Signed into law in December 2022, the Finance Act 2022 has changed the requirements governing the reporting of expenses to Revenue. Under a new system referred to as Enhanced Reporting Requirements (ERR), companies are now required to report any “reportable benefits” paid to employees and/or directors. These are benefits which are not currently subject to tax under the PAYE system and are the following:

• The remote working daily allowance of €3.20
• The payment of travel and subsistence expenses
• The small benefit exemption

Anyone wishing to examine these changes themselves should consult Section 897C of the Finance Act. However, here we will provide an overview of these changes, the system for reporting these expenses, and advice on how to prepare. The new ERR regime is effective from 1 January 2024.

There are 3 options from which employers can choose to make ERR submissions:

1. Completion of an online form on ROS Online
2. Manually upload a file to ROS Online
3. Directly from their payroll or expense management system

What information does ERR require?

Compliance with the “reportable benefits” system involves sending on employee-related information such as the employee’s name, address, DOB, PPSN, staff number, and employment ID. Additionally, the payment date, value, and category are all be included. However, the three categories of expense all have slightly different requirements, which can be broken down as follows:

Travel & Subsistence: this covers payments an employer makes to an employee/director regarding travel or subsistence incurred by the employee, where no tax is deducted. When submitting a report to Revenue, the amount and date paid should be provided for each of the following categories:

• Travel Vouched
• Travel Unvouched
• Subsistence Vouched
• Subsistence Unvouched
• Eating on site
• Site based employees (includes “Country Money”)
• Emergency Travel

Small Benefit: this covers any tax-free benefits that an employee/director may be provided by their employer. These can include vouchers but extends to many kinds of benefits. When making these payments, the employer should ensure the payment conforms to the standards set out in Section 112B of the Taxes Consolidation Act 1997.

Notable conditions here are that the voucher or benefit cannot exceed €1000 in value and only two vouchers or benefits may be given in any one tax year (it should be noted that these conditions have also only been in effect as a result of the Finance Act 2022; previous limits were €500 in value and only one voucher per year).

Employers are required to report the following:

• Date provided
• Value

Remote working daily allowance: this covers any payment an employee/director may receive from their employer which relates to days the employee worked from home. These payments can come to no more than €3.20 per day. Employers are now expected to report:

• Number of days
• Amount paid
• Date paid

How can we help?

• Provide bespoke training to key stakeholders.
• Review and analyse how your organisation currently collects information related to the reportable benefits.
• Review your organisation’s policies to evaluate the different types of employee expenses your organisation currently makes and update the language used, where necessary, to bring your own records of these expenses in line with the ERR categories.
• ERR Reporting on an outsourced basis (including reviewing databases, enriching file with the required data for ERR, preparing the final file to be converted to Revenue approved format and making ERR submissions to Revenue).

For further information, please contact Carol Hartnett, Manager in our Accounting & Financial Advisory Department.