The countdown for the second phase of mandatory e-invoicing has begun, with the Independent Authority for Public Revenue (AADE) already sending reminders to thousands of businesses and freelancers. October 1, 2026, marks the milestone date for the inclusion of entities with gross income up to €1 million in 2023.
The Three Critical Milestones
The transition to the new digital regime is defined by three specific dates that obligated parties must monitor closely:
- October 1, 2026: Official start of the obligation for the second group of businesses.
- October 12, 2026: Deadline for submitting the Declaration of Commencement of Electronic Issuance or the Declaration of Use for the "timologio" application.
- December 31, 2026: End of the transition period during which parallel use of old issuance methods is permitted.
It is noted that the transition period does not function as an automatic extension. To utilize it, a business must have submitted the relevant declaration, setting the start date no later than October 1st.
Scope and Methods of Issuance
The obligation concerns wholesale transactions (B2B) within Greece, as well as sales to businesses in third countries outside the EU. Conversely, transactions with businesses in other EU member states remain outside this specific framework. Obligated parties can choose between licensed providers or AADE's free applications (timologio and myDATAapp).
The Penalty Traps
AADE warns that issuing documents through non-prescribed methods (e.g., manually after the transition period ends) may be treated as "non-issuance," triggering corresponding sanctions. Different fines are provided for failure to submit or late submission of the commencement declaration, while penalties become stricter in cases of recidivism.
Despite reports suggesting a possible postponement of the start date to March 1, 2027, following market requests, AADE's official position remains committed to the current October schedule.
