- Failure to issue the tax invoice, the tax notice, or the VAT invoice is punishable, under Law No. 9920/2008, by a fine equal to 100% of the undeclared tax resulting from the failure to issue, in addition to the tax itself and any late‐payment interest.
- If the taxpayer accepts the tax assessment and pays the liability, the penalty is reduced by 30% upon written request and submission of the payment mandate to the DRT.
- This relief applies only to violations involving the issuance of invoices, tax receipts, and the documentation of transactions, not to any other type of fine.
- Since the Fiscalization Law No. 87/2019, there has also been a special sanctions regime for invoices that have been issued but not fiscalized. For the current amounts of any specific fine, verification is carried out in advance.
Failure to issue a tax invoice, a tax notice, or a VAT invoice is one of the most frequently pursued violations by the tax administration, because it is directly linked to undeclared revenues. Law No. 9920/2008 “On Tax Procedures” punishes this offense with a fine directly tied to the amount of tax lost to the state, rather than a fixed sum.
From our daily work we often see taxpayers treat this as a “standard” penalty, unaware that there is a direct relief—the 30% reduction—which is only available when action is taken quickly and upon formal request, not automatically.
Read also: On the key changes to the law on tax procedures.
Fine for failure to issue an invoice, how is it calculated?
Base, 100% of undeclared tax
The fine for failing to issue a tax invoice, tax receipt, or VAT invoice is equal to 100% of the tax that remained undeclared precisely as a result of this failure to issue. The penalty amount, therefore, is not fixed but varies according to the value of the undocumented transaction.
Tax and late fees are paid separately.
The 100% fee does not, by itself, satisfy the tax obligation. Undeclared tax and the corresponding late‐payment interest are calculated and paid separately, in accordance with the provisions of the Tax Procedure Law or the relevant specific tax laws.
Reduction of the 30% fine, as requested.
Condition, acceptance of the assessment, and payment
The 30% relief is activated only when the taxpayer accepts the tax assessment issued by the administration and pays the liability themselves, rather than contesting it. The reduction is not applied automatically without this step.
Procedure before the DRT
The reduction of the fine is carried out by the tax administration upon submission of a written request to the relevant regional tax directorate, together with the payment receipt issued by the taxpayer.
This facilitation has a clear limitation in its application:
- Valid only for violations in the issuance of tax invoices.
- Also applies to tax invoices.
- It applies to the documentation of transactions in general, but not to every other type of tax fine.
Every time there is a tax or financial change that affects your business, we notify you directly by email with a practical explanation.
Send me free notificationsHow does this relate to today's fiscalization?
The difference between non-issuance and issuance outside the fiscal framework
The rule described here concerns the complete non-issuance of the invoice, receipt, or VAT invoice. Since Law No. 87/2019 “On the Invoice and the System for Monitoring Turnover,” the vast majority of invoices are now issued through the fiscalization system, and issuing an invoice outside this system constitutes a separate violation, with its own rules, different from the complete non-issuance addressed by the 2019 notice here.
Why the current figures need to be verified
Law No. 9920/2008 has undergone several amendments since 2019, and the fiscalization framework has added additional rules on transaction documentation. For this reason, the exact fine amount for a specific case is verified in advance, rather than automatically assuming the 2019 figure.
Why it Matters
An invoice not filed in a timely manner can cost many times its original value, precisely because the penalty is calculated on the lost tax, not on the invoice's own value.
The real cost of an unpaid invoice
When a transaction remains undocumented, the business risks not only a fine but also the lost tax itself and the interest accrued until it is discovered—a cost that grows the longer it goes uncorrected.
How we handle this with our clients
When such a case is identified, we help the client quickly assess whether accepting the tax assessment and taking advantage of the 30% reduction is the best course of action, rather than letting the matter drag on and the cost continue to rise.
Frequently asked questions
How is the fine for failing to issue an invoice calculated?
It is equal to 100% of tax that remains undeclared as a result of non-filing, plus the tax itself and any interest and penalties, calculated separately.
How do I get the 30% reduction of the fine?
By accepting the tax assessment, paying the amount due, and submitting a written request to the DRT with the payment voucher attached.
Is the fine the same for an unfiscalized invoice?
Not necessarily. An invoice issued outside the fiscalization system is treated under the specific rules of Law No. 87/2019, which differ from the case of complete non-issuance addressed here. For specific cases, it is first determined which regime applies.
Does the 30% reduction apply to any type of tax penalty?
No. It applies only to violations in the issuance of tax invoices, tax receipts, and the documentation of transactions, as clarified by the DPT itself.
The original DPT notice remains the basis for this fine. Official DPT Announcement. For invoices issued outside the fiscalization system, the current rule is verified separately, in accordance with Law No. 87/2019.
