In August 2024, Greece launched the Electronic Delivery System, based on Law 4308/2014 (Greek GAAP). The Ministry of Finance and IAPR have provided details in Decisions A.1122/2024 and A.1123/2024, setting out the steps and requirements for compliance with the new e-delivery framework.
1. What is the scope of the regulation?
The regulation mandates the use of a digital consignment note system on the myDATA platform to monitor the movement of goods in real time, targeting transparency and tax compliance, with a phased implementation based on the size and sector of the business in question.
2. Who will be affected by this regulation?
The regulation applies to:
- Businesses with gross revenues over €200,000.
- Businesses in specific sectors (including energy, pharmaceuticals, building materials, and olive oil).
- All other businesses, starting in the second application period.
- Public entities, starting from January 1, 2026.
- Exemptions include small-scale farmers, certain natural persons, continuous flow networks, technicians’ tools, and funeral homes.
3. When will this regulation be effective?
Phase 1
- Until March 31, 2025, entities in the first group may transmit data voluntarily. Mandatory data transmission for entities with over €200,000 gross income or trading specific goods (e.g., pharmaceuticals, energy products) begins April 1, 2025. The initial phase will focus on basic shipping document functionality.
Phase 2 (applies to all businesses)
- From May 1, 2025, second-phase entities may begin voluntary transmission for the next stage.Voluntary transmission for second-phase entities is allowed until September 30, 2025, with full compliance for all entities is required by October 1, 2025.
4. What is the content of an e-delivery?
The required content for e-delivery documents is specified in Decision A.1123/2024, with distinct criteria for each of the two implementation phases.
In Phase One, essential details include the issuer’s and recipient’s information, the delivery document number, MARK and QR codes, the date of issue, the start of delivery, loading and delivery locations, and the type and quantity of goods.
In Phase Two, further information is required, such as transportation times, reloading details, EU Intrastat codes, and associated VAT numbers for the transportation and final recipients.
5. Is a digital signature required?
Yes, a digital signature is required to digitally sign the e-delivery documents. The approved electronic signature certificate must be issued by an approved certification service provider, which is included in the trusted list provided for in Decision 2009/767 / EC (EN as amended and in force) and following the provisions of Regulation (EU) 910/2014.
