Critical Compliance Update for January 2026

ERR 2026: Why Excel is Now a"Red Flag" for Revenue

The "Service for Compliance" grace period is over. Revenue is now using ERR data to trigger real-time interventions. If your Excel sheet doesn't match your bank transfer to the day, you are flagged.

€4,000+
Per Deliberate Breach
Same Day
Report Before Payment
Year 2
Full Enforcement
From €9
Per User/Month

1. The "Grace Period" is Over

Why 2026 is the year of no excuses

When Enhanced Reporting Requirements (ERR) were introduced in January 2024, Revenue adopted a "Service for Compliance" approach. They understood businesses needed time to adapt. Mistakes were treated as learning opportunities.

Full enforcement began in January 2025. We are now in year two—that safety net is long gone.

Revenue's systems have matured. Their analytics can now cross-reference your ERR submissions against bank transfers, payroll records, and historical patterns in real-time. Discrepancies that would have been overlooked during the grace period now generate automatic flags for review.

ERR Enforcement Timeline

1
January 2024
ERR Introduced

Revenue launches Enhanced Reporting Requirements with "Service for Compliance" grace period.

2
H1 2024
Grace Period

Revenue focused on education and guidance. Grace period extended through end of 2024.

3
January 2025
Full Enforcement

Grace period ends. Revenue begins using ERR data for real-time interventions and audits.

2026
Year Two

Second year of full enforcement. Automated systems flag discrepancies immediately.

2. The "On or Before" Rule: Why Manual Fails

The timing requirement that catches Excel users

The ERR Rule

You must report the expense to Revenue on or before the date you pay the employee.

Key: Not within 24 hours. Not the next business day. On or before.

The Excel Problem

1You pay Mary her mileage on Friday afternoon via bank transfer
2You forget to update your Excel until Monday morning
3You upload the JSON file to ROS on Monday afternoon
Result: Automatic Compliance Flag. You're 3 days late.

The Expense.ie Solution

Our system tracks every expense with correct classification, so when you're ready to file with Revenue, your ERR export is accurate and complete.

Step 1
Employee submits claim with correct classification
Step 2
Manager reviews and approves
Step 3
Export ERR-ready report for Revenue

3. The "Vouched vs. Unvouched" Trap

The classification that Revenue scrutinises most

Revenue requires you to split travel expenses into specific sub-categories. The distinction between vouched (receipted) and unvouched (flat-rate) expenses is critical for tax treatment.

In Excel, employees often mix these up in one column called "Expenses" or "Travel". This is exactly what triggers an audit.

Train Tickets
€45.00 Heuston to Cork
Original receipt required
Bus Fares
€12.50 Dublin Bus
Receipt or ticket stub
Toll Charges
€3.10 M50 toll
Bank statement or toll tag record
Parking
€8.00 NCPS parking
Parking receipt
Taxi/Uber
€25.00 Airport transfer
Digital or paper receipt
Flights
€180.00 DUB-LHR return
Booking confirmation + receipt

Common Excel Mistake

If you report Civil Service Mileage (unvouched) as 'Vouched Travel' in 2026, you are inviting an audit. Revenue's systems specifically look for this mismatch.

Our system detects this difference automatically and prevents incorrect classification.

How Expense.ie Handles ERR

See the ERR Export in Action

Every expense is automatically classified as Vouched or Unvouched, timestamped, and ready for Revenue — no manual sorting

expense.ie/reports/err-export

ERR Export — February 2026

Acme Solutions Ltd · Finance Act 2022, Section 897C

Export for ROS
Ready to file

Travel Vouched

€3.10

1 item · receipted

Travel Unvouched

€219.23

3 items · mileage rates

Subsist. Unvouched

€65.42

2 items · day rates

Total ERR

€287.75

6 line items

ERR Line Items

Auto-classified · No manual sorting needed
21 Feb · Aoife O'Brien
Travel Unvouched
Mileage — Dublin → Cork (264 km)
€142.38
Reported 21 Feb
21 Feb · Aoife O'Brien
Subsistence Unvouched
Day rate — 10+ hours domestic
€46.17
Reported 21 Feb
19 Feb · Cian Murphy
Travel Unvouched
Mileage — Galway → Limerick (98 km)
€52.67
Reported 19 Feb
19 Feb · Cian Murphy
Travel Vouched
Toll — M6 motorway
€3.10
Reported 19 Feb
19 Feb · Cian Murphy
Subsistence Unvouched
Day rate — 5–10 hours
€19.25
Reported 19 Feb
18 Feb · Siobhán Kelly
Travel Unvouched
Mileage — Office → Naas (45 km)
€24.18
Reported 18 Feb
All 6 items reported on or before payment date
0 late filings · 0 misclassifications
Vouched vs Unvouched — classified automatically

4. The Hidden Danger: "Country Money" & Site-Based Employees

Critical for construction, engineering, and field service companies

What is "Country Money"?

Also known as "Eating on Site Allowance" or "Site Subsistence", this is a payment made to employees who work away from their normal base—common in construction, engineering, and field service industries.

Typical weekly payment:
€50 - €150
Per employee, tax-free if compliant

The Audit Risk

"Country Money" is technically reportable under ERR. If you pay this tax-free but don't report it via ERR, you become liable for:

  • PAYE on every single payment
  • Employer's PRSI on every payment
  • Interest dating back up to 4 years
  • Potential penalties per unreported payment

Real-World Exposure Calculation

Employees on site
15
Weekly allowance
€100
Weeks per year
48
Lookback period
2 years
Unreported payments total:€144,000
Potential PAYE/PRSI liability (est. 40%):€57,600
Plus: Penalties + InterestAdditional

The Expense.ie Solution

Expense.ie includes a dedicated "Site Allowance" toggle that correctly tags these payments for ROS (Revenue Online Service). Your ERR submissions are compliant from day one.

5. 2026 Penalties: What Does a "Non-Compliance" Fine Look Like?

Current Revenue penalty structure for ERR breaches

Breach TypeFirst OffenceRepeatedDeliberateApplied
Late Filing€100€500€4,000Per return filed late
Incorrect Information€100€500€4,000Per incorrect submission
Failure to Report€100€500€4,000Per unreported payment
Misclassification€100€500€4,000Per misclassified expense

Expense.ie Solo Plan

RECOMMENDED
Monthly price€9 per user/month
Annual price€79 per user/year
Setup fee€0
ERR compliance
Starting from€79/year

Excel + Single ERR Fine

RISK
Single deliberate breach fine€4,000
Accountant audit prep€500 - €2,000
Back taxes (if applicable)Uncapped
Your time & stressSignificant
Minimum exposure€4,500+

In 2026, Using Excel for Expenses is LikeDriving Without Insurance

You might be fine for a while, but the crash will cost you everything. Don't wait for a Revenue audit to discover your spreadsheet isn't compliant.

ERR-Ready Reports

Export accurate, compliant data when you need it

Correct Classification

Vouched vs unvouched automatically handled

Site Allowance Toggle

Country Money correctly tagged for ROS

No setup fees. No per-employee charges. Cancel anytime.