If you are a sole trader or freelancer in Ireland and your turnover is below the VAT registration threshold, you probably do not charge VAT at all. You still need a proper invoice to get paid, keep your records straight and file your income tax return. The catch is that most invoice templates are built for VAT-registered businesses, so they push you to add a VAT number, a VAT rate and a "Tax Invoice" heading you should not be using. This guide explains what Revenue (the Irish tax authority) says, what to put on your invoice, what to leave off, and how to watch the threshold, with a worked example you can copy.
Quick answer: if you are not registered for VAT, send a document headed "Invoice" with your name and address, the client's name and address, a unique sequential number, the date, a clear description of the work and the total. Do not add VAT, do not show a VAT number, and add a short note such as "Not registered for VAT. No VAT has been charged."
Do you need to register for VAT in Ireland?
Revenue's page on VAT thresholds says registration is obligatory when your annual turnover exceeds the thresholds. The principal ones are:
- €42,500 if you supply services only.
- €42,500 if you supply goods at the reduced or standard rates that you manufactured or produced from zero-rated materials.
- €85,000 if you supply goods.
- €85,000 if you supply both goods and services and 90% or more of your turnover comes from goods (other than the manufactured goods above).
Most freelancers (designers, writers, developers, consultants, tutors, photographers) supply services only, so the figure that matters to them is €42,500.
How turnover is counted
Revenue measures annual turnover as the total value, excluding VAT, of your taxable goods and services in a calendar year, plus a few other items such as supplies of immovable goods and certain financial and insurance transactions. Some things are left out, for example occasional disposals of business assets such as a van or a machine. Revenue's own example is a trader who sells €70,000 of goods and a €20,000 delivery van in the same year: the van is disregarded, so his turnover for the test is €70,000.
When you cross the line
Revenue's page on who needs to register for VAT is strict about timing. You are generally obliged to register from the moment your turnover exceeds the threshold, you are regarded as an accountable person immediately on completing a transaction that takes you over it, and you must apply to Revenue within 30 days of that transaction. So it is not enough to look at your figures once a year when you file your return. Keep a running total.
The same page notes that businesses below the thresholds can use the SME Scheme and are generally not obliged to register, and that a person carrying out only exempt or non-taxable activities does not need to register either.
Can you charge VAT if you are not registered?
No. Revenue describes an accountable person as someone who supplies taxable goods or services in the State and is registered, or required to register, for VAT. As such, they are required to charge VAT. If you are under the threshold and have not registered, you are not an accountable person, so there is no VAT to charge and no VAT number to show.
Your price is simply your price. Do not add 23% "to be safe" and do not label the document a VAT invoice. Revenue explains that a VAT invoice is a document issued by an accountable person, and that it is what lets a VAT-registered customer reclaim the VAT charged to them. A client who sees VAT on your invoice will expect to claim it back, and that only works with a genuine VAT registration.
Should you register voluntarily?
You can. Revenue says you may still elect to register even if your turnover does not exceed the thresholds, and that a new business can register to reclaim VAT on start-up costs. Registering means you then charge VAT on your sales, issue proper VAT invoices and file VAT returns online. It can make sense if most of your clients are VAT-registered businesses (they can reclaim the VAT you add) and you have significant VAT on your own costs. It rarely helps if you sell mainly to private individuals, because they cannot reclaim anything and your price effectively rises. Revenue's page on how to register for VAT explains that sole traders use the TR1 form through the Revenue Online Service (ROS). Talk to an accountant before you elect, because the decision affects your prices and paperwork.
What to put on an invoice when you are not VAT registered
Revenue's list of information required on a VAT invoice applies to accountable persons, so it is not a legal checklist for you. It is still a sensible model, minus the VAT items. Your invoice should show:
- The word "Invoice" as the heading, not "Tax Invoice" or "VAT Invoice".
- Your name and address, plus a trading name if you use one.
- Your client's name and address.
- A unique, sequential invoice number, such as INV-2026-014. Our invoice numbering guide shows simple formats.
- The date of issue, and the date the work was done if it is different.
- A clear description of what you supplied: hours, days, items or a fixed fee.
- The amount for each line and the total, in euro.
- Payment terms and details: the due date, your IBAN and BIC, and a payment reference.
- A short note that you are not registered for VAT.
For a full general checklist, see what to include on an invoice.
What to leave off
- No VAT line, rate or VAT amount. Not even "VAT 0%", which can look like you are registered and making a zero-rated supply.
- No VAT number. Leave the field empty rather than inventing or borrowing a number.
- No "Tax Invoice" heading.
- No reverse-charge wording. That wording is for VAT-registered businesses supplying customers in other EU countries.
Wording for the note
Any of these works:
- "Not registered for VAT. No VAT has been charged."
- "VAT not applicable: supplier is not registered for VAT in Ireland."
- "The supplier is below the VAT registration threshold and is not registered for VAT."
Keep it short and factual. It answers the client's question before they email you about it.
Worked example: a freelance web designer in Galway
Aoife is a self-employed web designer in Galway. She supplies services only, so her threshold is €42,500. Her turnover from January to the end of October 2026 is €31,400, and she is not registered for VAT.
In November she finishes a small website project for a café in Dublin. Her invoice looks like this:
- Heading: Invoice
- From: Aoife Brennan Web Design, 12 Quay Street, Galway
- To: Harbour Café Ltd, 4 Dock Road, Dublin 2
- Invoice number: AB-2026-031
- Invoice date: 14 November 2026
- Due date: 28 November 2026 (14 days)
- Line 1: Website design and build, fixed fee, €1,400.00
- Line 2: Copywriting for five pages, 5 × €60.00 = €300.00
- Line 3: One-year hosting set-up and handover session, €150.00
- Total due: €1,850.00
- Note: Not registered for VAT. No VAT has been charged.
- Payment details: Account name, IBAN, BIC and reference AB-2026-031
There is no VAT line and no VAT number. The total is simply the sum of the lines: €1,400 + €300 + €150 = €1,850.
The threshold check
After this invoice, Aoife's turnover for 2026 is €31,400 + €1,850 = €33,250. She has €9,250 of headroom left before €42,500.
Now suppose a client offers her a €10,000 project to finish in December. Completing it would take her to €43,250, which is over the threshold. Under Revenue's rules she would become an accountable person on completing the transaction that crosses the line, and she would have 30 days to apply for registration. Before she accepts, Aoife should check with Revenue or an accountant how VAT would apply to that job and whether to quote it VAT-inclusive or VAT-exclusive. Spotting this in advance is far easier than fixing invoices afterwards.
How to make this invoice in InvoiceDesk
Our free Irish invoice generator is set up for VAT-registered businesses by default, so a few quick changes give you a clean non-VAT invoice:
- Open the generator. The currency is already set to euro and dates use the Irish day-month-year format.
- In the Document title field, type "Invoice". The Irish edition defaults to "Tax Invoice", which is wrong for you.
- Fill in your details and your client's details. Leave the VAT number and Customer VAT no. fields blank.
- Add your work with + Add item.
- Open Tax, discount and totals and remove the VAT line with the ✕ (Remove tax line) button. You will see "No tax lines" once it has gone. Do not use the "Zero-rated / exempt (0%)" preset; that still prints a VAT line.
- Under Notes, payment and signature, put your not-registered note in Notes and your IBAN and BIC in Payment details.
- Click Save as profile so your details and settings are ready next time, then download the PDF.
Everything stays in your browser. Nothing is uploaded unless you choose to save or share a file.
Income tax still applies
Not charging VAT does not mean your invoices are tax-free. Revenue's guide on registering for income tax self-assessment says you should register if you are self-employed, and you must register if your taxable non-PAYE income exceeds €5,000 or your gross non-PAYE income exceeds €30,000. Under the Pay and File system, you file your return (Form 11) on or before 31 October in the year after the tax year, so the 2026 return is due by 31 October 2027.
Your invoices are the backbone of the income figure on that return, which is why consistent numbering and good records matter. See our guide on how long to keep invoices and keep copies of every invoice you send, along with receipts for your expenses.
Selling outside Ireland
Clients abroad are common for freelancers, and two points are worth knowing.
First, you can invoice in another currency, such as pounds or dollars, if the client asks. Our guide to invoicing in a foreign currency covers exchange rates and bank fees.
Second, cross-border rules can pull an unregistered business into VAT. Revenue notes that even a person who is not otherwise required to register may have to register in certain situations, for example when acquiring goods from other EU member states or receiving services from abroad. If you buy services from suppliers outside Ireland, such as software or advertising, or you plan to sell into other EU countries, read Revenue's guidance or ask an accountant. Since 1 January 2025 there is also an optional EU VAT SME Scheme that lets small businesses use other member states' thresholds, with its own registration and quarterly reports.
If you later register for VAT and sell services to EU businesses, our reverse charge guide explains the wording you will need then.
Common mistakes
- Calling it a tax invoice. Use "Invoice" until you are registered.
- Adding VAT you cannot charge. If you are not registered, there is no VAT to add.
- Printing "VAT 0%". It suggests a registered, zero-rated supply. Remove the line.
- Forgetting the running total. The threshold is tested on calendar-year turnover, and the 30-day registration clock starts from the transaction that crosses it.
- Breaking the number sequence. If you make a mistake, issue a credit note rather than deleting the invoice.
- No due date. Put a clear date on every invoice. Our payment terms page explains the common options.
FAQ
Do I need a VAT number to send an invoice in Ireland?
No. If you are below the threshold and not registered, you can invoice without a VAT number. Just do not charge VAT or describe the document as a VAT invoice.
What is the VAT threshold for services in Ireland?
Revenue lists €42,500 for persons supplying services only. The threshold for supplying goods is €85,000. Check Revenue's thresholds page for the full rules, since mixed and manufactured supplies have their own tests.
Should I write "VAT exempt" on my invoice?
It is better not to. "Exempt" has a specific meaning in VAT law for certain types of supply. If you are simply below the threshold, say you are not registered for VAT and that no VAT has been charged.
Can a business client refuse an invoice without VAT?
A business client cannot reclaim VAT that was never charged, but your invoice is still a valid request for payment. A short not-registered note usually answers any question from their accounts team.
What happens if I go over the threshold?
Revenue says you become an accountable person on completing the transaction that takes you over the threshold and must apply to register within 30 days. From then on you charge VAT and issue VAT invoices. Get advice early if you see it coming.
Can I register for VAT even though I'm under the threshold?
Yes. Revenue allows you to elect to register. It can suit freelancers who work mainly for VAT-registered businesses and have VAT on their own costs, but it adds VAT returns and changes your prices, so take advice first.
Is a PDF invoice acceptable?
Yes, a PDF invoice is a normal invoice. Keep a copy of every one you send as part of your records.
Summary
If you are a sole trader in Ireland under the VAT threshold, keep your invoice simple: head it "Invoice", number it in sequence, describe the work, show a total with no VAT, and add a one-line note that you are not registered for VAT. Track your calendar-year turnover against €42,500 for services or €85,000 for goods, and register within 30 days if you cross it. When you are ready, create your invoice with the free Irish invoice generator.
This article is general information, not tax advice. Rules change, so check the Revenue pages linked above or speak to an accountant about your situation.