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Following the rollout of eBooks and e-Invoicing through the myDATA platform, the Greek government is now expanding its digitalization efforts to include the monitoring of goods movement. This next phase, referred to as e-Delivery or e-CMR, introduces new requirements for the digital tracking of transported goods, further enhancing control and visibility across the supply chain.
A significant legal development concerning the digital monitoring of goods movement was announced on August 6, 2024, by the Independent Authority of Public Revenue (IAPR) in Greece. This new regulation applies to both domestic and international transportation of goods in Greece and will be implemented in two distinct phases
Implementation Timeline
Phase A – Effective from June 2, 2025:
This phase applies to:
- Companies with gross annual income exceeding €200,000 (according to their income tax return)
- Businesses (regardless of their annual turnover) involved in the trade of:
- Medicines and medical consumables
- Energy products (e.g., fuels)
- Building and construction materials
- Production, standardization, and marketing of olives and olive oil
Phase B – Effective from December 1, 2025:
This phase extends the obligations to:
- All remaining companies
- Entities located in Greece with gross revenues over €5 million which are subsidiaries of foreign companies that utilize their parent company’s ERP system.
Key Requirements by phase
Phase A Highlights: Digital issuance and transmission of shipping notes
- Issuance of goods movement documents (such as delivery notes, combined invoice-delivery notes, and internal transfers between plants) must include a QR code indicating successful submission to the myDATA platform.
- Transmission of transportation data (e.g., delivery notes, revenue invoices, and internal stock transfers) to myDATA, along with recipient notifications.
- Transportation can be monitored via QR code scans of accompanying documents, enabling real-time control.
Phase B Enhancements: Digital monitoring of movement, transshipments and delivery of goods
- Full digital tracking of complex transportation flows, including multiple loads and post-load of goods activities.
- Goods receipt is confirmed, and transactions completed through QR code scanning.
- The recipient must validate received goods both quantitatively and qualitatively. Any uncovered discrepancies must be reported to myDATA within 15 days of the goods dispatch.
- XML submissions must include:
- Details of correlated entities (e.g. carrier, buyer)
- Associated documents
- Material codes following the EU Combined Nomenclature (CN) regulation 2658/87
This regulation aims to improve transparency, traceability, and tax compliance in goods movement across sectors. Businesses impacted should begin preparing their systems and processes to ensure seamless compliance with the upcoming deadlines.
Submission Responsibility
The party responsible for generating and submitting e-Delivery documents, can differ depending on the delivery’s circumstances:
- The goods’ owner must report the delivery to myDATA, if the goods are being dispatched from his facilities.
- The third-party logistics provider (3PL) must report the delivery to myDATA, if the goods are being dispatched from his warehouse, and he manages the inventory and accompanying documents.
- The Greek recipient of the goods must report the delivery to myDATA, if his goods were delivered by a foreign supplier who is not subject to the Greek e-Delivery requirements. Reporting must be done by the 20th of the month following the issuance of the delivery documents.
In any case, goods must be dispatched within five days after the e-Delivery document was submitted to myDATA.
Following transactions will be exempt from any e-Delivery requirements:
- Transactions by farmers under the special VAT regime
- Transactions by public or private employees conducting occasional sales
- Goods moved through continuous flow networks, tools for technicians, and undertaker activities
SAP DRC Compliance for Greek e-Delivery notes
As with any legal requirement, achieving compliance with the Greek e-Delivery note regulations brings some technical and process-related challenges for your company and your SAP system. From a technical SAP perspective, you need a solution that can extract the necessary data from your SAP system, convert it into the required XML file, and transmit the generated XML file to the central platform of the Greek tax authority (myDATA).
To support businesses in meeting the new Greek e-Delivery notes requirements, SAP provides a solution through SAP Document and Reporting Compliance (SAP DRC; ‘SAP Document and Reporting Compliance, on-premise’ license). This solution enables the generation, submission and monitoring of electronic delivery notes in line with the Greek regulation.
What makes SAP DRC particularly valuable is its user-friendly interface and adaptability. It supports a wide range of international compliance needs, such as Turkish e-Delivery, Romanian e-Transport, SDI Italy and myDATA e-Books and e-Invoicing Greece.
At the heart of SAP DRC is the eDocument Cockpit, a centralized SAP transaction that allows users to manage and monitor all compliance processes across different countries from one place. Whether you are dealing with e-Delivery in Greece or similar mandates elsewhere, SAP DRC offers a scalable, future-proof solution.
SAP DRC process flow for e-Delivery notes in Greece
The following graphic illustrates the end-to-end steps that are implemented in SAP DRC to achieve compliance with the Greek regulations for the monitoring of goods movement (e-Delivery Notes).
- Once you have posted an SAP delivery note in your SAP ECC or SAP S/4HANA system, a related SAP eDocument is automatically generated in the SAP eDocument Cockpit (EDOC_COCKPIT transaction) in the background. During set-up, you can decide whether the e-Delivery creation is to be triggered at the time of delivery document posting, or at the time of goods issue.
- To comply with the real-time submission requirements and the generation of the myDATA authentication QR code, the submission to myDATA must be initiated from a standard SAP printing program that is used to issue the delivery note. SAP provides two standard printing programs for this purpose:
- J_2GLPPDL for SD deliveries
- J_2GLPPMM for MM documents
- From within the printing program, the electronic delivery document is submitted to the SAP Application Interface Framework (AIF), which handles the transformation of the document data into the XML format required by the Greek tax authority (IAPR).
- This XML is then passed to SAP Cloud Integration (CPI). SAP CPI processes the XML and sends it to the IAPR myDATA platform. Upon successful receipt, the myDATA platform processes and stores the delivery note, and returns legal data including the:
- UID (Unique Document ID)
- MARK (Unique registration number)
- myDATA authentication URL
- These response values are forwarded back through SAP CPI and stored in the eDocument Cockpit, which updates the electronic document accordingly. The process status is then being updated.
- If the delivery document is accepted, the printing program retrieves the UID, MARK, and authentication URL and prints the corresponding QR code on the delivery note.
How PIKON can help you stay compliant in Greece
At PIKON, we have established our strategic Competence Center for Legal Requirements. We ensure that your SAP system and business processes meet different country-specific legal requirements all over the world on the long run. For this, we have a team of experts that combine SAP expertise and in-depth knowledge of the end-to-end legal process and technical requirements of the different Greek regulations for the electronic submission of VAT-related information, being e-Invoicing, e-Delivery and e-Books. Together with you, we analyse and define the best possible, future-proof SAP solution scenario for you and implement this in a minimum of time according to your pre-agreed budget and your specific wishes/ requirements.
If you want to have more information about compliance with the Greek e-Delivery Note regulations in SAP (or any other e-regulations), or if you have any other questions, then please feel free to click the button earlier in this article and request a web-meeting. Or you can always leave a comment in the comments section below, I will then come back to you as soon as possible.
Webmeeting Legal Requirements
If you have any questions, or if you would like to discuss how PIKON can help you with your business case, do not hesitate to leave a comment below or to request a web-meeting. I am happy to help you!
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