eInvoicing in Greece

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, 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 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)

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.

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. 

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.

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:

1. 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 General Secretariat of commerce and Consumer Protection Secretariat of the Ministry of Development
   • An informative website for eInvoice in Public Procurement: This website https://www.gsis.gr/e-invoice 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 2,500 contracting authorities have been registered.
   • 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 visualize eInvoices and to inform suppliers/contractors on the handling status of eInvoices e.g., acceptance, rejection, payment etc.
   • National Interoperability Centre (KE.D):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 and various horizontal IT systems . 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 (Label) 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.
   • General Accounting Office: IT system for the clearance and payment of the Central Government expenditures.
2. by Public Investments Program of Ministry of Finance:
   • e-PDE IT system for the clearance and payment of projects funded by Public Investment Program.
3. By Independent Authority for Public Revenue (IAPR)
   • MyDATA is the platform in charge of receiving all the summaries 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].

Especially for Public Sector, certified Service Providers possessing Peppol Access Points (APs) facilitate through Interoperability Center (KE.D), the issuers of the eInvoices   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:

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, General Accounting Office, Independent Authority for Public Revenue, the Court of Auditors, and University of 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 

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)

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 through 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 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)

Last updated:  Jun 25, 2024 15:59