Greece Einvoice

Greece E-Invoicing Compliance Skill v1.0

Section 1 -- Quick Reference

Quick Reference

Field	Value
Country	Greece (Ελληνική Δημοκρατία)
Currency	EUR
E-invoicing system name	myDATA (My Digital Accounting and Tax Application)
Governing body	AADE (Ανεξάρτητη Αρχή Δημοσίων Εσόδων -- Independent Authority for Public Revenue)
Key legislation	Law 4308/2014 (Greek Accounting Standards); Decision A.1138/2020 (myDATA launch); Law 5073/2023 (penalties); Law 5222/2025 (penalty updates); Decision 1128/2025 (B2B/B2C/B2G e-invoicing via providers)
Implementation timeline	myDATA platform launched July 2020; mandatory data transmission phased from 2021; B2G Peppol adopted; B2B/B2C mandatory electronic book reporting; MARK validation in force
Current status (2026)	All businesses must transmit invoice summaries in real-time to myDATA; MARK (Unique Registration Number) required on all invoices; AADE cross-checks myDATA vs VAT returns; escalating penalty regime active
Skill version	1.0

Section 2 -- Mandate Scope

Who Must Comply

• Who must comply with myDATA transmission — All Greek businesses -- every entity with a Greek AFM (Tax Identification Number) that issues revenue or expense documents must transmit data to myDATA. This includes: Sole proprietors (ατομική επιχείρηση); Companies of all legal forms (ΑΕ, ΕΠΕ, ΟΕ, ΕΕ, ΙΚΕ); Freelancers and professionals; Farmers under the special or normal regime. B2G (Business-to-Government): Greece has adopted the Peppol four-corner model for B2G. Structured e-invoices (EN 16931) are transmitted via Peppol to public entities. Data also flows to myDATA. B2B (Business-to-Business): Suppliers must transmit invoice summary data to myDATA in real-time or near-real-time. The transmitted data receives a MARK from AADE, which must appear on the invoice delivered to the buyer. Invoices issued through a certified e-invoicing provider are automatically transmitted. B2C (Business-to-Consumer): Retail transactions reported via electronic tax registers (eTax Register Machines / EAFΔΣΣ) are transmitted to myDATA. For invoices (not receipts), same rules as B2B apply.

Transmission Methods (By Entity Type)

Transmission Methods (By Entity Type)

Method	Description	Who Uses It
Certified e-invoicing provider (Πάροχος Ηλεκτρονικής Τιμολόγησης)	Automatic real-time transmission; provider handles XML formatting and AADE communication	Businesses using certified providers
ERP integration via myDATA API	Business transmits directly via AADE REST API	Businesses with in-house or commercial ERP systems
Electronic tax registers (EAFΔΣΣ)	POS/cash register data transmitted automatically	Retail businesses
Special Data Entry Form (Ειδική Φόρμα Καταχώρησης)	Manual entry on myDATA web portal	Small businesses with few documents and no software

Exemptions

• Exemptions from myDATA compliance — There is no turnover threshold -- all taxable entities must comply. Small entities issuing very few documents can use the Special Data Entry Form instead of software integration.

Section 3 -- Technical Format

myDATA XML Schema

• myDATA XML schema description — myDATA uses a proprietary XML schema defined by AADE, not UBL or CII. The current schema version is governed by AADE technical specifications.

myDATA XML Schema Components

Schema Component	File
Invoice document	InvoicesDoc.xsd
Expense classification	expensesClassification.xsd
Income classification	incomeClassification.xsd
Response	response.xsd
Detailed invoice (for providers)	InvoicesDoc_detailed.xsd
Delivery notes	RegisterTransfer.xsd, GetDeliveryStatusResponse.xsd

• Current API versions — Current API versions: v1.0.12 (for ERP/provider) and v2.0.1 (with digital delivery notes).

B2G Format

• B2G e-invoicing format — For B2G transactions, Greece uses EN 16931 with Peppol BIS Billing 3.0 (UBL 2.1 XML), transmitted via the Peppol network. The data also flows into myDATA for electronic book purposes.

Key Data Elements (myDATA Schema)

Key Data Elements (myDATA Schema)

Element	Description
invoiceHeader	Invoice type, series, AA (sequential number), issue date, currency
issuer	Supplier AFM, country, branch
counterpart	Buyer AFM, country, branch (for B2B)
paymentMethods	Payment method type, amount, payment info
invoiceDetails	Line items: line number, net value, VAT category, VAT amount, classification codes
invoiceSummary	Total net value, total VAT amount, total withheld amount, total gross value
taxesTotals	Tax type, tax category, underlying value, tax amount
invoiceClassification	Income/expense classification type and category per line

Section 4 -- Mandatory Fields

Fields Required on Every Greek Invoice

Fields Required on Every Greek Invoice

Field	Description
Issuer AFM (ΑΦΜ)	Greek tax identification number
Issuer name and address	Full legal name, DOY (tax office)
Issuer DOY (ΔΟΥ)	Tax office of the issuer
Buyer AFM	Required for B2B; "retail" indicator for B2C
Invoice series and number	Unique sequential identifier
Invoice date	Date of issuance
Invoice type	myDATA type code (e.g., 1.1 = Sales Invoice, 2.1 = Service Invoice, 5.1 = Credit Invoice)
MARK (Μ.ΑΡ.Κ.)	Unique Registration Number from AADE -- mandatory on the issued document
QR code	Encodes the MARK verification URL; mandatory on printed/PDF invoices
Description of goods/services	Line-level detail
Quantity and unit	Per line item
Net value per line	Before VAT
VAT category and rate	Per line (code + percentage)
VAT amount per line
Income classification	Revenue type and category code per line
Total net value	Sum of line net values
Total VAT	Sum of line VAT amounts
Total gross value	Net + VAT
Payment method	Cash, bank transfer, card, cheque, etc.
Withholding tax	If applicable (type, rate, amount)
Stamp duty	If applicable
Fees/charges	If applicable

MARK (Μοναδικός Αριθμός Καταχώρησης)

• MARK definition and role — The MARK is the critical fiscal identifier. It is: Assigned by AADE upon successful data transmission to myDATA; A unique numeric registration number (long integer); Required on the invoice before delivery to the buyer; Used to generate the QR code verification URL. Without a valid MARK, the document is not fiscally recognized under Greek law.

QR Code

QR Code sources by channel

Channel	QR Code Source
E-invoicing provider	downloadingInvoiceUrl returned by the provider, supporting /pdf, /myDATA, /EN16931 endpoints
ERP (direct API)	qrCodeUrl returned by the SendInvoices API call

Section 5 -- Transmission Method

myDATA REST API

myDATA REST API details

Component	Detail
API type	RESTful web services
Authentication	AADE user credentials (AFM + API key) or e-invoicing provider credentials
Environment URLs	Production: mydata-api.aade.gr; Testing: mydata-dev.aade.gr
Key methods (ERP)	SendInvoices, SendExpensesClassification, SendIncomeClassification, RequestDocs, RequestTransmittedDocs, CancelInvoice
Key methods (Provider)	Same as ERP plus SendInvoices with provider signature block
Response	MARK (on success) or error codes (on failure)
Real-time requirement	Transmission should occur at or near the time of invoice issuance

Workflow (ERP Integration)

1. Issue invoice in ERP system
2. Map data to myDATA XML schema (InvoicesDoc.xsd)
3. Call SendInvoices API endpoint
4. Receive response: MARK + QR code URL (success) or error codes (failure)
5. Print/embed MARK and QR code on the invoice
6. Deliver invoice to buyer

Workflow (Certified E-Invoicing Provider)

1. Issue invoice through the provider's platform
2. Provider transmits data to AADE automatically
3. Provider receives MARK from AADE in real-time
4. Provider embeds MARK, QR code, and provider identification on the document
5. Document delivered to buyer electronically (with downloadingInvoiceUrl)

Connection Loss Handling

• Handling loss of connection to myDATA during invoice issuance — If the connection to myDATA is lost during invoice issuance, the transaction continues normally. The invoice is issued with a "loss of connection" indicator and transmitted with a slight delay. The MARK is obtained shortly after connectivity is restored.

Section 6 -- Validation Rules

AADE Validation (on SendInvoices)

• AADE validation checks on SendInvoices — XML schema validation against the current InvoicesDoc XSD version; AFM validation for issuer and counterpart; Invoice type code validity (must match allowed type codes); Classification code validity (income/expense codes must exist in the designation combinations); Tax category and rate consistency; Arithmetic validation (line totals, VAT calculations, summary totals); Duplicate detection (same series/AA from the same issuer).

Pre-Submission Checks

• Pre-submission validation checks — Validate XML locally against the current InvoicesDoc.xsd before API call; Verify AFM validity using AADE's public AFM verification service; Confirm income classification codes match the designation combinations spreadsheet (published by AADE); Ensure all line items have valid VAT category codes; Verify arithmetic: sum of line net values = total net value; sum of line VAT = total VAT.

Common Rejection Reasons

Common Rejection Reasons

Reason	Detail
Invalid AFM	Issuer or counterpart AFM fails check-digit validation or is inactive
Schema violation	XML does not conform to the current InvoicesDoc.xsd
Invalid invoice type	Type code not recognized or not applicable for the transaction
Classification error	Income or expense classification code invalid or mismatched with invoice type
Arithmetic mismatch	Line totals do not sum to invoice summary values
Duplicate submission	Same series/AA already has a MARK for this issuer
Invalid VAT rate	Rate does not match the declared VAT category

Section 7 -- Tax Computation Rules

Greek VAT Rates (2026)

Greek VAT Rates (2026) (Annex to Greek VAT Code (Law 2859/2000))

Rate	Mainland	Aegean Islands (reduced jurisdiction)
Standard	24%	17%
Reduced	13%	9%
Super-reduced	6%	4%

• Aegean island reduced rate scope — Aegean island reduced rates apply to specific islands listed in Annex to Greek VAT Code (Law 2859/2000). (Annex to Greek VAT Code (Law 2859/2000))

Rounding Rules

• VAT rounding rules — VAT amounts calculated per line, rounded to 2 decimal places (EUR cents). Summary totals are the sum of rounded line-level amounts. myDATA validates arithmetic consistency with a tolerance of ±0.01 per line.

Multi-Rate Invoice Handling

• Multi-rate invoice handling — Each VAT rate appears as a separate element in the taxesTotals section. Line items must each declare their own VAT category and rate. Mixed-rate invoices are fully supported.

Withholding Tax

• Withholding tax types — Greek invoices frequently include withholding tax (παρακράτηση φόρου). Withholding types include: Income tax withholding (e.g., 20% on professional services); Solidarity contribution (where applicable); Stamp duty (χαρτόσημο). These are declared in the taxesTotals element with specific tax type codes.

Income and Expense Classification

• Income classification requirement — Every invoice line must carry an income classification code. The designation combinations are published by AADE in a spreadsheet and map invoice types to allowed classification categories.

Common income classification categories

Code	Category
category1_1	Revenue from sale of goods
category1_2	Revenue from sale of products
category1_3	Revenue from provision of services
category1_5	Revenue from sale of goods/services on behalf of third parties
category1_7	Revenue from subsidies/grants

Section 8 -- Archiving Requirements

Archiving Requirements

Requirement	Detail
Retention period	5 years from the end of the fiscal year (general rule under Greek Accounting Standards, Law 4308/2014); extended to 6 years for VAT purposes; indefinite if litigation is pending
Format	Electronic format; myDATA data is maintained on AADE servers; businesses must retain their own records
MARK record	The MARK and associated QR code URL must be retained with the invoice
Accessibility	Must be available for tax audit within 48 hours of request
E-invoicing provider records	Providers must maintain all transmitted data and make it available to both issuer and AADE
Integrity	No modification to issued documents; corrections via credit notes or modification invoices
AADE platform	myDATA retains all transmitted data; businesses can query their electronic books via the API

Section 9 -- Penalties for Non-Compliance

myDATA Penalty Framework (Law 5073/2023, updated by Law 5222/2025)

myDATA Penalty Framework (Law 5073/2023, updated by Law 5222/2025)

Violation	Penalty
First violation (failure to transmit or late transmission)	50% of the VAT amount on the untransmitted documents, minimum EUR 250
Repeat violation	100% of the VAT amount
Failure to transmit data for an entire period	EUR 2,500 per month of non-compliance
Discrepancy between myDATA and VAT return	Triggers automatic audit; potential reassessment of VAT + 50% surcharge

AADE Cross-Checks

• AADE cross-check sources and audit trigger — AADE actively cross-references myDATA electronic books against: VAT returns (Φ2/periodic and annual); Income tax declarations; Third-party data (banks, card payments). Businesses with zero VAT declarations but active myDATA data face targeted audits. In 2025, AADE identified approximately 400 businesses with zero-turnover declarations despite active transaction data in myDATA.

Additional Consequences

• Additional consequences of non-compliance — Untransmitted invoices are not fiscally valid -- buyers cannot claim VAT deductions. AADE may impose precautionary tax assessments based on myDATA data alone. Persistent non-compliance triggers classification as high-risk taxpayer.

Section 10 -- Interaction with Tax Skills

myDATA → VAT Return (Φ2)

• myDATA feeds into VAT return preparation — myDATA electronic books are the primary source for VAT return preparation. AADE pre-fills VAT return data from myDATA. The taxpayer must reconcile any differences between their accounting records and the myDATA data before filing.

Expense Classification → Input VAT

• Expense classification and input VAT deductibility — Buyers must classify received invoices in myDATA as expenses with the appropriate classification codes. This classification determines: Deductibility of input VAT; Allocation to the correct income tax expense category; Reconciliation with the VAT return. Buyers who do not classify counterpart invoices within the deadline risk having AADE auto-classify them.

myDATA → Income Tax

• myDATA feeds into income tax return — Income data transmitted to myDATA feeds into the annual income tax return. AADE cross-references declared revenue against myDATA totals. Significant discrepancies trigger audit procedures.

B2G → Peppol → myDATA

• B2G transaction flow via Peppol to myDATA — For B2G transactions, the e-invoice travels via Peppol to the public entity. The invoice data is simultaneously transmitted to myDATA. The public entity's payment system references the myDATA MARK.

Electronic Tax Registers → myDATA

• POS transmission via electronic tax registers — POS transactions from electronic tax registers (EAFΔΣΣ) are transmitted to myDATA as retail income. This data feeds into both VAT returns and income tax declarations.

Disclaimer

This skill and its outputs are provided for informational and computational purposes only and do not constitute tax, legal, or financial advice. Open Accountants and its contributors accept no liability for any errors, omissions, or outcomes arising from the use of this skill. All outputs must be reviewed and signed off by a qualified professional (such as a CPA, tax attorney, or equivalent licensed practitioner in your jurisdiction) before filing or acting upon.

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