The Independent Authority for Public Revenue (AADE) has published comprehensive guidance for Phase 2 of mandatory B2B electronic invoicing in Greece, effective January 1, 2027. The guidance, released October 1, 2026 via Circular A.1197/2026 and Decision 5338/2026, expands the e-invoicing obligation to all VAT-registered businesses regardless of turnover, following the Phase 1 rollout that covered businesses with annual turnover exceeding €500,000. Phase 2 introduces a detailed implementation timeline: (1) January 1, 2027 – mandatory issuance and receipt of e-invoices for all B2B transactions; (2) April 1, 2027 – mandatory use of structured e-invoice format (UBL 2.1) via certified providers; (3) July 1, 2027 – real-time reporting of invoice data to myDATA platform within 24 hours of issuance; (4) October 1, 2027 – full integration with the EU’s ViDA (VAT in the Digital Age) framework for cross-border e-invoicing. The guidance includes 15 practical examples covering scenarios such as advance payments, credit notes, self-billing, triangulation transactions, and reverse charge mechanisms. A dedicated FAQ section addresses 47 common questions on technical specifications, provider certification, archival requirements (10 years), and interplay with existing myDATA obligations. Penalties for non-compliance are tiered: €500 per missing e-invoice for first offense, €1,500 for repeat offenses, and 10% of the transaction value (minimum €3,000) for systematic non-compliance. Businesses must select a certified e-invoicing provider from AADE’s registry by November 30, 2026. The guidance also clarifies that paper invoices remain valid only for B2C transactions and specific exempted sectors (healthcare, education, financial services). AADE will conduct a pilot program with 500 volunteer businesses from November 2026 to test end-to-end processes.
Key Takeaways
- Universal B2B E-Invoicing Mandate from Jan 1, 2027: All VAT-registered businesses must issue and receive structured e-invoices (UBL 2.1) for B2B transactions, regardless of turnover. Paper invoices prohibited for B2B after December 31, 2026.
- Phased Implementation with Four Milestones: Key dates: Jan 1, 2027 (mandatory issuance), Apr 1, 2027 (structured format), Jul 1, 2027 (24-hour myDATA reporting), Oct 1, 2027 (ViDA cross-border integration). Businesses must onboard certified provider by Nov 30, 2026.
- Tiered Penalty Framework: €500 per missing e-invoice (first offense), €1,500 (repeat), 10% of transaction value minimum €3,000 (systematic non-compliance). 10-year archival requirement applies to both issuer and recipient.
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