Proposal for a COUNCIL IMPLEMENTING DECISION authorising Greece to introduce a special measure derogating from Articles 218 and 232 of Directive 2006/112/EC on the common system of value added tax
Date: 2025-01-13
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: Greece, VAT, derogation from EU law, e-invoicing, establishment, invoicing, tax collection, taxpayer

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.1.2025  COM(2025) 4 final 2025/0001 (NLE)  Proposal for a COUNCIL IMPLEMENTING DECISION authorising Greece to introduce a special measure derogating from Articles 218 and 232 of Directive 2006/112/EC on the common system of value added tax  
 
EXPLANATORY MEMORANDUM 

Pursuant to Article 395(1) of Directive 2006/112/EC of 28 November 2006 on the common 
system of value added tax1 (hereafter 'the VAT Directive'), the Council, acting unanimously 
on  a  proposal  from  the  Commission,  may  authorise  any  Member  State  to  apply  special 
measures  for  derogation  from  the  provisions  of  that  Directive  in  order  to  simplify  the 
procedure for collecting VAT or to prevent certain forms of tax evasion or avoidance. 

By letter registered with  the Commission  on  2 July 2024, Greece  requested authorisation  to 
derogate  from  Articles  218  and  232  of  the  VAT  Directive  to  be  able  to  impose  mandatory 
electronic  invoicing  for  transactions  between  taxable  persons  established  in  Greece  (B2B 
transactions).  

In accordance with Article 395(2) of the VAT Directive, the Commission informed the other 
Member States by letter dated 24 September 2024 of the request made by Greece. By letter 
dated  25  September  2024,  the  Commission  notified  Greece  that  it  had  all  the  information 
necessary to consider the request. 

1. 

• 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

Greece submitted a request for derogation, based on Article 395 of the VAT Directive, to be 
authorised  to  implement  an  obligation  to  issue  electronic  invoices  for  transactions  between 
taxable persons established in Greece. Greece has in place a digital platform called myDATA. 
Entities  obliged  to  keep  accounting  records,  in  accordance  with  the  Greek  legislation,  must 
transmit income and expense transaction data to this platform.  

Currently, there  are different  channels  that can  be used to  transmit  the  data to  the platform. 
Once the mandatory  electronic invoicing  is implemented in  Greece, electronic invoices will 
be  the  main  channel  for  this  transmission,  with  their  data  directly  feeding  the  myDATA 
platform. As a result, the information will arrive in real-time and with a high level of quality, 
making easier and faster for the tax administration to detect cases of VAT fraud. Further, the 
information  received  will  be  used  to  prepare  prefilled  VAT  returns,  helping  businesses  to 
comply with their VAT obligations. 

In addition, the creation of a digitized tool for the transport of goods is in progress, utilizing 
the capabilities of the myDATA digital platform. This tool aims to digitally monitor all goods 
being delivered in real time. To achieve this objective, the institutional framework regarding 
the electronic issuance of documents for the transport of goods was put in place in 2024, and 
the implementation of an operational and technical framework is being prepared, to facilitate 
the compliance to taxable persons. 

The  different  measures  implemented  so  far  have  helped  Greece  to  reduce  its  VAT  gap. 
According  to  the  VAT  gap  in  the  EU  report2,  published  by  the  European  Commission,  the 
VAT compliance gap has reduced from 29.1% in 2017 to 17.8% in 2021, and the forecast for 
2022  envisages  a  steep  decrease  in  that  figure.  According  to  the  Greek  authorities,  the 
introduction of mandatory electronic invoicing will help to further reduce this figure, as it can 
be an important instrument towards the fight against circular or “carousel” fraud, allowing the 
tax authorities to identify the involved parties within a shorter time.  

1 
2 

OJ L 347, 11.12.2006, p. 1, ELI: http://data.europa.eu/eli/dir/2006/112/oj. 
VAT gap in the EU - Publications Office of the EU (europa.eu) 

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According  to  Greece,  the  implementation  of  mandatory  electronic  invoicing  will  also  be 
beneficial  for  taxable  persons,  providing  them  with  prefilled  VAT  returns  and  allowing  the 
timely processing of tax refund requests. 

The  implementation  of  the  transmission  of  data  to  the  myDATA  platform  has  followed  a 
gradual  process  since  2018,  with  different  information  campaigns,  tests  and  pilot  projects. 
Taxable persons, accountants, software companies and service providers were involved in the 
testing process.  

The  transmission  of  data  to  the  myDATA  platform  can  be  done  through  five  different 
transmission  channels:  (1)  licensed  providers  of  electronic  invoicing  services,  (2)  software 
programs  (ERP)  for  issuing  invoices  and  managing  accounting  entries,  (3)  a  special  data 
registration  form  provided  by  the  Independent  Authority  for  Public  Revenue  (IAPR)  under 
certain conditions, which applies to small entities, (4) electronic mechanisms for the issuance 
of  retail  transaction  documents  and  (5)  an  invoice  issuance  and  transmission  application 
called “timologio”, provided by the IAPR. 

In  particular,  the  “timologio”  application  is  provided  free  of  charge  and  is  considered  a 
reliable solution for any kind of enterprises and especially small and medium-sized ones for 
the  issuance  and  transmission  of  data  in  real  time.  Once  the  derogation  is  granted,  Greece 
plans to expand the functionality of this application, which will become a way to comply with 
the electronic invoicing mandate. 

According  to  Greece,  the  initial  cost  of  subscribing  to  an  Electronic  Invoicing  Service 
Provider  or  upgrading  the  existing  management  programs  (commercial/accounting,  ERP) 
used by the entities, is expected to be compensated by the reduction of accounting costs (cost 
of  issuing,  sending  &  storing  invoices),  but  also  by  the  general  improvement  of  digital 
services which is expected to facilitate the development of entrepreneurship and the increase 
of  competitiveness  between  entities.  Greece  is  giving  tax  incentives  to  taxable  persons  who 
switch to electronic invoicing until 31 December 2024. Consequently, entities will meet their 
tax obligations immediately and at  a lower cost.  Electronic invoicing  will also  contribute  to 
the objective of transmitting classified information “only once” since through interoperability, 
more than one obligation will be fulfilled for the entities, triggering a corresponding reduction 
of errors and administrative costs. 

The myDATA platform does not require that all the data in the invoice is transmitted to the 
platform, but only that relevant for tax purposes. 

To  ensure  the  interoperability  of  electronic  invoicing  systems  used  in  the  European  Union, 
Greece  shall  allow  the  issuance  of  invoices  that  comply  with  the  European  standard  on 
electronic  invoicing  and  the  list  of  its  syntaxes  published  by  Commission  Implementing 
Decision (EU) 2017/18703. 

Article 218 of the VAT Directive provides for an obligation for Member States to accept all 
documents or messages both in paper or electronic form as invoices. Greece would therefore 
like  to  obtain  a  derogation  from  the  above-mentioned  Article  of  the  VAT  Directive  so  that 
only  documents  in  electronic  form  can  be  considered  as  invoices  by  the  Greek  tax 
administration. 

3 

Commission  Implementing  Decision  (EU)  2017/1870  of  16  October  2017  on  the  publication  of  the 
reference  of  the  European  standard  on  electronic  invoicing  and  the  list  of  its  syntaxes  pursuant  to 
Directive  2014/55/EU  of  the  European  Parliament  and  of  the  Council  (OJ  L  266,  17.10.2017,  p.  19, 
ELI: http://data.europa.eu/eli/dec_impl/2017/1870/oj). 

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Article 232 of the VAT Directive requires that the use of an electronic invoice shall be subject 
to  acceptance  by  the  recipient.  Therefore,  the  introduction  of  an  electronic  invoicing 
obligation in Greece requires a derogation from this Article so that the issuer no longer has to 
obtain the consent of the recipient to send an invoice in a paperless format. 

Derogations  are  in  general  granted  for  a  limited  period  of  time  as  to  allow  an  assessment 
whether the special measure is appropriate and effective and in order to grant Member States 
time  to  introduce  other  conventional  measures  to  tackle  the  respective  problem  until  the 
expiry of the derogating measure.  

Further, a Proposal for a Council Directive amending Directive 2006/112/EC as regards VAT 
rules for the digital age4 (VAT in the digital age proposal), is currently being discussed in the 
Council. This Directive will amend Article 218 and delete Article 232 of the VAT Directive. 
This  reform,  once  adopted,  will  allow  Member  States  to  implement  mandatory  e-invoicing, 
eliminating  the  need  to  request  further  derogations  from  the  VAT  Directive  in  order  to 
implement  such  systems.  Therefore,  the  authorisation  allowing  Greece  to  derogate  from 
Articles 218 and 232 should  only  be  granted  for the period needed until  such reform enters 
into force. 

Thus, it is proposed to grant the authorisation until 30 June 2026. Given the short period for 
which this derogation is granted, in case Greece needs to prolong further this authorisation no 
report should be needed. 

• 

Consistency with existing policy provisions in the policy area 

Article  218  of  the  VAT  Directive  puts  paper  and  electronic  invoices  on  equal  footing  by 
providing that Member States shall accept documents or messages on paper or in electronic 
form as invoices. Following Article 232 of the VAT Directive, the use of an electronic invoice 
shall  be  subject  to  acceptance  by  the  recipient.  The  obligatory  electronic  invoicing  as 
envisaged by Greece would indeed derogate from these two provisions. 

The  derogation  can  be  authorised  based  on  Article  395  of  the  VAT  Directive  in  order  to 
simplify  the  procedure  for  collecting  VAT  or  to  prevent  certain  forms  of  tax  evasion  or 
avoidance.  The implementation  of mandatory electronic invoicing  for B2B transactions will 
complement  the  existing  myDATA  digital  platform,  which  is  used  to  report  data  to  the  tax 
administration.  The  mandatory  electronic  invoicing  will  allow  to  send  the  data  to  that 
platform in real-time while ensuring the highest quality of the data reported. Further, it will 
simplify  the  VAT  obligations  of  taxable  persons  by  allowing  the  preparation  of  pre-filled 
VAT returns. Therefore, the envisaged mandatory electronic invoicing will contribute to both 
the  simplification  of  VAT  obligations  for  taxable  persons  and,  especially,  the  fight  against 
VAT  fraud.  The  derogation  requested  by  Greece  is  consistent  with  the  existing  policy 
provisions.   

Similar  authorisations  allowing  Italy,  France,  Poland,  Germany  and  Romania  to  derogate 
from Articles 218 and 232 of the VAT Directive, in order to implement mandatory electronic 
invoicing,  were  granted  by  Council  Implementing  Decision  (EU)  2018/5935  (extended  by 

4 
5 

EN 

COM/2022/701 final. 
Council  Implementing  Decision  (EU)  2018/593  of  16  April  2018  authorising  the  Italian  Republic  to 
introduce  a  special  measure  derogating  from  Articles  218  and  232  of  Directive  2006/112/EC  on  the 
14,  ELI: 
of 
common 
http://data.europa.eu/eli/dec_impl/2018/593/oj). 

19.4.2018, 

(OJ  L 

system 

added 

value 

99, 

tax 

p. 

3 

  EN 

 
Council  Implementing  Decision  (EU)  2021/22516),  Council  Implementing  Decision  (EU) 
2022/1337,  Council  Implementing  Decision  (EU)  2022/10038,  Council  Implementing 
Decision (EU) 2023/15519 and Council Implementing Decision (EU) 2023/155310. 

The Commission adopted in 2020 the “Communication from the Commission to the European 
Parliament  and  the  Council:  an  Action  Plan  for  fair  and  simple  taxation  supporting  the 
recovery  strategy”11. One of the actions envisaged in  this  action plan is the  adoption by the 
Commission  of  a  legislative  proposal  aimed  at  modernising  VAT  reporting  obligations.  As 
indicated  in  the  Action  Plan,  this  proposal  should,  amongst  others,  help  streamline  the 
reporting  mechanisms  that  can  be  applied  for  domestic  transactions.  The  need  to  further 
expand e-invoicing is also examined in this context.  

As a result of this Action Plan, the Commission adopted on 8 December 2022 the VAT in the 
digital  age  proposal,  which  is  being  discussed  in  the  Council.  This  Directive  will  amend 
Article  218  and  delete  Article  232  of  the  VAT  Directive.  This  reform,  once  adopted,  will 
allow  Member  States  to  implement  mandatory  e-invoicing,  eliminating  the  need  to  request 
further  derogations  from  the  VAT  Directive  in  order  to  implement  such  systems.  For  that 
reason,  once  this  proposal  for  a  Directive  is  transposed  by  the  Member  States,  this  Council 
Decision would no longer have any useful effect.  

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

Article 395 of the VAT Directive. 

• 

Subsidiarity (for non-exclusive competence)  

Considering the provision of the VAT Directive on which the proposal is based, subsidiarity 
principle does not apply. 

6 

7 

8 

9 

10 

11 

L 

of 

20, 

value 

added 

31.1.2022, 

Council  Implementing  Decision  (EU)  2021/2251  of  13  December  2021  amending  Implementing 
Decision  (EU)  2018/593  authorising  the  Italian  Republic  to  introduce  a  special  measure  derogating 
from Articles 218 and 232 of Directive 2006/112/EC on the common system of value added tax (OJ L 
454, 17.12.2021, p. 1, ELI: http://data.europa.eu/eli/dec_impl/2021/2251/oj). 
Council Implementing Decision (EU) 2022/133 of 25 January 2022 authorising France to introduce  a 
special  measure  derogating  from  Articles  218  and  232  of  Directive  2006/112/EC  on  the  common 
ELI: 
tax(OJ 
system 
http://data.europa.eu/eli/dec_impl/2022/133/oj). 
Council Implementing Decision (EU) 2022/1003 of 17 June 2022 authorising the Republic of Poland to 
apply  a  special  measure  derogating  from  Articles  218  and  232  of  Directive  2006/112/EC  on  the 
81,  ELI: 
tax 
of 
common 
http://data.europa.eu/eli/dec_impl/2022/1003/oj). 
Council Implementing Decision (EU) 2023/1551 of 25 July 2023 authorising Germany to introduce a 
special  measure  derogating  from  Articles  218  and  232  of  Directive  2006/112/EC  on  the  common 
system 
ELI: 
(OJ 
http://data.europa.eu/eli/dec_impl/2023/1551/oj). 
Council Implementing Decision (EU) 2023/1553 of 25 July 2023 authorising Romania to introduce a 
special  measure  derogating  from  Articles  218  and  232  of  Directive  2006/112/EC  on  the  common 
system 
ELI: 
(OJ 
http://data.europa.eu/eli/dec_impl/2023/1553/oj). 
https://taxation-customs.ec.europa.eu/system/files/2020-07/2020_tax_package_tax_action_plan_en.pdf  

27.6.2022, 

27.7.2023, 

27.7.2023, 

(OJ  L 

system 

added 

added 

added 

value 

value 

value 

272, 

168, 

188, 

188, 

42, 

48, 

tax 

tax 

of 

of 

p. 

p. 

p. 

p. 

L 

L 

EN 

4 

  EN 

 
• 

Proportionality 

The  proposal  complies  with  the  proportionality  principle.  The  Decision  concerns  an 
authorisation  granted  to  a  Member  State  upon  its  own  request  and  does  not  constitute  any 
obligation.  

It  should  be  noted  that  Greece  is  progressively  implementing,  from  September  2023  until 
January  2025,  the  obligation  to  use  electronic  invoicing  in  the  B2G relationships  following 
the implementation  of  Directive 2014/55/EU of the European Parliament and of the Council 
of  16 April  2014  on  electronic  invoicing  in  public  procurement12.  Further,  according  to  the 
data provided by Greece, the use of electronic invoicing is becoming more extended among 
businesses.  On  average,  on  a  daily  basis,  entities  transmit  more  than  1.700.000  electronic 
invoices  and  retail  receipts  through  an  Electronic  Invoicing  Service  Provider,  more  than 
4.700.000  documents  through  software  programs,  more  than  62.000  documents  through  the 
“timologio”  application  and  more  than  9.000  documents  through  the  Special  Registration 
Form.  This  “timologio”  application  is  provided  free  of  charge  and  is  especially  suited  for 
small and medium-sized companies to comply with their tax obligations.  

The  system  takes  into  account  the  main  features  laid  down  in  the  VAT  in  the  digital  age 
proposal, to avoid unnecessary adaptation costs when that proposal  enters into force. In this 
regard, the transmission of invoices using accounting software or through service providers is 
allowed. Taxpayers will be able to exchange electronic invoices according to the EU standard 
and will only report the data necessary for tax purposes and not the whole invoice.  

The  obligation  to  use  electronic  invoices  will  only  apply  for  transactions  between  taxable 
persons  established  in  Greece.  The  measure  will  not  impact  companies  not  established  in 
Greece, even if they are registered there for VAT purposes, and the right to receive a paper 
invoice  in  case  of  intra-Community  transactions  is  not  affected.  Supplies  of  goods  and 
services to final consumers are not included in the scope of the measure. 

The  derogation  is  also  limited  in  time  until  harmonised  rules  allow  Member  States  to 
implement mandatory e-invoicing.  

Therefore, the special measure is proportionate to the aim pursued, to combat tax  fraud and 
evasion while helping simplify the procedure for collecting VAT.  

• 

Choice of the instrument 

Proposed instrument: Council Implementing Decision.  

Under  Article  395  of  the  VAT  Directive,  derogation  from  the  common  VAT  rules  is  only 
possible  upon  authorisation  of  the  Council  acting  unanimously  on  a  proposal  from  the 
Commission. A Council Implementing Decision is the most suitable instrument since it can be 
addressed to an individual Member State. 

12 

OJ L 133, 6.5.2014, p.1, ELI: http://data.europa.eu/eli/dir/2014/55/oj. 

EN 

5 

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3. 

• 

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Impact assessment 

The  mandatory  electronic  invoicing  will  impact  both  the  tax  administration  and  taxable 
persons. 

The implementation of mandatory electronic invoicing will provide faster and higher quality 
data to the myDATA platform, helping the tax authorities in the detection of non-declaration 
or under-declaration of VAT. It will also help them in the fight against circular or “carousel” 
fraud, allowing the tax authorities to identify the involved parties within a shorter time. 

Greece has already reduced their VAT compliance gap from 29.1% in 2017 to 17.8% in 2021. 
The  implementation  of  mandatory  electronic  invoicing  will  contribute  to  continue  reducing 
this figure. 

Further,  the  implementation  of  mandatory  electronic  invoicing  will  reduce  the  errors  in  the 
reporting  of  the  data.  This  will  contribute  to  reducing  the  costs  incurred  by  both  the  tax 
administration and taxable persons, avoiding the burden derived from the procedure to correct 
such mistakes. 

The implementation of mandatory e-invoicing should not be very burdensome for businesses 
as  it  is  already  common  practice  in  many  sectors  of  the  economy  and  it  is  becoming 
mandatory  in  the  field  of  public  procurement.  As  explained  above,  a  significant  part  of  the 
reporting to the myDATA platform is already done via electronic invoices. 

Furthermore, the electronic invoicing will facilitate the issuance of prefilled VAT returns, that 
will help businesses in complying with their VAT obligations. Electronic invoicing will also 
contribute  to  fulfil  more  than  one  obligation  at  once,  with  the  corresponding  reduction  of 
errors and administrative costs.  

The  costs  for  business  derived  from  the  adaptation  to  electronic  invoicing  should  be 
compensated,  according  to  Greece,  by  the  reduction  of  the  costs  derived  from  the  issuing, 
sending and storing invoices compared with the current situation, but also by the benefits for 
taxable persons derived from the improvement of their processes though digitalisation. 

To  reduce  the  burden  on  businesses  from  this  transition,  Greece  is  giving  tax  incentives  to 
taxable persons who switch to electronic invoicing until 31 December 2024 and is providing 
the  “timologio”  application,  which  allows  to  comply  with  the  reporting  obligation,  free  of 
charge. 

In  addition,  the  e-invoicing  and  reporting  system  will  follow  the  main  features  of  the  one 
included  in  the  VAT  in  the  digital  age  proposal.  This  will  avoid  duplication  of  costs  for 
taxable persons and the tax administration. 

4. 

BUDGETARY IMPLICATIONS 

The measure will have no adverse impact on the Union's own resources accruing from VAT. 

EN 

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2025/0001 (NLE) 

Proposal for a 

COUNCIL IMPLEMENTING DECISION 

authorising Greece to introduce a special measure derogating from Articles 218 and 232 
of Directive 2006/112/EC on the common system of value added tax 

THE COUNCIL OF THE EUROPEAN UNION, 

Having regard to the Treaty on the Functioning of the European Union,  

Having  regard  to  Council  Directive  2006/112/EC  of  28  November  2006  on  the  common 
system of valued added tax1, and in particular Article 395(1) thereof, 

Having regard to the proposal from the European Commission, 

Whereas: 

(1) 

(2) 

(3) 

(4) 

By  letter  registered  with  the  Commission  on  2  July  2024,  Greece  requested  an 
authorisation  for  a  special  measure  to  derogate  from  Articles  218  and  232  of 
Directive 2006/112/EC  in  order  to  introduce  mandatory  electronic  invoicing  for  all 
transactions carried out between taxable persons established in the territory of Greece 
(‘the special measure’). 

In  accordance  with  Article 395(2),  second  subparagraph,  of  Directive 2006/112/EC, 
the  Commission  transmitted  Greece’s  request  to  the  other  Member  States  by  letters 
dated  24 September  2024.  By  letter  dated  25 September  2024,  the  Commission 
notified  Greece  that  it  had  all  the  information  necessary  for  the  appraisal  of  the 
request. 

Greece  has  in  place  a  digital  platform  called  myDATA.  Entities  obliged  to  keep 
accounting  records  under  the  Greek  legislation  must  transmit  income  and  expense 
transaction  data  to  this  platform.  The  implementation  of  mandatory  electronic 
invoicing will allow that the data from electronic invoices directly feed the myDATA 
platform. As a result, the information will arrive in real time and with a high level of 
quality,  making  it  easier and faster  for the tax  administration to  detect  cases of non-
declaration or under-declaration of VAT. Further, it will help the tax administration in 
the fight against circular or ‘carousel’ fraud, allowing the identification of the parties 
involved within a shorter time. 

that 

implementing  mandatory  e-invoicing  will  not  be 

Greece  considers 
too 
burdensome for taxable persons, as it is already common practice in many sectors of 
the  economy  and  it  is  becoming  mandatory  in  the  field  of  public  procurement. 
Furthermore, electronic invoicing will make issuing prefilled VAT returns easier and 
will allow taxable persons to comply with more than one reporting obligation at once, 
which will reduce both errors and administrative costs. According to Greece, the costs 
for  business  due  to  the  adaptation  to  electronic  invoicing  should  be  compensated  by 
the  reduction  of  the  costs  associated  with  the  issuing,  sending  and  storing  invoices 

1 

OJ L 347, 11.12.2006, p. 1, ELI: http://data.europa.eu/eli/dir/2006/112/oj. 

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(5) 

(6) 

(7) 

(8) 

compared with the current situation, and by the benefits for taxable persons  resulting 
from the improvement of their processes though digitalisation. 

On  8 December  2022,  the  Commission  adopted  a  proposal  for  a  Council  Directive 
amending Directive 2006/112/EC as regards VAT rules for the digital age2. By means 
of  that  Directive,  the  Commission  proposes  to  amend  Article 218  and  delete 
Article 232  of  Directive 2006/112/EC.  The  Council,  in  the  ECOFIN  meeting  of  5 
November,  reached  a  general  approach  on  the  proposal  and  will  re-consult  the 
European  Parliament  before  formally  adopting  the  proposal.  Once  adopted,  the 
proposal  will  enable  Member  States  to  implement  mandatory  electronic  invoicing, 
hence  eliminating  the  need  to  request  further  special  measures  to  derogate  from 
Directive 2006/112/EC.  Therefore,  from  the  date  Member  States  will  be  required  to 
apply any national provisions transposing the proposed Directive, this Decision should 
cease to apply. 

The special measure should not affect the right of customers to receive paper invoices 
in the case of intra-Community transactions. 

The  special  measure  is  proportionate  to  the  objectives  pursued  since  it  is  limited  in 
time and scope. In addition, the special measure does not give rise to the risk that fraud 
shift to other sectors or to other Member States. 

The  special  measure  will  not  negatively  affect  the  overall  amount  of  tax  revenue 
collected  at  the  stage  of  final  consumption  and  will  have  no  adverse  impact  on  the 
Union’s own resources accruing from VAT, 

HAS ADOPTED THIS DECISION:  

By  way  of  derogation  from  Article 218  of  Directive 2006/112/EC,  Greece  is  authorised  to 
only accept invoices which have been issued by taxable persons established in the territory of 
Greece in the form of documents or messages in electronic format. 

Article 1 

Article 2 

By  way  of  derogation  from  Article 232  of  Directive 2006/112/EC,  Greece  is  authorised  to 
provide  that  the  use  of  electronic  invoices  issued  by  taxable  persons  established  in  the 
territory of Greece are not subject to acceptance by the recipient established in the territory of 
Greece. 

Greece shall notify the national measures implementing the derogations referred to in Articles 
1 and 2 to the Commission. 

Article 3 

This Decision shall apply from 1 July 2025 until the earlier of the following two dates: 

Article 4 

(a) 

30 June 2026; or 

2 

COM/2022/701 final. 

EN 

8 

  EN 

 
 
(b) 
the  date  from  which  Member  States  are  required  to  apply  any  national  provisions 
transposing  a  directive  amending  Directive 2006/112/EC,  in  particular  Articles  218  and 232 
thereof, as regards VAT rules for the digital age, in the event that directive is adopted. 

This Decision is addressed to the Hellenic Republic. 

Done at Brussels, 

Article 5 

For the Council 
The President 

EN 

9 

  EN