E-invoicing & e-delivery | Upcoming obligations in 2026

2026 marks a pivotal year for digital tax compliance in Greece, bringing significant developments in e-invoicing and e-delivery documentation. These obligations building upon the already established myDATA digital reporting framework will significantly change the way Greek businesses issue and receive invoices and delivery documents. Greek businesses need to formulate their tax compliance strategy to ensure readiness for these new requirements as they come into effect.

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This issue outlines a summary of the key obligations of e-invoicing and e-delivery documents as well as the critical dates throughout 2026 and key implementation steps that Greek businesses should be aware of.

E-invoicing requirements

Starting from 2026, Greek businesses must issue e-invoices for (a) domestic B2B transactions, (b) B2B transactions with non-EU countries and (c) B2G transactions (the latter already in effect since 2023 under a special legal framework). E-invoices must be compatible with the European standard format as well as Greek Accounting Standards requirements.

  • Implementation shall take place in two phases depending on the business size as follows:

    Phase A From 2 February 2026 for businesses with annual turnover exceeding EUR 1M for FY2023; and

    Phase B From 1 October 2026 for all other businesses.

  • As of 2 February 2026, mandatory acceptance of e-invoices by Greek businesses also applies (subject to B2G transactions’ special requirements).

  • Greek businesses must issue e-invoices exclusively through either a certified E-invoicing Service Provider or the IAPR’s free applications (Timologio / myDATA App). A declaration of e-invoicing adoption indicating among others the selected invoicing method must be submitted electronically before the applicable start date per phase.

  • A two-month transitional period is also established during which parallel use of traditional invoicing methods (e.g. via ERP or handwritten invoices) is permitted (Phase A: 2 February – 31 March 2026; Phase B: 1 October – 31 December 2026) provided the declaration of e-invoicing commencement has been submitted in advance.

  • Businesses adopting e-invoicing at least two months before the mandatory enactment date may, under conditions, benefit from a 100% super-deduction of e-invoicing related expenses and 100% increased depreciation of e-invoicing equipment, respectively.

E-delivery documents requirements

Effective already from 2025 for the first implementation phase, new digital issuance and reporting requirements for the goods’ delivery and receipt documents have been introduced in Greek legislation.

  • Businesses must issue and receive delivery documents in digital format and transmit the relevant data to myDATA platform. The primary purpose of this regime is to enhance transparency of goods delivery for tax audit verification purposes and enable real-time tracking throughout the goods delivery cycle. 

  • Above requirements apply to both domestic and international shipments, covering road, sea, air and rail transport. Special exemptions from the above obligations are provided for specific types of businesses and certain types of transactions.

  • Implementation of the e-delivery documentation and tracking of goods’ shipments will be deployed in two phases depending on business size and business activity, namely:

    Phase A involving mainly the issuance and reporting of e-delivery documents, has been effective (a) as of 2 June 2025 for businesses active in specific sectors (pharmaceuticals and medical supplies, energy products, construction materials, olives and olive oil) or those whose turnover exceeds EUR 200k for FY2022 and (b) as of 1 December 2025 for all other businesses.

    Phase B involving more extensive reporting requirements for the e-delivery documents issuance and full digital tracking of shipments process, which becomes effective as of 1 May 2026 for all businesses.

  • E-delivery documents must include specific information (no special standard applies) while special requirements apply depending, among others, on whether delivery is simple or complex, the counterparties involved and whether loading/transloading of goods via change of transportation means takes place during the delivery process.

 

Next implementation steps

To comply with the new e-invoicing and e-delivery requirements, Greek businesses will need to adapt their existing ERP and invoicing systems as well as accounting and tax functions. Key implementation steps to consider include:

  • Identification of the use cases and affected invoicing flows (including B2B and B2G transactions) to determine applicable requirements and start date of relevant obligations.

  • Selection of the proper e-invoicing method (Certified E-invoicing Service Provider or the IAPR's timologio application) subject to special B2G e-invoicing requirements already in effect.

  • Assess whether early e-invoicing adoption is feasible to benefit from available tax incentives (currently applicable for entities subject to e-invoicing under Phase B).

  • Submission of the e-invoicing adoption declaration with the IAPR’s electronic applications indicating the selected e-invoicing method (by 2 February 2026 for Phase A and by 31 October 2026 for Phase B subject to early adoption cases).

  • Preparation for the mandatory acceptance of e-invoices from 2 February 2026 (irrespective of implementation phase).

  • Integration or update of existing ERP/invoicing systems taking also into account current myDATA reporting configuration allowing adequate time for necessary testing, troubleshooting and staff training.

How we can help

With extensive experience and expertise in e-invoicing, e-delivery documentation and myDATA reporting matters, we actively help our clients stay ahead of the evolving compliance requirements. From initial set-up to full implementation, our team provides comprehensive support across all relevant tax and accounting aspects of these obligations arising under the applicable framework.