Mandatory Domestic E-Invoicing and Digital VAT Reporting on a Legislative Footing for 1 November 2028

KGT Country Update | Ireland | 30 October 2026

Between 19 and 22 October 2026, the Irish Revenue Commissioners and the Department of Finance moved Ireland’s VAT modernization program from roadmap to legislation.

The Finance (No. 2) Bill 2026, published on 19 October 2026, contains the statutory basis for structured domestic e-invoicing and digital VAT reporting, and Revenue followed with a “2026 Update” implementation paper, a new eInvoicing Hub and the first set of draft VAT regulations.

The headline dates are unchanged: large corporates start on 1 November 2028. What is new is the legal footing, the confirmation that Peppol is the mandated reporting route, and the first draft of the secondary rules.

Background

Ireland has no domestic B2B e-invoicing mandate today. Revenue published its original implementation paper, “VAT Modernisation: Implementation of eInvoicing in Ireland”, in October 2025, and on 10 February 2026 confirmed the Phase One population as VAT-registered businesses managed by its Large Corporates Division.

The programme prepares Ireland for the EU’s VAT in the Digital Age (ViDA) package, under which intra-EU B2B transactions move to mandatory e-invoicing and digital reporting from 1 July 2030, and it adds a domestic layer on a faster timetable. Until now the programme has rested on policy papers; the October 2026 publications add primary legislation, draft secondary legislation and an operating model.

The Legislative Change

Revenue’s press release of 22 October 2026 states that the Finance (No. 2) Bill 2026, published on 19 October 2026, contains the legislative foundation for VAT Modernisation and proposes amendments to the Value-Added Tax Consolidation Act 2010.

According to Revenue, the Minister of State moved the Bill to Second Stage the day before the release. The provisions remain subject to the legislative process and may change before enactment. Revenue’s paper confirms that the Bill amends the VAT Consolidation Act 2010 and that it remains a Bill.

Revenue has also published a “Draft VAT Modernisation Regulations” document. It is drafted as a set of regulations to be made by the Revenue Commissioners under section 120 of the VAT Consolidation Act 2010, amending the Value-Added Tax Regulations 2010 (S.I. No. 639 of 2010), with a commencement date of 1 November 2028. The draft still carries unfilled placeholders (“XX”, “YYYY”) and is expressly a draft. Its main features are:

• Peppol format and network: invoices and other documents issued in a structured electronic format must be issued and received in a valid Peppol format and transmitted over the Peppol transmission network. Other structured formats or networks are permitted only where issuer and recipient have agreed them in advance.
• Reporting to Revenue: specified data must be sent to the Commissioners via the Peppol network under section 83A of the Act. The data includes the standard invoice particulars, the supplier’s registration number and the customer identification number, and, where relevant, the authorization number under section 56(5) and reverse-charge references under section 66A(10) to (15). Simplified invoices and credit and debit notes carry reduced data sets.
• Record keeping: taxable persons must keep electronic systems able to produce, store and retrieve structured invoices, searchable by customer identification number, name, date or unique invoice number, and reproducible on paper or electronically in a format an officer specifies.
• Third-party reporting: where a third party transmits the data, the taxable person remains responsible for compliance and must be able to produce the related documents on request.

This is therefore a legislative development at Bill stage, accompanied by draft secondary rules. Neither is yet binding. Both set the direction that systems must be built to, and Revenue states that it will publish technical specifications later, advising large corporates not to finalize system builds until the regulations and specifications are published.

Scope

• Phase One population: VAT-registered large corporates, about 2,400 businesses, defined as businesses managed by Revenue’s Large Corporates Division and established in Ireland or with a fixed establishment there. Revenue’s paper identifies the population by reference to Large Corporates Division administration on 1 January 2027.
• Transactions: domestic B2B supplies of goods and services to taxable persons in Ireland and to public bodies. Consumer supplies and exempt supplies are outside the obligation. Reverse-charge supplies still require an e-invoice and a digital report.
• Format: structured, machine-readable invoices compliant with EN 16931-1. Scanned images, Word documents and e-mailed PDFs do not qualify. Credit and debit notes follow the same format, and summary invoices are optional for multiple supplies in a month to the same customer.
• Network: Peppol is the default network, using UBL syntax, in a five-corner model: supplier, supplier’s access point, customer’s access point, customer and Revenue. Revenue receives the data through certified Peppol access points rather than directly from each business.
• Identifiers: VAT-registered businesses use their VAT number; non-VAT-registered taxable persons will receive an identifier from Revenue in 2027.
• Monetary thresholds: none. The Revenue paper determines scope by division and transaction type, not by turnover.

Timeline

• 19 October 2026: Finance (No. 2) Bill 2026 published, containing the VAT Modernisation provisions.
• 20–22 October 2026: Revenue launches the eInvoicing Hub (published 20 October), publishes the “2026 Update” paper (21 October) and issues its press release (22 October).
• Mid-November 2026: Revenue’s programme of communication events for businesses, tax practitioners, representative bodies and software providers begins.
• 1 January 2027: Revenue is due to become Ireland’s designated Peppol Authority, replacing the Office of Government Procurement. No e-invoicing obligation starts on this date; it is the reference date for identifying Phase One businesses.
• 1 January 2028: cut-off date for identifying businesses brought into Phase Two through the Large Corporates Division.
• 1 November 2028 (Phase One): large corporates must issue e-invoices and report data to Revenue in real time for domestic B2B supplies. From the same date all businesses in Ireland, including public bodies, must be able to receive e-invoices.
• 1 November 2029 (Phase Two): domestic obligations extend to VAT-registered businesses engaged in intra-EU trade, together with Phase One businesses and Large Corporates Division businesses as at 1 January 2028.
• 1 July 2030 (Phase Three): ViDA requirements become mandatory for cross-border EU B2B transactions and the periodic VIES return is removed.

Businesses Affected

Immediately, the roughly 2,400 large corporates in Phase One, which have about two years to prepare. Every Irish business must be able to receive structured e-invoices from 1 November 2028, although Revenue says businesses that only need to receive need take no action now. Irish-established businesses trading intra-EU fall into Phase Two. Multinationals with Irish entities should note that the Phase One test follows Revenue administration, so Irish entities of a group managed by the Large Corporates Division are likely to be caught even where turnover is modest. This should be confirmed with Revenue.

Required Actions

• Establish whether each Irish VAT-registered entity is, or is likely to be, administered by the Large Corporates Division on 1 January 2027 and 1 January 2028, and therefore which phase applies.
• Map domestic invoice flows, including B2B, public bodies, reverse charge, self-billing and intra-EU supplies, and the systems that issue and receive them.
• Cleanse customer and supplier VAT numbers in master data, since the VAT number is the Peppol and reporting identifier.
• Open discussions with ERP and e-invoicing providers on Peppol access point connectivity and UBL output compliant with EN 16931-1.
• Review invoice storage, authenticity controls and audit trails against the draft record-keeping rules.
• Submit comments through Revenue’s channels (This email address is being protected from spambots. You need JavaScript enabled to view it.) and attend the communication events that begin in mid-November 2026.

Practical Implications

Ireland is following the five-corner Peppol approach rather than a clearance platform: the invoice travels between access points and a data subset reaches Revenue through the same network. For SAP landscapes this points to Peppol-capable output, a certified access point and an e-reporting data feed, built once for domestic and later ViDA cross-border use. Revenue’s advice not to finalize builds until the regulations and technical specifications are published is sensible, but design, master data cleansing and provider selection can start now. Groups already building Peppol capability for Belgium, Denmark, Norway, Luxembourg or Slovakia should assess reuse.

Expected Next Steps

Passage of the Finance (No. 2) Bill 2026 through the Oireachtas (Revenue notes the provisions remain subject to the legislative process and may change; no enactment date has been announced in the sources reviewed); finalization of the VAT Modernisation Regulations; publication of Revenue’s technical specifications; Revenue’s assumption of the Peppol Authority role on 1 January 2027; and the start of the Revenue communication events from mid-November 2026. Test environments will be made available before 1 November 2028.

How Can KGT Support You?

KGT offers SAP-integrated e-invoicing add-ons and SAP Document and Reporting Compliance (DRC) services that connect SAP ERP and S/4HANA landscapes to Peppol access points and national reporting channels. We can help you determine your Irish phase, assess readiness, design the Peppol and data-reporting flows, and align the Irish build with your other European mandates. Please contact KGT to discuss your Irish roadmap.

This article is for general information only and is not tax or legal advice; please consult your adviser before acting.