Revenue has increased compliance activity in relation to Enhanced Reporting Requirements (ERR), with employers now receiving Level 1 compliance interventions where filings are missing or incomplete.

What is ERR?

ERR applies to all employers from 1 January 2024 and requires certain non-taxable payments to employees to be reported to Revenue in real time (on or before the payment date).

This includes:

• Travel and subsistence
• Small benefit exemption items
• Remote working daily allowance

ERR is mandatory — and Revenue is now actively reviewing employer compliance.

What we are seeing from Revenue

Following an initial transition period, Revenue has moved to formal compliance interventions.

Employers are now receiving Level 1 notifications under Revenue’s Code of Practice for Compliance Interventions where:

• ERR filings have not been made, or
• Filings are incomplete or incorrect

A Level 1 intervention is a formal compliance step and should be treated as time-sensitive.

Why this matters for employers

Revenue expects employers to fully regularise their ERR position - not simply acknowledge correspondence or start ERR filing going forward.

If issues are not addressed within the required timeframe, Revenue may escalate the matter to a Level 2 compliance intervention (e.g. a risk review or audit).

Level 2 interventions typically involve:

• Broader PAYE and employment tax review (beyond ERR)
• Increased penalties and interest
• Detailed review of payroll processes, expense policies and governance
• Greater ongoing Revenue scrutiny

What should employers do now

If you have received (or expect to receive) a Level 1 notification, you should act immediately:

1. Confirm whether ERR filings are complete and accurate from 1 January 2024
2. Validate that submissions meet Revenue data, schema and ROS requirements
3. Identify and remediate any historic gaps
4. Put in place a robust process for ongoing real-time compliance

How RSM can help

RSM supports employers through proactive and outsourced ERR solutions, as well as assisting clients in responding to Revenue compliance activity where required.

Our support includes:

• Targeted ERR exposure reviews following Revenue contact
• Completion of historic ERR backfilings
• Ongoing managed filing services (end-to-end)
• Technical review of expense classifications aligned with Revenue guidance
• Acting as ERR agent in engagement with Revenue

We can also integrate ERR reporting into your wider payroll and compliance processes, reducing internal burden and risk.

Next steps

Given the current level of Revenue activity, early action is key to managing risk and avoiding escalation.

If you would like to discuss your position or put a plan in place, please contact: Caoimhe Neary, Employment Tax Partner and Warren Keogh, Payroll Partner.