FATCA Reporting in Ireland: Revenue’s Paragraph 4.3 Update on US TINs

Revenue published eBrief No. 147/26 on 9 October 2026 to announce a revised Tax and Duty Manual Part 38-03-22, the Guidance Notes on the Implementation of FATCA in Ireland. The revision sits in paragraph 4.3, which now reflects IRS Notice 2024-78 and its extension of temporary relief for pre-existing accounts reported without a US taxpayer identification number (TIN) to the 2025, 2026 and 2027 reporting periods. For anyone running FATCA reporting in Ireland, that paragraph decides whether a missing TIN on an old account is a documented, tolerated gap or a possible finding of significant non-compliance.

The consequences are spelled out in the same manual. Revenue’s guidance notes say that a financial institution whose significant non-compliance remains unresolved after 18 months will be treated as a non-participating financial institution, and FATCA’s 30% US withholding tax targets payments to non-US financial institutions outside the framework. The relief holds only while every condition in paragraph 4.3.1 is met, and two of the seven conditions apply for the first time to the 2025 to 2027 periods. The filing mechanics around them have not moved: returns reach Revenue through ROS by 30 June after the calendar year, and Revenue exchanges the data with the IRS by 30 September.

Related reading: our FATCA reporting guide for Luxembourg financial institutions

The dates that frame the Irish FATCA cycle

• 30 June: the return date for the previous tax year (normally the calendar year) under Regulation 2(1) and Regulation 8 of S.I. No. 292 of 2014. The return for calendar 2026 is due by 30 June 2027.
• 30 September: Revenue’s stated date for exchanging FATCA data with the US. Section 891E(10) of the Taxes Consolidation Act 1997 (TCA) allows exchange within nine months of the end of the tax year.
• 12 November 2024: Internal Revenue Bulletin 2024-46, which carries Notice 2024-78.
• 9 October 2026: eBrief No. 147/26 and the revised Part 38-03-22, whose cover is now dated October 2026.
• Calendar years 2025, 2026 and 2027: the periods Notice 2024-78 covers, with Irish returns due by 30 June 2026, 2027 and 2028.
• 31 December 2031: the end of the retention period for the annual TIN-request policies and the evidence they were followed.

One of those return dates has already passed. The 2025 return, the first period Notice 2024-78 covers, fell due on 30 June 2026, more than three months before Revenue’s manual was revised.

Four layers of law and guidance behind an Irish return

The Minister for Finance signed the Ireland-US intergovernmental agreement on 21 December 2012. The order implementing it, S.I. No. 33 of 2013, is included in Part 3 of Schedule 24A to the TCA. Section 891E TCA, inserted by the Finance Act 2013, lets the Revenue Commissioners make regulations to give the agreement effect, and they did so in the Financial Accounts Reporting (United States of America) Regulations 2014, S.I. No. 292 of 2014, in operation from 1 July 2014. The 2014 Regulations were subsequently amended by S.I. No. 501 of 2015, S.I. No. 19 of 2018 and S.I. No. 245 of 2020.

Revenue’s manuals sit on top. Part 38-03-22 is the guidance for financial institutions, Part 38-03-25 holds the filing guidelines, and Part 38-03-24 is written for account holders. Revenue states plainly in the introduction to Part 38-03-22 that the guidance notes do not have the force of law.

That matters for reading the October revision. eBrief No. 147/26 announces a manual update and cites no amending regulations, and the conditions it adds come from an IRS notice. Notice 2024-78 is the US Competent Authority’s undertaking, where its conditions are met, not to find significant non-compliance under Article 5(2) or 5(3) of a Model 1 agreement solely because required US TINs for pre-existing accounts are missing. The Irish obligation itself is unchanged: Regulation 11 of S.I. No. 292 of 2014 requires each reporting financial institution to implement arrangements to obtain the TIN of every specified US person holding a reportable account, from 1 January 2017 for pre-existing accounts and from 1 July 2014 for new accounts.

Paragraph 1.3 of the guidance adds a less obvious rule. An Irish institution should not be disadvantaged by applying the Irish legislation compared with the US regulations or another Model 1 agreement, and where it considers an element of those to be more favourable, Revenue asks it to make contact and discuss the point.

Who is inside FATCA reporting in Ireland, including nil filers

The perimeter is set by four financial institution categories: custodial institution, depository institution, investment entity and specified insurance company. The custodial test in paragraph 2.2.1 is quantitative: at least 20% of gross income from holding financial assets for others and related services, measured over the shorter of the last three accounting periods or the period since the business began.

Location follows tax residence, generally. Paragraph 2.1 brings Irish branches of non-resident financial institutions into scope and leaves out branches and subsidiaries of Irish entities located abroad, which report under local rules. “Check the box” elections made to the IRS play no part in deciding Irish residence. Revenue’s own example is a UK-resident bank whose Irish branch reports to Revenue while the head office reports to HMRC.

Holding and treasury companies are the category where the original statutory text misleads. S.I. No. 292 of 2014, as made, listed a “relevant holding company” and a “relevant treasury company” as reporting financial institutions in their own right. S.I. No. 501 of 2015, in operation from 2 November 2015, deleted those definitions and categories. Paragraph 2.2.5 now treats such a company as a financial institution only if it meets one of the four categories; otherwise it is a non-financial foreign entity (NFFE), active or passive. Revenue allows a company that registered under the old categories as lead financial institution of an expanded affiliated group to keep acting in that role for reporting purposes, while it remains outside the financial institution definition with no Irish reporting obligations in its own right.

Registration runs on two tracks. Regulation 5 requires registration with the IRS, which issues the Global Intermediary Identification Number (GIIN) that goes on every return. Separately, the institution registers a FATCA reporting obligation with Revenue on ROS; an entity with no ROS access first registers as a reporting entity using Revenue’s Reporting Entity Registration Form, and agents can register clients through ROS. Appendix 3 of the guidance describes registration by a Model 1 institution as the way to apply for a GIIN and authorise one or more points of contact, and states that, although the IRS portal uses a “responsible officer” title, the title does not import the US Treasury concept for Model 1 institutions. An umbrella fund registers at umbrella level unless it elects to register sub-funds.

An institution with no reportable accounts still files. Regulation 9 requires a nil return, and paragraph 5.10 applies the point to securitisation vehicles that qualify as reporting financial institutions. Regulation 10 allows an agent such as a transfer agent to carry out the duties, but the institution stays responsible, and section 891E(7) and (8) apply to it as though it had acted itself.

What a reportable account record carries

Regulation 8 and paragraph 4.2 set the content. Every reportable account carries the account holder’s name, address and US TIN, the account number or its functional equivalent, the reporting institution’s name and GIIN, and the balance or value at the end of the period. The account type then adds amounts for the year:

The balance rules carry most of the detail. Values are taken at 31 December, or the last working day before it when it falls on a weekend. For an account closed during the year, the Regulations require the balance on the closing date; paragraph 4.7 accepts either the balance within five business days of the closure instruction or the most recent balance available after it. Joint accounts attribute the full balance to each holder, so two specified US persons on a USD 100,000 account produce two reports of USD 100,000. Regulation 8(7) treats a negative balance as nil for aggregation.

The dollar thresholds are elective. Regulation 6(2) lets an institution exclude, among others, new individual depository accounts of USD 50,000 or less at year end and pre-existing entity accounts of USD 250,000 or less. Paragraph 7.2 states the consequence of skipping the election: the institution will need to review all relevant accounts. The election must be made on or before the return date in the form Revenue requires, and on ROS that form is a checkbox at the top of the upload screen. Revenue’s filing guide says the same checkbox is also relevant when the nil return option is selected.

Paragraph 4.3 after 9 October: the seven conditions

The baseline in paragraph 4.3 is unconditional. Once an account holder is established as a specified US person, the institution is required to obtain a US TIN, for pre-existing and new accounts alike. The relief history explains why the paragraph is long. Notice 2017-46 covered 2017 to 2019. IRS Reporting FAQ3, added in October 2019, confirmed that from 1 January 2020 Irish institutions need not immediately close or withhold on pre-existing accounts without a TIN, and that the IRS would consult Revenue on the facts before any determination. Notice 2023-11 then covered 2022 to 2024, and Notice 2024-78 covers 2025 to 2027.

Paragraph 4.3.1 now lists the conditions for relief as follows:

The retention date moved by three years. Notice 2023-11 required the annual-request records to be kept until the end of 2028; Notice 2024-78 sets the end of 2031 and requires records adopted for Notice 2023-11 relief to be kept until 2031 as well. A records schedule built to the 2028 date now ends three years too soon.

The scope split runs in two directions. The relief covers pre-existing accounts only, which in Irish terms means accounts maintained on 30 June 2014, and Notice 2024-78 excludes accounts opened after the determination date, including new accounts held by holders of pre-existing accounts. The conditions are drafted wider: the Notice applies them to each US reportable account with a missing TIN “including new accounts”, and Revenue’s text repeats that the requirements cover both pre-existing and new accounts. Read literally, relief for the old book depends on how the institution handles missing TINs in the new book.

For new accounts, paragraph 4.3.2 requires a self-certification with a US TIN for every specified US person since 1 July 2014. Where a new individual account with US indicia becomes active without a TIN or confirmed status, the account is treated as reportable, the guidance expects the institution to document every effort to contact the holder, and the return carries the relevant placeholder. The IRS then issues an error notice allowing 120 days, after which it may examine the case with Revenue.

One further limb sits outside an institution’s control. Section 3.04 of Notice 2024-78 also requires the Model 1 jurisdiction to make good-faith efforts within nine months after the relevant year end. These include encouraging US citizens to provide TINs, taking measures to enforce compliance by institutions the IRS identifies as potentially non-compliant, encouraging institutions not to discriminate against US citizens who provide TINs and, where notified by the US Competent Authority, taking steps concerning competent authority arrangements, IGA implementation or amendment of Annex II, or country-by-country information exchange. Paragraph 4.3 does not discuss that limb.

The foreign TIN condition and Revenue’s own caveat

Condition 7 comes with a qualification written by Revenue. Directly after the list, paragraph 4.3.1 explains that a foreign TIN for the Notice’s purposes is a non-US TIN such as a PPSN, then states that there is currently no legal basis to collect or exchange non-US TINs under FATCA. The next sentence asks Irish institutions to endeavour to complete FATCA reporting as fully as possible, including reporting US TINs as Irish legislation requires.

The Notice’s wording narrows the conflict without removing it. Its condition applies only where the institution’s electronically searchable account information already contains a TIN issued by the person’s country of residence, so on its wording the condition does not require an institution to collect a PPSN for FATCA purposes. The filing guide already has the mechanics: paragraph 7.6 of Part 38-03-25 describes a record carrying both an Irish TIN and a US TIN, with the US TIN first.

What Revenue’s text does not say is which consideration governs when a PPSN sits in the customer file and the US TIN is missing. Notice 2024-78 requires an electronically held foreign TIN assigned by the person’s country of residence to be reported as a condition of relief. The Irish legal basis for collecting or exchanging a non-US TIN should be assessed separately, including the qualification in Revenue’s paragraph 4.3.1. Institutions should seek clarification from Revenue where those positions appear inconsistent. Revenue names its VIMA office, reached through MyEnquiries under AEOI and FATCA, as the contact point for questions on the guidance.

Condition 6 has a schema detail of its own. Revenue’s wording asks for city and country of residence without naming an XML element. Notice 2024-78 names it: city and country must appear in the AddressFix element, and AddressFree may be added as a supplement. On the Notice’s own terms, an address carried only as free text does not meet condition 6.

TIN placeholder codes, and where Revenue’s two manuals diverge

Condition 5 points to paragraph 7.6 of Part 38-03-25 for the code list. That filing guide shows a September 2026 review date on its cover, yet its paragraph 7.6 still describes the Notice 2023-11 relief as applying to 2022, 2023 and 2024, says the February 2023 codes “may be used” for 2023 and 2024, and does not mention Notice 2024-78. Part 38-03-22, revised in October 2026, says the February 2023 codes must be used for 2023 to 2027. Of the two manuals, only Part 38-03-22 sets out the 2025 to 2027 conditions; it is also the more recent text and the one that tracks the Notice.

The February 2023 code set, as listed in Part 38-03-25:

Part 38-03-25 and IRS Reporting FAQ6 both state that a placeholder code still generates a record-level error notification. Paragraph 7.6 of Part 38-03-25 adds that, in this case, the file is still accepted and exchanged, and the notice allows 120 days to correct the record. Revenue validation currently accepts both the May 2021 and February 2023 code sets for the relevant periods, nine capital “A” characters remain a permitted entry where no TIN exists (with the same error result), and nine zeros are no longer accepted. Outside the relief the codes are optional; inside it they are a condition.

The date of birth that condition 1 requires sits in the BirthInfo BirthDate sub-element, formatted per IRS Publication 5124, with the placeholder in the TIN element and the issuedBy attribute set to “US”.

Filing on ROS: file limits, characters and corrections

Paragraph 12.3 of the guidance makes the IRS FATCA XML format mandatory for full and nil returns alike, and returns in any other format are not accepted. ROS also offers a Submit Nil Return button, and the filing guide notes that XML nil returns may be uploaded. On ROS, a filer selects FATCA under “Upload Form(s) Completed Off-Line”; the same drop-down lists DAC2-CRS, which is a separate return. Part 38-03-25 refers filers to the FATCA XML Schema Guide (V2.0). For comparison on the CRS side, our note on Germany’s CRS schema v3.0 transition covers a schema change running on a different track.

The technical rules that reject files are specific:

• Size: individual files are recommended at no more than 10MB, and ROS rejects anything above 30MB or 20,000 records.
• Encoding: UTF-8 without a byte order mark.
• Characters: an unescaped ampersand or less-than sign rejects the file, as do the combinations double dash, slash-asterisk and ampersand-hash. The hash sign is valid on ROS but not in the FATCA schema.
• Pooled reporting: not permitted for a Model 1 jurisdiction, and ROS rejects it.

Corrections follow the IRS document types. A record-level error notification is answered with a corrected record (FATCA2), and Revenue’s guide states that an amended record is the wrong response to that notification. FATCA3 voids a record filed in error; FATCA4 amends a record after a valid notification, once the institution is aware of inaccurate information. Each links back to the original through the CorrMessageRefId and CorrDocRefId fields.

After submission: IRS notices, Revenue enquiries and penalties

Paragraph 12.5 sends every IRS query about errors in a return, and every specific enquiry, through Revenue as competent authority, which then contacts the institution, whether the issue is missing or incomplete fields, corrupted data or an incompatible format. Repeated minor errors can themselves become significant non-compliance where they continually disrupt the transfer of information.

Significant non-compliance can be determined by either authority. The notified institution then has 18 months to resolve it, during which Revenue discusses the failures, remedies and a timetable, and applies penalties where appropriate. Paragraph 12.7 gives examples: intentionally providing substantially incorrect information, deliberate or negligent omission of required information, ongoing failure to register, supply accurate information or establish governance and due diligence, and repeated failure to file or repeated late filing.

The TIN relief is narrow by its own terms. Notice 2024-78 states that nothing in it prevents a finding of significant non-compliance for failing any other obligation under the agreement, and it offers no protection to an institution that misses TINs without meeting the conditions.

Revenue’s own powers come from section 891E and the 2018 amendments. S.I. No. 19 of 2018, in operation from 1 January 2018, inserted Regulations 12 and 13: authorised officers may require information, books and records by written notice giving at least 14 days. Section 891E(7) lets an authorised officer enter a financial institution’s premises to test whether returns were correct and to examine its procedures. Revenue’s Notes for Guidance to the TCA (Finance Act 2025 edition) describe section 891E(8) as imposing a penalty of EUR 1,265 on a person who fails to comply with an officer’s requirements or with the Regulations, and section 891E(11) applies the rules as if any arrangement aimed at avoiding them had not been made.

FATCA and CRS in Ireland: one deadline, two obligations

Revenue applies the same calendar to the Common Reporting Standard: CRS and DAC2 returns are also due by 30 June, with exchange by 30 September. The obligations are still separate. Each needs its own reporting obligation on ROS, CRS registration and filing are covered by Part 38-03-26, and the legal bases differ: section 891E for FATCA, sections 891F and 891G for CRS and DAC2. Revenue’s Notes for Guidance list further reporting regimes beside them, including section 891HA for reporting crypto-asset service providers and section 891I for digital platform operators.

The population differs too. Revenue describes FATCA as covering accounts held by US citizens and US tax residents, while CRS information goes to the account holder’s jurisdiction of tax residence. Our CRS reporting guide covers the residence-based model, and our CARF and DAC8 explainer covers the crypto-asset layer now joining the same automatic exchange stack.

The 2025 return was due before the guidance changed

The IRS published Notice 2024-78 in the Internal Revenue Bulletin dated 12 November 2024. An earlier Revenue eBrief, No. 267/24 of 1 November 2024, reworded paragraph 4.3 of Part 38-03-22 for clarity and added wording to paragraphs 7.5 and 7.6 of Part 38-03-25. eBrief No. 147/26 of 9 October 2026 is the one that updates paragraph 4.3 to reflect Notice 2024-78. The 2025 return was due on 30 June 2026.

My reading is that the Notice’s conditions were the IRS’s terms for 2025 relief from the day the Notice was published, independent of when Revenue revised its manual. A team that filed its 2025 return in June 2026 can test that file against conditions 6 and 7: whether city and country of residence sat in AddressFix for each specified US person without a TIN, and whether an electronically held foreign TIN was reported. Neither eBrief No. 147/26 nor paragraph 4.3 says whether Revenue expects corrected 2025 submissions where those items were missing.

The Notice also limits how far ahead anyone can plan. It stops at calendar year 2027, and it says that if permanent relief is granted, the accounts it covers are expected to be narrower than the scope of the temporary relief.

Frequently Asked Questions

A customer with a pre-existing account opens a second account in 2026 and still has no US TIN. Does the relief reach the new account?

Notice 2024-78 excludes new accounts held by holders of pre-existing accounts, by reference to the agreement’s determination date. Regulation 7(8) of S.I. No. 292 of 2014 does let an institution treat a new account opened by an individual as pre-existing for due diligence, where it already holds a pre-existing account for that person and reports the aggregate balance. Paragraph 4.3 does not address how the two interact. My reading is that the Notice’s own exclusion governs the relief question, while the conditions, including the date of birth, annual request and placeholder code, apply to the new account regardless.

Does the institution have to check that a US TIN supplied by the customer is genuine?

Paragraph 4.3 says there is no requirement to verify that a US TIN provided is correct, and the institution is not held accountable where information supplied by an individual proves inaccurate. The format still has to pass the schema: Part 38-03-25 accepts nine digits with no separators, nine digits hyphenated after the third and fifth digits, nine digits hyphenated after the second digit, or a GIIN format.

How is the TIN field populated for a passive NFFE that is not a US entity but has a US controlling person?

Part 38-03-25 paragraph 7.13 requires a TIN element for both. The controlling person carries a validly formatted US TIN. The passive NFFE carries its foreign TIN with the issuing country in the issuedBy attribute, or, where none is available, the filer’s country code in issuedBy with “NA” as the value. Omitting either TIN element, or leaving it blank, produces a “TIN Not Populated” error even if the other field holds a US TIN.

Does an account classed as dormant under Irish rules automatically take code 777777777?

Paragraph 5.8 lets an Irish institution classify dormancy under its normal operating procedures, or failing those, where there has been no activity for three years, no contact from the holder for six years and no link to an active account. Code 777777777 refers to the US Treasury Regulations definition of a dormant account and gives way to any other applicable code. My reading is that the code needs its own test against the US definition, since the two definitions are worded differently. A dormant account that is reportable is still reported, contact or not.

An account holder renounces US citizenship part-way through the year. Is the account reported for that year?

Paragraph 12.1 asks the institution to verify the holder’s actual status and decides reportability by when that status is confirmed. Revenue’s example: a holder identified in July 2015 who documented renunciation in August 2015 was not reportable for the year ended 31 December 2015. In the opposite direction, a change indicating US status should be verified within 90 days, and an account holder who does not respond is treated as reportable until the status is established.

A fund is winding up. Can it delete its GIIN once trading stops?

Appendix 3 of Part 38-03-22 says an entity that ceases to be a financial institution should first make sure it has met all of its FATCA filing obligations, and only then de-register or delete its GIIN with the IRS.

Can balances be reported in euro?

Yes. Paragraph 4.9 allows the balance or value to be reported in US dollars or in the account’s currency. The dollar thresholds are converted using a published spot rate at 31 December of the reporting year, or on the date the closing balance is determined for an account closed during the year; Revenue lists Reuters, Bloomberg, the Central Bank of Ireland and the Financial Times as acceptable sources.

Related Articles

• FATCA Reporting in Luxembourg: how the Model 1 framework runs for Luxembourg reporting financial institutions, from registration to the annual return.
• CRS Reporting in Luxembourg: the residence-based Common Reporting Standard return that shares much of FATCA’s due diligence.
• BZSt CRS Reporting: The Schema v3.0 Switch: Germany’s move to the CRS XML schema v3.0 and the refile instructions in BZSt Newsletter 04/2026.
• CARF and DAC8 Crypto-Asset Reporting in Luxembourg: the crypto-asset reporting layer joining the EU automatic exchange framework.
• CARF Crypto Tax Reporting: the OECD Crypto-Asset Reporting Framework and what reporting crypto-asset service providers collect.

Key Takeaways

• Calendar 2026 data goes to Revenue on ROS by 30 June 2027; Revenue exchanges it with the IRS by 30 September 2027.
• For relief under Notice 2024-78, the reporting institution must meet the Notice’s conditions for each US reportable account, including new accounts, with a missing required US TIN. These include reporting the date of birth of relevant individuals, an accurate TIN code, city and country of residence in AddressFix, and a foreign TIN assigned by the person’s country of residence where held in electronically searchable account information. The Notice does not extend relief itself to new accounts.
• Annual TIN-request policies and evidence, including those kept for Notice 2023-11, now have a retention end date of 31 December 2031.
• Whether to transmit a PPSN the institution already holds is unresolved in paragraph 4.3; Revenue routes guidance questions through MyEnquiries under AEOI and FATCA.
• Threshold exclusions apply only if the Regulation 6(2) checkbox is ticked on the ROS upload screen on or before the return date.
• Part 38-03-25 paragraph 7.6 still describes only the 2022 to 2024 relief; the 2025 to 2027 conditions are in Part 38-03-22 paragraph 4.3.1.

Sources and References

• Revenue, eBrief No. 147/26, Guidance Notes on the Implementation of FATCA in Ireland (9 October 2026): https://www.revenue.ie/en/tax-professionals/ebrief/2026/no-1472026.aspx
• Revenue, Tax and Duty Manual Part 38-03-22, Guidance Notes on the Implementation of Foreign Account Tax Compliance Act (FATCA) in Ireland (October 2026): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-38/38-03-22.pdf
• Revenue, Tax and Duty Manual Part 38-03-25, Filing Guidelines for Foreign Account Tax Compliance Act (FATCA) (reviewed September 2026): https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-38/38-03-25.pdf
• Revenue, eBrief No. 267/24, AEOI – FATCA (1 November 2024): https://www.revenue.ie/en/tax-professionals/ebrief/2024/no-2672024.aspx
• Revenue, The Foreign Account Tax Compliance Act (FATCA): https://www.revenue.ie/en/companies-and-charities/international-tax/aeoi/fatca/how-to.aspx
• Revenue, CRS and DAC2: when and how information is exchanged: https://www.revenue.ie/en/companies-and-charities/international-tax/aeoi/fatca/when-how.aspx
• Revenue, Reporting Entity Registration Form: https://www.revenue.ie/en/companies-and-charities/documents/aeoi/reporting-entity-registration-form.pdf
• Agreement between the Government of Ireland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA (21 December 2012): https://www.revenue.ie/en/companies-and-charities/documents/aeoi/fatca-intergovernmental-agreement.pdf
• S.I. No. 292 of 2014, Financial Accounts Reporting (United States of America) Regulations 2014: https://www.revenue.ie/en/tax-professionals/legislation/statutory-instruments/2014/si-292-14.pdf
• S.I. No. 501 of 2015, Financial Accounts Reporting (United States of America) (Amendment) Regulations 2015: https://www.revenue.ie/en/tax-professionals/legislation/statutory-instruments/2015/si-501-15.pdf
• S.I. No. 245 of 2020, Financial Accounts Reporting (United States of America) (Amendment) Regulations 2020: https://www.irishstatutebook.ie/2020/en/si/0245.html
• S.I. No. 19 of 2018, Financial Accounts Reporting (United States of America) (Amendment) Regulations 2018: https://www.revenue.ie/en/tax-professionals/legislation/statutory-instruments/2018/si-019-18.pdf
• Revenue, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 38 (section 891E): https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part38.pdf
• IRS, Notice 2024-78, Extension of Temporary Relief for Foreign Financial Institutions to Report U.S. Taxpayer Identification Numbers: https://www.irs.gov/pub/irs-drop/n-24-78.pdf
• IRS, Internal Revenue Bulletin 2024-46 (12 November 2024): https://www.irs.gov/irb/2024-46_IRB
• IRS, Notice 2023-11, Foreign Financial Institution Temporary U.S. Taxpayer Identification Number Relief: https://www.irs.gov/pub/irs-drop/n-23-11.pdf
• IRS, Notice 2017-46, Revised Guidance Related to Obtaining and Reporting Taxpayer Identification Numbers and Dates of Birth by Financial Institutions: https://www.irs.gov/pub/irs-drop/n-17-46.pdf
• IRS, Frequently Asked Questions (FAQs) FATCA Compliance: Legal (Reporting Q3 and Q6): https://www.irs.gov/businesses/corporations/frequently-asked-questions-faqs-fatca-compliance-legal
• IRS, FATCA XML Schemas and Business Rules for Form 8966: https://www.irs.gov/businesses/corporations/fatca-xml-schemas-and-business-rules-for-form-8966

Building the 2026 file for 30 June 2027

The revised paragraph 4.3 turns into one working artifact: a register of every reportable account without a US TIN, showing whether it is pre-existing or new, the placeholder code applied, the date of birth, city and country of residence for AddressFix, any foreign TIN held electronically, and the date and channel of the year’s TIN request, with the request evidence kept until 31 December 2031. That register feeds the calendar 2026 return due on ROS by 30 June 2027, the first annual return that falls due after Revenue’s revision of paragraph 4.3.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.