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Greece

Executive summary

E-invoicing has been traditionally utilized by large companies only exchanging proprietary invoice formats or EDIFACT invoices. Additionally, electronic document interchange between companies in general is taking place in Greece. These documents may be any that are needed for the business cycle. However, these electronic messages are mainly used for information purpose, or to eliminate data entry at the reception point and are not of legal value.

The adaptation on November 20, 2003 (Law 3193/2003) of the European Directive 2001/115CE dated December 20, 2001 to Greek law allows fiscal dematerialization of invoices and enables the total removal of paper from the entire invoicing chain.

However, in order to issue a computer- or cash register-produced invoice in Greece there has to be present a “special secure fiscal device for the signing of data” manufactured by various companies and approved by the Ministry of Finances (MoF). For each invoice issued, this device intercepts the data sent to the printer, calculates a hash value, prints this hash value on the invoice and stores it in an internal memory module. These memory modules have to be presented to an eventual tax inspection. Exempt from this type of invoice issuance are only some professionals, issuing handwritten invoices (e.g. doctors) or others issuing handwritten invoices on specially perforated by MoF paper.

MoF imposes that this hash function be also present on electronic invoices. If this prerequisite is met there is no problem with the exchange of invoices following the directive 2001/115CE.

New information
According to the new law 3842-23/4/2010 entitled “Restoring fiscal justice, combating fraud and other provisions“, there are a number of changes made to the invoicing system in Greece. The changes are described in article 20 and foresee:

1. All invoices issued have to be transmitted electronically to a database of the General Secretariat of Information Systems of the Ministry of Finance. The Minister of Finance will decide on the time and the gradual process of implementing the above provision on the basis of transaction value or turnover and technical requirements for transmission of data.

2. Invoices or other documents issued for invoicing purposes of a total value exceeding three thousand Euro (3,000), have to be paid through a commercial bank account transaction between the issuer and the recipient or by checks drawn to the above accounts. These transactions have to be transmitted to an electronic database of the General Secretariat of Information Systems of the Ministry of Finance, with no application of the banking secrecy principle. Banks may not charge fees for the operation of commercial accounts.

3. Invoices or receipts totaling one thousand five hundred Euro (1,500) and above, issued for sale of goods or services to individuals, are paid by the customers-buyers through banks, by debit or credit card, checks or bank account transactions. It is not permitted to pay for those transactions in cash. Banks may not charge fees to deposit those funds in bank accounts.

4. The burden of proof of the transaction lies also on the recipient of the invoice as defined in paragraph 9 of Article 18 of the Code of Book-Keeping (Pres. Decree 186/1992), who shall, aside from the provisions of this article, confirm from an electronic database of the General Secretariat of Information Systems of the Ministry of Finance the accuracy of data and the fiscal consistency of his counterpart for transactions exceeding three thousand Euro (3,000).

5. The Minister of Finance will determine the timing of the sending of the data referred to in paragraph 1 hereof, the method, the process, the scope, the threshold value of the items and the way of confirmation or any other matter relating to the implementation of paragraphs 1, 2, 3 and 4 of this Article and Article 18 paragraph 2 of the Code of Book-Keeping.

Please keep in mind that this law does not make electronic invoicing mandatory - it just makes the submission of data for invoices over 3.000 Euro to the MoF mandatory. Its main goal is to eliminate fake invoicing by routing all payments through the banking system and making cash payment illegal for amounts exceeding 1.500 or 3.000 Euro respectively. The GSIS of MoF will be developing certain APIs, that will allow companies and banks to submit the data to their database.

Currently the GSIS of MoF together with the Athens University of Economics and Business are conducting a research on electronic invoicing targeting on the possibility and the perspectives of implementing e-invoicing. The relevant questionnaire is available at: http://e-invoicing.eltrun.aueb.gr

Legal aspects

The adaptation on November 20, 2003 (Law 3193/2003) of the European Directive 2001/115CE dated December 20, 2001 to Greek law allows fiscal dematerialization of invoices and enables the total removal of paper from the entire invoicing chain.

Important links
General information

Companies offering e-invoicing services

This page was last modified on: 28 April 2010