Enhanced Reporting Requirements (ERR) in Ireland: What Employers Must Now Report

If you are an Irish employer, ERR is no longer a “let’s see how this beds in” policy. Enhanced Reporting Requirements have been live since 1 January 2024, and Revenue’s own figures tell the story: in 2025, employers declared roughly 13.5 million reportable benefits worth around €2 billion under the regime. The reporting is happening, the data is flowing, and Revenue can now see across the country in near real-time what employers are paying outside of normal payroll.

The uncomfortable truth is that many employers are still not fully compliant. ERR is treated as a payroll add-on rather than a system change, gaps build up between policy, payroll and expenses, and benefits slip through unreported. This guide walks through what the rules actually require, the three categories that capture most of the reporting, the common pitfalls, and the practical actions to get clean.

What Are Enhanced Reporting Requirements (ERR) and Why Do They Matter?

Enhanced Reporting Requirements are Revenue’s mandatory, real-time reporting regime for non-taxable payments made to employees and directors. The legal hook is Section 897C of the Taxes Consolidation Act 1997, introduced by Finance Act 2022 and commenced on 1 January 2024. Section 897C and the accompanying regulations require employers to report details of certain non-taxable payments made to staff so Revenue can see, on a real-time basis, the value of tax-free items flowing alongside payroll.

In plain English, employers are required to report to Revenue, on or before the date of payment, the details of certain expenses and benefits. The reporting obligations sit beside the existing PAYE Modernisation submissions rather than replacing them, and the reporting requirement covers items that historically sat outside the payroll system entirely.

The scale of activity since launch has been significant. Revenue has reported around 13.5 million reportable benefits in 2025 alone, with a combined value close to €2 billion. That gives Revenue an enormous data set to cross-check, and it means under-reporting now sticks out faster than it ever did.

ERR matters because:

• The reporting obligation sits separately from the tax treatment. A payment can be tax-free and still be a reportable benefit; the two things do not cancel each other out.
• Reporting is real-time, on or before the date of payment. There is no quarter-end or year-end catch-up window.
• Revenue compliance activity is increasing as the data set matures, and gaps that looked tolerable in 2024 are getting harder to defend in 2025 and beyond.

For payroll, HR and finance teams, this is no longer a project; it is part of business as usual.

What Employers Must Report Under ERR

ERR covers three categories of expenses and benefits made to employees and directors. They are limited but easy to underestimate, because most employers operate at least two of them informally.

• Small Benefit Exemption: non-cash benefits (typically vouchers) provided within Revenue’s annual limits.
• Remote Working Allowance: the daily allowance an employer may pay to remote workers to cover utility costs.
• Travel and Subsistence: reimbursements and allowances for business travel, including subsistence expenses.

For each item that falls inside these categories, employers must submit details to Revenue on or before the date the benefit is provided or the payment is made. Every submission must be linked to the correct employee through the existing payroll employee record, so PPSN, employment ID and payroll alignment are non-negotiable.

What Information Do You Need to Capture?

For each reportable item, the data fields Revenue expects employers to report include:

• Employee identifier (linked to payroll records and PPSN).
• Date the benefit or payment was made.
• Category (Small Benefit, Remote Working, Travel, Subsistence).
• Amount or value, in euros.
• Where relevant, the number of days the allowance covers (for remote working) or the nature of the trip (for travel and subsistence).

Documentation requirements sit alongside the data fields. Receipts, approval trails, vouched expense claims and written policies all need to be available if Revenue asks. The reporting is the visible layer; the controls behind it are what make the reporting defensible.

How ERR Reporting Works in Practice

ERR submissions are made through Revenue Online Service (ROS), either directly on ROS or via the employer’s payroll software linking through to ROS. Most established payroll providers have built ERR submission into their existing PAYE Modernisation workflows, so for many employers the operational flow is:

1. An employee receives a reportable benefit or makes an eligible claim.
2. The benefit is approved against policy and routed into payroll or the expense system.
3. The payroll software generates an ERR submission to Revenue on or before the payment date.
4. The submission is acknowledged by Revenue and a reference is logged for the employer’s records.

That sounds clean on paper. In reality, most non-compliance starts upstream of payroll, where benefits are paid through expense systems, accounts payable, credit cards or third parties without a clean handover into the ERR feed. The single biggest risk for most employers is invisibility, not technical filing failure.

Common Reporting Pitfalls That Cause Non-Compliance

Across the population of Irish employers, the same handful of issues turn up again and again:

1. Treating ERR as periodic rather than real-time, so submissions are batched after the fact instead of made on the date of payment.
2. Missing non-cash items provided through accounts payable, credit cards or third-party providers (gift cards bought outside payroll, hotel stays charged to a corporate card, travel booked centrally).
3. Misclassifying items between Travel and Subsistence and ordinary reimbursements that are not in scope.
4. Incomplete data fields (date, value, category or employee mapping missing), which forces corrections.
5. No documented eligibility policy for remote working allowances, leading to inconsistent treatment between teams.

How to Report the Small Benefit Exemption Under ERR

The Small Benefit Exemption allows employers to provide non-cash benefits to employees and directors within specific annual limits without PAYE, USC or PRSI applying. From 1 January 2025, the rules permit up to five qualifying benefits per year, up to a combined value of €1,500, with the value of any single benefit counted at full value once awarded.

What employers should track:

1. Each benefit’s type (typically a non-cash voucher), date provided, and value.
2. Confirmation that the benefit is genuinely non-cash and meets the rules.
3. Cumulative position by employee across the tax year so the limits are not breached.

Common mistakes include treating cash bonuses or cash-equivalent payments as qualifying (they are not), missing the second or third award later in the year, and failing to link the benefit to the correct employee in the ERR feed. ERR reporting is required for these items even though the underlying tax treatment is exempt, so an exemption is never a reason to skip the report.

How to Report Remote Working Allowance Under ERR

The Remote Working Allowance refers to the daily, tax-free payment an employer can make to a remote worker to cover the additional household costs of working from home. The Revenue-set rate is currently €3.20 per day, paid for each day the employee genuinely works from home.

For ERR purposes, what to capture for each payment includes:

1. Dates or periods covered by the allowance.
2. Rate paid and total amount.
3. Employee’s eligibility basis (formal remote working arrangement or hybrid pattern).

The practical controls that hold up well are a written remote working policy, a consistent approval workflow, and payroll codes mapped explicitly to ERR categories. Where employers reimburse vouched home-office expenses instead of paying the daily allowance, they need to be careful to categorise the items correctly; a vouched expense reimbursement is a different beast from the per-day allowance, and the wrong category in the ERR submission causes downstream queries.

How to Report Travel and Subsistence Under ERR

Travel and Subsistence is the broadest of the three categories and, for most employers, the source of most reporting volume. It captures business mileage paid using civil service rates, day and overnight subsistence, and direct reimbursements that fall inside Revenue’s tax-free framework. Items that look similar but sit outside the framework (commuting costs, personal travel paid on a company card) are not reportable under ERR, but they still require clear policy and documentation to keep the categorisation defensible.

For each item, employers should capture:

1. Trip date or dates, amount paid, and the employee involved.
2. Type of payment (travel, day subsistence, overnight subsistence).
3. Business purpose, supported by receipts or vouched evidence.

The common issues here are blended expense claims that lump travel and subsistence with other categories, late submissions caused by missing receipts and approvals, and inconsistent interpretation of what counts as business travel between sites or to a normal place of work.

What Happens if You Don’t Comply With ERR

Revenue ran a service-first approach through most of 2024, focused on helping employers get used to the system. That posture has hardened as the data set has grown. Non-compliance now exposes employers to a familiar set of consequences:

1. Revenue queries and compliance interventions where reporting patterns look thin compared with peers or with the employer’s payroll profile.
2. Penalties under the relevant provisions, particularly for persistent failure to file or for incorrect submissions.
3. Reopening of PAYE settlement reviews where reportable items have not been declared.
4. Operational disruption: corrections, re-submissions, and finance time spent rebuilding the data after the fact.

The bigger risk for most employers is not a one-off penalty; it is the cumulative exposure across two-plus years of patchy data. The longer the gap goes uncorrected, the more painful the eventual clean-up.

Key Actions to Become ERR-Compliant Now

If you are not confident your ERR reporting is complete, the right move is a structured catch-up. A clean compliance action plan looks like this:

1. Map every benefit and allowance currently provided, including informal practices, items paid through expenses or accounts payable, and benefits arranged through third parties.
2. Confirm which items are in scope for ERR and set payroll, finance and expense codes accordingly. Every reportable item should have a single, unambiguous code.
3. Create a central ERR data capture process. One owner, one process, one audit trail. Spread the responsibility across HR, finance and payroll without a clear lead and items will fall through the gaps.
4. Update your policies for small benefits, remote working, and travel and subsistence so eligibility and approvals are written down and applied consistently.
5. Train approvers and payroll and expense teams so they recognise ERR-reportable items as they arise rather than weeks later.
6. Reconcile periodically. Payroll versus expense system versus general ledger, looking for items that should have been reported but were not.
7. Run a lookback from 1 January 2024 to identify gaps and correct them. Better to find and fix them than to let Revenue do it for you.

Category	What’s in scope	Common reporting pitfall
Small Benefit Exemption	Non-cash benefits within the €1,500 annual limit (up to 5 benefits)	Cash treated as qualifying, second or third benefit missed, wrong employee linkage
Remote Working Allowance	€3.20 per day paid for genuine remote working days	No record of days worked from home, no formal policy, mixed with vouched reimbursements
Travel and Subsistence	Civil service mileage, day and overnight subsistence, vouched business travel	Commuting included, blended claims, late submissions due to missing receipts

FAQs About Enhanced Reporting Requirements in Ireland

When did ERR start in Ireland?

ERR has been in effect since 1 January 2024 and applies to reportable benefits and payments provided from that date.

Do we need to report benefits even if they are tax-free or exempt?

Yes. ERR is a reporting requirement that sits separately from the tax treatment. Even where the underlying benefit is exempt, such as a Small Benefit Exemption voucher, the employer must still submit details to Revenue.

What are the most commonly reported items under ERR?

The three categories in scope are the Small Benefit Exemption, the Remote Working Allowance, and Travel and Subsistence. Across the Irish employer base, travel and subsistence drive most of the volume, with small benefits creating most of the year-end risk.

What if we think we’re only partially compliant. Should we fix past reporting?

Yes. A structured review from 1 January 2024 onward helps identify the gaps, correct the records, and reduce the risk of follow-up. Voluntary correction is materially less painful than Revenue finding the same gaps during an intervention.

How do we know what data fields Revenue expects for ERR submissions?

Revenue’s ERR guidance and the payroll reporting specifications set out the required fields. In practice, every reportable item must be linked to an employee record and include the date, category and value.

Get ERR-Compliant Without Disrupting Payroll

ERR is a deceptively simple regime: three categories, a handful of data fields, on or before the date of payment. The reason it trips up so many Irish employers is that the reporting depends on processes that sit outside payroll, in expenses, accounts payable, and informal benefit-giving. Get those upstream processes right and the ERR submission takes care of itself.

At Kinore, our payroll and tax team helps Irish employers run an ERR health-check covering benefit mapping, gap analysis from 1 January 2024, policy and controls review across small benefits, remote working, and travel and subsistence, payroll and expense coding, and support with corrections where needed. Senior-led, with dedicated client management and the depth to absorb a backlog without disrupting your live payroll. Request an ERR review and we’ll tell you exactly what you must report and where the gaps are.