Electronic invoice in Greece

This page provides an overview of the requirements, formats, and data fields used for electronic invoicing in Greece.

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Overview

Greece has moved from a reporting-led system built around myDATA to a genuine mandatory B2B e-invoicing regime. The legal basis is Law 5222/2025 with decisions A.1128/2025 and A.1129/2025, and the first wave went live on 2 March 2026 after a postponement.

What makes Greece unusual is that it runs two different circuits at once. B2G travels over Peppol under a Greek CIUS. Domestic B2B does not: it must be issued through a licensed YPAHES provider or a free AADE application, transmitted to myDATA in real time, and stamped with a unique registration number. Peppol certification is no substitute for the second circuit.

EAS 9933

the Greek AFM tax number, used without a country prefix

Two channels

a licensed YPAHES provider, or the free AADE applications

MARK

every document receives a unique registration number from myDATA

Timeline

B2G arrived first, in four steps between 2023 and 2025. The B2B mandate follows in two waves, each with its own conditional adaptation period.

Already in force

2023 – 2024

B2G phases one to three

From 12 September 2023 for a listed group of ministries, municipalities and public organisations; from 1 January 2024 for central administration contracts; from 1 June 2024 for the remaining contracting authorities and entities.

1 September 2025

B2G extends to general government expenditure

A joint ministerial announcement brought the remaining General Government expenditure into scope, with statutory exceptions — see B2G and Peppol.

2 March 2026

B2B wave one begins

Businesses with gross revenues above €1 million for the tax period starting in 2023. Decision A.1044/2026 had moved this from 2 February. At the time of the announcement AADE reported that roughly 34,000 of the 38,000 obliged businesses had already activated electronic issuance.

4 May 2026

Wave one becomes exclusive

The conditional adaptation period ran from 2 March to 3 May 2026, during which a business that had filed its declaration on time could keep running its ERP or the special entry form in parallel. Since then, issuance for this group must go through the mandated channels — and penalties apply.

3 August 2026

The early-adoption incentive window closed

The tax incentives for adopting at least two months before the deadline are no longer available to wave-two businesses.

Ahead

1 October 2026

B2B wave two begins

All remaining entities subject to the Greek Accounting Standards. A conditional adaptation period runs to 31 December 2026 for those that declare use of a YPAHES provider or timologio with a start date no later than 1 October.

1 January 2027

Wave two becomes exclusive

After the transition closes, the mandated channel is the only compliant route for this group as well.

1 July 2030

ViDA for intra-EU B2B

Digital reporting requirements based on e-invoicing take over the cross-border segment. By 1 January 2035 national real-time systems — myDATA among them — must be aligned with the EU model.

The B2B mandate

A.1128/2025 permits only two ways of issuing a mandatory electronic invoice. There is no third option, and an invoice produced outside them is treated as not issued at all.

A licensed YPAHES provider

Υπηρεσίες Παρόχου Ηλεκτρονικής Έκδοσης Στοιχείων — an electronic data issuance provider whose software holds an AADE suitability licence.

The free AADE applications

timologio and the mobile myDATAapp, which cover issuance for public contracts as well — at no cost.

Whichever channel is used, the process is fully digital: the transaction is transmitted automatically to myDATA in real time and the document receives its mandatory MARK (ΜΑΡΚ), the unique registration number.

Acceptance is mandatory

A.1044/2026 makes acceptance of the electronic invoice compulsory for the recipient in domestic transactions within scope. A Greek customer cannot insist on a different format or refuse the document because it arrived electronically.

If the connection fails

Contingency procedures exist. Where the link between provider and AADE is lost, documents may continue to be issued, but the provider must transmit them to myDATA and to the recipients within the prescribed emergency deadline — in the relevant scenario, no later than one day from the date of issue. Worth confirming with your provider that this path is actually implemented, not just documented.

Cross-border scenarios

Greece's cross-border logic is one of the most counter-intuitive in Europe, and it catches out anyone who assumes the EU is treated more favourably than third countries. It is the other way round.

Greece → GreeceIn scope. Mandatory issuance through YPAHES or timologio, with real-time myDATA transmission and mandatory acceptance

Greece → Germany (intra-EU B2B)Not in scope of A.1128. Intra-EU B2B is deliberately absent from the list of mandated transactions

Greece → Switzerland or USA (non-EU B2B)In scope. B2B invoices issued by a Greek entity to a foreign entity outside the EU follow the same waves and channels as domestic B2B, retail excepted

Foreign supplier → Greek public bodyGreek B2G CIUS over Peppol, using a certified access point of the supplier's choice

Foreign supplier → Greek private companyA Greek VAT registration alone does not automatically create a YPAHES obligation; establishment and Greek accounting status have to be analysed separately

Why the EU is excluded

This follows the derogation Greece obtained under Council Implementing Decision (EU) 2025/502. It authorised mandatory e-invoicing for taxable persons established in Greece and removed the need for recipient consent domestically — while preserving customers' right to receive paper invoices in intra-Community transactions. Greece could not have extended the mandate to intra-EU B2B even if it had wanted to.

One distinction worth holding on to: existing myDATA reporting obligations are not the same thing as the A.1128 issuance mandate. Having to report transaction data to AADE does not by itself mean the invoice must be issued through the YPAHES or timologio route.

B2G and Peppol

The public-sector circuit is a classic Peppol four-corner model with a single state Corner 3 at GSIS (the General Secretariat of Information Systems and Digital Governance). The National Interoperability Centre, KE.D, receives the flow, validates the XML and routes the invoice to the right contracting authority.

The route for a Greek issuer

Invoice → myDATA → MARK → state B2G intake → contracting authority

Greek-issued B2G invoices pass through myDATA validation and marking before entering the Peppol network. The model is best described as Peppol four-corner transport with a pre-Peppol tax control gate — not as a five-corner architecture, which is not how the Greek documentation describes it.

The state three-corner route

The current Greek National Peppol Format Guide describes a second option for Greek issuers: timologio → myDATA/MARK → timologioB2G → KE.D → public authority. Here no private Corner 2 provider is needed. timologioB2G adds the national CIUS routing data, generates the final Peppol/EN 16931 XML, validates it and sends it straight to KE.D by web service. GSIS officially calls this a simplified three-corner architecture.

What falls outside the B2G mandate

—Certain minor-value contracts under specific public procurement provisions

—Certain public-to-public contracts and concessions

—Other expenditure up to €2,500

—Certain classified expenses, and work-lease contracts between individuals and General Government bodies

The central receiver Participant ID is 9933:997001671. GSIS stresses that it is not itself the buyer: it acts as the central physical receiver and intermediary, while the actual contracting authority is identified by other routing fields inside the invoice. The Contracting Authority Code is a national routing identifier within the document — not a Peppol Electronic Address Scheme, and the two should not be confused.

Mandatory routing fields

Because the invoice is addressed to a single central receiver, the Greek CIUS uses business terms inside the document to identify the real buyer. Getting these wrong is the most common practical failure in Greek B2G — the invoice reaches GSIS and then goes nowhere.

BT-1Invoice number — also the key you use to trace the invoice status afterwards

BT-10Buyer reference

BT-11Project reference

BT-12Contract reference — the ADAM, the Greek contract registration number

BT-46Contracting authority label code

You cannot look these values up. GSIS states that the correct values are provided exclusively by the contracting authority that will receive the invoice. Ask for them before the first submission rather than after the first rejection — and store them against the customer record, not against the invoice.

Resubmission after a soft reject

The Greek format distinguishes an initial submission from a corrected one. Where the contracting authority has already received the invoice and asked for corrections — a soft reject — the resubmission must be flagged as such rather than sent as a fresh initial submission. Credit notes carry the same logic, with an additional billing reference where one applies.

GSIS publishes a free E-Invoice Support Tools application that takes these values and returns the exact XML segments to embed in the invoice, for both invoices and credit notes. It is the quickest way to check what a compliant Greek payload actually looks like before writing the mapping — the link is under resources.

B2C and fiscalisation

There is no separate structured B2C e-invoicing mandate comparable to domestic B2B. Retail is not in the list of mandated transactions under A.1128. What exists instead is a deep integration between retail and the Greek fiscalisation and myDATA ecosystem.

—Decision A.1112/2025 governs retail documents issued through a YPAHES provider instead of a fiscal electronic mechanism

—Such documents must carry the prescribed marking, uniqueness and authenticity controls, the time of issue, the MARK and QR-related data

—A tax summary is transmitted to AADE

—The receipt may be sent to the consumer electronically — provided it can be produced during a tax audit — or printed and handed over

In short, Greek B2C is a fiscal receipt and fiscal data reporting regime rather than an EN 16931 e-invoice mandate.

Formats and standards

The two circuits have different format logic, and carrying the B2G answer across to B2B is a common and expensive mistake.

B2G

Semantic modelEN 16931, through a Greek specialisation of the Peppol CIUS

Operational profilePeppol BIS Billing 3.0 in UBL 2.1 — Invoice and CreditNote — plus the Greek national business rules

CIIThe GSIS format guide mentions both EN 16931 syntax bindings, but the operational Greek profile and the published XML specifications are built on UBL. Implement Greek B2G as UBL 2.1, not CII

PDFGSIS states plainly that an invoice image, PDF included, e-mailed to a contracting authority is under no circumstances an electronic invoice for public contracts

Domestic B2B

The B2B mandate is not a Peppol BIS or UBL mandate. The legal requirement is issuance through YPAHES or timologio and transmission to myDATA. The format follows from the channel rather than driving it.

In the myDATA technical specification AADE provides a downloadingInvoiceUrl through which a provider can make the document available in three representations — /pdf, /myDATA as detailed myDATA XML, and /EN16931 as an ELOT EN 16931 representation. The same URL is used for the QR code and is being developed as a mandatory field.

So EN 16931 is supported as a standardised representation of a domestic B2B invoice, but it is not the transport requirement. A PDF may be the human-readable rendering of a properly provider-issued invoice — a PDF-only invoice created and sent outside the YPAHES, timologio and myDATA process is not.

The myDATA model

For domestic B2B the architecture is a centralised, clearance-like CTC model centred on AADE and myDATA. The term is used deliberately: AADE describes the system through electronic issuance, real-time transmission and the MARK rather than officially calling it a clearance model — but architecturally, that is a tax control loop with mandatory fiscal registration of the document.

01 The invoice is issued through a YPAHES provider or timologio

02 The data is transmitted automatically to AADE and myDATA in real time

03 The document receives its mandatory MARK

04 The provider authenticates the document and delivers it to the recipient

This is neither a Peppol four-corner B2B model nor an official Peppol five-corner model. For a country matrix, Greece should not be recorded as five-corner: the Greek documentation does not use that description, and the B2G and B2B circuits behave differently enough that a single label misleads.

YPAHES and providers

Three separate layers of qualification exist in Greece and they are routinely conflated: Peppol certification, YPAHES licensing by AADE, and KE.D testing for B2G. Having one does not give you the others.

Decision A.1112/2025 provides that a YPAHES suitability licence may be granted to a legal person that has its headquarters in Greece or operates through a permanent establishment in Greece. A foreign certified Peppol access point without a Greek establishment and without a YPAHES licence cannot rely on its Peppol certification to serve mandatory domestic Greek B2B issuance.

What a YPAHES licence requires

—Adequate technical personnel

—A documented and verifiable data security policy

—ISO 27001 or another security certificate recognised as equivalent

—Financial solvency

—Storage of issued-document data within the EU

—A description of the issuance and document authentication process, the interfaces and the myDATA transmission, submitted for a suitability assessment

Who needs what

Provider serving Greek B2G suppliersPeppol provider certification, an AADE licence for the YPAHES software, and a successful KE.D test cycle

Provider serving foreign B2G suppliersCertification by OpenPeppol and/or the provider's home Peppol Authority, plus the KE.D test cycle. No Greek subsidiary needed purely for Peppol transport

Provider serving mandatory domestic B2BThe YPAHES framework, which means a Greek establishment or permanent establishment

A Greek supplier itselfMay bypass private providers entirely by using the free timologio and timologioB2G route

The OpenPeppol Greece country profile sets out three routes for a foreign provider: establish a Greek subsidiary and obtain YPAHES accreditation while using the parent's technical platform; do the same with separate Peppol service provider certification; or contract with a Greek certified Peppol provider and route Greek customer invoices through its Corner 2. No separate national official electronic mailbox comparable to the Slovak model was found — the entry barrier here is the licence and the establishment requirement, not a state mailbox.

Tax incentives

Greece attached real money to early adoption, under Article 71ΣΤ of the Income Tax Code. The benefit was substantial and is the sort of thing most country guides leave out.

—A 100% super-deduction on the initial purchase of technical equipment and software required to implement e-invoicing, fully depreciable in the year incurred

—The same super-deduction on the costs of generating, transmitting and electronically archiving e-invoices during the first twelve months of implementation

—Conditional on adopting at least two months before the applicable mandatory date

Both windows have now closed. The deadline was 1 December 2025 for wave-one businesses and 3 August 2026 for everyone else. Any vendor still presenting these incentives as a reason to sign is quoting an expired benefit.

The incentives are withdrawn where the declaration for using e-invoicing is revoked, or where an invoice is issued without a licensed provider or the AADE application. Note also that Article 71Θ is not available to entities that took the Article 71ΣΤ benefit — the two do not stack.

Archiving

Under the Greek Accounting Standards and the Tax Procedure Code, accounting records and documents must be retained for as long as the tax authority may audit them — as a rule five years from the end of the year in which the relevant return was filed, with the period extended in specific cases such as undeclared income or where a longer limitation applies.

Keep the issued document together with its MARK — the marking is what evidences that the document went through the mandated channel

A licensed YPAHES provider must store issued-document data within the EU — a condition of its licence, and worth confirming contractually

Documents must remain accessible and producible during a tax audit — including retail receipts sent electronically to consumers

The provider's downloadingInvoiceUrl is a convenience for retrieval, not an archive you own. Where the relationship with a provider ends, make sure the underlying documents come with you.

Penalties

A.1128/2025 contains no separate tariff along the lines of "€X per invoice sent outside the system". The sanctions sit in the general Tax Procedure Code, Law 5104/2024 — but AADE has been explicit about how the two connect.

The key qualification

Under circular E.2004/2026, failing to comply with the obligation to issue an electronic invoice is treated as non-issuance of that invoice. The penalties of Article 57(5) and (6) of Law 5104/2024 therefore apply — which is a far heavier consequence than a formatting error.

50% of the taxFor failure to issue an electronic invoice for VAT-bearing transactions — on the tax that would have arisen from the non-issued document, or on the difference

€500 per auditFor non-VAT transactions, where the taxpayer keeps single-entry accounts

€1,000 per auditFor non-VAT transactions, where the taxpayer keeps double-entry accounts

Failure to transmit data to AADE

Article 58(3) provides for 10% of the net value of each untransmitted document, capped at €250 per day, with late transmission in the relevant categories penalised at 50% of the non-transmission fine. Note that the Code allows the commencement, entities and procedure for applying Article 58(3)–(6) to be set by separate decisions, so a given breach needs to be qualified on its facts rather than assumed into a category.

Penalties on the provider

Where a YPAHES provider fails to transmit provider-issued documents to myDATA and those documents consequently did not receive a MARK, Article 58(7) provides for 50% of the VAT on the untransmitted documents for VAT transactions, or 10% of net value for non-VAT ones — with a minimum of €10,000 and a maximum of €50,000 per tax audit, doubled on repetition. Greece places substantial compliance responsibility on the licensed provider itself, which is worth weighing when choosing one.

Is an e-invoice the only basis for deducting VAT?

Not in those literal terms. Article 37 of the Greek VAT Code requires a lawful invoice or another document taking its place, evidencing the supply and the VAT charged. For intra-Community acquisitions and reverse-charge scenarios the law even provides an alternative where no invoice exists, linking the right to the relevant VAT return provided the transactions are reflected in the accounting records.

The critical procedural constraint sits elsewhere: Article 16(2) of the Tax Procedure Code provides that deductions and deductible expenses are not recognised where the supporting documents were not electronically transmitted to AADE under the mandatory transmission rules. So the accurate formulation is that a structured e-invoice is not named as the sole substantive basis for deduction — but electronic transmission to AADE is a critical procedural condition, and for transactions inside A.1128 the invoice must additionally have been issued through the mandated channel.

How we help

Greece needs both circuits handled correctly, and honesty about where a European access point can and cannot act:

Greek B2G over Peppol as a certified Access Point — Peppol BIS Billing 3.0, UBL 2.1 and the Greek CIUS rules

Addressing on EAS 9933 with the Greek AFM, and correct routing to the central receiver

Validation against the Greek national business rules before dispatch

EN 16931 data preparation from ERP, CSV and IDoc sources, ready for either circuit

A clear assessment of whether your Greek transactions fall inside A.1128 — including the non-EU export trap

Coordination with a licensed YPAHES provider where the domestic B2B mandate applies to you

One connection covering Greece and the rest of Europe, via API, SFTP or CSV

Frequently asked questions

Can I use Peppol for domestic Greek B2B?

No. Peppol is the backbone of Greek B2G, but for the mandatory domestic B2B regime it is not the required transport. A.1128/2025 permits only issuance through a licensed YPAHES provider or the free AADE applications — timologio and the mobile myDATAapp — with real-time transmission to myDATA and a MARK on the document. Peppol certification is a different qualification entirely.

Why is an invoice to Switzerland in scope but one to Germany is not?

Because of the EU derogation. A.1128 lists domestic B2B, B2B with a company in a country outside the EU, and B2G — intra-EU B2B is deliberately absent. Council Implementing Decision (EU) 2025/502 authorised mandatory e-invoicing for taxable persons established in Greece and removed recipient consent domestically, while preserving customers' right to receive paper invoices in intra-Community transactions. Greece could not extend the mandate to intra-EU B2B. From 1 July 2030 that segment falls under ViDA instead.

Can a foreign Peppol access point serve Greek B2B clients?

Not on Peppol certification alone. A YPAHES suitability licence under A.1112/2025 requires headquarters in Greece or operation through a Greek permanent establishment. The practical routes are to establish a Greek subsidiary and obtain YPAHES accreditation — optionally using the parent's technical platform — or to contract with a Greek certified provider and route Greek customers through its infrastructure. For B2G it is much more open: a foreign certified access point can serve foreign suppliers invoicing the Greek state, subject to the Greek CIUS and a successful KE.D test cycle.

What happens if we issue outside the mandated channel?

AADE treats it as non-issuance of the invoice under circular E.2004/2026, which triggers Article 57(5) and (6) of Law 5104/2024: 50% of the tax that would have arisen for VAT-bearing transactions, or €500 per audit for single-entry and €1,000 per audit for double-entry taxpayers where no VAT is involved. This is not treated as a technical formatting issue.

Are the tax incentives still available?

No — both windows have closed. The Article 71ΣΤ incentives gave a 100% super-deduction on the initial equipment and software purchase and on generation, transmission and archiving costs during the first twelve months, conditional on adopting at least two months before the mandatory date. That meant 1 December 2025 for wave-one businesses and 3 August 2026 for everyone else. The benefit is also withdrawn if the e-invoicing declaration is revoked or an invoice is issued outside the licensed channel.

Does my Greek customer have to accept the electronic invoice?

Yes, for domestic transactions in scope. A.1044/2026 makes acceptance mandatory for the recipient, so a Greek customer cannot demand a different format or refuse the document on the ground that it arrived electronically. This mirrors the derogation, which removed the recipient-consent requirement for domestic transactions.

What happens if the connection to AADE drops?

Contingency procedures apply. Where the provider–AADE link is lost, documents may still be issued, but the provider must transmit them to myDATA and to the recipients within the prescribed emergency deadline — in the relevant scenario, no later than one day from the date of issue. The stakes are high for the provider: failure to transmit, leaving documents without a MARK, carries a fine of €10,000 to €50,000 per tax audit.

Is there a B2C e-invoicing mandate?

No separate structured B2C mandate comparable to B2B exists. Retail is not among the mandated transactions under A.1128 and sits instead within Greek fiscalisation and myDATA. Decision A.1112/2025 governs retail documents issued through a YPAHES provider rather than a fiscal electronic mechanism: they must carry the prescribed marking, uniqueness and authenticity controls, the time of issue, the MARK and QR-related data, with a tax summary transmitted to AADE. The receipt may be sent electronically or printed.

Summary

Greece is live and enforced for large businesses. Wave one started on 2 March 2026 and the transition closed on 3 May; wave two follows on 1 October 2026 with its own transition to the end of the year. Issuance must go through a licensed YPAHES provider or a free AADE application, and the document is registered in myDATA with a MARK.

The two circuits are the thing to get right. B2G is Peppol with a Greek CIUS and a myDATA gate in front of it; domestic B2B is a national licensed-provider regime where Peppol certification carries no weight. A European provider can serve the first directly and the second only through a Greek establishment or a Greek partner.

The detail that most often goes unnoticed: an invoice from Greece to a non-EU customer is inside the mandate, while the same invoice to another EU member state is outside it. Scope your transactions by destination before anything else.

Resources

GSIS — E-Invoice Support Tools Enter BT-10, BT-11, BT-12 and BT-46 and get back the exact XML segments to embed — for invoices and credit notes GSIS — Track and Trace Invoices Check the status of a submitted B2G invoice using its invoice number (BT-1) Required fields in the Greek B2G e-invoice Where to fill in each mandatory and optional field inside Invoice-Portal AADE — announcement of the wave-one postponement The official release with the new dates, the two permitted channels and the applicable penalties OpenPeppol — Greece country profile The three routes open to a foreign provider, and the Greek national requirements

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