The Greek tax authority has published Decision 1047/2025 introducing a new set of amendments to Greece’s e-transport framework by amending Decision 1123/2024.
Following the recent updates carried out by Decision A.1046/2025, the new decision 1047/2025 focuses on terminology alignment, document types, field requirements, and the phased rollout of digital inventory tracking.
The changes aim to clarify scope, refine the myDATA reporting process, and support more accurate compliance processes.
Key Amendments are as follows:
- Terminology Standardization: The term “goods” is replaced by “inventory” throughout the regulation. The update reflects a broader application of the e-transport framework, including both sales-related and internal stock movements. All documents previously referred to as “Goods Transportation” documents will now be termed “Inventory Movement” documents.
- Inventory Movement Without Sales: Movements not involving a sale or supply to ships/aircraft must now be reported using only document types 9 or 10.
- Surpluses and Shortages: When surpluses or shortages are identified, only document type 10.1 (linked Quantity Receipt Note) can be used. Type 10.2 is no longer permitted in these cases.
- Cross-Border Transactions: Document types 14.1 and 14.2 are no longer in scope. Cross-border inventory reception must now be documented using types 10.1 or 10.2.
- Multiple Purposes in a Single Document: A single movement document can now include multiple movement purposes, provided each is listed per summary line.
- Retail Receipts via FEM: The updated framework allows retail receipts to be issued separately from transport documents when using Fiscal Electronic Mechanisms (FEM).
- Document Cancellation: Non-value movement documents (types 9 and 10) can now be cancelled before dispatch, with the option to link to a new document. This was previously only noted in Annex I.
- Field Adjustments: Key XML field changes include the use of TIN instead of VAT numbers, and the introduction of a new section for transport means (e.g., vehicle, vessel, flight). Some fields have been added, removed, or made mandatory earlier than initially planned.
- UID Composition: The Recipient VAT number field has been removed from UID composition for document types no longer in scope.
- QR Code Requirements: QR codes are now mandatory for document types 10.1 and 10.2, which were previously exempt.
- Scope Clarification: Inventory movements via postal and courier services and those involving energy products are now explicitly included. Retail inventory movements must be reported even without an accompanying value document.
- Updated Annex I outlines two implementation phases:
- Phase A: Document issuance and transmission to myDATA
- Phase B: Real-time tracking and receipt confirmation
Some features originally planned for Phase B are now required in Phase A.
- New Annex II – Operational Guide: A new Annex II provides a step-by-step operational analysis of the digital inventory tracking process, from document issuance to final receipt. This is a helpful guide for taxpayers implementing the mandatory e-transport framework.
Compliance Deadlines:
Phase 1 go-live is just days away, scheduled for 1 April. This deadline has been postponed once before, however, as it stands, Phase 1 remains set for 1 April 2025 and Phase 2 for 1 October 2025.
To learn more about Greece myDATA obligations, access our Sovos myDATA webpage.
