Revenue confirmed on 10 February 2026 that companies who deal with Revenue’s Large Cases Division and have an establishment in Ireland will be considered within scope for Phase One of Ireland’s VAT Modernisation programme. Therefore they will be subject to the first phase of implementation for mandatory eInvoicing and real-time reporting for domestic transactions from 1 November 2028.
This announcement follows the publication of Revenue’s October 2025 implementation document which detailed Ireland’s pathway to domestic mandatory eInvoicing and real-time reporting.
Key Confirmations from Today’s Press Release
Phase One Scope Definition
For the purposes of Phase One, a business will be considered a large corporate if:
- it is a VAT-registered business whose tax affairs are managed by Large Corporates Division in Revenue; and,
- is established or has a fixed establishment in Ireland.
From 1 November 2028, these VAT-registered large corporates will be required to issue eInvoices and report a subset of relevant data to Revenue for domestic business-to-business (B2B) transactions.
From the same date, all businesses in Ireland must be able to receive structured eInvoices.
Technical Requirements
Revenue has confirmed that businesses in scope must issue eInvoices in a structured electronic format (for example, XML) that complies with European Standard EN16931. Unstructured formats such as PDFs or scanned paper documents will not meet the eInvoicing requirement.
Action Required Now
Businesses that fall within the Phase One scope should begin preparations now, including reviewing systems for eInvoicing capability, engaging with software providers to ensure technical readiness, and planning any required system and process changes.
Revenue will write to large corporates in the coming weeks to confirm their inclusion in Phase One.
Background to VAT Modernisation roadmap
In October 2025, Revenue published an implementation roadmap for implementing mandatory eInvoicing and real-time digital reporting for domestic B2B transactions in Ireland, representing the most significant modernisation of Ireland’s VAT system since the tax was introduced over 50 years ago.
The phased implementation timeline outlined was:
- November 2028 (Phase One): VAT-registered large corporates would be required to implement mandatory eInvoicing and real-time reporting for domestic B2B transactions
- November 2029 (Phase Two): The obligation (as regards domestic supplies) would extend to all VAT-registered businesses engaged in cross-border EU B2B trade
- July 2030 (Phase Three): Full implementation of EU ViDA requirements for all cross-border EU B2B transactions becomes mandatory across all Member States
Even where business is not yet required to issue eInvoices under the earlier phases (prior to July 2030), it will need to have the capability to receive them in the required structured electronic format, meaning all VAT-registered businesses would need to prepare for these changes, regardless of size or sector.
Importantly, the changes relate solely to invoicing and reporting processes, with tax rates, payment requirements, and liability calculations remaining unchanged.
What This Means for Your Business
Today’s announcement provides crucial clarity on which businesses fall within the Phase One scope. If your business is managed by Revenue’s Large Corporates Division and has an establishment in Ireland, you now have formal confirmation that you must be ready to issue compliant eInvoices and report transaction data in real-time from 1 November 2028.
With fewer than three years until the Phase One deadline, affected businesses should treat this as a priority for 2026 planning cycles. The system and process changes required to achieve compliance will be substantial for most organisations.
If you have any questions about how these mandatory eInvoicing requirements will affect your business or need guidance on preparing for the transition, please contact Matheson’s Indirect Tax Team who will be happy to assist you.