Greece postpones second-wave mandatory e-invoicing to 2 November

Who is affected

A.1197/2026 replaces Article 2(2) of Joint Decision A.1128/2025. The second implementation group comprises businesses within the Greek Accounting Standards framework that are not in the first wave—principally entities whose gross revenue did not exceed €1 million, based on the income-tax return for the tax year beginning in 2023.^[1][2][3]

The mandate covers invoices for domestic business-to-business transactions, wholesale supplies to entities outside the EU other than retail transactions, and business-to-government transactions. The underlying authority is Article 14 of Law 4308/2014 on Greek Accounting Standards, as expanded by Article 239 of Law 5222/2025. The amending decision took legal effect when published in Government Gazette B’ 5905 on 30 September 2026.^[2][3]

Revised timetable and permitted systems

Affected second-wave businesses must begin issuing electronic invoices from 2 November 2026. Between that date and 31 January 2027, they may phase in compliance while continuing to use commercial or accounting ERP systems, manual or computerised invoicing, and transmission through AADE’s special electronic-books form.^[2]

That transitional treatment is conditional. The business must make a timely declaration commencing electronic issuance under Article 6 of Decision A.1112/2025, or declare use of AADE’s timologio application, with the relevant services starting no later than 2 November 2026.^[2]

After the transition, A.1128/2025 requires in-scope invoices to be issued through an authorised electronic-invoicing service provider or AADE’s timologio application. A standalone ERP is among the temporary alternatives permitted during the transition, rather than one of the two prescribed electronic-issuance routes.^[2][3]

Practical consequence

Groups with Greek entities outside the greater-than-€1 million first wave now have until 2 November to start mandatory implementation and a transition ending on 31 January 2027. The amendment changes the timetable, not the transaction scope. Businesses should use the additional period to complete provider or AADE-application onboarding, submit the required declaration and test invoice flows for domestic B2B, non-EU wholesale B2B and government customers.^[2][3]