Briefing Document & Podcast: Greece e-Compliance Mandates (2025)

Not yet included in this Briefing document & Podcast: B2B E-Invoicing delayed till 2026

Overview and Implications of Greece’s Mandatory e-Invoicing and e-Transport Regulations

Executive Summary:

Greece is implementing mandatory electronic compliance (e-Compliance) for businesses operating within its borders, encompassing e-Bookkeeping, e-Invoicing, and e-Transport (e-Delivery). These initiatives, managed by the Independent Authority of Public Revenues (AADE) through the myDATA platform, aim to improve tax collection, streamline transactions, and enhance transparency. Mandatory B2B e-Invoicing commences on July 1, 2025, while e-Transport has a phased rollout culminating in full mandatory implementation on December 1, 2025. Businesses must adapt their systems to comply with specific XML standards and validation processes via myDATA, or risk significant financial penalties. This document provides an overview of the key requirements, timelines, and considerations for businesses to ensure a smooth transition.

Key Themes and Details:

e-Compliance Initiative: Greece is digitizing financial transactions and tax reporting through mandatory e-Compliance managed by the AADE via the myDATA platform. This covers creation, transmission and storage of electronic documents using standardised XML formats.
- Quote: “Electronic compliance in Greece includes the creation, transmission, and storage of electronic documents based on standardized XML formats. This transformation is aimed at optimizing tax collection and simplifying B2B and B2G transactions.”
Timeline: A phased approach with key deadlines:
- July 2021: Mandatory e-Bookkeeping (already implemented).
- July 1, 2025 (??): Mandatory B2B e-Invoicing.
- June 2, 2025: Start of mandatory digital issuance and submission of transport documents for high-revenue companies and specific sectors.
- August 1 – November 30, 2025: Voluntary phase for real-time digital tracking of goods in transit.
- December 1, 2025: Mandatory digital issuance and reporting of transport documents for all remaining businesses and mandatory real-time tracking of goods in transit for all myDATA-covered taxpayers.
Clearance Continuous Transaction Control (CTC) Model: Greece uses a CTC model where all invoices are validated through the myDATA platform prior to being sent to the recipient.
- Quote: “Greece employs a Clearance Continuous Transaction Control (CTC) model, where all documents must be validated through myDATA before reaching the recipient.”
Transmission Methods: Documents must be submitted through myDATA in XML format. Methods include:
- ERP/Accounting Software (automated real-time integration)
- Certified E-Invoicing Providers (ΥΠΑΗΕ Providers) and Peppol & KED Interoperability (automated for B2B and B2G)
- myDATA Online Portal (manual entry, for small businesses under €50,000 turnover)
Invoice Submission Process:
- B2B: XML invoice sent to myDATA for validation and assignment of a MARK code, then returned to the issuer to be forwarded to the recipient.
- B2G: Invoices follow Peppol standards, reported to myDATA for validation, then submitted via the Peppol network through the KED (Greek State’s AP).
Document Types:
- B2B (myDATA): E-Invoices, Credit/Debit Notes, Payroll documents, E-delivery transport documents.
- B2G (myDATA + Peppol): E-Invoices (Peppol BIS Billing CIUS 3.0 format), Credit Notes.
Document Structure: E-documents require mandatory data fields.
- E-Invoice: Issuer and recipient details, VAT breakdown, Payment terms, MARK code, Supply Details.
- E-Delivery:
- Phase A: Place of Loading, Place of Delivery, Unit of Measurement, Purpose of Transportation
- Phase B: Number of Means of Transport, Time of start of actual movement, Date and time of transshipment, Other Associated VAT Numbers (Sender, Third Party Sender, Carrier, Recipient, Third Party Recipient), Date and time of completion of the movement, Number of Packages
Digital Certificates: Digital signatures are not mandatory, but myDATA validation and the Peppol network ensure authenticity.
Storage and Archiving: Businesses are responsible for secure, audit-ready document retention for 5 years, as myDATA does not store full records.
- Quote: “As myDATA does not store full records, businesses are responsible for secure, audit-ready document retention.”
Penalties for Non-Compliance: Substantial fines for unreported documents.
- E-Delivery: €100 per unreported document (max €500 daily, €20,000 annually).
- E-Bookkeeping: €250 (simple accounting), €500 (double-entry) per violation.
- E-Invoicing: 10% fine of net invoice value per unreported invoice (max €250/ day). Late transmission: 50% of initial fine. Repeat offences: doubled/quadrupled penalties.
XML Standards:
- B2B e-Invoices: myDATA XML Schema.
- B2G e-Invoices: Peppol BIS Billing CIUS 3.
- E-Delivery & E-Bookkeeping: XML format aligned with myDATA API specifications.
E-Transport Phased Rollout: The e-Transport system is split into two phases, both beginning with voluntary adoption before becoming fully mandatory in December 2025.

Key Considerations for Businesses:

Compliance Deadlines: Prioritise adherence to the July 1, 2025, and December 1, 2025, deadlines for e-Invoicing and e-Transport respectively.
XML Standards: Ensure ERP systems and software providers are compliant with myDATA XML and Peppol BIS Billing CIUS 3.0 standards.
Automation: Implement automated submission via ERP integrations or certified providers to ensure real-time compliance. Manual submission presents a higher risk of error and inefficiency.
MARK Code: Accurately generate, integrate, and track the MARK code on all documents.
Data Accuracy: Ensuring accuracy in uploading e-Delivery documents, especially as mandatory fields differ between Phase A and Phase B.
Peppol Compatibility: Businesses engaging in B2G transactions must ensure compatibility with Peppol standards.
Data Storage: Establish secure systems for archiving e-documents for a minimum of 5 years.

Actionable Items:

Conduct a thorough assessment of current accounting and invoicing systems to identify gaps in compliance.
Engage with certified e-invoicing providers or update ERP systems to support myDATA XML and Peppol BIS Billing CIUS 3.0 standards.
Develop internal processes and training programs to ensure accurate data entry and compliance with e-compliance requirements.
Establish robust archiving procedures for the secure retention of e-documents.
Stay informed of the latest updates and guidance from the AADE regarding e-compliance mandates, potentially via VATupdate.com or similar resources.

Disclaimer: This briefing document provides a summary of available information and should not be considered legal or tax advice. Businesses should consult with qualified professionals to ensure full compliance with Greek e-compliance regulations.

Source RTCsuite – Master Greece’s myDATA Mandate: Comprehensive Guide to E-Invoicing and E-Transport Compliance – VATupdate

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