General information
Revenue confirmed the first phase of its VAT Modernisation programme targets large corporates, who must issue structured electronic invoices (e.g., XML meeting EN16931) for domestic B2B transactions from 1 November 2028. Businesses managed by Revenue’s Large Corporates Division and established (or with a fixed establishment) in Ireland are in scope. Unstructured formats like PDFs or scans will not qualify.
All Irish businesses, regardless of size, must be able to receive structured e-invoices from the same date.
This early phase allows market adaptation before the EU VAT in the Digital Age (ViDA) reforms apply to cross-border EU transactions from July 2030. Confirmation letters for Phase One will be issued soon.
Revenue will continue engaging stakeholders and provide comprehensive support, recognising the significant change involved.
She noted affected firms will receive direct communication from Revenue but highlighted that detailed domestic B2B e-invoicing requirements are still unpublished, making full impact assessment difficult. Large corporates should start preparations now, as system changes and process redesign take time.
Revenue advises in-scope businesses to review e-invoicing system capabilities, collaborate with software providers, and assess internal processes.
For SMEs (not in Phase One), this begins a multi-year transition. While issuing structured e-invoices comes later under ViDA, receiving them becomes mandatory from 2028, so incoming invoice systems must be compatible.
Enquiries: vatmodernisation@revenue.ie
Key Recommendations for SMEs
- Assess current invoicing/finance systems
Check support for EN16931-aligned structured formats (e.g., XML), identify gaps in receiving/processing/storing e-invoices, and confirm upgrade paths/timelines with providers.
- Engage software vendors early
Request ViDA/VAT Modernisation roadmaps, ensure upgrades enable receiving structured e-invoices by 2028, and clarify costs, testing, and training.
- Map invoicing and AP workflows
Understand how e-invoices integrate into AP processes, review approvals/matching/data capture, and identify automation opportunities.
- Strengthen digital record-keeping
Ensure secure, consistent storage of structured invoices and standardise supplier data/invoice categorisation.
- Ask key suppliers about their plans
Inquire about transition timing, testing/onboarding needs, and formats (as large corporates start sending e-invoices from late 2028).
- Prioritise cybersecurity and data protection
Implement secure transfers, strong access controls, updated cyber policies, and staff training for machine-readable financial data.
- Prepare for organisational change
Educate finance, purchasing teams, and owners via awareness sessions and process documentation.
- Track Revenue updates
Monitor for detailed Irish B2B requirements (still unpublished) and subscribe to updates from Revenue, advisers, or partners.
- Integrate into medium-term digital strategy
Early investment in digital finance systems can deliver faster payments, less manual work, fewer errors, and better cash-flow visibility.
- View the next two years as an opportunity
Receiving structured e-invoices will become essential; early preparation reduces disruption and can lower operating costs.
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