Information on Mandatory Electronic Invoicing (B2B)

As of 2 February 2026, the mandatory implementation of electronic invoicing for business-to-business (B2B) transactions will come into force,

in accordance with decisions of the Ministry of National Economy and Finance and the Independent Authority for Public Revenue (IAPR).

The obligation concerns the issuance of electronic invoices for the sale of goods and the provision of services:

• between businesses established in Greece (mandatory issuance and acceptance),
• to businesses in third countries (outside the EU).

For transactions with businesses established in the European Union, electronic invoicing remains optional.

Implementation Timeline

• Businesses with gross revenue exceeding €1,000,000 (tax year 2023):
  Mandatory implementation as of 2 February 2026, with a transition period until 31 March 2026.
• All other businesses:
  Mandatory implementation as of 1 October 2026, with a transition period until 31 December 2026.

Businesses may comply either through a Certified Electronic Invoicing Provider or by using the free applications of the IAPR (timologio & myDATAapp).

Incentives for Early Adoption

Businesses that adopt electronic invoices at least two months earlier than the applicable mandatory deadline benefit from:

• 100% increased depreciation of expenses for technical equipment and software in the year of purchase,
• 100% increased deduction of expenses related to production, transmission, and electronic archiving of electronic invoices for the first twelve (12) months.

The introduction of mandatory electronic invoicing represents a significant step toward the digital transformation of businesses, reducing administrative costs and simplifying tax compliance obligations.

Extension of the 3% Cap on Commercial Leases for 2026

An amendment to the bill of the Ministry of Development titled “Establishment and operation of the Independent Authority for Market Control and Consumer Protection, regulations for the Competition Commission and other provisions”, extends once again until 31.12.2026 the validity of the maximum limit for rent adjustment for commercial property leases under Presidential Decree 34/1995.

The relevant provision, among others:

Article 3

Extension of validity of Ministry of Development provisions:

a) Maximum limit for rent adjustment for commercial and professional property leases

b) Inventory and posting of supporting documents in the Integrated Information System for Business Activity and Control – Amendment of par. 1 of article 96 of Law 5007/2022

In par. 1 of article 96 of Law 5007/2022 (Government Gazette A’ 241), regarding the determination of the maximum limit for rent adjustment for commercial and professional property leases, the following amendments are made:

a) the words “from January 1, 2025 until December 31, 2025” are replaced by the words “January 1, 2026 until December 31, 2026“

b) the words “of the year 2024” are replaced by the words “of the year 2025”, and par. 1 is formulated as follows:

“1. For commercial property leases falling within the scope of Presidential Decree 34/1995 (Government Gazette A’ 30), from January 1, 2026 until December 31, 2026, a rent adjustment of up to three percent (3%), as a maximum limit, on the rent of the year 2025 is permitted.”

Source: Taxheaven

Important Changes to Delivery Notes – Mandatory Digital Submission from 1 December 2025

We would like to inform you about the upcoming changes to Delivery Notes. As of 1 December 2025, all businesses will be required to comply with the first phase of implementation of the Digital Delivery Note.

What changes from 1 December 2025:

• Mandatory electronic transmission to myDATA All delivery notes must be transmitted to AADE (Independent Authority for Public Revenue) in real time or within a specified time frame (typically within the same day).
• Integration with sales documents The delivery note is now linked to the sales invoice through a specific classification code in myDATA.
• New fields and codes The following fields become mandatory:
  • Mode of transport
  • Recipient’s Tax Identification Number (TIN)
  • Product code and quantity
  • Time of dispatch
• Abolition of handwritten delivery notes Only electronic issuance is permitted, through ERP systems or applications connected to myDATA.

Exemptions under Decision A.1046/2025

Additionally, certain exemptions from POL 1003/2014 have been abolished. Under the new Decision A.1046/2025, the exemptions for the Digital Delivery Note are as follows:

• Relocation of business premises When an entity relocates its headquarters or branch.
• Movement of fixed assets Provided they are not being transported for the purpose of sale.
• Movement of spare parts for fixed assets Transfer between the entity’s premises, provided they are not traded commercially and are intended solely for repairs.
• Transfer of inventory within the same premises or between premises Exempt only if the premises are located within 10 kilometres of each other.
• Movement of quarry products and minerals
  • Raw quarry products (sand, gravel, etc.) transported by construction entities for projects carried out by them.
  • Minerals transported from site to site or to storage, processing, and unloading facilities.
• Retail transactions accompanied by a document When a retail receipt or invoice is issued.
• Distribution of university textbooks (Eudoxus) Exemption for the distribution of books to students through the Eudoxus system.

Disposal of Damaged, Unusable, or Unsuitable Inventory

In the case of transport of damaged, unusable, or unsuitable inventory (goods, products, or residues) or fixed assets for the purpose of disposal, destruction, or recycling at designated facilities, there is no obligation to issue a digital dispatch document or transmit the relevant data to myDATA, provided that all of the following conditions are cumulatively met:

i) The items carry no commercial value for the sender, recipient, or any third party

ii) No impairment has been recorded in the accounting books

iii) No revenue is generated from their disposal

iv) They are transported for the purpose of disposal (e.g., recycling facilities, landfills, etc.)

Note: This exemption also applies to the transport of excavation materials (rubble), provided the above conditions are met.

Clarifications under Circular E.2030/2025

The Ministry has issued Circular E.2030/2025, which provides clarifications and practical guidance on the implementation of the Digital Delivery Note and its transmission to myDATA, as well as the applicable penalties for non-compliance. The key points are as follows:

• Specifications and markings Digital delivery notes must comply with specific technical specifications and include defined roles (Sender, Recipient, Carrier, Third Party) with TIN where required.
• Examples of common transport scenarios Detailed scenarios are provided, including:
  • Triangular transactions (e.g., Sender → Third Party → Customer)
  • Transport using own or third-party vehicles
  • Role of commission agents and third-party logistics providers (3PL)
• Exemptions and special cases
  • Transport of minor materials in the context of service provision
  • Damaged or unsuitable inventory (under specific conditions)
  • Movements to/from farmers, shipbuilding and repair enterprises, third-party warehouses
  • Courier deliveries
  • Fuel in retail sales
• Handling of technical issues Late transmission is permitted in cases of power outages or loss of connection to myDATA.
• Penalties for non-compliance
  • €500 for single-entry bookkeeping
  • €1,000 for double-entry bookkeeping, per audit

Update to All Businesses – Actions Required in OpenBusiness
According to the new regulations, all businesses operating under a license or notification are required to take specific actions by December 31, 2025, depending on their category.
Please read carefully the case that applies to you:

• Businesses without a Notification in Notify Business
(those holding an old paper license and MHTE number)
You must register your activity in the OpenBusiness platform.
Deadline: December 31, 2025.
After the deadline, the registration will be considered late, and a €200 fee will apply.

• Businesses with a Notification in Notify Business
No registration is required, as your data has been automatically transferred to OpenBusiness.
However, you must update your record and upload the required supporting documents (previously kept in the licensing file).
Deadline: December 31, 2025.
Failure to upload the necessary documents may result in administrative penalties.

• Businesses with Swimming Pools and Extractive Activities (Chapters IB and IG)
You must register your activity in OpenBusiness.
You are required to submit an operation notification and attach the necessary documentation, in accordance with the relevant legislation.
Failure to comply will result in penalties.

Important:
The final deadline for registration or uploading documents is December 31, 2025.
After this date, fines and administrative sanctions will be imposed.
For any questions or assistance with the process, please do not hesitate to contact us — we are available to guide you step by step.

PROGRAM “Digital Transactions II”

Through the “Digital Transactions II” Program, participating businesses can receive support in order to implement one or more of the following Categories of Actions:

Category 1: Supply of new or replacement of existing EFT/POS.
Category 3: Acquisition of electronic invoicing provider services & invoicing software.
Category 4: Upgrade of cash registers (FTM) & tax devices (ADIME) for interconnection with EFT/POS.
Category 5: Supply of a new cash system or replacement of existing fiscal devices (EAFDSS) and non-upgradable FTM & ADIME (excluding catering businesses).
Category 6: Supply of a new cash system or replacement of fiscal devices (FTM, ADIME, or EAFDSS), specifically for catering businesses.
Category 7: Upgrades, software improvements, and technical support of interconnected POS.

DEADLINES – PROGRAM PHASE COMPLETION

• Funding Applications for the 1st Cycle of Action Categories (1), (3), (4), (5), (6), and (7) may be submitted by eligible beneficiaries from Monday, June 23, 2025 until Friday, September 5, 2025.

• Purchases of products and services included in the Action Categories (1), (3), (4), (5), (6), and (7), using vouchers issued for approved beneficiaries, may be made until Friday, November 7, 2025.

• The end of the transitional (cooling-off) period, during which only limited (exceptional) voucher redemptions are allowed, is set for Friday, November 21, 2025.

• The completion date for all types of payments and for the Program itself is Friday, January 30, 2026.

July 16, 2025

With the bill submitted to Parliament, “National Customs Code and other provisions – pension provisions”, the framework of the Tax Procedure Code (Law 5104/2024) is being reformed.

• Increasing fines are redefined, from the designated date, for taxpayers who transport goods without supporting transport documents.

• Legal entities mentioned are obliged to exclusively accept payments through interconnected Electronic Funds Transfer at the Point of Sale (EFT/POS) terminals, with penalties provided in case of non-compliance.

• The Independent Authority for Public Revenue (AADE) establishes a “Property Ownership and Management Registry” (POMR), with necessary authorizations for issuing regulatory decisions regarding its operation (Articles 213–219).

Explanatory Report

Article 214
Stricter fines are introduced for transporting goods without transport documents. Specifically, a fine of €5,000 per tax audit is imposed if the entity uses a single-entry bookkeeping system, and €10,000 if it uses a double-entry system. In case of repeat violation, the provisions of Article 67 of the Tax Procedure Code apply. The measure aims to increase tax revenues and ensure compliance with tax obligations, particularly for double-entry bookkeeping entities. The provision applies from June 2, 2025, following the postponement of the start of digital monitoring of goods transport.

Article 215
Businesses required to accept payments through account-to-account instant payment services (e.g., I.R.I.S. online payments) must accept such payments at the point of sale, either via interconnected EFT/POS terminals or via Electronic Invoicing Provider Services. Updated sanctions will apply to entities and Payment Service Providers that fail to comply with the required interconnection and software upgrade obligations.

Article 217
The creation of the Property Ownership and Management Registry (POMR) is deemed necessary in order to consolidate and maintain property ownership and management information in a unified digital registry. This registry will be updated by taxpayers’ declarations and interconnected with the Unified Property Registry (E-Registries) of the Hellenic Cadastre and other public/private systems containing property-related data. Its purpose is to prevent tax evasion regarding property ownership and to increase tax revenues quickly.

Section B

With the same bill, among other provisions:

1. It is established that, in the case of leasing or subleasing real estate, rent must be paid into the landlord’s bank account.

2. In case of violation:

   • Deduction of property-related expenses (repairs, maintenance, renovations, etc.) is disallowed.

   • Tenants lose eligibility for any rent-related benefits, subsidies, or allowances. (Article 210)

Explanatory Report – Article 210
The obligation to pay rent through a bank account is established, along with penalties for non-compliance, in order to tackle tax evasion and loss of public revenue from undeclared rental income. This applies to tax year 2026 and onwards.