Greece: New Deadlines Move Second-Period E-Invoicing to 2 November 2026 and Phase B of the Digital Delivery Note to 1 January 2027, with ERP Transmission Ending on 1 February 2027

On 30 September 2026, the Greek Ministry of National Economy and Finance and the Independent Authority for Public Revenue (AADE) announced new deadlines for two obligations that were due to start in October.

Mandatory e-invoicing for the second period, covering businesses with declared gross revenue of up to EUR 1 million, now starts on 2 November 2026 instead of 1 October 2026, with a phased period to 31 January 2027, and transmission through an ERP will no longer be possible from 1 February 2027.

Phase B of the digital delivery note, which was due to start on 12 October 2026, now starts on 1 January 2027, with unified Combined Nomenclature coding from 1 January 2028.

Background

Greece is introducing mandatory B2B e-invoicing through myDATA in periods, with the largest businesses first and smaller businesses in a second period. In parallel, AADE is moving goods movement documents into a digital delivery note in phases.

KGT reported on 11 August 2026 on the second period starting on 1 October 2026 and on digital goods movement starting on 12 October 2026, and on 11 September 2026 on the myDATA 2.0.2 release that supports the goods movement functionality. The dates in the August update have now been replaced.

AADE also issued a press release on 22 September 2026 with clarifications on the declaration of start of use for the timologio and myDATAapp applications. The body of that release was not readable for this update and is not described here.

The Legislative Change

This is a legislative change, made by joint decisions of the Deputy Minister of National Economy and Finance, Dimitrios Markopoulos, and the AADE Governor, Giorgos Pitsilis. AADE’s press release of 30 September 2026 does not give the decision numbers.

A Greek legal database reproducing the decisions identifies them as Decision A.1197/2026, amending Decision A.1128/2025 on e-invoicing, and Decision A.1198/2026, amending Decision A.1122/2024 on the digital delivery note, both published in Government Gazette (FEK) B’ 5905 of 30 September 2026 and taking effect on publication. These details are provisional until the FEK text is read on the official register.

On e-invoicing, the amended provision requires second-period entities to issue electronic invoices only, from 2 November 2026. Between 2 November 2026 and 31 January 2027 they may phase in the obligation and, in parallel, use the other methods available under the earlier decision, which are issuance and transmission through ERP or business software, or manual issuance with transmission through the entry form in the AADE electronic books application. The stated reason is to give enough time for technical implementation.

On the delivery note, the amended provisions set Phase B for loading, unloading, receipt, and quantity-control data from 1 January 2027, and unified goods coding under the Combined Nomenclature from 1 January 2028.

Until each obligation starts, businesses may transmit the relevant data to myDATA on an optional basis. Olive-producing farmers’ obligation to issue movement documents and transmit Phase A data is postponed to 1 January 2027, on condition that the olive mill issues a quantity receipt slip on delivery and that the farmer is not among the first-period obliged entities.

Scope

The e-invoicing deadline applies to businesses whose declared gross revenue for the tax year that began in 2023 was up to EUR 1 million, and AADE’s release describes no other turnover category.

From 1 February 2027 domestic B2B invoices, B2B invoices with non-EU third countries and B2G invoices, together with their transmission to myDATA, must go through an e-invoicing provider or through the AADE applications timologio or myDATAapp. The delivery note deadlines apply to the businesses subject to digital tracking of stock movements under the existing framework.

Timeline

• 30 September 2026 — AADE and the Ministry announce the new deadlines; the joint decisions are reported as published in FEK B’ 5905 of the same date.
• 2 November 2026 — second-period e-invoicing becomes mandatory; the phased period begins.
• 31 January 2027 — end of the phased period.
• 1 February 2027 — e-invoices and their transmission to myDATA must go through a provider, timologio or myDATAapp; ERP transmission is no longer possible.
• 1 January 2027 — Phase B of the digital delivery note (loading, transshipment, receipt, quantity control); olive growers’ obligation starts.
• 1 January 2028 — unified item coding under the Combined Nomenclature.

Businesses Affected

Greek subsidiaries and branches of multinational groups with declared gross revenue of up to EUR 1 million, and any business, of any size, that moves goods and falls within the digital delivery note framework.

Larger Greek entities are not moved by this change. Businesses that had already prepared for 1 October or 12 October have gained time but should not treat it as a release from preparation, because the 1 February 2027 end of ERP transmission and the 1 January 2027 goods movement date are fixed.

Required Actions

• Re-baseline Greek project plans: second-period e-invoicing from 2 November 2026, Phase B from 1 January 2027, goods coding from 1 January 2028.
• Where a provider will be used, file the Declaration of Start of Electronic Issuance with effect from 2 November 2026 and begin issuing e-invoices within the phased period. Businesses that will use only timologio or myDATAapp from 2 November 2026 and will not use the phased period do not need to file it, according to AADE.
• Plan the exit from ERP-based transmission before 1 February 2027, because after that date an ERP can no longer send these invoices to myDATA directly.
• Keep the myDATA 2.0.2 interface work on the delivery note moving, because the optional period is a testing opportunity and not a reason to stop.

Practical Implications

The extension removes a short-term deadline but sharpens the medium-term one. The phased period lets a business run its ERP and the AADE tools in parallel, which is useful for testing, but the end of ERP transmission on 1 February 2027 means a smaller business that built its process around direct ERP transmission must move to a provider or to the AADE applications in a three-month window.

For SAP-based groups this changes the integration decision from a technical preference into a deadline-driven one.

The delivery note change decouples e-invoicing from goods movement. Teams that planned to launch both on consecutive dates in October now have separate programs with a year-end start for logistics data, which falls on the busiest period for physical stock movements.

Expected Next Steps

The FEK text of both decisions should be read on the official register to confirm decision numbers and article wording. AADE has indicated that further stock categories may receive different start dates for Phase B by later decision, and AADE is expected to continue releasing myDATA versions, so the interface should be treated as a moving version pin.

How Can KGT Support You?

KGT is a specialist indirect tax technology firm. We implement and run SAP Document and Reporting Compliance (SAP DRC) and deliver SAP-integrated e-invoicing add-ons where DRC does not yet cover a requirement or where a transformation programme makes a DRC rollout impractical in the available window. Our work is done inside the SAP landscape rather than around it, so VAT determination, document creation, transmission, status handling and reconciliation stay in one place.

For Greece KGT can reassess your readiness for the revised dates, choose between a provider route and the AADE applications, and test the myDATA e-invoicing and delivery note interfaces before 2 November 2026 and 1 January 2027.

This Country Update is provided for general information only and is not tax, legal or professional advice. No reliance should be placed on it without specific advice on the facts of your situation.