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Memorandum of Understanding between the Central Statistics Office and the Office of the Revenue Commissioners

This Memorandum of Understanding is made on the 16th day of October 2025 between the Central Statistics Office, Skehard Road, Cork, T12 X00E and the Office of the Revenue Commissioners, Dublin Castle, Dublin 2

List of abbreviations
CSO Central Statistics Office
MoU Memorandum of Understanding
JLG                 Joint Liaison Group
NDI              National Data Infrastructure  
RMF              Research Microdata File

 

Definitions of Terms

 “Act” 

The Statistics Act, 1993 as may be amended from time to time.

“Breach”  

 A ‘personal data breach’, as defined by Article 4(12) of the General Data Protection Regulation (GDPR).

“Controller”  

 Has the meaning assigned by Article 4(7) of the GDPR.

“Data” 

Information transferred to the CSO.

“Non-personal Data

Has the meaning assigned by Article 3(1) of Regulation 2018/1807 on a framework for the free flow of non-personal data in the European Union.

“Personal Data”

Has the meaning assigned by Article 4(1) of the GDPR.

“Processing”

Has the meaning assigned by Article 4(2) of the GDPR.

“Parties”

The CSO and Revenue.

“Purpose”   

The collection, compilation, extraction, and dissemination for statistical purposes of information concerning tax and customs administration.

“Revenue” 

Revenue Commissioners.

“Section 851(A)”    

Section 851(A) of the Taxes Consolidation Tax 1997.

 “SPAR Report”  

The CSO report entitled ‘Statistical Potential of Administrative Records - An Examination of Data Holdings in the Office of the Revenue Commissioners.

Establishment of the Parties

The Central Statistics Office was established in 1949 and became a statutory body in 1994, under the Statistics Act, 1993 (the ‘Act’).

The Office of the Revenue Commissioners was established by Government Order 2/23 on 21 February 1923.

The Role of the Parties

Central Statistics Office (CSO)

The functions of the CSO are set out in the Act. In particular, Section 10 states that the functions of the Office are the collection, compilation, extraction and dissemination for statistical purposes of information relating to economic, social and general activities and conditions in the State. The Office has the authority to co-ordinate official statistics compiled by public authorities to ensure, in particular, adherence to statistical standards and the use of appropriate classifications and has the authority to assess the statistical potential of the records maintained by public authorities and to ensure that the potential is realised. Furthermore, the CSO has legal obligations regarding the development, production and dissemination of European statistics under Regulation 223/2009.

Office of the Revenue Commissioners

Revenue is the Irish Tax and Customs Administration. It is responsible for the administration, assessment and collection of taxes and duties and the implementation of customs law.  Its mission is “to serve the community by fairly and efficiently collecting taxes and duties and implementing Customs controls”. Revenue recognises that its data holdings are a valuable asset and is committed to playing an important role in the development of Ireland’s National Data Infrastructure (NDI) and supporting other initiatives to further the strategic use of public sector data where appropriate.

Context and Background

Revenue and the CSO have a longstanding history of collaboration. Revenue collects a wide range of data from the administration of taxes and duties for which it has responsibility. The data are required for a number of reasons, namely, the calculation of tax liability and/or repayment, fulfilment of statutory obligations, and to support risk analysis.

The Act provides for the collection, compilation, extraction, and dissemination of official statistics. In particular, Section 10(3) provides that the CSO “shall have authority to assess the statistical potential of the records maintained by public authorities and, in conjunction with them, to ensure that this potential is realised”, while Section 30(1)(a) provides that the Office’s Director General:

 “may by delivery of a notice request any public authority to allow officers of statistics at all reasonable times to have access to, inspect and take copies of or extracts from any records in its charge, and provide the Office, if any such officer so requires, with copies or extracts from any such record, and the public authority shall […] comply with any such request free of charge.”

Recognising a growing need to maximise the use of administrative data for statistical purposes to reduce the overall administrative burden on businesses and to generate enhanced statistical outputs in support of evidence-based policy making, a report entitled ‘Statistical Potential of Administrative Records - An Examination of Data Holdings in the Office of the Revenue Commissioners’ (the ‘SPAR Report’) was published by the CSO in February 2009. This report contained recommendations as to how the potential of taxation, duty, and trade data collected by Revenue could be maximised for statistical purposes by the CSO.

To build on the SPAR report, and to strengthen the relationship between the Parties, a Memorandum of Understanding (MoU) was adopted in July 2009. The existence of an MoU has enabled the CSO to realign its processes to ensure a more systematic use, for statistical purposes, of administrative data transferred by Revenue. The MoU has also facilitated the implementation of key SPAR and NDI developments.

The MoU has contributed to enhanced statistical outputs by the CSO and to Revenue’s playing its part in the reduction of the administrative burden on individuals and businesses arising from CSO surveys. Beyond the transference of data to the CSO, which is the focus of this MoU, the Parties actively collaborate across important areas, such as the accreditation of Official Statistics produced by Revenue and secondment of Statisticians from CSO to Revenue.

Purpose of the Memorandum of Understanding

The purpose of this MoU is to clarify the roles and responsibilities of, as well as the areas of cooperation between, the Parties with regard to Revenue’s transference of data to the CSO.  The agreement will contribute to enhanced statistical outputs by the CSO and to a reduction in the response burdens arising from CSO surveys.

This agreement is a MoU and is not intended to create binding or legal obligations on either Party. The MoU is entered into on the understanding that it is subordinate to the relevant legislation governing each Party.

This MoU also sets out a shared understanding of the Parties in relation to data protection issues that may arise and roles relating to the compilation, transfer and use of this data.  The processing of personal data of data subjects is governed by the Act, the Data Protection Act, 2018, and the General Data Protection Regulation (GDPR).

Responsibilities of each Party

Personal Data

Revenue is the controller for the data it collects in the first instance. When the data is transferred to the CSO, the CSO will become the controller. It follows then that it is the responsibility of the CSO to report any personal data breach (a ‘Breach’) relating to the data it holds.

In the event of a breach relating to data held by the CSO, the CSO will inform the Data Protection Officer of Revenue and the Joint Liaison Group (JLG). Two nominated members of the JLG, one from each party, will be the point of contact for an out-of-hours/non-working day breach. These two members will share relevant contact details with one another once nominated to be used in such a scenario. This notification will be made within 24 hours of awareness. In addition, the CSO will refer to their own data breach procedures and may report the breach to the Data Protection Commission as appropriate. CSO shall be responsible for any loss, damage or injury caused as a result of such a breach. 

In the event of a breach relating to data the CSO will inform Revenue through the JLG, in advance, of any decision to issue a public statement in relation to the breach. Similarly, Revenue will inform the CSO through the JLG, in advance, of any decision to issue a public statement in relation to the breach.  

Non-personal Data

In the event of a disclosure relating to Non-personal Data, as defined by Regulation 2018/1807 on a framework for the free flow of non-personal data in the EU, the CSO will inform Revenue through the Joint Liaison Group (JLG). Two nominated members of the JLG, one from each party, will be the point of contact for an out-of-hours / non-working day disclosure. These two members will share relevant contact details with one another once nominated to be used in such a scenario. This notification will be made within 24 hours of awareness. The CSO will inform Revenue through the JLG, in advance, of any decision to issue a public statement in relation to the disclosure. Similarly, Revenue will inform the CSO through the JLG, in advance, of any decision to issue a public statement in relation to the disclosure.  

Legal Basis

Transfer and processing of the data shall be done in accordance with the Act, the Data Protection Act 2018, the GDPR, the Official Secrets Act, 1963, EU law and in accordance with the CSO’s Code of Practice, in particular its protocol on data matching where one or more datasets originate from outside of the CSO.

 The transfer and processing of the data is covered by, inter alia, the following provisions:

  • Section 10 of the Act, concerning the functions of the CSO;
  • Section 13 of the Act, concerning the statistical independence of the Director General of the CSO;
  • Sections 30 and 31 of the Act, concerning the use of the records of public authorities for statistical purposes;
  • Sections 32 and 33 of the Act, concerning the protection of information;
  • Section 851A(2) of the Taxes Consolidation Act, 1997, concerning Revenue’s disclosure of taxpayer information in accordance with statutory provisions;
  • Article 6(1)(c) of the GDPR;
  • Article 6(1)(e) of the GDPR concerning processing necessary for the exercise of official authority;
  • Article 9(2)(j) of the GDPR, concerning processing necessary for statistical purposes;
  • Article 89 of the GDPR concerning safeguards and derogations relating to processing for statistical purposes, and;
  • Section 42 of the Data Protection Act, 2018, concerning processing for statistical purposes.

Data transfer, Security and Data storage

A complete transmission timetable, including transfer methods will be agreed between the Parties. Changes to the transmission timetable and methods will be discussed and agreed at the JLG.

Data will be retained, securely stored, and processed by the CSO in accordance with CSO Policies.

Revenue will provide the CSO with the data in an agreed format. 

Agreement

General

A number of data files are currently provided by Revenue to the CSO.[1] Revenue shall continue to provide data to the CSO for statistical purposes in accordance with the legislation detailed above at 8. A list of these files, with delivery frequency, is in the Data Exchange Agreement. Revenue acknowledges the requirement by the CSO to continue to receive these files and undertakes to provide these data at the required frequency.  The Parties agree that this list of data files shall be periodically reviewed, and amendments thereto shall be made with the consent of the Liaison Officers detailed below at 10.3.

The CSO shall use the data provided by Revenue for statistical purposes only, in accordance with the legislation detailed above at 8.

The CSO shall ensure that all linking of Revenue data with other data sources, both CSO and non-CSO, will be carried out in accordance with the CSO Data Matching Policy[2].

Revenue acknowledges a stakeholder role for the CSO in those Revenue data holdings required as inputs into statistical processing. At the same time, the CSO acknowledges that the primary purpose of Revenue data is for tax and duty collection purposes.

Should Revenue propose to make significant changes to any system for the storage and retrieval of information or to make a statistical survey that could affect the CSO’s ability to carry out its mandate, it shall consult with the CSO as early as possible via the JLG.

As part of its mandate, the CSO serves the specialist needs of business and the research and academic community for detailed and focused data.  Research Microdata Files (RMFs) are the means through which the CSO grants access to anonymised business microdata. RMFs are made available to persons authorised to access such files under the Act, subject to strict criteria.

Subject to resource availability in the respective Offices, the Parties will work collaboratively to ensure that access to anonymised tax and duty data through the strictly controlled RMF process is maximised. This approach supports the integrity and confidentiality of taxpayer data provided to the CSO under the Act. It also enhances opportunities to maximise the value and utility of data to support evidence-based policymaking, reduce the cost of research and avoid duplicate data collections.

In certain circumstances, requests for access to Revenue-sourced data through the RMF process will be made to the CSO. The CSO will consult with Revenue’s Liaison Officer on all such requests. Revenue will also be consulted for their views on the outputs produced in advance of publication.  Whenever the CSO intends to publish new statistics where Revenue-sourced data is a primary input, the CSO will advise Revenue’s Liaison Officer in advance of publication.

[1] In this agreement, “file” and “data file” shall be understood to mean any collection of data or information held at unit, tax entity, or record level.

[2]CSO, ‘CSO Data Matching Policy’ (cso.ie, 7 August 2025) <https://www.cso.ie/en/aboutus/lgdp/csodatapolicies/csodatamatchingpolicy/> accessed 16 October 2025

Joint Liaison Group

The CSO-Revenue Joint Liaison Group shall be the formal, high-level mechanism for consultation and communication between both Offices.

It shall be the responsibility of the JLG to consider all data matters and related issues of mutual interest.

The two Offices shall maintain a delivery schedule of data files currently provided by Revenue to the CSO. The data files in the delivery schedule and any amendments to that list are being requested by the CSO under Section 30 of the Act. This MoU serves as a notice request for the purposes of that section of the Act. Changes to this list, and the composition of the data files thereon, shall be agreed between the Liaison Officers detailed below at 10.3.

Revenue shall inform the CSO as early as possible of any proposed changes in availability/scope of Revenue data which could potentially impact on the CSO in carrying out its mandate. Any proposed changes shall be discussed by the JLG.

Revenue will brief the CSO on changes arising from Finance Acts or other legislation, where they consider it likely that such changes will significantly affect CSO operations, so that any potential impact on the CSO in carrying out its mandate using Revenue data can be reviewed.

The JLG shall address matters of data protection, in accordance with the Act and the relevant data protection legislation, and regularly review the security of data transfer between both Organisations and the related storage mechanisms. Responsibility for approving data transfer mechanisms between both Organisations shall rest with the JLG.

The JLG shall appoint, as required, ad hoc working groups to progress issues arising; such working groups shall report to the JLG.

The JLG shall meet on at least two occasions each year and shall be chaired alternately by the Parties at Assistant Secretary/Assistant Director General level.

Liaison Officers

The CSO shall appoint a Liaison Officer as the main point of contact with Revenue; this role shall encompass a Data Custodian function, with responsibility for the management and use of Revenue data by the CSO. Revenue shall likewise appoint a Liaison Officer as the main point of contact with the CSO.

All current data transfers between the two Organisations are considered authorised by the CSO/Revenue Liaison Officers and approved by the JLG and shall continue to take place between the relevant areas of Revenue and the CSO Liaison Officer or a nominated deputy of the CSO Liaison Officer, except in a very limited number of cases, such as External Trade data, where the data transfers shall continue to take place on the pre-existing basis between Revenue’s VIMA Trade Statistics Unit and the CSO’s Trade Division in accordance with long-established practice.

All new requests for data transfer and amendments to existing data transfers between the two Organisations shall be submitted through, and considered by, the Liaison Officers. Any recommendations by the Liaison Officers for changes to the data to be provided shall take into account the relevant resource implications and shall be subject to sign off of the updated Annex A in the Data Exchange Agreement by the chairs of JLG from Revenue and the CSO. When authorised by the JLG, the data transfer shall take place between the relevant area of Revenue and the CSO Liaison Officer, or a nominated deputy of the CSO Liaison Officer. The delivery schedule of data files provided to the CSO shall be updated by the Liaison Officers.

For exceptional transfers of data subject to critical timelines, the Liaison Officers will coordinate to ensure JLG chairs authorise the necessary transfer.

Data Protection

The Parties shall maintain the appropriate infrastructure to ensure the secure transfer of data between the two Organisations. In particular, data will be sent via the secure methods set out in the Data Exchange Agreement.

The CSO undertakes that all data received from Revenue shall be treated as strictly confidential and shall be used for statistical purposes only, in accordance with national and EU statistical law, and also in conformity with the relevant data protection legislation.  In particular, treatment of data shall be subject to the CSO’s Code of Practice on Statistical Confidentiality.[1]

The CSO shall maintain the appropriate infrastructure to ensure the secure storage of, and controlled access to, all data received from Revenue.

Revenue shall maintain the appropriate infrastructure to ensure the secure storage of, and controlled access to, all data required by the CSO.

[1] CSO, ‘Code of Practice’ (cso.ie, 5 January 2018) <https://www.cso.ie/en/aboutus/lgdp/csodatapolicies/statisticalconfidentiality/codeofpractice/> accessed 16 October 2025

Statistical quality

Data files shall be accompanied by the relevant metadata, where available.

The Parties agree to cooperate in examining the quality and appropriateness of Revenue data for statistical purposes. Recommendations towards improvement in the statistical quality of Revenue data will be considered by the JLG and implemented where feasible. 

Revenue requirements

The CSO acknowledges that Revenue has statistical requirements, and agrees, where feasible and in line with the Statistics Act, 1993, to try to meet these requirements by providing statistical analyses of CSO data and other administrative data holdings in the form of nonconfidential, aggregate-level data.

Duration and Review

This MoU will be published on the Parties’ websites.

This MoU will remain in force until a new one is entered into or until it is revoked. Depending on events, this MoU may be amended, subject to the mutual agreement of the Parties.

This MoU will be reviewed biennially by the Parties. Any changes to the MoU shall only be made with the mutual agreement of the Parties.

Signed:

Central Statistics Office
Jennifer Banim, Director General
Date: 17/10/2025

Signed:

Office of the Revenue Commissioners

Niall Cody, Chairman

Date: 23/02/2026