E-book reporting scheme in Greece and e-invoicing: What is what

Blog Compliance August 12, 2020

“If it looks like a duck and quacks like a duck, it’s probably a cat,” says Pagero’s VP of Regulatory Affairs Nazar Paradivskyy about the language surrounding the new e-book reporting scheme in Greece. Here he clarifies how e-reporting regulations differ from e-invoicing and lays out responsibilities of buyers and sellers under the obligations.

The truth about e-invoicing under the e-book reporting scheme in Greece

As previously reported, there has been a lot of progression in the digital reporting landscape in Greece. Under the new e-book scheme, taxpayers have several technical options to fulfil the reporting obligations. One of the options is to submit data via a myDATA-accredited electronic invoicing (e-invoicing) service provider (myDATA Agent). Despite the use of “e-invoicing” language, we have determined that this is in fact a reporting obligation unrelated to e-invoicing.

After carefully studying the regulations and specifications from the IAPR (Independent Authority of Public Revenue) of Greece, we’d like to outline our perspective for using a myData Agent to fulfil the reporting obligations and how it relates to electronic invoicing (e-invoicing).

Reporting obligations are not e-invoicing

Simply put, e-invoices are the same as paper invoices except for being issued and exchanged in an electronic format. E-invoices must include data elements according to a jurisdiction’s indirect tax regulations. Other regulations, such as commercial, may require provisions of additional data elements in an e-invoice. Finally, e-invoices include relevant business data that the trading parties may have agreed upon as part of their business processes.

Under the e-book reporting scheme in Greece, both sellers and buyers are required to submit revenue and expense classification for each item on the invoice based on their VAT treatment to the myDATA platform. In other words, they must assign individual revenue and expense classification to each item on an invoice belonging to exempt, 6%, 13%, 24%, etc. VAT treatment. Typically, neither paper nor e-invoices include such information as they are accounting fields.

Provision of such classification entries along with an invoice summary (synopsis) can hardly be considered the same as e-invoicing. This is a reporting obligation, which can be done in multiple ways. Although Greek regulators refer to one reporting mechanism as “e-invoicing,” it actually has nothing to do with e-invoicing.

Which data must taxpayers report?

Besides the invoice summary (synopsis) and the revenue and expense classification, taxpayers must also report additional data unrelated to invoices. This includes such accounting entries as payroll (salary statements), amortisations and depreciations. Such data is not generally included in an invoice nor processed by e-invoicing service providers.

Buyer reporting obligations

Important to note is that not only sellers (typically the issuer of the invoice) has reporting obligations under the e-book scheme. Buyer reporting obligations are not as time-constrained, but the scope is wider than those of the seller. Buyers must report expense classification for received invoices (already reported by the seller) or payroll, as well as report, among other information, cross-border transactions, transactions with credit institutions, cash transactions, etc.

We wonder how cost-efficient it is for taxpayers to use different reporting mechanisms, one for reporting of sales data (e.g. via myDATA Agent) and another for reporting purchase data (e.g. via ERP).

Exclusivity of the reporting mechanism

As outlined earlier, taxpayers have several mechanisms to select from in order to fulfil reporting obligations. In this respect, it is worth stressing the fact that a taxpayer’s choice has to be exclusive. This means that taxpayers cannot report certain data via ERP or accounting software (e.g. revenues and expenses classification or payroll) while reporting other data via a myDATA Agent (e.g. invoice synopsis). Taxpayers must perform all reporting via the same electronic mechanism.

Assignment of MARK

Earlier drafts of the e-book reporting scheme in Greece communicated that myDATA Agents could act on behalf of myDATA. The IAPR stated that myDATA Agents could perform validation of submitted data and, upon successful validation, approve the submission by assigning a unique identifier (MARK in Greek). However, in the most recent draft regulations, only the myDATA platform will be able to assign the MARK. This means taxpayers can no longer leverage potential benefits of limiting dependency on myDATA through use of a myDATA Agent.

Such a change gives rise to further questions surrounding e-invoicing as a reporting mechanism under these regulations.

Is there an obligation to issue e-invoices?

In short, no. The e-book reporting regulations only cover the reporting of accounting entries to the myDATA platform. Even if a myDATA Agent has been selected to report such entries, the seller is not required to actually exchange the e-invoice with the buyer. The seller also does not have to use the selected myDATA Agent to send the e-invoice to the buyer.

Can I issue e-invoices in Greece?

Yes. The new regulations do not change the taxpayers’ ability or obligations to issue or exchange invoices electronically. Further, our understanding is that a Greek taxpayer has two options for issuing and exchanging e-invoices:

  • Use services of a locally accredited myDATA Agent who may or may not be supporting the taxpayer with myDATA reporting obligations; or
  • Use services of any e-invoicing service provider preferred by the taxpayer, irrespective of whether the Greek taxpayer uses services of ERP/accounting software or myDATA Agent to fulfil the myDATA reporting obligations.

Are myDATA Agents recommended to fulfil obligations?

myDATA Agents will certainly fulfil an important role under the e-book reporting scheme in Greece. Not all ERP or accounting software will manage to upgrade to the new reporting requirements. Additionally, it is unlikely that systems will be able to hold necessary data or connect myDATA to submit accounting entries. In such cases, taxpayers will be able to use myDATA Agents as middleware between their system and myDATA platform in order to fulfil the e-book reporting obligations.


The regulations under the e-book scheme reporting scheme in Greece that mention “e-invoicing” have nothing to do with e-invoicing. In fact, an “accredited e-invoicing service provider” under these regulations is just one of several mechanisms provisioned for reporting accounting entries to the myDATA platform.

When it comes to actual e-invoicing, the new obligations have limited impact on this process compared to existing regulations and business processes. Taxpayers should be able to continue using their preferred e-invoicing service provider whether accredited as myDATA Agent or not.

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