DAC8 Reporting in Greece: Practical Guide

Greece has been developing its approach to crypto-asset regulation and taxation as part of the broader modernisation of its tax administration. The Anexartiti Archi Dimosion Esodon (AADE), Greece's Independent Authority for Public Revenue, is expected to implement DAC8 reporting requirements. This guide provides practical information for crypto-asset service providers operating in Greece.

National Authority

The Anexartiti Archi Dimosion Esodon (AADE), the Independent Authority for Public Revenue, is the competent authority for tax administration in Greece, including international exchange of information. AADE already manages CRS and FATCA reporting obligations and is expected to oversee DAC8 compliance. The Ministry of Finance (Ypourgeio Oikonomikon) and the Ministry of National Economy (Ypourgeio Ethnikis Oikonomias) may also be involved in the legislative transposition.

Submission Requirements

Greece has been investing in the digitisation of its tax administration through the TAXISnet platform, and DAC8 submissions are expected to be handled electronically.

• Format: Reports should follow the OECD CARF XML schema as required by DAC8. AADE may publish supplementary technical specifications.
• Language: Official tax administration in Greece is conducted in Greek. The standardised XML data fields should follow international formats, but any accompanying documentation may need to be in Greek.
• Submission channel: AADE's TAXISnet platform is the primary electronic tax filing system in Greece. DAC8 reporting may be integrated into this platform or handled through a dedicated module. The exact submission method is to be confirmed by AADE.
• AFM number: Reporting entities will need a Greek tax identification number (AFM - Arithmos Forologikou Mitroou) for filings.

Transposition Status

Greece must transpose the DAC8 directive into national law by December 31, 2025. The transposition typically involves a law (nomos) passed by the Hellenic Parliament (Vouli ton Ellinon) or provisions included in omnibus legislation. Greece has had variable experiences with EU transposition timelines. Reporting entities should monitor the Efimeris tis Kyverniseos (Government Gazette) for the publication of implementing legislation.

Local Variations

Greece may introduce specific national elements:

• Evolving crypto tax treatment: Greece has been developing its approach to taxing crypto-asset gains. DAC8 data may help Greek authorities better enforce domestic tax obligations on crypto-asset transactions.
• Capital controls legacy: Although Greece has lifted most capital controls, the experience may influence the authority's approach to monitoring cross-border crypto-asset flows.
• Bank of Greece and HCMC coordination: The Bank of Greece and the Hellenic Capital Market Commission (HCMC/Epitropi Kefalaiagotas) may be involved in the regulatory framework for crypto-asset service providers under MiCA. DAC8 reporting obligations may be coordinated accordingly.
• Enhanced enforcement focus: Greek tax authorities have been strengthening enforcement capabilities. DAC8 data may be actively used for cross-referencing with domestic tax declarations.

Key Dates

• Transposition deadline: December 31, 2025 (directive must be incorporated into Greek law)
• Data collection begins: January 1, 2026 (reporting entities should start collecting relevant information)
• First reporting period: Calendar year 2026
• First reports due: 2027 (exact date to be confirmed by AADE)

Practical Tips

• Register on TAXISnet: Ensure your entity has active TAXISnet access and a valid AFM well before the reporting deadline.
• Monitor AADE circulars: AADE publishes circulars (egkyklioi) and decisions that provide operational guidance. Watch for DAC8-specific publications.
• Prepare Greek-language capabilities: Ensure your compliance team or local advisors can handle communications in Greek.
• Engage local tax advisors: Greek tax law can be complex. Consider engaging logistes-forotechnikoi (accountants-tax consultants) with experience in international reporting.
• Ensure AFM collection for reportable persons: Verify that your systems can accurately collect Greek AFM numbers for reportable individuals.
• Plan for potential implementation delays: Monitor the transposition timeline and have contingency plans if implementation is delayed.

Important Notice

This guide provides general information about DAC8 reporting in Greece. Requirements may change as the directive is transposed into national law. The information presented here should not be considered definitive legal or tax advice. Always consult AADE and the Ministry of Finance for the latest official requirements. For specific compliance questions, seek advice from qualified Greek tax professionals.