Page History

Legislation

The transposition of the Directive 2014/55/EU into Greek law was adopted in the first quarter of 2019 (Law 4601/2019). The transposition aligns with the text and scope of the Directive however it mandates the issuance of two Joint Ministerial Decisions (JMDs), i.e. secondary level legislation, in order to stipulate the details regarding the adoption of the semantic data model of eInvoices and the architecture of eInvoicing in Greece.

The Ministerial Decision No. 1017 / 14.02.2020 (National Gazette, Issue B, Sheet 457) was issued by the Ministry of Finance, which is specifying the eInvoice format for B2B transactions (fully compliant to the European standard on eInvoicing and the chosen Peppol CIUS for B2G).

Also, the Ministerial Decision No. A.1035 / 18.02.2020 (National Gazette, Issue B, and Sheet 551) was issued by the Ministry of Finance, which is stipulating rules and regulations regarding eInvoicing Service Providers.

For the alignment of the European semantic data model specifications of eInvoice with the procurement rules and financial procedures in Greece, two Joint Ministerial Decisions have been issued for further specifying and providing guidance on how to use it in public procurement (Government Gazette 2338 B' 02-06- 2021). In these Ministerial Decisions the four-corner model interoperability architecture of Peppol eDelivery network was adopted (Government Gazette B '2425 18-06-2020).

On September 23August 7, 2022, Greece published Law 4972Ministerial decision A. 1090/2022 (link in Greek), which includes a mandate on the use of the electronic invoice for all sales made to the government, regardless of the value involved in the transaction. The law further incorporates new sanctions for not transmitting the e-invoice information and other data via the myDATA system. In addition to the current penalties, the tax authorities are now allowed to suspend the operations of non-compliant taxpayers that can go from 48 to 96 hours, depending on the severity of the violation.

eInvoicing platform and eInvoicing management solutions

The eInvoicing implementation in Greece consists of the following solutions that have been developed and supported by the General Secretariat of Information Systems for Public Administration of the Ministry of Digital Governance in cooperation with the General Secretariat of Fiscal Policy of the Ministry of Finance, the Ministry of Development and Investments and the Hellenic Single Public Procurement Authority:

• An informative website for eInvoice in Public Procurement: This website includes all relevant information for: a) suppliers/contractors, b) eInvoicing services providers, c) contracting authorities, d) financial services responsible for clearing and paying invoices and d) audit services.
• Contracting Authorities Registry for eInvoicing: A new registry that contains all the required information regarding the competent contracting authorities and their financial services for handling eInvoices. This registry was based on the information provided by the Hellenic Single Public Procurement Authority of Greece and provided a unique identifier for each contracting authority. Currently, more than 2,300 contracting authorities have been registered. Moreover, the appropriate amendments have been made in the Greek public procurement Law i.e. 4412/2016 to ensure that public contracts contain the required information for eInvoicing.
• A Web application (EDHT) for distributing the eInvoice to the competent contracting authorities. This web application delivers eInvoices to contracting authorities and offers basic administration facilities to users. It provides the opportunity to the contracting authorities and Financial Service to visualise eInvoices and to inform suppliers/contractors on the handling status of eInvoices e.g., acceptance, rejection, payment etc.
• National Interoperability Centre: The Interoperability Centre is responsible for receiving all the eInvoices by the suppliers/contractor through the certified eInvoice Service Providers and the Peppol network, routing them to the competent contracting authority. The Interoperability Centre has developed several online and web services to check the eInvoices, regarding their compliance with the specifications of European and national standards, to receive and transmit the eInvoices to competent public authorities for further processing and payment. Important information that is checked includes: a) the existence of the contracting authority based on the unique identifier of the Contracting Authorities Registry, b) the existence of the public contract that the eInvoice refers to, c) the budget d) the commitment required for the payment of the eInvoice. These services are addressed to either the eInvoicing Service Providers or the Public Authorities’ IT systems.
• IT Systems responsible for the acceptance, clearance and payment of eInvoices: In this regard, two major horizontal systems have been adapted so that they can handle eInvoices i.e. the IT system for contracts funded by the Public Investment Fund and the IT system for the clearance and payment of the Central Government expenditures.

The format of the eInvoices exchanged between all parties is based on the EN standard.

The Interoperability Center of the General Secretary for Information Systems for Public Administration (GSIS PA) implemented and installed a Peppol Access Point (AP) for the reception of eInvoices of the Greek State and transmitting back responses.

After the initial semantic check of eInvoices by the AP, eInvoices are forwarded to the Interoperability Center. The Interoperability Center stores eInvoices and directs them to the respective Information Systems of the public bodies. eInvoices are made available with the use of web services.

In addition, the Interoperability Center manages the forwarding of replies by the public contracting authorities for the acceptance and payment or rejection of eInvoices, through SOAP web services. The General Accounting Office (GAO) back-office system, also operated by the General Secretariat for Information Systems of Public Administration will be able to handle standardised eInvoices for expense approval, processing and payment.

Moreover, the horizontal IT system responsible for the management of contracts funded by the Public Investment Fund is also capable of receiving eInvoices from the interoperability centre and process them until the respective payment or rejection. This system is managed by the Ministry of Development and investments in Greece.

Last but not least MyDATA is the platform in charge of receiving all the summary of eInvoices for B2B and B2G transactions. On this platform, the Greek authorities can process all the data and then create financial reports for each taxpayer in Greece.

Approach for receiving and processing eInvoices

The transfer method for myDATA is the myDATA Representational State Transfer Application Programming Interface (REST API). All entities that are obliged to apply the provisions of the Greek Accounting Standards, are obliged to transmit e-book data to Independent Authority of Public Revenues (A.A.D.E.), regardless of the type of the company (indicatively S.A., limited liability, private capital, limited or general partnership and others, as well as branches)[1].

The Peppol Access Point (AP) exclusively facilitating the issuers of the eInvoices enables the receiving of eInvoices from their ERP systems. Additionally, other systems, including the Peppol Access Point for the Public Administration Authorities are part of the National Interoperability Center of the General Secretariat for Information Systems of Public Administration at the Ministry of Digital Governance. Other Enterprise Resource Planning systems and standalone applications of the Public Authorities allow further processing of eInvoices, until their liquidation and payment.

The main eInvoice process flow scenario for public procurement includes the following steps:

1. Preparation of eInvoice data by the supplier/contractor and transmission to an eInvoicing service provider.
2. The eInvoicing service provider validates invoice data before submitting it, using the respective Interoperability Centre services.
3. The eInvoicing service provider reports and registers the eInvoice, for taxation reasons, to “MyData” application i.e. to a digital financial information application for taxation operated by the Independent Authority of Public Revenue in Greece.
4. The eInvoicing service provider prepares the eInvoice based on a) the European standard semantic model, b) the national specification that derives from the Joint Ministerial Decisions, and the Peppol Business Interoperability Specification.
5. The eInvoicing service provider submits the eInvoice to the access point of the Interoperability Centre through the Peppol network.
6. The Interoperability Centre receives and validates the eInvoice, according to the European and national rules for eInvoicing,
7. The Interoperability Centre routes the eInvoice to the competent contracting authority or competent IT system of the public body,
8. The competent contracting authority and financial service handle the invoice according to their internal procurement and payment practices using one of the IT systems or web application mentioned in the previous section. The competent authorities send the appropriate messages regarding the status of the processing of the eInvoice through the Interoperability Centre and the eInvoicing service providers to the supplier/contractor.

A working group (WG) has been established at the Ministry of Finance, with the mandate to steer and monitor all the necessary tasks for enabling the eInvoicing implementation. Members of the WG are senior/executive employees from the Ministry of Finance, the Ministry of Digital Governance, the Court of Auditors, the Information Society S.A. and the Athens University of Economics and Business (AUEB).

This WG has been established as a part of the major Fiscal Reform that the Ministry of Finance is pursuing, with the goal to switch gradually all General Government Entities to accrual accounting.

eInvoicing implementation in sub-central level contracting authorities 

These eInvoicing platforms and exchange services are now available for both central and sub-central administrations since 2020.

1. “MyData” application i.e. a digital financial information application for taxation managed by the Independent Authority of Public Revenue in Greece.
2. National Interoperability Center managed by the General Secretariat for Information Systems of Public Administration (GSIS PA) at the Ministry of Digital Governance, providing the following web services:
1. getInvoiceInfo (eInvoice reception from the systems of contracting public authority)
2. sendInvoiceResponse (transmission to the invoice issuer of the results from the processing of an eInvoice by the systems of public authority)
3. pdeCheckProject (validation checks of the project ePDE code)
4. sendInvoiceInfo (transmission of invoice data from the Governmental Peppol AP to National Interoperability Center)
3. Contracting Authorities Registry for eInvoicing managed by the General Secretariat for Information Systems of Public Administration (GSIS PA) at the Ministry of Digital Governance
4. A Web application for distributing the eInvoice to the competent Contracting Authorities managed by the General Secretariat for Information Systems of Public Administration (GSIS PA) at the Ministry of Digital Governance
5. IT Systems responsible for the accounting, acceptance, clearance and payment of eInvoices managed by the competent organisations.

Status on the implementation of the European Standard on eInvoicing (EN)

The Greek authorities have completed the development and testing of their own Peppol Access Point (AP) implying the usage of Peppol BIS Billing 3.0 which is based on the European standard on eInvoicing (EN 16931). The necessary fields and items of an eInvoice are outlined in the publication of the A. 1017/27-01-2020, which is the EN-compliant format used as well as in the relevant JMD regarding the semantic model.

Monitoring mechanism

Even though there is not an actual mandate for eInvoicing, eReporting is a mandatory obligation in Greece trough myDATA in accordance with the Νόμος ν. 4646/2019, this information encompass al the sales invoices in real time, as well as classification of revenues and expenses type and Enough accounting entries to determine end of year accounting and tax results.

The platform will analyse and validate the information published.

Digital reporting requirements

Greece has officially adopted a decision to introduce Digital Reporting Requirements. The available information estimates the policy development at the national level in the next years. Between 2022 and 2024, Greece started operating their own DRRs. Greece opted for Digital Reporting Requirements with the possibility of periodic reporting for smaller companies. This DRR will cover all transactions, over B2B, B2G and B2C segments, and both domestic and international transactions. All companies resident in Greece (or in any event subject to local accounting requirements) will have to comply with the system, with no threshold foreseen. The taxable person with a turnover of less than EUR 50 000 or issuing less than 50 invoices per year will be able to use a special data entry form, which allows them to manually upload invoice data on the myDATA web portal.

Moreover, in 2023 with the Decision 1170/2023 and the Ministry of Finance’s Law to combat tax evasion, several requirements have changed to demonstrate Greece’s will to move to a broader use of eInvoicing.

The two abovementioned legal acts established new guidelines regarding eInvoicing, additional guidance regarding the electronic data transmission and new provisions regarding fines in case of non-compliance. The law establishes that, in case of failure to send the summaries of invoiced revenue, a fine of 10% of the net value of each non-transmitted document applies.

In addition, Greece has extended the incentives to businesses, which decide to use eInvoicing through an accredited service provider.

Additional information

Greece participated in the Peppol Large Scale Pilot and tested the electronic procurement system for public administrations (e-Prior). e-Prior is an eProcurement system that facilitates standardised eProcurement document exchanges between a public administration and suppliers across Europe[2]. 

The project Interoperable eInvoicing in Greece (GRinv) funded by CEF program was a key initial implementation for e-Invoicing in Greece. This project aimed to implement an interoperable eInvoicing infrastructure in Greece via the Peppol ‘four corner model’ to process B2G eInvoices. 

Due to the recent Ministerial Decision on certified eInvoicing service providers and the enforced electronic way of doing business, more private companies are using these well-established service providers to exchange eInvoices. 

establishes the new timing for the electronic submission of accounting/invoicing information to the tax authority via the MyData digital platform, and the procedure to be followed by taxpayers in cases of contingency impeding the transmission of that data, or discrepancies between the data reported and the ledgers due at the end of each month. Effective January 1, 2023, invoicing information regarding wholesale transactions by taxpayers using commercial/accounting ERP systems should be submitted to the tax authority by the next day following the one in which the invoice or receipt was issued. 

On September 23, 2022, Greece published Law 4972/2022 (link in Greek), which includes a mandate on the use of the electronic invoice for all sales made to the government, regardless of the value involved in the transaction. The law further incorporates new sanctions for not transmitting the eInvoice information and other data via the myDATA system. In addition to the current penalties, the tax authorities are now allowed to suspend the operations of non-compliant taxpayers that can go from 48 to 96 hours, depending on the severity of the violation.

In 2023, with the Decision 1170/2023 and Law 5073/2023, several requirements have changed to demonstrate Greece’s will to move to a broader use of eInvoicing. The two  legal acts established new guidelines regarding eInvoicing, additional guidance regarding the electronic data transmission and new provisions regarding fines in case of non-compliance. The law establishes that, in case of failure to send the summaries of invoiced revenue, a fine of 10% of the net value of each non-transmitted document applies.

eInvoicing platform and eInvoicing management solutions

The eInvoicing implementation in Greece consists of the following solutions that have been developed and supported by the General Secretariat of Information Systems for Public Administration of the Ministry of Digital Governance in cooperation with the General Secretariat of Fiscal Policy of the Ministry of Finance, the Ministry of Development and Investments and the Hellenic Single Public Procurement Authority:

• An informative website for eInvoice in Public Procurement: This website includes all relevant information for: a) suppliers/contractors, b) eInvoicing services providers, c) contracting authorities, d) financial services responsible for clearing and paying invoices and d) audit services.
• Contracting Authorities Registry for eInvoicing: A new registry that contains all the required information regarding the competent contracting authorities and their financial services for handling eInvoices. This registry was based on the information provided by the Hellenic Single Public Procurement Authority of Greece and provided a unique identifier for each contracting authority. Currently, more than 2,300 contracting authorities have been registered. Moreover, the appropriate amendments have been made in the Greek public procurement Law i.e. 4412/2016 to ensure that public contracts contain the required information for eInvoicing.
• A Web application (EDHT) for distributing the eInvoice to the competent contracting authorities. This web application delivers eInvoices to contracting authorities and offers basic administration facilities to users. It provides the opportunity to the contracting authorities and Financial Service to visualise eInvoices and to inform suppliers/contractors on the handling status of eInvoices e.g., acceptance, rejection, payment etc.
• National Interoperability Centre: The Interoperability Centre is responsible for receiving all the eInvoices by the suppliers/contractor through the certified eInvoice Service Providers and the Peppol network, routing them to the competent contracting authority. The Interoperability Centre has developed several online and web services to check the eInvoices, regarding their compliance with the specifications of European and national standards, to receive and transmit the eInvoices to competent public authorities for further processing and payment. Important information that is checked includes: a) the existence of the contracting authority based on the unique identifier of the Contracting Authorities Registry, b) the existence of the public contract that the eInvoice refers to, c) the budget d) the commitment required for the payment of the eInvoice. These services are addressed to either the eInvoicing Service Providers or the Public Authorities’ IT systems.
• IT Systems responsible for the acceptance, clearance and payment of eInvoices: In this regard, two major horizontal systems have been adapted so that they can handle eInvoices i.e. the IT system for contracts funded by the Public Investment Fund and the IT system for the clearance and payment of the Central Government expenditures.

The format of the eInvoices exchanged between all parties is based on the EN standard.

The Interoperability Center of the General Secretary for Information Systems for Public Administration (GSIS PA) implemented and installed a Peppol Access Point (AP) for the reception of eInvoices of the Greek State and transmitting back responses.

After the initial semantic check of eInvoices by the AP, eInvoices are forwarded to the Interoperability Center. The Interoperability Center stores eInvoices and directs them to the respective Information Systems of the public bodies. eInvoices are made available with the use of web services.

In addition, the Interoperability Center manages the forwarding of replies by the public contracting authorities for the acceptance and payment or rejection of eInvoices, through SOAP web services. The General Accounting Office (GAO) back-office system, also operated by the General Secretariat for Information Systems of Public Administration will be able to handle standardised eInvoices for expense approval, processing and payment.

Moreover, the horizontal IT system responsible for the management of contracts funded by the Public Investment Fund is also capable of receiving eInvoices from the interoperability centre and process them until the respective payment or rejection. This system is managed by the Ministry of Development and investments in Greece.

Last but not least MyDATA is the platform in charge of receiving all the summary of eInvoices for B2B and B2G transactions. On this platform, the Greek authorities can process all the data and then create financial reports for each taxpayer in Greece.

Approach for receiving and processing eInvoices

The transfer method for myDATA is the myDATA Representational State Transfer Application Programming Interface (REST API). All entities that are obliged to apply the provisions of the Greek Accounting Standards, are obliged to transmit e-book data to Independent Authority of Public Revenues (A.A.D.E.), regardless of the type of the company (indicatively S.A., limited liability, private capital, limited or general partnership and others, as well as branches)[1].

The Peppol Access Point (AP) exclusively facilitating the issuers of the eInvoices enables the receiving of eInvoices from their ERP systems. Additionally, other systems, including the Peppol Access Point for the Public Administration Authorities are part of the National Interoperability Center of the General Secretariat for Information Systems of Public Administration at the Ministry of Digital Governance. Other Enterprise Resource Planning systems and standalone applications of the Public Authorities allow further processing of eInvoices, until their liquidation and payment.

The main eInvoice process flow scenario for public procurement includes the following steps:

1. Preparation of eInvoice data by the supplier/contractor and transmission to an eInvoicing service provider.
2. The eInvoicing service provider validates invoice data before submitting it, using the respective Interoperability Centre services.
3. The eInvoicing service provider reports and registers the eInvoice, for taxation reasons, to “MyData” application i.e. to a digital financial information application for taxation operated by the Independent Authority of Public Revenue in Greece.
4. The eInvoicing service provider prepares the eInvoice based on a) the European standard semantic model, b) the national specification that derives from the Joint Ministerial Decisions, and the Peppol Business Interoperability Specification.
5. The eInvoicing service provider submits the eInvoice to the access point of the Interoperability Centre through the Peppol network.
6. The Interoperability Centre receives and validates the eInvoice, according to the European and national rules for eInvoicing,
7. The Interoperability Centre routes the eInvoice to the competent contracting authority or competent IT system of the public body,
8. The competent contracting authority and financial service handle the invoice according to their internal procurement and payment practices using one of the IT systems or web application mentioned in the previous section. The competent authorities send the appropriate messages regarding the status of the processing of the eInvoice through the Interoperability Centre and the eInvoicing service providers to the supplier/contractor.

A working group (WG) has been established at the Ministry of Finance, with the mandate to steer and monitor all the necessary tasks for enabling the eInvoicing implementation. Members of the WG are senior/executive employees from the Ministry of Finance, the Ministry of Digital Governance, the Court of Auditors, the Information Society S.A. and the Athens University of Economics and Business (AUEB).

This WG has been established as a part of the major Fiscal Reform that the Ministry of Finance is pursuing, with the goal to switch gradually all General Government Entities to accrual accounting.

eInvoicing implementation in sub-central level contracting authorities 

These eInvoicing platforms and exchange services are now available for both central and sub-central administrations since 2020.

1. “MyData” application i.e. a digital financial information application for taxation managed by the Independent Authority of Public Revenue in Greece.
2. National Interoperability Center managed by the General Secretariat for Information Systems of Public Administration (GSIS PA) at the Ministry of Digital Governance, providing the following web services:
1. getInvoiceInfo (eInvoice reception from the systems of contracting public authority)
2. sendInvoiceResponse (transmission to the invoice issuer of the results from the processing of an eInvoice by the systems of public authority)
3. pdeCheckProject (validation checks of the project ePDE code)
4. sendInvoiceInfo (transmission of invoice data from the Governmental Peppol AP to National Interoperability Center)
3. Contracting Authorities Registry for eInvoicing managed by the General Secretariat for Information Systems of Public Administration (GSIS PA) at the Ministry of Digital Governance
4. A Web application for distributing the eInvoice to the competent Contracting Authorities managed by the General Secretariat for Information Systems of Public Administration (GSIS PA) at the Ministry of Digital Governance
5. IT Systems responsible for the accounting, acceptance, clearance and payment of eInvoices managed by the competent organisations.

Status on the implementation of the European Standard on eInvoicing (EN)

The Greek authorities have completed the development and testing of their own Peppol Access Point (AP) implying the usage of Peppol BIS Billing 3.0 which is based on the European standard on eInvoicing (EN 16931). The necessary fields and items of an eInvoice are outlined in the publication of the A. 1017/27-01-2020, which is the EN-compliant format used as well as in the relevant JMD regarding the semantic model.

Monitoring mechanism

Even though there is not an actual mandate for eInvoicing, eReporting is a mandatory obligation in Greece trough myDATA in accordance with the Νόμος ν. 4646/2019, this information encompass al the sales invoices in real time, as well as classification of revenues and expenses type and Enough accounting entries to determine end of year accounting and tax results.

The platform will analyse and validate the information published.

Digital reporting requirements

Greece has officially adopted a decision to introduce Digital Reporting Requirements. The available information estimates the policy development at the national level in the next years. Between 2022 and 2024, Greece started operating their own DRRs. Greece opted for Digital Reporting Requirements with the possibility of periodic reporting for smaller companies. This DRR will cover all transactions, over B2B, B2G and B2C segments, and both domestic and international transactions.

All companies resident in Greece (or in any event subject to local accounting requirements) will have to comply with the system, with no threshold foreseen. The taxable person with a turnover of less than EUR 50 000 or issuing less than 50 invoices per year will be able to use a special data entry form, which allows them to manually upload invoice data on the myDATA web portal.

In addition, Greece has extended the incentives to businesses, which decide to use eInvoicing through an accredited service provider.On August 7, 2022, Greece published Ministerial decision A. 1090/2022, which establishes the new timing for the electronic submission of accounting/invoicing information to the tax authority via the MyData digital platform, and the procedure to be followed by taxpayers in cases of contingency impeding the transmission of that data, or discrepancies between the data reported and the ledgers due at the end of each month. Effective January 1, 2023, invoicing information regarding wholesale transactions by taxpayers using commercial/accounting ERP systems should be submitted to the tax authority by the next day following the one in which the invoice or receipt was issued. 

[1] (MyDATA Electronic Books AADE, 2020),[2] (VAT in the Digital Age Report, 2022)

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