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Start-up Refunds for Entrepreneurs (SURE): the 2026 guide for Irish founders
Income TaxTax PlanningStartup & Small Business

Start-up Refunds for Entrepreneurs (SURE): 2026 Guide

Aonghus SamminPublished 13 October 20267 min read
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Start-up Refunds for Entrepreneurs (SURE) is Ireland's premier non-dilutive funding mechanism for founders. It is not a grant — it is the strategic monetisation of PAYE you have already paid. Invest your own capital in a new company and Revenue refunds the income tax on it, with a ceiling of up to €140,000 a year and €980,000 across the seven-year retrospective window.

  • Maximum capital recovery: a cash refund of up to 41% of the capital you personally invest, with a technical ceiling of 50% for certain pre-market ventures.
  • Investment thresholds: the annual individual investment limit is €140,000, and the cumulative reclaim can reach €980,000.
  • Seven-year window: the deduction can be set against the year of investment and the six preceding years of assessment.
  • The 15% equity rule: you must hold at least 15% of the issued share capital and commit to the venture full-time for 12 months.
  • The four-year hold: shares must be held for at least four years to avoid a clawback of the relief.

Why founders are using SURE in 2026

The 2026 fiscal landscape is the most founder-friendly in a decade, largely because of the structural enhancements codified in the Finance Act 2024. Raising the annual individual investment limit to €140,000 accommodates the rising cost of entry for capital-intensive start-ups, and the restoration of the 35% relief rate for follow-on funding corrects previous restrictive interpretations for companies still within seven years of their first commercial sale. Personal tax changes — including the expansion of the 2% USC band to €28,700 — compound the effect.

Together, these thresholds offer a superior risk-finance multiplier. They make the current window the optimum time to execute a "capital flip": converting past tax liabilities into current liquid assets, so you can launch without the immediate pressure of external equity dilution.

Am I eligible? Decoding the "specified individual" criteria

Revenue applies rigorous compliance tests to ensure SURE is reserved for active, dedicated founders. Qualification as a "specified individual" rests on three pillars.

What historical income profile is required?

Your income history must be dominated by employment: you must have had mainly PAYE income in each of the three years of assessment prior to the year immediately preceding the year of investment. Non-employment income is permitted within strict statutory limits. The rule ensures the relief supports people moving out of salaried employment rather than individuals with existing diversified investment portfolios. A spell of unemployment does not disqualify you — the scheme allows founders who have been out of work for up to two years to qualify.

What are the full-time commitment rules?

SURE demands an executive commitment. You must take up full-time employment as a director or employee of the new company for at least 12 months. During that first year you cannot work more than 10 hours a week in any outside employment — a non-negotiable test of your primary professional focus.

What ownership constraints must I follow?

You must acquire and maintain at least 15% of the issued share capital of the new company. You also cannot hold more than 15% of the share capital or voting power in any other active company during the 12 months before you invest. That closes the "serial director" loophole and keeps the relief tied to genuine new venture creation.

Does my start-up qualify? Defining the "qualifying new venture"

Individual eligibility is moot if the company itself is not a "qualifying new venture". It must commence entirely new commercial operations: it cannot be a successor to a previous trade, and turning an existing sole trade into a limited company does not qualify.

SURE eligibility: sector analysis

Activities that qualifyActivities excluded
Commercial manufacturing and distributionFinancial and lending activities
Tourist traffic undertakingsProvision of professional services
Rendering of commercial services to parentsOccupation of woodlands
Purchase and sale of goods produced by the companyFilm production
Small and medium enterprises (SMEs)Real estate rental and holding companies

The venture must also trade at arm's length: any transactions with a founder's former employer have to be on strictly commercial terms. Under Section 490 the company must not be under the control of any other company, which keeps the relief with independent, standalone ventures.

How your SURE refund is calculated

The value of the refund is dictated by the interaction between your investment amount, the risk classification of the venture and your historical marginal tax rate.

The "mop-up" strategy: the seven-year reclaim election

The most important strategic decision is when the shares are issued. Because a single investment can be set against the current year and the six preceding years, you can time the subscription to "mop up" income that was taxed at the 40% rate. Set the deduction against years in which income fell into the 20% band and the value of the refund is effectively halved. A founder who invests the maximum €980,000 across the seven-year window can theoretically recover more than €340,000 in cash, provided there is enough high-rate income in the relevant years.

Item2026 position
Annual individual investment limit€140,000
Cumulative reclaim across the seven-year windowUp to €980,000
Benchmark refundUp to 41% of capital invested (50% for pre-market ventures)
Minimum shareholding15% of issued share capital
Minimum holding periodFour years, to avoid clawback under Section 496

The compliance roadmap: filing, forms and the proprietary director trap

The proprietary director classification

By taking 15% or more of the company you become a proprietary director, which is a permanent change to your tax profile: you must file a Form 11 self-assessment every year, whether or not you have non-PAYE income. Missing the 31 October deadline triggers an immediate surcharge of 5% to 10% on your total tax liability, which can erode much of the value of the refund you are claiming.

Administrative workflow

  1. Form RICT: the company files this electronically through ROS to declare the investment.
  2. Statement of Qualification: once the filing is processed, the company issues this document to the founder.
  3. The reclaim: the founder claims the relief through Form 11 or the MyEnquiries portal.

Strategic pivot: scaling beyond the initial refund

SURE is the foundation of a wider 2026 scaling strategy. It works best when integrated with the other high-value incentives available to Irish founders:

  • Revised Entrepreneur Relief: a €1.5 million lifetime cap on gains taxed at the reduced 10% rate.
  • R&D Tax Credit: the 35% rate, with an enhanced first-year refund threshold of €87,500.
  • Section 486C relief: a corporation tax exemption for qualifying start-ups, based on the Class S PRSI paid by working directors, capped at €1,000 per director and €40,000 overall.

Documentation holds these claims together. Keep the business plan, share certificates, bank statements and the auditor's report for six years, in a paperless system that can produce them on request.

The Bradán way: your four-step SURE action plan

  1. Eligibility audit: a deep-dive into your three-year PAYE history to verify "specified individual" status.
  2. Investment structuring: time the share subscription to maximise recovery at the 40% rate across the seven-year window.
  3. Corporate compliance: file Form RICT and issue the Statement of Qualification promptly.
  4. Personal reclaim: integrate the claim into your self-assessment cycle, keeping preliminary tax and Form 11 obligations on track.

Deadlines and milestones checklist

  • 31 October: income tax return (Form 11) deadline for proprietary directors.
  • 12-month mark: the end of the mandatory full-time employment and outside-work restriction period.
  • Four-year anniversary: the minimum holding period that avoids clawback of the relief.
  • Six-year retention: the statutory period for keeping records available for Revenue inspection.

Ireland's two SURE schemes: don't confuse them

There are two different Irish reliefs called SURE. Start Your Own Business (SURE) relief is for people who have been unemployed for 12 months or more: it exempts up to €40,000 of profits from income tax for two years. This guide covers the other one, Start-up Refunds for Entrepreneurs, which refunds the PAYE paid by high-earning professionals on capital they personally invest in a new company. If the first of those schemes describes your situation, read our separate article on the Start Your Own Business (SURE) relief — the acronyms match, but the legislation, the beneficiary and the mechanic are entirely different.

Frequently asked questions

Can I claim SURE if I was unemployed?

Yes. The scheme allows individuals who have been out of work for up to two years to qualify, so it operates as an active labour market measure as well as a founder incentive.

What is the maximum SURE investment for 2026?

The annual individual investment limit is €140,000. Using the seven-year election, a founder can reclaim tax on a cumulative investment of up to €980,000.

Does a sole trader transitioning to a limited company qualify for SURE?

No. The legislation is explicit that a qualifying venture cannot be the incorporation of an existing sole trade; it must be an entirely new commercial operation.

How long must I hold SURE shares?

At least four years from the date of issue. Disposing of them earlier can trigger a clawback of the relief under Section 496.

Can I convert a director's loan into a SURE refund?

Yes, but only if a comprehensive written business plan was in place before the loan was issued and the conversion is supported by an auditor's report. The safeguard prevents retroactive tax engineering of informal debts.

Navigating the technical architecture of Irish tax law takes a partner who understands both the ledger and the legislation. Bradán Accountants advises founders on SURE from the eligibility audit through to Form RICT and the personal reclaim — and on the structure that protects the refund when the company scales.

Sources

  • Revenue.ie – Start-up Refunds for Entrepreneurs (SURE)
  • Revenue.ie – Form RICT and Statement of Qualification
  • Taxes Consolidation Act 1997 – Part 16, Sections 488 to 498
  • Finance Act 2024 – annual investment limits and follow-on funding
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Written by

Aonghus Sammin

Bradán Accountants

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