Extension to Phase 2 of the Digital Dispatch Form

By joint decision of the Deputy Minister of National Economy & Finance and the Governor of the Independent Authority for Public Revenue (AADE), the implementation date of Phase B of the digital monitoring system for goods movement is postponed for all businesses.

Phase B will now be implemented gradually, allowing businesses additional time for technical and organizational adaptation.

Specifically:

• From 12/10/2026 the processes of loading, transshipment, and receipt are activated, as well as the transmission of quantitativeand qualitative inspection data..
• From 1/1/2027 the Unified Item Coding System comes into effect,in accordance with the Combined Nomenclature (TARIC).
• Until each respective obligation becomes mandatory, the transmission of relevant data to the myDATA platform remains optional.
• The Phase A obligation,i.e. the digital issuance of transport documents and the transmission of related data, remains in force as of 1/12/2025.

The extension does not eliminate the need for preparation. Businesses are encouraged to use the transitional period to review their ERP/accounting systems, warehouse procedures, receipt and dispatch workflows, as well as their ability to scan and verify documents.

Special attention is required for businesses with frequent inventory movements, multiple storage locations, transshipments, or high volumes of receipts, as Phase B now affects the entire goods movement lifecycle and not only the issuance of transport documents.

 Phase B of the Digital Delivery Note: Overview

Phase B of the digital goods movement monitoring system for all obligated entities is no longer limited to the issuance and submission of the digital transport document. It now extends to the entire lifecycle of goods movement, from dispatch initiation to final receipt.

Within this framework, new obligations are introduced for declaring transshipments, confirming receipt by the recipient, recording received quantities, and reporting discrepancies such as shortages, surpluses, item variations, or damages.

The role of the recipient becomes particularly important, as they are required to confirm receipt by scanning the QR code of the transport document, accept or reject the shipment, and where necessary, transmit relevant documents or data within the prescribed deadlines.

Phase B fundamentally changes business operations, as it requires systematic monitoring, control, and documentation of every critical stage of inventory movement.

   Analytical Note

 Digital Delivery Note & Phase B Implementation

This note is based on the current regulatory framework governing the digital monitoring of goods movement, as defined by Decision A.1123/2024, as amended by A.1047/2025, and relevant clarifications under E.2030/2025.

 A. General Framework

1. Distinct Roles in Goods Movement

Within the digital goods movement process, distinct roles are defined which do not necessarily coincide with ownership of the goods.

Sender (Dispatcher): The entity issuing the digital transport document and initiating the movement. This may be the seller, the owner of the goods, or a warehouse operator acting on behalf of a third party.

Third-party Sender: An entity that is not the owner of the goods but issues the Delivery Note for the movement, such as a warehouse operator or logistics provider.

Carrier: The entity responsible for the physical transportation of goods. It does not issue transport documents but is declared as a role in the digital Delivery Note.

Recipient: The entity at which the movement is completed. This may be the buyer, a third party acting on behalf of the buyer, or a warehouse operator.

Third-party Recipient: Applies when goods are delivered to an entity different from the final owner.

2. Issued Documents

• Issuance of Delivery Note

The issuer is the business from whose premises the movement starts, regardless of ownership of the goods.

The recipient is the business at whose premises the movement is completed and goods are received.

Where applicable, additional VAT numbers involved:

1. Carrier (when third-party transport is used)
2. Third-party sender (triangular transactions or third-party dispatches)
3. Third-party recipient (triangular transactions)

Goods in Transit

During transport, the digital document must be available and presentable (via QR code in digital form) for inspection by competent authorities.

• Issuance of Quantity Receipt Note

The issuer The issuer is the business where the goods are physically received.

The recipient The recipient is the business from whose premises the goods were originally dispatched.

Receipt at Recipient’s Facility

The Quantity Receipt Note is issued upon arrival of goods at the recipient’s premises to document receipt in cases where no digital transport document has been issued or transmitted by the sender.

• Reverse Movement – Delivery Note Issuance

The issuer The issuer is the receiving business, which initiates movement from the sender’s premises or a third-party sender’s premises, using its own transport means or third-party carriers.

 The recipient The recipient is the sender or third-party sender from whose premises the movement originates.

Where applicable, additional VAT numbers involved:

1. Carrier (when third-party transport is used)
2. Third-party sender (triangular transactions or third-party dispatches)
3. Third-party recipient (triangular transactions)

Goods in Transit

During transport, the digital document must be available and presented in digital form (via QR code) to enable inspection by authorities.

1. Phase B

During Phase B, the obligation is no longer limited solely to the issuance of the document, but extends to the entire movement cycle, making the transmission of Phase B data mandatory for all liable entities(A. 1145/2025).

The recipientassumes an active role, as they are required to confirm receipt, declare any discrepancies, and accept or reject the movement of goods.

Furthermore, the declaration of transshipments,namely any change of transport vehicle or carrier, becomes mandatory in order to ensure the complete recording of the transportation route.

The simple movement of inventory, as established under Phase B of digital monitoring, follows a specific operational workflow which ensures full traceability from the beginning to the completion of the transportation process.

More specifically, the digital movement document is initially issued and transmitted to the myDATA platform in accordance with the applicable legislative framework.

Subsequently, during the loading of inventory and prior to the commencement of transportation, final confirmation of the transport vehicle and the departure time is carried out through scanning the QR Code of the relevant movement document.

Finally, upon completion of the transportation process, the recipient scans the QR Code of the document, confirming receipt of the inventory and contributing to the completion of the movement cycle within the framework of digital monitoring.

In cases involving complex inventory transportation,where changes of transport vehicle or carrier occur, the transportation process includes additional stages that record the overall route of the inventory and ensure complete traceability.

Specifically, the digital movement document is initially issued and transmitted to the myDATA platform in accordance with the applicable legislative framework.

During the loading process and prior to the commencement of transportation, final confirmation of the first transport vehicle and the departure time is completed through scanning the QR Code of the relevant movement document.

During transportation, every change of transport vehicle requires the implementation of the transshipment procedure. At each transshipment stage, the details of the new transport vehicle receiving the inventory, as well as the start time of the transshipment, are transmitted to the Independent Authority for Public Revenue (AADE) through scanning the QR Code of the document, thereby accurately recording the continuity of the route.

The procedure is completed when the recipient scans the QR Code of the document upon receipt of the inventory, confirming the completion of the transportation process .

Furthermore, in cases involving the sale of inventory stored with a warehouse operator or third-party logistics provider (3PL), and transported on behalf of the seller to the customer, Circular E.2030/2025 provides for an alternative transportation procedure instead of the direct issuance of a Delivery Note by the 3PL provider.

More specifically, the following procedure may be applied::

Initially, the warehouse operator (3PL) issues a digital delivery note with the depositor (seller) as the recipient and delivers the inventory to a designated point within its facilities (e.g. loading ramp or gate), which is declared as an off-premises transportation completion point.

Subsequently, for the shipment to the final customer, a new transportation document is issued either by the seller or by the buyer, depending on who undertakes the transportation.

In particular, where transportation is undertaken by the seller (using either own or third-party means), a digital delivery note is issued by the seller to the buyer, with an off-premises point of departure.

Alternatively, where transportation is undertaken by the buyer, a digital transportation document is issued by the buyer, with the seller listed as the counterparty.

Phase B also introduces the obligation to declare transshipments (including date, time, and quantities), as well as the recording of the receipt process by the recipient, including the quantities received, any discrepancies, and the acceptance or rejection of the transportation. In this way, full and continuous monitoring of inventory movement is achieved from dispatch to final receipt.

Purchase Procedure – Role of the Recipient

During Phase B, the obligation is not limited to the issuance of the document by the sender, but extends to the entire transportation cycle.The buyer actively participates, being required to monitor, verify, and accept the transportation of inventory.

First of all, it should be noted that the sender remains responsible for issuing the digital transportation document. However, the buyer assumes a crucial role upon completion of the transportation process.

Upon receipt of the inventory, the buyer receives the digital Delivery Note through the system (myDATA or ERP), bearing a unique identification number (UID). The buyer is then required to verify the transported goods, quantities, and receipt time.

At the time of receipt, the buyer must record the actual quantities received, as well as the date and time of receipt. This information constitutes mandatory data during Phase B and is directly linked to the completion of the transportation process.

In the event of discrepancies (shortages, surpluses, differences in goods, or damages), these must be declared within the system. The discrepancies are recorded and transmitted in accordance with the applicable framework.

Following verification, the buyer is required to either accept or reject the transportation, thereby completing the traceability cycle.

In cases of domestic purchases within Greece,the buyer does not issue any document but is obliged to digitally receive the Delivery Note and complete the receipt and acceptance process.

If the seller does not issue a transportation document or is not obligated to issue one, the buyer may document the movement either by issuing a Goods Receipt Note or by issuing a 9.3 Delivery Note marked as “Reverse Movement”, indicating the reason for issuance of the reverse movement document (1 – Non-obligated issuer or 2 – Refusal to issue / accidental non-issuance). This document must be transmitted to the myDATA platform within the deadlines provided by the applicable framework and serves as the basis for recording the receipt, verifying quantities, and subsequently accepting or reporting discrepancies.

In cases of intra-community acquisitions (purchases from the European Union), the foreign supplier does not issue a digital document through myDATA. In this case, if no digital transportation document exists, the buyer is obliged to document the movement by issuing a 9.3 Delivery Note marked as “Reverse Movement”, indicating reason code 3 – Intra-community Acquisition. This document must be transmitted to the myDATA platform within the deadlines provided by the applicable framework (i.e. within five (5) days from the relevant shipping documents / receipt, as applicable). Subsequently, the process of recording, verification, and reporting shortages or surpluses, if any, is applied.

In cases of imports from third countries, transportation up to customs is covered by customs and international shipping documents. For transportation from customs to the buyer’s premises, the following apply:

In cases where customs clearance is carried out by a customs broker on behalf of the importer, and the delivery location is not specified in the international shipping documents (e.g. CMR, bill of lading), there is an obligation to issue a 9.3 Digital Delivery Note marked as “Reverse Movement”, indicating reason code 4 – Third Country Acquisition, and transmit it to myDATA. Subsequently, the process of recording, verification, and reporting shortages or surpluses, if any, is applied. Alternatively, a digital delivery note may be issued by the customs broker, stating at minimum the type of inventory items and the type and quantity of packaging.

In conclusion, during Phase B:

• The sender issues the document and declares the route (including transshipments).).
• The buyer confirms receipt, reports discrepancies, and accepts or rejects the delivery.
• In cases where no transportation document exists, the buyer issues a Goods Receipt Note or a Digital Delivery Note marked as “Reverse Movement”.
• Any shortages or surpluses, where applicable, are recorded and transmitted according to the applicable framework..

Transmission Deadlines

Regarding transmission deadlines for surpluses/shortages, intra-community acquisitions, and transactions with third countries, the following apply according to Decision 1122/2024 (Article 3):

1. Surpluses – Shortages (paragraph 3)

The recipient of inventory items for which discrepancies (surpluses or shortages) are identified must transmitzero-value transportation documents (goods receipt notes) to the myDATA platform within fifteen (15) days from the date of receipt.

2. Domestic Receipts (paragraph 4)

In the case of receipt of inventory from a domestic issuer, the recipient transmits the acceptance of the receipt through scanning the QR code of the transportation document in real time upon completion of the receipt process.

3. Receipts from Foreign Suppliers (Intra-community Acquisitions & Third Countries) (paragraph 5)

The recipient of inventory from foreign suppliers transmits zero-value transportation documents (goods receipt notes) platform within five (5) days from the date of receipt.
The supporting document of the foreign sender (e.g. invoice, international shipping documents, etc.) may be used as the transportation document.

4. Transshipments (paragraph 6)

Entities receiving inventory within the framework of transshipments and acting as associated VAT numbers for each movement transmit the relevant data through QR code scanning in real time upon completion of the transshipment process..