Regulatory updates - Ireland

As previously mentioned by Pagero, the public consultation for digital reporting requirements and electronic invoicing has been published by Revenue Commissioners. The duration of the consultation is from 13 October 2023 to 12 January 2024.

Stakeholders are encouraged to provide their views on real-time digital VAT reporting and electronic invoicing and their impact on the business models of different entities in different industries of economic operators in Ireland.

On 10 October 2023, Irish Minister of Finance Michael McGrath announced in his Statement on Budget 2024 the opening of a public consultation regarding existing VAT invoicing and reporting systems.

The public consultation will be published by Revenue Commissioners, and it welcomes stakeholders to submit their views and opinions on making digital advancements to reporting requirements and invoicing.

The European Directive on e-invoicing in Public Procurement (2014/55/EU) mandated public sector organisations to receive and process electronic invoices that are compliant with the European e-invoice Standard (EN-16931) by 18 April 2019 for Central Government Departments and April 2020 for all other public sector bodies.

To enable it to meet its obligations under the Directive, the Irish Government chose the Peppol network to provide a consistent and standardised channel for the Irish public sector to be able to receive e-invoices from its suppliers.

In March 2019, the Irish Office of Government Procurement (OGP) established an ‘e-invoicing’ Framework agreement, from which public bodies could procure the services and solutions they needed to comply with the Directive from an approved list of solution providers, including Pagero.

This e-invoice framework Agreement has expired, and the Office of Public Procurement has decided not to extend or establish a new Framework Agreement. It now advises Irish Public Sector Bodies to directly procure the Peppol-based e-invoicing services and solutions they require directly from the open market.

As a global Peppol Services provider with considerable experience in working with public sector bodies in Ireland, Pagero continues to provide a range of solutions to help them become and remain compliant with the Directive.

The National Standards of Ireland (NSAI) Technical Committee 002/SC 12 has published new guidelines to help suppliers who trade electronically with public sector bodies. The guide lists common requirements for suppliers who send e-invoices to more than one of the four Irish public body shared services.

As the Irish public sector prepares to start receiving e-invoices in volume to comply with the European standard on eInvoicing, private suppliers to these bodies must also know how to issue and send e-invoices.

Facilitating electronic trade with public sector bodies

The Office of Government Procurement (OGP) states a few benefits of e-invoicing and says the purpose of the guideline is to:

“…help suppliers that are beginning to trade electronically with these public bodies, to plan the configuration of their system, particularly if intending to trade with more than one shared service. This should help to reduce any associated costs and shorten (the time to) implementation time,” (9 March 2022).

Requirements for Irish public sector e-invoicing

Published in the guide is a non-definitive list of e-invoice data required to meet the standards for Irish public sector e-invoicing. The listed elements are based on the business rules of the four Irish public bodies with shared services operations:

• Central Government Departments: National Shared Services Office (NSSO)
• Local Government: Local Government Management Agency (LGMA)
• National Finance Division of the Republic of Ireland’s Health Service Executive (HSE)
• Department of Education’s ETBs: Education Shared Business Services (ESBS)

The guide shows which mandatory elements are common between organisations as well as additional elements where the public body requirements vary.

For more information on how you can connect to and send e-invoices to Irish public sector bodies, as well as any questions about these guidelines, please feel free to contact us.

Since VAT introduction in Ireland 50 years ago, businesses have reported and paid VAT by filing periodic summary VAT returns. To modernize the existing requirements, Irish Revenue has recently launched the evaluation of VAT reporting procedures already implemented in different countries.

According to Revenue’s Corporate Priorities 2022, the potential changes focus on digital reporting requirements. Although it is unknown yet what the new regime in Ireland will imply, it is likely to involve businesses archiving and reporting data in structured digital formats. In addition, real-time invoice reporting might be adopted.

The current attempts of VAT modernization in Ireland run simultaneously with the European Commission’s initiative VAT in the Digital Age and the aim to announce EU-wide legislative proposals by the end of 2022. These proposals will focus on harmonizing reporting requirements across all EU Member States.