Regulatory updates - Greece

On October 29, 2025, the Independent Authority for Public Revenue (AADE) published revised timelines for the Digital Delivery Note implementation, confirming that Phase B (second period) has been postponed from December 1, 2025 to May 1, 2026.

Implementation phases and timelines

 Phase A (previously phase one) remains unchanged: digital issuance and transmission of the relevant Types of Documents for the commencement of circulation on the myDATA digital platform, as well as informing the recipient.

• Since June 2, 2025: certain taxpayers
• From December 1, 2025: remaining of taxpayers

Phase B (previously phase two) timeline has been revised: procedures for loading, unloading, receipt, quality and quantity control, as well as other procedures for the digital monitoring of circulation. Exceptions

• Optional from December 1, 2025 until April 30, 2026: voluntary data transmission to the myDATA digital platform
• Mandatory from May 1, 2026: mandatory data transmission

Additionally, AADE has expanded exemptions from the digital dispatch note requirement to include specific sectors. Further details about these exemptions are available in the official press release published in Greek.

On September 16, 2026, the Independent Authority of Public Revenue (AADE) announced the implementation timeline for mandatory electronic invoicing for business-to-business (B2B) transactions, with incentives available for early adoption.

This obligation concerns the issuance of electronic invoices for every sale of goods and provision of services for domestic and cross-border transactions.

Scope:

• Mandatory electronic invoice issuance for all sales of goods and services between businesses in Greece, with mandatory acceptance by receiving domestic businesses
• Mandatory electronic invoice issuance for sales to businesses in third countries (outside the EU), with alternative sending methods available if the foreign business does not accept electronic invoices
• Optional electronic invoice issuance for sales to businesses within the European Union
• No obligation for domestic businesses to accept electronic invoices from foreign businesses (EU or non-EU)

Implementation timeline:

Period A - Large enterprises (gross revenues exceeding €1,000,000 for tax year 2023)

• February 2, 2026: Mandatory implementation begins
• February 2 - March 31, 2026: Gradual implementation period allowing simultaneous use of business management programs or special entry forms

Businesses must submit a Declaration of Commencement of Electronic Issuance of Documents or a Declaration of Use of the timologio Application and begin issuing electronic invoices within this quarter.

Period B - All other businesses

• October 1, 2026: Mandatory implementation begins
• October 1 - December 31, 2026: Gradual adjustment period

Early adoption incentives:

Businesses implementing electronic invoicing two months before their respective deadline (by December 1, 2025 for Period A or August 3, 2026 for Period B) will receive:

• 100% depreciation on expenses for technical equipment and software in the purchase year
• 100% Deduction on expenses related to production, transmission, and electronic archiving of electronic invoices for the first 12 months

Available options:

Businesses can fulfill this obligation by choosing either:

• Services from an Electronic Invoice Issuer Provider
• AADE's free applications: timologio and myDATAapp for mobile devices, which provide equivalent solutions at no cost for issuing electronic invoices related to public contracts

Technical specifications have yet to be released along with other important information.

The Greek Parliament passed the National Customs Code and Other Provisions – Pension Regulations law (ΦΕΚ 134 Α΄/28.7.2025), which introduces mandatory electronic invoicing.

The document outlines amendments to the electronic invoicing regulations under Greek law, specifying mandatory electronic invoicing for certain transactions and detailing the technical standards and procedures for implementation  law 4308/2014 and (EU) 2025/516. It also introduces incentives for entities that adopt electronic invoicing early, before the mandatory enforcement date.

• Mandatory electronic invoicing scope: Electronic invoicing is compulsory for sales and services within Greece to entities under the law, to foreign entities outside the EU (excluding retail), and for public contracts and government expenses, with specific provisions for each case. Other transactions require recipient acceptance of electronic invoicing. 
• Electronic invoice standards and procedures: The Minister of National Economy and Finance, together with the Independent Authority for Public Revenue (IAPR), defines the electronic invoice format based on European standards and sets procedures for invoice processing, interoperability, and technical requirements. Public contracts are subject to separate provisions. 
• Implementation details: The scope, effective date, and other necessary matters for applying mandatory electronic invoicing will be specified by joint ministerial and IAPR decisions, including the roles and obligations of Electronic Invoicing Providers and control procedures. 
• Incentives for early adoption: Entities opting for exclusive electronic invoicing before the mandatory start date benefit from full amortization of initial technical equipment and software costs plus a 100% increase, and deductible expenses for invoice production and archiving for the first 12 months, also increased by 100%. 
• Conditions and compliance: Incentives apply from tax year 2025 onward if declarations are submitted timely and electronic invoicing commences within the prescribed period. Withdrawal of declarations or non-compliance results in loss or revocation of benefits. Providers must maintain records for verification, and procedures for declarations are defined by IAPR decisions. 

A joint ministerial decision will specify the scope of application, effective date, and implementation provisions of the mandate. Additional decisions will establish the electronic invoice format, interoperability requirements, and define the obligations and rights of certified e-invoicing providers.