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Legislation The transposition of the Directive 2014/55/EU 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, JMD 63446/2-6-2021 and JMD 98979/10.8.21, in order to stipulate the details regarding the adoption of the semantic data model of eInvoices and the architecture of eInvoicing in public procurement (B2G) in Greece. In these Ministerial Decisions the four-corner model interoperability architecture of Peppol eDelivery network was adopted. The 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 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 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. 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 the Decision 1170/2023 and 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. On 12/4/2023 Joint Ministerial Decision No. 52445 EX 2023 was issued describing the conditions and dates on which the "Obligation to submit electronic invoices by economic operators (EO)" is introduced. According to this JMD, from 1/6/2024 Economic Operators (EO) are obliged to send electronic invoices according to EN 16931 to all Contracting authorities and contracting entities in the context of public procurement. Additionally, from 1/1/2025 einvoicing will be mandatory for every expenditure over 2500€ in General Government. eInvoicing platform and eInvoicing management solutions The eInvoicing implementation in Greece consists of the following solutions that have been developed and supported:
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
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 Especially for Public Sector, certified Service Providers possessing Peppol Access Points (APs) facilitate through Interoperability Center (KE.D), 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 in sending the einvoice to CAs over eDelivery PEPPOL network . The data format of the eInvoices exchanged between all parties is based on the EN standard and follows the Greek business rules of PEPPOL implementing national data specifications deriving from Joint Ministerial Decisions. After the initial semantic check of eInvoices by the AP of KE. D, eInvoices are forwarded to the Interoperability Center. The Interoperability Center stores eInvoices and directs them to the respective Information Systems of the public bodies and transmits back to the issuers responses for the acceptance and payment or rejection of eInvoices, through SOAP web services. Final reception and processing of the einvoices is carried out either by Horizontal Systems of the Government such as EDHT, ePDE, General Accounting Office (GAO), and Contracting Authorities owned IT Systems. The main eInvoice process flow scenario for public procurement includes the following steps:
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, General Accounting Office, Independent Authority for Public Revenue, the Court of Auditors, the Information Society S.A. and the Athens University of Economics and Business (AUEB)Piraeus. 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.
There are no specific considerations at the sub-central level with respect to eInvoicing implementation. 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 According to referenced legislation, from 1/6/2024 Economic Operators (EO) are obliged to send electronic invoices according to EN 16931 to all Contracting authorities and contracting entities in the context of public procurement. From 1/1/2025 einvoicing will be mandatory for every expenditure over 2500€ in General Government. Monitoring mechanism Even though through there is not an actual mandate for eInvoicing, eReporting is a mandatory obligation in Greece trough myDATA in accordance with the the Νόμος ν. 4646/2019, this information encompass al all 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. [1] (MyDATA Electronic Books AADE, 2020),[2] (VAT in the Digital Age Report, 2022)
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