Security Alert
A new National Customs Code was published on 28 July, while pending transposition of EU VAT Directives has been completed and mandatory B2B e-invoicing has been introduced.
At a glance
Law 5222/2025 has introduced the new National Customs Code - a structured effort to modernise and consolidate customs legislation, replacing the current Customs Code (Law 2960/2001) with a more coherent and administratively aligned framework.
The new National Customs Code aims to clarify definitions and customs procedures for different categories of goods, strengthens digital reporting, and aligns closely with EU Regulations (notably the Union Customs Code). Below is a summary of what’s changing and how it may affect your business.
At the same time, the new law has transposed into Greek VAT law Council Directives (EU) 2022/542 and 2020/285 and has introduced the much-anticipated mandatory B2B e-invoicing.
A. What’s new in the National Customs Code
Law 5222/2025 introduces a restructured and unified legal framework, replacing a system that has evolved since 2001. Key customs and excise reforms include:
Customs procedures: Entry, storage, and controls
The new Code (Articles 15–21) provides for digital filings of declarations, mandatory arrival notifications, and the use of electronic systems for all modes of transport, detailing more comprehensively electronic declarations and imposing narrower timelines.
The new Code intensifies digital control and data exchange among customs authorities, clarifies digital surveillance systems and imposes more rigorous checks, while explicitly empowers customs officers to use advanced surveillance devices, install integrated monitoring systems, and share data with other agencies.
Special procedures and free zones
Specific references in the new Code (Articles 34–35) confirm or update free zone regulations: establishing, operating, and abolishing free zones, with tight oversight and digital recordkeeping, mandating closer alignment with EU customs legislation and more detailed monitoring.
Expanded supervision powers
Customs controls are extended beyond customs offices, including outside official hours under special fees.
Revised excise rules
The Code reorganises excise tax provisions (for alcohol, tobacco, energy products), introduces rules for new categories (e.g. flavoured liquids for e-cigarettes), and streamlines movement, exemption, and refund procedures under EU harmonised standards.
Vehicle taxation
The new Code’s vehicle taxation rules refine the CO₂-based adjustments, implement WLTP measurement standards for newer vehicles, and introduce digital checks for cross-border transport. Stricter licensing and monitoring of approved vehicle warehouse keepers are introduced in the new Code.
Notifications and legal protection
The new Code introduces modernised processes for serving official notices and assessments, including digital notification methods, while explicitly safeguards the right to be heard before any administrative action or measure is taken against an individual’s rights or interests.
The new Code further clarifies when personal liability arises (for directors, managers) for unpaid customs duties and introduces a uniform rule establishing an automatic 70% suspension of collection of certain customs fines and multiple fees assessed by the competent authorities.
Strengthened enforcement & penalties
The new framework for customs infringements and smuggling is updated, including higher fines for customs infringements. Repeated offenses, misreporting, and operating outside authorised warehouse licenses can trigger severe financial penalties or license revocations.
Smuggling definitions largely remain the same but relevant audits will be performed via electronic means, expanded licensing oversight, and real-time data sharing.
B. VAT Code changes
Alongside the customs reform, the new law introduces targeted amendments to the VAT Code (Law 5144/2024):
Place of supply of services
New rules are introduced for B2B virtual events, where the place of supply will be where the service recipient is established.
Likewise for B2C activities which are streamed or otherwise made virtually available, the place of supply will be the place where the non-taxable recipient is established or resides.
Special scheme for small enterprises
The domestic annual turnover for the application of the scheme has remained the same at EUR 10,000, despite anticipation of the market that it would be increased.
The scheme has been extended to apply to taxable persons established in other EU Member States, whose EU annual turnover does not exceed EUR 100,000 and their annual turnover in Greece does not exceed EUR 10,000.
The new law further regulates the application of the regime by other EU Member States to taxable persons established in Greece.
New VAT rate for works of art, collectors’ items and antiques
The import of works of art, collectors’ items and antiques as well as the supply of works of art by the artist himself or his successors for the first time will be subject to the super reduced VAT rate of 6% (from 13% that was applicable until now).
The reduced rate will not be applicable for supplies of works of art subject to the special margin scheme, whereas the taxable reseller cannot opt to apply the margin scheme when the works of art, collector’s items and antiques have been supplied to him or imported by him with a reduced VAT rate.
C. Mandatory B2B e-invoicing
The new law has introduced mandatory B2B e-invoicing for all domestic supplies of goods and services, as well as supplies of goods and services to entities established outside the EU (although in the latter case it is allowed for the recipient to indicate an alternative way for the invoices to be sent). To be noted that B2G invoicing is already mandatory.
The details and the timeline for the implementation of the mandatory e-invoicing will be determined with decisions issued by the Ministry of Finance and the Independent Authority for Public Revenue.
Next steps for businesses
Entities engaged in import/export, excise trade, customs representation, or e-commerce should now:
Review compliance procedures in light of the new digital and regulatory framework
Monitor updates on customs clearance and post-clearance audits
Ensure staff and IT systems are prepared for digital transition
Our VAT and customs/excise duties team is available to support you with tailored advice, compliance audits, and strategic transition plans.