New clarifications regarding the interconnection of the Electronic Funds Transfer at the point of sale (EFT/POS) terminals of the obliged entities with their cash systems and the information systems of AADE are provided by circular E.2044/ 2024 of the Governor of the Independent Public Revenue Authority, Giorgos Pitsilis.

For the further convenience of interested parties, 22 short Questions – Answers (Q&As) were created which are included in the appendix of the Circular and have been posted on the official website of AADE (www.aade.gr), in the POS Interface – Cash Systems option on the home page.

Here are the Questions – Answers for interfacing POS with Cash Registers:

1. Q: Which businesses have an obligation to interface their POS terminals with their Cash Systems?

A: An interconnection obligation exists for the conduct of retail transactions of businesses:

o that have an obligation to use Tax Electronic Mechanism (FEM) or make use of them,

o who have an obligation to use FIM but have chosen to carry out the specific transactions using the Services of an Electronic Data Issuance Provider.

2. Q: Does a business that conducts retail transactions always have the obligation to connect its POS terminals with its Cash System?

A: In the event that the company carries out transactions for which the use of a FIM is not mandatory according to the legislation (POL. 1002/2014) and does not use a FIM, it does not have the relevant interconnection obligation for the specific transactions.

On the contrary, in the event that for the retail transactions it carries out there is a FIM obligation, the company has an obligation to interconnect all the POS terminals it has with the FIM(s) it uses.

3. Q: Does a business that carries out exclusively wholesale transactions have an obligation to connect its POS terminals with its Cash System?

A: No, it does not have an interconnection requirement.

4. E: A business with mixed transactions (either wholesale and retail with an obligation to use a TIN or retail with an obligation to use a TIN and retail exempt from the use of a TIN based on POL. 1002/2014) has the obligation to interconnect all POS terminals it has with its Cash System, for all its transactions?

A: No, he has the obligation to connect the POS terminals he chooses, for the retail transactions for which he has an obligation to use FIM or for which he uses FIM despite not having an obligation.

It does not have the obligation to connect only the POS terminals through which the following are completed:

o wholesale transactions or

o transactions exempted from the use of FIM based on the POL. 1002/2014, as long as it does not use FIM to carry out these transactions.

It is pointed out that in the event that a company accepts payments at a non-interconnected POS terminal for transactions for which it has an obligation to interface, a fine of 10,000 or 20,000 Euros is imposed, depending on the accounting system used.

To comply with the relevant obligation n AADE proceeds with extensive cross-checks of the data kept in its information systems, as well as data of third parties, while, in any case, compliance is also checked in the context of proper bookkeeping and data issuance checks (preventive checks).

5. Q: A business with mixed transactions (either wholesale and retail with an obligation to use a POS or retail with an obligation to use a POS and retail subject to POL. 1002/2014) as long as it has a single POS terminal has the obligation to connect it to the Cashier of System?

A: Yes, in this case there is an obligation to interface the company’s POS terminal, given that the terminal in question also accepts payments for retail transactions with the obligation to use FIM.

6. Q: Business has more than one FIM and one or more POS terminals. Do all FEMs need to interface with the POS terminal(s)?

A: No, as there is an obligation to interface all POS terminals with one or more of the FIMs. FIMs that are not connected to any of the POS terminals can be used exclusively for cash transactions.

7. Q: Can a business connect more than one POS to a FIM?

A: Yes, it can connect more than one POS to a FIM. The usual technical specifications allow the possibility of connecting at least three (3) POS terminals to a FIM if of course the company so desires.

8. Q: How do standalone All in One devices work?

A: Standalone All in One devices include in the same device:

o Cash System software that interfaces with an Electronic Data Issuance Service Provider and

o POS transaction software that interfaces with a Payment Service Provider (Aquirer).

Therefore, there is no need to interface the Cash System and POS because they work together on the same device.

9. Q: Do All-in-One stand-alone devices only carry out card transactions?

A: No, the standalone All in One devices also carry out transactions in other ways, e.g. cash, on credit.

10. Q: Can standalone All in One devices issue invoices, catering order slips and Tax Free transactions?

A: Yes, through standalone All in One devices businesses can conduct the above transactions.

11. Q: Which entities are licensed to market standalone All in One devices?

A: All-in-One stand-alone devices are available on the market exclusively from Electronic Data Issuance Service Providers licensed by AADE. The relevant licenses are posted on the official website of AADE, at the following address:

https://www.aade.gr/mydata/adeiodotimena-logismika-parohon-ilektronikis-timologisis

12. Q: Is there an interconnection obligation for remote sales of goods and services (e-commerce transactions), as well as for transactions carried out through automatic payment terminals (unattended POS)?

A: No, the above transactions are excluded from interconnection.

13. Q: What applies to businesses that have an EMS that works with ERP system software in relation to the interface protocol?

A: The interconnection obligations for companies that have a MIS that cooperates with an ERP software system, are specified in the provisions of A.1155/2023 and A.1098/2022 Decisions of the Governor of AADE and companies can follow what is defined in either either to the other depending on their operational requirements.

14. Q: What are the Simultaneous Transactions conducted using POS?

A: Simultaneous Transactions are those for which the document is issued at the same time as the payment is completed by the customer using POS.

15. Q: What are Timed Transactions conducted using POS?

A: Backdated Transactions are those for which the document is issued at a time earlier than when the payment is completed by the customer using POS.

16. Q: In what cases is the POS Collection Receipt (pre-collection via POS terminal) used?

A: a) In the case of interconnection, in accordance with the provisions of A. 1098/2022 Decision of the Governor of AADE, FIM performs a pre-collection transaction, which is paid via card from EFTPOS if a wholesale transaction invoice or a tax free document is to be issued without use of FIM or to pre-collect or pre-pay a certain amount via card.

b) In the case of interconnection in accordance with the provisions of A. 1155/2023 Decision of the Governor of AADE, the POS Collection Receipt may be used for transactions carried out using POS and related to pre-collection or advance payment, issuance of a tax-free document or invoice without use of FIM.

It is pointed out that in the case of interconnection in accordance with the provisions of A. 1155/2023 decision of the Governor of AADE and the use of the Services of the Provider of Electronic Data Issuance and FIMAS, the above transactions, except for the advance collection or advance payment, are carried out with the simultaneous issuance of the required tax document.

17. Q: When is the POS Collection Receipt used for third party collections?

A: The POS Collection Receipt for third party collections is used for transactions carried out using the POS and involving the collection of amounts on behalf of third parties. In these cases, the VAT number of the third party for whom the company collects the relevant amounts is also indicated and then a settlement is carried out for the return of these amounts to the third party.

18. Q: Can Payment amounts in POS transactions be of greater value than the total value of the document or documents involved?

A: No. The exception is the case where the extra amount refers to a tip which is registered separately in the POS terminal. In any case, as long as the value of the payment amount is less than the total value of the document, the transaction is completed normally.

19. E: Business that has been interconnected in accordance with the provisions of A. 1155/2023 and conducts only retail transactions that fall under the POL. 1002/2014 and relate to the issuance of tax-free documents (except for other retail transactions), can it have a second non-interconnected POS terminal to receive payments related to the specific tax-free transactions?

A: No. In particular, tax-free transactions carried out by an entity that uses FIMAS or Electronic Data Issuance Provider Services and is interconnected in accordance with A. 1155/2023, must be carried out by an interconnected POS terminal. In case a document is to be issued without the use of FIM with payment by card, a pre-collection transaction is performed at an interconnected POS terminal.

20. E.: A catering business that does not use an open table system but issues a receipt directly at the time of service, needs to ask the customer to indicate in advance the method of payment (cash or card), and, in the case of card payments, to does he ask for immediate payment from him, because otherwise he will not be able to serve him?

A.: No. Under no circumstances does the business need to disrupt its normal operation and violate its obligation to issue a receipt with each serving. In more detail, the following are provided for:

o In the event that the relevant receipt has been issued by FIM and the company does not know the method of payment, then the issued data is preloaded on the POS terminal.

o The terminal is then able to perform one or more payment transactions (eg using different cards) for each of the preloaded receipts.

o If the customer finally pays in cash, the business, as long as it is interconnected according to A.1098/2022, does not need to take any further action for the receipts it has already preloaded.

21. Q: How are transactions carried out via POS for which the issuance of the document (invoice, retail sales receipt) precedes the Payment thereof, e.g. ready food distributor (delivery)?

A: The POS terminal is preloaded with the data of the documents already issued so that it can be paid later.

22. Q: A hotel that also offers services outside the accommodation package (e.g. catering services) and the customer requests that they be charged to the room in order to pay in total upon departure, must oblige him, if he wishes to pay by card, to pay for the relevant services by issuing the receipt?

A: No. In the event that services are offered to the customer within the hotel, which are not included in the “Agreed Room Price” package, then separate sales documents are issued for each of these transactions at the time specified (usually upon completion of the transaction or upon serving etc.). If the hotel uses software applications Property Management System (PMS – System for monitoring the daily income and accounts of “staying customers”) and the customer does not wish to pay by receiving the document, upon departure an APY is issued for the accommodation package, which includes the already issued receipts for the other services provided and the total amount is paid using the POS terminal at the point of issuance of the APY of the accommodation package.