Compliance · Facts last checked: 28/8/2026 · Reviewed monthly until 1/1/2027

E-invoicing & myDATA 2026: what changes for hospitality from 1 October

Mandatory B2B e-invoicing has already begun for large businesses. On 1/10/2026 every remaining business joins them on the issuing side. Here is exactly what the decisions provide for, with references to the official texts.

The essentials, briefly

Electronic invoices are already reaching you

Large businesses have been issuing electronically since March 2026, so part of your documents already arrives in structured form. Today's question is not when you start issuing, but what you do with what you already receive.

Penalty: 50% of the VAT per document, with minimums per audit

Issuing by a method not provided for counts as non-issuance (article 57 of law 5104/2024, circular Ε.2004/2026): 50% of the VAT per document identified during an audit, with a minimum of €250 (single-entry) or €500 (double-entry) cumulative per audit. 100% on a repeat offence, 200% on a further repeat.

Two dates, not one

2/3/2026 for revenue above €1m (tax year 2023) · 1/10/2026 for everyone else, with room for phased application until 31/12/2026 and a timely declaration by 12/10/2026.

It concerns wholesale, not your dining room

B2B within Greece, wholesale to third countries outside the EU, and transactions with General Government bodies not already covered under law 4601/2019. Retail to private individuals is exempt from the e-invoice obligation — but not from transmission to myDATA.

Two lawful routes to issue

A licensed Electronic Document Issuance Provider, or AADE's free applications (timologio, myDATAapp). For invoicing the public sector the framework of law 4601/2019 also applies.

A possible extension

An extension moving the start to 1 March 2027 cannot be ruled out; the market is pressing for one. Until a decision is taken, 1/10/2026 stands. This page is kept updated.

The amounts and deadlines here are informational and do not replace tax advice. Before you decide anything — especially about penalties and incentives — confirm it with your accountant. Facts last checked: 28/8/2026.

E-invoicing and myDATA — what the difference is

This is the number one confusion. They are not the same thing and they do not start at the same moment.

myDATA (AADE's electronic books)

  • • Where your data goes: every document is transmitted to AADE.
  • • Already in force, for wholesale and retail.
  • • Every document receives a MARK — its unique identity as far as the state is concerned.
  • • The receipt at your table is transmitted too; it is not exempt.

E-invoicing

  • • How the invoice is produced: in a structured electronic format, not on paper or as a plain PDF.
  • • Mandatory in wholesale: 1/10/2026 for most businesses.
  • • First-period businesses have been issuing electronically since 2/3/2026.
  • • Through a licensed e-invoicing provider or AADE's free timologio application.
  • • Transmission to myDATA happens automatically along the same route.

Official timeline

As set out in decisions Α.1128/2025 (Gazette Β΄4937/16.9.2025) and Α.1044/2026 (Gazette Β΄880/17.2.2026) and in circular Ε.2004/2026. The status of each step is calculated automatically against today's date.

  1. 16/9/2025 (Gazette)

    In force

    Α.1128/2025 — decision of 15/9/2025, Gazette Β΄4937/16-09-2025

    The joint decision of the Deputy Minister of National Economy and the Governor of AADE setting the scope of application and two commencement periods, on the basis of article 14 of the Greek Accounting Standards (law 4308/2014) as added by article 239 of law 5222/2025.

  2. 2/3/2026

    In force

    First period: revenue above €1,000,000

    Applies to businesses with gross revenue above €1m based on the income tax return for tax year 2023. For entities whose tax year did not end on 31.12.2023, the return for the tax year that began during 2023 is taken. The date was moved from 2/2/2026 by Α.1044/2026 (Gazette Β΄880/17.2.2026).

  3. 2/3/2026

    In force

    Electronic invoices start arriving from suppliers

    From this date first-period businesses issue electronically, so your own incoming invoices begin arriving in structured form. When your own receiving obligation formally arises is for your accountant to confirm.

  4. 2/3 – 3/5/2026

    Passed

    Phased application, first period

    Parallel use of an ERP/commercial-accounting system or of a special entry form, provided a timely declaration of commencement of electronic issuance had been submitted with effect from 2/3/2026.

  5. 1/8/2026

    Passed

    Declaration deadline for the article 71Θ incentives — now passed

    This was the deadline (2 months before the obligation began) for the incentives of article 71Θ of law 4172/2013 to apply. Anyone who missed it loses the tax incentives, not the ability to comply: the compliance declaration is still submitted as normal by 12/10/2026.

  6. 1/10/2026

    Upcoming

    Second period: all remaining businesses

    This is where the overwhelming majority of restaurants, bars, cafés and small and medium hotels fall — essentially every business outside the first period. From this date a wholesale invoice is issued exclusively in electronic form. AADE is already sending bulk notifications to those covered.

  7. By 12/10/2026

    Upcoming

    Timely declaration of commencement of electronic issuance

    The declaration is submitted through myDATA with a start-of-use date no later than 1/10/2026 and is timely if submitted by 12/10/2026. Failure to submit, or late submission, attracts the penalties of the Tax Procedure Code; a fine of €2,500 is cited for non-submission or inaccurate details.

  8. 1/10 – 31/12/2026

    Upcoming

    Phased-compliance window

    Parallel use of the other methods of issuance/transmission is permitted, but only where a timely “Declaration of Commencement of Electronic Document Issuance” or a Declaration of Use of the timologio application has been submitted, with a start date no later than 1/10/2026.

  9. 1/1/2027

    Upcoming

    Full application, with no parallel routes

    Every wholesale document is issued electronically, through a Provider or through AADE's applications. The other methods of issuance no longer satisfy the obligation.

The article 71Θ incentives: what they mean in euros

The cost of e-invoicing equipment and software is deducted with a 100% uplift: you declare twice the cost you actually paid. The uplift applies to the deduction from taxable profits, not to the price itself. Basis: article 71Θ of law 4172/2013 & decision Α.1129/2025, for costs from tax year 2025 onwards.

The real benefit in euros depends on your legal form and your tax rate — a company is one thing, a sole trader on progressive rates is another. We do not publish a worked example with figures: ask your accountant to calculate it for your own case.

  • The initial cost of acquiring equipment and software is depreciated in full within the year, with a 100% uplift.
  • The cost of producing, transmitting and electronically archiving documents for the first 12 months is increased by 100% when deducted.
  • Condition: a declaration of use of a provider or of AADE's application at least 2 months before the obligation begins — for the second period, by 1/8/2026, a deadline that has already passed. Anyone who missed it loses the incentives, not the ability to comply. They do not apply to those who used article 71ΣΤ.

What it means in practice for a restaurant or hotel

The change solves the problem of receiving the document. It does not solve the problem of cost.

What solves itself

  • • The invoice arrives in structured form, not as scanned paper.
  • • VAT number, date, number, MARK and totals arrive ready.
  • • Fewer reading errors, less typing in the office.
  • • Your accountant sees the document without chasing it out of the kitchen.

What remains your problem

  • • Every supplier carries on naming the same product differently. E-invoicing standardises the envelope, not the naming of the items.
  • • Nobody tells you the price of oil went up 14% in March.
  • • Nobody compares the cost of the same item across your sites.
  • • The stocktake and the month-end close remain your job.

From 1/10/2026 you will receive more data, faster. If your item catalogue is a mess today, it will be a mess at higher speed afterwards.

Statutory deadlines

Dates set by AADE's decisions — not recommendations of ours.

  1. 1.From 2/3/2026: first-period businesses (revenue above €1m) issue electronically.
  2. 2.1/10/2026: the issuing obligation begins for the second period, that is for all remaining businesses.
  3. 3.By 12/10/2026: timely submission of the Declaration of Commencement of Electronic Document Issuance or of the Declaration of Use of timologio, with a start date no later than 1/10/2026. Without it you lose the phased-application window and risk the penalties of the Tax Procedure Code.
  4. 4.1/10 – 31/12/2026: the phased-compliance window, with parallel use of other methods of issuance.
  5. 5.1/1/2027: full application, with no parallel routes.

Our own recommended schedule

Not required by any decision. This is the order in which we see preparation actually work in practice.

  1. 1.Immediately: check which period you fall into — tax year 2023 revenue above or below €1,000,000.
  2. 2.Immediately: make sure you can receive and handle electronic invoices from your suppliers.
  3. 3.At least 4 weeks before the start: choose your route — a licensed provider or AADE's free application. Ask your accountant which suits your volume.
  4. 4.At least 3 weeks before: record which of your suppliers already issue electronically and which do not.
  5. 5.At least 2 weeks before: merge your duplicated suppliers and clean up the item catalogue, so that you are comparing prices and not names.
  6. 6.Before the start: make sure the purchase history from before the change stays in the same system as what comes after.

Frequently asked questions

E-invoicing and myDATA: what is the difference?

They are two different things and are constantly confused. myDATA is AADE's electronic books: that is where you transmit the data from your documents and receive a MARK — this already applies to everyone, wholesale and retail. E-invoicing is the method of issue: a wholesale invoice is issued in a structured electronic format through a licensed e-invoicing provider or AADE's free timologio application, and is transmitted automatically to myDATA. Put simply: myDATA is where the data goes, e-invoicing is how the invoice is produced.

I mainly receive invoices. Does anything affect me today, before 1/10/2026?

In practice yes. Large suppliers (revenue above €1m) have been issuing electronically since March 2026, so a restaurant or hotel is already receiving such documents today and must be able to handle them. When your own receiving obligation formally arises depends on which period you fall into — confirm it with your accountant.

What is the MARK and why does it matter to me?

MARK is the Unique Registration Number that myDATA assigns to every document transmitted to AADE. It is the invoice's identity as far as the state is concerned: without a MARK your accountant cannot reliably match the document against the books. Deductibility of the expense is judged on its own conditions, but matching becomes far harder when it is missing.

From when is e-invoicing mandatory for my business?

If your gross revenue exceeds €1,000,000 (based on the income tax return for tax year 2023 — and for those whose accounting period did not close on 31.12.2023, the tax year that began during 2023), the obligation has applied since 2/3/2026. For all other businesses — that is, the great majority of restaurants, bars and small hotels — the obligation starts on 1/10/2026, with the option of phased application until 31/12/2026.

By when must I submit the declaration of commencement of electronic issuance?

The declaration is submitted through myDATA with a start-of-use date no later than 1 October 2026, and is considered timely if submitted by 12 October 2026. Note: that is the deadline for compliance. The deadline for the tax incentives under article 71Θ was different and earlier (2 months before the obligation begins, that is 1/8/2026). Failure to submit, or late submission, attracts the penalties provided for by the Tax Procedure Code, while a fine of €2,500 is cited for non-submission or inaccurate details. Confirm the exact amount with your accountant.

Which transactions does it cover?

Wholesale within Greece to another entity (B2B), wholesale to an entity in a third country outside the EU, and transactions with General Government bodies for which no e-invoicing obligation already exists under law 4601/2019 (part of B2G was already covered). Retail to private individuals — that is, the customer at your table — is exempt from the e-invoice obligation, but not from transmission to myDATA. Retail receipts continue to be transmitted as normal.

Do I have to pay a provider?

Not necessarily. There are two routes: a licensed Electronic Document Issuance Service Provider (what the market calls an “e-invoicing provider”) or AADE's free applications (timologio and myDATAapp). For invoicing the public sector the framework of law 4601/2019 also applies — ask your accountant what the solution you choose actually covers.

What is the penalty if I do not comply?

Issuing an invoice by a method not provided for counts as non-issuance (article 57 of law 5104/2024, circular Ε.2004/2026): a fine of 50% of the VAT per document found during an audit not to have been lawfully issued, with a minimum amount, cumulative per tax audit, of €250 for single-entry and €500 for double-entry books. On a repeat offence the rate rises to 100% and on a further repeat to 200%, and an additional fine of €500 or €1,000 per tax audit is also provided for. The minimum thresholds are cumulative per audit, not per document.

Is there any benefit to starting earlier?

Under article 71Θ of law 4172/2013 and decision Α.1129/2025, those who opted for exclusively electronic issuance before mandatory application depreciate the equipment/software cost fully within the year, increased by 100%, and deduct the cost of issuance, transmission and archiving increased by 100% for the first 12 months. A declaration of use was required no later than 2 months before the obligation began — for the second period, by 1/8/2026. The uplift applies to the deduction from profits, not to the price itself — the real benefit in euros depends on your legal form and tax rate, and your accountant calculates it.

Is an extension possible?

An extension moving the start to 1 March 2027 cannot be ruled out; the market is pressing for one. Until a decision is taken, the date in force remains 1/10/2026 and your preparation should not rely on a possible extension. This page is kept updated.

Does e-invoicing solve my cost problem?

No. It standardises the envelope of the document, not the naming of the items. Every supplier will carry on naming the same product differently, and nobody will tell you that the price of olive oil went up 14%.

Official sources & review history

Change history

  • 28/8/2026: Second review pass: two points not 100% confirmed were temporarily withdrawn (the formal acceptance obligation from 2/3/2026, and the benefit table using a 22% rate); a functionality claim about the MARK was removed; the wording on matching expenses was softened; statutory deadlines were separated from our own recommendations; the reference to article 53 for the €2,500 fine was removed; the “In force” and “Passed” labels were separated. Earlier: the penalty was corrected (minimum amounts cumulative per audit, repeat offences), the 1/8/2026 deadline was marked as passed, and the declaration deadline of 12/10/2026, the €2,500 fine and the possibility of an extension were added.

Maintained by: utilize.gr · Review frequency: monthly until 1/1/2027.

Legal basis: article 14 of law 4308/2014 (Greek Accounting Standards) as in force following article 239 of law 5222/2025, Α.1128/2025 (decision of 15.9.2025, Gazette Β΄4937/16.9.2025), Α.1044/2026 (Gazette Β΄880/17.2.2026), articles 53 and 57 of law 5104/2024 (Tax Procedure Code), article 71Θ of law 4172/2013 & Α.1129/2025, and circular Ε.2004/2026 on penalties. This text is informational and does not replace tax advice — confirm your obligations with your accountant. See also our calculation methodology.

Go into 2027 with clean data

Those who reach 1 October with merged suppliers and a clean item catalogue will gain from the change. The rest will simply receive the same confused data faster.

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