Revenue Contractor Compliance in Ireland: What the Settlement Window Means, and How Businesses Can Protect Themselves in 2026

In late 2025, the Irish Revenue Commissioners announced a time-limited settlement opportunity for contractor misclassification, allowing businesses to correct genuine classification errors for the 2024 and 2025 tax years before the window closes on 30 January 2026. (Crowe, 2025)

This announcement followed the landmark Supreme Court decision in Revenue Commissioners v Karshan (Midlands) Ltd t/a Domino’s Pizza, which clarified how employment status should be assessed for tax purposes in Ireland.

For businesses that rely on contractors or freelancers such as delivery drivers, this is not just a legal update. It is a practical moment to review how workers are engaged, managed, tracked & paid in reality, and to decide how compliance should be handled going into 2026 and beyond.

What Is the Revenue Contractor Misclassification Settlement Window?

Revenue’s settlement window provides businesses with an opportunity to make a voluntary disclosure where workers may have been incorrectly classified as contractors rather than employees, without penalties, interest, or publication, provided the misclassification arose from a bona-fide error and disclosure is made before 30 January 2026.

Revenue has acknowledged that many businesses relied on earlier guidance in good faith, and that the Karshan judgment materially changed how employment status must be assessed. The settlement window exists to allow businesses to regularise their position under this updated framework.

However, the settlement applies only to past periods (2024–2025). The expectations around compliance, documentation, and evidence apply fully going forward.

The Key Principle Revenue Applies: Substance Over Contract Wording

A central takeaway from the Karshan / Domino’s decision, and from Revenue’s subsequent guidance is that:

|The reality of the working relationship matters more than the existence or content of any contract.

In practice, the level of control exercised by the business is often the primary driver when determining worker classification. Revenue and the courts look closely at who controls how, when, and where the work is carried out, regardless of how the relationship is described on paper.

That assessment is then reinforced by other key factors, including:

• How the work is actually performed in practice
  
  
• Whether personal service is required, or genuine substitution exists
  
  
• How integrated the worker is into the business

In the Domino’s case, delivery drivers were classified as employees for tax purposes because the factual working arrangements pointed toward employment, regardless of contractual labels.

This principle underpins Revenue’s current approach to contractor compliance.

The Five-Point Criteria & The Decision Tree Used to Determine Employment Status

Revenue and the courts apply the five-point criteria, as outlined in recent governmental guidance following the Karshan decision. (Revenue, 2025)

1. Does the contract involve the exchange of wage or other remuneration for work?
2. If so, is the agreement one where the worker is agreeing to provide their own services, and not those of a third party, to the employer?
3. If so, does the employer exercise sufficient control over the supposed employee to render the agreement one that is capable of being an employment agreement?
4. If requirements 1-3 are met, the decision maker must then determine whether the terms of the contract between employer and worker and the reality of the working arrangements are consistent with a contract of employment, or whether they point to some other form of contract.
5. Finally, it should be determined whether there is anything in the particular legislative regime under consideration that requires the court to adjust or supplement any of the foregoing.

This framework reinforces that employment status is determined by how the relationship operates in practice, not by labels or intent alone.

And the decision tree below summarises the framework set out in governmental guidance and Supreme Court case law. While not a substitute for professional advice, it illustrates the logic Revenue applies when assessing employment status.

For businesses, the implication is clear:
you must be able to evidence how work is performed, tracked, and paid.

Why Contractor Compliance Becomes Difficult Over Time

Contractor misclassification rarely arises from deliberate action. More often, it develops gradually as businesses grow and operations evolve.

Common challenges include:

• Shifts tracked across multiple systems
  
  
• Payments processed separately from attendance records
  
  
• Inconsistent treatment across teams or locations
  
  
• Manual processes that make evidence hard to assemble later
  
  

Individually, these processes may function well. Collectively, they can make it difficult to demonstrate compliance when required.

A Smarter 2026 Strategy: Compliance from Day One

While the Revenue settlement window closes on 30 January 2026, the underlying compliance expectations do not.

Many businesses are using this period to adopt a smarter strategy putting systems in place so that evidence Revenue expects is created automatically as part of daily operations.

In practical terms, this means:

• Digital shift and attendance tracking
  
  
• Clear links between work performed and payments made
  
  
• Consistent records across contractors and in-house teams
  
  
• Centralised reporting that is audit-ready by default
  
  

This is where Gigable CMS (Contractor Management Software) supports businesses operationally with compliance built in from day one.

Gigable does not provide legal or tax advice. Instead, it helps businesses operate compliantly in practice by:

• Keeping compliance in place with audit-ready records generated automatically
  
  
• Hiring and managing contractors through a single platform
  
  
• Automatically tracking shifts, attendance, and on-site location
  
  
• Generating clear, digital payroll and payment records
  
  
• Managing contractors and in-house teams together using the Team feature consistently across sites
  
  

By embedding compliance into everyday operations rather than a separate task, businesses reduce risk, avoid disruption, and enter 2026 with greater confidence.

If you’re looking for a calmer, more joined-up way to manage contractors in 2026, you can explore how Gigable CMS works here.

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