Today: electronic invoices by agreement
Under section 66(2) of the Value-Added Tax Consolidation Act 2010, you may issue a VAT invoice electronically only by prior agreement with your customer. You must guarantee the authenticity of its origin, the integrity of its content and its legibility, for example through business controls that create a reliable audit trail between the invoice and the supply.
So a PDF sent by email is a valid VAT invoice in Ireland once your customer has agreed to it. No structured format is imposed between businesses today. The particulars the invoice must carry are the same whatever the format: see what an Irish VAT invoice must include.
Revenue’s plan, phase by phase
Revenue consulted on VAT Modernisation from 13 October 2023 to 31 January 2024 and published its report on 27 June 2024. Its VAT Modernisation timeline, published on 20 July 2026, sets out three phases:
| Date | Phase | Who is concerned |
|---|---|---|
| November 2028 | Phase 1 | VAT-registered large corporates: mandatory e-invoicing and real-time reporting for domestic B2B transactions |
| November 2029 | Phase 2 | VAT-registered businesses that trade cross-border with businesses in other EU countries |
| July 2030 | Phase 3 | Full ViDA requirements for intra-EU B2B trade |
This is Revenue’s plan, not yet law. Dates, scope and technical details may still change before they are written into legislation.
Phase 3 follows the EU’s “VAT in the Digital Age” (ViDA) rules. Revenue notes, for example, that under ViDA suppliers will have to issue e-invoices for intra-EU transactions within 10 days.
Who counts as a “large corporate”?
Revenue defines a large corporate as a VAT-registered business established in Ireland whose tax affairs are managed by Revenue’s Large Corporates Division. There is no turnover threshold: Revenue will write to the businesses concerned to notify them.
For most small businesses, the question is therefore not whether they issue e-invoices in 2028, but whether they can receive them from their large customers and suppliers.
From November 2028: every business must be able to receive
Revenue states that for all phases, businesses must ensure they can receive and process e-invoices from any supplier mandated to issue them. Its announcement of phase one adds that all businesses in Ireland must be able to receive structured e-invoices from November 2028.
Receiving a structured e-invoice is not the same as receiving a PDF. The software you use will need to accept files in the European standard format and turn them into readable invoices and accounting entries.
Format and network: EN 16931, Peppol, and open questions
Revenue’s document “Implementation of eInvoicing in Ireland” describes the e-invoice as a structured electronic format, for example XML, that complies with the European standard EN 16931. A PDF or a scanned invoice will not satisfy the ViDA requirements.
Revenue says it will use various existing technical infrastructures, including the Peppol framework, and will consult industry experts to evaluate the exchange mechanisms. In other words:
- the exchange model has not been decided;
- nothing has been published on how service providers will be accredited, if at all;
- Revenue has committed to publishing detailed guidance and technical specifications well in advance of each phase, and had published none on 19 October 2026.
The public sector: already open to e-invoices
Since the European Union (Electronic Invoicing in Public Procurement) Regulations 2019 (S.I. No. 258 of 2019), public buyers must receive and process e-invoices that comply with the European standard, for contracts above the EU thresholds. Suppliers are not obliged to send them.
Ireland joined OpenPeppol as a Peppol Authority in January 2018, and the Office of Government Procurement is Ireland’s Peppol authority. Public-sector e-invoices use Peppol BIS Billing 3.0.
What a small business can do now
- Keep invoicing as you do today, with your customers’ agreement recorded, and make sure every invoice carries the full VAT particulars.
- Check whether your large customers or suppliers are likely to be in phase 1: they may ask you about e-invoices first.
- Ask your invoicing and accounting software providers how and when they will receive EN 16931 e-invoices, before November 2028.
- If you trade with businesses in other EU countries, plan for issuing e-invoices from November 2029.
- Follow Revenue’s VAT Modernisation pages for the technical specifications.
Le Frac sends Irish invoices by email as a PDF today, with reminders under Irish late payment rules. E-invoicing for Ireland will be added before Revenue’s mandates apply; our e-invoicing guide for Ireland is updated as Revenue publishes more.
Frequently asked questions
Is e-invoicing mandatory in Ireland in 2026?
No. Between businesses, an electronic invoice requires your customer’s prior agreement, and a PDF by email is then a valid VAT invoice. Revenue’s mandatory e-invoicing plan starts in November 2028 and is not yet law.
My business is small. When am I concerned?
Under Revenue’s plan, from November 2028 you must be able to receive structured e-invoices. Issuing becomes mandatory in November 2029 if you are VAT registered and trade cross-border with businesses in other EU countries. The published timeline sets no date for businesses that only trade within Ireland and are not large corporates.
Will a PDF invoice still be accepted after 2028?
Revenue states that a PDF or a scanned invoice will not satisfy the ViDA requirements. Where e-invoicing becomes mandatory under the plan, the invoice will have to be a structured file following EN 16931.
Will Ireland use Peppol?
Revenue mentions Peppol among the existing infrastructures it will use, but the exchange model has not been decided. Peppol is already used for public-sector e-invoices, with the Office of Government Procurement as Ireland’s Peppol authority.
Sources
- Revenue — VAT Modernisation timeline (published 20 July 2026) (revenue.ie)
- Revenue — Press release: phase one of VAT Modernisation (revenue.ie)
- Revenue — Large corporates and VAT Modernisation (revenue.ie)
- Revenue — Implementation of eInvoicing in Ireland (8 October 2025) (revenue.ie)
- Revenue — VAT Modernisation (VAT in the Digital Age) (revenue.ie)
- Revenue — Other types of VAT invoices (electronic invoices) (revenue.ie)
- Revised Acts — Value-Added Tax Consolidation Act 2010, section 66 (revisedacts.lawreform.ie)
- Irish Statute Book — European Union (Electronic Invoicing in Public Procurement) Regulations 2019 (S.I. No. 258 of 2019) (irishstatutebook.ie)
- European Commission — eInvoicing in Ireland (ec.europa.eu)
This article summarises the official texts to help you get organised. It is not a substitute for personalised advice from your accountant.