The recently issued decisions A.1128/2025 and A.1129/2025, define the scope and method of implementation, as well as the commencement date of the mandatory Electronic Invoicing (E-Invoicing).
Scope
According to the provisions of the Greek Accounting Standards (“GAS”), entities subject to this law are required to issue an Invoice for every sale of goods and provision of services.
Additionally, an Invoice is also issued for the following transactions:
- Purchases from persons not obliged to issue invoices (not liable entities).
- Purchases from entities who, for any reason, do not issue an invoice.
- Sales on behalf of third parties.
The Invoice is issued exclusively electronically for transactions:
a) Within the country, to a liable entity (wholesale transactions/B2B)
b) To a foreign entity, outside the European Union (wholesale transactions with a third country outside the EU/B2B)
c) Transactions with the public sector (public contracts, expenses of General Government entities/B2G).
E-Invoices are issued exclusively through the use of E-Invoicing Providers' services or the application provided by the Independent Authority of Public Revenue (IAPR) for issuing and transmitting invoices ("Timologio").
Entry into force
Mandatory E-Invoicing will be implemented gradually in two phases and a transitional period is also provided:
First Phase
Entities with turnover exceeding one million Euro (€1,000,000) for the fiscal year 2023:
- Start of mandatory implementation from 2.2.2026
- Transitional period from 2.2.2026 to 31.3.2026
Second Phase
Entities not included in the first phase:
- Start of mandatory implementation from 1.10.2026
- Transitional period from 1.10.2026 to 31.12.2026
From the commencement of the mandatory implementation, entities based on the Phase that they belong to, are obliged to issue exclusively E-Invoices for every sale of goods and provision of services for categories (a) to (c), including transactions in subcategories (i) to (iii).
During the transitional period of each phase, there is the option to gradually fulfil the aforementioned obligation, while using the other methods of issuing and transmitting invoices that are currently into force. This is on the condition that the Declaration of commencement for an E-Invoicing Provider or Timologio application has been submitted by the date of mandatory implementation (2.2.2026 or 1.10.2026).
Other matters
As of 2.2.2026 the use of E-Invoicing, for domestic transactions (B2B and B2G), becomes compulsorily acceptable by the recipient (subject to specific exemptions for public contracts and the invoicing to entities of General Government).
In order to fulfill the obligation to issue E-Invoices, entities have the option to use one or more E-Invoicing Providers and at the same time or independently use of Timologio application. This obligation may also be fulfilled exclusively by using Timologio application.
Early adoption incentives
Decision A.1129/2025 defines the terms and conditions for granting incentives to entities that choose to implement E-Invoicing two months earlier than each mandatory implementation deadline (i.e. by 1/12/2025 for the first phase and by 3/8/2026 for the second phase).
The incentives provided are:
- For the purchase of technical equipment and software, full and enhanced (by 100%) depreciation in the year incurred,
- For the expense of generating, transmitting, and electronically archiving Electronic Invoices, a super-deduction with a 100% increase for the first twelve (12) months.
