Datalex's auditor has told the Registrar of Companies that it has formed the opinion that the firm failed to comply with its obligations under the Companies Act to keep adequate accounting records last year.
The development emerged in a statement provided to the stock exchange by the travel software firm, in which it noted the decision by Ernst and Young.
"The Company takes its legal and corporate governance responsibilities very seriously and seeks to comply at all times with all relevant laws and regulations," Datalex said.
The firm added that it has expended significant effort during this year in taking corrective actions to address shortcomings identified by an independent review of accounting issues carried out by PwC and its legal advisers.
"The Board is satisfied that, while it continues to assess the Group's material risks and effectiveness of its internal controls, it has taken all appropriate immediate action."
"Further detail will be included in the Company's financial statements for 2018 which the Company expects to publish very soon."
Failure to keep adequate accounting records as required by the law is considered a serious matter.
However, it had been thought likely that EY would at some point report Datalex to the registrar over last year's accounts.
Datalex undertook an audit of its 2018 accounts after a review discovered "significant accounting irregularities" at the firm.
The PWC report said the company's figures for the first six months of 2018 were "materially overstated", with some revenue recorded before it had actually been received.
A delay to Datalex's publication of full year results led to the suspension of its Dublin-listed shares in April, while chairman Paschal Taggart and CEO Aidan Brogan also resigned.
Last month the company said it now expects to record a loss of between $4m and $6m for 2018, considerably higher than its previous forecast.
Earlier this year the firm agreed to a €6m loan from the investment vehicle of Dermot Desmond, who also increased his stake in Datalex to 29.9%.
Datalex provides ecommerce software to the travel industry, including well-known airlines such as Lufthansa, Aer Lingus and Jet Blue.