On March 14th, 2025, a significant amendment to the existing framework for digital monitoring of goods movements — now referred to as stock movements — was published in the Greek Government Gazette (Β’ 1264). Officially cited as No. A 1047/2025, this amendment modifies the decision A.1123/15.07.2024 of the Governor of the Independent Authority for Public Revenue (AADE).
Below, we break down the essential points of this newly enacted decision, focusing on key changes, practical implications, and the broader context for businesses and professionals who need to ensure compliance with the myDATA (AADE) platform.
1. Key Amendments
1.1 Terminology Update: From “Goods” to “Stocks”
One of the most visible modifications is the replacement of the term “goods” with “stocks.” In every reference within the earlier decision A.1123/15.07.2024, the word “goods” is now replaced by “stocks.” This change seeks to clarify the precise scope of the monitored items, emphasizing that these rules apply more comprehensively to various forms of inventory.
1.2 Document Types for Digital Monitoring
- New clarifications were made concerning Document Types used to transmit data to the myDATA platform.
- The amendments specify that the Types of Invoices (A1 category) and Consignment Notes (A1 category, no value) are adapted to the new term stocks.
- Certain document categories were renamed or re-articulated to ensure they accurately capture transactions such as retail sales, sales on behalf of third parties, intra-Community transactions, and third-country transactions.
1.2.1 Sale, Return, and Surplus/Deficit Documentation
- Quantitative Receipt Notes (10.1 or 10.2) come into play when stock is received from non-obligated entities or when there is a refusal to issue a movement document by an obligated person.
- These notes also apply when surpluses or deficits appear after qualitative and quantitative control of stocks, ensuring consistent digital documentation.
1.3 Purpose of Movement & Correlation Rules
- The amendments list out all possible purposes of movement (e.g., sale, free disposal, sampling, returns, storage to third parties, etc.) and clarify which document types should be used for each.
- Notably, retail transactions requiring digital monitoring may now have a Retail Receipt issued separately if a Tax Electronic Mechanism (FIM) is used.
- Correlation between different document types (e.g., between Consignment Notes and Quantitative Receipt Notes) can now be done chronologically, even if the documents are issued at different times, allowing more flexibility in the system.
1.4 Simplification & Phased Implementation
- A major goal of this amendment is to simplify procedures for businesses by offering clearer guidelines on reporting and digitizing stock movements.
- The new Annex I, labeled “Visualization of Phases of Implementation of Digital Stock Movement Monitoring,” shows how digital monitoring will be split into two phases. These phases are designed to gradually bring businesses onboard without disrupting daily operations.
1.5 Handling Loss of Interconnection
- In the event of a loss of internet connectivity, the updated decision clarifies that digital stock movement documents must still be issued on time (with a distinct note about the connectivity loss). These documents should be transmitted as soon as the connection is restored, ensuring that no interruption in compliance occurs.
2. Operational and Practical Considerations
2.1 Streamlining the First Period of Application
- Article 8 of the amending act highlights the need to simplify procedures especially during the first period of application. This shows the legislators’ awareness of potential challenges businesses face while transitioning to fully digital systems.
2.2 Role of the myDATA Platform
- The myDATA platform remains at the core of digital transmission and centralized documentation in Greece. Each transaction type (e.g., invoice, credit note, consignment note) must be accurately categorized and posted to myDATA, ensuring transparency and ease of auditing.
2.3 Penalties and Compliance
- While the amendments do not introduce new penalties, they underscore that stock movement documents are integral to tax compliance. Entities must ensure they align their internal systems with these updated requirements to avoid discrepancies or future penalties.
The No. A 1047/2025 amendments published on March 15th, 2025, represent a thoughtful evolution of the digital monitoring system for stock movements in Greece. By refining terminology, defining clearer document types, and outlining a phased approach, AADE aims to facilitate smoother compliance for businesses of all sizes.
If you’re an entity dealing with any form of stock movement, now is the time to revisit and update your processes — from how you categorize your transactions to how you issue and transmit digital documents. These changes not only streamline administration but also ensure you remain fully compliant with the latest legal and technological standards set by AADE.
Disclaimer: This blog post is for informational purposes only and is based on the amendments cited in Government Gazette Β’ 1264/14-03-2025. It is not a substitute for professional legal or tax advice.
