Digital delivery notes: what to do before October 12, 2026

After mandatory e-invoicing, goods movement is next. The delivery note, the paper that accompanies every shipment, is going digital: issued electronically, transmitted to myDATA before transport begins, with the recipient digitally confirming what arrived. The dates have already shifted more than once, so let’s look at them as they stand today, without the scare tactics.

What exactly changes

Today you issue a delivery note from your software or a paper block, and the paper rides with the driver. Under the new regime the document is issued digitally before the goods leave and is transmitted to the tax authority (AADE) in real time. On the road, checks happen electronically. On delivery, the recipient confirms receipt, and in the second phase also declares what was received quantitatively. “I ordered 100, 98 arrived” gets a digital trail.

AADE’s goal is obvious: goods travelling without paperwork means a sale that will never be declared. Traceability closes that hole.

The dates, as they stand today

• Phase A, in force since 2025: businesses with gross revenue above 200,000 euros, plus specific sectors regardless of turnover: pharmaceuticals, fuel, building materials. Digital issuance and transmission of movement documents.
• Phase B, from October 12, 2026: the loading, transshipment and receipt processes activate for all obligated businesses, together with the transmission of quantitative and qualitative inspection data. This phase was scheduled earlier and was postponed because implementation questions remained open.
• From January 1, 2027: unified goods coding (TARIC) is added.

This timeline has already changed in the past and may change again. Accounting bodies have formally requested further extensions. That does not mean you leave it to chance; it means you confirm the deadlines with your accountant before committing to dates.

Who it affects and who it doesn’t

If you move physical goods, it affects you: wholesale, manufacturing, warehouses, e-shops shipping B2B or moving stock. There are important exemptions though:

• Retail sales with a value document. A parcel to a consumer accompanied by a receipt does not need a digital delivery note. If your e-shop only sells retail, the burden is smaller than it sounds.
• Moves under 10 km between facilities of the same business.
• Special-status VAT farmers, where the recipient issues the document.
• Continuous-flow networks (electricity, water, gas), empty packaging, fixed assets not being sold.

The parts that need attention

Phase one showed where things break in practice. If the connection drops at loading time, the document is issued with a connection-loss flag and transmitted once connectivity is restored, at the latest the next day. In remote locations handwritten issuance is still allowed. AADE’s myDATAapp now supports offline operation too.

And the penalty for moving goods without documents is not symbolic: 5,000 euros per audit for simple books, 10,000 euros for double-entry books.

What is worth doing now

1. Check which phase you belong to. Revenue above 200,000 euros or a Phase A sector means you should already have moved. Everyone else has until October 2026.

2. Check whether your software supports digital movement documents. If you have already solved e-invoicing, the same provider usually covers goods movement too. One decision, not two.

3. Map your flows. How many delivery notes you issue per month, from how many locations, with what system. If the answer is “a few, from one location”, off-the-shelf covers you. If it is “many, from a warehouse, an ERP and an e-shop combined”, then automation is worth the effort and the time to set up properly, before the deadline squeezes you.

If your flow needs a connection that doesn’t exist off the shelf, e-shop to warehouse, ERP to courier, production to points of sale, that is work I do. Write to me about how your goods move, and I’ll tell you honestly whether you need custom work or something ready-made covers you.