When will the digital delivery note become mandatory?
The implementation of the digital delivery note follows a phased approach managed by the Independent Authority for Public Revenue (AADE) to ensure businesses can integrate the new requirements into their logistics workflows. The rollout is structured around two major milestones to facilitate a smooth transition from manual to digital oversight.
On January 1, 2027, the first phase begins, activating digital processes for the loading, unloading, delivery, and receipt of goods, as well as quantitative verification. This initial stage focuses on the movement and physical verification of stock. The second phase, scheduled for January 1, 2028, introduces a unified product coding system based on Combined Nomenclature and the Integrated Tariff of the European Communities (TARIC). This ensures that all goods moved within the system are categorized under standardized international classifications.
The phased implementation timeline
The decision to stagger the implementation is intended to prevent operational shocks. By separating the logistical verification (2027) from the complex product classification (2028), AADE provides a window for companies to upgrade their software and training protocols. Businesses must prepare for a significant shift in how they record every touchpoint of a product's journey.
How does the new system change quantity verification?
The digital delivery note eliminates the practice of recording quantity discrepancies solely in internal company records. Under the new rules, if a shipment arrives with more or fewer items than stated on the original document, the recipient must issue and transmit a 'Quantitative Receipt Note' (Δελτίο Ποσοτικής Παραλαβής) through the myDATA platform.
This requirement ensures that the digital record matches the physical reality of the stock at every transfer point. However, there are specific exemptions to this rule to prevent administrative overload:
- Internal Transfers: No Quantitative Receipt Note is required for discrepancies found during the movement of goods between different facilities owned by the same legal entity.
- Weight Verification Challenges: In cases where weighing goods is objectively difficult—such as when a scale is unavailable—companies may use the label 'To Be Weighed' (Προς Ζύγιση). In these instances, an approximate quantity is recorded initially. Once the actual weighing occurs, the recipient issues a Quantitative Receipt Note marked 'Final Quantity' (Τελική Ποσότητα) to update myDATA with the precise figures.
What are the new obligations for carriers and intermediaries?
The new regulations clarify the responsibilities of third-party logistics providers and those managing intermediate storage. A central goal of the AADE digital monitoring system is to create a continuous chain of custody for all commercial goods.
For carriers acting on behalf of third parties, the regulation specifies that their status as a carrier does not automatically mandate the issuance of a separate delivery note, unless specifically required by their operational role. The focus remains on the primary documentation provided by the sender and the receipt confirmed by the recipient.
Managing intermediate facilities and transit times
A critical component of the new rules concerns goods moving through intermediate facilities. To maintain the continuity of the digital trail, a 24-hour time limit has been established from the start of movement to the completion of reloading. If this window is respected, the business is not required to issue a new document at the intermediate facility. However, if the 24-hour limit is exceeded, the facility or the entity managing it will be digitally recorded as a 'related carrier' through a QR code or other technical methods, ensuring the gap in the timeline is accounted for in the AADE database.
How are partial deliveries and unknown recipients handled?
The digital delivery note system is designed to be flexible enough to handle common logistical irregularities, such as incomplete shipments or anonymous deliveries. The AADE has introduced specific protocols to ensure these scenarios do not create 'blind spots' in the tax authority's monitoring.
When a shipment is not delivered in full, or if only a portion of the order reaches its destination, the movement must still be recorded digitally to reflect the actual volume of goods in transit. Furthermore, the 'Consolidated Delivery Note' (Συγκεντρωτικό Δελτίο Αποστολής) has been designated for specific circumstances. This tool is used when the recipient's details are unknown at the time of dispatch or when the exact quantity to be delivered can only be determined after the movement has already commenced.
What happens during technical failures or internet outages?
Recognizing that digital-only systems are vulnerable to infrastructure failures, the AADE has included contingency measures for connectivity issues. The regulation provides a legal pathway for businesses to continue operations during power outages or proven internet disruptions.
In such events, companies are permitted to issue handwritten documents or use other technical means to record the movement. However, the digital obligation is not waived; once connectivity is restored, the data must be transmitted to myDATA without delay. These entries must include a specific digital indicator noting the 'loss of connectivity' (απώλεια διασύνδεσης) to explain the discrepancy between the timestamp of the transaction and the timestamp of the digital upload.
Frequently asked questions
What is the main purpose of the digital delivery note?
The primary purpose is to implement a second phase of a digital monitoring and traceability system for the movement of goods. By requiring real-time digital reporting via myDATA, the AADE aims to improve the accuracy of stock tracking and enhance tax compliance across the supply chain.
Do I need to issue a new note for every internal transfer?
No, you are not required to issue a Quantitative Receipt Note for discrepancies discovered when moving goods between different facilities belonging to the same company. This exemption is intended to reduce the administrative burden on businesses managing their own internal logistics.
What should I do if I cannot weigh goods immediately?
If weighing is impossible due to lack of equipment, you should record the quantity as an approximation and use the 'To Be Weighed' label. Once the actual weight is confirmed, the recipient must issue a Quantitative Receipt Note marked 'Final Quantity' to update the official records.
How does the 24-hour rule work for intermediate facilities?
Goods moving through intermediate stops must complete reloading within 24 hours of starting their journey. If this limit is met, no new document is needed. If it is exceeded, the facility is automatically registered as a related carrier via QR code to maintain traceability.
Can I use paper documents if the internet is down?
Yes, if there is a proven inability to connect to the internet or a power outage, you can use handwritten documents. You must upload this data to myDATA as soon as connection is restored, marking the entries with a specific connectivity loss indicator.
Key takeaways
- The digital delivery note mandate begins on January 1, 2027, for logistical processes.
- Unified TARIC product coding requirements will follow on January 1, 2028.
- Quantity discrepancies must be reported via myDATA using a Quantitative Receipt Note.
- Intermediate facility reloading must be completed within a 24-hour window.
- Handwritten documents are permitted during documented internet or power outages.
The future of Greek logistics traceability
The transition to a mandatory digital delivery note represents a significant evolution in the Greek economic landscape. By moving away from internal, manual records toward a centralized, real-time digital ledger, the AADE is creating a more transparent environment for the movement of goods. While the initial phases require substantial adjustments in documentation and technical preparedness, the long-term goal of standardized coding and seamless traceability promises to modernize the national supply chain and align it with broader European digital standards.
