Can you invoice without a VAT number in Ireland? Yes. Here is how to do it properly

Who can invoice without a VAT number

Two groups. First, anyone whose turnover is under the registration threshold. Revenue’s principal thresholds are €42,500 for a business supplying services only and €85,000 for a business supplying goods (or goods and services where 90% or more of turnover is goods). Revenue says registration is obligatory when annual turnover exceeds the threshold; below it, registration is optional. Second, businesses whose supplies are exempt from VAT. Revenue says a person supplying only exempt goods or services is “not generally entitled to register” at all. Citizens Information gives financial, medical and educational services as the everyday examples. A limited company, a partnership and a sole trader are all in the same position: the test is turnover, not structure.

What to write instead of a VAT number

Your invoice still needs everything an invoice needs: your name and address, an invoice number in sequence, the date, the customer’s name and address, a description of what you supplied with quantities and unit prices, one total, payment terms and bank details. In place of the VAT block, add a single clear statement. Any of these:

• “Not registered for VAT.”
• “Not registered for VAT. No VAT has been charged on this invoice.”
• “Supplier is below the VAT registration threshold; this is not a VAT invoice.”

There is no prescribed wording in Irish law for this statement. Its job is to answer the two questions a business customer’s bookkeeper will otherwise email you about: where is the VAT number, and is this total inclusive of VAT. A worked example of the whole document is in our sole trader invoice template.

What not to write

Revenue puts it in one sentence: “A trader not registered for Value-Added Tax (VAT) should not issue an invoice showing an amount of VAT. Any trader who does so will be liable for the VAT shown on the invoice.” It adds that such a trader “may also be liable to penalties”, and its schedule of fixed penalties lists the issue of a VAT invoice by a non-registered person at €4,000. So:

• No VAT rate column and no VAT amount line. Not even a column of zeros.
• No “VAT 0%” or “VAT @ 0%”. Zero-rating is something registered traders do to exports, bread, milk, books and children’s clothes. On your invoice it implies a registration you do not have, and a customer might file it as a zero-rated purchase.
• No “VAT invoice” heading and no “VAT No:” label left blank. A blank field invites a query.
• No “price includes VAT”. It does not.
• No made-up or borrowed VAT number. EU business customers check numbers on the Commission’s VIES site, and Revenue can check them at any time.

When you must register

The thresholds are tested over calendar years. Since 1 January 2025, under the EU VAT SME scheme, Revenue’s guidance says a trader stays outside VAT only while annual turnover “does not exceed the applicable threshold in the current and previous calendar years”. Turnover means the VAT-exclusive value of your taxable supplies in the calendar year; one-off disposals of business assets such as a van are left out. Two consequences follow.

1. You register immediately, not at year end. Revenue’s own example: a manufacturer with €84,000 of goods sales by 30 September makes a €1,500 sale, is over the €85,000 goods threshold for the year, and “is required to register for VAT, from the date of the €1,500 transaction”. Revenue puts it generally: “A trader is regarded as an accountable person immediately on completing a transaction that exceeds the threshold.”
2. Last year counts too. If you went over the threshold last calendar year, you are outside the scheme this year even if this year is quieter. Revenue’s table gives the case of €90,000 last year and €87,000 this year as not eligible, and €86,000 last year with €80,000 this year the same.

The older rule of thumb about “any continuous 12-month period” and being “likely to exceed” the threshold has been replaced by this calendar-year test for domestic supplies; advice that still uses the 12-month wording predates the 2025 change. Failing to register when required carries a fixed penalty of €4,000 on Revenue’s list.

Two more triggers have nothing to do with the threshold. Revenue says businesses that are not VAT registered may still have to register and account for VAT if they receive taxable services from abroad, or if they acquire goods from other EU states above €41,000 in any 12 month period. Buying software or advertising from a supplier outside Ireland is the common way a small business meets the first one. Check before assuming the threshold is the only test.

You can also choose to register early. Revenue confirms that businesses under the threshold may elect to register, from a current date only, with the same obligations as a compulsory registration. Registering lets you reclaim VAT on purchases and start-up costs; it also adds 23% to your price for private customers if your work is at the standard rate. If turnover later falls below the threshold, Revenue says the registration can be cancelled, though separate rules apply to cancelling an election.

What changes on your invoices the day you register

Registration takes effect from the date on your form (TR1 for sole traders and partnerships, TR2 for companies, both done online through ROS). From that date:

• Your VAT number goes on every invoice, and the “not registered” statement comes off.
• Every line shows its VAT-exclusive unit price and its rate, and the invoice ends with net, VAT and gross broken down by rate. The full list is in VAT invoice requirements in Ireland.
• There is a deadline. A VAT invoice must issue within 15 days of the end of the month in which the supply was made.
• You must issue a VAT invoice to business customers, public bodies and exempt businesses, whether or not they ask for one.
• Prices to consumers need rethinking. A €500 job is now €500 plus €115 at the standard rate, or you absorb it.
• Returns and payments go through ROS, and Revenue must be told of any change in your details within 30 days.

The free invoice generator covers both states. Before registration, leave the VAT number blank, keep every line at 0% and put your statement in the notes. After registration, add the number and choose the rate per line; the breakdown by rate is built for you.

A note on customers in other EU countries

The reverse charge is what registered Irish businesses use when invoicing a business customer in another EU state: no Irish VAT, the customer’s VAT number on the invoice, a notation that the reverse charge applies, and the supply reported on a VIES return. Revenue says businesses intending to trade with EU businesses should apply for the Intra-EU version of VAT registration rather than Domestic-only. If you are not registered, none of that machinery is available to you, and you should not write “reverse charge” on an invoice. Revenue’s general rule for services to a business customer abroad is that the place of supply is where the customer is established, so no Irish VAT is due either way. Selling to EU businesses regularly is a good moment to talk to an accountant about registering, because their paperwork and VIES will want a VAT number.

Frequently asked questions