In short
- Who: Greek businesses that declared gross revenue of up to €1,000,000 for the fiscal year starting in 2023 — the "second period" of the mandate.
- When: mandatory from 2 November 2026, with a gradual application period to 31 January 2027.
- How: through a certified e-invoicing provider, or AADE's free timologio and myDATAapp applications.
- What ends: from 1 February 2027, these invoices can no longer reach myDATA through an ERP or any other route.
- Legal footing: an EU derogation, Council Implementing Decision (EU) 2025/502, applying from 1 July 2025 to 31 December 2027.
Greece did not start from zero. Since the launch of the myDATA platform, Greek businesses have been transmitting invoice data to the tax administration (AADE). The mandate changes what is transmitted and by whom: the invoice itself becomes an electronic document issued through an approved channel, and the data reaches myDATA as a by-product of issuing it rather than as a separate upload. How Greece fits among the other national schemes is set out in mandatory e-invoicing in Europe.
The second period, in the announcement's own terms
On 30 September 2026 the Ministry of National Economy and Finance and AADE announced, by joint decisions of the Deputy Minister and the Governor of AADE, that the start of mandatory e-invoicing for businesses with turnover below €1,000,000 was being moved. The scope test is the gross revenue declared in the tax return for the fiscal year that began in 2023.
- 2026-11-02Mandatory e-invoicing applies. Businesses using a provider file the start declaration with this effective dateadopted
- 2026-11-02 to 2027-01-31Gradual application: ERP or accounting software, or AADE's special registration form, may still be used in paralleladopted
- 2027-02-01Issuing these e-invoices and transmitting them to myDATA only through a certified provider or AADE's timologio and myDATAappadopted
Dates as set by the joint decisions announced on 30 September 2026, which replaced earlier dates. Greek deadlines have moved more than once; confirm against AADE before relying on any of them.
The announcement also gives a sense of scale: around 655,000 businesses, nearly 70% of those potentially in the second period, were already using a provider or AADE's applications for wholesale transactions, and almost 488,000 had filed the declaration or started using those channels in the preceding month alone.
The two routes in
A business meets the obligation in one of two ways.
A certified e-invoicing provider. The provider issues the invoice, transmits it, and passes the data to myDATA. This is the route for anyone issuing from an ERP at volume, because the ERP feeds the provider rather than myDATA directly. Choosing one is the same kind of controls decision as anywhere else in Europe — see choosing an access point or service provider.
AADE's free applications. timologio and myDATAapp issue e-invoices directly, and according to the announcement they also cover e-invoices for public contracts. For a small business issuing a handful of invoices a month, this is a real option and costs nothing. Its limit is integration: invoices issued in a web application have to be reconciled back into the accounting system.
The gradual period lets a business keep its old way of transmitting data to myDATA alongside the new one until 31 January 2027. On 1 February 2027 the old way closes for the invoices in scope. A business that uses the transition to postpone choosing a channel reaches February with nothing that works.
Filing the start declaration
The rule on declarations is easy to get backwards:
- A business using a provider must file the Declaration of Start of Electronic Issuance with an effective date of 2 November 2026, and begin issuing e-invoices within the gradual period.
- A business that will issue exclusively through timologio or myDATAapp from 2 November 2026, and does not need the gradual period, does not have to file it.
Why Greece needed EU permission
Before the changes adopted in the VAT in the Digital Age package, the VAT Directive made the use of an electronic invoice subject to the recipient's acceptance (Article 232), so a Member State could make electronic invoices compulsory only with a Council authorisation to derogate. Greece obtained that authorisation through Council Implementing Decision (EU) 2025/502, which lets it require invoices from taxable persons established in Greece to be electronic without the recipient's acceptance. The decision applies from 1 July 2025 until 31 December 2027, or until an EU-wide e-invoicing system applies if that is earlier. The mechanism is the same one other early movers used: see Article 395 derogations.
What cross-border senders should know
The mandate is about invoices issued by businesses established in Greece. A foreign supplier invoicing a Greek customer is not issuing a Greek mandated e-invoice — but it will find more and more Greek customers equipped to receive structured documents, and some will ask for them.
For anyone exchanging with Greek businesses over Peppol, note that the Peppol BIS Billing 3.0 rule set includes Greek national rules: GR-R-009 and GR-R-010 require the electronic address to carry a correct Greek tax identification number under scheme 9933. A Greek party's electronic address is therefore not a free choice, and master data holding the wrong identifier will fail validation — the same class of failure covered in master data for e-invoicing.
Alongside: digital dispatch documents
The same announcement moved the second phase of digital tracking of stock movements. From 1 January 2027 loading, reloading and receipt procedures and quantity-control data transmission are activated for all businesses; from 1 January 2028 a single product coding based on the Combined Nomenclature (TARIC) applies. These are separate obligations from invoicing, but they run through the same platform and usually the same provider, so they belong in the same project plan.
What to do before 2 November
- Confirm the period. Check the gross revenue declared for the fiscal year that started in 2023. Up to €1,000,000 means the second period.
- Choose the channel. A certified provider if invoices come from an ERP or at volume; timologio or myDATAapp if volumes are small.
- File the declaration if using a provider, with the effective date of 2 November 2026.
- Plan the cut-over before 1 February 2027, when ERP transmission to myDATA stops for these invoices.
- Clean the customer master so that each Greek customer's tax identification number is correct and usable as an electronic address.
- Add dispatch documents to the same plan, with the 1 January 2027 and 1 January 2028 dates.