As the adoption of mandatory e-invoicing in Greece gets closer, the government has specified which e-invoicing format should be used by businesses in order to fulfil the mandates. Government agencies have also been working towards creating an accreditation commission for service providers, including specifications for qualification.

The Greek Gazette, the official journal of the Government of Greece, has published a circular on business-to-business (B2B) e-invoicing regarding the format of e-invoices exchanged between entities. Businesses are encouraged and likely to work with service providers for assistance in fulfilling format requirements and further technical details in order to remain compliant with mandatory e-invoicing regulations in Greece. Consequently, the Greek Gazette also released prerequisites that data service providers must meet in order to provide e-invoicing services to local companies.

Greece has long been hampered by tax fraud, and inadequate tax collection systems continue to cost the country billions of euros in tax revenue. This may change in 2020, however, with the expected introduction of two mandates being put in place to require e-invoicing in Greece. The mandates, among other objectives, aim to put an end to false, incorrect and incomplete invoices.

Invoicing format

After public consultations last year over which tools could most effectively combat the country’s VAT gap, Greece has defined the format to be used for mandatory e-invoicing.

The circular states that e-invoices between entities should be in accordance with the European standard as defined in EN 16931-1 as well as the operational rules set out in Peppol CIUS. The necessary fields of an e-invoice are outlined in the publication and listed for each line item.

The European standard is a semantic data model that outlines the essential elements of an e-invoice to ensure legal compliance for domestic, cross-border and cross-sector trade; Peppol CIUS provides Peppol participants a straightforward and well-documented approach to becoming compliant with the European standard. This is an important step as the EU member states are required to transpose the EU Directive by 18 April 2020.

Electronic data service provider obligations

The second circular outlines obligations for service providers in Greece and states that the Independent Public Revenue Authority (AADE) will create an Accreditation Commission to evaluate service providers.

The accredited service providers will be assigned a YPAIES (Υ.ΠΑ.Η.Ε.Σ) number, which serves as a unique license number for software applications issuing e-Invoices and is valid for five years. Holders of a YPAIES number must fulfil the following requirements:

  • Be established or active through a permanent establishment in Greece;
  • Have the appropriate technical staff available with an adequate service network;
  • Have a recorded and documented security policy data maintenance and policy that is ISO 27001 certified;
  • Fulfil the financial stability requirements: proof of tax information, certificate of non-debt of insurance contributions, certificate for non-lodging of an application of the supply, certificate of non-bankruptcy, certificate of non-liquidation.

Accredited service providers have a list of responsibilities they must fulfil, including registering with AADE. The method and data transmission to AADE, including document issuance, format, exchange and technical details, are all outlined in the publication.

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