In accordance with Article 5 of Law 4308/2014 (Greek GAAP), the electronic delivery notification system is scheduled for launch in Greece by the end of the year.
The implementation of the electronic delivery notification system will be conducted in two phases, each of which will necessitate the completion of disparate fields by users.
In the initial phase, users will be required to input data pertaining to the sender and consignee, the delivery document number, the MARK and QR codes, the date of dispatch, the commencement of delivery, the loading and unloading locations, the type and quantity of goods, and other pertinent details. The implementation date is scheduled for 1 December 2024.
In the second phase, users will be required to input the exact time, means of transport, reloading data (if applicable), Intrastat codes, and the Value Added Tax (VAT) numbers of the carrier. This phase will commence on April 1, 2025.
Failure to comply may result in penalties of 100 euros per document not transmitted per day, with a maximum of 20,000 euros per year.
Status of B2B e-invoicing in Greece
The publication of Law 5073/2023 "Measures to Combat Tax Evasion" on 11 December 2023 introduced a number of significant provisions designed to strengthen tax compliance within the country.
According to the content of this law, themyDATA platform has undergone updates and upgrades as of 1 January 2024, with the potential for mandatory e-invoicing in Greece to be established as early as 2025.
The new features include:
- The commencement of the obligation to submit via the ERP API the following invoicing data: issued tax documents, accounting books and records, relevant tax records of electronic cash registers and their files and created data.
- It is imperative that the value of taxable transactions and VAT receipts of an entity does not fall below the figures derived from the tax documents transmitted to myDATA.
- The deadlines, transaction reports, technical specifications and exemptions will be defined by ministerial decisions.
Furthermore, the Greek Ministry of Finance and the Greek tax authority (AADE) have announced the extension of tax incentives for taxpayers who adopt e-invoicing through certified e-invoicing providers until 2024.
What's new in B2G e-invoicing in Greece?
On 12 April 2023, Resolution No. 52445 EX 2023 was published, thereby making the use of the B2G e-invoice mandatory in Greece. The implementation is being carried out in a gradual manner, commencing in September 2023 in accordance with the following schedule:
12 September 2023. The following entities were involved in the project: the Ministry of Infrastructure and Transport, the Ministry of Digital Governance, the Ministry of Immigration and Asylum, the Municipality of Athens, the National Health Centre, the Central Ministry of Development, Procurement and Investment, the Information Society S.A., the Athens University of Economics, Attiko Metro S.A., EYDAP S.A., and Egnatia Odos S.A.
As of 1 January 2024, all other obligated belonging to the General Administration will be required to comply with the aforementioned regulations.
As of 1 June 2024, other contracting entities.
As of 1 June 2025, other entities that are dependent on the General Administration.
On the other hand, the use of e-invoicing is not mandatory for the following contracts:
- Contracts concluded in the fields of defence and security.
- Public contracts and contracts for projects, preparation of studies and provision of technical and scientific services.
- Concession contracts for works and services.
- Public expenditure of less than 2,500 euros.
- Public contracts of low value specified by law.
History of electronic invoicing in Greece
In 2017, Greece set up the “Interoperable eInvoicing in Greece (GRinv) programme”. The programme aimed to create a model for B2G e-invoicing.
ESIDIS - Promitheus.gov.gr is the national e-procurement system that allows suppliers of public institutions to exchange e-invoices.
After creating the best way to use e-invoicing in Greece, the government decided to make it a voluntary tool in different areas. B2G, B2B and B2C.
The government started work on GAOS, an electronic platform for approving, processing and paying electronic invoices.
Mandatory B2G e-invoicing
El Gobierno heleno decretó el 29 de octubre de 2018 un proyecto de ley para posponer la Directiva 2014/55/UE, que finalmente tuvo lugar durante el primer trimestre de 2019 a través de la Ley 4601/2019.
The Greek government passed a bill on 29 October 2018 to delay the EU directive. This was finally implemented in the first quarter of 2019 through Law 4601/2019.
Two joint ministerial decisions (JMDs) were also published as a regulatory complement.
Ministerial Decision No. 1017/14.02.2020 (Edition B, folio 457) set out the format of the B2B e-invoice, which was compatible with European standards and PEPPOL. This decision also includes the CIUS for B2G.
Ministerial Resolution No. A.1035/18.02.2020 (Number B, folio 551) of the Ministry of Finance sets out the rules and regulations concerning e-Invoicing Service Providers.
B2B e-invoicing in Greece is allowed, but not mandatory. It is up to the buyer to decide whether to use it.
E-invoicing system in Greece and myDATA platform
All electronic invoices use the EN standard. The GSIS PA has set up a Peppol Access Point (AP). This point receives electronic invoices from the Greek State and sends responses.
Once the e-invoices have been checked by the AP, they are sent to the Interoperability Centre, where they are stored and sent to the right public body.
The Interoperability Centre also manages responses from public procurement entities. This process includes accepting, paying or rejecting electronic invoices using SOAP.
The Greek Ministry of Development and Investment manages a horizontal IT system that can receive electronic invoices from the interoperability centre and process them.
The e-invoicing system in Greece has the myDATA platform, which receives e-invoices linked to B2G and B2B transactions. This platform lets the Greek authorities process data and create individual financial reports for each taxpayer in Greece.
The e-invoice system will comply with European regulations and is currently being designed.
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