Enhanced Reporting Requirements (ERR)

ERR involves the mandatory reporting to Revenue by employers in respect of reportable benefits.

Reportable benefits are those paid to employees without the deduction of tax and include the following three specific benefits:

• Remote working daily allowance of €3.20
• Payment of travel & subsistence expenses
• The small benefit exemption

If you, as an employer, pay any of the above to your employees, from 1 January 2024 you have an obligation to report this information directly to Revenue on or before the date of payment to the employee.

Current obligations

Currently all employers are required to submit payroll details to Revenue in respect of each individual employee/director in their employment on or before the date they make a payment of an emolument to the employee/director.

Payroll details include pay, income tax, USC and PRSI deductions, as well as taxable benefits, pension contributions and redundancy payments.

Non-taxable payments are not reported in submitted payroll details at present.

Updated obligations

Finance Act 2022 extends current reporting obligations to include these additional non-taxable payments made by employers to their employees/directors.

ERR therefore requires an employer to notify Revenue on or before the provision of any of the three reportable benefits, just like the current process for submitting all other payroll details.

It is important that employers continue to ensure that payments made are done so in line with all relevant qualifying conditions attached to these benefits.

As an employer is already required to maintain detailed records of all non-taxable payments or benefits provided to employees, Revenue envisage that this process will closely align with existing governance processes.

For further information on eligibility to these reportable benefits, please see the following:

1. Remote working daily allowance of €3.20 (pdf)
2. Payment of travel & subsistence expenses (pdf)
3. The small benefit exemption

What details are required to be included/reported?

Revenue requires employers to report the following information in respect of each item subject to reporting.

Remote working daily allowance:

• total number of remote working days
• amount paid
• date paid to the employee/director

Small benefit exemption:

• value of the benefit
• date granted to the employee/director

Travel and subsistence:

• amount paid
• date paid to the employee/director for each of the following subcategories:
• travel vouched
• travel unvouched
• subsistence vouched
• subsistence unvouched
• site-based employees (including "country money")
• emergency travel
• eating on-site

How will the information be reported to Revenue?

There are three reporting mechanisms available to employers.

1. Direct reporting software packages

This will allow third-party software to integrate with Revenue systems, enabling employers to report non-taxable payment information to Revenue directly. For more information, please contact your payroll software provider.

2. ROS file upload

Employers will have the option to input the required information to a file which they can upload directly to their Revenue Online Service (ROS) account.

It's important to note that data uploaded to Revenue by employers must be transferred in a specific data structure (JSON or .xml) to ensure the quality of the data and allow Revenue to match it automatically to the correct employee record.

Note: Employers will be able to create JSON or .xml files using standard Excel functions such as Excel macros.

3. ROS online form

Using the online form, employers will be able to input the required information directly into ROS, with the necessary screens being provided.

These screens will have pre-population features to allow employers to save employee details, thus enabling the easy submission of future expense and benefit data.

A demonstration on how to complete ROS file uploads can be found on the Revenue website.

How can an employer prepare for Enhanced Reporting Requirements?

Revenue have confirmed that this initial reporting requirement is only Phase I and that further employee payments and/or benefits are likely to come within the scope of ERR in the coming years.

To prepare for 1 January 2024, employers should:

• Review how they are currently collating the reportable benefit information, as systems may need to be introduced where information is currently stored in a manual format
• Consider whether a cross-departmental approach to collating the data is required, as information may be stored in HR systems but Finance may be the department responsible for reporting the details to Revenue
• Determine how current IT systems will integrate with Revenue's online reporting facility
• Consider current payment frequencies, e.g. where an employer has an on-demand expense payment policy, to determine whether these need to be changed to a more structured process to reduce potential administration

In advance of January 2024, employers should review their policy on the reimbursement of reportable benefits to ensure current practices are aligned to legislation and Revenue guidance. ERR will provide Revenue with increased visibility of tax-free amounts being paid to employees, along with data capable of being analysed for compliance interventions.

Penalties for breaches of the PAYE regulations

Revenue will assist any employer who is experiencing genuine difficulty in complying with the new PAYE requirements. However, employers who fail to engage with Revenue or who persistently breach the PAYE regulations are liable to a €4,000 penalty per offence under Section 987 of the Taxes Consolidation Act 1997.

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