The Data Protection Commissioner has warned that the use of information from utility bills to track down people who have not paid their household charge could be open to legal challenge.
Billy Hawkes says the risk of a challenge is low provided the Department of the Environment puts in place proper safeguards.
Property owners must pay the €100 charge by the end of March.
The legislation allows for information from utility bills to be used to identify properties that have not been registered for the charge.
Mr Hawkes says the move could be seen as an extension of the powers of the State.
Already 10,000 people have paid the controversial fee, which will be replaced by a full blown property tax either next year or in 2014.