Mandatory Electronic Invoicing & Digital Goods Movement Documents - Frequently asked questions - answers

In accordance with Decision A.1122/2024, all businesses that keep books in accordance with the provisions of the Greek Accounting Standards (GAS) are required to issue inventory movement documents digitally and to transmit the relevant data to the myDATA digital platform of the Independent Authority for Public Revenue (IAPR). The obligation to issue digital inventory movement documents covers both domestic and international movements.

Article 2 of Decision A.1122/2024 sets out the relevant exemptions from the issuance of the digital movement document. More specifically, the following are exempted:

1. the movement of inventory by the natural persons referred to in paragraph 1 of Article 39 of the GAS, which include farmers under the special VAT regime. In this case, the movement document is issued by the recipient (the obliged business),
2. the movement of inventory that is supplied through a continuous-flow network, i.e. for movements of natural gas, water, town gas, electricity and thermal energy,
3. the movement by technicians of the tools and machinery necessary for the performance and completion of their work,
4. the movement carried out by funeral homes and related to the business activity of those homes, using their specially adapted vehicles,
5. the movement in the event of relocation of the business's premises.
6. the movement of fixed assets (provided that they are not moved for the purpose of their sale) which are intended to be used on a permanent basis for achieving the business objectives of the business (production of goods, provision of services, etc.). As clarified by Circular E.2030/2025, it is inferred, by way of contradistinction, that where fixed assets are moved for purposes other than the aforementioned — such as, for example, for loan for use, lease or free-of-charge disposal, as well as for return upon completion of the purpose for which they had been moved to the other business — there is an obligation to issue a digital movement document both for the business holding them in the case of dispatch and for the business using them in the case of return. Furthermore, the movement of spare parts for fixed assets between the business's premises is also exempted, provided that they do not constitute an item of trade for it and are intended exclusively either for the repair of faults in its premises or for the maintenance and repair of its network (such as a water supply and sewerage network, an electricity distribution network, or a motorway network),
7. the movement of inventory within the same premises of the business or between its business premises that are up to ten (10) kilometres apart,
8. the movement of
   1. quarry products in their natural state (sand, gravel, etc.) by construction entities, which are produced by those same entities for the projects carried out by them,
   2. ore and industrial minerals, from worksite to worksite and from worksite to storage, processing and unloading areas, as the case may be, carried out by mining and extractive entities, and
   3. stone, gravel, clay-rock and clay-soil, by entities producing aggregates, lime, cement, ceramic bricks and roof tiles, from the collection or extraction sites to the processing sites,
9. (θ) the distribution of university textbooks to students that is monitored electronically by the “Eudoxus” information system, as well as the distribution of free school textbooks to public primary and secondary education schools by the Computer Technology Institute and Press “Diophantus” (ITYE),
10. (ι) retail transactions where they are accompanied by a value document, with the exception of movements through a postal or courier service company in which the value document is not placed at a visible and directly accessible point on the transported item or cannot be shown immediately by the carrier, as well as movements of energy products (fuels), in accordance with the provisions of Decision A.1060/2021 (Government Gazette B' 1217) of the Deputy Minister of Finance and Governor of the IAPR, which are included within the scope of the present decision,
11. the movement of newspapers and periodicals to postal-services companies or directly to subscribers by the businesses issuing or distributing these items, as well as the movement of newspapers and periodicals from and to sub-agents (newsagents), to and from the points of sale, respectively.
12. the movement of industrial and small-scale manufacturing items by retailers who sell their goods exclusively at street markets, at other organised open-air markets (such as trade fairs and religious festivals) and in itinerant trade (open-air trade — mobile shops), provided that the data of the purchase documents for their inventory have been transmitted to the myDATA digital platform,
13. the movement of empty packaging items,
14. the movement for repeated wholesale sales of medicines, optical items and other items to the national healthcare organisation or to insurance funds, where the items sold are delivered to the insured persons.

Furthermore, Circulars E.2030/2025 and E.2016/2026 of the Governor of the IAPR have clarified the following:

1. in the event of the movement of materials (e.g. cleaning materials, or disinfestation and rodent-control materials, by entities operating building-cleaning crews) which are used for the provision of services (e.g. cleaning of buildings), there is no obligation to issue a digital delivery note, provided that the quantities required are not easily measurable, nor can they be determined in advance, and, in addition, the fee for the services provided is not linked to the quantity consumed, the value of which is of minor importance in relation to the fee received,
2. the movement of items prepared in dental laboratories by dental technicians during the stage of the necessary preparatory work and tests is treated similarly to the above,
3. for producer-farmers under the normal VAT regime (irrespective of whether or not they sell their produce at open-air trade venues), it is accepted that, where the movements of the agricultural products are carried out from/to the agricultural holding (fields, sheepfolds or farms, etc.) to/from the storage areas of the same producer, there is no obligation to issue a digital movement document, provided that the distance does not exceed ten (10) kilometres,
4. for inventory moved from the premises of courier companies (Sorting Centre – Hub), a digital movement document need not be issued, provided that the above businesses provide all the required detailed information through the internal electronic system they use for the real-time monitoring of the goods being moved, and this information is immediately available in the event of an audit.

In accordance with Decision A.1123/2024, the transmission channels that the obliged businesses may use for the transmission of the data of the digital inventory movement documents are the following: a) an Electronic Tax Document Issuance Provider. b) Business management software (commercial/accounting, ERP) used by the entities and interconnected with the IAPR through a relevant interface. c) The Application for the Issuance and Transmission of Tax Documents, “timologio” for access from desktop computers and “myDATAapp” for access from mobile devices.

In accordance with Article 5 of Decision A.1123/2024, in the event of loss of connection, the digital inventory movement documents are issued without the transaction being interrupted, with a distinct indication of the loss of connection, and are transmitted immediately upon restoration of the connection and no later than one day after their issuance. In the case of loss of connection for movements that require the issuance of a digital delivery note outside the business's premises, and especially at geographically remote points with limited network coverage, the business issues the movement documents manually. The data of those documents are transmitted to the myDATA digital platform without delay upon restoration of the transmission capability, under a separate numbering series and with an indication of loss of connection. Now, following the upgrade that took place at the beginning of June to the myDATAapp application, it is possible to issue a movement document without connection (offline). The data are transmitted automatically upon restoration of the connection.

In accordance with Article 57(13) of Law No 5104/2024, a business that moves goods without the required movement documents is subject to a penalty of €5,000 per tax audit, if it is required to keep a single-entry accounting system, and €10,000 per tax audit, if it is required to keep a double-entry accounting system.

Depending on the case:

1. For dispatch of inventory
   The transmission is carried out before the start of the transport.
2. For receipt of inventory
   The transmission takes place in real time, upon completion of the receipt.
3. In the event of discrepancies (excesses or shortages)
   The transmission takes place within 15 days of the date of receipt.
4. For receipt from abroad (intra-Community acquisitions or imports)
   The transmission takes place within 5 days of the date of receipt.

There are two types of documents that may be used in inventory movements:

Α. Document Types that include value and movement data, such as: 1.1 Sales Invoice_Inventory Movement 
1.2 Sales Invoice/Intra-Community Supplies_Inventory Movement 
1.3 Sales Invoice/Third-Country Supplies_Inventory Movement 
1.4 Sales Invoice/Sale on Behalf of Third Parties_Inventory Movement
3.1 Title of Acquisition (non-obliged Issuer)_Inventory Movement 
3.2 Title of Acquisition (refusal to issue by obliged Issuer)_Inventory Movement 
5.2 Credit Invoice_Inventory Movement 
11.1 Retail Sales Receipt_Inventory Movement 
1.4 Retail Credit Document_Inventory Movement 11.5 Retail Sales Receipt/Sale on Behalf of Third Parties_Inventory Movement.
 

Β. Document Types that include only movement data, without value, such as: 9.1 Correlated Delivery Note 
9.2 Consolidated Delivery Note 
9.3 Delivery Note
10.1 Correlated Quantity Receipt Note 
10.2 Quantity Receipt Note 
 

It is noted that the digital Delivery Note (Document Types 9.1, 9.2 and 9.3) is issued before the start of the movement and accompanies the inventory during its transport. The Quantity Receipt Note (Document Types 10.1 and 10.2) is issued after the completion of the movement, for the purpose of documenting the receipt, and does not constitute a document used for accompanying the inventory during its transport.