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2026-10-02
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PN-20261002 mandates
Mandates

Greece's e-invoicing phase 2 starts 1 October; declaration deadline is 12 October

Phase 2 of Greece's mandatory e-invoicing started on 1 October 2026 for businesses with turnover up to 1 million euro. The transition period to 31 December applies only to businesses that file a myDATA declaration by 12 October 2026.

Phase 2 of Greece’s mandatory e-invoicing took effect on 1 October 2026 for businesses with gross annual turnover up to 1 million euro. A second date matters just as much: 12 October 2026. By then, businesses must declare through myDATA that they are moving to electronic invoicing. Only that declaration gives access to the transition period to 31 December 2026.

Greece’s Independent Authority for Public Revenue (AADE) began contacting taxpayers in late August 2026 about phase 2 of mandatory B2B e-invoicing. Two dates apply. 1 October 2026 is the date the obligation takes effect. 12 October 2026 is the final date to declare electronic issuance through myDATA.

Two dates, two different meanings

Phase 2 took effect on 1 October 2026 for businesses with gross annual turnover up to 1 million euro. The threshold is based on the tax return for the financial year beginning in 2023. Businesses above that threshold have been under the obligation since 2 March 2026.

The scope covers B2B transactions within Greece and B2B transactions with entities outside the European Union. It also covers B2G transactions with public bodies, unless separate legislation already prescribes electronic invoicing.

A transition period runs until 31 December 2026. During it, businesses may keep using existing invoicing methods alongside electronic ones. That flexibility is conditional. It applies only to businesses that formally declare through myDATA that they are moving to electronic invoicing. The declaration must state 1 October 2026 or earlier as the start date and must be submitted by 12 October 2026.

Companies that file late or not at all face penalties for late or missing informative returns. Without the declaration of electronic issuance, there is no transition period.

How the Greek system works

myDATA, My Digital Accounting and Tax Application, has been the real-time reporting framework for Greek VAT-registered businesses since 2021. The 2026 mandate adds structured invoice exchange. VAT books and invoice data go to myDATA in a prescribed XML format following the European standard EN 16931-1. The invoice then receives a unique registration reference, the MARK, and a QR code for verification against myDATA.

There are two permitted channels for sending invoices:

  • Authorised e-invoicing service providers meeting AADE’s technical and security requirements, known as Electronic Data Issuance Providers (EDIP). Commercial providers must be established in Greece and meet financial stability requirements. Invoice data may be stored elsewhere in the EU.
  • The free AADE applications timologio and myDATAapp, which create invoices and send them to myDATA.

A Peppol service provider is not automatically an accredited provider in Greece. An Access Point alone does not cover the Greek clearance model. Greece validates invoices in advance through the tax authority, while Peppol is a decentralised four-corner network. Peppol has been in use for B2G invoicing in Greece since 2025.

The Greek mandate rests on Council Implementing Decision (EU) 2025/502. The decision allows Greece to derogate from Articles 218 and 232 of Directive 2006/112/EC from 1 July 2025 to 31 December 2027. Under ViDA, the pre-clearance model must be replaced by January 2035.

Penalties and the obligation to accept

Issuing an invoice outside the new framework counts as non-issuance. For documents subject to VAT the penalty is 50 percent of the VAT amount on the invoice. For non-VAT transactions fixed penalties of 500 or 1,000 euro apply, depending on the taxpayer’s accounting system.

An acceptance obligation has applied since 2 March 2026. Recipients, both businesses and public bodies, must accept e-invoices. Refusal can amount to non-compliance.

What businesses should check

For finance and accounting teams, the steps are:

  • File the declaration of electronic issuance through myDATA by 12 October 2026, stating 1 October 2026 or earlier as the start date.
  • Check whether 2023 financial-year turnover sits below 1 million euro, and which entities and flows are in scope.
  • Verify master data: tax numbers, addresses, legal names, invoice classifications, tax codes and payment details.
  • Define who handles rejected invoices, within what deadline and along which escalation path.

For integrators and service providers, the steps are:

  • Verify that the chosen provider is an EDIP authorised in Greece. Accreditation elsewhere in Europe does not count.
  • Assess whether timologio or myDATAapp is enough, or whether volume requires ERP integration with an EDIP.
  • Map VAT books and invoice data to the EN 16931-1 XML format and the myDATA classifications.
  • Write the validation result, MARK, QR code and document status back to accounting records, with exception handling for rejections.

References

  1. Council Implementing Decision (EU) 2025/502
  2. peppol.nu (Solventis)