Regulatory updates - Greece

The tax authority has released a circular providing clarifications regarding digital stock movement documentation obligations. The circular addresses requirements for digitally issuing stock movement documents and transmitting the relevant data to the AADE's myDATA digital platform.

BASIC ROLES

Below are listed the entities obligated to issue or receive digital documents for the movement of stocks and the transmission of their data to the myDATA digital platform:

• Sender of inventories (main Inventory)
• Third Party (Consignor or Warehouseman)
• Inventory carrier (can also be a Warehouseman)

SCOPE AND EXCEPTIONS

Annex A of Law 4308/2014 defines assets as items that are:

• Held for sale in the entity's normal course of business, or
• In the production process for the purpose of sale, or
• In the form of materials or supplies (materials of any kind) intended for consumption in the production process or for service provision.

Exemptions for non-commercial movements, fixed assets, and waste

• In the case of movement of materials that are used for the provision of services, there is no obligation to issue a digital consignment note since (special conditions apply)
• Movement of fixed assets provided that they are not moved with the intention of selling them
• fixed assets for the purpose of their disposal/destruction/recycling in disposal areas, there is no obligation to issue a digital movement document

Rules for courier deliveries, fuel sales, and customs shipments

• For retail transactions carried out through postal and courier service entities the seller issues a movement document indicating movement to the final recipient of the inventory and delivers the package to the courier.
• When energy products (fuels) are transported from a seller's establishment to retail customers—whether using the seller's own vehicles, third-party transport arranged by the seller, or other means—a movement document must be issued and transmitted.

PENALTIES

According to par. 9A of article 5 of Law 4308/2014 , entities moving stock inventory must issue digital movement documents that meet specific requirements. These documents must conform to the format and specifications outlined in the Governor of the Public Administration Authority's Decision A.1123/2024.

Entities that transport stock without properly formatted digital movement documents fail to meet their legal obligations. As a result, penalties apply under par. 13 of article 57 of Law 5104/2024 (A' 58):

• For entities maintaining single-entry accounting systems: a fine of five hundred (500) euros per tax audit
• For entities maintaining double-entry accounting systems: a fine of one thousand (1,000) euros per tax audit

 Not all information and scenarios have been included in this update. To learn more details, get information on conditions that apply, and read examples, access Circular E.2030 / 12-06-2025

Amendment of the joint decision of the Ministers of Finance, Development and Investment, Infrastructure and Transport and State under item 52445 EX 2023/04-04-2023 "Obligation to submit electronic invoices by economic operators".

According to the legislation, contracting authorities and contracting entities are obliged to receive and process electronic invoices and at the same time economic operators are obliged to submit electronic invoices, which are in accordance with the European standard for issuing electronic invoices and are issued during the execution of public contracts, regardless of their value.

The revised implementation timeline for mandatory electronic invoice submission is as follows:

• Since 12 September 2023: e-invoicing mandatory for suppliers to selected public entities (e.g. Ministries of Transport, Digital Governance, Migration & Asylum, etc.).

• From 1 January 2024: extension to all central government entities
• From 1 June 2024: extension to all other public sector contracting authorities
• From September 1, 2025: invoicing of non-procurement public expenses (e.g. utilities, rents).

It's worth noting that the deadline for non-procurement public expenses has been postponed multiple times - originally set for January 2025, then June 2025, and now September 2025.

The amendment also adds a fifth category to the list of excluded contracts and expenditures:

• Public contracts that fall within the scope of Article 148 of Law 4601/2019, and are concluded pursuant to Articles 117A and 327A of Law 4412/2016 (of minor value).
• Public contracts between public sector bodies, awarded in accordance with Article 12 of Law 4412/2016, b) contracts between contracting authorities, awarded in accordance with Article 247 of Law 4412/2016 and c) concession contracts between public sector bodies, awarded in accordance with Article 16 of Law 4413/2016.
• Other expenses of up to 2,500 euros.
• Other expenses of General Government bodies, regardless of value, which are classified as confidential and do not fall within the scope of Laws 4412/2016 and 4413/2016.
• Costs of work lease agreements concluded between natural persons and bodies of the General Government

More information can be found in Articles 1 and 2 from the Official Gazette of the Government of the Hellenic Republic (in Greek)

Greece has recently released many amendments that affect the E-transport mandate. Below is a summary to help businesses understand the changes that the digital transportation mandate has gone through, including tailoring the scope, changes to the timeline, and others.

Redefined scope for the first period in the first phase

• The amount of taxpayers' gross income exceeds two hundred thousand 200,000 EUR (based on the 2022 income tax return, excluding entities whose gross income exceeds 5 million EUR, are subsidiaries of a foreign company and make use of the commercial/accounting management program of the foreign company they operate or;
• Taxpayers active in the sectors of energy products (fuels), pharmaceutical products and medical consumables, construction and related materials, regardless of the gross revenue. This is based on the income tax return submitted for the 2022 tax year.

Timeline of digital transportation documents data transmission

The following updates were made to the timeline of digital transportation documents data transmission:

• Within 5 days from the date of receipt: In case where surpluses or deficits are identified, the Recipient transmits to myDATA digital platform Types of Transportation Documents without value (quantitative receipt notes);
• Within 5 days from the date of receipt: In case of inventories, transportations relating to intracommunity acquisitions or acquisitions from non-EU countries, the Recipient transmits to myDATA digital platform Types of Transportation Documents without value (quantitative receipt notes).

Other amendments

Further amendments include:

• Terminology standardization;
• UUID: The Recipient VAT number field has been removed from UID composition for document types no longer in scope;
• QR codes are now mandatory for certain documents;
• Cross-Border Transactions: Some documents will no longer be required (documents 14.1 and 14.2). While cross-border inventory reception will still be required to be documented (documents 10.1 or 10.2), it is no longer in scope;

Updated Annex I outlines two implementation phases:

• Phase A: Document issuance and transmission to myDATA;
• Phase B: Real-time tracking and receipt confirmation.

For a detailed overview of all amendments related to digital transportation documents, visit the official sources A.1046/2025, Α.1047/2025, and A.1052/2025