The myDATA mandate finally went live on 1 October 2021 for most taxpayers after several postponements (and lobbying for a further postponement).
The Greek authorities have stated that no penalties will be imposed for 2021 until relevant legislation is published. The primary goal of the authorities is to ensure all taxpayers are in a position to comply with the myDATA requirements, legal and technical, and can adapt to the new continuous transaction control (CTC) system.
Timeline for myDATA compliance
For 2020, myDATA compliance remains voluntary.
On 1 October 2020, myDATA was classified as voluntary scheme for 2020; except for taxpayers who, as of July 2020, opted for e-invoicing through a certified e-invoicing service provider. In cases of voluntary adoption via other transmission methods, e.g. ERP, companies could opt to send only data of the final calendar quarter of 2020 (October – December).
For 2021, myDATA becomes mandatory for certain taxpayers and transactions.
The mandate covers only income transactions. Expenses may be transmitted to myDATA anytime until 31 May 2022.
- The first phase of the mandate starts on 1 October 2021 and applies to taxpayers with double entry books and revenue, in financial year 2019, over 50.000 EUR as well as taxpayers with single entry books and revenue over 100.000 EUR.
- The second phase of the mandate starts on 1 November 2021 and extends to all other taxpayers.
For 2022, myDATA is expected to become mandatory for all.
- From 1 January 2022, the myDATA mandate extends to all data (summary and classifications) of revenue and expenses.
- All historical (income) data, i.e. data issued between 1 January – 30 September 2021 or 31 October 2021, must be transmitted to myDATA by 31 March 2022. In case of non-transmission of the above data by the invoice issuer, these may be reported by the recipient from 1 April – 30 April 2022 while the issuer may accept and classify such transactions by 31 May 2022.
- Accounting (adjustment) entries for revenue must be reported by the deadline of filing the annual income return of financial year 2021 (respective entries for expenses may be transmitted by the same deadline).
The myDATA framework seems to be taking shape in time for its scheduled full implementation next year. However, additional clarifications are still expected regarding certain matters, such as the transmission process of expense classifications by a certified accountant or the upgrade and interconnection process of Greek cash registers (Φ.Η.Μ) with myDATA.