What has to be on a Cyprus invoice

Where the rules actually live

If you look for invoice requirements in the Cypriot VAT Law 95(I)/2000, you will not find them. The law delegates the question; the fields themselves sit in Regulation 12 of K.D.P. 314/2001, the VAT General Regulations. That matters because the regulation is more precise — and in two places more relaxed — than almost every summary written about it.

The mandatory fields

Regulation 12(1) requires:

• an identification number
• the time of supply, or the date of a payment received on account
• the date of issue
• the supplier’s name, address and VAT registration number
• the customer’s name and address
• a sufficient description of the goods or services
• per line: the quantity or unit price, or the extent of the service, the rate and the net amount
• the total excluding VAT
• the percentage of any cash discount
• the total VAT

On top of that, specific notes where they apply: the margin scheme for travel agents, the details of a VAT representative, “Cash Accounting”, “Self-Billing” and “Reverse Charge”.

Regulation 12(3) adds one rule people miss: exempt and zero-rated items have to be shown separately, with their own totals per supply and rate.

Because the rate and the net amount have to appear per line, rounding decides whether the totals add up: the VAT calculator rounds once at the end and derives the VAT as the difference, so the figures reconcile to the cent.

Two things Cyprus does not require

This is where the regulation differs from the received wisdom, and both points are worth knowing because they save work.

The customer’s VAT number is not a mandatory field on a domestic invoice. Regulation 12(1) asks for the customer’s name and address, nothing more. It becomes mandatory for cross-border supplies under Regulation 12(1A), where you also prefix your own number with CY and state the customer’s number with its country code. Lists of “14 mandatory invoice fields for Cyprus” circulating online say otherwise; the regulation is the regulation.

Strict sequential numbering without gaps is not prescribed either. The regulation asks for an “identification number”. We searched the consolidated text for the Greek words for sequential, consecutive and ascending and found no such requirement in the invoicing part. The EU VAT Directive does speak of a sequential number based on one or more series, and separate rules apply to handwritten and mechanical documents and to fiscal devices — but the Cypriot invoicing regulation itself does not impose the gapless series that advisory blogs describe.

None of that is an argument for sloppy numbering. Continuous numbering is good practice, easy to defend in an audit, and what our own product does. It is simply not the legal hook people claim it is.

When the invoice has to go out

• Domestic: within 30 days of the time the supply is treated as taking place (Regulation 11(5)). A longer period requires written permission from the Commissioner.
• Intra-Community supplies, and services where the customer accounts for the VAT: by the 15th day of the following month (Regulation 11(6)). Triangular transactions: 15 days.

The second deadline is the one that catches people, because it is a calendar date rather than a count from the transaction — and it lines up with the monthly VIES statement.

Language and currency

Language: there is no obligation to invoice in Greek. Regulation 11Β says that if an invoice, or part of it, is not in an official language of the Republic, the Commissioner may ask in writing for a translation within 30 days. English is therefore fine; the duty only arises on request. You will find sources claiming invoices must be in Greek — that is not what the regulation says.

Currency: Regulation 12(4) allows amounts in any currency, provided the VAT amount is stated in euro. Conversion uses the European Central Bank rate for the day in question.

Simplified invoices, and the receipt that carries a 20% penalty

Two lighter documents exist, and the second one has teeth.

Simplified retail invoice, up to €85 (Regulation 14): a retailer may, on request from a taxable customer, issue an invoice with only the trader’s name, address and registration number, the date of issue, a sufficient description, the total including VAT, and per rate the total including VAT and the rate applied.

The lawful consumer receipt (Regulation 13Α): for supplies to non-taxable persons a receipt has to be issued at the time of supply, carrying the date, an identification number, the supplier’s name, address and registration number, a sufficient description, the total including VAT, the total and rate per rate band, and whether it was cash, a deposit or a part payment.

Failing to issue that receipt is the most expensive small mistake in the Cypriot VAT system: Article 45(9) sets the penalty at 20% of the value of the transaction, and Article 45(11Α) makes it a criminal offence punishable by a fine of up to €1,700, up to three years’ imprisonment, or both.

Reverse charge and intra-EU wording

The prescribed note is short. Regulation 12(1) requires the words “Αντίστροφη χρέωση” — reverse charge — where the recipient is liable for the tax. A citation of the legal basis is not a Cypriot requirement: the formulas like “Article 196 EU VAT Directive” that appear in templates are not mandated here, however common they are.

For intra-Community supplies, the invoice follows Regulation 12(1A) and the 15th-of-the-following-month deadline. Regulation 88Α ties the zero rating to two conditions: the customer has given you a valid VAT number, and the recapitulative statement has been filed.

One subtlety on zero-rated supplies: Regulation 15(a) takes zero-rated supplies out of the invoicing regulations altogether — except those connected with the acquisition of goods in another member state. In other words, a purely domestic zero-rated supply does not itself trigger the VAT invoice obligation, while an intra-EU one does.

Neither applies outside the EU. Reverse charge and VIES are single-market mechanisms. Once goods cross the EU’s external border it becomes a customs matter: the invoice accompanies a customs declaration, and that can only be lodged with an EORI number. Import VAT is then paid at the border rather than reverse charged.

Credit notes and the three-year wall

For a change of VAT rate or exemption category, Regulation 13 requires a credit note within 14 days, titled “Πιστωτικό σημείωμα – αλλαγή συντελεστή του Φ.Π.Α.”, carrying its own identification number and date plus the number and date of the original invoice.

More important in daily practice is Regulation 27: an increase or decrease in consideration, evidenced by a credit or debit note, is adjusted — but not once it occurs more than three years after the end of the tax period of the original supply. After that, the correction has nowhere to go.

Cyprus does not set out a separate list of mandatory fields for ordinary credit notes beyond Regulation 13; Regulation 22 simply requires you to keep every credit and debit note issued and received.

Retention: six years or seven?

Here two official Cypriot sources contradict each other, and we are not going to pretend otherwise:

• The Tax Department’s web page on keeping books and records says six years.
• The Tax Department’s own General VAT Guide (EE10), chapter VIII, says seven years.
• The VAT Law’s Tenth Schedule allows regulations to require retention for a period not exceeding seven years, and imposes seven years on non-taxable persons who carry on a business.
• Eight years, which appears in advisory blogs, has no basis in the law or the regulations.
• For One Stop Shop records the period is ten years from the end of the year of supply.

The regulation that would settle it, K.D.P. 27/2002, is linked from gov.cy as a download that returns a 404, so we could not check it at source. Practically: keep everything for seven years and the question never arises.

Electronic storage is expressly allowed. Invoices must be kept in their original form — paper as paper, electronic as electronic — and where stored electronically, the data assuring authenticity and integrity has to be kept electronically too. The Commissioner can require production within five days. Storing outside Cyprus must be notified in advance, full online access is required, and storage in third countries without a mutual assistance agreement is not permitted.

Electronic invoicing today

• No B2B or B2C mandate in Cyprus. Electronic invoices are equal to paper, subject to the recipient’s agreement, with authenticity, integrity and legibility assured from issue to the end of the retention period — through business controls with a reliable audit trail, or optionally a qualified electronic signature or EDI.
• Public bodies (B2G): under Law 89(I)/2019, central authorities have had to receive and process EN 16931 invoices since 18 April 2019 and sub-central ones since 18 April 2020. There is no obligation on suppliers to send them electronically; submission via Peppol or the government gateway is voluntary.
• ViDA: structured e-invoicing and digital reporting become compulsory for intra-EU B2B supplies from 1 July 2030. Cyprus runs a post-audit model today, with no clearance and no real-time reporting. A decided national B2B mandate does not exist.

Electronically produced consumer receipts are a separate matter: they need an approved fiscal device.

What it costs to get this wrong

From Article 45 of the VAT Law:

• Missing consumer receipt: 20% of the transaction value; as a criminal offence, up to €1,700 and up to three years.
• Breaching the regulations or the record-keeping duty: €85 per breach.
• Breaching the retention duty: €341.72.
• Issuing an invoice showing VAT without being registered: about €85.
• Reverse-charge and place-of-supply breaches: €200 per tax period, capped at €4,000.
• Late VAT return: €100. Late payment: 10% additional tax plus default interest.

Two honest footnotes. The consolidated law text still prints some of these as £50 and £200 — pre-euro amounts carried forward — while practice and advisory sources quote €85 and €341.72. And the interest rate on late VAT is set by ministerial decree each year; the consolidated text still shows 9%, while the single public default rate for 2026 is 3.5%. We could not verify the 2026 VAT figure at source.

Beyond the fixed amounts there is a quieter risk: under the Tenth Schedule the Commissioner may require documents as a condition of input VAT deduction, which means a non-compliant purchase invoice can cost you the deduction.

What this looks like in practice

Almost every requirement above is decided before you write the invoice: whether the customer is domestic or in another member state, whether they are a business with a valid VAT number, which rate applies, whether the reverse charge note belongs on it. Get that wrong at the client level and every invoice for that client is wrong the same way.

That is why Volk Accountant stores country, VAT number and tax treatment on the client record: the mandatory fields come out of it, the reverse-charge note appears where it belongs, and the same invoice goes out in the client’s language and in English for the authorities. See how Cypriot VAT is handled in the product, or read on about the quarterly VAT return these invoices feed into.