Finance (No. 2) Bill 2026

The legislative provisions take effect from 1 January 2027, however the substantive obligations are introduced in phases.

Phase 1: 1 November 2028

The new obligations apply to accountable persons who are established in Ireland, registered (or required to be registered) for Irish VAT and whose tax affairs are administered by Revenue's Large Corporates Division on 1 January 2027.

Phase 2: 1 November 2029

The regime extends to accountable persons established in Ireland and registered (or required to be registered) for VAT that engage in intra-Community acquisitions and/or supplies of goods and/or services.

The number one most useful clarification in the legislation is that the mandatory e-invoicing regime applies to taxable supplies of goods and services.  The legislation does not extend the mandatory requirements to exempt supplies. This confirms that exempt transactions are outside the initial scope of the mandatory regime. For businesses operating in sectors such as financial services, insurance, healthcare and education, this is an important point. The legislation is focused on taxable transactions rather than applying across all business activity irrespective of VAT treatment.

A structured electronic invoice is more than an electronic version of a paper invoice or a PDF attachment. The legislation requires invoices to be issued in a structured electronic format that complies with the European e-invoicing standard and can be processed automatically by systems. The emphasis is on the electronic exchange of invoice data rather than the electronic exchange of invoice documents.

For taxpayers within scope, structured electronic invoices must be issued in relation to taxable supplies made within the State to taxable persons established in the State and public bodies.

The structured invoicing requirements also apply to certain domestic reverse charge transactions including:

• greenhouse gas emission allowances;
• RCT-type construction services;
• scrap metal supplies;
• certain connected-party construction services;
• supplies of gas and electricity; and
• supplies of gas and electricity certificates.

No, the customer does not need to agree to receive an e-invoice.

The legislation provides that the issue of an invoice or other document in a structured electronic format is not subject to the prior agreement of the recipient. This is a significant provision. Where a supplier is required to issue a structured electronic invoice, or chooses to do so voluntarily, there is no requirement to obtain customer consent before that invoice is issued in structured electronic format.

The framework is not restricted to VAT-registered recipients. The legislation requires invoices to contain a customer identification number. Where a taxable person or public body is not VAT registered, Revenue may assign a tax reference number for these purposes. This allows the framework to operate even where the customer does not hold an Irish VAT registration number.

Yes. The legislation is not limited to businesses that fall within the mandatory implementation phases. Businesses that are outside the mandatory scope may nevertheless issue structured electronic invoices voluntarily. This creates an opportunity for businesses that are already investing in finance transformation programmes, ERP upgrades or international e-invoicing projects to adopt the framework before they are required to do so.

The Finance Bill is wider than e-invoicing and a separate chapter introduces a digital VAT reporting framework. Where a taxpayer is required to issue structured electronic invoices, specified transaction data must also be transmitted electronically to Revenue. This reflects Revenue's long-stated objective of introducing digital reporting supported by structured e-invoicing rather than introducing e-invoicing as a standalone requirement.

The reporting obligation sits primarily with the person issuing the invoice. Where a specified person issues a structured electronic invoice, that person must transmit prescribed transaction data electronically to Revenue. The legislation also contains separate provisions covering self-billing arrangements.

The legislation requires the relevant transaction data to be transmitted no later than the point at which the invoice is issued or should have been issued. In the case of self-billing arrangements, the legislation provides for reporting within five days after the invoice is issued.

At present, the legislation provides the legal framework rather than the detailed operating model. Revenue will have the power to specify the information that must be reported and the method by which the information is transmitted.  As a result, while the direction is now clear, many practical details still need to be provided through secondary legislation and Revenue guidance.

Based on the legislation as currently drafted, the reporting obligation is imposed on the party issuing the invoice or, in certain circumstances, the party operating a self-billing arrangement. There is no equivalent general obligation requiring customers to report invoices received from suppliers. This is an important distinction. In practical terms, this has the below impact for suppliers and customers:

1. suppliers within scope may need to issue structured electronic invoices;
2. suppliers within scope may need to report invoice data to Revenue;
3. customers may need to be capable of receiving structured electronic invoices;
4. customers do not currently have to report incoming supplier invoices to Revenue.

No, although the reporting obligation sits with the issuer, businesses will still need to consider their ability to receive and process structured invoice data. To that end, the legislation:

1. allows suppliers to issue structured invoices without customer consent;
2. requires customer identification information to be provided; and
3. imposes control requirements on persons issuing and receiving structured electronic invoices.

For many businesses, particularly those with large accounts payable functions, the practical challenge may therefore be receiving, validating and processing structured invoice data rather than reporting it.

The legislation requires controls to be applied to ensure:

• authenticity of origin;
• integrity of content;
• a reliable audit trail; and
• retention of invoices in structured electronic format.

Businesses should therefore assess whether existing systems can:

• generate structured invoice data;
• receive structured invoice data;
• validate invoice information;
• integrate invoice data into ERP platforms;
• support VAT coding and determination processes; and
• maintain appropriate audit trails and document retention procedures.

The implications are likely to extend beyond tax teams and into finance, procurement, accounts payable, accounts receivable and ERP functions.