Greece Publishes Accreditation Scheme for E-invoicing Service Providers

Joanna Hysi
February 27, 2020

Certification of e-invoice service providers is an important first step and milestone ahead of the implementation of e-invoicing in Greece.  The Greek Government has now defined the regulatory framework for e-invoice service providers, their obligations, and a set of requirements needed to certify their invoicing software.  

Key details and parameters

Scope

E-invoice service providers are defined as entities authorized by the taxpayer to issue invoices on their behalf electronically for B2B and B2C transactions. They’re responsible for issuing, the authenticity and integrity, and the transmission of transaction data to the tax authority in real-time. Other outsourced functions include e-invoice delivery to the buyer directly and archiving on behalf of the issuer.

Software requirements

 The service provider’s software must meet a number of requirements. It must for example be able to guarantee integrity and authenticity of the invoice according to the SHA-1 algorithm, provide real-time connection with the customer’s software, and make the invoice available to the customer in electronic  (or, upon request, in paper) form. Any software which meets these criteria is granted a “Suitability Permit”, which is valid for five years.

Service provider requirements

Service providers must be a Greek registered entity or be permanently established in Greece. They must also meet certain technical, security and financial criteria and the invoice data must be stored within the EU. Other obligations include making a user manual available to the customer, notifying the tax authority of each outsourcing contract they have entered into, and addressing privacy-related matters.

Transmission method and e-invoice format

The transmission method to the myDATA will be the myDATA REST API and the format of the e-invoice exchanged between the parties is based on the EN norm, as defined by law just a few days ago. Any details and further legislation are expected to be published on the myDATA website.

Through this Decision, the Greek Government is introducing the long-awaited secondary legislation, as mandated in the budget law 2020 earlier this year. Precisely how these provisions will work together with the myDATA scheme, scheduled to be fully operational on 1 April 2020, is still to be defined by the authorities. However, further legislation as well as a formal derogation decision from Brussels are still needed if the Greek government wishes to mandate e-invoicing in the country, since such a reform would deviate from principles laid out in the EU VAT Directive.   

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Author

Joanna Hysi

Joanna is a Regulatory Counsel at Sovos TrustWeaver. Based in Stockholm and originally from Greece, Joanna’s background is in commercial and corporate law with research focus on EU law and financial innovation. Joanna earned her degree in Law in Greece and her masters in Commercial and Corporate from London School of Economics and Political Science (LSE) in London.
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