Entering Greece through distributors: KIMDIS records, EKAPY health frameworks, myDATA e-invoicing and a first contact by letter

Greece is a market where the public record is unusually complete and the first contact is unusually strict. Public buyers log each step of a purchase in one national registry, health purchasing has a national central authority, and invoices pass through the tax authority's systems. Yet a cold e-mail to a distributor is unlawful. A manufacturer that reads the record, prepares Greek documents and writes a letter instead of an e-mail can find its partner without a misstep.

Putting it simply: Greek public buyers publish requests, invitations, award decisions and contracts in KIMDIS, the central electronic registry of public contracts, and run their electronic tenders on ESIDIS, the national e-procurement system. Purchases of supplies and services up to €30,000 may go by direct award; larger ones by competitive procedure, and above the EU thresholds also on TED. In health, the National Central Authority for Health Procurement (EKAPY) runs framework agreements for public health services. Electronic invoicing between Greek businesses is being made mandatory in phases, and public buyers pay in 30 days as a rule, 60 at most. Marketing e-mail needs the recipient's prior consent, so the first approach goes by letter, at a fair or through an introduction.

How the market buys

Distributors, Athens, Thessaloniki and the islands

In most technical and professional categories a foreign manufacturer sells to a Greek distributor that holds stock, bids for public contracts and delivers to hospitals, municipalities and companies. Buyers sit on the mainland and on the islands, and deliveries to islands depend on ferry and air links, so ask early which regions and islands a distributor serves itself, which it reaches through sub-dealers and how it handles urgent orders.

Greek public demand ends up with local companies. In our analysis of TED award notices for supplies (September 2026), 99% of the winners in the 1,660 notices from buyers in Greece were companies registered in the country (methodology). Those winners include independent distributors as well as manufacturers' own Greek subsidiaries; the first job is to tell them apart.

Hospitals and EKAPY

Health is the most visible public category. EKAPY (Εθνική Κεντρική Αρχή Προμηθειών Υγείας) describes its role as the coordination and conduct of central purchasing, and the receipt, storage and distribution of health products, materials and services, together with monitoring of consumption across public health services. It keeps electronic registers of suppliers, products and services, and publishes its tenders on its own site.

Its tenders show the scale. On 24 September 2026 EKAPY announced tender 8/2026, an open electronic procedure above the EU thresholds for a framework agreement for intraocular lenses (CPV 33731110-7), with call-off contracts without reopening of competition, a one-year term and an estimated value of €11,928,488.13 excluding VAT, plus an option for a further year of the same value. This one splits the total quantity among its holders by pre-agreed percentages, so a framework of that size usually goes to several suppliers; in medical devices those suppliers are the distributors and subsidiaries to look at first. Individual hospitals still buy below and alongside EKAPY's frameworks, and those purchases appear in KIMDIS.

The proof Greek buyers expect

CE marking and documents in Greek

Buyers and distributors expect conformity evidence before price: CE marking and the declaration of conformity where the product is regulated, plus test reports against the standards named in the tender. For medical devices, article 10(11) of Regulation (EU) 2017/745 requires the manufacturer's information to be supplied in the official Union language or languages determined by the Member State where the device reaches the user or patient; ask your distributor which Greek labels and instructions it needs before the first tender. As of 3 November 2026 we could not open the text of the Greek implementing rule ourselves, so treat the exact scope of any Greek-language requirement as something to confirm.

In practice expect to work in Greek: technical sheets, instructions, safety information and price lists, ready as files a distributor can upload to an electronic tender.

Company identity: GEMI and the tax number

Greek companies are registered in the General Commercial Registry, ΓΕΜΗ (GEMI), whose one-stop portal lets anyone look up information on a business, order certificates and copies, and subscribe to notifications when a company's record changes. Greek award notices and invoices identify companies by their tax number, the ΑΦΜ (AFM). When a distributor gives you its AFM and GEMI number, check the registry entry and match the number against the contracts it has won.

Invoicing through myDATA

Greece reports invoices to the tax authority, AADE, through its myDATA platform, and is moving from reporting to mandatory electronic invoicing. Council Implementing Decision (EU) 2025/502 authorises Greece to accept only electronic invoices from taxable persons established in Greece, without the recipient's acceptance, for transactions between them; it applies from 1 July 2025 until 31 December 2027.

The national timetable is set by joint decision A.1128/2025, amended since. According to an EY Greece tax alert on decision A.1044/2026 (ΦΕΚ Β΄ 880/17.02.2026) and an AADE announcement republished on 1 October 2026, with decision A.1197/2026:

• businesses with gross revenue above €1,000,000 were obliged from 2 March 2026 (instead of 2 February 2026 as first planned);
• for all other businesses the start, first set for 1 October 2026, was moved to 2 November 2026, with a transition until 31 January 2027 in which other issuing methods may still be used alongside e-invoicing; from 1 February 2027 their B2B, non-EU and B2G invoices must be issued only through a certified e-invoicing provider or AADE's own applications;
• the scope covers domestic B2B sales and sales to entities outside the EU (retail excluded), and invoicing under public contracts (B2G), subject to more specific provisions, under article 14 of Law 4308/2014, as amended by Law 5222/2025.

AADE's own site was not reachable for us on 3 November 2026, and the decisions have been amended more than once, so confirm the current timetable on aade.gr. For a foreign manufacturer the obligation falls first on your Greek distributor: it must issue e-invoices to Greek customers through a certified provider or AADE's own application. Your invoice to the distributor is an intra-EU or export invoice under your own rules. Confirm the invoicing rules for your contracts with your tax adviser.

Payment terms

Law 4152/2013 (ΦΕΚ Α΄ 107) transposed the Late Payment Directive 2011/7/EU. Where the debtor is a public authority, subparagraph Ζ.5 sets 30 calendar days from receipt of the invoice, extended to 60 days for public undertakings with commercial activity and for recognised public healthcare providers and EOPYY, the national health insurer. A longer contractual term must be expressly agreed and objectively justified, and "σε κάθε περίπτωση η προθεσμία δεν υπερβαίνει τις εξήντα (60) ημερολογιακές ημέρες": in any case, 60 calendar days. Between companies the Directive limits agreed payment periods to 60 days as a general rule, unless expressly agreed otherwise and not grossly unfair to the creditor. Agree the terms with your distributor before the first tender, and check them with your adviser.

Where public demand is visible

ESIDIS and KIMDIS

Both systems are reached from the national e-procurement portal (promitheus.gov.gr redirects there). ESIDIS has separate subsystems for supplies and services and for public works, with search, open data and statistics; on 3 November 2026 the portal's statistics showed 7,993 participating economic operators and 32,458 offers over the previous 12 months. KIMDIS records the transparency and publicity data of public contract acts and decisions: requests, invitations, award decisions and contracts. It offers an Open Data API, so the record can be searched systematically.

Direct awards up to €30,000

Under article 118 of Law 4412/2016, as replaced in 2021, a contracting authority may award a supply or service contract directly when its estimated value is €30,000 or less (€60,000 for certain ICT and special services). The national procedures registry, mitos.gov.gr (last updated 7 August 2026), sets out the steps:

• the approved request and the first invitation to submit an offer are published on KIMDIS;
• the award decision is published on KIMDIS at least five days after the first invitation;
• for contracts above €2,500 plus VAT, the signed contract is published on KIMDIS too;
• since 1 October 2025, using ESIDIS for direct awards is no longer mandatory.

So even the small awards, where a distributor first wins a hospital or municipality, leave a trace with the supplier's name.

Above the EU thresholds: TED

For supplies and services in 2026 and 2027 the EU thresholds are €140,000 for central government and €216,000 for other contracting authorities (Delegated Regulation (EU) 2025/2152). Above them, Greek buyers publish award notices on TED, naming the winner and carrying CPV codes (how to read a TED contract award notice). Between €30,000 and the EU thresholds, use KIMDIS for the awards and contracts.

Lawful first contact

Greece requires consent. Article 11(1) of Law 3471/2006 permits unsolicited e-mail for direct marketing only if the subscriber has expressly consented in advance. The Hellenic Data Protection Authority states that without a prior transaction you must have the recipient's consent, in writing or electronically, before sending any message, and that a pre-ticked box is not consent. It lists unlawful sources of addresses: bought lists collected without consent, lists not created for direct marketing, such as directories of professional associations and trade fairs, and addresses harvested from websites, forums and blogs, by hand or by crawler, explicitly including generic company addresses "τύπου «info@company.gr»". The only exception covers your own customers: details obtained in a previous transaction may be used to market similar products or services.

That is why we describe Greece as forbidden for cold e-mail. Write by post, in Greek, to the owner or commercial director, with a one-page sheet on your range and a clear reason why it fits what the distributor already sells; meet at the sector's trade fair; or ask a chamber, an association or an existing Greek partner for an introduction. Once a distributor has written to you, reply by e-mail. The Greece market page sets out the rule and its sources. This is a summary, not legal advice; check your approach with a Greek adviser.

What this means for a manufacturer

• Read the public record first: TED above the EU thresholds, KIMDIS for every stage below them, direct awards included.
• In health, check EKAPY's frameworks for your category; their holders already serve the hospitals.
• Prepare Greek documents and conformity evidence as electronic files, ready for ESIDIS.
• Check a distributor's GEMI entry and AFM, and ask which regions and islands it covers itself.
• Expect your distributor to issue e-invoices through myDATA; confirm the current AADE timetable.
• Keep payment terms within 60 days and expect 30 on most public work.
• Make the first contact by letter, at a fair or through an introduction, never by cold e-mail.

Where Cresques fits

Create a market for Greece, choose your CPV categories (or let the materials reader suggest them from a brochure or website), and Cresques shows the companies named in TED award notices for those categories, with personal details removed. For the smaller awards below the EU thresholds, search KIMDIS yourself. Company profiles with an AI-researched role, telling distributors from manufacturers' subsidiaries, are live, and so are first messages drafted in Greek with an English version, written for the lawful channel (a letter, not a cold e-mail); e-mail alerts on new awards come with paid plans.