Compliance

Revenue s71 & PEPPOL / EN 16931

Self-billing here is built directly on the conditions in section 71 VATCA 2010 and produced as structured e-invoices to the European standard — the same format Ireland’s B2B e-invoicing mandate (phasing in from 2028, ViDA-aligned) will require over the PEPPOL network.

PEPPOL self-billing exists for exactly this case: Directive 2006/112/EC Article 224 requires a prior agreement and a procedure for the supplier to accept each invoice — the same two pillars as Revenue s71(1)(a) and s71(1)(d)/(2).

How each s71 condition is met

s71(1)(a)Prior agreement that the customer may draw up and issue invoices.
The self-billing agreement is accepted by both parties before any invoice can be raised; an invoice can only be created against an active agreement.
s71(1)(b)The customer is a person registered for VAT.
The Customer (business) carries a VAT number and is the self-biller; it appears as AccountingCustomerParty with PartyTaxScheme in every invoice.
s71(1)(c)Form, content and issue conditions are met by the customer.
Invoices are produced as EN 16931-conformant UBL with all mandatory business terms (parties, VAT breakdown, totals, line).
s71(1)(d)Agreed procedure for the supplier to accept the validity of the invoice.
Each invoice has a supplier accept/reject step recorded with name, timestamp, IP and user-agent.
s71(2)An invoice is deemed issued only when accepted by the supplier.
An invoice stays 'pending' until the supplier accepts it; only then does it become 'accepted' (deemed issued).
s71(3)Outsourcing — invoices issued by a person acting in the name and on behalf of the supplier/customer.
The agreement's outsourcing clause names Oxus Technologies software as acting in that capacity; the s71(1)(c)/(d) conditions still apply.
s71(4)Credit/debit notes that refer unambiguously to an invoice are treated as invoices.
Self-billed credit notes (type 261) and debit notes (527) follow the same agreement and acceptance rules. (Credit-note issuance is a planned follow-up.)
s71(5)Regulations may set further conditions (Reg 21, VAT Regulations 2010).
The agreement is expressly made under s71 and Reg 21, implementing Article 224 of Directive 2006/112/EC.

PEPPOL / EN 16931 conformance

StandardEN 16931 (European e-invoicing standard)
ProfilePEPPOL BIS Self-Billing 3.0 (a CIUS of EN 16931)
SyntaxUBL 2.1 Invoice
BT-3 type389 — self-billed invoice (261 credit note, 527 debit note)
BT-24 CustomizationIDurn:cen.eu:en16931:2017#compliant#urn:fdc:peppol.eu:2017:poacc:selfbilling:3.0
BT-23 ProfileIDurn:fdc:peppol.eu:2017:poacc:selfbilling:01:1.0
Participant ID (EAS)9935 — Irish VAT number scheme

On transmission

This platform generates and validates the compliant UBL document. Sending it over the PEPPOL network requires a certified Access Point and SMP registration — a provider integration that plugs in at the invoice “Download UBL XML” step.

This is an implementation summary, not tax or legal advice. Master templates and VAT treatment should be confirmed with your advisers before go-live.