The second phase of implementation of the digital delivery note is postponed until 2026, with the AADE planning to grant an extension due to the complexity of the project and the need for businesses to adapt smoothly.

By all indications, the second phase, which will extend digital monitoring of movements to all businesses, will not start in December 2025 as originally planned. The new timeline will aim to give businesses, accounting systems, and software vendors time to mature the interfaces and processes.

In effect, the universal “online” transmission requirement to the AADE for every commodity or cargo handled in the country by all businesses is “frozen” for this year. The phase A obligations remain in force only for businesses that have already joined. However, it is still allowed for any business to join phase 2 voluntarily and earlier, before phase 2 becomes mandatory from 2026, at a time to be announced.

What is currently in force (phase A)

From 2 June 2025, the digital delivery note is mandatory for companies with a turnover of more than EUR 200,000, with specific exceptions for foreign subsidiaries using the parent company’s commercial ERP software abroad.