On 1st April 2021, the end of the first quarter of 2021, the myDATA (my Digital Accounting and Tax Application) requirements for the electronic submission of E-Books accounting and e-invoicing records are coming into force in Greece. These regulations are imposed by the Greek IAPR tax authority (Independent Authority for Public Revenue) and require all businesses that manage accounting processes according to Greek regulations to submit E-Invoice data and Electronic Books with e-ledger details electronically to the central myDATA platform.
In this blog post, I will provide you with more details on the Greek myDATA requirements and explain how you can ensure compliance with SAP Document Compliance for SAP ECC and SAP S/4HANA and avoid paying severe penalties.
The E-Books and E-Invoicing data that needs to be electronically submitted to the AADE myDATA platform
On 1st August 2019, the Independent Authority for Public Revenue (IAPR) in Greece, also named AADE (Ανεξάρτητη Αρχή Δημοσίων Εσόδων (ΑΑΔΕ)), first published official technical information about possibilities to implement E-Invoicing in Greece through the My Digital Accounting and Tax Application system (myDATA platform). The Tax Reform Law (L. 4646/2019), published in December 2019, first introduced E-Books and E-Invoices as changes to the Greek Tax Procedure’s Code (L. 4174/2013).
The new Greek myDATA E-Books and E-Invoicing regulations state that all businesses that keep accounting records according to the Greek Accounting Standards, regardless of the type of company, need to periodically submit the following 2 sets of VAT-related data electronically to the myDATA portal from the Greek IAPR tax authority:
- E-Invoices: sales VAT invoices (domestic B2B transactions). Plus records of purchase e-invoices that have been received. Invoice details must include accounting code details – unlike regular e-invoices.
- E-Books: accounting General Ledger transactions; Cash ledger Payroll; and Fixed asset transactions, including depreciation provisions. B2C and cross-border transactions, not included in e-invoice data, will be added to the E-Books.
From a technical perspective, the VAT books and the e-invoice data needs to be mapped and prepared in a pre-defined XML format. Then, this XML file needs to be submitted to the Greek AADE myDATA platform. The XML format follows the European EN 1691-1 standard.
The submission itself will be on a monthly or on a quarterly basis – depending on your current filing frequency and the respective requirements. The data submission needs to be completed before the 20th day after the end of the month in which the relevant invoices were issued.
Note: whilst termed e-invoicing by the Greek IAPR authorities, this model is actually closer to transaction reporting seen in Spain with SII reporting and other EU countries recently. There is no Greek requirement to send e-invoices to the customer; only to report VAT-related transaction details to the IAPR tax office.
Why Greece is mandating you to send E-Books and E-Invoices to their myDATA platform
By imposing the myDATA eBooks and eInvoicing requirements, the Greek IAPR tax authority can create online income and balance sheet statements for all businesses operating in Greece. In practice, the myDATA (Digital Account and Tax Applicatio) platform will use digital VAT Books and E-Invoices to validate and compare Greek companies’ VAT transactions with their counterparts’ transactions. As a result, the Greek tax authority is able to identify and prevent tax evasion, clerical errors, and fraud. This aligns with Articles 217-240 of the EU VAT Directive to lower the VAT gap of the EU member states, of which Greece has one of the largest VAT gaps, making this initiative a crucial directive.
On the long run, the initiative also aims to be more cost effective whilst reducing the dependency of physically storing and transporting documents, with the addition of more transparency within tax relevant transactions.
Another goal is to provide businesses with a digital platform, which makes it able to fulfil their tax obligations in an automated manner. Moreover, the platform makes it easy to connect with companies that have an automated computerized accounting system, such as SAP. Therefore, this legal requirement is a very important step in the digital transformation of the Tax Administration and its relationship with businesses.
It is not a big surprise that Greece has introduced their myDATA E-Books and E-Invoicing requirements. Currently, tax administrations all around the world, such as the IAPR tax authority in Greece, are using technology more than ever before to collect and analyze more data from taxpayers, often in real time or near real time. What began as a Business-To-Government (B2G) legislation first evolved in Latin America into a B2B initiative. Originally, Latin American businesses billed the government, but not each other, with e-invoices. Then, seeing an opportunity to expand a successful anti-fraud strategy to a much greater part of the economy, Latin American countries, led by Brazil and Mexico, spread e-invoicing into the B2B domain. In recent years, this trend towards a digital government has spread across the globe with Greece now picking up this initiative and imposing their own legal requirements for the electronic submission of VAT-related data to their NAV tax authority system. Other examples of similar legal requirements include SDI in Italy, SII in Spain, RTIR and EKEAR in Hungary, XRechnung and ZUGFeRD in Germany and many more country-specific requirements that are currently being developed.
Greece delayed their myDATA deadline to 1st April 2020 due to COVID-19
The deadline for compliance with the Greek myDATA E-Invoice and E-Books regulations was set for 1st January 2021, after postponing from the initial deadline on 1st October 2020. However, after having evaluated the preparedness of businesses as a result of COVID-19 and following requests from market participants, it was necessary that the first quarter of 2021 was offered as additional time for training and adaptation of companies to myDATA. The Greek AADE tax authority decided to provide taxpayers in scope with additional time by recategorizing the roll-out of the myDATA rules to a voluntary pilot program for 2021. This means that the remaining time before the deadline is used as a phase, in which you can voluntarily opt to report your VAT data of the first calendar quarter of 2021 (January – March 2021) electronically through the myDATA portal. The mandatory phase has instead been deferred to 1st April 2021, meaning that all businesses that keep accounting records according to the Greek Accounting Standards are required to submit the VAT-relevant E-Invoice and E-Books data to the IAPR myDATA platform. Note that data which is issued during the 1st quarter of 2021 still needs to be submitted to the myDATA platform no later than the 31st October 2021. Non-compliance with these legal requirements will be sanctioned with penalty fees.
In case you use SAP ECC or SAP S/4HANA to manage your Greek accounting processes, it is crucial to make the necessary SAP adaptions to ensure compliance with the Greek myDATA rules. Please click the following button or leave a comment in the Comments section below to request our demo of SAP Document Compliance for myDATA Greece and learn how we can help you with your own SAP compliance project.
Penalties for non-compliance with the Greek myDATA E-Books and E-Invoice regulations
As from 1st April 2021, the following penalties shall apply for non-compliance with the Greek myDATA E-Books and E-Invoice rules:
- Failure of registration:
- Late registration EUR 102,40
- Non-registration EUR 2.500
- 50% of non-paid VAT amount if failed to register during a tax audit (Reference to article 58A par. 3 of Law 4174/2013)
- Non- or late payment: interest payment (currently 8,76% annually or 0,73% monthly) calculated on the VAT.
- Non- or late submission of VAT returns: not less than EUR 500 for double entry accounting books or EUR 250 for single entry accounting books.
- Incomplete and incorrect VAT returns: 50% of VAT amount.
- Non-compliance with invoicing and accounting obligations: not less than EUR 500 for double entry accounting books or EUR 250 for single entry accounting books.
SAP Document Compliance to manage the Greek myDATA E-Invoicing and E-Books regulations in SAP ECC or SAP S/4HANA
In order to implement the Greek myDATA E-Books and E-Invoicing requirements in SAP, I recommend using the SAP Document Compliance Solution (formerly known as the SAP eDocument Solution). SAP Document Compliance is a strategic, integrated SAP solution that works with SAP ECC and SAP S/4HANA and that makes your SAP accounting processes 100% legally compliant with the Greek rules.
SAP has developed this solution not only to comply with the Greek myDATA requirements, but also to ensure compliance with many other country-specific legal requirements all over the world, such as SII in Spain, SDI in Italy, CFDI and Complemento de Pago in Mexico, RTIR and EKAER in Hungary, DIAN in Colombia, E-Invoicing and E-Archiving in Turkey, etc. All the implemented country-specific legal requirements can be easily managed with the SAP eDocument Cockpit that takes a central role in SAP Document Compliance. With SAP Document Compliance, you have an end-to-end solution that automatically generates the required XML files based on source information from your SD or FI billing documents and digitally signs the XML file, when required. SAP Document Compliance can be connected with SAP CPI or with 3rd party EDI middleware systems to manage all data transmission with the local tax authority systems (e.g. the myDATA platform from the Greek IAPR tax authority).
An additional benefit of using SAP Document Compliance is its flexibility. Several SAP BAdI’s (Business Add-Ins) are available to change the standard XML structure and PDF mapping, to change the e-mail content and the recipients, to partially automate the customer feedback process, etc. We have already adapted SAP Document Compliance to many different customer-specific cases. Please let me know in the Comments section below if you have a specific business requirement that needs to be implemented in your Greek SAP accounting process. I am happy to investigate how this can be integrated with SAP Document Compliance.
The SAP Document Compliance process flow for myDATA E-Books and E-Invoicing compliance in Greece
For the Greek myDATA requirements, SAP provides the SAP Document Compliance for Greece solution. The following graphic illustrates the different end-to-end process steps that are implemented in SAP Document Compliance to achieve compliance with the Greek myDATA regulations for E-Books and E-Invoicing:
- Once you have created an SAP SD or SAP FI billing document in your SAP ECC or SAP S/4HANA system, a related SAP eDocument is automatically triggered in the SAP eDocument Cockpit (EDOC_COCKPIT transaction).
- The SAP eDocument Framework retrieves the SAP eDocument data from the database and makes a call to deploy the Interface Connector.
- This connector calls the AIF_Proxy interface type that enables the system to make a connection with the SAP AIF Add-On (SAP Application Interface Framework).
- The SAP Application Interface Framework triggers the mapping of the transactional data into the by the Greek IAPR tax authority required XML format and saves the XML file.
- In a next step, SAP CPI (SAP Cloud Platform Integration) is called through an ABAP Proxy. SAP CPI establishes the communication with the IAPR myDATA platform and takes care of all data transmission through WebServices. In this step, also an alternative, 3rd party EDI platform can be used for all data transmission between SAP and the myDATA system.
- SAP Cloud Platform Integration then triggers an additional technical validation check to ensure compliance with the official Greek communication requirements. After a successful validation, the XML file is transmitted to the Greek myDATA platform via WebServices.
- SAP CPI receives feedback information from the myDATA platform and converts this information into a “consumable” format by decoding and mapping the results.
- In a next step, SAP CPI transmits the converted feedback information to the SAP AIF Add-On and to the SAP eDocument Cockpit, which will take care of updating the SAP eDocument. This updated information is then visible in your SAP eDocument Cockpit.
How PIKON can help you with your SAP compliance project for E-Books and E-Invoicing in Greece
With our Competence Center for Legal Requirements, we ensure that your SAP system and business processes comply with different country-specific legal requirements all over the world on the long run. We are a team of experts that combine SAP expertise and in-depth knowledge of the end-to-end legal processes and technical requirements of the Greek myDATA regulations and many other legal requirements. We have gathered this experience through our many SAP Document Compliance and local implementation projects all over the world, such as SDI in Italy, SII in Spain, CFDI and Complemento de Pago in Mexico, RTIR and EKAER in Hungary, XRechnung and ZUGFeRD in Germany, E-Invoicing and E-Archive in Turkey, DIAN in Colombia, etc.
We have also developed own compliance SAP Add-Ons for e.g. MTD VAT in the UK and the VAT Whitelist in Poland. Furthermore, we always keep an eye on new and changing legal requirements and inform our customers when action is needed. This ensures that your company doesn’t need to follow-up on all the legal requirements yourselves and you can concentrate on your daily business.
If you have any questions about the Greek myDATA E-Books and E-Invoicing regulations or about how we can help you achieve compliance in your SAP system, please ask me your questions in the Comments section below or feel free to request a web-meeting with system-demo by clicking on the button earlier in this blog post. I am happy to help you.