Phase B of the e-Delivery Note will officially apply from 1/1/2026
The extension granted until 31/12/2025 (based on the IAPR announcement dated 04.12.2024) was the final extension.
Therefore, from January 1st, 2026, the mandatory implementation of Phase B begins without any further postponement.
What does this mean in practice?
- Every Delivery Note issued must be transmitted digitally to IAPR in real time.
- Transmission must occur before or at the start of transport.
- This obligation applies to all businesses that transport goods using their own or rented vehicles, and that issue delivery notes.
IAPR: Implementation Guide for 2026 (preliminary information)
Up to this moment, IAPR has not issued a new guideline or circular for 2026, but it has indicated that:
The framework will remain the same as Decision A.1177/2023, meaning:
✔ Universal application for businesses transporting goods
✔ Transmission mainly through ERP software
✔ Exceptions remain for courier companies, transport agencies, and logistics carriers
A revised official guide is expected in the first quarter of 2026, but has not yet been published (as of 05/12/2025).
Electronic Platforms / Software
Most commercial applications (ERP, invoicing, accounting systems) have already implemented the e-Delivery Note module, including:
- Real‑time transmission
- QR code generation
- Recording of driver and vehicle details
If your business does not yet have the e-Delivery Note functionality, it is essential to take action before the end of 2025.
(Note: The EMDI software already supports e-Delivery Note integration.)
What changes in 2026 compared to 2025?
| Topic | 2025 (extension period) | 2026 (full obligation) |
|---|---|---|
| e-Delivery Note Transmission | Optional | Mandatory |
| Penalties | Not applied | Applied based on the Tax Procedure Code (KFD) |
| AADE Audits | Informative | Full audits with penalties |
| Compliance Requirement | Mild | Strict |
Penalties for non‑transmission (from 2026)
According to Article 54 of Law 4174/2013 (Tax Procedure Code) and related decisions:
- Fines ranging from €500 to €2,500
- Rejection of expenses (non‑deductible for tax purposes)
- Possible classification of transactions as “suspected tax evasion”
- Recorded non‑transmissions in myDATA for cross‑checks
Recommended actions before the end of 2025
It is important to take advantage of the time remaining.
✔ Contact your accountant
✔ Confirm your ERP system supports e-Delivery Note (EMDI already supports it)
✔ Train drivers/employees on the new procedures
✔ Check whether your business qualifies for any exemptions
✔ Prepare internal procedures for complianc
Sources
| Source | Description |
|---|---|
| A.1177/2023 | Decision regarding e-Delivery Note implementation |
| A.1138/2020 | myDATA obligations |
| Law 4308/2014 | Greek Accounting Standards – definitions of invoices & delivery notes |
| AADE Digital Delivery Note Platform | Official AADE application |
| Law 4174/2013 | Tax Procedure Code |
| Taxheaven – 04/12/2024 update | Extension of Phase B |
Disclaimer:
This article is for informational purposes only and does not constitute legal, tax, or professional advice. While every effort has been made to ensure the accuracy and timeliness of the information provided, no guarantee is offered regarding its completeness or correctness. SBZ IKE bears no responsibility for any direct or indirect loss arising from the use of this content. Readers should consult qualified professionals before making decisions or taking action based on this material.
