Greece e-invoicing

Electronic invoicing is mandatory for B2G supplies and optional for B2B and B2C supplies.

However, the Greek authorities want to implement a nationwide B2B e-invoicing mandate as part of the e-invoicing reform. The reform started in 2020 with the roll-out of the country’s e-audit scheme called myDATA.

E-invoicing requirements across B2G, B2B and B2C transactions vary, making it a demanding task to stay on top of compliance with the country’s e-invoicing regulations. This page details the current status quo and will be updated as changes are enforced – be sure to bookmark it and revisit it to stay compliant.

Table of contents

At a glance: E-invoicing in Greece

Greece B2G e-invoicing

CTC Type

E-invoicing through an accredited e-invoicing service provider

Network

PEPPOL

Format of e-invoice

EN-compliant, PEPPOL BIS 3.0 (Greek CIUS)

eSignature Requirement

N/A

Archiving Requirement

5 years

Greece B2B e-invoicing

E-invoicing/CTC Type

Post-audit/Voluntary CTC e-invoicing (via an accredited e-invoicing service provider)

Network

Exchange not regulated (unless CTC e-invoicing is used)

Format of e-invoice

E-invoice format not regulated (EN-compliant, if CTC e-invoicing is used)

eSignature Requirement

N/A

Archiving Requirement

5 years

Greece B2C e-invoicing

Greece does not have a mandate for e-invoicing as far as B2C transactions are concerned. Fiscal devices currently used for issuing compliant invoices for B2C sales must follow new technical requirements for the connection and real-time reporting of B2C sales data to the myDATA platform (new generation online tax mechanisms).

E-Invoicing regulations in Greece

In Greece, there are several regulations relating to electronic invoicing. The regulations include:

  • The transposition of Directive 2014/55/EU mandates the government sector to receive electronic invoices.
  • Joint Ministerial Decision No. 52445 ΕΞ/2023, mandating the use of e-invoices for all sales made to the government.
  • Joint Ministerial Decision no. 63446/2021 (as amended by Joint Ministerial Decision no. 31781ΕΞ2022/2022), specifies the e-invoice format for B2G transactions which is compliant with the European standard (EN 16931).
  • The Ministerial Decision No. 1017/2020 specifies the e-invoice format for B2B transactions in the nation.
  • The Ministerial Decision No. A.1035/2020 dictates rules and regulations for accredited e-invoicing service providers.

Timeline: B2G e-invoicing adoption in Greece

The tax authority is rolling out the B2G e-invoicing mandate in phases. The mandate covers most public contracts, from defence to general supplies and services. The gradual implementation is ongoing, covering:

  • As of 12 September 2023, suppliers to some major government agencies (e.g. Ministry of Transport, Ministry of Digital Transformation, Ministry of Migration and Asylum, etc.).
  • As of 1 January 2024, suppliers to all central government agencies.
  • From 1 June 2024, suppliers to all other government authorities.
  • From 1 January 2025, other government expenses must be invoiced electronically (outside the scope of public procurement contracts).

Format of an e-invoice in Greece

Governments implement electronic invoices to simplify and standardise the transmission of data in transactions, and Greece is no different. The e-invoice format in B2G transactions is based on the European standard for e-invoicing (EN 16931) and PEPPOL BIS Billing 3.0.

The format of a B2B e-invoice in Greece is not regulated and largely falls in line with the obligations of the EU VAT Directive. Invoices must include information such as:

  • Issuance date
  • Date of supply
  • Supplier’s VAT number
  • Names and addresses of both supplier and customer
  • Full description and quantities of goods
  • Net taxable value
  • VAT rate and amount

CTC e-invoicing via an accredited e-invoicing service provider is voluntary. While Greece has yet to implement a nationwide B2B mandate, it has a set standard and format for taxpayers who issue e-invoices voluntarily. The e-invoice must be in a structured format compliant with the European standard.

Process of B2G e-invoicing in Greece

If you do business with a public sector entity in Greece, you must issue invoices electronically. Doing so requires you to follow a set process:

  1. Prepare the e-invoice data and send it to the accredited e-invoicing service provider.
  2. The e-invoicing service provider validates the invoice data before submitting it, using the respective services of the National Interoperability Center (KED), which is responsible for receiving all e-invoices by suppliers through the PEPPOL network.
  3. The e-invoicing service provider reports certain invoice data in a structured format and according to specific technical specifications to the myDATA platform for clearance and receives back a unique registration number (MARK).
  4. The e-invoicing service provider prepares the e-invoice based on the European standard, according to the Joint Ministerial Decision no. 63446/2021 (as amended by Joint Ministerial Decision no. 31781ΕΞ2022/2022).
  5. The e-invoicing service provider submits the e-invoice to the Access Point of the National Interoperability Center through the PEPPOL network.
  6. The National Interoperability Center receives and validates the e-invoice according to the European standard and national rules for e-invoicing.
  7. The National Interoperability Center routes the e-invoice to the competent contracting authority.
  8. The competent contracting authority handles the e-invoice according to their internal procurement and payment process.
  9. Upon receipt of the e-invoice, the contracting authority sends a response message regarding the status of the e-invoice back to the supplier through the National Interoperability Centre and his e-invoicing service provider.

Benefits of using e-invoicing in Greece

Greece provides incentives for using CTC e-invoicing through accredited service providers, as per Law 4701/2020, for the 2020-2024 tax years.

These incentives include a reduction of the statute of limitation for fiscal matters by two years and a depreciation of twice the cost incurred for acquiring technical equipment and software required to implement electronic invoicing.

Implementing e-invoicing can also be beneficial by automating and standardising your processes, reducing the chance of clerical errors and freeing up resources.

Future of e-invoicing in Greece

While the future of e-invoicing in Greece is not set in stone, the end goal seems clear.

With Greece engaging in a dialogue with the European Commission over a nationwide e-invoicing mandate, there is a chance that electronic invoicing will become mandatory for B2B transactions.

Many European countries are looking to digitize their tax systems to increase transparency for tax authorities and reduce the VAT gap – Greece appears to be moving in this same direction.

Additional obligations for VAT compliance in Greece

Electronic invoicing and myDATA are important obligations for taxpayers in Greece to be aware of, but there are more compliance needs that many need to meet.

Consider the evolving nature of tax regulations. The number of obligations and the chance of change make meeting your obligations an ongoing, demanding task.

It’s vital that you are aware of what applies to your organisation, and how to stay on top of your requirements. Find out more about Greece VAT compliance through our dedicated overview, and bookmark the page to stay updated on any regulatory updates.

FAQ

Electronic invoicing is mandatory for B2G supplies, as of September 2023, and optional for B2B and B2C supplies. However, invoice data for B2B, B2G and B2C supplies and other accounting data must be reported to the myDATA platform.

Taxpayers who transact with the public sector must issue electronic invoices based on the European standard.

The PEPPOL network must be used to exchange e-invoices between businesses and the public sector (B2G transactions).

Since 2021, companies established in Greece have been required to electronically report accounting data through the myDATA system. The implementation timeline of the myDATA mandate is ongoing.

Greece’s myDATA is a reporting obligation of ledger-type data, and it is not to be confused with e-invoicing as it doesn’t require invoices to be issued and exchanged in electronic form.

Greece mandates e-invoices in B2G transactions and allows for invoices in B2B/B2C transactions to be issued and exchanged on paper or electronically, following the standard e-invoicing rules of the EU VAT Directive or the voluntary CTC e-invoicing scheme.

How Sovos can help

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