On 22 September 2026, AADE issued Circular 1098/2026 providing detailed clarifications on the mandatory “Declaration of Start of Use” (Δήλωση Έναρξης Χρήσης) for the timologio and myDATAapp applications, which are the certified software solutions for B2B and B2G e-invoicing under the myDATA framework. The declaration must be submitted electronically through the myAADE portal within 10 calendar days of the first invoice issuance via the app. The circular specifies that businesses using multiple certified providers must file a separate declaration for each. It also addresses scenarios such as switching providers, temporary cessation of activity, and the obligations of tax representatives for non-resident entities. Failure to submit the declaration results in a €500 fine per omission, and invoices issued without a registered start-of-use declaration are considered non-compliant for VAT deduction purposes. AADE also released an updated user guide (v4.1) with screenshots and FAQs.
Key Takeaways
- Mandatory 10-Day Window: The declaration is a prerequisite for legal validity of e-invoices; late submission incurs automatic penalties and jeopardizes VAT recoverability for counterparties.
- Multi-Provider Management: Companies using both timologio (for B2G) and myDATAapp (for B2B) must file two distinct declarations, each linked to the respective provider’s certification code.
- Tax Representative Obligations: Non-established taxable persons must ensure their Greek tax representative files the declaration on their behalf, with joint liability for omissions.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement
