On 10 February 2026, Irish Revenue officials confirmed that Phase One (effective 1 November 2028) will apply only to value-added tax (VAT)-registered companies whose tax affairs are managed by the Irish Revenue's Large Corporates Division. Notably, this means that many financial services businesses will not be in scope for Phase One, as another Irish Revenue division typically addresses their tax issues. Implementation for these businesses will commence from November 2029. Businesses that are not in scope for Phase One will still need to be able to receive e-invoices from November 2028.

The 10 February announcement follows the Irish Revenue's publication of VAT Modernisation: Implementation of e-invoicing in Ireland in October 2025, which details the implementation plans for domestic e-invoicing in preparation for the EU's VAT in the Digital Age (ViDA) initiative. (For background, see EY Global Tax Alert, Ireland announces introduction of e-invoicing, dated 14 October 2025.)

Note, as well, that many businesses managed by the Large Corporates Division may still carry on VAT-exempt activities, e.g. Treasury, captive insurance, payments, etc. These companies will still be within the scope of Phase One.

The Irish Revenue also confirmed it will contact affected large corporates in the coming weeks to confirm their inclusion in Phase One.

This clarification will be welcome for many businesses as they continue to plan for the implementation of e-invoicing and real-time VAT reporting under Ireland's VAT Modernisation program.

See the full publication on the Irish Revenue's website for further details — Revenue confirms large corporates for Phase One of VAT Modernisation — Implementation of e-invoicing in Ireland.