As previously reported, the Greek Independent Authority of Public Revenues (IAPR) held consultations for their new real-time invoice reporting (RTIR) initiative. However, no response has been published regarding the feedback received from the industry and other stakeholders.

There are, nevertheless, developments worth pointing out.

B2G e-invoicing mandate

As the Directive 2014/55/EU has entered into force, the central public entities in Greece have since April 2019 become obliged to receive invoices in an EN compliant format. The obligation will start to apply to all other public entities from April 2020.

According to the latest information, it is likely that the suppliers will be required to submit invoices electronically to the public sector of Greece. The Greek authorities have completed the development and testing of their own PEPPOL Access Point, which in turn means that the PEPPOL BIS 3.0 will be the mandatory EN compliant format.

No dates have been published yet, but sources have stated that this new obligation may start April 2020 and will be in line with the second EU directive deadline for the public sector.

RTIR initiative

Although the public consultations have ended, the IAPR has continued conducting unofficial discussions with various organisations and associations regarding the exact details of the RTIR obligation.

It can be confirmed that the IAPR still intends to receive, in real-time, sales and purchase invoices, and receipt data delivered electronically to the myData platform (My Digital Accounting and Tax Application). However, it is unclear whether the second part of the RTR obligation, which is real-time reporting of income and expense classification, will be removed or deployed at a later stage. The IAPR has received significant objections to this part of the obligation from the industry.

From a technical point of view, it is uncertain whether the RTIR can be combined with the B2G e-Invoicing mandate, as the PEPPOL BIS 3.0 does not support the anticipated classification data elements.

To date, no final technical specifications of the myData RTIR obligation have been published.

Timelines

None of the above-mentioned requirements have been passed by parliament, and thus there are no final timelines for inception the new obligations.

Some of the dates discussed are:

  • January 1, 2020 or January 2020 with penalty grace;
  • March or April 2020

Takeaways

Even though the timelines are still undisclosed and the final technical specifications have not been published, one should expect that the Greek authorities will express their intentions in the first half of 2020.

Greek entities should be ready to act when the final specifications of the two mandates, RTIR via myData and B2G e-invoicing via PEPPOL, are released to the public.

Pagero maintains close communication with the bodies in charge of both RTIR and the PEPPOL-based initiatives and expects to be compliant with the Greek requirements

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