Ireland (2019 eInvoicing Country Sheet)

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 and which came into effect from 1 January, 2013. This established electronic invoices on an equal footing with paper invoices and incorporates 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.

There is no legislation in place that mandates the provision or use of electronic invoicing (eInvoicing) in the Public Sector, however the transposition of the European Directive on eInvoicing (2014/55/EU) into Irish law is in progress and expected to be introduced in the first quarter of 2019. The transposition will align with the text and scope of the European Directive on eInvoicing (2014/55/EU) and the resulting legislation is expected to provide for the following:

1. Public bodies, as provided for by the Directive’s definitions of ‘contracting authorities’ and ‘contracting entities’, shall have a legal obligation to receive and process electronic invoices that are compliant with the European Standard by the 18th April, 2019.

2. Local and regional public bodies, as provided for by the Directive’s definitions of ‘sub-central’ ‘contracting authorities’ and ‘contracting entities’, shall have a legal obligation to receive and process electronic invoices that are compliant with the European Standard by the 18th April, 2020.

3. A legal obligation shall only apply to electronic invoices that are compliant with the European Standard on eInvoicing as referenced in the Directive.

4. A legal obligation shall only apply to electronic invoices which are issued as a result of contracts which exceed EU thresholds as provided for in the Directive.

5. A legal obligation shall NOT apply to electronic invoices issued as a result of contracts where the procurement or the performance of the contract are declared to be secret or must be accompanied by special security measures as provided for in the Directive.

In terms of policy, the following points should be noted:

• 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.
• Where a public body expects to establish, or have access to, an eInvoicing capability to meet the obligation arising from the Directive to receive and process eInvoices that have been issued as a result of contracts which exceed EU thresholds, it is recommended that the said public body should also accept eInvoices that have been issued as a result of contracts which do NOT exceed EU thresholds. In particular, eInvoicing capabilities established for high-volume invoice processing environments, such as shared services facilities or through sectoral leads or coordinating bodies for invoice processing across the public sector, will be expected to accept eInvoices issued as a result of contracts of any value. This is recommended in order for public bodies to avoid a potential administrative burden associated with differentiating invoices above and below threshold and to facilitate the uptake of eInvoicing to the public sector which increases the potential to realise associated benefits.
• 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 having 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, in also 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 on 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 burden on enterprises, including SMEs, and to allow public bodies gain maturity in processing eInvoices.

eInvoicing platform and eInvoicing management solutions

The Irish government does not legislate for the use of any eInvoicing platform.

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 but there has not been a national eInvoicing architecture or model for B2G transactions per se. eInvoicing solutions in place have been established in conjunction with 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 EDIFACT, UBL and PEPPOL-BIS through a range of transport channels, including email, PEPPOL and online portals. In some cases, eInvoices are also received as PDF files via email.

As part of the plans to comply with the eInvoicing Directive (2014/55/EU) and the European Standard for electronic invoicing, Ireland is planning to adopt PEPPOL for the transport infrastructure. The 4 corner model, supported by PEPPOL, will allow each Sector or group of contracting authorities and each economic operator choose their own 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, will be expected to arrange access to or establish an eInvoicing capability that supports receiving and processing European Standard eInvoices via the PEPPOL eDelivery network.

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.

As part of Ireland's plans to comply with the eInvoicing Directive (2014/55/EU), PEPPOL will be adopted for the transport infrastructure and the '4 corner model' that PEPPOL supports will allow each Sector or group of contracting authorities and each economic operator choose their own service providers and solution that best fits their requirements and that comply with the PEPPOL and EU eInvoicing Standards.

As part of Ireland's plans to comply with the eInvoicing Directive (2014/55/EU), PEPPOL will be adopted for the transport infrastructure and the '4 corner model' that PEPPOL supports allows contracting authorities and entities in each Sector, and cooperating groups of contracting authorities, and each economic operator choose their own service providers and solution that best fits their requirements, once they support PEPPOL and the European eInvoicing Standard.

It is expected that financial management shared services systems and/or leads, within key Sectors (Health, Education, Central, Local) will be the main implementation points for establishing Sector level eInvoicing solutions that comply with the Directive and the national approach.

Typically, the shared reception point would be connected with the invoice processing system of the relevant shared services centre that would also carry out the post-reception validation, processing and payment functions.

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 progress or 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. Examples of shared services facilities and sectoral leads planning to establish eInvoicing capabilities include:

• Central Government – The NSSO Financial Shared Services Centre (NSSO-FSS)
• Local Government – The Local Government Management Agency (LGMA)
• Health – HSE-Health Business Systems (HSE-HBS)
• Education – Education Training Boards shared services (ESBS-ETB)

It is also expected that a range of Public Bodies which are in transition to, or not in 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 is a PEPPOL member and therefore the PEPPOL CIUS will be used at national level.

Additional information

The Office of Government Procurement (OGP) is responsible for leading 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 stakeholder groups and to establish a national framework agreement for the procurement of eInvoicing services. Through the national framework agreement Public Bodies will be able to avail of commercial eInvoicing solutions to meet their obligations with respect of the Directive and a common national implementation model based on pan-European standards. The national framework agreement is expected to be available for use in the 4th quarter of 2018.

• 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's communications strategy 

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 being in a position to take the relevant actions needed to achieve compliance. To date a combination of

a) face-to-face engagements,

b) presentations and speaking opportunities,

c) online publication of guideline/infographic information and

d) dissemination of announcements and information articles

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 to 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.

A number of key milestones and events to date in the eInvoicing Ireland programme are noted below:

• 22nd December, 2017 - The Office of Government Procurement published a Prior Information Notice via the eTenders platform for the establishment of a Framework for the provision of PEPPOL networking and eInvoicing Systems and Services to the Irish Public Sector.
• 18th January, 2018 - Ireland announced its membership of OpenPEPPOL as a PEPPOL Authority.
• 2nd February, 2018 - The Office of Government Procurement published a Request for Information (RFI) for the Provision of PEPPOL networking and eInvoicing Systems and Services to the Irish Public Sector to seek market views. The closing date for submissions to this RFI was the 23rd Feb, 2018.

Ireland is a PEPPOL Authority Member of OpenPEPPOL, participates in the European Multi-Stakeholder Forum on eInvoicing (EMSFeI) and has benefited from the support and resources being provided by the CEF eInvoicing team and the eInvoicing experiences that have been shared by other European Member States in this and other eInvoicing forums.

Ireland is not adding additional requirements to the Directive and it will not be mandatory for suppliers to submit eInvoices. The draft legislation is being finalised and transposition will be done by end of this year. The extra year for sub central entities will apply.

There is a complex eInvoicing landscape with four key sectors (Health, Local Government, Education and Defence) operating independently with some using PEPPOL and others using the central government shared services platforms, among other solutions. Therefore, the eInvoicing implementation follows a hybrid approach.

The national framework for the procurement of eInvoicing solutions that are compliant with the EN and the eInvoicing Directive is currently under legal review, and public entities will be able to use it by early January 2019.

The shared services’ approach for the public sector are the main form of implementation used within the public sector and this solution will gradually cover more Public sector entities.

The main challenges to implement eInvoicing related to the need to specify requirements that satisfy the whole public sector, the competition for subject matter expertise at EU level and in integrating eInvoicing within eProcurement. Ireland expects to have a very low level of eInvoicing adoption and use inititially and there are concerns about SMEs’ onboarding.

eInvoicing Ireland is continuously engaging with a wide range of stakeholders in the eInvoicing domain to raise awareness of the Directive, the objectives of the Programme and to develop a National Framework Agreement for the Provision of eInvoicing and PEPPOL networking systems and services to the Public Sector in order to facilitate and enable Public Sector Bodies establish eInvoicing capabilities to meet their obligations under the Directive.

The tender process to establish the National Framework Agreement is underway and the Framework is expected to be available for use by Public Bodies in the first quarter of 2019.

In January 2018, the Office of Government Procurement, through the eInvoicing Ireland programme, joined OpenPEPPOL as a PEPPOL Authority member.

Further information is available at the Office of Government Procurement's eInvoicing Ireland website: https://ogp.gov.ie/einvoicing/

For specific queries please email: einvoicing@ogp.gov.ie

NOT VALIDATED BY THE EMSFEI MEMBER

Last updated:  Jun 26, 2019 16:07