Greek businesses face expanded digital monitoring of their inventory and delivery records from 12 October 2026, when the second phase of the country's Digital Delivery Note system takes effect, according to tax consultant Stathis Kriaras.
Writing in Capital.gr, Kriaras, who specialises in the cost organisation of businesses, said the new phase would add tracking of loading, transshipment and receipt processes in the movement of stock, together with data from quantitative and qualitative inventory checks, to the existing requirement to issue and transmit delivery data to the myDATA digital platform.
He said the obligation would extend beyond industrial, commercial and mixed businesses that issue delivery notes daily to cover all companies, including those that provide only services. Even businesses that do not issue digital delivery notes will need the relevant software from the second phase onward, he said, for example when accepting a purchase of stock or of a fixed asset through the platform.
Warehouse ledgers and tax audits
Under Law 4308/2014, the Warehouse Ledger is an accounting record that businesses are not legally required to keep. Kriaras said the market had gone beyond the law regardless, so that no industrial, commercial or mixed business with even basic organisation now operates without one, for management and costing reasons. Once a business keeps such a ledger, though, it becomes subject to tax audit.
Citing decision POL 1067/2018, Kriaras said tax audits of warehouse ledgers focus on three checks: a quantitative count of stock to verify correct recording of goods in the business's own detailed inventory movement records, selectively for two types of goods among merchandise, finished products and raw materials; the existence of any credit balances in those detailed ledgers, limited to the final month of the tax year and one other month; and whether the quantity balances in those ledgers match the amounts recorded in the year-end inventory count, known as the Inventory Book.
He noted that the Council of State, Greece's highest administrative court, ruled in decisions 805/1998 and 1510/2013, and the tax authority's Dispute Resolution Directorate ruled in decision 873/2019, that where a business keeps a warehouse ledger and quantity shortfalls appear that cannot be explained by natural loss or destruction of goods, the tax authority may add the value of those shortfalls to the business's revenue without having to prove that its records are inaccurate.
Digital delivery notes since 2025
Kriaras said all businesses were gradually brought into the first phase of the system during 2025, covering the issuing and transmission of data to the myDATA platform, which abolished the paper delivery note for all businesses, aside from exceptions set out in decisions A.1122/2024, A.1046/2025 and E.2030/2025.
How the ledger shapes costing
Kriaras said transmissions to the digital platform affect the Warehouse Ledger on both the import and export side, and that accurate, timely updates to the ledger matter for tracking stock precisely. In commercial companies, he said, this supports correct valuation of inventory, calculation of the cost of goods sold and gross profit, and accurate stock counts by quantity and value.
In industrial businesses, he said, once all reasons for stock movements and production orders are recorded correctly, the ledger drives product costing, underpins technical specifications, feeds the Production and Costing Book, and supports accurate stock counts by quantity and value so results can be properly determined.
Using AI to compare production and sales
Kriaras said Greece's Independent Authority for Public Revenue, known as AADE, already holds sales data by quantity, value and product code for production businesses. If those businesses eventually also upload opening and closing stock by product code, he said, AADE would be able to calculate the quantity produced of each product, closing the gap left by the absence of data on raw material consumption and production. He set out the underlying formula: produced quantity equals sold quantity plus closing stock minus opening stock.
Because the quantity cycle would then have to balance for each product type, Kriaras said businesses would lose their last remaining room to manipulate results through their stock counts, production figures or any other variable. He said AADE, armed with technical specifications for at least the main raw materials and using artificial intelligence, would be able to identify businesses whose raw material consumption does not match their output at company level. He said he expected significant gaps between production and raw material consumption to be followed by targeted tax audits, exposing tax evasion within the production process.
For commercial businesses, Kriaras set out a parallel formula: sold quantities equal purchases plus closing stock minus opening stock. With this data, he said, a trading business would find it hard to manipulate any single variable in the equation, whether sales, stock counts or purchases, because the cycle would fail to balance and reveal the evasion.
Limits and a TARIC code criticism
Kriaras said the checks could currently be applied to businesses that sell by item type, namely wholesalers and retailers that use enterprise resource planning software to issue retail receipts. For the system to apply universally, he said, other businesses would also need to invoice by item type, which in his view would take a significant amount of time.
He was critical of a separate requirement now imposed by AADE from the second phase of the Digital Delivery Note, obliging businesses to record TARIC codes, the European Union's integrated tariff classification system for goods. Kriaras said this created an obligation for businesses with no benefit to either the businesses or AADE, since a single TARIC code can cover 100 or 200 different products, making it hard to see what audit check the code could support.
What comes next
Kriaras said that if the audit checks he described are introduced gradually, they should reduce the number of businesses manipulating their results, whether to survive or to lower their tax bills. He said the higher running costs created by digital transformation meant that, to stop mainly small businesses leaving the market, serious consideration should be given to mergers or acquisitions among similar businesses to build larger groups able to absorb higher management costs and benefit from economies of scale.
He added that in today's digital environment, combined with the heavy fines imposed for failures to meet these obligations, even medium-sized and large businesses will need serious organisation to adapt smoothly to the new operating framework, whether they work in production, trade or services.
