The Independent Authority for Public Revenue (AADE) is seeking to bring order to the digital transition of agricultural products “from farm to shelf” by issuing new clarifications regarding the digital delivery notes that farmers are required to maintain. However, not all farmers fall into the same category. Some will issue the document themselves, others will be exempt, while in many cases the digital obligation may be assumed by the trader, cooperative, or olive mill instead of the producer.

Based on the new clarifications it has issued, AADE explains which farmers must issue digital delivery notes, who is exempt, and what changes apply to farmers’ markets, olive mills, and short-distance transport between fields and warehouses. These provisions, however, apply only temporarily during the next two months of the transition period. From October 12, when the requirement becomes mandatory for everyone, it will become clear who is able to adapt to the new rules and to what extent.

According to the new decision (Circular E.2038/2026) issued by AADE Governor Giorgos Pitsilis:

• Farmers under the special VAT regime (small-scale producers with a few family-owned plots in the village or limited production, such as peaches, etc.) will not issue digital delivery notes themselves. Instead, this will be done by the recipient—for example, a trader, olive mill, or cooperative—through a quantitative receipt note.

• Professional farmers under the standard VAT regime, as well as individuals engaged in another profession who also carry out farming activities, may, in certain cases, leave the issuance of the document to the counterparty, using the indication “Reverse Movement,” provided that the buyer also agrees.

• No digital delivery note is required when products are transported between a producer’s own field and warehouse, provided the distance does not exceed 10 kilometers. However, uncertainty remains regarding situations where there is no scale in the field. For example, what applies when the products must be transported 500 meters to a weighing point without issuing a delivery note? In theory, under a strict inspection, the fine could reach €5,000.

• For farmers’ markets and open-air markets, the consolidated delivery note may remain handwritten until October 11, 2026 (the start date of Phase Two). From October 12, 2026, it becomes mandatory for all professional farmers to issue it digitally.

• Any products that remain unsold may be returned using the same delivery note. Upon arrival back at the producer’s premises, a quantitative receipt note is issued. The aim is to make implementation of the measure easier for producers and sellers.

In other words, AADE recognizes the challenges of the transition and is attempting to facilitate the process by clarifying that the system does not apply uniformly to everyone: the small producer under the special VAT regime, the professional farmer, the olive mill, and the farmers’ market will each operate under different rules. To avoid confusion, exemptions, transitional deadlines, and special provisions have been introduced for returns, unsold products, and short-distance transport.

Specifically, under the new framework:

1. The goal is for small producers not to have to manage the digital documentation themselves. It remains to be seen how this will work in practice—whether, for example, the trader will be required to assume this responsibility or, if the trader refuses, whether the obligation will revert to the farmer.
2. For farmers under the standard VAT regime, the situation is more complex. However, there is also greater flexibility. AADE allows, in certain cases, for the document to be issued not by the farmer but by the counterparty—that is, the trader, cooperative, or olive mill. In such cases, the document will bear the indication “Reverse Movement.” This provision is particularly important in practice, as its purpose is to simplify day-to-day operations when the transport is carried out using the producer’s own vehicle.
3. The circular also provides that no digital delivery note is required when products are transported between the same producer’s fields and storage facilities, provided the distance does not exceed 10 kilometers. This measure eases the burden for many farmers making short, routine transport trips.
4. Special rules also apply to farmers’ markets and open-air markets. Until October 11, 2026, the Consolidated Delivery Note may still be issued manually. From October 12, 2026, it must be issued digitally.

However, if some products remain unsold—as often happens—there is no need to conduct an inventory every time the market closes. The products may return to the producer’s premises using the same delivery note, and a quantitative receipt note is issued there. If a producer attends more than one farmers’ market without returning to the farm or warehouse in between, the original document covers the entire journey. It remains to be seen, however, how accurately this process can be followed in the common situation where the producer has discarded the unsold produce in organic waste (“brown”) bins and returns to the premises with an empty vehicle.

In addition, AADE provides that if there is an internet or power outage, the transaction does not have to be interrupted. The document may be issued manually (if the transaction takes place away from the business premises) or issued with the appropriate indication and transmitted later once the connection has been restored.