Irish Revenue Confirms What Constitutes a Large Corporate for Phase One of VAT Modernisation

February 16, 2026 EU VAT Update

On 10 February 2026, Revenue confirmed what constitutes a “large corporate” for the purposes of Phase One of Ireland’s VAT Modernisation programme, which aims to digitise and streamline VAT reporting through e-invoicing and real-time data reporting, improving compliance, efficiency, and alignment with upcoming EU VAT reforms.

Phase One introduces mandatory electronic invoicing (eInvoicing) and digital reporting obligations for certain domestic business-to-business (B2B) transactions. These requirements will take effect from 1st November 2028.

From that date, businesses within scope will be required to issue structured electronic invoices and transmit specified invoice data electronically to Revenue.

Importantly, from 1st  November 2028, all VAT-registered businesses establishedin Ireland, regardless of size, must be capable of receiving structured eInvoices, even if they are not required to issue them under Phase One.

What Is a Large Corporate?

Revenue has confirmed that, for the purposes of Phase One, a “large corporate” is:

  • a VAT-registered business whose tax affairs are managed by Revenue’s Large Corporates Division, and
  • established in Ireland or has a fixed establishment in Ireland.

This definition is not based on turnover or employee numbers. No financial threshold applies. The determining factor is whether the business is administered by Revenue’s Large Corporates Division (LCD).

Businesses managed by the LCD will already be aware of this status through their Revenue correspondence and assigned Revenue district.

What Will Be Required?

Businesses within scope of Phase One will be required to:

  • issue structured electronic invoices for domestic B2B supplies;
  • ensure those invoices comply with the European Standard EN16931; and
  • transmit a defined subset of invoice data electronically to Revenue.

Unstructured formats such as PDFs or scanned invoices will not meet the structured eInvoicing requirement.

Revenue has indicated that it will write directly to affected businesses and will continue engagement with representative bodies, advisers and software providers as implementation progresses.

Next Steps for Businesses

Large corporates within scope should begin preparations now. This should include:

  • reviewing current invoicing systems and ERP capabilities
  • confirming ERP master data is accurate and up-to-date.
  • ensuring VAT determination within any ERP system is correct as this information will be going to Revenue in real time
  • engaging with software providers regarding EN16931-compliant structured invoicing; and
  • assessing internal processes to ensure readiness for digital reporting obligations.

Although Phase One applies only to businesses managed by the LCD, the requirement for all VAT-registered businesses to be capable of receiving structured eInvoices means the impact will be broader.

Further guidance is expected as Revenue continues to roll out it’s VAT Modernisation programme. If you have any questions on whether your business falls within scope, or how to prepare, please contact our VAT Consultants.

 

Archives