Regulatory updates - Greece

E-transportation Phase B has been postponed and divided into two phases, with the first phase starting on October 12, 2026 followed by the second phase on January 1, 2027.

Decision A.1094/2026 primarily postpones and clarifies the implementation timeline for Phase B of the digital monitoring of inventory movements transmitted to myDATA, providing additional time for technical readiness.

The decision does not alter the scope of the mandate but redefines when each phase becomes mandatory.

Phase A — Mandatory since December 1, 2025

Since December 1, 2025, all entities within scope have been required to transmit Phase A data to myDATA. Phase A covers the basic digital monitoring of inventory movements, as defined in Annex I of Decision A.1123/2024.

Farmers are not yet within scope of the Phase A obligation.

Phase B — Implementation split into two sub-phases

Previously scheduled to begin on May 1, 2026, Phase B has been postponed and divided into two sub-phases:

Phase B1 — From October 12, 2026

Mandatory transmission of:

• Loading
• Transshipment
• Receipt of goods
• Data supporting traceability of inventory movements
• Quantitative and qualitative inventory controls

Phase B2 — From January 1, 2027

Mandatory transmission of:

• Unified item codification according to the Combined Nomenclature (CN) 

Voluntary transmission before the obligation takes effect

Businesses are allowed to adopt Phase B voluntarily since December 1, 2025.

The Independent Authority for Public Revenue (AADE) has announced an extension of the implementation timeline for mandatory electronic invoicing for large enterprises with gross revenues exceeding 1,000,000 EUR in the 2023 tax year.

On February 17, 2026  the AADE released a press release, announcing an extension of the implementation timeline for mandatory electronic invoicing for large enterprises included in the first implementation phase. This decision aims to facilitate timely compliance by providing additional time for the necessary technical adjustments required by electronic invoice issuers.

Scope of the Measure

The extension applies to large enterprises of the first phase, defined as businesses with gross revenues exceeding 1,000,000 EUR in the 2023 tax year.

Updated Implementation Timeline

The revised schedule for mandatory electronic invoicing is as follows:

• 2 March 2026: Start of mandatory application
• 2 March 2026 – 3 May 2026: Transitional period for gradual implementation

Businesses can comply with the e-invoicing obligation by using:

• Electronic Invoicing Service Providers (ΥΠΑΗΕΣ) or
• AADE's free applications, including the timologio web application and myDATAapp for mobile devices. These free tools also cover electronic invoicing requirements for public contracts at no cost.

Obligated enterprises must submit either a Declaration of Commencement of Electronic Issuance of Fiscal Documents or a Declaration of Use of the timologio application, with an effective start date of March 2, 2026.

AADE has clarified that failure to issue an electronic invoice will be treated as non-issuance of the invoice itself, with penalties under the Code of Tax Procedure applying. For transactions subject to VAT, a fine of 50% of the VAT amount will be imposed. For transactions not subject to VAT, fines of 500 EUR per tax audit for entities keeping single-entry books and 1,000 EUR for those with double-entry books will apply.

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.