Ireland: Proposed mandatory e-invoicing and real-time VAT reporting from November 2028

The Irish government published the Finance (No. 2) Bill 2026 on October 19, 2026. The bill proposes a legislative framework for the phased introduction of mandatory structured electronic invoicing and real-time digital VAT reporting in Ireland. The measures form part of Revenue’s VAT modernization program and are intended to prepare Ireland for the EU’s VAT in the Digital Age (ViDA) requirements.

Proposed implementation

Under the proposed first phase, beginning November 1, 2028, approximately 2,400 VAT-registered large companies would be required to issue structured electronic invoices for relevant domestic B2B and B2G supplies and transmit prescribed invoice data to Revenue in real time. From the same date, other Irish businesses and public bodies would need to be able to receive structured electronic invoices from affected suppliers.

From November 1, 2029, the domestic issuance and reporting obligations would extend to VAT-registered businesses engaged in specified cross-border EU transactions. A third phase would begin on July 1, 2030, when the EU ViDA requirements for cross-border EU B2B transactions become mandatory. The existing VAT information exchange system (VIES) recapitulative statement requirement is expected to be removed from that date.

E-invoicing requirements

The proposed mandate would apply principally to taxable supplies made in Ireland by an in-scope Irish-established supplier to another Irish-established taxable person or public body. It would therefore cover domestic B2B and B2G transactions but would not introduce a general B2C e-invoicing mandate.

Invoices would need to comply with the European electronic invoicing standard EN 16931 and use an approved structured syntax. A conventional PDF or scanned invoice would not, by itself, satisfy this requirement because it does not contain invoice data in a structured, machine-processable format. The recipient’s prior agreement to receive the structured invoice would no longer be required.

Structured invoices would also need to include an appropriate customer identifier, generally the recipient’s VAT registration number or another tax reference number assigned by Revenue. The proposed framework also addresses self-billing, summary invoices, credit and debit notes, structured record retention, and certain domestic reverse-charge documents.

Real-time digital reporting

In-scope suppliers would be required to transmit prescribed transaction data electronically to Revenue when an invoice is issued or should have been issued. Third-party service providers could submit the data on behalf of businesses, although the underlying compliance responsibility would remain with the relevant taxable person.

Revenue has indicated that Peppol will be the default network for exchanging structured invoices and the mandated channel for transmitting invoice data to Revenue. However, the supporting regulations remain in draft, and the detailed data fields, validation requirements, and technical specifications are still to be finalized.

Business implications

The proposals are likely to require changes to accounts receivable, accounts payable, ERP systems, tax determination, customer and supplier master data, invoice corrections, and VAT reconciliations. Even businesses outside the initial issuance mandate may be affected, as they may need to receive structured invoices from November 1, 2028.

Potentially affected businesses should begin assessing their likely implementation phase, invoice processes, data quality, and system capabilities. Early planning can proceed, but businesses may wish to avoid finalizing system designs until Revenue publishes the relevant technical specifications.

Legislative status

The Finance (No. 2) Bill 2026 has not yet completed the legislative approval process. It was introduced in Dáil Éireann on October 19, 2026, with its second-stage debate commencing on October 20, 2026. The bill must complete the applicable stages in Dáil Éireann and Seanad Éireann and be signed by the president before becoming law. Its provisions may therefore be amended before enactment.

For further information, contact a KPMG tax professional:

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com