1
                                                                     Exhibit 5.1


                             [Letterhead SAP AG]





June 20, 2001


SAP Aktiengesellschaft
Neurottstrasse 16
69190 Walldorf
Federal Republic of Germany

             Re:  REGISTRATION STATEMENT ON FORM S-8

Ladies and Gentlemen:

       I am the General Counsel of SAP Aktiengesellschaft Systeme, Anwendungen,
Produkte in der Datenverarbeitung (the "Company"), a stock corporation
organized under the laws of the Federal Republic of Germany. This opinion is
being furnished to you in connection with the preparation and filing with the
Securities and Exchange Commission under the Securties Act of 1933, of a
Registration Statement on Form S-8.

       The Registration Statement covers 30,000 Ordinary Shares, without par
value, of the Company, which may be issued and sold in the form of American
Depositary Shares ("ADSs"), each representing one quarter of an Ordinary Share,
under the SAP Canada, Inc., Employee Discount ADR Purchase Plan (the "Discount
Plan").

       I have examined the Registration Statement and copies, furnished to me,
of the Discount Plan and such other documents, records, certificates and other
instruments of the Company as in my judgment are necessary or appropriate for
purposes of this opinion.

       I have assumed the genuineness of all signatures, the authenticity of
all documents submitted to me as originals and the conformity with originals of
all documents submitted to me as copies.

       Based on the foregoing, I am of the following opinion:

  1.   The Company is a stock corporation (Aktiengesellschaft) duly organized
  and validly existing under the laws of the Federal Republic of Germany.

  2.   The Ordinary Shares have been duly authorized and, when issued and paid
  for in accordance with the terms of the Discount Plan, will be validly issued,
  fully-paid and non-assessable.


       The foregoing opinion is limited to the laws of the Federal Republic of
Germany, and I express no opinion as to the laws of any other jurisdiction.

       I am furnishing this opinion solely for the Company's benefit. It may
not be relied upon by any other person or entity without my prior written
consent. Nothing in this opinion shall be construed to create any liability for
the Company.

       I consent to the use of this opinion as an exhibit to the Registration
Statement. In giving this consent, I do not thereby admit that I am acting
within the category of persons whose consent is required under Section 7 of the
Securities Act of 1933 or the rules and regulations of the Securities and
Exchange Commission thereunder.


                                                  Very truly yours,


                                                  Michael Junge
                                                  General Counsel