Tax returns
Enhanced Compliance Engagement: Revenue's pilot for high-wealth individuals
Last updated 16 October 2026
A voluntary Revenue pilot to the end of 2027 lets individuals worth €20 million or more have returns reviewed and big transactions checked in advance.
Enhanced Compliance Engagement (ECE) is a framework Revenue launched in 2026 for its wealthiest individual taxpayers. It is like the co-operative compliance framework Revenue runs for large companies. It aims to build a relationship based on trust and co-operation. The goal is the highest level of voluntary compliance and more certainty for the taxpayer.
Who it is for
High-wealth individuals whose tax affairs are managed by Revenue's High Wealth and Financial Services Division. Revenue defines a high-wealth individual as someone with estimated wealth (assets less debts) of €20 million or more. It runs as a pilot from the second quarter of 2026 until 31 December 2027, after which Revenue will review it.
The two parts
- Tax pack compliance review: after filing the annual return, the taxpayer can send Revenue the computations and supporting papers behind it for review. This suits years with something unusual in them. It is treated as a Level 1 compliance intervention, which means the taxpayer can still make an unprompted qualifying disclosure.
- Opinions on significant transactions: the taxpayer can talk to Revenue about the tax treatment of a significant transaction. This can be before the transaction, or before filing the return that includes it.
Is it compulsory?
No. Taking part is voluntary, needs no formal agreement, and can start at any stage during the pilot. A taxpayer can use the review for one year without committing to others. Taxpayers who qualify receive a letter offering participation, with contact details for a branch manager and a dedicated case manager.
What each side commits to
- the taxpayer: true and correct information, reasonable co-operation, and meeting agreed timelines
- Revenue: recognising that participation is voluntary, timely and courteous engagement, a presumption of honesty, and openness to meet
The benefits Revenue describes
- more certainty, and a lower chance of later enquiries, audits and compliance interventions
- less exposure to interest, because issues are dealt with early
- a dedicated case manager
Communication runs through secure channels: MyEnquiries in ROS, Revenue's secure file transfer service, or encrypted email. For how disclosures and penalties work more generally, see the tax defaulters list.
Work it out
Sources
- Revenue: Pay and file system: how does it work? (checked 25/10/2026)
General information, not tax advice. HeyPenny is not a tax agent.