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Greece e-invoicing from 2 November 2026: what invoicing software needs to ship

Greek B2B e-invoicing wave 2 starts 2 Nov 2026; ERP only in parallel until 31 Jan 2027. Timeline, provider vs ERP, MARK/QR, checklist.

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If you build invoicing or ERP software with Greek customers, this post gives you the dates that matter for the second wave of Greek B2B e-invoicing, what is in scope, why "our ERP talks to myDATA" stops being enough on 1 February 2027, and a checklist to work through before 2 November 2026.

The short version

From 2 November 2026 the remaining Greek businesses (2023 gross revenue up to EUR 1 million) must issue electronic invoices for domestic B2B wholesale, B2B wholesale to non-EU countries and B2G (joint decision A.1128/2025 as amended by A.1197/2026, published 30 September 2026). Businesses above EUR 1 million have been in since 2 March 2026. Until 31 January 2027 a declared ERP or special-form path can still run in parallel; from 1 February 2027 only an AADE-licensed provider or AADE's free timologio / myDATAapp may issue in-scope invoices.

Timeline

  • 2 Mar 2026: first period (gross revenue over EUR 1m) mandatory; recipients must accept domestic B2B and B2G e-invoices.
  • 30 Sep 2026: A.1197/2026 moves the second-period start from 1 October to 2 November 2026.
  • 2 Nov 2026: second period starts. The start declaration (provider or timologio) must give a start date no later than 2 November.
  • 2 Nov 2026 – 31 Jan 2027: gradual fulfilment; ERP or the myDATA special entry form may still be used in parallel.
  • 1 Feb 2027: licensed provider or AADE timologio / myDATAapp only.

What changes for software

  • Scope: domestic wholesale B2B, non-EU wholesale B2B (not retail), and B2G. Retail B2C and intra-EU B2B are outside this decision.
  • Issue channel: an AADE-licensed Electronic Tax Document Issuance Provider, or timologio. AADE's FAQ says plainly that ordinary business software (commercial / accounting, ERP) is not an accepted way to issue the e-invoice.
  • Transmission: providers post myDATA XML (InvoicesDoc) to the myDATA API and get back a MARK (unique registration number); keep it with the invoice.
  • Recipient download: since myDATA v1.0.12 provider invoices carry downloadingInvoiceUrl; recipients can fetch /pdf, /myDATA or /EN16931. Use that URL for the printed QR code.
  • Penalties: not issuing an electronic invoice counts as not issuing an invoice (Tax Procedure Code).

Checklist before 2 November 2026

  1. Flag each customer and transaction as in or out of scope.
  2. Integrate at least one licensed provider API, or a clean hand-off to timologio for the smallest users.
  3. Support the start declaration with a start date on or before 2 November 2026.
  4. Store MARK, uid, authenticationCode and the QR URL on every transmitted invoice.
  5. Offer the EN 16931 download for EU buyers who need the European standard, and validate EN 16931 files you generate.
  6. Accept inbound e-invoices for domestic B2B and B2G.
  7. Block "PDF only" for in-scope invoices after the user's obligation date.

Checking the EN 16931 side

Disclosure: I build W System, an EU e-invoicing and counterparty-check API. It is not a Greek licensed provider and does not transmit to myDATA. What it does help with here: creating and validating the EN 16931 representation (the same European standard behind /EN16931), checking Greek VAT numbers (prefix EL) in VIES before you invoice, and a free in-browser validator at wsystem.dev/e-invoice-validator. The full article, with a live API example and sources, is on wsystem.dev.

Sources

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