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
Key takeaway for finance and tax leaders: 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 as three projects. The question to ask this month: if we have a Greek subsidiary with revenue up to €1 million, have we declared the channel we will use to issue invoices from 2 November?
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
| Obligation | What it requires | Status |
|---|---|---|
| myDATA e-books | Invoice summaries and their income and expense classifications sent to AADE | Live since 2021–22 |
| B2B e-invoicing | Invoices issued only through a licensed provider or AADE’s own tool | Phase 1 live; Phase 2: 2 Nov |
| Digital delivery notes | Movements of goods documented and transmitted before they start | Phase A live; Phase B: 2027 |
| B2G e-invoicing | Invoices to public bodies over Peppol | Live since 2023–25 |
The Regime at a Glance
myDATA reporting phased in; full by January 2022
Real-time sales transmission; QR code on documents
B2B Phase 1: revenue above €1 million
B2B Phase 2: everyone else
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
| Date | What happens |
|---|---|
| By 2 Nov 2026 | Declare which channel you will use: a licensed provider or AADE’s tool |
| 2 Nov 2026 – 31 Jan 2027 | Transition: approved channels apply; old methods still tolerated for declared businesses |
| From 1 Feb 2027 | Invoices 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: 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
| Channel | Typical user |
|---|---|
| ERP, through AADE’s API | Larger companies transmitting directly from their own system |
| Licensed e-invoicing provider | Companies that issue through a provider, now the main route under the B2B mandate |
| AADE web and mobile apps | Very small businesses with low volumes |
| Cash registers | Retail sales to consumers |
Deadlines
| Document | When it must be transmitted |
|---|---|
| Sales invoices and self-billing | In real time, when issued |
| Purchase invoices and their expense classification | By the deadline of the VAT return for the period |
| Missing or different supplier data | Reported 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
| Failure | Penalty |
|---|---|
| Document not transmitted | 10% of its net value, capped at €250 a day and €100,000 a year |
| Document transmitted late | 5%, capped at €125 a day and €50,000 a year |
| Repeat within five years | Doubled |
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.
Legal Basis
| Instrument | What it does |
|---|---|
| Law 5222/2025 | Makes B2B e-invoicing mandatory; sets penalties and early-adopter incentives |
| Decision A.1128/2025 | Scope, phases and procedure; amended by A.1044/2026 and A.1197/2026 |
| Decision A.1129/2025 | The declaration of which channel a business will use |
| EU Decision 2025/502 | Authorises the mandate from 1 July 2025 to 31 December 2027 |
Phases
| Phase | Who | Start | Approved channels only |
|---|---|---|---|
| Phase 1 | 2023 gross revenue above €1 million: around 38,000 businesses | 2 Mar 2026 | After 3 May 2026 |
| Phase 2 | Everyone else in scope | 2 Nov 2026 | 1 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
The ERP sends the invoice to the licensed provider, or it is created in AADE’s tool
The data is transmitted to myDATA, which returns the MARK and a unique invoice identifier
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.
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
| Phase | What it covers | From |
|---|---|---|
| Phase A, first wave | Delivery note issued and sent before the movement starts | 2 Jun 2025: larger businesses and listed sectors |
| Phase A, second wave | The same, for everyone else | 1 Dec 2025 |
| Phase B | Loading, transshipment, receipt, discrepancies and quantity data | 1 Jan 2027 (moved from 12 Oct 2026) |
| Product coding | Goods coded on customs nomenclature | 1 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
The note must exist before the truck leaves, so issuing sits in the warehouse process, not month-end.
Receipt and discrepancies in Phase B involve the customer’s warehouse too.
Carriers, third-party warehouses and returns all create movements to document.
The invoice later references the delivery note: two MARKs that must tie up.
What Phase B Adds
| Event | What must be reported |
|---|---|
| Loading | When and where the goods are actually loaded |
| Transshipment | Changes of vehicle or carrier during the journey |
| Receipt | Confirmation of what arrived, and when |
| Discrepancies | Differences 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.
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
| Wave | Who receives electronically |
|---|---|
| 2023 | The main ministries |
| 1 Jan 2024 | All central government |
| 1 Jun 2024 | All other contracting authorities |
| 1 Sep 2025 | Non-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
| Area | Greece | Typical EU neighbour |
|---|---|---|
| Invoice data to the authority | Every document, near real time, since 2021–22 | Periodic files or none |
| Periodic audit file | No SAF-T: the e-books play that role | SAF-T in several countries |
| Movement of goods | Digital delivery note before transport | Only 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.
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
| Requirement | In SAP | Watch for |
|---|---|---|
| myDATA: sales | Electronic documents created from billing, with income classification, sent in real time | Classifications mapped per revenue account |
| myDATA: purchases | Expense classification of supplier invoices, transmitted by the VAT deadline | Nobody owning AP classification |
| B2B e-invoice | Invoice routed to the licensed provider; MARK and identifier returned to SAP | Provider integration and status return |
| Delivery notes | Created from outbound deliveries and goods movements, before dispatch | Movements outside the standard flow |
| MARK on documents | Stored on the electronic document and printed with the QR code | Output 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
- Which provider, and whether its integration with SAP DRC is standard or custom.
- Who classifies purchases: accounts payable at posting, or tax at period end.
- Which logistics flows create delivery notes, and from which documents.
- How statuses return to SAP, so that the MARK sits on the accounting document.
A Typical Project
Entities and phases, document types, logistics flows, provider choice
Classification mapping, provider integration, delivery-note triggers, status return
SAP notes, DRC configuration, provider test environment, myDATA test
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.
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
| # | Question | If the answer is unclear |
|---|---|---|
| 1 | Do we know which phase each Greek entity is in? | Phase 2 on 2 November, unprepared |
| 2 | Was the channel declaration filed on time? | No transition period: invoices count as not issued |
| 3 | Does every sales document get a MARK? | 10% penalty per document not transmitted |
| 4 | Are purchase invoices classified by the VAT deadline? | Expenses missing from pre-filled returns |
| 5 | Do we report suppliers’ missing or wrong data? | Differences found by AADE first |
| 6 | Does the VAT return reconcile to myDATA? | Income below myDATA or expenses above it: rejected |
| 7 | Do provider statuses and MARKs return to SAP? | Finance working from a portal |
| 8 | Can we receive e-invoices from every supplier? | Lost deductions without a valid MARK |
| 9 | Does every goods movement have a delivery note? | €5,000–10,000 per audit |
| 10 | Are we ready to report receipts and discrepancies? | Phase B in January, unplanned |
| 11 | Do invoices reference their delivery notes? | Two MARKs that do not tie up |
| 12 | Who 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
Phase and declaration per entity; provider status
MARK coverage, sales and purchases; VAT return vs myDATA
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
| Figure | What a good answer looks like |
|---|---|
| Sales documents without a MARK | Zero, or a short list being fixed this week |
| Purchases classified after the deadline | A small, falling number |
| Differences reported to AADE last quarter | Known, explained and owned by AP |
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.
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.
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.
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
| Output | Content |
|---|---|
| A phase position | Each Greek entity’s phase, declaration and provider, against the November and February dates |
| A myDATA view | MARK coverage on both sides, purchase classification timeliness, VAT return versus myDATA |
| A logistics view | Movements 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
Sources consulted 5 October 2026: AADE and Taxheaven (decisions A.1128/2025, A.1129/2025 and A.1197/2026); VATupdate (June, August and 1 October 2026); KPMG, EY Greece and Zeya alerts on myDATA, Law 5073/2023, Law 5222/2025 and the e-invoicing phases; European Commission eInvoicing country sheet and OpenPeppol on B2G; Sovos, EDICOM, ecosio, vatcalc and Fiscal Solutions on formats, delivery notes and penalties; PwC tax summaries on VAT rates. SAP behaviour from SAP knowledge-base material and partner commentary (PIKON, SAP Community).
Prepared by 30 Advisory, October 2026 (status at 5 October 2026). Information only — not tax, legal or accounting advice. Greek deadlines changed repeatedly in 2026 and many published guides still show superseded dates; sources differ on detail, including the end of the Phase 1 transition, the cohorts of the first delivery-note wave and the B2B invoice format. Confirm the position for your entity with AADE or a qualified adviser before acting.
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.
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