MD 197/2026 — E-invoicing system amendments

Factual summary

Amends Ministerial Decision No. 243 of 2025 on the Electronic Invoicing System. It excludes transactions between members of the same VAT Tax Group for 24 months from 1 January 2027; sets the issue-and-transmit period at 14 Business Days, subject to the VAT-law timeline for registrants (Art. 6(4)); replaces the data-storage article with a duty to retain e-invoices, e-credit notes and their data for the Tax Procedures Law period and produce them to the FTA on request; and repeals the system-failure article (Art. 12).

What it means in practice Professional insight

Who: every person subject to the Electronic Invoicing System. What changes: VAT-group members get a 24-month exclusion for transactions between themselves from 1 January 2027; the 14-day period is counted in Business Days; data must be kept for the Tax Procedures Law period and produced on request, without the former in-State storage wording; no separate two-business-day system-failure notice.

Key provisions

• Art. One MD 243 Art. 1: the "Accredited Service Provider" definition now refers to the legislation regulating the Electronic Invoicing System; "Tax Group" and "Taxable Person" are added; "System Failure" is deleted.
• Art. Two Replaces MD 243 Art. 4 (adds the exclusion of transactions between members of the same Tax Group for 24 months from 1 January 2027), Art. 6(5) (14 Business Days, subject to Art. 6(4)) and Art. 11 (retention for the Tax Procedures Law period; production to the FTA on request).
• Art. Three Repeals MD 243 Art. 12 (system-failure notice).
• Art. Four Published in the Official Gazette; in force on 1 October 2026.