Briefing Document & Podcast – Greece E‑Invoicing, E‑Reporting, and E‑Transport: Scope, Timeline & Requirements

Last Update: October 25, 2025

Summary

I. Executive Summary

Greece is overhauling its tax system through mandatory digitization. Key components include:

• E-Invoicing: Mandatory for B2G (Business-to-Government) and soon B2B (Business-to-Business) transactions.
• MyDATA E-Reporting: All businesses must report accounting data electronically to the tax authorities. “Every business subject to Greek accounting standards must transmit its accounting data… to the Independent Authority for Public Revenue (AADE).”
• E-Transport: Mandatory electronic delivery notes for all goods shipments. “Any shipment of goods within Greece, or entering/leaving Greece, must be accompanied by an electronic delivery document registered in the AADE myDATA system.”
• Pre-filled VAT returns: Since 2024, the VAT return form is automatically populated by the tax authority (AADE) using the data that the business has reported to the myDATA platform.
• Strict enforcement: Significant penalties for non-compliance. “Non-compliance is met with both monetary fines and structural consequences.”

II. Core Components & Requirements

A. E-Invoicing

• Scope: B2G is mandatory, B2B becoming mandatory in 2026. No current mandate for B2C.
  • B2G: All invoices issued to the public sector must be electronic and comply with the European standard EN 16931 using the Peppol network. “Public entities are required to accept and process e‑Invoices that comply with the European standard EN 16931, and suppliers must issue such invoices for their government sales.”
  • B2B: Mandatory for domestic transactions starting in 2026, phased in by company size. Includes exports to non-EU customers but cross-border B2B within the EU remains optional.
• Timeline: B2B mandate begins February 2, 2026, for large companies (revenue > €1 million), and October 1, 2026, for all other businesses.
• Technical Format: Structured electronic format adhering to the European e-Invoicing Standard EN 16931. “Greece has adopted the European e-Invoicing Standard EN 16931, meaning the data model of Greek e-invoices aligns with the EU core invoice standard.” Businesses can use AADE-certified providers or the tax authority’s free online portals.
• Data Requirements: All legally required invoice fields, including supplier and customer details, VAT IDs, invoice date and number, description of goods/services, quantity, taxable amounts, VAT amounts. Once issued, the invoice is immediately transmitted to the myDATA platform and a unique invoice identification code (MARK/UID) is assigned.”From January 2024, any invoice shared as a PDF must include a QR code linking to its myDATA record.”
• Penalties: After the mandate, paper invoices will be considered improper tax documents. “If a sales invoice is not reported in myDATA, the purchaser cannot deduct the VAT on that invoice.”
  • Missing e‑transport document: fines in the hundreds or thousands of euros (with proposals to increase to five figures).
  • Not reporting invoices: loss of VAT deductions for the counterparty and potential tax audit flags.

B. MyDATA E-Reporting

• Scope: Applies to all Greek businesses for all transactions affecting VAT and accounting (B2B, B2G, B2C). “Every business subject to Greek accounting standards must transmit its accounting data (invoice records of sales and purchases, credit/debit notes, expense records, etc.) to the Independent Authority for Public Revenue (AADE).”
• Timeline: Mandatory since July 2021, with full implementation from 2024.
• Technical Format: Data transmitted via APIs in JSON over REST API.
• Data Requirements: Issuer and recipient tax IDs, invoice number, date, product/service category, net amount, VAT amount, VAT rate, and other bookkeeping classifications. “Essentially, all the key invoice fields and accounting classification info are sent electronically.”
• Deadlines: Invoice data should ideally be reported in real-time or daily, but no later than the VAT return due date. “The figures on the VAT return (sales, purchases, VAT due/credit) are derived from the accumulated myDATA submissions.”
• Penalties: Taxpayers are not allowed to manually alter the prefilled VAT figures by more than a small margin. Persistent failure to transmit data can result in fines.

C. E-Transport/E-Delivery

• Scope: All movements of goods involving a Greek business, both domestic and cross-border. “Any shipment of goods within Greece, or entering/leaving Greece, must be accompanied by an electronic delivery document registered in the AADE myDATA system.”
• Timeline: Phased implementation, beginning in April 2025 for larger businesses and certain high-risk industries, and extending to all businesses by October 2025. Public sector entities must comply from January 1, 2026.
• Technical Format: Standardized XML schema/format for data transmission.
• Data Requirements:
  • Phase 1: Issuer’s and recipient’s information, unique document number and the myDATA MARK, a QR code, the date/time of issuance, the planned dispatch date/time, the location of loading and delivery, and a description of the goods with their quantity or weight.
  • Phase 2: Additional data on transport milestones (departure, arrival, transshipment), commodity codes, and VAT numbers of parties involved in the transport.
• Deadlines: The electronic delivery note must be generated before or at the time the goods commence transport. “The shipper is expected to register the shipment in the myDATA portal prior to dispatch to obtain the QR code and MARK. Once generated, the goods can move.”
• Responsibilities: Business dispatching the goods is responsible for issuing the e-delivery note. Carriers and logistics companies must ensure an e-Transport document exists for each load. The Greek recipient must ensure the delivery is reported in myDATA upon arrival for imports where a foreign supplier isn’t in myDATA.
• Penalties: Failing to issue or properly transmit an e-delivery note triggers financial penalties. Current fines are €500 for taxpayers using single-entry bookkeeping and €1,000 for those with double-entry books. Draft legislation proposes to increase these fines tenfold. “Law 5104/2024 established fines for non-compliance with the e‑transport requirements.”

III. Integration & Technology

• MyDATA Platform: Uses a REST API for all transmissions.
• E-Invoicing Providers: Licensed e-invoicing providers offer end-to-end solutions.
• Digital Signatures: E-Delivery notes must be digitally signed.
• QR Codes: Used for verification and real-time tracking.

IV. Pre-Filled VAT Returns

• Since January 1, 2024, VAT returns are pre-filled based on myDATA submissions.
• Taxpayers must review and confirm the figures.
• The data reported to myDATA and the data on the VAT return must match exactly in most cases.
• “The data reported to myDATA and the data on the VAT return must now match exactly in most cases.”

V. Logistics & Customs Integration

• Logistics providers must collect necessary tax data for shipments.
• Both customs declarations and e-delivery notes are required for goods crossing Greece’s borders.
• Real-time tracking is enabled through QR codes and required scanning.

VI. Key Takeaways

• Greece is undergoing a significant digital transformation of its tax system.
• E-invoicing, e-reporting, and e-transport are becoming mandatory for most businesses.
• Non-compliance carries significant penalties.
• Businesses must adapt their processes and systems to meet the new requirements.
• The goal is near-total compliance in real-time.

Detailed version

E‑Invoicing, E‑Reporting, and E‑Transport in Greece: Scope, Timeline & Requirements

Overview

Implementation Timeline

Scope of Transactions and Taxable Persons in Scope

• B2G: All invoices issued to the public sector (for public procurement contracts) must be electronic. This became mandatory in stages from 2023 to 2025, initially for larger contracting authorities and now for all government bodies (for contracts over €2,500). Public entities are required to accept and process e‑Invoices that comply with the European standard EN 16931, and suppliers must issue such invoices for their government sales. (The Greek public e‑Invoicing system uses the Peppol network via a National Interoperability Centre called KED.) [ec.europa.eu], [ec.europa.eu] [edicomgroup.com], [ec.europa.eu] [edicomgroup.com]
• B2B: Electronic invoicing for business-to-business transactions within Greece will become mandatory in 2026. The obligation applies to all sales of goods and services between taxable persons established in Greece (entities under Greek GAAP). It will roll out in two phases: first for large companies (revenue > €1 million) starting Feb 2, 2026, then for all other businesses from Oct 1, 2026. Notably, this mandate includes sales to non-EU customers (exports) in a B2B context. However, cross-border B2B within the EU remains optional – if the foreign EU counterparty does not agree to receive an e‑Invoice, the seller can use other methods. [ey.com] [edicomgroup.com], [ey.com] [edicomgroup.com], [kpmg.com]
• B2C: There is no general mandate for B2C (business-to-consumer) e‑invoicing in Greece at this time. Businesses may issue electronic receipts/invoices to consumers on a voluntary basis, but paper receipts are still allowed for retail transactions. (The new B2B rules explicitly exclude retail transactions to non-EU customers as well.) [ec.europa.eu], [ec.europa.eu] [ey.com]

• Sellers are responsible for reporting the details of each sale (output invoices), and
• Buyers must report their purchase invoices/expenses (especially if the supplier is not reporting them through an e-invoice).

• Any shipment of goods within Greece, or entering/leaving Greece, must be accompanied by an electronic delivery document registered in the AADE myDATA system. This includes domestic freight, intra-EU shipments, and imports/exports. [dhl.com]
• The obligation falls on the business dispatching the goods. If goods leave from the seller’s own facilities, the seller (consignor) issues the e‑delivery note; if shipped from a third-party logistics (3PL) warehouse, the 3PL provider must issue and report it on the owner’s behalf. For imports where a foreign supplier isn’t in myDATA, the Greek recipient must ensure the delivery is reported in myDATA upon arrival. [marosavat.com]
• Carriers and logistics companies are also implicated: Every transporter (including couriers and freight companies) must ensure an e‑Transport document exists for each load. For example, courier and last-mile delivery services must generate an e‑Transport record as soon as they load packages for delivery. Fuel distributors must create e‑delivery notes for each tanker shipment from depot to gas station. Even goods moving under customs procedures (imports/exports) still require an e‑Delivery note in addition to customs documentation. [rtcsuite.com] [rtcsuite.com], [rtcsuite.com]
• All types of businesses are included. Phase 1 (April 2025) initially covers those with annual revenue > €200k and certain high-risk industries (energy, pharmaceuticals, building materials, olive oil, etc.). Phase 2 (Oct 2025) extends the mandate to all other businesses, including SMEs. By 2026, even public sector entities that dispatch goods will have to comply (public bodies are explicitly brought in from Jan 1, 2026). [marosavat.com], [snitechnology.net] [marosavat.com] [snitechnology.net]
• There are limited exemptions for non-commercial or special transfers. According to the rules, movements that do not involve inventory or sales are exempt – e.g. moving a company’s own fixed assets (office furniture) or tools, transporting waste, or small farmers transporting their produce in certain cases are not required to issue e-delivery notes. But most commercial shipments are covered, so businesses need to assume an e‑transport document is required for virtually every sale or stock transfer involving physical goods. [rtcsuite.com], [snitechnology.net]

Data Requirements and Technical Format

• an AADE-certified e-invoicing service provider who will format and transmit the invoice data on their behalf, or
• the tax authority’s free online portals (the “Timologio” web application or the “myDATA” mobile app) to generate compliant e‑Invoices. [kpmg.com], [ey.com]

• In Phase 1 (2025), the e‑delivery document must contain all essential shipment details: the issuer’s and recipient’s information (names, VAT/Tax IDs), the unique document number and the myDATA MARK (unique code) for that delivery, a QR code, the date/time of issuance, the planned dispatch date/time, the location of loading (origin) and the location of delivery (destination), and a description of the goods with their quantity or weight. This essentially mirrors a paper delivery note but with a digital identifier and QR for tracking. [snitechnology.net]
• In Phase 2 (late 2025), additional data must be reported: exact transport milestones (departure, any reloading or transshipment events, arrival time) and confirmation of receipt, details on any transfers between vehicles or intermediate stops, and the “nomenclature of goods” (commodity codes) as per the EU Combined Nomenclature / Intrastat codes. Also, the VAT numbers of any parties involved in the transport (e.g. if goods are delivered to a different location/warehouse than the buyer, that location’s VAT ID must be provided). [kpmg.com], [snitechnology.net] [dhl.com]

Timing for Data Transmission (Deadlines)

• Sales invoices ideally should be reported in real-time or daily, especially if using e-invoicing or a connected ERP, it happens automatically. If not automatically, they must be input by the return due date.
• Purchase invoices should also be confirmed/reported by the return due date to claim the VAT credit.

• The shipper is expected to register the shipment in the myDATA portal prior to dispatch to obtain the QR code and MARK. Once generated, the goods can move. Greek rules stipulate that after an e‑Delivery document is submitted, the actual dispatch of goods must occur within 5 days. This prevents companies from pre-registering shipments too far in advance; if more than 5 days pass, presumably a new submission is needed. [dhl.com] [marosavat.com]
• During transport, that QR code on the documents can be scanned by authorities roadside or at ports.
• In Phase 2 (after Oct 2025), the recipient of the goods is required to scan/confirm receipt by scanning the QR code upon delivery and logging the receipt in the system. Also, if goods are transferred to another truck or there’s partial delivery, those events must be updated. This implies near real-time updates at key steps (loading, any transfer, unloading). [kpmg.com]
• If there’s a system outage or the myDATA portal is unreachable at the time of dispatch, the law provides that the business can issue a manual (paper) delivery note so as not to stop the truck, but they must upload the details to myDATA by the next working day. This ensures even if real-time submission failed, the data is not lost and is reported with minimal delay. [rtcsuite.com]

Compliance and Penalties for Non‑Compliance

• E‑Transport (Electronic Delivery Notes) Penalties: Failing to issue or properly transmit an e‑delivery note for a goods shipment currently triggers financial penalties under Greek law. Law 5104/2024 established fines for non-compliance with the e‑transport requirements: €500 for taxpayers using single-entry bookkeeping (generally smaller businesses) and €1,000 for those with double-entry books (larger businesses). These fines apply per infringement (e.g. per missing or unreported shipment document). Repeat violations can incur higher fines under existing tax penalty provisions (Article 67 of the Tax Procedures Code). Moreover, a draft new customs code (pending as of mid-2025) proposes to increase these fines tenfold – raising them to €5,000 and €10,000 respectively – reflecting a much harsher stance on e-transport failures in the near future. In short, businesses that dispatch goods without registering an e‑delivery note (or that are caught with un-scanned QR codes) face steep fines, which are poised to become even heavier. [rtcsuite.com], [sovos.com] [rtcsuite.com]
• E‑Invoicing Compliance and Penalties: For B2B e‑invoicing, since it’s not mandatory until 2026, direct penalties are not yet in force for not using e‑invoices. However, once mandatory, issuing paper invoices when e-invoicing is required will likely be treated as issuing improper tax documents, subject to penalties. Greece’s tax code generally penalizes failures in invoice issuance (which can range from a few hundred euros per invoice or a percentage of the invoice value, depending on severity). Additionally, the incentive structure for early adopters of e-invoicing (100% extra deduction of costs, etc.) implies that after the grace period, those not complying simply won’t be able to legally issue invoices. Importantly, Greece has implemented a measure to indirectly enforce invoice reporting: if a sales invoice is not reported in myDATA, the purchaser cannot deduct the VAT on that invoice. This means starting in 2024, any invoice that isn’t lodged in the tax authority’s system is essentially non-deductible and non-recognizable for tax purposes, which is a powerful deterrent. A buyer will pressure the supplier for a proper e-invoice because otherwise the VAT on that purchase is lost. This aligns with the rule introduced by Circular A.1020/2024 that VAT return sales figures cannot be less than what was transmitted, and purchase claims cannot exceed what’s in myDATA. Thus, even without a specific “fine” for not doing e-invoicing, the consequence is losing tax credit and facing likely audits. For B2G, if a supplier fails to issue an electronic invoice for a public contract when required, practically the government might refuse to pay until a compliant invoice is received (and such a failure could also lead to penalties or disqualification from tenders). [kpmg.com] [sovos.com]
• General Reporting Non-Compliance: Beyond specific e-invoice or e-delivery document fines, Greece’s broader tax compliance framework has penalties for not adhering to bookkeeping and reporting requirements. Under myDATA, if a business persistently fails to transmit data, the tax authority can impose fines for inaccurate record-keeping. Also, as noted, the VAT return is now bindingly tied to myDATA – taxpayers are not allowed to manually alter the prefilled VAT figures by more than a small margin. In effect, not reporting a transaction = not including it on your VAT return (or vice versa), which is a serious compliance issue. The system is designed to catch discrepancies automatically. [sovos.com]

• Missing e‑transport document: fines in the hundreds or thousands of euros (with proposals to increase to five figures). [sovos.com]
• Not reporting invoices: loss of VAT deductions for the counterparty and potential tax audit flags. [sovos.com]
• Failing to use mandated e‑invoicing channels (after deadlines): likely treated as a tax violation with penalties and no recognition of those invoices for tax purposes.
• Additionally, companies that do not follow the new rules could forfeit the tax incentives provided for early or on-time adoption (e.g. the extra depreciation and deductions were only granted if one exclusively uses e-invoicing and doesn’t revert to paper). [ey.com], [ey.com]

Pre-Filled VAT Returns in Greece

Integration with Logistics and Customs (E‑Transport Details)

• Logistics Provider Integration: As described, third-party logistics (3PL) companies and carriers have responsibilities in the e‑Delivery framework. If a 3PL manages stock and ships goods on behalf of a client, that 3PL must issue the e‑delivery note through myDATA. This requires logistics providers to collect necessary tax data (like the shipper and recipient VAT numbers) before dispatch. Major carriers (e.g., DHL, FedEx) are adapting their procedures. For instance, DHL has informed customers that for all freight shipments to, from, or within Greece, they must provide the recipient’s VAT number (and any unloading party’s VAT) so that an e‑delivery note with a QR code can be created prior to shipping. The QR code then accompanies the shipment documents. This shows how deeply the requirement penetrates the supply chain: even B2C shipments (where a consumer might not have a VAT number) now need a tax ID (for individuals, some form of tax identification like a national ID may be used) for the e‑delivery registration. All transport operators are affected, and they must ensure their IT systems (e.g., EDI data to/from clients) include the necessary fields to comply. [marosavat.com] [dhl.com]
• Customs Coordination: Goods moving across Greece’s border will involve both a customs declaration and an e‑delivery note. The e‑delivery note is primarily a tax control for movement, complementing (but not replacing) customs documents. For imports, once goods clear customs, the Greek importer must have the e‑delivery note to transport the goods within Greece (the import entry might generate data that feeds into it, but essentially the importer ensures that the receipt of goods is logged in myDATA). For exports, the exporter’s dispatch of goods will generate an e‑delivery note which can be checked against the customs export declaration. The regulations explicitly mention “customs shipments” are in scope for e‑Transport, ensuring no loophole whereby goods leaving the country escape the domestic reporting. This integrated approach improves oversight: the tax authority can cross-verify that any truck leaving Greece with goods has both a customs export entry and a myDATA e‑delivery record, and similarly for entering goods. [rtcsuite.com]
• Real-Time Tracking: The use of QR codes and required scanning means that the system provides near real-time visibility of goods in transit to the tax authority. If a truck is stopped by enforcement on the road, officers can scan the QR code on the delivery note and instantly see the declared contents, shipper, route, etc.. This makes it easier to catch undeclared cargo or detect discrepancies. The recipient scanning upon arrival (phase 2) adds a confirmation layer — the authorities will know the goods actually reached their destination and see if there were any changes (like short delivery or damage noted). [rtcsuite.com], [dhl.com]
• Supply Chain Benefits: Although primarily for tax control, this integration has side benefits. It can enhance supply chain transparency for businesses too. Greece anticipates that these digital records can improve efficiency (for example, faster VAT refunds since the tax authority already has all transaction data and can trust it). Companies that adapt early can also leverage the data for better inventory tracking and fraud prevention in their own operations. [rtcsuite.com]

• See also
  • E-Invoicing/Real Time Reporting – What can you find on VATupdate.com
  • Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
  • Collection of E-Invoicing Guides – Worldwide – VATupdate
  • Briefing / Comprehensive Guides (incl. podcasts)

• Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE