eInvoicing in Ireland

Legislation

The transposition of the European Directive on VAT (2010/45/EU) into Irish Law is set out in the Statutory Instrument 354 published in 2012, effective as of 1 January 2013. This established electronic invoices on an equal footing with paper invoices and incorporated the definition of an electronic invoice's processing, such as the appropriate application of business control to ensure authenticity, integrity and a reliable audit trail of the electronic document. Apart from this, there is no other existing national legislation specifically relating to eInvoicing.

Statutory Instrument 258, in effect from 12 June 2019, transposed the European Directive on eInvoicing (2014/55/EU) in public procurement. The legislation is in line with and does not exceed the scope of the Directive, setting out the following:

• a contracting authority or a contracting entity shall, where an electronic invoice complies with the European standard on electronic invoicing established under the Directive, receive and process the electronic invoice;
• the regulations required Central Government contracting authorities and entities to be compliant by 18 April 2019;
• the regulations required sub-central contracting authorities and entities to be compliant by 18 April 2020;
• the legal requirement only applies to invoices that relate to public procurement contracts above EU threshold values;
• there is no legal obligation on economic operators to submit invoices electronically in public procurement;
• it is expected that sector-shared services facilities and/or sectoral leads or coordinating bodies for invoice processing, within each sector or within sector segments, will be the main implementation points for establishing eInvoicing solutions and capabilities across the public sector.The national eInvoicing approach for Ireland has been developed to facilitate and enable all public bodies to achieve compliance with the Directive as well as have the opportunity to realise the potential benefits of eInvoicing beyond compliance. By establishing consistent and standardised channels to submit eInvoices to both Irish and European public administrations, the national approach looks to assist suppliers, including SMEs, also in reaping the benefits. To support these objectives, public bodies should adopt eInvoicing capabilities that are pursuant but need not be restricted, to the national eInvoicing approach, as set out at the time of adoption, by the Ministry competent in the area of the given policy. There is no legal requirement for suppliers to submit invoices in electronic format to public bodies at this point in time. This is in order to avoid additional costs or administrative burdens on enterprises, including SMEs, and to allow public bodies to gain maturity in processing eInvoices.

On 9 March 2022, the National Standards Authority of Ireland (NSAI) published new guidelines containing further obligations to send European standard complaint eInvoices to Irish public sector bodies.

These guidelines list common requirements for suppliers sending eInvoices to any of the 4 Irish public body shared services, with the aim to reduce costs and shorten implementation time.

The listed elements are based on the business rules of the four Irish public bodies with shared services operations:

• Central Government Departments: National Shared Services Office (NSSO).
• Local Government: Local Government Management Agency (LGMA).
• National Finance Division of the Republic of Ireland’s Health Service Executive (HSE).
• Department of Education’s ETBs: Education Shared Business Services (ESBS).

The guidelines show which elements are common between organisations and which differ.

eInvoicing platform and eInvoicing management solutions

As part of the plans to comply with the eInvoicing Directive (2014/55/EU) and the European Standard for electronic invoicing, Ireland has adopted Peppol for the transport infrastructure. The four-corner model, supported by Peppol, allows each sector or group of contracting authorities and each economic operator to choose their service providers and solution, best suited to their requirements, and that also comply with the Peppol and EU eInvoicing Standards. Existing eInvoicing and invoice capture solutions can remain in use but contracting authorities and entities, as defined in the eInvoicing Directive, are expected to arrange access to or establish an eInvoicing capability that supports receiving and processing European Standard eInvoices via the Peppol eDelivery network.

It is important to mention that Ireland joined the OpenPeppol association as a Peppol Authority member in January 2018.

There are a number of eInvoicing initiatives and solutions across the Irish public sector, which are aimed at addressing the business needs of an individual contracting authority or of a specific group of contracting authorities within a sector. eInvoicing solutions in place have been established in conjunction with individual Service Providers.

Generally, the eInvoicing solutions provide an interface to the contracting authority’s main invoice processing system. Where solutions are in place, the concerned contracting authorities are capable of receiving eInvoices in one or more standards, such as UN/CEFACT and UBL through Peppol. Most public bodies still support traditional forms of invoicing such as transmitting paper invoices by post and pdfs by email.

Approach for receiving and processing eInvoices

The current level of eInvoicing capabilities and the approach for receiving and processing eInvoices varies across contracting authorities and sectors. Some contracting authorities have advanced standards-based, automated, and integrated systems while others process invoices in both manual and semi-automated ways.

Financial management shared services systems and/or leads, within key Sectors (Health, Education, Central, Local) are crucial implementation points for establishing Sector level eInvoicing solutions that comply with the Directive and the national approach.

Financial Management Shared Services systems now service the main Public Service Sectors (Central Gov, Health, Education, Local Gov). These systems all support Peppol-based eInvoicing. While Central and Health are still at early stages of rollout, these systems are expected to be the main eInvoicing receiving and processing points across the public sector as they expand their roll out and coverage of their respective sectors over the coming years.

Typically, a Peppol Access Point is connected with the invoice processing system of the relevant shared services centre. The Peppol Access point will validate the eInvoice and forward it to the shared service system that carries out the post-reception validation, processing and payment functions.

All implementations must be able to receive and process European Standard-compliant eInvoices via the Peppol eDelivery network. 

In order to avoid additional costs or burden on enterprises, including SMEs, and to allow public bodies gradually gain maturity in processing eInvoices, there is no requirement on suppliers to submit invoices in electronic format at this point in time, although specific sectors may choose to adopt measures to drive the uptake of eInvoicing within their domain.

For more information gov.ie - eInvoicing Ireland (www.gov.ie). 

eInvoicing implementation in sub-central level contracting authorities 

At the sub-central level, Ireland has adopted an open-standards-based hybrid model, facilitating implementations by shared services functions and by individual public bodies. All implementations must be able to receive and process European Standard-compliant eInvoices via the Peppol eDelivery network. 

Sub-central government bodies receive the services they need from the Local Government Management Agency (LGMA) Shared Service. This enables them to receive and process European Standard-compliant eInvoices via the Peppol network.

Many public bodies are scheduled to be on-boarded to a single finance shared services system for invoice processing over the next few years. Until this on-boarding is completed, it makes it more difficult to drive the uptake of eInvoicing, as public bodies are less likely to individually invest in longer-term integrated eInvoicing solutions.

eInvoicing communication mainly goes through the national eInvoicing Ireland Programme. The Steering Committee comprises Senior Business and Finance Management representatives from across the Public Sector.

The benefits being targeted by the adoption of eInvoicing include the reduction of administrative burden, cost savings and enabled the better use of data for more informed decision making and better outcomes for the public and businesses. The implementation of eInvoicing is varied across the sub-central level in Ireland with pockets of excellence, for example in some areas of the education and health sectors. A number of eInvoicing implementations are underway as a result of the impetus created by the EU Directive.

Status on the implementation of the European Standard on eInvoicing (EN)

In terms of national implementation approach, there is an emphasis on a 'build to share' standards-based access model using pan-European standards.

Strategic programmes are in the progress of being planned to establish shared services financial management facilities in each of Central Government, Health, Education sectors and standardised financial management systems and processes are in place across Local Government bodies. These programmes are a move towards providing financial management services, including invoice processing, through standardised systems and processes within each sector.

It is expected that sector-shared services facilities and/or sectoral leads or coordinating bodies for invoice processing, within each sector or within sector segments, will be the main implementation points for establishing eInvoicing solutions and capabilities across the Public Sector on a ‘build to share’ basis. As these will be high-volume invoice processing environments, the eInvoicing solutions should look to implement fully automated Straight-Through-Processing (STP) of invoices and deliver non-legislative benefits in as much as is possible.

It is also expected that a range of Public Bodies which are in transition to, or not in the scope of, a shared services model or a coordinating body in their sector will also be required to establish individual eInvoicing solutions to comply with the Directive. It will be for each Public Body to determine the level of functionality they require, from the minimal capability to receive and process eInvoices through to the fully automated back-office interfacing solutions. Their decision in this regard should consider the advantages of eInvoicing whilst not placing a disproportionate financial or administrative burden on the public body.

From a technical perspective, the national strategy sets out that eInvoicing implementations must support two key standards:

1. The European eInvoicing standard (EN 16931-1) as referenced in the Directive.
2. Access to the Peppol (Pan European Public Procurement On-Line) eDelivery network.

Existing solutions can remain in use but contracting authorities and entities, as defined in the eInvoicing Directive, will be expected to arrange access to or establish an eInvoicing capability that supports receiving and processing of European Standard eInvoices via the Peppol eDelivery network.

Use of Core Invoicing Usage Specifications (CIUS) at national level

Ireland joined the OpenPeppol association in January 2018 as a Peppol Authority member and the Peppol CIUS is used at national level. A specific CIUS has been developed by the Local Government to provide more specific guidance for the submission of eInvoices to that sector. 

The Central Government agency (NSSO) has also developed a CIUS. More information on it are available at eInvoicing for suppliers - NSSO. The Department of Education ETBs also have specific requirements related to specific identification numbers for schools.

Furthermore, the NSAI Technical Committee 002/SC 12 on eProcurement produced a new Irish eInvoice Guideline for Shared Services, whose purpose is to help suppliers to plan the configuration of their system to trade electronically with public bodies. The main focus will be on the suppliers that are beginning to trade electronically with these public bodies, to plan the configuration of their system, particularly if intending to trade with more than one shared service. This should help to reduce any associated costs and shorten (the time to) implementation time.

This is not a definitive list but a summary of the common requirements. A supplier to a specific public sector body will receive more detailed information when being on-boarded by them. For example, this guide would be useful if a supplier is already sending eInvoices to a Local Authority and then need to send eInvoices to Central Government Departments, it will show what is common to both and what (extra few) additional elements are specific.

The document contains a list of elements required to send EN16931 compliant eInvoices to Irish public sector bodies serviced by shared services operations namely Central Government Departments (NSSO), Local Government (LGMA), HSE (National Finance Division) and Department of Education ETBs (ESBS).

Digital reporting requirements

Since the Value Added Tax (VAT) introduction in Ireland, businesses have reported and paid VAT by filing periodic summary VAT returns. To modernise the existing requirements, the Irish Revenue (Ireland Tax Authority) has recently launched the evaluation of VAT reporting procedures.

The European Commission has recently proposed a series of measures to modernise and make the EU’s Value-Added Tax (VAT) system work better for businesses and more resilient to fraud by embracing and promoting digitalisation. The initiative is called VAT in the Digital Age proposal (ViDA). Part of the proposals is for member states to move to real-time digital reporting based on eInvoicing for businesses.

The EU’s ViDA proposal would make eInvoicing mandatory for cross-border business and also allow all member states to introduce mandatory eInvoicing for domestic business to business transactions, if they so wish. Suppliers and other interested parties, such as the Irish Revenue Commissioners, are monitoring this development closely and in some cases exploring how best to prepare for the change.

These factors have helped to increase awareness among suppliers that eInvoicing is an option in public procurement and, in a growing number of cases, that it is a condition of doing business in the European Single Market. Suppliers are now looking to find out more about eInvoicing, the Peppol network and in particular how they can get connected to send eInvoices as being requested by their clients,

https://www.eolasmagazine.ie/einvoicing-moves-closer-to-the-tipping-point/

Additional information

The Office of Government Procurement (OGP) led the transposition of the eInvoicing Directive (2014/55/EU) into Irish Law and has established the eInvoicing Ireland programme to achieve the following objectives:

1. Communicate the obligations of the Directive and a national implementation model.
2. Establish a framework for the procurement of a set of commercially available solutions for public bodies (PBs) to use in achieving compliance and additional benefits.

The National eInvoicing Programme (eInvoicing Ireland) is continuously engaging with public sector partners, economic operators and service providers, to communicate with all stakeholders.

eInvoicing Ireland's communications strategy 

The goal of the eInvoicing Communications strategy is to engage all stakeholders, including public bodies, suppliers (including SMEs) and service providers to facilitate compliance with the eInvoicing Directive and encourage all parties to consider this as an opportunity to innovate in terms of automating business processes and driving new efficiencies.

eInvoicing Ireland has developed a multi-stakeholder, multi-channel communications strategy which aims to progress the stakeholders from having an awareness of the basic elements of the Directive, to a comprehensive understanding of the implications for their organisation, to be in a position to take the relevant actions needed to achieve compliance. To date a combination of:

• face-to-face engagements;
• presentations and speaking opportunities;
• online publication of guideline/infographic information; and
• dissemination of announcements and information articles.

These have involved stakeholder group specific communication channels, representative bodies, and the tech media, as well as public sector procurement, finance and ICT events. The OGP is leading communication activities about the benefits and opportunities of eInvoicing and eProcurement.

eInvoicing Ireland is working on a programme of activities and engagements, which have already commenced, to consult with stakeholder groups, interested parties and the general public on the Directive and national strategic approach. This is an ongoing role of the programme and will continue to inform our thinking with regards to the policy and implementation choices being considered.

The eInvoicing Ireland team leverages a range of online channels to share information and promote the adoption and uptake of eInvoicing (websites, social media, online publications, and mainstream media). A dedicated eInvoicing Ireland team proactively promotes and raises awareness through public sector events, forums and localised meetings. The eInvoicing Ireland programme promotes the adoption and benefits of eInvoicing among Contracting Authorities, economic operators and other stakeholders. This team also engaged with SME representative bodies through a government public procurement SME advisory group and has promoted the uptake of eInvoicing at SME-focused industry events.

Moreover, at the end of March 2023, the OGP’s Multi Supplier Framework Agreement for the provision of PEPPOL networking and eInvoicing Systems and Services to the Irish Public Sector (‘eInvoicing Framework’) reached its full term. No new contracts can be established within the framework.

There is now greater maturity and understanding of public sector needs in the eInvoicing services and solutions available on the market that will help public bodies meet their legal obligations arising from the eInvoicing Directive.  In many cases, public sector bodies (PSBs) can now easily, quickly, and cost-effectively procure eInvoicing services directly from the market in a compliant manner.

The following information is available to assist public bodies in that regard:

• In line with the national approach, eInvoicing solutions should support the delivery of supplier invoices via the Peppol eDelivery network. A list of certified Peppol service providers is available on the official Peppol website.
• General eInvoicing information is available on the gov.ie website.
• Public procurement guidelines for goods and services are available here on the gov.ie website.

Last updated:  Jun 13, 2024 13:15