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Greece’s E-Transport and E-Delivery Regulations

2 months ago
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12 min read

Greece’s E-Transport and E-Delivery Regulations: Digital Monitoring of Goods Movement Under the myDATA Platform

Summary

  • Greece has implemented a comprehensive e-Transport and e-Delivery framework within its myDATA ecosystem, requiring businesses to digitally issue, transmit, and monitor transport documents in real-time to combat VAT fraud, eliminate fictitious invoices, and provide the tax authority (AADE) with real-time oversight of the physical supply chain.
  • The e-Transport system is being rolled out in phases: Phase A, mandatory since December 2025, requires digital issuance and transmission of dispatch notes; Phase B, with a revised timeline, will introduce digital monitoring of loading, reloading, receipt, and discrepancy reporting from October 2026, and mandatory TARIC-aligned commodity coding from January 2027.
  • This e-Transport system operates in conjunction with Greece’s mandatory B2B e-invoicing regime, creating a robust digital tax control architecture that cross-references financial and physical data, with significant penalties for non-compliance, emphasizing the need for businesses to align contracts, documentation, and invoicing with these new digital requirements.

1. Introduction and Policy Objective

Greece is implementing one of the most granular goods-movement tracking systems in the European Union. Through its E-Transport and E-Delivery framework — operating within the broader myDATA (my Digital Accounting and Tax Application) ecosystem managed by the Independent Authority for Public Revenue (AADE) — the Greek tax authority now requires businesses to digitally issue, transmit, and monitor transport documents for the physical movement of goods in real time.

The policy objectives are threefold. First, to combat VAT fraud by creating a verifiable digital trail for every movement of goods between businesses. Second, to eliminate fictitious invoices — a long-standing problem in Mediterranean tax administrations — by cross-referencing invoice data with actual goods movement data. Third, to provide AADE with real-time tax oversight over the physical supply chain, enabling proactive rather than reactive audit activity.

The e-Transport system does not operate in isolation. It runs in parallel with Greece’s mandatory B2B e-invoicing regime (also routed through myDATA), its existing e-Books real-time transaction reporting obligation (in place since 2021), and its B2G e-invoicing framework via Peppol. Together, these systems give AADE a comprehensive, real-time view of both the financial and physical dimensions of B2B transactions across the Greek economy.

2. Legal Basis

The e-Transport / e-Delivery framework finds its statutory basis in Article 5, paragraph 9B of Law 4308/2014 (Greek Accounting Standards — ‘Greek GAAP’). This provision empowers the Ministry of National Economy and Finance and AADE to define the scope, timeline, and technical requirements for the digital issuance of goods movement documents.

The implementing legislation comprises the following key instruments:

3. Scope — Who Is Obligated?

The e-Transport obligation applies to all entities falling under Article 1 of Law 4308/2014 that move inventory. Whether a business is the sender, a third-party sender (commissionaire or storekeeper), a carrier, or a recipient, the obligation to issue or receive digital transport documents applies. Drop-shipping arrangements and outsourced fleet operations are explicitly included.

3.1 First Group

  • Businesses with gross revenues exceeding €200,000, plus businesses operating in designated high-risk sectors (energy products/fuels, pharmaceuticals, construction materials, olive fruit/olive oil production and marketing), regardless of their revenue.

3.2 Second Group

  • All remaining businesses not captured by the first group criteria. These entities were integrated into the Phase A obligation from 1 December 2025.

3.3 Third-Party Logistics (3PL) Providers

Where a 3PL provider manages inventory and issues delivery documents on behalf of the inventory owner, the 3PL provider assumes the full reporting obligation.

For more detail on scope and roles, see: RTC Suite — Greece e-Transport Rules 2025: Penalties, Exemptions, Action Plan and PIKON — Greece launches e-Delivery for Goods and Material Movement

4. Phase A — Dispatch Layer (In Force Since December 2025)

Phase A establishes the baseline compliance layer. It has been mandatory for all obligated entities since 1 December 2025. Every movement of goods between businesses must be documented in a structured digital format and reported to AADE in real time.

Phase A requires businesses to:

  • Digitally issue transport documents (e-delivery/dispatch notes) and transmit the corresponding data to myDATA before or at the start of goods movement.
  • Receive a unique MARK (Monadikos Arithmos Katahorisis) and QR code from AADE at the time of transmission.
  • Notify the recipient automatically via the myDATA platform.
  • Ensure actual delivery is completed within 5 days of document issuance.
  • In the event of system failure, manual transport documents remain permissible — but data must be uploaded to myDATA by the next working day.

See: Comarch — Greece Extends Implementation Timeline for Phase B of E-Transport

5. Phase B — Movement and Receipt Layer (Revised Timeline)

Phase B significantly expands the scope from document issuance to event-based monitoring. Where Phase A captures the start of a goods movement, Phase B captures what happens during and after: loading, transshipment, delivery, and quantitative/qualitative control at the point of receipt.

5.1 Phase B1 — From 12 October 2026

  • Digital monitoring of loading and reloading during transport.
  • Digital receipt and acceptance of e-delivery documents by the recipient.
  • Quantitative and qualitative control at point of receipt — discrepancies reported to myDATA within 15 days.
  • QR code scanning for transshipment, loading, and receipt events.

5.2 Phase B2 — From 1 January 2027

  • TARIC-aligned Combined Nomenclature (Unified Commodity Coding) becomes mandatory for item-level classification.

5.3 Postponement History

  • Original deadline: 1 December 2025 (Decision A.1122/2024).
  • First postponement (Nov 2025): Decision A.1145/2025 → moved to 1 May 2026.
  • Second postponement (Apr 2026): Decision A.1094/2026 → split into B1 (Oct 2026) and B2 (Jan 2027).

See: RTC Suite — Greece Redesigns e-Delivery Phase B: Phased Rollout from October 2026 | SNI Technology — Greece Postpones Phase B of e-Delivery Notes under myDATA | Regfollower — Greece postpones implementation of e-transport Phase B

6. Exemptions and Sector-Specific Provisions

The following categories are exempt from the issuance of digital transport documents (broadened by Decision A.1145/2025, effective from 1 December 2025):

  • Spare parts for repair/maintenance of network systems (water supply, sewage, electricity, motorways).
  • Industrial minerals by mining entities; ceramic bricks and tiles.
  • Newspapers and magazines to/from newsagents and points of sale.
  • Free educational books to schools by ITYE ‘Diophantus’.
  • Retail transactions via postal/courier providers — if retail receipt is visibly placed on the package.
  • Non-commercial movements: fixed assets, waste disposal, non-inventory movements (Circular E.2030/2025).

See: EY Greece — myDATA e-Transportation: New Timeline and Exemptions (Nov 2025) | SNI Technology — Greece Delays Digital Delivery Note Phase B to May 2026

7. Operational and Technical Requirements

Compliance requires integration with the myDATA platform via one of the following methods:

  • Direct ERP integration via myDATA REST API (v2.0.1).
  • Certified EDIPs (Electronic Data Issuance Providers) — issue and transmit on behalf of the entity.
  • Free AADE tools: timologio web application (v2.0.0 for Phase B) and myDATAapp mobile.

See: AADE — myDATA Technical Specifications v2.0.1 (official) | AADE — myDATA Platform

8. Interaction with B2B E-Invoicing

The e-Transport system runs in parallel with Greece’s separate mandatory B2B e-invoicing regime. The two systems are distinct but interconnected: e-invoicing governs the commercial document (the invoice), while e-Transport governs the physical movement document (the transport/delivery note). Together, they allow AADE to cross-reference financial and physical data to detect inconsistencies.

B2B e-invoicing timeline:

  • 2 March 2026: Mandatory for businesses with >€1M turnover (transition period to 3 May 2026).
  • 1 October 2026: Mandatory for all remaining businesses (transition period to 31 December 2026).

See: EY Greece — Mandatory e-Invoicing (Decisions A.1128/2025 and A.1129/2025) | EDICOM — Greece: B2B and B2G Electronic Invoicing via myDATA | Marosa VAT — Greece Introduces B2B E-Invoicing Mandate | Deloitte — Mandatory B2B e-Invoicing in Greece

9. Penalties for Non-Compliance

Under the Tax Procedure Code (Law 4174/2013), Article 54, procedural violations carry the following fines:

  • €100 for taxpayers not required to maintain accounting books.
  • €1,000 for entities with simplified accounting (single-entry).
  • €2,500 for entities with full accounting records (double-entry).
  • Repeat offences within 5 years: fine doubles for first repeat, quadruples for second (Art. 54, par. 3).

Under Law 5222/2025 (amending Article 57, par. 13 of Law 5104/2024), penalties for transporting goods without digital transport documents were increased tenfold: €5,000 for single-entry entities and €10,000 for double-entry entities per tax audit.

See: AADE — Law 4174/2013, Article 54 (official text) | EY Greece — Developments in the Digital Tax Environment (Law 5222/2025) | AADE — Law 5104/2024 (new Tax Procedure Code)

10. Practical Implications and Outlook

Greece’s e-Transport system, taken together with its B2B e-invoicing mandate and existing myDATA e-reporting framework, represents one of the most ambitious digital tax control architectures in the EU. The system goes beyond invoice-level reporting to track the physical movement of goods in real time — a level of granularity that few EU Member States have yet attempted.

Businesses that have not yet integrated e-transport functionality into their ERP should treat the October 2026 Phase B deadline as a firm target. Key areas to address: real-time transmission capability, receipt-side processes, QR-based event capture, and TARIC commodity code mapping ahead of January 2027.

Greece’s approach aligns with the broader EU-wide trend toward real-time digital tax reporting. The ViDA (VAT in the Digital Age) package envisages EU-wide Digital Reporting Requirements for cross-border B2B transactions from July 2030 and potential domestic alignment by January 2035.

See: Fiscal Solutions — Greece Advances e-Invoicing and Delays Part of e-Transport Reporting | Thomson Reuters — Greece Regulatory Updates | VATupdate — Greece Advances B2B E-Invoicing and E-Transportation Reporting Reforms

Key Takeaways

  • Phase A is live: Since 1 December 2025, all obligated entities must digitally issue and transmit transport documents to myDATA before goods movement.
  • Phase B has been restructured into two stages: loading/receipt/control data from 12 October 2026; TARIC commodity coding from 1 January 2027 (Decision A.1094/2026).
  • The e-Transport system operates alongside Greece’s B2B e-invoicing mandate (March 2026 for large companies; October 2026 for all), enabling AADE to cross-reference invoice and goods movement data.
  • Penalties range from €100 to €10,000 per violation under current law. Non-compliance may also result in expense rejection and suspected tax evasion classification.
  • 3PL providers assume the e-transport reporting obligation when they manage inventory and issue delivery documents on behalf of the inventory owner.
  • Voluntary submission of Phase B data is available now — businesses should use this window for system testing before the October 2026 enforcement date.
  • Greece’s dual e-invoicing and e-transport framework positions it as one of the most advanced digital tax control jurisdictions in the EU, ahead of ViDA’s 2030/2035 timeline.

Sources and References

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