Mandatory e-invoicing

Pursuant to the Joint Decision 1128/2025 of the Deputy Minister of Economy and Finance and the Governor of the Independent Authority for Public Revenue (“IAPR”) as well as to the Decision 1129/2025 of the Governor of the IAPR, the framework for the implementation of mandatory e-invoicing, as well as the procedure and timeline for submitting the relevant declarations are defined.

1.  Mandatory e-invoicing

• The Decision 1128/2025 specifies the scope of application, the effective date, and all other necessary issues for the implementation of mandatory e-invoicing.
  
  
• According to art.14 of the Greek GAAP (L.4308/2014), as amended by L.5222/2025, e-invoicing becomes mandatory for every sale of goods and provision of services by entities subject to the provisions of the Greek GAAP:
  
  - within the Greek territory, to entities subject to the Greek GAAP (wholesale transactions / B2B),
  - to a foreign entity, based outside of the European Union, except for retail transactions (wholesale transactions with non-EU countries / B2B),
  - for transactions relating to public contracts, as well as the invoicing of other expenditures to General Government, unless other special provisions are applicable (B2G).
  
  
• The above obligation also applies in case of transactions:
  
  - with persons non-liable to issue an invoice, or
  - with persons who refuse to issue an invoice, or  
  - where a “clearance note” is issued.
  
  
• For the above transactions, e-invoices shall be issued exclusively through:
  
  - either an e-invoicing Licensed Provider, or
  - the relevant application hosted in IAPR website (“timologio”).

2.  Implementation timeline of mandatory e-invoicing

Based on the Decision 1128/2025, the periods and timeframe for the commencement of mandatory e-invoicing are defined as follows:

3. Incentives for the early adoption of e-invoicing

According to Article 71Θ "Incentives to entities for the early adoption of e-invoicing" the Income Tax Code (Law 4172/2013, "ITC"), the incentives for entities that opt for the early implementation of e-nvoicing are defined. Specifically:

• For entities which opt for e-invoicing for the exclusive issuance of their tax documents for transactions subject to the mandatory e-invoicing, prior to its mandatory implementation, the following incentives are provided:

        -     the expense for the initial procurement of technical equipment and software required for the implementation of e-invoicing is fully depreciated in the year incurred, increased by 100% and

        -     the expense for the production, transmission and electronic archiving of e-invoices for the first 12 months of issuance of sales invoices through e-invoicing, which is tax deductible from gross business income, is increased by 100% in the year incurred.

• Article 71Θ is not applicable for entities that benefited from the incentives of article 71ΣΤ of the ITC “Incentives for the implementation of e-invoicing”.
  
  
• The above incentives are not granted or are withdrawn in the event of:

       -     revocation of the declaration for the use of e-invoicing, or

    -     issuance of an invoice without the use of e-invoicing Licensed Provider or the relevant application hosted in IAPR website, prior to the commencement of the mandatory e-invoicing despite the relevant declaration.

• For the proper transition to the e-invoicing regime and the application of the incentives provided for expenses incurred from the tax year 2025 onwards, the liable entities should issue exclusively e-invoices and should timely submit the relevant declarations of e-invoicing adoption, in accordance with the following deadlines:

• The above incentives are also granted to liable entities, which have already submitted a declaration for the adoption of e-invoicing through the use of a Licensed Provider and the exclusive adoption of e-invoicing for the relevant transactions has commenced within 2025 and prior to 01.12.2025.