Ireland confirms phased e‑invoicing – while the UK weighs a different path

Under Ireland’s roadmap, the obligation is introduced gradually:

• November 2028 – mandatory e‑invoicing and real‑time reporting for large VAT‑registered corporates on domestic B2B transactions
• November 2029 – extension to VAT‑registered businesses engaged in intra‑EU trade
• July 2030 – full alignment with ViDA, covering all cross‑border EU B2B transactions

Crucially, all Irish VAT‑registered businesses must be able to receive structured e‑invoices from November 2028, even if they are not yet required to issue them. This “receive‑ready” obligation is intended to smooth adoption but also introduces practical complexity for businesses sitting outside the early phases. [kpmg.com], [ey.com], [rtcsuite.com]

Official Revenue documentation and professional firm analyses confirm that Ireland will rely on EN 16931‑compliant structured invoices and leverage the PEPPOL network, with PDFs and scanned invoices explicitly excluded from meeting the new requirements. [revenue.ie], [kpmg.com]

Key links:

• Irish Revenue – VAT Modernisation: Implementation of e‑Invoicing in Ireland (Revenue.ie)
• KPMG – Ireland: Phased rollout of mandatory e‑invoicing and real‑time VAT reporting (KPMG TaxNewsFlash)
• EY – Ireland announces introduction of e‑invoicing (EY Global Tax Alert)

A contrast with the UK approach under consideration

By contrast, HMRC is currently consulting on a UK e‑invoicing regime that does not envisage phasing by taxpayer size or activity, at least in principle.

Following the February–May 2025 consultation and the Autumn Budget 2025, the UK government confirmed its intention to introduce mandatory e‑invoicing for all VAT invoices from April 2029, applying across B2B and B2G transactions in one step. [gov.uk], [kpmg.com]

While detailed design work is ongoing, the government response explicitly positions this as a broad, economy‑wide mandate, rather than a staggered rollout by segment. Real‑time reporting to HMRC has been explicitly deferred, with e‑invoicing viewed as the foundational capability first. [gov.uk], [fiscal-req…ements.com]

This “big‑bang” approach arguably provides greater certainty around who is in scope and when, avoiding some of the boundary and classification issues that arise in phased regimes (e.g. large vs small taxpayers, domestic vs cross‑border activity). At the same time, it concentrates delivery risk and places significant pressure on readiness across the entire market.

Key links:

• HMRC – Promoting electronic invoicing across UK businesses and the public sector: consultation response (GOV.UK)
• KPMG UK – Autumn Budget 2025: Electronic invoicing (KPMG UK)
• Fiscal Solutions – UK Mandatory E‑Invoicing from 2029: Main points from consultation response (Fiscal‑Requirements.com)

Important caveat – and a call to engage

All of this comes with an important health warning. In the UK, HMRC is still actively consulting and co‑designing the regime, with further stakeholder engagement, technical collaboration and an implementation roadmap expected around Budget 2026. Representations can – and should – continue to be made throughout this process, particularly on scope, standards, transition, and interoperability.

👉 Have your say: businesses that engage early are far more likely to influence outcomes than those that wait for final rules to land.