Greece e-Invoicing Guide

Greece has built its e-invoicing infrastructure around the myDATA (my Digital Accounting and Tax Application) platform, operated by the Independent Authority for Public Revenue (AADE). It is a real-time reporting system rather than a clearance one: the tax authority receives transaction data as invoices are issued, and no approval is needed before an invoice reaches the customer.

The B2G duty attaches to contracts whose award procedures start after a set date: 12 September 2023 for a named group of ministries and state bodies, 1 January 2024 for the rest of central administration and 1 June 2024 for every other contracting authority. Other General Government expenses followed for invoices issued from 1 January 2025. The B2B mandate began on 2 March 2026 for large businesses, with all remaining businesses following on 1 October 2026.

The myDATA platform launched for voluntary reporting in 2020 and B2G e-invoicing was phased in from September 2023. Law 5222/2025 carried the B2B mandate, and AADE Decision A.1128/2025 set the scope and the two application periods. Decision A.1044/2026 then moved Phase 1 from 2 February to 2 March 2026 for businesses with 2023 gross revenues above EUR 1 million, with a transition period to 3 May 2026. Phase 2 covers all remaining businesses from 1 October 2026, with a transition period to 31 December 2026.

Government suppliers issue structured e-invoices in the Greek national format, which is based on Peppol BIS Billing 3.0 and the EN 16931 standard. The B2B mandate covers domestic wholesale supplies, wholesale supplies to entities outside the European Union, and public contracts. Sales to customers in other EU member states stay outside it, so the derogation Greece obtained does not disturb an EU customer's right to a paper invoice. It is being phased in by business size from March 2026, and all businesses already report transaction data to myDATA.

The myDATA reporting obligation applies to all businesses regardless of size and covers income classifications, expense classifications, and VAT data. B2C transactions are covered by myDATA reporting but stay outside the e-invoicing mandate.

Greece runs two channels. B2G invoices travel over the Peppol network to the interoperability centre of the General Secretariat for Information Systems, while mandatory B2B invoices are issued through an electronic issuance provider holding the AADE suitability licence known as ΥΠΑΗΕΣ, or through the free AADE timologio application. Both transmit the data to myDATA.

Peppol is the route for public procurement, not a requirement of the B2B mandate. Under AADE Decision A.1112/2025, every document issued through a provider carries the provider's name and website, an authentication string, a Unique Registration Number (known as the MARK), the issue timestamp and a QR code. A business with a permanent establishment in Greece and gross revenues of at least EUR 50 million may act as its own provider for its wholesale trade. Digital goods movement documents run on a separate track to myDATA under Decisions A.1122/2024 and A.1123/2024.

AADE Circular E.2004/2026 treats an invoice issued by hand or straight from an ERP, rather than through a licensed provider or timologio, as an invoice that was never issued. The only exception is a loss of connection caused by a power cut or an internet outage.

The fines then come from Article 57 of Law 5104/2024. For transactions carrying VAT it is 50% of the tax the missing document would have carried, or of the shortfall where the document was inaccurate, with a floor per audit of EUR 250 for single-entry and EUR 500 for double-entry bookkeeping. A repeat raises that to 100% and each further repeat to 200%. For transactions outside VAT the fine is EUR 500 or EUR 1,000 per audit depending on the bookkeeping system. Article 58 adds separate fines for data that never reaches myDATA, including EUR 100 for each digital goods movement document, capped at EUR 500 a day and EUR 20,000 a tax year.