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Emerging e-Invoicing Regulations: Comparative Overview in Greece, Israel, Poland and Romania


On September 23, 2022, Greece introduced Law 4972/2022, a pivotal regulation mandating the adoption of electronic invoicing for all transactions with government entities, irrespective of the transaction’s value. This law also brings forth additional penalties for non-compliance, empowering tax authorities to temporarily suspend operations for non-compliant taxpayers, with suspension durations ranging from 48 to 96 hours, depending on the severity of the violation.

Looking ahead to 2023, the Greek government, as outlined in the Official Gazette on April 12, 2023, unveiled the phased implementation plan for mandatory business-to-government (B2G) electronic invoicing. 

The legislation specifies that public entities must be equipped to receive and process electronic invoices, with suppliers obligated to transmit invoices in accordance with European standards, mainly using the Peppol model. The eligibility license (YPAHES) is given to invoicing software providers to ensure secure transmission of documents.

The government has released a comprehensive implementation schedule categorized by public entities to facilitate a smooth transition. Starting September 12, 2023, key entities, such as the Ministry of Infrastructure and Transport and the Ministry of Digital Governance, are mandated to comply. The rollout moves on to the next phase on January 1, 2024, encompassing all remaining central administration entities, followed by all administrative bodies on June 1, 2024. Finally, by January 1, 2025, all general state administrative expenses will have to adhere to the electronic invoicing mandate.

On the broader landscape, Greece’s myDATA serves as the electronic compliance system, orchestrating the digitization of fiscal and accounting information for companies. Since July 2021, companies adhering to Greek accounting standards must transmit their information to the myDATA platform, marking a significant shift towards streamlined and digitized financial reporting.


In light of the current circumstances in Israel, the Israel Tax Authority (ITA) has decided to defer the introduction of e-Invoicing for transactions exceeding 25,000 Shekels until April 2024 (approximately €6100), postponing the original implementation date from January. Throughout this extension period, invoices above 25,000 Shekels will still qualify for VAT tax claims without the requirement for an allocation number. However, companies are encouraged to apply voluntarily for an allocation number from January. Those who have completed the process by then will benefit from expedited processing of VAT refunds by the ITA.

Israel has proposed a model for sending electronic invoices to the tax authority in real time, known as CTC. This entails the tax authority validating received invoices before they are transmitted to the final recipient, aligning with validation models used by countries like Mexico and China.

Exploring the landscape of B2B electronic invoicing in Israel, the current status is voluntary, explicitly applying to B2B company transactions. The Ministry of Finance has established a phased timetable for the implementation of the electronic invoicing system, categorized by the value of the invoices:

  • January 1st, 2024: Voluntary phase
  • April 1st, 2024: Mandatory for all invoices exceeding 25,000 NIS
  • January 1st, 2026: Mandatory for all invoices exceeding 15,000 NIS
  • January 1st, 2027: Mandatory for all invoices exceeding 10,000 NIS
  • January 1st, 2028: Mandatory for all invoices exceeding 5000 NIS

Under the real-time validation model in Israel, obtaining a unique identifier from the tax authority is mandatory. Invoices lacking tax authority validation will not be eligible for deductions. This allocation number must be integrated into the electronic invoice before delivery to the buyer.

The pre-clearance model involves a step-by-step process:

  • Invoices must be communicated to and approved by the Israeli Tax Agency in real time, with the authority assigning a unique identifier (allocation number) and verifying data for approval or rejection.
  • Key transaction details must be shared with the tax authority, including the transaction date, invoice number, issuer and recipient company information, and the invoice amount excluding VAT.
  • Validated invoices are returned to the seller for delivery to the buyer.
  • Implementation of the e-Invoicing solution enables the recipient to verify received invoice data for document authenticity.
  • Electronic invoices must be archived for seven years.


The Ministry of Finance has mandated taxpayers to adopt e-Invoicing through the National E-Invoicing System (Krajowy System e-Faktur, or KSeF), as previously announced. These legislative changes aim to combat VAT fraud and tax evasion, with the effective date set for July 1, 2024.

However, on January 19, 2024, the Finance Minister of Poland announced a postponement in the implementation of KSeF due to system errors and possible improvements identified by the Ministry of Finance. The new implementation date is yet to be determined, expected in April or May 2024. A consultation organized by the tax authority is scheduled to start on February 16, involving various working groups with stakeholders. The final decision will be made upon the conclusion of the consultation.

Taking a general overview of KSeF, managed centrally by the Ministry of Finance, it serves as the designated platform for e-invoicing in Poland. This system streamlines the issuance of sales invoices and ensures their technical accuracy. Since January 1, 2022, taxpayers have had the option to voluntarily transmit structured e-invoices through this platform.

Before the postponement, the latest government document (Draft Regulation No: 827) outlined technical guidelines for KSeF, focusing on enhancing the system’s functionality and security. The proposed regulation suggests extending anonymous access to invoices during system failures, particularly emphasizing VAT RR invoices and VAT RR corrective invoices in contingency mode. QR codes will now be generated both in regular situations (KSeF online mode) and during contingency situations (KSeF offline mode). The Ministry of Finance (MoF) will soon release specifications, including QR technical requirements. Additionally, the scope of authorization will be broadened to include flat-rate farmers [farmers, who pay a flat rate of tax], as eligible taxpayers.


President Klaus Iohannis of Romania has signed fiscal and budgetary measures into law, including VAT regulations, that establish the compulsory use of electronic invoices. The legislation mandates the issuance and receipt of electronic invoices through the RO E-Invoice system, a centralized e-invoicing platform.

Romania has introduced new decrees outlining amendments and penalties for its upcoming B2B e-invoicing regime, set to launch in two phases in 2024. The regulations outlined in Government Emergency Ordinance 115/2023 include the following:

  • Simplified invoices for goods and services are now exempted.
  • Invoices for exports, non-resident counterparties, or B2C transactions are also exempted.
  • The 3-month grace period for fines, initially until April 1, 2024, has been extended to July 1, 2024, with amended penalty levels.

The legislation for the launch of B2B electronic invoicing for resident and non-resident businesses has received approval from the Parliament and the President. The rollout will occur in two stages:

  • January 2024: A near real-time reporting regime is proposed for invoices issued between January 1 and June 31, 2024. Penalties will be applied in July 2024. 
  • For domestic supplies, digital reporting of invoices (in XML) as well as paper invoices, is required within five working days of issuance. 
  • All fines will be imposed for non-compliance after March 31, 2024.
  • July 2024: Full pre-clearance electronic invoice submissions via the eFactură platform will become operational. 
  • Paper invoices will not be considered for tax compliance.

The Romanian e-invoicing regime mandated preclearance submission of invoices in CIUS_RO format (UBL 2.1 or CIN) to the government’s portal. This includes basic validation checks on information and format, with the possibility of this requirement being dropped from January 2026 to align with ViDA’s proposal of eliminating government pre-clearance checks from 2028.

After the grace period ends on April 1, 2024, substantial fines ranging from 5000 to 10,000 RON (approximately 1000 to 2000 EUR) may be imposed on larger taxpayers, while penalties from 500 to 2500 RON (100 to 500 EUR) are stipulated for other taxpayers failing to fulfill their obligation to issue electronic invoices through the RO E-Invoice system. The Romanian SAF-T and e-transportation began on July 1, 2022 for large taxpayers. High-risk goods require registration via API schema submission and must be recorded with ANAF using an XML document before any movement. In 2025, SAF-T compliance is expected to be obligatory for all taxpayers in Romania.

Regarding invoice reception, only electronic formats will be deemed valid starting from July 2024, with potential sanctions applicable to both the sender and the recipient. The foundation and operational framework for the national e-invoicing system are established by the government.


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