Greece Postpones Phase 2 of Digital Goods Movement Requirements to 2027 and 2028

Greece has postponed Phase 2 of its digital goods movement framework. Loading, transshipment, receipt and quantitative-control reporting will become mandatory on January 1, 2027, while standardized TARIC-based item coding moves to January 1, 2028.

The Tax Authority (AADE) has postponed the second phase of the digital monitoring of goods movements, giving businesses more time to adapt their systems and operational processes. The revised timetable was announced on September 30, 2026 and formalized through Decision A.1198/2026, which amends Decision A.1122/2024 governing the digital issuance of goods movement documents.

This is a postponement of Phase 2, not of the entire Digital Goods Movement framework. The existing first-phase requirements remain applicable to businesses already within scope. The Tax Authority expressly states that the additional time is intended to allow businesses to complete the necessary technical implementations and prepare for the additional obligations.

For retailers, wholesalers, warehouses, distribution operations and software providers, the distinction is important. Businesses cannot stop issuing and transmitting the digital goods movement documents already required under Phase 1 simply because the next phase has been delayed.

Phase 2 adds further digital monitoring around what happens to goods after the initial movement document has been issued. Under the Tax Authority’s revised schedule, the requirements will be introduced in two stages:

• From January 1, 2027, the procedures for loading, transshipment and receipt become mandatory for digital monitoring and traceability of inventory movements, together with transmission of quantitative control data.
• From January 1, 2028, businesses must apply the Unified Coding of Items according to the Combined Nomenclature (TARIC). Until each mandatory date arrives, the corresponding Phase 2 information may be transmitted voluntarily through myDATA.

This replaces the timetable announced in April 2026. Under that schedule, loading, transshipment, receipt and control processes were due to apply from October 12, 2026, while standardized item coding was scheduled for January 1, 2027.

The first part has therefore been postponed by roughly two and a half months, while the standardized goods-coding requirement receives a much longer extension of one year.

The postponement does not affect the basic requirement to digitally document applicable inventory movements.

The Tax Authority confirms that mandatory digital issuance of goods movement documents and transmission of Phase 1 data has applied from December 1 ,2025 for the businesses within scope.

Under the Tax Authority’s current guidance, businesses keeping books under the Greek Accounting Standards are generally required to issue inventory movement documents digitally and transmit the corresponding information to the myDATA platform, subject to the exemptions established in Decision A.1122/2024. The rules apply to both domestic and international movements where the movement falls within scope.

The timing of the document is particularly relevant operationally. The Tax Authority explains that a digital Delivery Note is issued before the movement starts and accompanies the inventory during transport. For dispatches, the relevant information is transmitted before transport begins.

Businesses can transmit movement data using an Electronic Tax Document Issuance Provider, business management software such as an ERP connected to the Tax Authority, or the Tax Authority’s timologio and myDATAapp applications.

There is one specific transition mentioned in the September announcement. For certain olive-producing farmers that do not belong to the entities covered by the first implementation period, the Phase 1 obligation is moved to January 1, 2027, subject to the conditions specified by the Tax Authority concerning the issuance of a quantitative receipt document by olive mills.

The practical difference is that the system develops from digital documentation of the dispatch into broader digital traceability of the physical movement.

For a retailer moving inventory from a central warehouse to a store, for example, compliance will no longer concern only the document created before the truck leaves the warehouse. The subsequent stages of the movement will also become part of the digital tracking process, including receipt and quantitative-control information.

The Tax Authority has also confirmed that the current version of myDATAapp already supports scanning and receipt of movement documents, while timologio includes functionality connected with Phase 2. Businesses can therefore use the postponement period to test these processes voluntarily before they become mandatory.

The 2028 coding requirement creates a separate implementation issue. Businesses will need to prepare their product master data for the Unified Coding of Items according to the Combined Nomenclature specified by the Tax Authority. For retailers with large product catalogues, this may require coordination between tax, ERP, warehouse and master-data teams well before the mandatory date.

Impact on affected businesses and retail systems

The postponement provides additional implementation time, but it should not be treated as a reason to suspend Phase 2 projects.

Retailers with warehouses, store transfers, distribution centres or other inventory movements should review how loading, transshipment and receipt events are currently captured in their ERP, warehouse management system or other operational software. The relevant question is whether those events can also support the data transmission required by myDATA from January 2027.

For software providers and system integrators, the change mainly affects the implementation timetable, rather than removing planned functionality. Solutions supporting goods movements should still be prepared for receipt processing, traceability and quantitative-control data, but mandatory production use is now delayed.

What should affected businesses do now?

Businesses should continue complying with Phase 1 and should not interpret the September decision as a suspension of Digital Delivery Note requirements.

Preparation should now focus on validating the Phase 2 process before January 1, 2027, particularly the recording of loading, transshipment, receipt and quantitative-control events. Businesses with large inventories should also begin assessing their product master data and TARIC/Combined Nomenclature mapping rather than leaving this work until the end of 2027.

Where ERP, warehouse or logistics applications are involved, businesses should confirm the revised implementation plan with their software providers and consider using the voluntary transmission period to test the new processes.

From our perspective, the most useful aspect of the postponement is the separation between the operational tracking requirements and standardized product coding. These are different implementation projects. Transaction-event tracking needs to be ready first, while businesses now have until 2028 to complete the more extensive product-classification work.

The principal legal source is the Tax Authority Decision A.1198 of September 30, 2026, which amends Decision A.1122/2024 and postpones the start of Phase 2. Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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