Ireland (2021 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, 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 and will set 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 require Central Government contracting authorities and entities to be compliant by 18 April 2019.
• The regulations require sub-central contracting authorities and entities to be compliant by 18 April 2020.
• The legal requirement will only apply to invoices that relate to public procurement contracts above EU threshold values.
• There will be no legal obligation on economic operators to submit invoices electronically in public procurement at this point in time.

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 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

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 4 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.

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. However, 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 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 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.

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.

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.

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

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. 

The Office of Government of Procurement has established a national framework agreement for the provision of eInvoicing and Peppol networking services and solutions. The central and the sub-central government bodies can procure the services they need from this framework that will enable 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.

The 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 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. Examples of shared services facilities and sectoral leads that either have or are planning to establish eInvoicing capabilities include:

• Education – Education Training Boards shared services (ESBS-ETB)
• 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)

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.

Monitoring eInvoicing implementation 

The eInvoicing Ireland Programme is working with partners across each sector to monitor implementations at both central and sub-central levels. The implementation of eInvoicing by public sector bodies is monitored as opposed to the uptake by suppliers. The service providers on the national framework for the provision of eInvoicing services are contractually obliged to report on public bodies that have implemented eInvoicing solutions. As of January 2020,

• Central Government Departments and the main Shared Services functions in all sectors have made the necessary provisions to comply with eInvoicing legislation.
• The main Shared Services functions in the Education, Local Government sectors have established an integrated eInvoicing capability
• The main Shared Services functions in Health and Central Government sectors have works underway to establish an integrated eInvoicing capability

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

Ireland joined 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 Local Government to provide more specific guidance for the submission of eInvoices to that Sector. More information regarding the development of this CIUS is found at the link below:

Local Authorities in Ireland promote uptake of eInvoicing

Enduring Model to Sustain eInvoicing in Public Procurement

The eInvoicing Ireland Programme is working with key stakeholders to develop a proposal for an enduring model to sustain a national approach and foster the adoption of eInvoicing in public procurement. An important benefit of this European Multi-Stakeholder Forum on eInvoicing has been the network of expertise and experiences that is available thanks to the willingness of all participants to collaborate and share experiences and knowledge from their local situation. Ireland has leveraged this forum and network to help inform our proposal for an enduring model through liaisons with experts from the European Commission's CEF eInvoicing team and counterparts from a number of member states (including Sweden, Denmark, Norway, Italy, Netherlands).

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 stakeholder groups and to establish a national framework agreement for the procurement of eInvoicing services. Through the national framework agreement Public Bodies are 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 was established and available for use since March 2019.

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 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

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 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.

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, mainstream media). A dedicated eInvoicing Ireland team proactively promotes and raises awareness through public sector events, forums and localised meetings. The team also work closely with the European Commission's CEF team to leverage pan-European opportunities and channels to communicate on eInvoicing. 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.

In January 2018, the Office of Government Procurement, through the eInvoicing Ireland programme, joined OpenPeppol as a Peppol Authority member. The tender process to establish the National Framework Agreement is underway and the Framework is available for use by Public Bodies since the first quarter of 2019.

Further information is available at the Office of Government Procurement's eInvoicing Ireland website.

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

Reference article: https://www.eolasmagazine.ie/einvoicing-digital-transformation-in-action/

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Last updated:  Jun 29, 2021 10:48