consultation (from October 13 to December 2023) on “modernising VAT administration,” specifically seeking input on e-invoicing and digital reporting requirements. Over 1,000 businesses and stakeholders responded, and the findings – published in June 2024 – showed broad support for e-invoicing coupled with concerns about time to prepare and the need for clear guidance (especially from SMEs). This consultation phase was a voluntary information-gathering step; no obligations yet, but it set the stage and informed the eventual roadmap. [sovos.com] [revenue.ie], [deloitte.com]
• March 2025 – EU Directive Adopted: In March 2025, the EU formally adopted the “VAT in the Digital Age” Directive, which, among other things, made e-invoicing for intra-EU B2B mandatory from 2030 and allowed Member States to mandate domestic e-invoicing without individual EU permission. This EU legislative adoption was a critical prerequisite – it created the legal framework Ireland needed. Ireland supported these changes and began aligning its plans accordingly. [revenue.ie]
• Budget 2026 Announcement (October 2025): On October 10, 2025 (as part of the Budget 2026 speech), the Minister for Finance announced that Ireland would implement a phased mandatory domestic B2B e-invoicing system, in preparation for the EU-wide 2030 requirement. The very next day, 8 October 2025, Revenue published a detailed roadmap document titled “VAT Modernisation: Implementation of e-Invoicing in Ireland.” This publication outlines the timeline and approach and is effectively the formal policy announcement by Revenue. From this point, the timeline for rollout became official. [kpmg.com], [kpmg.com] [bdo.ie]
• Legislation and IT development (2025–2027): Following the roadmap, Revenue has started on the necessary legislative changes, systems development, and operational process design. The roadmap indicates technical work on legislation and IT systems is already underway. Although as of early 2026 no new law is in force yet for domestic e-invoicing, we expect enabling provisions in an upcoming Finance Act. Revenue will draft regulations or amendments to the VAT Act to mandate e-invoicing and reporting by the set dates. This legislative adoption is likely to occur well before 2028 to give certainty (possibly in Finance Act 2027 or a dedicated VAT amendment in 2028). In parallel, Revenue’s IT teams are building the infrastructure to receive and process e-invoice data. They’re working closely with the OGP and others to expand the Peppol network usage for businesses. During 2025–2027, we may see pilot testing environments and the release of technical specifications (formats, APIs) for software developers – the timeline notes that detailed guidance and specs will be published “well in advance” of each phase. [kpmg.com] [revenue.ie], [deloitte.com]
• Phase 1 – November 2028 (Mandatory for Large Corporates, Domestic B2B): Starting 1 November 2028, large VAT-registered corporate entities in Ireland will be required to issue electronic invoices and report them in real time for all their domestic B2B transactions. “Large corporates” hasn’t been precisely defined in public documents, but it likely refers to companies under Revenue’s Large Cases Division or above certain turnover thresholds. This will be a relatively small number of businesses (the largest in Ireland), which typically have robust ERP systems and often experience with e-invoicing in other countries. Phase 1 is essentially a pilot mandatory phase – these big companies will lead the way, allowing Revenue and others to learn and iron out issues before wider rollout. During Phase 1, only those designated large corporates are obliged to e-invoice, but all their business customers must be capable of receiving e-invoices. (The ViDA law imposes an obligation on buyers to accept e-invoices from that date, so even SMEs must be ready to receive invoices electronically from their large suppliers in Phase 1.) There’s no formal “voluntary” period mandated in law, but effectively the period from now until Nov 2028 is voluntary/transition for everyone, and smaller businesses not in Phase 1 can watch and optionally participate. Revenue will use this time to provide training and support to those large early adopters. [kpmg.com], [bdo.ie] [revenue.ie]
• Phase 2 – November 2029 (Mandatory for all VAT-Registered Cross-Border Traders): From 1 November 2029, the obligation extends to all VAT-registered businesses that engage in intra-EU trade (cross-border B2B transactions within the EU). This means if a business sells to or buys from other EU countries (and avails of the 0% intra-Community VAT), it must now comply with e-invoicing for all its B2B invoices (including its purely domestic sales). Essentially, any company that is an importer or exporter within the EU single market comes into scope in Phase 2. This will bring in a much broader range of businesses, including many SMEs that trade with Northern Ireland or mainland EU. The rationale is to give these companies a domestic e-invoicing environment to acclimate in before the EU-wide cross-border mandate hits in 2030. By Phase 2’s start, detailed guidance will have been issued and the system should be well-tested by Phase 1 experiences. Notably, Phase 2 is not “all SMEs” universally – it’s all companies with cross-border activity. Some very small purely-domestic businesses might still not be covered by Phase 2 (if they never trade abroad and aren’t large). However, many businesses will fall in either Phase 1 or 2, such that by the end of 2029 a significant majority of B2B transactions in Ireland will be under e-invoicing. During Phase 2 (Nov 2029 – June 2030), e-invoicing is effectively mandatory for most active VAT traders except perhaps local-only micro businesses. [kpmg.com], [bdo.ie] [bdo.ie] [revenue.ie]
• Phase 3 – July 1, 2030 (Mandatory EU-Wide for all intra-EU B2B; Full ViDA enforcement): From 1 July 2030, the EU requirement from the ViDA Directive becomes effective across all Member States. Ireland’s Phase 3 corresponds to this date, mandating full compliance for all cross-border B2B transactions. At this point, any Irish VAT-registered business issuing an invoice to a VAT-registered customer in another EU country must do so electronically and report the data in real time, or else that invoice will not be considered valid for zero VAT treatment. Likewise, any invoice an Irish business receives from an EU supplier will be electronic via the new system. Effectively, July 2030 marks the completion of Ireland’s rollout – by then Ireland expects to have all businesses ready to use e-invoicing, even those who until then only operated domestically. (Irish businesses not engaged in any cross-border trade by 2030 would theoretically not be forced by EU law on that date, but Ireland will have its domestic system in place already. It’s likely Ireland will simply extend the domestic mandate to any remaining VAT-registered businesses at that stage, so that ultimately 100% of VAT businesses are using e-invoicing for B2B sales.) In any case, from July 2030 forward, the distinction between domestic and EU B2B likely disappears in practice – all B2B invoicing is electronic and reported. The monthly VIES (EU sales list) is eliminated at this point, since tax authorities will be receiving transaction data automatically. [kpmg.com], [ey.com] [deloitte.com] [revenue.ie], [ey.com] [revenue.ie]
• Grace periods: The phased approach itself serves as a kind of grace period for smaller businesses. The timeline gives about 2.5 years from announcement (Oct 2025) to first mandatory phase, and then an additional 1–2 years for the rest. This is intended to ensure businesses have adequate preparation time. As for post-launch grace periods (e.g. leniency in enforcement), none has been explicitly announced yet. However, it’s common in such rollouts to have a soft landing – for example, Italy in 2019 had a six-month grace with reduced penalties. Ireland’s documents do not mention a specific penalty-free window, but Revenue’s tone is collaborative, emphasizing support over punishment in the early stages. We will have to watch for guidance if, say, penalties will be suspended for the first few months of each phase. At minimum, the “grace” has been built into the timeline (with years of advance notice). [revenue.ie], [deloitte.com]
• Different timelines for different sectors/transactions: The mandate timing is primarily by size and EU-trading status, not by industry. There is no separate timeline, for example, saying “financial sector starts later” or “specific transaction types start earlier.” One relevant differentiation: public sector B2G e-invoicing has essentially been mandatory for receivers since 2019, so one could say B2G was on its own timeline due to EU Directive 2014/55/EU. By now (2025), all Irish public bodies can accept e-invoices via Peppol. But again, suppliers to government weren’t mandated to send them. As the new phases kick in, large suppliers to government (if large corporates) will start e-invoicing in 2028 along with their other B2B customers; smaller suppliers to government will follow in 2029/30 when they fall into cross-border or remaining domestic scope. Thus, B2G will effectively become covered without a special date – simply through Phase 1 and 2 as applicable. There’s also an indication that intra-Community transactions have a hard EU deadline (July 2030), which Ireland is using as Phase 3. No separate domestic “B2C” timeline is given since B2C is not mandated. If in the future Ireland decides to require real-time reporting for B2C (as some countries plan), that would be a new timeline beyond 2030, but currently it’s not scheduled. [ec.europa.eu]
• Pilot / Voluntary phase: While not a formal phase, from now until 2028 businesses and software providers are encouraged to prepare. Revenue has committed to intensifying stakeholder engagement and will likely run pilot programs or trials with industry before Phase 1. For instance, they may invite some businesses to test integrations in 2027 or early 2028 (voluntarily) to ensure the platform works. Many businesses may also start using e-invoicing voluntarily – since e-invoices are already legally accepted in Ireland, any two parties can agree to use them even today. We might see an increasing uptake of voluntary e-invoicing in 2026–2027, spurred by awareness of the coming mandate. Also, the government could introduce an early adoption program, though specifics aren’t published yet. [revenue.ie], [deloitte.com] [basware.com]

• Q4 2025: Roadmap released, work on laws/specs begins. [kpmg.com]
• 2026–27: Drafting legislation, building system, stakeholder consultations (through forums like TALC). Possibly a pilot environment launch in this period. [deloitte.com]
• By mid-2028: Detailed technical guidelines available, and system likely open for voluntary use in preparation.
• Nov 2028: Mandatory for large enterprises’ domestic B2B invoices. [kpmg.com]
• Nov 2029: Mandatory for all businesses involved in EU trade (covering most remaining medium/small businesses that are VAT-registered). [kpmg.com]
• Jul 2030: Full mandatory e-invoicing for intra-EU B2B across EU; Ireland’s system in full effect for all B2B trade. [bdo.ie], [ey.com]

• E-invoice format and standard: Ireland will adopt the European EN 16931 e-invoicing standard for structured invoices. EN 16931 defines the semantic data model (the core set of information an invoice must contain) for electronic invoices across the EU. In practice, this means invoices must be issued in a structured data format such as XML that conforms to EN16931. Ireland is leveraging the Peppol BIS 3.0 format, which is an implementation of EN16931, as the likely primary format. Peppol BIS 3.0 uses UBL (Universal Business Language XML schema) to represent invoices. This is already used for public procurement invoices (B2G) in Ireland, and Ireland is a member of OpenPeppol. According to Revenue, existing technical infrastructures like Peppol will be expanded to all B2B invoices. Thus, the e-invoice will be an XML data file (not a PDF) respecting the standardized structure. Other EN16931 compliant syntaxes (like UN/CEFACT CII) are also technically acceptable, but Peppol UBL is the national norm. In summary, invoices must be issued in a structured electronic format (XML/UBL) that adheres to EN16931; traditional formats (PDF, Word, paper scans) will no longer satisfy legal requirements. Each e-invoice file will contain all mandatory fields and follow the schema so that it can be automatically validated and read by machines. [kpmg.com] [cleartax.com], [cleartax.com] [ec.europa.eu], [sovos.com] [revenue.ie] [revenue.ie], [kpmg.com]
• E-reporting format and data: “E-reporting” refers to the transmission of invoice data to the tax authority. In Ireland’s model, this is essentially accomplished by sending the e-invoice itself (or a subset of its data) to Revenue in real-time. The exact format for the report will thus mirror the invoice format – it will likely be the same XML payload or a standardized message derived from it. The ViDA directive specifies a common “digital reporting” requirement for intra-EU transactions, meaning certain key data fields must be reported in a consistent way. We can expect that when an invoice is sent via the system, Revenue will receive a subset of the invoice data including at least: supplier and buyer VAT numbers, invoice date, invoice number, line item details or summary (description, quantity, price), tax base, VAT rate(s) applied, VAT amount, and codes for any special treatment (e.g. reverse charge, intra-Community supply). This aligns with current invoice content requirements and what used to be reported quarterly via VIES (partner VAT, amount, etc.) but in much more detail. Notably, under EU rules suppliers must report specified data “electronically within 2 days of invoice issuance” for cross-border transactions. Ireland hasn’t published a separate schema for reporting, suggesting the invoice itself is the report – i.e. by sending the structured invoice through the platform, you simultaneously fulfill the reporting obligation. If any transactions require reporting without an invoice (perhaps self-accounted imports of services), there might be a special reporting form or self-billing invoice to submit. For typical cases, the data model is EN16931, which includes around 200+ data elements (though not all are used every time). Among these, Ireland will have a set of mandatory fields that must be present on every e-invoice. These correspond to the legal requirements for invoice content such as: [revenue.ie], [revenue.ie] [revenue.ie]
  • Supplier’s name, address and Irish VAT number [revenue.ie]
  • Customer’s name and address; for B2B, customer’s VAT number if applicable (especially required for EU cross-border sales) [revenue.ie]
  • Invoice date and a sequential invoice number unique to that supplier [revenue.ie]
  • Description of the goods or services, including quantity and unit price [revenue.ie]
  • The date of supply if different from invoice date [revenue.ie]
  • Net amount (taxable amount) for each VAT rate or exemption category [revenue.ie]
  • The VAT rate(s) applied and the VAT amount for each rate, and total VAT amount [revenue.ie]
  • If an exemption or zero-rate applies, an indication of that (often a reason code or note) [revenue.ie]
  • If reverse charge applies, the customer’s VAT number and a note “reverse charge” (no VAT amount shown) [revenue.ie], [revenue.ie]
  • If intra-Community supply, customer’s VAT number and note of that (usually “intra-Community supply – VAT exempt”) [revenue.ie]
  • If triangulation, a note that it’s triangulation and the customer will account for VAT.
    These are current legal requirements for invoices in Ireland and will all have their place in the e-invoice structure. Any invoice missing a required element will fail validation. The mandatory data elements in the e-invoice thus mirror what a paper invoice must legally contain, with the addition of any fields needed for the platform (like perhaps an indication of invoice type, or a unique document identifier for the system). [revenue.ie] [revenue.ie], [revenue.ie]
• Validation rules: Every e-invoice will be subject to automated validation checks. At a basic level, the Peppol Access Point or the tax portal will validate that the XML file is in the correct format (schema validation). This ensures all required fields are present and data types correct (e.g. dates in proper format, numeric fields numeric, mandatory tax breakdown provided, etc.). If an invoice fails schema or business rule validation, it will be rejected and considered not issued. Some expected validation rules: the VAT identification numbers must be valid (e.g. follow the country format and possibly be active in VIES), the invoice date and number should not be duplicates or far out of logical range, arithmetic consistency (the sums of line items plus VAT match totals), and presence of required notes for special regimes. For example, if an invoice has no VAT charged and the buyer is Irish, the system might require a reason (like “reverse charge” or “exempt”) – otherwise it’s an error. If an invoice is marked as “reverse charge” the system might check that the buyer’s VAT number is provided and is Irish, etc. These kinds of business rules will be defined in technical documentation. Peppol BIS 3.0 has built-in validation rules as well (via Schematron), and Ireland may add additional business rules (CIUS – Core Invoice User Specification) to tailor it, although as of 2025 Ireland’s public sector uses mostly standard Peppol BIS with minor CIUS tweaks. One known rule from EU ViDA: an invoice must be issued within 10 days of the tax point (transaction date), so if an invoice date is beyond that, perhaps it could flag an error or warning. Also, the system will enforce that PDFs or images are not accepted – attempting to submit such would fail (only structured data is allowed). Overall, invoices will undergo real-time validation, and only upon passing will they be considered successfully reported (and transmitted to the buyer). This assures high data quality for tax reporting. [cleartax.com] [ec.europa.eu], [ec.europa.eu] [revenue.ie]
• Digital signature or integrity measures: Under EU law, e-invoices must ensure authenticity of origin and integrity of content. This can be achieved by business controls or technology (like digital signatures). Ireland does not currently mandate a specific method such as an electronic signature on each invoice. In practice, using the approved network (Peppol) and formats inherently meets the requirements because the transmission is secure and traceable. According to guidance, digital signatures on e-invoices are optional in Ireland; any method that guarantees the invoice hasn’t been altered and confirms the sender is acceptable. Peppol messages have their own security (they travel via accredited Access Points with PKI trust). So we do not expect Ireland to require suppliers to digitally sign each invoice file, unlike some countries did in the past. Instead, compliance relies on the closed system and audit trail. The integrity of an invoice’s content must be maintained from issuance to archiving – meaning no undetected changes. The system likely will assign a unique ID or hash to each invoice report, ensuring any tampering would be evident. As an extra layer, businesses can choose to apply advanced electronic signatures to invoices, but it’s a choice, not an obligation. What is mandatory is that the electronic records system must be able to guarantee integrity and authenticity through controls – e.g. through secure storage, audit logs, etc. [sovos.com] [cleartax.com] [sovos.com], [cleartax.com] [revenue.ie]
• Real-time or near-real-time reporting: The system is described as “real-time reporting.” In practice, this means that invoice data is transmitted to Revenue essentially immediately as the invoice is issued. The objective is that tax authorities receive transaction data within a very short window after the transaction. The EU requirement for cross-border invoices is within 2 days, but many expect near-instant reporting even for domestic. Ireland has indicated this will be a real-time digital reporting system integrated with business processes. So when a supplier issues an e-invoice to their customer through the platform, a copy/government report is simultaneously sent to Revenue (or pulled by Revenue’s system). This could be truly instantaneous or could permit a short grace (T+1 or T+2 days) for transmission issues. The likely model (given use of Peppol) is: the supplier sends the invoice via the network, the buyer receives it, and in parallel the tax authority is notified. Some countries using a post-audit system with Peppol (like some Nordic countries) don’t get data in real-time, but Ireland’s plan explicitly calls it real-time reporting, closer to a clearance model albeit distributed. In summary, suppliers will need to submit invoices to Revenue no later than when they deliver them to the customer. In fact, the act of sending through the mandated network will accomplish both deliveries at once. Thus “real-time” for businesses simply means you must use the system for every invoice as you issue it (you cannot batch send them weeks later). For cross-border, ViDA says 2 days max, so that’s an outer limit. Domestic might follow the same timeline or possibly be even tighter. There’s no provision for only monthly summary reporting of individual B2B invoices – each invoice must be reported. Only in cases like B2C (which are out of scope) or perhaps certain self-billing or flat-rate farmer situations might periodic summaries come into play, but those are exceptions. For the mandate at hand, think real-time = immediate/continuous reporting. [revenue.ie]
• Mandatory data elements on each invoice: We covered a lot of these under e-reporting data and invoice format, but to summarize clearly: Every e-invoice must include all information currently required by law on a VAT invoice. To recount in bullet form, the core mandatory fields are: [revenue.ie], [revenue.ie]
  • Date of invoice issue
  • Unique invoice number (sequential for that supplier)
  • Supplier’s name, address and VAT registration number
  • Customer’s name and address; and if the customer is a taxable person, the customer’s VAT number (especially mandatory for EU customer if zero-rating is applied)
  • Description of the goods/services (what is supplied) and the quantity/extent thereof
  • The date of supply (or completion of service) if different from the invoice date
  • The unit price and any discounts (price elements)
  • The net amount (excluding VAT) chargeable for each rate of VAT or exempt category
  • The VAT rate(s) applicable to each line or item (e.g. 23%, 0%)
  • The VAT amount, calculated for each rate and in total (except in fully zero/exempt cases where no VAT is to be shown)
  • If an exemption or reverse charge applies, a notation to that effect (like “VAT Reverse-Charge” or “Exempt – Article X of VAT Directive”) [revenue.ie]
  • Intra-Community supply: customer’s VAT number and a reference like “intra-Community supply – 0% VAT” [revenue.ie]
  • Triangulation: a note that “VAT triangulation simplification applies – customer will account for VAT” [revenue.ie]
  • If a tax representative is involved (for foreign businesses), the representative’s name, address and VAT number. [revenue.ie]
  These elements map to specific tags in the EN16931/Peppol BIS format. If any required info is missing (say a VAT number where needed, or an invoice number), the invoice wouldn’t be considered valid. Additionally, Ireland requires invoices in foreign currency to also show the equivalent in euro (using a specified exchange rate). That will remain a requirement, so the e-invoice should include a converted total in EUR if billing in e.g. USD. The e-invoicing schema supports multiple currencies and one can indicate the exchange rate used. [revenue.ie]
• Real-time clearance vs post-audit model: While not explicitly asked, it’s worth noting the functional model: Ireland appears to be adopting a model closer to clearance (like Italy) albeit using a decentralized network. That means the invoice is effectively cleared through the system as it is issued. The buyer and tax authority get it nearly simultaneously. This contrasts with a post-audit system (like current EU practice) where the tax authority only sees invoices later (if at all, via audits or periodic listings). Ireland’s system is moving to transactional, near real-time collection of invoice data. This is functionally a big change – businesses must integrate their invoicing process with the reporting process, rather than just keeping records for later use. [revenue.ie], [bakertilly.ie]

• Transmission model – Peppol 4-Corner Network: Ireland will leverage the Peppol network for transmitting e-invoices. Peppol is an interoperability framework used widely for e-invoicing in Europe. It operates on a “four-corner” model: the supplier and buyer each connect to the network through certified Access Point (AP) providers, rather than directly to each other. In practice, an Irish supplier will send its invoice in standardized format to its chosen Access Point (which could be a service like a software provider or the Revenue’s own gateway if provided). The Access Point looks up the buyer’s receiving address (via a Peppol ID registry) and transmits the invoice to the buyer’s Access Point, which then delivers it to the buyer’s system. In the context of the mandate, Revenue itself will likely be an intermediary or at least receive a copy of the invoice in transit. Ireland’s Revenue is working closely with the OGP (which is the Peppol Authority in Ireland) to scale up this network usage for all businesses. This approach means Ireland is not creating a brand-new centralized “clearance platform” like Italy’s SDI, but rather piggybacking on an existing decentralized network where invoices flow directly between trading parties through interoperable nodes. However, in effect, the system will function with similar oversight because the tax authority gets the data from the network. [kpmg.com], [ey.com] [cleartax.com], [cleartax.com] [kpmg.com]
• Central clearance vs interoperability: In a central clearance model, all invoices go through a government platform that validates and forwards them (e.g. Italy, Mexico). In an interoperability model, invoices can go through various service providers as long as they meet standards, and the government can receive the data. Ireland’s plan leans to the interoperability side (the Peppol model is decentralized). That said, because of mandatory reporting, the distinction blurs – even if invoices flow via different providers, all must be connected to Revenue’s systems. We can analogize that Revenue will act as an “additional recipient” of each invoice or will tap into the network flow. The Office of Government Procurement (OGP) acts as Ireland’s Peppol authority, accrediting providers and maintaining the directory. This means businesses will have a choice of accredited service providers (Access Points) to handle their invoice transmission, fostering a competitive market for e-invoice solutions. Many accounting software and ERP vendors will likely integrate Peppol AP services. For businesses that do not want to use a third-party provider, the government may offer a basic solution (for instance, a web portal to create and send invoices, or a free AP for SMEs), though details are pending. Many EU countries plan a free portal for small businesses; Ireland hasn’t announced one yet, but it’s possible given the need to help SMEs connect easily. [ey.com] [sovos.com]
• Use of APIs and gateways: Businesses with IT capability will likely integrate via APIs. The Access Point software will expose APIs for sending invoices, looking up recipients, etc. Revenue may also provide APIs for reporting if needed. But since using Peppol essentially covers both sending to buyer and notifying authorities, companies might mainly integrate with their AP and not directly with Revenue’s API. However, it’s conceivable that Revenue will set up a central platform to receive invoices as a virtual “third corner.” For example, France’s upcoming system uses either direct transmission to the tax portal or via registered service providers. Ireland’s approach suggests Revenue will get the data through Peppol: one scenario is the buyer’s AP (if buyer is Irish) could forward a copy to Revenue, or the supplier’s AP could do so. Since OGP is coordinating, they might set it such that every invoice with an Irish VAT number is also routed to a Revenue endpoint for recording (this could be an automated “CC” of the message to Revenue’s system). The technical specifics are to be determined, but the commitment is to use Peppol as the backbone for secure and standardized exchange. Peppol uses web services protocols; sending an invoice essentially means your system (or provider) calls a web service to deliver the XML. The network ensures interoperability – any AP can reach any other AP – meaning a large business can use one provider and a small supplier another, and they can still exchange invoices seamlessly. [ey.com] [ec.europa.eu], [ec.europa.eu]
• Workflow for issuing an invoice: A likely scenario for how an invoice flows:
  1. A supplier generates an e-invoice in their system (or via an online portal), ensuring it’s in the correct format (Peppol BIS 3.0 XML).
  2. The supplier’s system sends the invoice to their chosen Access Point (transmission is typically via secure HTTPS with both parties authenticated).
  3. The Access Point validates the invoice format and looks up the buyer’s receiving details in the Peppol network (using the buyer’s VAT or Peppol ID). It then sends the invoice through the Peppol network to the buyer’s Access Point. [cleartax.com]
  4. The buyer’s Access Point receives the invoice, performs any schema validation and passes it to the buyer’s accounting system in a way they can process (for example, many APs will convert it to a format the buyer’s ERP can ingest, or provide a portal for the buyer to download/view it).
  5. Simultaneously, one of these Access Points (or a middleware service) forwards the key invoice data to Revenue’s central VAT reporting system. Because this step is key for compliance, it might be implemented such that Revenue itself operates an Access Point and the invoice is actually addressed to two recipients: the buyer and Revenue. Indeed, the roadmap says Revenue is “working closely with OGP to prepare for expanded network usage” as businesses adopt e-invoicing for domestic and cross-border needs. This implies Revenue will be an integral node on the network. [revenue.ie]
  6. The tax authority thus receives the invoice data in real time, and can issue back a technical acknowledgment (received/accepted or errors if any).
  7. Both supplier and buyer get confirmation that the invoice was delivered/received. If there was a transmission error or a validation error, the supplier would get a notice to correct it (meaning the invoice in that case would not be considered issued for VAT purposes until fixed).
• Deadlines for transmission to tax authorities: Real-time or near-real-time is the rule. As soon as an invoice is issued, it must be transmitted. The EU ViDA law gives a maximum of “report within T+2 days” for cross-border invoices. Ireland will likely align with this for all invoices, meaning an invoice should be in the system within 2 days of its issue date at the latest. The expectation, however, is that businesses will do it immediately. There is no suggestion of a monthly reporting option for individual invoices – unlike some systems that allow reporting domestic B2B with a lag, Ireland’s plan is real-time continuous transaction reporting. That said, certain aggregated reporting might persist for B2C or non-invoice data. For instance, if in the future they capture some B2C sales data, they might allow a monthly summary of those (this is speculative; currently B2C not required). But for B2B, each invoice must be reported when it’s generated. Ireland’s current VAT return deadlines (bi-monthly filing by the 19th of the month, etc.) remain for summary tax payments, but those are separate from invoice reporting. Under e-invoicing, businesses won’t wait until the VAT return to report sales; they’ll already have reported each sale via the invoice system. In effect, the deadline to report a sale is the moment of invoicing (with at most a very short grace if systems are down). Legally, since an invoice must be issued by the 15th of the following month at the latest under VAT rules, and ViDA tightens cross-border to 10 days, delays beyond that break VAT law anyway. With e-invoicing, enforcement will be stricter: if you don’t submit the invoice in time, you haven’t complied. [revenue.ie] [bakertilly.ie] [spaceinvoices.com] [legalblog.ie]
• Monthly or periodic summaries: The new system will eliminate the monthly VIES summary of EU sales from 2030, because those details come via e-invoices. For purely domestic data, there might not be a need for any separate monthly summary either; all detail is in Revenue’s hands. However, the periodic VAT3 return will likely continue to be submitted (as an aggregate of sales, purchases, etc.), at least initially, because it covers things like non-invoiced sales, correction of errors, or other adjustments. Over time, as the system matures, one could imagine more of the return being pre-filled (see section 10) and possibly future elimination of some periodic forms. But as of the mandate’s introduction, no special monthly report is required for those using e-invoicing – the e-invoice IS the report. Only if a type of transaction isn’t captured by e-invoicing (for example, certain import self-accounting or flat-rate farmer additions) might there remain a need for a monthly or bi-monthly summary. [revenue.ie]
• Role of service providers: Businesses can choose to comply by using accredited third-party service providers. These providers (such as software companies, ERP vendors, or specialized e-invoicing firms) typically serve as Peppol Access Points. They handle the connectivity, format conversion, and may offer workflow solutions (like invoice approval processes, etc.). Ireland’s use of Peppol means any provider that is Peppol-certified can be used. This creates a framework of “authorized intermediaries” – though not explicitly licensed by Revenue (except in as far as Peppol APs are authorized by OGP). Many accounting softwares (e.g. SAP, Oracle, Quickbooks, etc.) either have built-in Peppol connectivity or partner with APs. For compliance, a company could also outsource the entire invoicing process to a service bureau. The key requirement is that the service provider can transmit the invoice to both the buyer and Revenue according to the rules. Ireland will likely maintain a list of trusted providers or at least rely on the Peppol AP registry for this. If any “accreditation” beyond Peppol is needed (some countries create a notion of certified software or fiscal service provider), we will learn that from future guidance. The current indication is the existing network suffices, so using a Peppol AP = using an accredited channel. [sovos.com]
• Receiving e-invoices: All businesses, even those not yet forced to issue e-invoices, will need the capability to receive them by Nov 2028. This means every VAT-registered business should, at minimum, be registered on the network with an electronic address and be ready to accept invoices (for example, via a portal or their software). Practically, we expect Revenue/OGP to assist in onboarding businesses to the Peppol directory. Possibly, all Irish VAT numbers could be loaded into the Peppol lookup service by default, or there will be a campaign instructing businesses to sign up with an Access Point for receiving. If a small business does nothing, one scenario is that Revenue might provide a default mailbox where invoices to that VAT go. But details are forthcoming. The important point is that by the start of Phase 1, even businesses not in Phase 1 must not impede e-invoices – they cannot insist on paper if a large supplier sends an e-invoice. They have to accept it (which practically means processing it or at least retrieving it). This is part of the EU legal obligation: buyers cannot refuse electronic invoices from suppliers once the mandate is active. [revenue.ie], [ey.com] [revenue.ie]
• Interoperability and foreign alignment: Ireland’s system will interoperate with other countries via Peppol and via EU data exchange. If an Irish company invoices a French company in 2031, for instance, the invoice might go through Peppol and satisfy both Irish reporting and French reporting simultaneously. Ireland’s use of open standards and networks ensures international interoperability, which is a big advantage compared to isolated national systems. Also, Ireland benefits from the fact that many large software providers will already adapt their solutions for other EU countries’ e-invoicing mandates in 2024–2026 (e.g. France, Poland, etc.), so by the time Ireland’s turn comes, solutions will be mature.
• Timing specifics: Real-time essentially means T0 or T+ seconds/minutes. “T” here is the moment of issuing the invoice. We expect the workflow to be integrated such that issuing the invoice triggers immediate transmission. The law will likely allow a tiny window (the EU 2 days rule) for exceptional circumstances. Also, if the system or network faces downtime, there will be contingency procedures (like batch sending once back up, or manual fallback). These will be addressed in technical guidelines. For regular operations, think of it this way: no later than the next day after issuing an invoice, that invoice’s data should be in Revenue’s database – and typically much faster.

• Real-time – invoice data flows as invoices are issued (no significant lag). [outbooks.com]
• T+1/T+2 day – absolute latest for cross-border compliance, effectively a grace if immediate send wasn’t possible. [revenue.ie]
• Periodic – the only remaining periodic submission will be the VAT return (which might eventually be simplified due to e-invoicing), as all invoice-level data is handled continuously.

• Conditions for self-billing (current rules): The customer can raise the invoice for a supply (instead of the supplier) only if there is a prior agreement between both parties and a procedure to ensure the supplier accepts each invoice’s validity. Essentially, the supplier and customer agree that the customer will generate the invoices, and the supplier will not issue their own. Each self-issued invoice must contain all information required of a VAT invoice and must be marked with the words “self-billing” to clearly indicate this arrangement. Once the supplier accepts the invoice (explicitly or implicitly according to the agreed procedure), it is deemed to have been issued by the supplier for VAT purposes. These conditions remain unchanged by e-invoicing: companies must still have that agreement in place and ensure compliance with content rules and acceptance. [revenue.ie]
• Need to pass through the e-invoicing platform: A self-billed invoice is still a VAT invoice, just issued by a different entity. Therefore, if the transaction is within the scope of the mandate (B2B domestic or cross-border trade), the self-biller (customer) will have to send the invoice through the e-invoicing system just as any supplier would. The e-invoice will list the supplier and customer as usual (with their VAT numbers), but the document origin is the customer’s system. From the tax authority’s perspective, it doesn’t matter who technically prepared it – what matters is that an invoice for that sale was submitted. So yes, self-billed invoices must be transmitted to Revenue via the e-invoicing network in real time, like any other invoice. The buyer who issues it will effectively act as the “supplier” in the e-invoicing workflow for that document. They will need to use their Peppol Access Point to send the invoice to themselves (as weird as that sounds) and to Revenue. In practice, the workflow is simplified because the buyer issuing the invoice doesn’t actually need to send it to themselves – but they do need to send it to the tax authority. We might see special handling where a self-billed invoice is flagged in the data (so that Revenue knows the buyer created it) and the supplier gets a copy perhaps for their records. The key point: the mandate covers the invoice, not who issues it – since a self-billed invoice is required to contain all the same fields and is legally an invoice issued by the supplier, it must be part of the electronic reporting system. There is no exemption saying “if the customer issues the invoice, you don’t have to report it.” Both parties remain responsible for ensuring it’s reported.
• Buyer-side validation/approval requirements: Under self-billing arrangements, the supplier must agree to each invoice to confirm it’s correct. Typically, the procedure is that the supplier periodically signs off that the self-billed invoices raised by the customer are accepted (some do this per invoice, others via summary acceptance). In an e-invoicing scenario, this acceptance could be done electronically. For example, the supplier might receive an electronic copy and either explicitly approve it or have a standing agreement that all invoices are deemed approved unless disputed. The current rule is that the parties must have “agreed procedures for the acceptance by the supplier of the validity of the invoice”. This doesn’t change – they should still have that in place, perhaps integrated into their systems. The e-invoicing platform itself may not handle the acceptance step (it transmits invoices, but the agreement/approval is off-system between the parties). However, in practice, many self-billing scenarios are between trusted partners (like a company and its contractor), so they often have continuous agreement. [revenue.ie]
• Mandatory content rules for self-billed invoices: The e-invoice generated by the customer must include all the usual invoice content (dates, VAT numbers, etc.) of the supply, as if the supplier made it. Additionally, it must be marked “Self-billing” on its face – this is critical to identify it as such. In the electronic format, there will be a field or code to indicate that the invoice is self-billed. EN16931 has provisions to flag the invoice issuer and perhaps an indicator when the seller and issuer are not the same. The invoice will still contain the supplier’s name and VAT number as the “Supplier” and the customer’s details as the “Customer,” but possibly with an annotation that the invoice is issued by customer. The requirement to include the notation “Self-billing” ensures that anyone (including Revenue) reviewing it understands the scenario. Also, the invoice series might be managed by the customer (so numbering might be sequential in the customer’s system but still must be unique and sequential overall). As long as these conditions are met, the invoice is valid. [revenue.ie]
• Restrictions or notifications: Ireland’s rules do not require prior notification to Revenue to use self-billing (unlike some countries). It’s an arrangement between the parties. Thus, there isn’t a special registration or approval needed from tax authorities to do self-billing, beyond following the rules. Self-billing is typically more common in industries like construction or agriculture (e.g., supermarkets self-billing farmers for produce deliveries, etc.). Under e-invoicing, Revenue will actually see the pattern of self-billing if invoices are flagged as such. This provides even more transparency – e.g. Revenue could see that Company X is issuing invoices on behalf of its suppliers and check that those suppliers indeed are accounting for them properly. There’s no newly mandated notification in the e-invoicing plan regarding self-billing, aside from the existing requirement of prior agreement between the two businesses.
• Processing through the platform: For a concrete example, consider an Irish company (“CustomerCo”) self-billing for services received from a contractor (“SupplierCo”). Today, CustomerCo generates an invoice, sends a copy to SupplierCo for records, both keep it, and VAT is accounted by SupplierCo (output) and CustomerCo (input) accordingly. In 2029, if this is a domestic B2B transaction, CustomerCo will generate the invoice in the e-format. They will send it via the network: effectively, CustomerCo is both sender and receiver in Peppol terms, since they issue the invoice to themselves as the buyer. However, the Revenue receives the invoice as well, fulfilling the reporting duty. SupplierCo will get visibility (maybe CustomerCo will share a copy or via system access) but SupplierCo doesn’t send anything themselves. SupplierCo’s obligation is to ensure those self-billed invoices are correct and then just account for the VAT on them in its VAT return. There might be a facility in the system for the supplier to acknowledge the invoice (not sure if that will be built-in or just handled contractually offline).

• Triangulation transactions (EU three-party chain): Triangulation occurs when a middleman (Company B) in one EU country orders goods from a supplier (Company A) in another EU country, and A ships directly to B’s customer (Company C) in a third EU country. EU VAT law provides a simplification so that B doesn’t have to register in C’s country – B can issue a VAT-free invoice to C under certain conditions. Currently, Irish VAT rules require that the invoice used in a triangulation scenario includes an explicit reference to the triangulation simplification and that the customer (C) will account for the VAT. For example, if an Irish company is the middleman (B) shipping goods from a supplier in Germany to a customer in France, the Irish company’s invoice to the French customer should state something like “EU Triangulation – Article 141 VAT Directive – VAT to be accounted for by the purchaser.” Under e-invoicing, this requirement remains – the electronic invoice has a field for a free-text note or a code for triangulation, and the Irish business must include that wording or a standardized code indicating triangulation. The real-time reporting will capture that B (Irish co) did an intra-Community acquisition from A (German co, which will be reported via A’s system to German and shared with Ireland), and an intra-Community supply to C (French, reported via Ireland’s system and shared with France). The triangulation indicator on B’s invoice will signal to French authorities that C needs to self-account for VAT. The Irish Revenue also will see that data; although Ireland doesn’t collect VAT on that onward sale (since it’s zero-rated intra-EU), having the data can help ensure B properly declared the acquisition and the sale. In summary, triangulation doesn’t change procedurally except that tax authorities get instant visibility. Irish companies involved in triangulation must continue to issue proper invoices with the required references, now in electronic form. The e-invoicing system likely will have a specific code or check for triangulation (possibly using the “tax category code” or note element). The net effect is to simplify compliance: today, triangulation info is often only on the invoice and on the VIES report (with special codes). In the future, the invoice itself (in real time) suffices – no separate listing needed as VIES goes away. [revenue.ie] [revenue.ie]
• Chain transactions (multiple intermediaries or domestic chains): A chain transaction refers more generally to goods supplied through several parties but physically delivered once. Triangulation is a specific three-party cross-border chain. If more than three parties are involved across borders, the principle is similar but beyond the standard simplification which covers just one intermediary. Each link in the chain still requires an invoice and appropriate VAT handling (some links will be zero-rated intra-EU supplies, the final will be domestic, etc.). Under e-invoicing, each invoice in the chain must be reported by its issuer. There isn’t a single “chain document” – it’s still multiple invoices, but tax authorities will be able to link them by looking at the goods description, quantities, dates, parties, etc., if needed. For domestic chain transactions (all parties in Ireland, e.g. A sells to B, B sells to C, but goods go directly from A to C), Irish VAT law doesn’t have a special concept like EU triangulation; it’s just two domestic supplies (A->B and B->C, both charge VAT). Each must be invoiced and under e-invoicing, both invoices will be reported. The business practice of one delivery note covering a drop shipment doesn’t change the invoicing requirement – both A and B issue invoices to their respective customers. The e-invoicing system will capture both invoices and presumably tax authorities could piece together that it was one physical movement if needed (though that’s not usually required for compliance, more for audit analysis). If an Irish business is part of an international chain beyond triangulation (say four companies in four countries), the situation gets complex but each trade between two parties is either intra-EU or domestic and gets handled accordingly in that country’s reporting. So effectively, the e-reporting handles chain transactions by capturing each “link” with its correct VAT status. No additional forms or “chain declarations” are needed beyond what’s on the invoice (e.g. “triangulation” note for the intermediate link in a 3-party chain, etc.). The main thing for businesses is to continue to use correct invoice wording and VAT treatment to indicate if they are the middleman who doesn’t charge VAT. Under ViDA, all cross-border legs will be in the system, so authorities can more easily detect if someone incorrectly charges or doesn’t charge VAT when they should.
• Cross-border reverse charge scenarios: This typically refers to services supplied cross-border within the EU (or certain goods like installation services) where the reverse charge applies, meaning the recipient must account for VAT. For instance, an Irish company buying consulting services from a supplier in Spain – the Spanish supplier doesn’t charge VAT, the Irish buyer self-accounts via reverse charge. Currently, the Spanish supplier must issue an invoice with no VAT, stating “reverse charge” and including the Irish customer’s VAT number. Under e-invoicing, if Spain (or whichever country) mandates e-invoicing for cross-border services, that Spanish invoice will be electronically sent and shared with Ireland. If not, the Irish company will still likely have to manually account. From Ireland’s perspective, incoming reverse-charged services and goods (like intra-EU services, or certain imports of services from outside EU) pose a question: how are they reported to Revenue in real time? If the supplier is foreign and not in Ireland’s system, the onus might be on the Irish buyer to report the purchase. ViDA’s current focus is on sales listings rather than purchases, so it’s possible such transactions might not all be captured unless the foreign side does it. However, many intra-EU B2B services would be included because all EU countries must do cross-border reporting. So if an Irish company receives an invoice for services from an EU supplier, that supplier’s country will report it and forward info to Ireland. For non-EU suppliers (e.g. USA), Ireland may rely on the VAT return of the Irish business (still need to reverse charge on the return). There’s no mention yet of requiring an Irish business to self-issue an e-invoice for an imported service (some countries do a “self-invoice” for imports of services, but Ireland historically has not required a separate document; the reverse charge is handled via accounting entries). This could remain outside the transaction reporting system, or Ireland might introduce an option for businesses to input such purchases into the system for completeness. We have to see – in the mandate outline, no explicit method is given, so likely it stays as is (declared on VAT return only). [revenue.ie]
  In summary for reverse-charge scenarios:
  • Domestic reverse charge: There are a few domestic reverse charges (like construction industry reverse charge in Ireland). In those cases, the supplier’s invoice has no VAT and says “reverse charge applies”. Under e-invoicing, the supplier will still do that – issue an e-invoice with 0% and an indicator that reverse charge applies, and this will be reported to Revenue. The buyer accounts for VAT off-system (in their VAT return). The system will hold data showing that supply was reverse-charged (which helps Revenue cross-check that the buyer indeed declared VAT). [revenue.ie]
  • Intra-EU service reverse charge: foreign supplier will report the invoice via their system, data comes to Revenue. Irish buyer’s VAT return should match up.
  • Imports of services (non-EU): likely still just buyer’s VAT return; possibly future integration but nothing yet.
• Zero-rated supplies (exports and certain domestic zero rates): Exports: If an Irish company exports goods to a non-EU country, that supply is zero-rated (no VAT charged) but requires evidence of export. Under e-invoicing, the invoice for an export will be in the system (assuming the business chooses or is required to issue it via the system – as noted, exports aren’t mandated by EU, but Ireland might encourage their inclusion). If exports are not immediately mandated, an Irish company may still put their export invoices through the same system for convenience, though Revenue might not require it until perhaps a later stage. If they do, the invoice would have VAT code “0%” with a note “export” or similar. The system could potentially be linked with customs to confirm goods left the EU (a possible future development). For now, treat exports as zero-rated invoices – if they go through the platform, they must indicate zero VAT and likely a reason code (like “EXPORT”). That data will go to Revenue, which is useful to match against any refund of import VAT on the other side, etc., but mainly just records a sale with 0%. Domestic zero-rated supplies: Ireland has some zero-rated goods domestically (e.g. most food, children’s clothing). Those are just normal domestic invoices but with 0% VAT line items. The e-invoicing system will easily handle that – the invoice carries 0% as the tax category for those items and the total VAT is 0. It’s not an exemption, it’s a zero rate, but either way no VAT is charged. Revenue will see the sale happened (though with no tax due). This helps them ensure the product sold is indeed a zero-rated type, if they cross-check product descriptions or classification (perhaps more detail than on VAT3 now). But functionally, the business just marks the item as zero-rated in the invoice, as they do on paper now. Intra-Community supplies: These are zero-rated as well (0% VAT charged to EU customer with VAT number). We covered that under cross-border – again, invoice must include customer VAT ID and phrase like “intra-Community supply”. E-invoice will have a code for intra-Community supply (likely a tax category code in EN16931). That triggers the data sharing and ensures no domestic VAT is expected on it. The system replaces the VIES listing (so each such invoice’s details go to Revenue and onward to the customer’s country). [revenue.ie] [revenue.ie]
• Exempt supplies: If an Irish business supplies something VAT-exempt (like a financial service to a business), they are still required to issue an invoice if the customer is a taxable person and requests one. The invoice would show no VAT and state the legal reason for exemption (e.g. “VAT exempt per VATCA 2010 Schedule…” usually). Under e-invoicing, such invoices are certainly allowed; they would have a tax category code like “E” (exempt) and perhaps a reason text. Revenue will get these and know there’s no VAT due from the supplier. Currently exempt supplies don’t appear on any VAT return (except just included in total sales maybe), so having transaction data could help Revenue see volumes of exempt dealings. For the mandate: if a business only makes exempt supplies and thus isn’t VAT-registered, they wouldn’t be in the system anyway. But many partially exempt businesses (like banks that have both exempt and taxable outputs) will be in the system for their taxable supplies, and likely will also send invoices for exempt fees through it for consistency. The law doesn’t force an invoice for exempt B2B unless requested, but many do issue anyway. If they do, those invoices should be electronic too. So bottom line: exempt invoices can be issued via e-invoicing and should be if the transaction is otherwise in scope. The invoice must clearly indicate that no VAT is charged and cite the exemption (Irish VAT law requires a notation like “Exempt supply” on the invoice). The e-invoice has a field for that, which must be filled. [revenue.ie]
• Special schemes (margin schemes, etc.): As discussed in Section 1, for margin schemes (e.g. second-hand goods, travel agents) the invoice should not show VAT amount. Instead it is endorsed with the scheme name. Under e-invoicing, those invoices will be transmitted as well. The tax category might be coded as “Not subject to VAT – margin scheme”. The system will convey that no VAT was charged, which is expected. For the travel agent margin scheme (TAMS), similar rules (likely mention on invoice and no VAT shown). The point is that these special scenarios will be reflected in the e-invoice via proper codes and texts, just like on paper invoices. There’s no new reporting form needed specifically for them. [revenue.ie]
• Local nuances and specifics: One local nuance is the flat-rate farmer invoices as mentioned before. In that case, a farmer who is not VAT-registered can still charge a flat-rate addition (5.4%) to a VAT-registered purchaser, and the purchaser can reclaim it. The law requires the purchaser to provide an invoice to the farmer that shows the price and the flat-rate amount. In effect, it’s a self-billing scenario. Under e-invoicing, if, say, a supermarket (VAT-registered) is buying from many small farmers, the supermarket might issue self-billed invoices with the flat-rate addition. Those would be e-invoices (self-billing) with a note “Flat-rate farmer – X% added”. That data goes to Revenue, showing that the flat-rate was paid. The farmers themselves aren’t in the system to issue invoices, but their customers are, and they would report these. This could actually streamline the administration of the flat-rate scheme by giving Revenue transaction-level data on how much flat-rate credit is being passed. But again, nothing changes in obligation: the purchaser must issue that invoice in any case; e-invoicing just changes the format of how they do so. [legalblog.ie]

• “0% VAT – intra-Community supply” with customer VAT ID for EU sales. [revenue.ie]
• “0% VAT – export” for exports.
• “VAT Reverse Charge” for cases where recipient pays VAT. [revenue.ie]
• “Exempt supply” for exempt services (with legal reference possibly).
• “Margin scheme – second-hand goods (or travel, etc.)” for margin scheme invoices. [revenue.ie]
• “Flat-rate farmer” for those special self-bills. These keywords or codes ensure each scenario is properly flagged to both the buyer and Revenue. The e-invoicing schema has allowance for “VAT category code” (like Standard rate, Zero rate, Exempt, RC for reverse charge) and also free text notes where needed for legal references. Ireland will make use of those to implement the existing obligations. [legalblog.ie]

• Retention period: Irish law generally requires that all VAT records (including invoices) be retained for 6 years from the date of the transaction (or longer in certain circumstances). This 6-year retention rule will continue to apply in the e-invoicing regime. In other words, an electronic invoice must be stored for at least 6 years after its issue (or the tax year of issue, effectively). There are some specific cases where records might need to be kept longer – e.g., records related to property transactions or waivers of exemption must be kept for 6 years after the event ends (which can make it longer total), but those are special cases. For most invoices, six years is the period. This aligns with what companies already do for paper or PDF invoices. [sovos.com], [revenue.ie] [revenue.ie]
• Format of archiving: Electronic invoices must be archived in a way that guarantees their integrity and readability over the entire retention period. Ireland’s rules allow invoices to be stored electronically (and indeed paper invoices can be converted to electronic and stored, with Revenue’s permission). The key requirements are that the e-invoice data cannot be altered once stored (integrity) and that it can be reproduced in legible form on request. Typically, businesses will store the original XML files in secure archive systems. They may also store human-readable versions (like PDF renderings) for convenience, but the legal record is the structured data plus the ability to present it intelligibly. Mandatory archiving format could simply mean keep the original electronic format. There is no requirement to print out e-invoices (that would defeat the purpose). In fact, Revenue explicitly equates electronic storage with paper storage as long as certain conditions are met. Businesses can use specialized e-archive solutions that often include digital signature or hashing to ensure integrity. Ireland doesn’t mandate use of a particular technology (like some countries require a specific format or clearance from an archive service). It just mandates the outcome: authenticity and integrity over time. Many will rely on system controls and possibly digital signatures/hashes to ensure invoices haven’t changed. Each invoice typically will have a unique ID and possibly checksums. As long as those match and the record is unchanged, it’s good. [sovos.com] [revenue.ie]
• Location of storage (local vs remote): Current guidance says paper records must be kept within the State (Ireland) unless Revenue agrees otherwise. For electronic records, the requirement is a bit more flexible: they must be maintained in a manner accessible from Ireland. The official guidance states: “Retain electronic records in accordance with the electronic invoicing rules”. Those rules (stemming from EU Directive 2010/45/EU as implemented) allow storage in another EU country provided they are accessible to tax authorities without undue delay. Ireland likely permits electronic records to be stored on servers outside Ireland (including cloud servers in other countries), on the condition that: [revenue.ie]
  • Revenue can request them and get them delivered/produced in Ireland quickly.
  • The records meet all integrity/authenticity requirements.
  • If stored outside the EU, possibly additional conditions or permissions might be needed (the law isn’t explicit, but often Revenue would want assurance of access).
    The absence of a strict “must be in Ireland” for electronic records indicates EU-wide storage is acceptable. Many Irish companies use cloud solutions (some of which host data in datacenters across Europe). This is generally fine as long as the data is secure and accessible. In some cases, businesses seek Revenue’s consent for storing records abroad. For electronic, an implicit consent might exist if conditions are met. To be safe, if storing outside Ireland (especially outside the EU), companies might inform Revenue. But what’s crucial is that records are kept in a readable format and can be retrieved promptly by name, date, etc.. So a company in Ireland could archive invoices in, say, an AWS cloud in EU or a SharePoint, etc., provided they ensure the above. [revenue.ie]
• Ensuring integrity and authenticity: From the moment of issuance until the end of the retention period, an invoice’s contents must remain unaltered (integrity) and it must be possible to verify the identity of the issuer (authenticity). Under e-invoicing, authenticity is largely ensured by the fact that the invoice travels through the structured system from a known sender (e.g., via a registered Access Point). Additionally, each invoice likely will have a unique identifier or maybe a digital signature or hash attached either by the system or by the issuer. While Ireland doesn’t force a specific method, companies might implement digital signatures on archived invoices to prove they haven’t been tampered with. Alternatively, some will rely on the secure audit logs of their ERP systems (this is called “business controls” ensuring a reliable audit trail). The EU standard allows either approach. In practical terms, an archived invoice file should be exactly the file originally sent/received. Good practice is to store it in a write-protected environment (e.g., WORM storage or with checksums). When asked by Revenue, the business should be able to demonstrate that these files are what were issued, not modified later. Many e-invoicing archive solutions automatically apply time stamps and hash chains to meet these requirements. Ireland’s rules simply say maintain a “reliable audit trail” and be able to validate source and content integrity. So a company might show, for instance, that the invoice file’s SHA-256 hash matches the hash recorded at time of sending, or that it’s digitally signed by the sender’s certificate. [sovos.com], [revenue.ie] [revenue.ie]
• Readability and accessibility: It’s not enough to keep the raw data; one must be able to render it in a human-readable form quickly if needed. Revenue officers may request to see invoices in a legible format. Therefore, businesses should have tools to convert the XML to a formatted display or printout (like using a viewer that turns it into a replica of an invoice PDF). They should also index and organize archives so that any given invoice can be located by key references: e.g., by invoice number, by date, by customer or supplier name, etc.. The regulation explicitly requires that electronic records be stored in a manner allowing retrieval by those references (name, date, number). That means your archive solution should have search functionality. If Revenue comes for an audit and says “show me invoices 1001 to 1050 from March 2029” or “show me all invoices to Customer X in July 2030”, the company must be able to pull those out without delay. Keeping them in a structured database or using a commercial archiving system accomplishes this. [revenue.ie]
• Audit access: Revenue has broad powers to inspect records, including electronic records. During an audit, they may request access to the e-invoice archive. There are a few ways this can happen: [revenue.ie]
  • The business might export the requested invoices (in XML or PDF form) and provide them to the auditor on a disk/drive.
  • The auditor might view them on the company’s system.
  • In some advanced cases, tax authorities can be granted read-only remote access to an archive. It’s not explicit that Ireland demands remote access, but EU law allows tax authorities to access electronic records stored abroad online if the business provides that. The key is that there should be no hindrance to the auditor obtaining and reading the records. If records are stored abroad and, say, privacy laws could impede access, that would be an issue – so companies must ensure compliance with any data protection law but still fulfill tax record obligations (often tax data is exempt from local privacy blocks since it’s legally required data). [revenue.ie]
  Also, under Council Regulation (EU) 904/2010 on administrative cooperation, tax authorities of EU countries might request each other for invoice data. With e-invoicing, much will flow automatically, but for archives of older stuff or domestic, Revenue might have to supply copies to other jurisdictions upon request. A good archive makes this easy.
• Local vs EU vs Third-country storage:
  • Local (within Ireland): E-invoices can be stored on servers in Ireland freely. Many companies might use local data centers or on-premises storage – fully allowed, but ensure backups etc.
  • EU storage: Storing in another EU country is generally permitted as EU VAT law (and Irish regulations transposing it) say storage can be abroad if accessible online. Since all EU jurisdictions have similar 6-10 year requirements, it’s common to centralize EU archives. Ireland doesn’t restrict that as long as Revenue access is guaranteed.
  • Outside EU (third-country): This is a bit trickier. EU law doesn’t forbid it outright, but Member States can require that such storage be notified or that access is via the business in the Member State. Irish guidance requires Revenue permission to keep paper records outside Ireland. For e-records, one might infer similar caution. If a company wants to use a data center in the US, for instance, it would be prudent to inform Revenue or ensure mirror copies in EU. In practice, many multinational companies do keep electronic records on global servers, but they often maintain that they can pull any needed data to Ireland promptly. To be safe: either keep a duplicate copy within Ireland/EU or formally seek clearance from Revenue for third-country storage. Given the prevalence of cloud, likely what matters most is on-demand access. If you can, at audit, immediately retrieve any invoice, the auditor probably won’t mind that it physically sits on a server in say UK or US. But if internet issues or legal hoops hamper retrieval, then it’s not compliant. [revenue.ie]
• Acceptable archiving methods: Ireland doesn’t mandate one method like some countries require “fiscal archives” or notarization. It leaves it to the business. Options include:
  • Using your ERP’s database to store invoices and ensure backups – but must be careful that data isn’t editable after the fact without trace.
  • Using a dedicated e-archiving solution that might include time-stamping and locking files.
  • Outsourcing archiving to a service provider specializing in compliant storage (some providers offer certified e-archiving as a service).
  • Even storing on durable media (like WORM drives). But retrieving from those might be slower.
  Many e-invoicing service providers also offer integrated archiving to meet multi-country rules. Basware, for example (from which we saw info), suggests that Ireland requires retention for six years and presumably their solution covers that. Basware also notes no specific mandated solution, just ensure compliance. So businesses can choose their approach but must meet the criteria. [basware.com], [basware.com]
• Original vs copy: When storing electronically, it’s considered that the electronic file is the original if that’s how it was sent/received. If a paper invoice is scanned into electronic form, one should get Revenue’s blessing that the scan will count as the VAT record (Revenue usually allows this if quality is good and controls are in place). In an e-invoice world, no scanning needed because it’s born digital. Companies might still generate a human-friendly PDF as a courtesy copy, but the key record to keep is the XML data, since that’s what was actually exchanged. Both XML and any human-readable equivalent should be retained together ideally.
• Integrity and readability over time: A challenge can be that file formats or systems can become obsolete in 6+ years. XML is fairly future-proof (being plain text), but it’s possible that the specific schema could evolve. It’s important that if the schema changes, companies still preserve the original invoices under the old schema along with documentation so they can interpret them later if needed. Being plain XML, one can always read it with a text editor, but understanding the context might require the schema definition. So including the XSD or documentation in archive might be wise. Or at least, by law, they might have to be able to present them in “readable form” – which could mean by then you have a reader for old invoices or convert them to the newer format.
• Audit trail and logging: The requirement for authenticity and integrity implies an audit trail – i.e., you should have logs of invoice creation, sending, any modifications (though modifications aren’t allowed except via credit notes). If an invoice got canceled or credited, those notes too should be kept. The system itself (the e-invoice platform) will likely generate logs/receipts (like a timestamp of when it was reported, message IDs, etc.). These might be needed to demonstrate compliance (like “yes, we sent it on time; here’s the acknowledgment from Revenue”). It’s good practice to keep those acknowledgments and any related communications as part of records. Possibly not mandatory by letter of law, but helpful if contested.
• Legal admissibility: In case of disputes, the archived e-invoice is a legal document. EU rules say an invoice in electronic form is acceptable evidence if authenticity and integrity are guaranteed. With proper archiving, an e-invoice should be admissible just like a paper invoice. Integrity measures (like a hash or signature) can provide non-repudiation. While not explicitly a requirement, many companies will sign their invoices (or archives) to strengthen evidential value. However, as pointed earlier, Ireland doesn’t force digital signatures by law (optional). [cleartax.com]

• Failure to issue a required invoice: If a taxable person fails to issue a VAT invoice when obliged to (which, under the mandate, includes failing to issue it in the proper electronic form once it’s required), they can face a fixed penalty. Currently in Ireland, the penalty for not issuing a VAT invoice as required is €4,000 per offense. This figure is set by Section 115 of the VATCA 2010 (general VAT penalties). We can expect that if a business does not comply with e-invoicing (e.g., continues to issue only paper or PDF invoices when they should be e-invoicing, or refuses to issue an invoice at all), Revenue could levy this €4,000 fine for each instance of non-compliance. Essentially, not using the platform to issue an invoice when mandated = failure to issue a proper VAT invoice, which is an offense. [spaceinvoices.com], [spaceinvoices.com]
• Late or incorrect e-reporting: If an invoice is not reported in time (say a business delays sending it to Revenue beyond the allowed window) or if the report contains inaccuracies (e.g., wrong amount due to not following the data format), penalties can arise. This might be treated analogously to an incorrect VAT return or VIES statement. Given the newness, specific new penalties might be introduced, but likely they’ll use existing ones: For example, failing to comply with “regulations made under the VAT Act” might incur a general penalty. Not submitting required information timely could fall under a default penalty. Presently, late VAT return filing or failure to submit a VIES return can also trigger €4,000 fines. It’s reasonable that failing to meet e-reporting deadlines would similarly be penalized. So if a company systematically delays sending their e-invoices (thus not in real time), Revenue could impose penalties or surcharges. However, initial enforcement might be lenient (warnings first) as businesses adjust.
• Not using the mandated platform (platform non-compliance): If a business tries to circumvent the system (for instance, they issue invoices outside the platform to avoid reporting), that’s essentially a compliance breach. Revenue could treat each such invoice as an unreported transaction – potentially invoking penalties not just for failing to invoice properly but also possibly considering it a more serious offense if done willfully (like evasion). Repeated non-compliance could lead to audits or prosecutions for tax evasion if VAT is unaccounted. However, for formal penalty, it would be covered by the above “failure to issue invoice” fine. There isn’t a separate fine just for “not using Peppol.” It translates to either not issuing an invoice or issuing an improper invoice.
• Failure to keep or archive invoices correctly: If a business does not retain the invoices for 6 years or fails to ensure their availability to Revenue, there is a penalty of €4,000 for failure to keep proper books and records. This would encompass issues like deleting invoices early, not being able to produce them on request, or not maintaining integrity. Additionally, obstructing a Revenue officer’s access to records is an offense. So, archiving violations (like missing records, or storing them in an unreadable way) can trigger that €4,000 general penalty for records. Each inspection where records are found lacking could incur this fine. [spaceinvoices.com], [spaceinvoices.com]
• Intentional or negligent errors: If a business deliberately tampers with invoices or submits false data through the system, it could be subject to heavier penalties. Irish law distinguishes “careless” vs “deliberate” behavior for incorrect returns/records. A careless (but not deliberate) submission of incorrect information can lead to a penalty (in VAT context) usually up to 10% of underpaid tax or a fixed amount if no tax underpayment is directly quantifiable. The document provides an example: incorrect VAT records can be penalized €3,000 for careless behavior and €5,000 for deliberate behavior. Those figures might be specific to record-keeping offences. However, if false information leads to underpayment of VAT, the penalty can be a percentage of the tax underpaid (up to 100% for deliberate evasion). E-invoicing data will tie into that: e.g., if someone deliberately doesn’t report some invoices to evade VAT, that’s tax evasion – penalties (and interest) on the unpaid VAT and potentially prosecution. [spaceinvoices.com]
• Denial of zero-rating or input credit: A form of enforcement beyond fines: under EU law, if a business does not comply with the e-invoicing mandate for cross-border sales, they may lose the right to treat that sale as zero-rated intra-Community. The ViDA directive suggests that an invoice not issued electronically might not be recognized for the 0% VAT exemption on EU supplies. Thus, a serious consequence is that a cross-border sale could be reclassified as domestic taxable if not properly e-invoiced, meaning the supplier might have to pay Irish VAT on it (which is a huge incentive to comply). This is essentially an enforcement mechanism built into the law. Similarly, for purchases, tax authorities might deny the input VAT credit if the purchase invoice wasn’t properly reported (though that’s less clearly stated, it can happen if something is not considered a valid invoice). For instance, if an Irish company insists on receiving a paper invoice from a domestic supplier who should e-invoice, Revenue could argue the paper invoice is not a valid VAT invoice (post-mandate) and thus deny input credit to the buyer (though that would penalize the buyer for the supplier’s fault, which is tricky – more likely they’d go after the supplier with fines). But definitely for cross-border, if not e-invoiced, the 0% can be disallowed, effectively charging VAT that the supplier would have to remitt. That’s a strong enforcement lever.
• Penalties for late returns or payments: These still apply; while not directly about e-invoicing, if a business fails to incorporate the reported data into their VAT return and pay the right tax, normal penalties/interest apply. For instance, late VAT payment interest is ~0.0274% per day in Ireland. Those remain unchanged. But the e-invoicing may reduce certain mistakes that lead to these, ideally. [spaceinvoices.com]
• Penalties for failing to comply with platform technical rules: The current law may be amended to include, for example, a penalty for not transmitting data electronically as required. Many countries explicitly add something like “penalty X for not submitting e-invoice data to the tax authority.” If Ireland does, expect the penalty to align with the general €4k figure per breach or maybe per period. Given the existing structure, they might rely on general clauses rather than new ones.
• Enforcement approach: Revenue has indicated that it recognizes the significant change and is committed to supporting businesses through it. Early on, enforcement might focus on education and nudges. However, once the system is mature, Revenue will likely use automated checks to enforce compliance. For example, they will know which companies are in Phase 1 and can monitor if they are indeed sending invoices. If not, they can send reminders or warnings. They might impose penalties for continued non-compliance fairly quickly because by Phase 1 those are large companies that should be capable. For smaller ones in Phase 2, maybe a softer approach initially. But ultimately, the law-backed penalties as described above can and will be applied for serious or persistent failures. [revenue.ie], [deloitte.com]
• Prosecution for evasion: If e-invoicing data reveals deliberate fraud (like creating fake invoices or failing to report sales), Revenue can prosecute under existing tax evasion laws. That could mean larger fines or even imprisonment for serious cases (though usually imprisonment is for egregious VAT fraud cases). For instance, missing trader fraud rings could be caught by data analysis, and those involved could face criminal charges beyond administrative penalties.
• Instances of penalty references: The compiled information [14] in the Spaceinvoices guide lists concrete penalties:
  • Not registering when required: €4,000. [spaceinvoices.com]
  • Failure to charge/pay VAT: €4,000. [spaceinvoices.com]
  • Failure to keep proper records: €4,000. [spaceinvoices.com]
  • Failure to comply with invoicing requirements: €4,000. [spaceinvoices.com]
  • Late/non-filing of returns: €4,000 each. [spaceinvoices.com]
  • Late payment interest: ~0.0274% per day. [spaceinvoices.com]
  • Incorrect records due to careless vs deliberate: €3,000 vs €5,000. [spaceinvoices.com]
  • “E-invoicing Non-Compliance: Penalty €4,000… for failures such as not issuing electronic invoices when mandated.” (That last line shows how the general invoice penalty is basically being interpreted to cover e-invoicing specifically). [spaceinvoices.com]

• Grace/leniency periods: Though not officially stated, often when new systems go live, authorities might have a grace period where they issue warnings or reduce penalties. Ireland hasn’t detailed this yet. Possibly for the first few months of Phase 1 and Phase 2, they might not immediately fine a company for a minor slip (particularly SMEs). But this is at Revenue’s discretion. The law on penalties doesn’t automatically wait – but enforcement can be calibrated.
• Audits & compliance checks: We can expect Revenue to increase VAT audits focusing on e-invoicing compliance. They might do system audits where they check that a business’s software is properly sending invoices and archiving. Also, they’ll use analytics on the e-invoice data to find anomalies (like a business that stops sending data suddenly, or gaps in invoice sequences, etc.). Such triggers could prompt an audit or inquiry. The knowledge that Revenue has detailed transaction data might itself deter non-compliance.
• Peer enforcement (indirect): Interestingly, with mandated e-invoicing, your business partners help enforce compliance. For example, if a supplier is mandated to send e-invoices but tries to send a paper one, the buyer might refuse it because they know it should be electronic. Conversely, a buyer might demand a legal invoice to reclaim VAT; if they don’t get an e-invoice where required, they might bug the supplier because they fear losing their VAT credit. So there’s a self-policing aspect: once the system is norm, businesses will pressure each other to use it. This reduces chances of non-compliance out of convenience.
• International enforcement: Since much is EU-driven, Ireland will share data with other countries. If an Irish company doesn’t report an EU sale, the other country may alert Irish Revenue (like “we see an invoice from our side of a purchase from X Irish company that wasn’t reported by them”). That cross-check ability means hiding transactions is much harder without being caught.

• A standard €4,000 fine for failures in invoicing, reporting, or record-keeping. [spaceinvoices.com]
• Potential denial of VAT reliefs (0% rate) for non-compliance (especially cross-border).
• Interest on any late paid VAT arising from non-reporting.
• More severe penalties or prosecution for deliberate fraud.

• Current situation (no pre-filled returns): At present, Ireland does not provide pre-populated VAT returns for taxpayers. VAT-registered businesses must file periodic returns (bi-monthly by default, or quarterly/monthly/etc. under certain conditions) in the Revenue Online Service (ROS), entering the total sales, total purchases, and VAT due/refundable themselves. These returns are summary-level and are not automatically populated with data from invoices. There is currently no mechanism where Revenue sends you a draft return – it’s entirely taxpayer-prepared. So as of now, no pre-filled VAT returns exist in Ireland; each taxpayer is responsible for compiling figures from their records and submitting the return. [spaceinvoices.com]
• Plans or future introduction: The e-invoicing roadmap documents did not explicitly mention pre-filled returns, focusing instead on reducing administrative burdens by eliminating separate reports (like VIES) and making compliance easier. However, since real-time reporting will provide Revenue with detailed sales and purchase data, the foundation for pre-filled returns is being laid. Revenue’s narrative emphasizes modernizing VAT to integrate with business processes and reduce compliance costs. In some countries (e.g., Italy, Spain), once electronic reporting was in place, tax authorities began to offer pre-calculated VAT ledgers or returns. The EU ViDA initiative also envisions moving towards more automated compliance for businesses. Ireland has not yet officially announced a pre-filled return system, but it is likely to consider it once e-reporting data is reliable and comprehensive. A statement in the Revenue doc indicates real-time data will “reduce the likelihood of compliance interventions for compliant businesses” and help with “faster processing of VAT repayment claims”. That suggests that with data in hand, Revenue might automatically process refunds or at least verify them faster. Pre-filling returns could be a logical next step to help compliant businesses. [revenue.ie], [revenue.ie] [revenue.ie]
• Reliance on e-invoicing/e-reporting data: If and when pre-filled returns are introduced, they would indeed rely on the e-invoicing data. For example, Revenue could sum up all the sales reported by a business in a period (from the outgoing e-invoices) to suggest the Box T1 (VAT on sales) figure, and sum up all purchases reported by suppliers to that business (the business’s incoming invoices) to suggest the Box T2 (VAT on purchases) figure. Any adjustments (like corrections, or items not captured by invoices such as import VAT or some domestic reverse charges) would still have to be added by the taxpayer. But the heavy lifting of listing all sales and purchase totals could be done by Revenue’s system. However, achieving this will require that virtually all transactions are captured – which by 2030 (with domestic and cross-border B2B in system) could be close to true, except B2C sales (which don’t generate input credit anyway) and possibly import services or such.
• Whether planned: Officially, Ireland has not published a plan to implement pre-filled returns yet. The initial focus is on implementing the e-invoicing and ensuring compliance. Pre-filling might come after the system has been running stably for some time. It could be an incentive the authorities introduce to encourage timely e-reporting: e.g., “if all your invoices are reported, we’ll give you a draft return to simply confirm or correct.” That would indeed lower admin burden. The question’s phrasing “whether they are planned” suggests looking for any indication. As of the latest info (end of 2025), we don’t have a concrete public statement that “Ireland will start issuing pre-filled VAT returns in year X”. We might mention that some other EU countries are doing it as part of their digital reporting, implying that Ireland could follow suit.
• Prefilled fields vs still input by taxpayer: If pre-filling were in place, likely some fields could be auto-calculated:
  • Total output VAT and total inputs based on e-invoices.
  • It could even break down sales by rate (since the invoice data includes rate breakdown). But the taxpayer might still need to input certain things:
  • Any corrections or amendments (e.g., bad debt relief claims, or manual adjustments).
  • Transactions not captured by e-invoicing (one example: imports from outside EU – currently, import VAT is not reported through e-invoicing, it’s handled via customs/ postponed accounting statement).
  • Some sectors like flat-rate farmers, or unregistered to registered self-account, etc.
  • VAT on reverse-charged imports of services from outside EU might not be fully captured by e-invoices (depending on if they require self-report). In short, some fields would be prefilled, but some would still need input. For instance, European Commission’s vision is that with digital reporting, the tax authority can pre-fill at least the sales listing part of the return and possibly the purchase listing for domestic transactions. The taxpayer might then just confirm and add any missing items. At minimum, one could imagine a prefilled draft of the VIES (EC Sales List) is no longer needed individually by taxpayers because with e-invoicing, Revenue automatically has all that info. In effect, the VIES return will be abolished and folded into the system. That’s already a given under ViDA. Pre-filling the main VAT3 return is the next step from that. [revenue.ie]
• Any existing partial features: Currently, Ireland does not pre-populate any part of VAT3. However, note that for certain taxes like payroll (PAYE) and some income tax credits, Revenue does provide prefilled info (like incomes reported by employers). But for VAT, not yet. With e-invoicing, they could eventually mirror e.g. Spain’s approach (Spain’s SII provides a draft VAT return form called “Pre303” if all data is in SII). Possibly by the early 2030s, Ireland could do similar.
• What would pre-filled likely include: Likely things like:
  • The total taxable sales in each VAT rate category and corresponding VAT amount (because e-invoices detail which rate was applied per line) – so the sales and output VAT portion of the return could be almost entirely derived from the reported invoices.
  • The total taxable purchases (inputs) and VAT on those – which come from supplier invoices you received. However, note that to prefill inputs, Revenue needs to marry supplier outputs to buyer inputs. With full domestic e-invoicing, they do have both sides, but currently if a foreign supplier sells to Ireland, the invoice goes to the foreign system and is to be shared to Ireland. That should happen via ViDA central VIES replacement. So yes, they could know your EU inputs too.
  • Things like “VAT on imports” – if postponed accounting is used, Revenue already provides a statement, not sure if that could feed automatically.
  • If one uses the Domestic Reverse Charge (construction) or certain self-account scenarios, those might not come from an invoice from a supplier (the supplier in domestic RC issues a document without VAT, and the buyer self-accounts). Possibly these can be addressed by the buyer issuing a self-invoice into the system or the supplier’s “document” going into system. If captured, those can be prefilled as well (the output and input for the same amount).
  • Prefilled return fields might include: T1 (VAT on Sales), T2 (VAT on Purchases), T3 (VAT payable or repayable), and maybe E1/E2 which are intracommunity sales/purchases totals for the period. Actually, if e-invoices track cross-border, E1 and E2 (which are currently on the VAT3 form for EU trade totals) could be known directly.
  • They likely would not prefill the net payable, because that’s just T1 – T2 in formula, but they could show it.
• Which fields still require input: Possibly:
  • Adjustments like credit notes that were issued late or outside period? But if credit notes are e-invoiced too, they are captured, just negative invoice.
  • Any partial exemption calculations (if a business can’t reclaim all VAT because of exempt activities, that’s not visible from invoices; the business would have to adjust their input claim manually).
  • Annual adjustments (like capital goods scheme or adjustment of provisional vs actual deductible ratio at year-end). Those are not transaction-level, so the business must add them.
  • VAT that is not linked to an invoice: e.g., if you gift business assets and have to account for VAT, you do that via an internal accounting entry, not an invoice. The system wouldn’t automatically know unless you issue yourself an invoice. Possibly such things remain manual.
  • Also, if a business missed reporting an invoice in the time and catches it later, they might have to manually adjust.
• Timeline for pre-filled introduction (if any): Possibly after 2030, once the data from Phase 3 is flowing. The EU is also exploring something called “transaction-based VAT returns” which might even replace the concept of a separate return. It could be that by 2030s, the periodic return becomes a mere confirmation of totals that the system already has. In the interim, maybe by mid-2030’s, Ireland might start offering prefilled drafts. But until any official word, we say no prefilled returns as of now or immediate plan.
• Eurofisc data sharing: Not directly in prefill, but since all cross-border will be reported, the need for businesses to fill out certain parts of returns (like listing EU acquisitions) will go away. That itself is a relief.
• Conclusion of answer for this section: At present, no pre-filled VAT return system exists in Ireland, and none has been explicitly scheduled yet. However, with the advent of comprehensive e-invoicing data, the groundwork is there for possibly introducing pre-populated returns in the future. For now, businesses will still need to prepare and submit their VAT returns, but they can expect that some compliance burdens (like separate EC Sales Lists) will be eliminated by the use of e-invoicing. [revenue.ie]

• Output VAT would be prefilled from e-invoices issued.
• Input VAT could be prefilled from e-invoices received.
• But taxpayer would review these and add any missing items (like import VAT or adjustments).

• Prefilled: totals of domestic and intra-EU sales and the VAT on them (from your outgoing invoices), totals of purchase VAT (from incoming invoices), and possibly the net calculation. [revenue.ie]
• Require input: any VAT due on imports or reverse charges not captured by an invoice, any adjustments (e.g. bad debt relief claims, annual corrections), any exempt or partial exemption adjustments, etc.

• Phased onboarding and transition for SMEs: One important aspect is that Ireland’s phased approach deliberately schedules SMEs later, giving them more time. Phase 1 targets only large corporates, and Phase 2 in 2029 will pull in the rest mainly if they engage in EU trade. This means many purely domestic SMEs might not be mandated until possibly 2030 or later (a micro local business with no EU sales might effectively be last). The gradual timeline is a form of relief for SMEs, allowing them to learn from early adopters and better prepare. Additionally, during the consultation, stakeholders highlighted the need for clear guidance and support especially for smaller enterprises. Revenue has committed to intensive engagement and support to ensure practical implementation for businesses of all sizes. This suggests there might be training sessions, helpdesks, possibly even financial support for software (though nothing specific is announced, awareness of SME needs is clearly stated). [bdo.ie] [revenue.ie] [revenue.ie], [deloitte.com]
• Simplified regimes and threshold exemptions: Ireland is likely to maintain existing simplifications. For example, businesses below the VAT registration threshold (~€37.5k/€75k turnover) remain outside scope entirely (as they don’t register for VAT) – effectively an exemption for micro-businesses from the mandate. Also, the One Stop Shop (OSS) for small cross-border B2C sales means such sellers don’t issue invoices and that continues. So, micro-enterprises selling to EU consumers via OSS won’t suddenly have to e-invoice those sales. There isn’t a new threshold specifically for e-invoicing, but the general VAT threshold serves as one (if you’re not VAT-registered, you don’t participate). Another simplification in EU proposals is possible cash accounting alignment – however, e-invoicing doesn’t alter cash accounting scheme usage (that’s internal). No special SME “light regime” is defined yet, but the long lead time and existing small business exemptions mitigate the immediate impact on the tiniest firms. [revenue.ie]
• Government support programs: While not yet specified for e-invoicing, Ireland does have digitalization grants for SMEs (for example, the “Digital Start” or local enterprise office vouchers). The Digital Ireland Framework mentioned by Revenue stresses helping SMEs adopt technology. It’s plausible that as e-invoicing rollout nears, the government could introduce support such as: free basic e-invoicing tools, training programs, or even subsidies for purchasing compliant software. Indeed, other EU states (France, etc.) are providing free solutions for small businesses to use the e-invoice portal. Ireland’s Revenue said they are exploring options to make meeting the obligation “as straightforward as possible for all businesses”. This hints at possibly providing easy-to-use solutions (maybe a web portal or plugin in ROS for invoice submission). Startups and SMEs often use off-the-shelf accounting software, and those will likely update to comply, possibly at low cost via subscription. Also, since Ireland uses Peppol which many inexpensive services support, SMEs can choose a low-cost provider on the market for e-invoicing. In sum, support will come in the form of guidance and accessible technology. If needed, the government might step in with direct help (to be seen, but commitments to support are documented). [revenue.ie]
• Cost of compliance: For SMEs, the shift will bring some upfront costs:
  • Upgrading or acquiring software that can generate and send e-invoices. Many SMEs currently might use basic invoicing tools (Excel, Word, etc.) which won’t suffice. They might need to invest in a compliant software or an online service. However, numerous affordable cloud invoicing and accounting platforms exist, and they are expected to incorporate Ireland’s requirements by 2028. Competitive pressure should keep costs reasonable. For instance, some solutions might charge a small monthly fee based on number of invoices. There could also be free options (e.g., if Revenue provides a free portal or if open-source tools like PEPPOL access are used).
  • Potentially fees for a Peppol Access Point provider. Some providers charge per invoice or a flat fee. But for low volumes, these fees are often minimal (some countries see maybe €0.10–€0.50 per invoice charge by providers). For micro businesses issuing few invoices, the absolute cost is small.
  • Implementation time: learning the new system, training staff or oneself to use new software. That’s a one-time productivity cost.
  • If an SME has an older ERP, integration could cost developer time to update.
  A 2022 EU study predicted significant initial investments EU-wide for businesses to adapt to digital reporting but large savings in compliance costs later. Ireland’s own consultation responses from businesses likely brought up cost concerns, which is why they emphasize reducing compliance cost in the long run. A Big4 newsletter (Deloitte) noted that while the long lead time (3 years to first phase) is welcomed, companies of all sizes will need “time and resource investment” to upgrade systems and processes. SMEs will need to allocate resources in the years before 2029 to get ready (preferably in 2027-2028). [revenue.ie] [deloitte.com], [deloitte.com]
  There is also reference that early preparation can allow integration with broader digital transformation, implying the cost can be folded into general improvements that yield benefits (like faster processes). [bakertilly.ie]
• Administrative burdens vs simplifications: Initially, SMEs may feel burdened by having to change how they issue invoices (which is a core admin process). There will be a learning curve and transitional overhead. However, over time there are potential simplifications:
  • With automatic reporting, SMEs might spend less time compiling VAT returns or listings. For example, if one day the VAT return is partly pre-filled or at least the tedious VIES report goes away (as it will), that’s less form-filling for the SME. [revenue.ie]
  • E-invoicing should reduce errors (like arithmetic mistakes on invoices or missing mandatory info) because the software will enforce those. This can save time correcting issues and prevent audits triggered by errors. Indeed, the consultation found businesses expect compliance efficiencies, provided guidance is clear. [revenue.ie]
  • If SMEs use software that integrates invoicing with accounting, they get automation benefits (like automatic posting of sales, easier preparation of accounts).
  • Digital invoices can be processed faster by customers, potentially leading to quicker payments (important for SME cash flow). A small company might get paid sooner if their big customer’s AP system automatically processes the e-invoice and schedules payment.
  • Real-time reporting could reduce the risk of penalties by catching mistakes early. For instance, Revenue might notify a business if something looks off rather than waiting for an audit years later, meaning small issues can be fixed quickly.
  • No more paper handling or postage: SMEs that still post invoices or email PDFs might save on printing, mailing, and manual emailing time. Over a year, that’s a modest cost saving.
  • Over the longer term, as indicated by EU analysis, the hope is that compliance costs (bookkeeping, preparing returns, etc.) drop because so much is systematized. The Revenue paper cites an EU estimate of €4.1 billion annual compliance cost reduction EU-wide due to e-invoicing over ten years. SMEs would get a share of that benefit since large companies already have efficient processes and it’s often SMEs who struggle more with compliance overhead. [revenue.ie]
• Cash flow effects: This can be positive or negative:
  • Positive: If invoices are processed faster and mistakes (which cause payment delays) are reduced, SMEs might get paid faster by clients. Also, Revenue mentions faster VAT repayment processing as a benefit [bakertilly.ie]