Section 487A — the Irish unscripted tax credit

Section 487A of the Taxes Consolidation Act 1997 (as inserted) provides corporation tax relief for producers of qualifying unscripted programmes. Operationalised by the Unscripted Production Regulations 2025 (S.I. No. 671 of 2025), commenced 23 December 2025. Cultural certification is administered by the Department of Culture, Communications and Sport (DCCS); tax processing is by the Office of the Revenue Commissioners (Revenue); skills development is administered jointly between DCCS (below €1.5m eligible spend) and Screen Ireland (above €1.5m eligible spend).

What you can claim

The relief is given at 20% of the lowest of:

a) Eligible expenditure
b) 80% of the total cost of production of the unscripted programme
c) €15,000,000

Claimed against the producer company's corporation tax liabilities.

Minimum thresholds

A project must meet two minimums to qualify:

On-screen services are excluded from qualifying expenditure (per DCCS S487A Guidance Notes, December 2025).

Producer Company test

The producer company must:

• Be resident in the State, or in an EEA State other than the State and carry on business in the State through a branch or agency
• Carry on a trade of producing unscripted programmes on a commercial basis with a view to the realisation of profit
• Make the unscripted programmes for exhibition to the public by means of broadcast
• Not be a broadcaster, or a company whose business consists wholly or mainly of transmitting unscripted programmes on the internet, nor be connected to one
• Not be part of an undertaking which would be regarded as in difficulty within the meaning of the EU Rescuing and Restructuring Guidelines as defined in Section 487A

(No requirement for a separate DAC — distinct from Section 481 — the Irish scripted tax credit.)

Categories of unscripted programmes — eligible (Reg 5)

Per S.I. 671/2025 Regulation 5, eight eligible categories:

1. Observational documentaries
2. Docuseries
3. Factual entertainment
4. Factual programming
5. Lifestyle programming
6. Quiz, contest and game shows
7. Studio and panel shows
8. Reality programming

Categories NOT eligible (Reg 6)

Per S.I. 671/2025 Regulation 6:

1. Any category of film eligible for certification as a qualifying film under section 481 (statutory mutual exclusion — see Section 481 vs Section 487A — picking the right credit)
2. Unscripted programmes comprising, or substantially based on, live programming (including programming pre-recorded and broadcast or transmitted on the internet as live)
3. Unscripted programmes comprising or substantially based on: - News - Current affairs programming - Talk show formats involving one or more hosts - Sports programming (other than documentaries) - Concerts, galas or awards shows
4. Unscripted programmes (other than documentaries) consisting wholly or substantially of stock footage
5. Unscripted programmes regarded by the Minister as being of a type listed in paragraphs (a) to (e) of section 46J or Schedule 3 of the Broadcasting Act 2009 (as amended by the Online Safety and Media Regulation Act 2022)
6. Unscripted programmes produced wholly or mainly for exhibition to the public by transmission on a video-sharing platform service

Culture Test

Administered by DCCS. Pass mark:

• Minimum 50% overall in the Culture Test
• Minimum 5 points from Section A

Four sections:

The producer company must demonstrate compliance by specific reference to aspects of the programme, parties involved and content — not merely reiterate the wording.

State aid

The cumulation of State Aid is limited to 50% of the production budget of the programme, with a view to stimulating normal commercial initiatives.

(Per DCCS S487A Guidance Notes, December 2025. The DCCS guidance does not reference the 60% cross-border allowance or the low-budget / "difficult" film mitigations that exist for Section 481 — the Irish scripted tax credit. The S487A regime appears to operate the strict 50% cap without those mitigation routes — see State Aid — the EU cumulation cap and its mitigations and Section 481 vs Section 487A — picking the right credit for the structural contrast.)

State aid includes the S487A credit itself, Section 481 — the Irish scripted tax credit credits on other projects of the same producer where relevant for cumulation purposes, Screen Ireland funding, CnaM Sound & Vision awards, and any other EU Member State public funding. Post-Brexit, UK public funding — NI Screen Fund + sister funds and sister funds, BFI, Screen Scotland, Ffilm Cymru — is excluded from the Irish 50% cumulation. See State Aid — the EU cumulation cap and its mitigations.

Two-stage certificate process

S487A operates a two-stage certificate process — distinct from S481's single Culture Certificate.

Interim certificate (Regulation 3 of S.I. 671/2025)

• Application under section 487A(2)(a) made in writing to the Minister by a producer company
• Submitted at least 21 working days prior to commencement of Irish production
• Application bundle: Tab A application form + Tabs B–M supporting documentation
• Submission email (DCCS-side): unscripted@CCS.gov.ie
• A certificate shall not issue unless the Minister is satisfied that the unscripted programme is eligible under Part 3, is likely to be an eligible unscripted programme when completed, the production will contribute to the promotion and expression of Irish or European culture (Culture test), and the production will provide quality employment including training and skills development opportunities
• The interim certificate sets out: that it is an interim certificate; that the programme is to be treated as an interim unscripted programme; the category; conditions per s.487A(6) (employment, trainees, maximum aid intensity having regard to Commission Communication 2013/C 332/01, acknowledgement in opening/closing titles); the expiry date of the interim certificate

Final certificate (Regulation 4 of S.I. 671/2025)

• Application under section 487A(2)(b) made in writing to the Minister
• Submitted in advance of the expiry date of the interim certificate and in all cases within 6 months of completion
• Application bundle: per Schedule 2 of S.I. 671/2025
• A certificate shall not issue unless the Minister is satisfied that: the programme as completed is an eligible unscripted programme; meets the requirements of the Culture test; conditions specified in the interim certificate have been met
• The final certificate sets out: that it is a final certificate; that the programme is a qualifying unscripted programme; conditions per s.487A(11) (employment, maximum aid intensity, acknowledgement)

Acknowledgement in credits

The S487A credit must appear in the opening titles or closing credits per the conditions attaching to the interim and final certificates. Confirmed in the Stage 3 compliance declaration.

Skills Development

Review pathway

Exception: where a Producer Company is involved in multiple projects and has already engaged with Screen Ireland on a project with anticipated eligible expenditure over €1.5m, the Department may ask that smaller (<€1.5m) projects also go through Screen Ireland.

In no circumstances should any skills development participant be paid at a rate lower than the minimum wage.

Participant floor — minimums by spend tier (S487A)

Per the DCCS S487A Guidance Note December 2025:

A minimum of one skills development participant must be employed on the production.

Participant categories

S487A recognises three categories:

(S481 adds a fourth — Animation Junior — for animation industry roles. Not applicable to S487A.)

Submission email (Screen Ireland-side)

section487A@screenireland.ie

Engagement cadence

The Screen Ireland 487A team will, in most cases, insist on 2/3 meetings + one set visit: initial meeting well in advance of production, follow-up at final submission stage, and a final meeting if required at compliance stage up to 12 weeks after production ends.

(Distinct from S481 where the cadence is 3 meetings + 1 set visit unconditionally — see Skills Development Plan (Tab F).)

Tab A–M application bundle (DCCS-side)

Qualifying expenditure

Per Regulation 12 of S.I. 671/2025, qualifying expenditure includes all expenditure incurred by the producer company on the production of the programme during the development phase and up to and including post-production, together with the cost of providing an archive print.

Development phase is defined as the period commencing 6 months before the interim cert application date (or, if later, the date development begins) and ending on the date the application is made.

Non-qualifying expenditure (Reg 13)

Distribution/promotion costs; costs after delivery; pre-sales monies; costs of acquiring rights other than necessary for production; (and additional categories per the full text of Reg 13).

Records retention

Producer company must keep records demonstrating breakdown of expenditure to Revenue's specification (Regs 7 + 8). Records must be available prior to making interim claim (per Schedule 3) and final claim (per Schedule 4). Retention obligations per s.487A.

Forms + paperwork producers actually file

Mutually exclusive with S481

S487A is mutually exclusive with S481 by statute (Reg 6(1) of S.I. 671/2025). See Section 481 vs Section 487A — picking the right credit for the decision rule and detailed comparison.

How Togra supports the S487A lifecycle

The S487A readiness tracker scores the project across twelve dimensions including the state-aid 50% check — when cumulative state aid exceeds 50% of total budget the tracker surfaces a loud red banner.

Pack generators cover the lifecycle: a Tab F skills development pack, an interim certificate application pack, an interim claim pack for Revenue, and a final claim pack for the post-completion filing.

The Skills Development setup workspace captures the Skills Needs Analysis, names the Skills Development Officer and nominates the carbon calculator. A participants register holds every named skills participant with their Individual Learning Plan and Reflective Learning Journal. A mandatory courses tracker keeps the per-person × per-course matrix against the 80% all-crew and 2-of-3 senior management thresholds.

The Stage 3 compliance flow walks the producer through the Quality Assurance answers, declarations (Irish IBAN, no S487A(18)(a) arrangements, no outstanding tax returns), and the acknowledgement-in-credits confirmation. A one-click compliance bundle produces a ZIP containing the QA report, Tab Z skills breakdown, SI engagement log, and per-participant evidence — ready to submit to section487A@screenireland.ie.