Direct award and ΚΗΜΔΗΣ: how a Greek public lab buys consumables

What must a supplier provide, and a public lab post, for a small consumables purchase to be paid?

A small consumables purchase in a public laboratory is paid when the contracting authority has posted the right documents in ΚΗΜΔΗΣ and the supplier has issued an invoice that carries the ΑΔΑΜ of the award. If the posting, the ΑΔΑΜ or a supporting document is missing, payment stops, whether or not the consumables were delivered.

This article describes the paper trail of a direct award as the supplier and the buying laboratory meet it. It differs from the procurement of university laboratories, which has its own invoicing framework, and covers the general public-sector procedure. Ceilings, forms and deadlines change with amendments to the law, so they are read from the ΕΑΔΗΣΥ pages and not from secondary sources.

When a purchase is a direct award

Law 4412/2016, which transposed Directive 2014/24/EU on public procurement into Greek law, allows a contracting authority to award a contract directly when its estimated value does not exceed a set ceiling ^[2][4]. The figure cited in the sources for Law 4412/2016 is 30,000 euro excluding VAT, but the ceiling has been amended in the past and the legal framework for public contracts is being recast, so the current amount and the provision that sets it are confirmed from the consolidated ΕΑΔΗΣΥ text on the day you draft or accept the award ^[2].

The ceiling refers to the estimated value of the contract excluding VAT, not the amount on one invoice. For that reason the authority calculates the value from the whole need and not from the first order. An annual requirement for consumables that exceeds the ceiling cannot be divided into small orders each of which stays below it.

What ΚΗΜΔΗΣ is and what is posted

The Central Electronic Public Procurement Registry (ΚΗΜΔΗΣ) is the registry in which the details of public contracts are recorded, and ΕΑΔΗΣΥ publishes its user guidance ^[1][3]. For a direct award the contracting authority posts three basic documents, in the order the guidance sets.

The ΑΔΑΜ on the invoice

The ΑΔΑΜ (Αριθμός Διαδικτυακής Ανάρτησης Μητρώου, the registry posting number) is the number ΚΗΜΔΗΣ assigns to each posting ^[1]. The contracting authority tells the contractor, and the contractor writes it on the invoice and, where asked, on the delivery note. The administration checks that the invoice matches the award before paying, and an invoice with no ΑΔΑΜ is returned for correction. The exact requirement and where the reference sits on the document are set by the invitation and the authority's guidance, and are confirmed before delivery, not after.

For the other invoice elements, namely tax number, description and VAT, the usual invoice rules apply and are set out in the article on invoicing and intra-Community acquisition. The public sector adds one comparison: the description and quantities on the invoice must match the offer.

What supporting documents the authority asks for

The documents requested from a supplier are set out in the invitation and depend on the authority and the amount. It is common to ask for proof that the supplier is up to date with tax and social-security obligations and is lawfully established, together with its offer and, where needed, a solemn declaration that no grounds for exclusion apply. Do not take the list for granted: read the posted invitation and ask for clarification before offering ^[3].

• The offer, with a price per item and a total excluding VAT.
• Certificates of tax and social-security clearance, valid on the date the invitation specifies.
• Proof of registration in the relevant registry or chamber, where requested.
• A solemn declaration on exclusion grounds, where provided for.
• Technical leaflets or safety data sheets for the consumables, where the description requires it.

The offer is the document on which the whole award rests, and it deserves care. It lists each item with the full description that will later appear on the invoice, the pack, the quantity per pack, the unit price excluding VAT and the delivery time. If the offer says «vials» and the invoice says «2 ml glass vials with stopper», the administration will ask for an explanation. One consistent wording from offer to invoice saves a lot of correspondence.

For consumables that carry an expiry date or a quality document, the invitation should say what minimum remaining shelf life the laboratory accepts on delivery and what documents accompany the lot. What the invitation does not specify is hard to require after the award. The supplier asks before offering, and the laboratory writes into the invitation what it will check on receipt, so that accepting or rejecting a delivery has a clear basis.

Splitting: why it is not allowed

Splitting means dividing a single need into several small awards so as to avoid a stricter procedure. Public procurement law prohibits it, and the contracting authority must calculate the estimated value from the whole need ^[2][4]. For a supplier the practical point is that a series of orders to the same laboratory over the year can be examined as one purchase, and that the responsibility lies with the contracting authority, not the supplier. The laboratory therefore plans its needs over an annual horizon.

Payment timing and the procurement file

Payment times in the public sector are set by the contract and by the payment framework the authority applies, and they usually run from receipt of the goods and complete supporting documents, not from the invoice date. A missing document therefore delays payment by as long as it takes to supply it. The real deadline is read from the invitation or the contract.

The laboratory keeps one procurement file per award. Receipt of the consumables is evidenced by a delivery note that quotes the ΑΔΑΜ and the lot numbers, so the invoice, the note and the quality documents all match; see also documentation and batch traceability.

• The invitation to submit an offer, with the posting date and the ΑΔΑΜ.
• The supplier's offer and supporting documents.
• The award decision and the contract or equivalent document.
• The delivery note with lots and the confirmation of receipt.
• The invoice with the ΑΔΑΜ and the proof of payment.