Greece: Phase Two of Mandatory B2B Electronic Invoicing Begins October 1, 2026, and Phase B1 of Digital Goods Movement Monitoring Begins October 12, 2026

Country Update — Greece  |  11 August 2026  |  Topic: E-Invoicing / Digital Reporting

Two Greek obligations of first-order importance take effect within twelve days of each other this autumn, and neither derives from a recent announcement.

Joint decision A.1128, signed on September 16, 2025, and published in Government Gazette B' 4937 of the same date, requires all remaining obliged entities — those below the first-period revenue threshold — to issue exclusively electronic invoices from October 1, 2026, with a gradual-compliance concession running to December 31, 2026.

Decision A.1094 of April 29, 2026, published in Government Gazette B' 2445 of April 30, 2026, brings Phase B1 of mandatory digital monitoring of goods movements into force from October 12, 2026. This is a backfill update: the governing decisions are settled law, the dates are close, and neither has been covered here before.

Background

Greece has been building continuous transaction controls since 2020 through the myDATA platform, into which transaction summaries are transmitted and against which a unique registration mark is issued.

The framework was established by decision A.1138/2020, and the format and transmission channels for electronic invoicing were set by decision A.1123 of July 15, 2024, published in Government Gazette B' 4571.

Mandatory business-to-business electronic invoicing was then introduced by joint decision A.1128, signed on September 16, 2025 by the Deputy Minister of National Economy and Finance, Georgios Kotsiras, and the Governor of the Independent Authority for Public Revenue, Georgios Pitsilis, and published in Government Gazette B' 4937 of September 16, 2025.

The tax authority’s own index records the decision as A.1128/15-09-2025, a one-day discrepancy against the gazette date that is worth noting for anyone citing it.

Article 1(3) of A.1128 divides obliged entities into two periods by reference to gross revenue in the income tax return for financial year 2023. The first period covers entities whose gross revenue exceeded one million euros.

The second period covers all remaining entities. That is the division that makes October 1, 2026 the operative date for the large majority of Greek businesses by number.

The first period did not begin on its originally scheduled date. Decision A.1044 of February 17, 2026, published in Government Gazette B' 880 of the same date, moved the first-period start from February 2, 2026 to March 2, 2026, permitted gradual fulfilment between March 2 and May 3, 2026, and made acceptance by recipients mandatory from March 2, 2026.

The pattern is relevant to how businesses should read the second-period date: Greece has shown willingness to shift a start date by weeks, but it did so by formal amending decision and it did not shift the underlying obligation.

The goods movement obligation runs on a parallel track. Decision A.1122/2024, published in Government Gazette B' 4570, established digital monitoring of goods movements. Its first phase became mandatory on December 1, 2025. Decision A.1094 of April 29, 2026, published in Government Gazette B' 2445 of April 30, 2026, amended A.1122/2024 and set the second-phase dates that concern this update.

The Legislative Change

Both developments are legislative, and both were enacted before the review period covered by KGT’s current reporting cycle.

They are presented here because the obligations they impose take effect within weeks, because the governing decisions have never been covered in these updates, and because in each case the operative date is fixed in the text rather than in an announcement.

On electronic invoicing, Article 2(2) of A.1128 provides that from October 1, 2026, and thereafter, second-period entities must issue exclusively electronic invoices.

It then creates a defined concession: exceptionally, for the period from October 1, 2026, to December 31, 2026, those entities may fulfill the obligation gradually while also using the other channels permitted under decision A.1138/2020 — that is, through an enterprise resource planning system, or by manual or mechanical issue with transmission through the myDATA special entry form.

The concession is conditional. It requires the timely submission of a declaration of commencement of electronic issue of documents under Article 6 of decision A.1112/2025, published in Government Gazette B' 4206, or a declaration of use of an invoicing service provider with a start date no later than October 1, 2026.

That conditionality is the point most likely to be missed. The gradual-compliance window to December 31, 2026, is not an automatic grace period. It is available only to entities that have filed the required declaration in time and with a start date no later than October 1, 2026. An entity that reaches October 1 without having filed is not within the concession.

Scope under A.1128 covers domestic business-to-business transactions, business-to-business transactions with entities in third countries outside the European Union excluding retail, and business-to-government transactions.

On goods movements, A.1094 of April 29, 2026 provides that from October 12, 2026 and thereafter, second-phase data are transmitted mandatorily in respect of loading, transhipment and receipt, together with quantitative and qualitative stock control.

That is Phase B1. It further provides that from January 1, 2027 and thereafter, single item coding under the Combined Nomenclature established by Regulation (EEC) No 2658/1987 applies. That is Phase B2.

A.1094 also closes a transitional arrangement. Paragraph 5.8.4 of circular POL. 1003/2014 ceased to apply from December 1, 2025, with one surviving exception: movement of olive fruit to olive mills, for which it survives until October 11, 2026 — the day before Phase B1 begins.

The only development within the current review window is a clarification rather than a change: on July 28, 2026, the Independent Authority for Public Revenue published circular E.2038 of July 8, 2026, giving clarifications on decisions A.1122/2024 and A.1123/2024 for professional open-market sellers of agricultural products, professional open-market sellers of industrial and handicraft goods, and farmers within the normal value added tax regime, with questions and answers on the digital movement of agricultural products.

Scope

The October 1, 2026, electronic invoicing obligation applies to second-period entities under Article 1(3) of A.1128 — those whose gross revenue, per the income tax return for financial year 2023, did not exceed one million euros.

Because the threshold is fixed to a historical year, an entity’s period is not affected by subsequent revenue movements, and an entity cannot move between periods by growing or shrinking.

Transactions in scope are domestic business-to-business, business-to-business with third-country entities outside the European Union excluding retail, and business-to-government.

Retail transactions are outside the electronic invoicing obligation, though they remain within the wider myDATA framework.

First-period entities — those above one million euros of financial year 2023 gross revenue — have been obliged since March 2, 2026, following the amendment by A.1044, with gradual fulfillment permitted to May 3, 2026.

They are not affected by the October 1 date except in their capacity as recipients, and recipients have been obliged to accept electronic invoices since March 2, 2026.

Format and transmission channels for electronic invoicing are governed by A.1123 of July 15, 2024, published in Government Gazette B' 4571, and are unchanged by these dates.

The October 12, 2026, goods movement obligation, Phase B1, covers loading, transhipment and receipt data together with quantitative and qualitative stock control. First-phase data have been mandatory since December 1, 2025. Phase B2, requiring single item coding under the Combined Nomenclature, follows on January 1, 2027.

Movement of olive fruit to olive mills remains under the old regime of paragraph 5.8.4 of POL. 1003/2014 until October 11, 2026, and comes within the new framework from October 12, 2026.

Timeline

• July 15, 2024 — decision A.1123 published in Government Gazette B' 4571, setting the format and transmission channels for electronic invoicing.
• 2024 — decision A.1122/2024 published in Government Gazette B' 4570, establishing digital monitoring of goods movements.
• September 16, 2025 — joint decision A.1128 signed and published in Government Gazette B' 4937, introducing mandatory business-to-business electronic invoicing in two periods by financial year 2023 gross revenue. The authority’s index records it as A.1128/15-09-2025.
• December 1, 2025 — first-phase goods movement data become mandatory; paragraph 5.8.4 of POL. 1003/2014 ceases, except for olive fruit movement to olive mills.
• February 17, 2026 — decision A.1044 published in Government Gazette B' 880, moving the first-period electronic invoicing start from February 2, 2026 to March 2, 2026.
• March 2, 2026 — first-period entities, those above one million euros of financial year 2023 gross revenue, must issue electronic invoices; acceptance by recipients becomes mandatory.
• May 3, 2026 — end of gradual fulfilment for first-period entities.
• April 29, 2026 — decision A.1094 signed; published in Government Gazette B' 2445 of April 30, 2026, amending A.1122/2024 and setting the second-phase goods movement dates.
• July 8, 2026 — circular E.2038 issued; published by the authority on July 28, 2026, giving clarifications for open-market sellers and farmers in the normal value added tax regime.
• October 1, 2026 — second-period entities must issue exclusively electronic invoices. Gradual fulfilment permitted to December 31, 2026, conditional on timely declaration with a start date no later than October 1, 2026.
• October 11, 2026 — last day on which paragraph 5.8.4 of POL. 1003/2014 applies to movement of olive fruit to olive mills.
• October 12, 2026 — Phase B1 of digital goods movement monitoring becomes mandatory: loading, transhipment and receipt data, plus quantitative and qualitative stock control.
• December 31, 2026 — end of the gradual fulfilment concession for second-period entities.
• January 1, 2027 — Phase B2: single item coding under the Combined Nomenclature established by Regulation (EEC) No 2658/1987.

Businesses Affected

By number of entities, the October 1, 2026 date affects far more Greek businesses than the March 2026 date did. Second-period entities are those at or below one million euros of financial year 2023 gross revenue, which in the Greek economy is the substantial majority.

Multinationals will mostly have Greek entities in the first period and will therefore already be live, but groups frequently hold smaller Greek entities — dormant companies, small service entities, recently acquired businesses, branches with modest turnover — that fall into the second period and that nobody has scoped.

That is the specific risk this update is intended to surface. A group that completed its Greek electronic invoicing project for March 2026 may have scoped only the entities then in scope.

Any Greek entity that was excluded from that project on threshold grounds is now in scope from October 1, 2026, and needs a declaration filed with a start date no later than that day if it wants the gradual fulfilment concession.

Recipients are affected in both directions. Acceptance has been mandatory since March 2, 2026, so a business already accepting electronic invoices needs no change, but from October 1 the volume and the range of counterparties issuing electronically expands materially.

On goods movements, businesses moving physical goods in Greece are affected by Phase B1 from October 12, 2026, and the obligation reaches loading, transhipment and receipt as distinct events plus stock control. This is a warehouse and logistics obligation as much as a tax one, and it typically sits outside the finance function’s systems.

Businesses in agricultural supply chains are affected by circular E.2038 and, in the specific case of olive fruit movement to olive mills, by the expiry of the old regime on October 11, 2026.

Businesses moving goods should note Phase B2 on January 1, 2027 separately: Combined Nomenclature item coding requires commodity codes at item level, which many enterprise systems hold incompletely.

Required Actions

• Identify every Greek entity in your group and determine its period under Article 1(3) of A.1128 by reference to gross revenue in the financial year 2023 income tax return. Do not assume that a project completed for March 2026 covered them all.
• For every second-period entity, file the declaration of commencement of electronic issue under Article 6 of decision A.1112/2025, or the declaration of use of an invoicing service provider, with a start date no later than October 1, 2026. Without a timely declaration, the gradual fulfillment concession to December 31, 2026 is not available.
• Treat the concession as conditional, not automatic. This is the single most consequential misunderstanding available on these facts.
• Confirm that the invoicing format and transmission channel comply with decision A.1123 of July 15, 2024, and that the unique registration mark is captured and retained on transmitted documents.
• Scope Phase B1 of goods movement monitoring for October 12, 2026, as a logistics project, not a tax project. Loading, transshipment, and receipt are warehouse events, and the data has to come from whatever system records them.
• Assess quantitative and qualitative stock control reporting against your current inventory data. This is the element most likely to require new data capture rather than new reporting.
• Begin the Combined Nomenclature item coding exercise now for Phase B2 on January 1, 2027. Populating commodity codes at item level across a material master is a data project with a long tail and it cannot be compressed into December.
• If you operate in agricultural supply chains, review circular E.2038 of July 8, 2026 for the clarifications on open-market sellers and farmers in the normal value added tax regime.
• If you move olive fruit to olive mills, diarize October 11, 2026 as the last day of the old regime under paragraph 5.8.4 of POL. 1003/2014.
• Watch for a further amending decision. Greece moved the first-period date by a month through decision A.1044, and a comparable adjustment to the October 1 date is possible — but it would come as a published decision, and planning on the assumption of one is not prudent.

Practical Implications

The most useful observation about Greece is that its obligations arrive by published decision on dates fixed months or years earlier, and consequently attract very little attention in the weeks when they actually matter.

Nothing was announced this summer about October 1 or October 12, because everything that needed to be said was said in September 2025 and April 2026. An organization whose monitoring is driven by news flow will see nothing, and will then be late.

The conditional nature of the gradual fulfilment concession deserves emphasis because it inverts the usual expectation. In most jurisdictions a transitional period is a default that applies to everyone.

Here it is a benefit that must be claimed in advance, by filing a declaration with a start date no later than the day the obligation begins. An entity that intends to rely on the transition and does nothing has, by doing nothing, forfeited it.

The two dates falling twelve days apart is an operational problem in its own right for businesses that both invoice and move goods. October 1 requires an invoicing change and October 12 requires a logistics data change, and the two typically sit with different functions, different systems and different vendors.

Sequencing them into a single autumn is tight, and the second is the one more likely to slip because it does not look like a tax obligation.

Phase B2 on January 1, 2027 is the sleeper. Item-level Combined Nomenclature coding is conceptually simple and practically laborious: it requires a commodity code against every item that moves, and in most material masters that field is populated for customs-relevant goods and empty elsewhere.

Organizations that treat Phase B2 as a reporting configuration rather than a master data programme will find the reports cannot be produced.

Finally, the one-day discrepancy between the authority’s index entry for A.1128 and the gazette date, and the amendment of the first-period date by A.1044, together make the point that Greek references should be taken from the gazette text rather than from an index or a summary. Where a Greek position matters, the operative source is the Government Gazette publication of the decision.

Expected Next Steps

A further amending decision adjusting the October 1, 2026 date cannot be ruled out, on the precedent of decision A.1044 which moved the first-period date by a month. Any such change would be published in the Government Gazette, and organizations should monitor the authority’s myDATA provisions index rather than relying on secondary reporting.

Further clarifying circulars should be expected in the run-up to October 1 and October 12, 2026, on the pattern of circular E.2038. Greece has consistently supplemented its decisions with sector-specific clarifications.

Technical guidance and specification updates for Phase B1 should be expected, particularly on the data content of loading, transhipment and receipt events and on quantitative and qualitative stock control.

Guidance on Combined Nomenclature item coding for Phase B2 should be expected ahead of January 1, 2027, and would be the point at which the practical scope of the coding requirement becomes clear.

Greece will also need to address the transposition of Council Directive (EU) 2025/516 for the January 1, 2027 provisions, and no Greek instrument on that has been identified. KGT will report separately on any Greek ViDA transposition, on further amending decisions, and on the practical operation of the October 2026 obligations.

How Can KGT Support You?

KGT is a specialist indirect tax technology firm. Our SAP-integrated e-invoicing and e-reporting add-ons generate, validate, and transmit country-compliant structured documents directly from SAP ECC and SAP S/4HANA, keeping tax determination, document mapping, status handling and the audit trail inside the system of record rather than in a downstream converter. Because the add-ons validate against the current national schemas, schematrons and code lists before transmission, a change of specification version becomes a configuration and regression-test exercise rather than a redesign.

We also deliver SAP Document and Reporting Compliance (DRC) services end to end: fit-gap assessment against the national mandate, activation and configuration of the relevant country versions, eDocument and eStatement setup, interface and connectivity design, master and transactional data remediation, test strategy including negative testing against the authority’s own validation artifacts, and post-go-live monitoring of rejections and status reconciliation. If you would like a readiness review against the developments described above, or an impact assessment for your SAP landscape, we would be glad to help.

Official sources

• Independent Authority for Public Revenue, myDATA relevant provisions index: View source
• Joint decision A.1128, Government Gazette B' 4937 of 16.09.2025 (mandatory B2B electronic invoicing, two periods): View source
• Decision A.1044, Government Gazette B' 880 of 17.02.2026 (first-period start moved to 2 March 2026): View source
• Decision A.1094 of 29.04.2026, Government Gazette B' 2445 of 30.04.2026 (Phase B1 from 12 October 2026, Phase B2 from 1 January 2027): View source
• Independent Authority for Public Revenue, circular E.2038 of 08.07.2026: View source
• Independent Authority for Public Revenue, circular E.2038 of 08.07.2026 (document): View source
• Independent Authority for Public Revenue, myDATA portal: View source
• National Printing House, Government Gazette: View source
• EUR-Lex, Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common Customs Tariff: View source

This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.