Revenue recently published details of a new digital client/agent linking approval process, called e-linking, that will come into operation on 25 March 2025. The new process does not affect existing agent-links. It will apply when requesting to agent-link to a new client or to additional tax heads for existing clients of the following taxpayers:

• Taxpayers that have an active ROS digital certificate
  E-linking will replace the current paper-based Agent-Link Notification and the Transaction Advisory Notification Link.
• PAYE taxpayers who are registered for myAccount
  E-linking will replace the PAYE A1 Authorisation Form

While tax agents will initiate the agent-link request on ROS, the client must separately approve the agent-link via ROS (or myAccount) before the request will be processed by Revenue. Consequently, agents will no longer be able to create an agent-link for these taxpayers by uploading signed consent forms on ROS.

The current paper-based process will continue to apply to other taxpayers.

Revenue’s New Development

Revenue has designed a new Agent Link Manager Application which will be available in ROS (and in myAccount). On initiating an agent-link request in ROS, agents will be routed automatically to either the e-linking or the paper-based pathway depending on the online status of the taxpayer to which they are seeking to agent-link. Revenue’s Manual, Guidelines for Agents and Customers regarding the Agent e-linking Process includes information and screenshots so agents and taxpayers can become familiar with the e-linking process before its implementation on 25 March 2025.

Revenue notes that this development is intended to enhance digital security and improve transparency for both taxpayers and agents. It will also provide taxpayers with more control over access to their records.

Initially planned for release in November, the launch of e-linking was postponed following discussions at TALC about the release of a new process without engaging with the tax profession in advance of its design and practical concerns.

Institute Representations

The Institute has raised the well-known issues for taxpayers accessing ROS. Access is via a ROS certificate specific to a particular device, which is cumbersome and out-of-step with current applications available to consumers accessing sensitive personal data and transferring funds.

We expressed concerns about the potential impact of the new procedure on time-sensitive applications or returns, such as CG50 applications, preparation and filing of SARP 1A, filing Stamp Duty returns and sought an exemption for agent-links in respect of these items. In addition, we raised that the person with the authority to engage a tax agent may not access the ROS inbox, in particular in larger organisations. In our view, the new procedure appears less efficient than the current agent-link process and could result in delays if clients have limited familiarity with ROS; have forgotten their passwords or, do not check the email addresses linked to their ROS or myAccount profile. Furthermore, approval of the agent-link request online will not result in faster processing by Revenue to activate the link.

However, despite our concerns about the practicalities of this development, Revenue intends to proceed and will not agree to exclude any specific applications or returns from the e-linking process. If a taxpayer has an active ROS registration or is registered for myAccount, it will be their responsibility to accept or reject any agent-link request as per the process described in the Manual.

Revenue reiterated that digital security of taxpayer information to protect against identity theft and potential fraud is of paramount importance. Revenue accepts the new procedure is a significant departure from current practices for taxpayers and agents. However, the enhancement is consistent with Revenue’s increasing focus on encouraging e-enabled taxpayers to interact with Revenue online. According to Revenue figures, approximately 28,000 taxpayers had one or more agent-links created last year. 82% of these taxpayers accessed ROS multiple times after linking to an agent, which indicates to Revenue that taxpayers with agents have a level of familiarity with ROS. Revenue has also been monitoring the open rate for communications sent to the ROS inboxes of taxpayers.

We will monitor member feedback on the new process once implemented and continue to raise the need to modernise ROS to simplify compliance for taxpayers and agents.

Revenue Information for Tax Agents and Affected Taxpayers

A copy of the ROS inbox notification issuing to agents on the e-linking system is available. The notification includes a QR code for a webpage with further information for taxpayers on how to accept the agent-link requests through myAccount and ROS, together with contact details for the ROS Helpdesk. This information is included should agents wish to provide this letter to clients.

We requested that Revenue issue a communication to the ROS inboxes of impacted taxpayers, noting Revenue’s expectation that those with active ROS certificates engage with Revenue online. A similar approach could be adopted for myAccount users. Revenue could then draw the attention of taxpayers to the new agent-link procedures, provide tips on how to reset passwords, and provide Revenue contact information for the divisions and the ROS Helpdesk, as appropriate. We emphasised that it is not the role of the tax agent to troubleshoot issues taxpayers may experience in accessing or using Revenue’s systems. Revenue agreed to issue a communication to the ROS inboxes of taxpayers. We will update members once it is released. Revenue is also adding information on e-linking to the ROS login page.

We recommend that members review the Manual carefully and consider any updates that may be needed to their internal procedures to manage this revised process from 25 March. We outline below some clarifications from our discussions with Revenue to assist members with this process.

Client Approval of the Agent-link

As outlined in paragraph 2.1.1.4 of the Manual, the taxpayer will have 30 days to accept or reject the agent-link request. This was extended from 15 days at our request, to take account of annual leave or other periods of absence. If the link is not accepted or rejected within this 30-day period, the link will expire. It is possible to send a new agent-link request in the same manner, if required. The agent will be notified of updates to the status of link requests they initiate. There is also a dashboard to enable agents to monitor the status of all e-linking requests.

In the e-linking process, the linking request initiated by the agent will issue automatically to the taxpayer’s ROS inbox or to MyEnquiries in myAccount, as appropriate. Therefore, agents will be able to issue the link request and guide the client through its acceptance during a call/meeting when taking on a new client or discussing a transaction.

If the person who engaged the agent does not have access to the ROS inbox, the ROS Administrator will need to provide them with access or responsibility for accepting the agent-link would need to be delegated to a staff member in the business who has ROS access.

The Reference to an ‘active’ ROS Digital Certificate

Institute members will be familiar with the requirement to renew ROS digital certificates every two years or they expire. ROS cannot be accessed using an expired certificate. We asked Revenue about the meaning of an ‘active’ digital certificate and sought reassurance that taxpayers whose ROS certificate has expired would not have to download a new certificate simply to approve an agent-link request.

An active ROS digital certificate is a certificate that has not expired. Therefore, if a taxpayer’s ROS certificate has expired (and has not been renewed) when the agent-link request is initiated, the agent-link process will default to the paper-based process. For example, if a taxpayer registered for ROS many years ago out of curiosity but has not accessed ROS since, the paper-based agent-link process would apply.

myAccount Access

Access to myAccount is not reliant on a digital certificate that expires. Consequently, if a taxpayer only accessed myAccount once to register their first job in Ireland their myAccount profile remains active. Therefore, the e-linking process will apply to the approval of any new agent-link going forward.

Help on Resetting Passwords

Revenue amended the ‘ROS login reset process’ in 2024 to assist taxpayers who forget their passwords or cannot locate their ROS certificates. Information is available on the ROS login page.

The information to have at hand to reset a MyAccount password is available on Revenue’s website.

Contacting Revenue in Urgent Cases

It will not be possible to file a return on a ‘pending’ agent-link that has not been approved (and processed). In exceptional circumstances, if a deadline is imminent Revenue can be contacted to review the case and determine how best to support the taxpayer/agent.

For example, if contacted by a taxpayer who is having difficulty approving the agent-link request online, Revenue may ask a number of security questions to verify the taxpayer’s identify and activate the link prior to its processing. We have raised the difficulties in reaching Revenue on urgent matters, in particular, when contacting divisions that deal with high volumes of calls and contacts.

Revenue advises that tax practitioners can contact the divisional Exceptional Contacts in the scenario where a return needs to be filed urgently and they are unable to make contact via the normal channels.

eCG50

We queried specifically how to address difficulties when implementing the agent-link for CG50 applications given the potential impact on transactions. Revenue notes that it understands when urgent applications need to be processed due to unforeseen circumstances. Those vendors and purchasers and their representatives can contact Revenue to highlight the urgency. Revenue endeavours to prioritise CG50 requests when it receives these contacts. As above, the Exceptional Contacts can be contacted in urgent cases where practitioners have been unable to make contact with Revenue via normal channels.

Revenue notes that its data indicates that the average period an agent was linked to a client prior to submitting an eCG50 application is four years.