SAP DRC & Tax Compliance

Greece: myDATA Was Only the Beginning

Greece has reported every invoice to its tax authority since 2021. In 2026 it went further: invoices now have to be issued through approved channels, and goods cannot move without a digital delivery note. Phase 2 of B2B e-invoicing was just moved to 2 November 2026: what that means, and what to do about it in SAP.

Country briefing  ·  October 2026  ·  CFOs, Tax and Finance leads

Download Full Briefing (PDF, EN)

2 Nov 2026

Phase 2 of B2B e-invoicing: every business not in Phase 1, moved from 1 October

1 Feb 2027

End of the transition: invoices only through approved channels

1 Jan 2027

Delivery notes Phase B: loading, transshipment and receipt reported

MARK

The unique number myDATA gives every accepted document, and it travels everywhere


Context

Reporting Since 2021, Issuing Control from 2026

Greece built its regime in layers. First the tax authority, AADE, asked for a copy of every invoice’s data through myDATA. Now it controls how invoices are issued and how goods move, and each layer reuses the identifier the first one created.

Four Obligations, One Platform

ObligationWhat it requiresStatus
myDATA e-booksInvoice summaries and their income and expense classifications sent to AADELive since 2021–22
B2B e-invoicingInvoices issued only through a licensed provider or AADE’s own toolPhase 1 live; Phase 2: 2 Nov
Digital delivery notesMovements of goods documented and transmitted before they startPhase A live; Phase B: 2027
B2G e-invoicingInvoices to public bodies over PeppolLive since 2023–25

The Regime at a Glance

2021–22

myDATA reporting phased in; full by January 2022

2024

Real-time sales transmission; QR code on documents

Mar 2026

B2B Phase 1: revenue above €1 million

2 Nov 2026

B2B Phase 2: everyone else

1 Jan 2027

Delivery notes Phase B

A Postponement Most Guides Have Not Caught Up With

On 30 September 2026, decision A.1197/2026 moved Phase 2 from 1 October to 2 November 2026, with a transition to 31 January 2027. Many vendor pages still show 1 October. Use 2 November, and note that the declaration of how you will issue invoices is also due by then.

Phase 2, Step by Step

DateWhat happens
By 2 Nov 2026Declare which channel you will use: a licensed provider or AADE’s tool
2 Nov 2026 – 31 Jan 2027Transition: approved channels apply; old methods still tolerated for declared businesses
From 1 Feb 2027Invoices in scope only through approved channels; otherwise treated as not issued

Who This Briefing Is For

  • Phase 1 companies, live since March, now working out what the transition left unfinished.
  • Phase 2 companies (Greek subsidiaries with revenue up to €1 million), with four weeks to go.
  • Anyone shipping goods in Greece, for whom delivery notes change logistics as much as finance.

myDATA

myDATA: Every Invoice, Classified, in AADE’s Hands

myDATA (my Digital Accounting and Tax Application) is AADE’s platform for electronic books. Businesses send a summary of every income and expense document, with its classification for VAT and income tax. Each accepted document receives a MARK, a unique registration number, and a QR code on the document links to it.

How Data Reaches myDATA

ChannelTypical user
ERP, through AADE’s APILarger companies transmitting directly from their own system
Licensed e-invoicing providerCompanies that issue through a provider, now the main route under the B2B mandate
AADE web and mobile appsVery small businesses with low volumes
Cash registersRetail sales to consumers

Deadlines

DocumentWhen it must be transmitted
Sales invoices and self-billingIn real time, when issued
Purchase invoices and their expense classificationBy the deadline of the VAT return for the period
Missing or different supplier dataReported by the buyer, with a note, by the same VAT-return deadline

Two Sides That Must Agree

What a supplier sends appears in the customer’s myDATA. Documents are matched on both tax numbers, date, series and number. If the supplier sent nothing, or sent different figures, the buyer must report the omission or difference, so accounts payable is part of myDATA, not only billing.

Why myDATA Drives the Tax Returns

Since 2024 the income declared on the VAT return cannot be lower than the income in myDATA, and the expenses cannot be higher than those in myDATA. VAT returns and the business income form are pre-filled from it. An unclassified purchase invoice is, in practice, a lost deduction.

Penalties

FailurePenalty
Document not transmitted10% of its net value, capped at €250 a day and €100,000 a year
Document transmitted late5%, capped at €125 a day and €50,000 a year
Repeat within five yearsDoubled

B2B E-Invoicing

From Reporting the Invoice to Controlling Its Issue

myDATA received a copy of the data. The B2B mandate goes further: an invoice in scope may only be issued through a licensed e-invoicing provider or AADE’s free invoicing tool. Outside those channels, after the transition, it counts as not issued.

InstrumentWhat it does
Law 5222/2025Makes B2B e-invoicing mandatory; sets penalties and early-adopter incentives
Decision A.1128/2025Scope, phases and procedure; amended by A.1044/2026 and A.1197/2026
Decision A.1129/2025The declaration of which channel a business will use
EU Decision 2025/502Authorises the mandate from 1 July 2025 to 31 December 2027

Phases

PhaseWhoStartApproved channels only
Phase 12023 gross revenue above €1 million: around 38,000 businesses2 Mar 2026After 3 May 2026
Phase 2Everyone else in scope2 Nov 20261 Feb 2027

Phase 1 was first set for 2 February 2026 and Phase 2 for 1 October 2026. During each transition, old issuing methods remain allowed only for businesses that filed their channel declaration on time.

In Scope

Domestic sales between businesses.

Sales to businesses outside the EU, except retail.

Invoices under public contracts.

Optional or Outside

Sales to businesses in other EU countries: optional.

Retail sales to consumers: cash-register regime.

Entities not keeping Greek accounting books.

How an Invoice Is Issued

1 · Issue

The ERP sends the invoice to the licensed provider, or it is created in AADE’s tool

2 · Register

The data is transmitted to myDATA, which returns the MARK and a unique invoice identifier

3 · Deliver

The invoice, carrying its MARK and QR code, reaches the customer, who must be able to receive it

Penalties and Incentives

An invoice not issued properly for a VAT-able sale costs 50% of the VAT; for other sales, €500 or €1,000 per audit depending on the books kept. Without a valid MARK the buyer risks its VAT deduction. On the other side, early adopters could claim double deductions for e-invoicing costs and equipment.


Delivery Notes

No Goods Move Without a MARK

Greece extended the same logic to the movement of goods. A digital delivery note must be issued and transmitted to myDATA before transport starts, and it receives its own MARK. Phase B extends reporting to what happens on the way and on arrival.

The Phases

PhaseWhat it coversFrom
Phase A, first waveDelivery note issued and sent before the movement starts2 Jun 2025: larger businesses and listed sectors
Phase A, second waveThe same, for everyone else1 Dec 2025
Phase BLoading, transshipment, receipt, discrepancies and quantity data1 Jan 2027 (moved from 12 Oct 2026)
Product codingGoods coded on customs nomenclature1 Jan 2028; voluntary before

Sources differ on whether the June 2025 wave covered businesses above €200,000 of turnover as well as the listed sectors (pharmaceuticals, energy, construction materials, olives and olive oil). Confirm your own wave.

Why This Is a Logistics Project

Before the truck leaves

The note must exist before the truck leaves, so issuing sits in the warehouse process, not month-end.

The customer’s warehouse

Receipt and discrepancies in Phase B involve the customer’s warehouse too.

More movements

Carriers, third-party warehouses and returns all create movements to document.

Two MARKs

The invoice later references the delivery note: two MARKs that must tie up.

What Phase B Adds

EventWhat must be reported
LoadingWhen and where the goods are actually loaded
TransshipmentChanges of vehicle or carrier during the journey
ReceiptConfirmation of what arrived, and when
DiscrepanciesDifferences between quantities sent and received

Penalties

Failure to issue or transmit a delivery note costs €5,000 per audit for businesses with single-entry books and €10,000 for double-entry books, doubled for a second offence and quadrupled for further repeats.

Three Months to Phase B

Phase A proves a note was issued. Phase B proves what actually happened to the goods. The gap between what was shipped and what was received becomes visible to AADE, so returns, short deliveries and stock transfers between your own sites need a designed process before January.


The Rest of the Picture

Public Sector, Retail and ViDA

B2G e-invoicing runs on Peppol BIS Billing 3.0 with a Greek specialisation, through the National Interoperability Centre. It was phased in by type of public body.

Invoices to Public Bodies

WaveWho receives electronically
2023The main ministries
1 Jan 2024All central government
1 Jun 2024All other contracting authorities
1 Sep 2025Non-procurement public spending above €2,500

Retail

  • Cash registers send retail receipts to myDATA.
  • Card terminals had to be linked to cash registers by early 2024.
  • Handwritten retail receipts were abolished by Law 5222/2025.
  • Standard VAT rate 24%; reduced 13% and 6%; lower rates on some islands.

How Greece Compares

AreaGreeceTypical EU neighbour
Invoice data to the authorityEvery document, near real time, since 2021–22Periodic files or none
Periodic audit fileNo SAF-T: the e-books play that roleSAF-T in several countries
Movement of goodsDigital delivery note before transportOnly for high-risk goods, if at all

ViDA and the 2027 Horizon

Greece’s EU authorisation for the B2B mandate runs to 31 December 2027, with an evaluation due by March 2027. Under the ViDA reform, member states no longer need such an authorisation, and from 1 July 2030 cross-border B2B invoices within the EU move to digital reporting. Expect the Greek design to be aligned with the European standard over that period: another reason to keep mappings clean.

For Foreign Groups with a Greek Subsidiary

The Greek entity is often small, runs on the group’s SAP template, and was not in Phase 1. That makes it a Phase 2 company on 2 November, with a group template that has no Greek provider, no delivery-note flow and no purchase classification. Check it now, not in the first week of November.

What We Would Watch

  • Further date changes: Greece moved three deadlines in 2026 alone.
  • The format of B2B invoices, which official texts define less precisely than vendors do.
  • The 2027 evaluation and what it means for the Greek model under ViDA.

The SAP Side

What It Means for Your SAP System

SAP Document and Reporting Compliance covers the Greek requirements on both SAP S/4HANA and classic SAP ERP: myDATA e-books, invoices and delivery notes as electronic documents, with SAP’s cloud integration or a partner’s middleware for the connection. Under the B2B mandate the invoice itself must pass through a licensed Greek provider: one framework, three flows, a provider in the middle.

Requirement by Requirement

RequirementIn SAPWatch for
myDATA: salesElectronic documents created from billing, with income classification, sent in real timeClassifications mapped per revenue account
myDATA: purchasesExpense classification of supplier invoices, transmitted by the VAT deadlineNobody owning AP classification
B2B e-invoiceInvoice routed to the licensed provider; MARK and identifier returned to SAPProvider integration and status return
Delivery notesCreated from outbound deliveries and goods movements, before dispatchMovements outside the standard flow
MARK on documentsStored on the electronic document and printed with the QR codeOutput forms not updated

Platform Notes

  • S/4HANA and SAP ERP 6.0: Greek e-books and electronic documents supported; no platform move required for compliance.
  • Cloud edition and public cloud: delivery notes supported in SAP’s cloud compliance service.
  • SAP ERP’s maintenance ends 31 December 2027: the Greek design should not be built twice.
  • Confirm country content in SAP notes for your release.

Decisions to Take Now

  1. Which provider, and whether its integration with SAP DRC is standard or custom.
  2. Who classifies purchases: accounts payable at posting, or tax at period end.
  3. Which logistics flows create delivery notes, and from which documents.
  4. How statuses return to SAP, so that the MARK sits on the accounting document.

A Typical Project

1 · Scope

Entities and phases, document types, logistics flows, provider choice

2 · Design

Classification mapping, provider integration, delivery-note triggers, status return

3 · Build and test

SAP notes, DRC configuration, provider test environment, myDATA test

4 · Run

Daily status review, monthly myDATA reconciliation, Greek decisions tracked

The Provider in the Middle

Invoices travel from SAP to the provider, then to myDATA and the customer, and each hop returns a status. If the MARK and errors never come back into SAP, finance works from the provider’s portal and myDATA goes unreconciled.


Health Check

A Health Check: Twelve Questions, and What a Poor Answer Costs

Greek compliance usually works on the sales side, where it started. The value leaks on the purchase side and in logistics: unclassified expenses, unreported differences and movements without a note.

The Twelve Questions

#QuestionIf the answer is unclear
1Do we know which phase each Greek entity is in?Phase 2 on 2 November, unprepared
2Was the channel declaration filed on time?No transition period: invoices count as not issued
3Does every sales document get a MARK?10% penalty per document not transmitted
4Are purchase invoices classified by the VAT deadline?Expenses missing from pre-filled returns
5Do we report suppliers’ missing or wrong data?Differences found by AADE first
6Does the VAT return reconcile to myDATA?Income below myDATA or expenses above it: rejected
7Do provider statuses and MARKs return to SAP?Finance working from a portal
8Can we receive e-invoices from every supplier?Lost deductions without a valid MARK
9Does every goods movement have a delivery note?€5,000–10,000 per audit
10Are we ready to report receipts and discrepancies?Phase B in January, unplanned
11Do invoices reference their delivery notes?Two MARKs that do not tie up
12Who tracks Greek decisions and dates?Learning about changes from rejections

Questions 1 and 2 are urgent for Phase 2 companies this month. Questions 4 to 6 are where established Greek implementations most often leak value, through deductions nobody claimed.

The First Thirty Days

Week 1

Phase and declaration per entity; provider status

Weeks 2–3

MARK coverage, sales and purchases; VAT return vs myDATA

Week 4

Delivery-note gaps and a Phase B plan

What We Typically Find

  • Sales transmission reliable since 2024
  • Purchase classification done late, by hand
  • Provider connected, statuses not returned to SAP
  • Delivery notes for the standard flow only

Three Figures to Ask For

FigureWhat a good answer looks like
Sales documents without a MARKZero, or a short list being fixed this week
Purchases classified after the deadlineA small, falling number
Differences reported to AADE last quarterKnown, explained and owned by AP

How We Help

How 30 Advisory Can Help

A founder-led boutique specialised in SAP DRC & e-invoicing compliance, S/4HANA Finance optimisation and CFO/CIO strategic advisory. Greece rewards companies that treat compliance as one design (e-books, invoices and delivery notes sharing the same data and the same MARK) rather than three projects.

1 · Diagnose

Greek health check, two to three weeks

Against the twelve questions: phases, declarations, MARK coverage, purchase classification, reconciliation and delivery notes. Output: a prioritised gap list.

2 · Prepare

Phase 2 and Phase B readiness

Provider integration with SAP DRC, statuses returned to SAP, delivery notes for every flow, receipts and discrepancies. Output: ready for November and January.

3 · Run

Run and legal change

Monthly myDATA reconciliation, decisions tracked, and the design aligned with ViDA as it arrives. Output: a regime that stays current.

What a Health Check Produces

OutputContent
A phase positionEach Greek entity’s phase, declaration and provider, against the November and February dates
A myDATA viewMARK coverage on both sides, purchase classification timeliness, VAT return versus myDATA
A logistics viewMovements without notes, and the Phase B design for receipts and discrepancies

What Makes This Different

We look at the purchase side. That is where Greek implementations leak deductions.

We bring statuses back into SAP. The provider is a channel, not the system of record.

We include logistics. Delivery notes are a warehouse process with a tax consequence.

We say what we are not. We are not your tax adviser or your provider; we work alongside both.

What to Bring to the First Conversation

Your Greek entities, their phase and revenue.

Your SAP release and current myDATA set-up.

The provider you use or are choosing.

Your main logistics flows in Greece.

A Sensible First Step

Ask for two numbers: purchase invoices classified after the VAT deadline last quarter, and goods movements without a delivery-note MARK. Together they show where Greek compliance is costing you.

Founder-led

Finance + SAP DRC depth

Multi-country: Italy, Türkiye, Spain

Boutique agility


Not Sure What This Means for Your SAP Landscape?

We'll review your phase, your provider, the purchase side and your logistics flows against the Greek regime in a 1-hour diagnostic session.

Schedule Assessment (1 hour)