Possible EXTENSION Until 1 March 2027 for Electronic Invoicing

The government’s economic team is considering a significant postponement of the universal implementation of electronic invoicing, offering valuable breathing space to the country’s small and micro-enterprises. The strong pressure exerted by institutional market bodies and professional associations appears to be yielding results, as the authorities are now seriously considering moving the mandatory compliance date for the second phase from 1 October 2026 to 1 March 2027.

Although reports of a five-month extension are becoming increasingly widespread, we at Epsilon Informatics would like to emphasise that this change should not be regarded as final until the relevant official decision is issued by the Ministry of National Economy and Finance and the Independent Authority for Public Revenue (AADE).

At this crucial transitional stage, timely preparation remains the key to a smooth digital transition. Even if the extension until 1 March 2027 is officially approved, the additional time should not lead to complacency.

What Applies Under the Current Framework

Under the current implementation schedule, mandatory electronic invoicing is being introduced gradually. Businesses with annual gross revenues exceeding €1 million have already been fully integrated into the new system. For all other businesses and self-employed professionals with turnover below this threshold, the official start date remains 1 October 2026, followed by a transitional adjustment period lasting until the end of the year.

Why a Postponement Until 2027 Is Being Requested

The need for additional time is primarily due to the large number of small businesses required to undergo digital transformation. Professional bodies stress that businesses need sufficient time to select the appropriate specialised software, complete the necessary technical configurations and, most importantly, train their staff in order to prevent errors when transmitting data to the myDATA platform.

Financial Penalties and Strict Fines for Non-Compliance

In addition to the operational need for modernisation, timely compliance with the new framework is essential, as audits conducted by AADE may result in substantial administrative fines.

Under the legislation currently in force (Article 54H of the Code of Tax Procedure), failure to transmit the relevant invoices and other documents to the myDATA platform results in a fine equal to 50% of the VAT attributable to each document that was not transmitted, where the underlying transaction is subject to VAT. The minimum fine per tax audit is set at €250 for businesses using a single-entry bookkeeping system and €500 for those using a double-entry bookkeeping system.

For VAT-exempt transactions, separate fines of €500 or €1,000, respectively, are imposed per audit. This makes the risk associated with delayed compliance particularly costly for every business and self-employed professional.