The second phase of the digital delivery note comes into full implementation from May 1st, with the market pressing for an extension as thousands of businesses declare they are not yet ready to meet the increased requirements of the measure.
The digital delivery note is one of the key tools of the Greek tax authority (AADE) for monitoring goods movement and combating tax evasion. It is a system that allows tax authorities to monitor commercial transactions in real time through mandatory data transmission to the electronic myDATA platform, contributing to enhanced transparency and limiting revenue concealment practices.
It’s worth noting that the implementation of the second phase has already received one postponement, as the original timeline provided for its launch in December 2025. However, the complexity of the undertaking and technical difficulties faced by businesses and software providers led to an extension, moving the relevant milestone to 2026. According to a relevant ministerial decision, the period until April 30, 2026 functions as a transitional adaptation period for businesses.
Despite this additional time margin, professional bodies express serious concern about market readiness. As they point out, many small and medium enterprises still lack the appropriate information systems or technical support required for full integration of the new framework.
Additionally, there is talk of increased administrative costs and the need for staff training. In this context, market representatives are requesting additional time to avoid malfunctions and fines when mandatory implementation begins.
The second phase extends the obligation to almost all businesses that handle goods, making digital issuance of delivery notes a basic rule for the market. The goal is to automate the process and eliminate handwritten documents, which until now left room for irregularities.
For its part, AADE maintains that the new system constitutes a critical step for market modernization and creating a fairer tax environment. At the same time, it emphasizes that adequate transitional periods and technical guidance have been provided so that businesses can adapt smoothly.
Specifically, the new system with the digital delivery note simplifies controls and brings:
- Real-time tracking with immediate updates on the location and status of transported goods (In Transit, Delivered, Completed, Rejected).
- Minimization of errors and losses through digital recording of each transfer.
- Simplification of goods control and receipt procedures with a single scan.
- Ability to group multiple delivery notes into a single QR code for easier and bulk management.
- Ability to issue delivery notes by the goods recipient for specific cases (e.g., agricultural product movements), significantly facilitating primary sector transactions.
Who the new digital delivery note affects
The new digital process covers the entire supply chain spectrum:
- wholesale commercial enterprises,
- retail businesses that handle inventory,
- e-shops with product shipments,
- businesses with warehouses or branches,
- companies with transfers between facilities,
- workshops and production units,
- processing plants,
- food packaging factories,
- logistics companies and sorting centers,
- businesses that perform transfers,
- companies that deliver products to customers or partners,
- businesses that receive organized goods from suppliers.
Exceptions
There are categories that are exempted or not directly included in the obligation such as businesses that provide exclusively services (e.g., lawyers, doctors, consultants) and do not handle merchandise or inventory, are not required to issue delivery notes, very small businesses (under conditions), special status farmers, movements without delivery note obligation.
