Small businesses in Greece must e-invoice from 2 November 2026; old methods may run alongside until 31 January 2027, but only with a declaration

From 2 November 2026, businesses in Greece with gross income up to €1 million must issue their invoices to other businesses and to the public sector only as electronic invoices ¹ΕΛ². The rule is set by joint decision Α.1197/2026, published in the Government Gazette (ΦΕΚ, Εφημερίδα της Κυβερνήσεως, Efimerida tis Kyverniseos) on 30 September 2026 ¹. Until 31 January 2027 these businesses may keep their old invoicing methods running alongside, but only if they filed a declaration with a start date no later than 2 November 2026 ¹ΕΛ. Sales to consumers are not covered ⁶⁷.

This guide is for small firms, freelancers and expats who run a business in Greece and invoice other businesses.

What changes on 2 November 2026?

Decision Α.1197/2026 is signed by the deputy minister of national economy and finance, Dimitrios Markopoulos, and by Georgios Pitsilis, governor of ΑΑΔΕ (Ανεξάρτητη Αρχή Δημοσίων Εσόδων, Anexartiti Archi Dimosion Esodon), the Independent Authority for Public Revenue, which runs Greece's tax administration ¹. It rewrites Article 2(2) of an earlier decision, Α.1128/2025, which sets the scope and start of e-invoicing under Article 14 of law 4308/2014, the Greek Accounting Standards (Ελληνικά Λογιστικά Πρότυπα, ΕΛΠ, Ellinika Logistika Protypa) ¹. Decision Α.1197/2026 applies from its publication on 30 September 2026 ¹.

From 2 November 2026, "second-period" businesses must issue "exclusively" an electronic invoice for every sale of goods and services in scope, in our translation ¹ΕΛ. The second period covers businesses that declared gross income up to €1,000,000 in the tax year that started in 2023, according to ΑΑΔΕ's release of 30 September 2026 ². Decision Α.1197/2026 does not restate that threshold itself ¹.

The second period was originally due to start on 1 October 2026, with gradual compliance until 31 December 2026 ⁴⁶⁷. Decision Α.1197/2026 gives its reason as the need to move the start date "so that sufficient time is given for the necessary technical implementations", in our translation ¹.

Which invoices are covered?

The e-invoicing obligation covers three kinds of sale, according to EY's summary of the rules and ΑΑΔΕ's release ⁴²:

• sales within Greece to entities subject to the Greek Accounting Standards (B2B) ⁴;
• sales to businesses in countries outside the European Union, except retail sales ⁴²;
• public contracts and other spending by general-government bodies (B2G) ⁴².

The obligation also covers invoices a business issues itself in place of the seller: when it buys from someone not obliged to invoice, when the seller refuses to issue an invoice, and when it issues a settlement (εκκαθάριση, ekkatharisi) ⁴.

Retail (B2C) sales to consumers are not covered by mandatory e-invoicing ⁶⁷. E-invoices to businesses in other EU countries are optional, not mandatory ⁷.

Does it apply to freelancers and expat-run businesses?

Decision Α.1197/2026 applies to every obliged second-period entity and does not mention sole traders or freelancers separately ¹. Taxheaven's guide of 1 October 2026 says freelancers who invoice businesses or the public sector fall under the obligation, while their retail sales stay outside it ⁶. Decision Α.1197/2026 does not distinguish businesses by the nationality of their owners ¹.

How do you issue an e-invoice?

From 1 February 2027, invoices to businesses in Greece and outside the EU, and to the public sector, must be issued and their data sent to the myDATA platform only through an e-invoicing provider (Πάροχος Ηλεκτρονικής Τιμολόγησης, Parochos Ilektronikis Timologisis) or ΑΑΔΕ's timologio and myDATAapp applications ². myDATA is ΑΑΔΕ's digital platform (ψηφιακή πλατφόρμα, psifiaki platforma) to which invoice data are transmitted ². timologio and myDATAapp are free ΑΑΔΕ applications ⁶⁹.

ΑΑΔΕ said on 30 September 2026 that 655,000 businesses, almost 70% of those potentially in the second period, already used a provider or timologio or myDATAapp for wholesale transactions ²³.

What does the window to 31 January 2027 allow?

From 2 November 2026 to 31 January 2027 inclusive, second-period businesses may meet the e-invoicing obligation gradually and keep using their old methods in parallel ¹ΕΛ. Those old methods are invoicing software such as an ERP, or handwritten or computer-made invoices sent through a special entry form on ΑΑΔΕ's website ¹. The window from 2 November 2026 to 31 January 2027 lasts 91 days, by our calculation ¹.

The window to 31 January 2027 does not delay the obligation: it is open only to businesses that filed a declaration with a start date no later than 2 November 2026. ¹

The window to 31 January 2027 has a condition ¹ΕΛ. A business must have filed either a timely start declaration for electronic issuing (Δήλωση Έναρξης Ηλεκτρονικής Έκδοσης Στοιχείων, Dilosi Enarxis Ilektronikis Ekdosis Stoicheion), which is the provider route, or a declaration of use of ΑΑΔΕ's timologio application ¹. In both cases the start date must be no later than 2 November 2026 ¹. ΑΑΔΕ says businesses using a provider must file the start declaration with a start date of 2 November 2026 ². It also says businesses that issue all their invoices through timologio or myDATAapp from 2 November 2026, and do not need the window, need not file a declaration ²⁶.

From 1 February 2027, only a provider, timologio or myDATAapp may be used for these invoices ².

What happens if you file no declaration?

Decision Α.1197/2026 contains no waiver of penalties ¹. ΑΑΔΕ's circular Ε.2004/2026 of 13 February 2026 treats invoicing outside the permitted routes, for example by hand or from an ERP, as not issuing an invoice at all, except when the connection is lost, according to EY and Taxheaven ⁴⁶. The penalties then come from Article 57, paragraphs 5 and 6, of law 5104/2024, the Tax Procedure Code (Κώδικας Φορολογικής Διαδικασίας, ΚΦΔ, Kodikas Forologikis Diadikasias) ⁴⁶.

Taxheaven's guide says parallel use of an ERP is allowed only with a timely declaration, and that otherwise the ERP may serve only as a bookkeeping tool ⁶. By our reading, a business without a declaration that keeps invoicing from an ERP after 2 November 2026 would face those penalties, because the decision's parallel window is open only to businesses that filed one ¹⁴.

How large are the fines?

EY's February 2026 tax alert sets out the fines under circular Ε.2004/2026 for both single-entry (απλογραφικά, aplografika) and double-entry (διπλογραφικά, diplografika) books ⁴. Taxheaven's guide gives the same figures ⁶.

For a transaction with VAT, the fine is 50% of the VAT that the missing invoice would have carried, with a minimum of €250 for single-entry books and €500 for double-entry books per audit, according to EY and Taxheaven ⁴⁶. A repeat breach raises the rate to 100%, and each further repeat to 200%, according to EY and Taxheaven ⁴⁶.

What is the timeline for larger businesses?

Businesses with gross income above €1 million form the "first period" ⁴. They have had to issue only e-invoices since 2 March 2026, instead of the 2 February 2026 originally planned, under decision Α.1044/2026 (ΦΕΚ Β' 880/17.02.2026) ⁴⁵. Their gradual-compliance window ran from 2 March to 3 May 2026 ⁴⁵.

The same Government Gazette issue of 30 September 2026 also carries decision Α.1198/2026 on digital delivery notes, which sets 1 January 2027 for the next phase of reporting goods movements and 1 January 2028 for unified product coding ¹.

What should you do now?

1. Check whether you are in the second period. It covers businesses with gross income up to €1,000,000 in the tax year that started in 2023 ².
2. Check what you sell. Invoices to Greek businesses, to businesses outside the EU and to the public sector are covered; retail receipts are not ⁴⁶.
3. Choose a route. Use an e-invoicing provider, or ΑΑΔΕ's free timologio or myDATAapp ²⁶.
4. Decide whether you need the window. If you want to keep your ERP or handwritten invoices running alongside after 2 November 2026, a start declaration or a timologio usage declaration must be filed with a start date no later than 2 November 2026 ¹.
5. If you use a provider, file the start declaration with a start date of 2 November 2026, as ΑΑΔΕ asks ².
6. Move everything to e-invoices before 1 February 2027, when only a provider, timologio or myDATAapp may be used ².
7. Ask if unsure. ΑΑΔΕ's my1521 service answers on 1521 on weekdays from 7:00 to 20:00, or online ²³.

Both dates are on our key dates page.