2025 B2B e-invoicing mandate – Council of the EU gives permission for e-invoicing July 2025. Realistically, 2026 launch more likely
On 25th February, the Council of the European Union published its Greek B2B domestic e-invoicing implementing decision. It includes provision for e-reporting of transactions information to the government via its myDATA platform.
This approval will be time limited from 1 July 2025 until 31 December 2027 before which time VAT in the Digital Age reforms removed the obligation for such EC permission. However, practically, a launch in 2026 if more likely as often at least one-year’s notice for businesses to prepare is required.
Greece applied on 2 July 2024 for permission to replace paper invoices with e-invoicing, which requires EC authorisation to derogate from Articles 218 and 232 of Directive 2006/112/EC.
It is hopeful of receiving a derogation from the VAT Directive for a 2025 launch. E-invoicing would support the existing myDATA regime (see below) which already requires full reporting of VAT invoices and e-Books to the tax authority’s portal since 2022. The Greek e-invoicing mandate will look to consolidate gathering of transaction data for the myDATA platform. This will result in pre-filled VAT returns possibly from 2025 or 2026.
Details of the requirements have yet to be confirmed.
Jan 2024: Updates to revenue and expense reporting to myDATA reporting
Greece’s tax transaction reporting regime platform, myDATA, includes a number of updates from 1st January 2024. There are longer term plans (see below) include mandatory VAT e-invoicing potentially from 2025.
- The start of the requirement to submit via ERP API sales invoicing and bookkeeping data. The new requirement from the Greek tax office, AADE for transmission of summary data will switch to live reporting. Taxpayers reporting by other routes (manually, cash registers or portal upload) are unaffected. AADE announced a range of other changes, including using QR Codes from systems for fiscal receipts.
- Customers receiving fiscal documentation that is different from that issued by the vendor before their next VAT return.
Greece’s Ministry of Finance and tax authority (AADE) will also extend into 2024 the tax incentives for taxpayers which adopt e-invoice reporting via certified e-invoicing providers.
myData sales & purchase invoice and ledger reporting
myData was phased in between 2021 and 2022. It covers: sales & purchase invoices; and key ledgers reporting:
- e-Books or Ledgers: General Ledger; Payroll; Fixed Assets, including amortisation. Cross-border transactions and B2C sales not included in e-Invoices
- e-Invoices: B2B sales and purchase invoices, which accounting coding data. Only sales invoices are shared with AADE which is then matched to supplier sales invoices.
Taxpayers also still issue paper or PDF invoices to their suppliers, and must submit regular VAT returns, Intrastat and EC Sales Lists, as required. It is only a requirement for resident VAT registered businesses.
myData filing submissions
There are five routes for submitting e-invoices and e-books.
- Manual uploads for small numbers of invoices;
- From enabled ERP’s and accounting software linked to myDATA;
- Online certified cash registers which are connected to AADE; or
- Commercial providers of e-Invoicing services. These must be Greek-resident businesses. Providers must have demonstrated robust invoice creation, storage and retrieval systems to guarantee the integrity of invoices. The must also be Greek resident, and meet financial stability tests. Invoice data may be stored elsewhere in the EU.
- a free invoice issuance and transmission application called “timologio”, provided by the IAPR.
From a technical perspective, the VAT books and the e-invoice data needs to be mapped and prepared in a pre-defined XML format. Then, this XML file needs to be submitted to the Greek AADE myDATA platform. The XML format follows the European EN 16931-1 standard.
The submission is on a monthly or on a quarterly basis – depending on the size of the taxpayer. The data submission should to be completed before the 20th day after the end of the month for ledgers in which the relevant invoices were issued. This will be supplemented with the online cash register VAT system for retail transactions.
AADE will use e-invoice to match with customer reporting to identify and return via myDATA any discrepancies. Check VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time submissions of invoices is being implemented.
Certified Cash registers
The rollout of the certified online cash registers, linked to the tax office, AADE, progresses with the requirement to adopt Quick Response Code (QR Code) for receipts by November 2021.
EU Digital Reporting Requirements
The ongoing EU VAT in the Digital Age proposals includes a strand around harmonised Digital Reporting Requirements (DRR) and Continuous Transaction Control (CTC) across the member states. This originated from the 2020 Tax Package measures for a fairer and more efficient EU tax regime.
