The introduction of e-invoicing, (the automated, secure exchange of invoice data in a structured, machine-readable format (e.g., XML) between supplier and buyer), forms a key part of the EU ViDA Directive.
As part of this the Irish Revenue Commissioners have confirmed that large corporates will be required to issue e-invoices from 1st November 2028. What steps should in-scope companies now be taking to meet the new obligations?
Contributor: Emma Galvin, VAT Director, BDO
On 8 October 2025, the Irish Revenue released a publication setting out details of the work it is undertaking to prepare for the implementation of the EU’s VAT in the Digital Age (ViDA) requirements, an initiative to modernise EU VAT systems to better support how businesses trade, while bolstering the fight against VAT fraud.
“VAT Modernisation: Implementation of e-invoicing in Ireland” is effectively a roadmap for the introduction of domestic e-invoicing and real-time reporting in Ireland.
E-invoicing and real-time reporting will be phased in to give businesses and Revenue adequate time to learn from early adopters and prepare systematically in advance of 1 July 2030, the date the EU ViDA requirements for e-invoicing and real-time reporting become mandatory.
An e-invoice is an invoice which is issued, transmitted, and received in a structured electronic format that enables automatic processing. The e-invoice must comply with the European Standard EN 16931, and unstructured formats such as PDFs or scanned paper documents will not meet the e-invoicing requirement.
A three-phase implementation timeline will provide businesses with sufficient preparation time while building on Ireland’s strengths in digital innovation:
- Phase 1 - November 2028: VAT-registered large corporates will be required to implement e-invoicing and real-time reporting for domestic B2B transactions.
- Phase 2 - November 2029: Domestic B2B e-invoicing and real-time reporting will be extended to all VAT-registered businesses engaged in intra-EU B2B trade.
- Phase 3 - July 2030: Full implementation of EU ViDA requirements for all cross-border EU B2B transactions becomes mandatory in all 27 EU Member States.
As such, all Irish VAT-registered businesses already operating under the domestic system will transition to meet these EU obligations
On 10 February 2026, Revenue confirmed the definition of a “large corporate” for Phase 1, namely:
- a VAT-registered business whose tax affairs are managed by the Large Corporates Division in Revenue and
- is established or has a fixed establishment in Ireland.
It was further advised in this publication that Revenue will write to “large corporates” in the coming weeks to confirm their inclusion in Phase 1.
As e-invoicing is an end-to-end digital process, for the system to operate effectively, all businesses will need to be able to receive e-invoices from the above-mentioned suppliers, regardless of whether they are obliged to issue them.
Modernising the administration of VAT will have a significant impact on numerous parts of Irish businesses, including tax, finance, IT, procurement, etc. Although there is a proposed 3 year lead in time from the publication date, as the transition to mandatory e-invoicing will require significant time and resource investment, businesses need to start familiarising themselves with the measures now so they can assess the impact on their business, and should begin to action the following steps:
- Reviewing their ERP systems and/or invoicing software to determine the extent to which existing systems will be able to cope with the new digital requirements or whether additional tools/add-ons are required.
- If software updates are required, engage with software suppliers early as software updates can have long lead in times, to ensure that any required updates will be operational on time.
- Review current digital record-keeping to ensure that the system/s will be capable of storing structured invoices securely and to ensure that structured invoices can be produced to Revenue, if required.
- Ensuring that employees are adequately trained and supported in the transition to e-invoicing to ensure that the business is compliant.
- Stay informed and monitor any future developments both locally in Ireland and at EU level (where applicable).