Progress with the implementation of due specific commitments and relevant continuous commitments (*) given to the Eurogroup ( Annex to the Eurogroup statement , 22 June 2018)

Commitment State of play and next steps

(*) Fiscal. Achieve a primary surplus of 3.5% of GDP over the medium-term. On 15 October 2021, Greece submitted the Draft Budgetary Plan for 2022, which expects the primary deficit monitored under enhanced surveillance to decrease from 7.6% of GDP in 2021 to 1% of GDP in 2022. The General Escape Clause remains active in 2022. The General Escape Clause allows for a temporary departure from the budgetary requirements, including Greece’s fiscal targets monitored under enhanced surveillance, provided that this does not endanger fiscal sustainability in the medium term.

Public financial management. Complete the chart of accounts for the central administration by implementing the fund and functional classifications in the 2022 State budget. It is noted that the implementation of the fund classification is subject to a provision of technical assistance. Extend the Chart of Accounts reform to General Government entities by mid-2022. The mid‑2021 specific commitment to implement the first level of functional classification has been completed and the development of its second level (a mid‑2022 specific commitment) is on track. The first level of functional classification for both ordinary and public investment budget was finalised in October 2021 and will be presented in November 2021 in the context of 2022 budget along with a simplified version of the economic classification of the public investment budget. The authorities are progressing with the development of the second level with the assistance of a working group consisted of representatives from Hellenic Statistical Authority, Ministry of Finance and Ministry of Development and Investment. The second level of functional classification is expected to be completed in time by April 2022 and presented in the annual update of the Medium Term Fiscal Strategy.

(*) Arrears. The authorities will implement the arrears clearance plan and avoid the accumulation of new arrears. Complete the implementation of reforms identified by the Hellenic Court of Auditors. The gap to the target to materially clear the non‑pension arrears, which was due in June 2021, has marginally narrowed. The stock of net non-pension arrears reached €555 million in September 2021, €251 million above the targets set in the March 2021 clearance plan. This is slightly lower than the July 2021 outcome reported in the 11th report (a stock of €564 million). Deviation from the targets are observed across subsectors except for arrears on the payments of tax refunds. The most problematic sectors remain the extra-budgetary funds, local governments and hospitals. The divergence results from a number of factors, most notably delays in implementing the actions agreed in the March 2021 clearance plan, accumulation of new arrears and a smaller-than-expected impact of other initiatives. The authorities have taken actions to remedy the situation with a view to materially clear the non-pension arrears by the end of 2021. These actions aim to further improve the liquidity of some entities and are expected to help the clearance of their arrears in the coming period. A capital increase took place in the public entities in the defence sector in October 2021 under the precondition that they will clear their arrears by the end of the year while the public transport companies will receive during November 2021 the amounts owed to them in relation to the conduct of public sector obligations. In addition, the regular instalments of hospitals’ grants were brought forward and an additional grant of €115 million was paid to hospitals in October 2021. Regarding local governments, the mechanism for the prevention of arrears accumulation entered into force in October 2021 and the first results are expected to materialise in the December 2021 arrears data. The mechanism envisages that local governments submit a list of their remaining arrears accompanied by a justification for their non-payment and transfer the amounts to a special account at the Consignment Deposits and Loan Fund earmarked for arrears payment. The clearance of pension arrears also continues to underperform. According to September 2021 data, the stock of net pension arrears remained stable at €360 million compared to €359 million in July 2021 presented in the last report. This translates to a deviation from the target of €251 million. The main drivers behind the underperformance are the delays in the implementation of actions which would increase the pace of pension awards, as well as a higher number of new pension application compared to what was expected in the March 2021 clearance plan. The authorities currently expect pension arrears to be fully cleared only by mid‑2022. Following the delays in meeting the targets, the authorities appointed a Project Manager from the private sector who, in cooperation with the dedicated Task Force already established at the ministry, is mandated to coordinate the efforts to fully clear the stock of unprocessed pension applications. The main new initiative taken by the authorities is the creation of a centralised facility in September 2021, with cross-functional teams focused on resolving complex cases and aiming at process optimization and creation of a vertical pension award structure, which will be able to deal with all problematic cases of the previously scattered branches of the Single Social Security Fund (e-EFKA), including the Agricultural Insurance Organization, Self-employed Social Security Fund, and the main Social Insurance Institution for the private sector (IKA). Concerning earlier actions, delays occurred in the training of certified lawyers and accountants, envisaged to support the processing of pensions. They should become fully operational in November 2021. Other initiatives to the acceleration of pension awards include legislative simplification of procedures and the implementation of smart Business Intelligence tools and analytics and the new automation in pension processing. A monthly monitoring mechanism will be set up to support the achievement of the agreed targets. The objective of this detailed monitoring is to obtain a better overview of the progress made on the implementation of agreed actions, detect early any deviation and understand the reasons for the accumulation of new arrears. This mechanism will involve a monthly exchange on the basis of a policy action table concerning both pension and non-pension arrears. Implementation of the recommendations of the Hellenic Court of Auditors and the simplification of fiscal procedures continued as planned. The vast majority of reforms identified by the Hellenic Court of Auditors have already been completed. Additional recommendations were finalised by October 2021, notably the ones related to the update of Ministry of Development’s IT system (e-PDE). Finally, the simplification of procedures related to the payment of grants to legal entities was adopted as planned. The law amendments of the regulatory framework for the conflict of interest of accounting officers and the payment of certain types of costs through simplified procedures were submitted to the parliament and are scheduled to be voted until the end of November. These initiatives are expected to further help the prevention of new arrears.

Tax administration. Make the end-to-end IT collection systems fully operational. The testing phase of the end-to-end IT collection system has been successfully completed, but its full operationalisation is now expected to be achieved only by April 2022. The Independent Authority for Public Revenue is in parallel training its staff and the IT platform arrangements with the Ministry of Digital Governance will be in place by January 2022, in order for the new collection system and its web portal to be fully operational by April 2022.

Tax policy. Greece will undertake a nationwide valuation exercise of property tax value based on market values and will update property tax values for ENFIA and other taxes fully in line with market values. The authorities have committed to make a reform the ENFIA property tax based upon the new wider property tax base with payments starting in March 2022. The new property tax zonal values for all property taxes will enter into force on 1 January 2022. The Authorities are still working on the finalisation of a revenue-neutral ENFIA property tax reform. They have provided a timetable to bring forward the 2022 property tax assessment with first instalments made in March 2022.

(*) Health care. The authorities will complete the full offsetting and collection of the clawback by June every year for the previous calendar year. Despite long delays in the past, clawback collection has resumed and currently progresses almost regularly for clawbacks accumulated in 2021, with larger difficulties for the ones accumulated in the past. In particular: ·As regards 2021, the newly introduced methodology to collect clawbacks for services providers on a rolling basis is bearing fruit and approximately 20%, i.e. 60 million of the clawback of 2021 has already been collected after three months from the start of its implementation. ·Collection of clawback from 2020 is behind schedule for pharmaceuticals and has not started for health services providers, due to a combination of technical constraints and new administrative procedures. For pharmaceuticals, the new measure allowing for clawback discounts against companies’ investments in research and development of pharmaceuticals has delayed the finalisation of the instalment plans (at present, as a result, approximately €230 million, i.e. one third, are not yet collected or covered by instalment plans); for other providers, an increase in the ceilings for certain categories called for a recalculation of the amounts due, so instalment plans are not yet in place for the full amount of 2020, which is €280 million. Based on the information provided by the authorities, the Ministerial Decision for the amended 2020 ceilings for providers, needed to enable the collection, will be issued shortly. The level of the clawbacks remains high, at approximately €700 million and €300 million for pharmaceuticals and services providers, respectively. A minor decrease in the clawback for pharmaceuticals has been achieved, mostly due to the recent exclusion of vaccines from the budget under expenditure ceiling. This underlines the need for a more consistent implementation of existing structural measures in place and for additional supporting measures. A stronger negotiation and health technology assessment (HTA) capacity, together with more numerous and compulsory protocols would support a faster reduction.

Health care. Greece will ensure the rollout of the primary health care system, in particular by opening all 240 primary health care units. The reform of the primary health care is currently still on hold, with little progress over the past months partly on account of the pandemic. The planned revision of the legislative framework for the primary health care system, announced already in 2019, has seen further delays. Apart from the severe challenges posed by the pandemic and the additional time that has become necessary in light of the recent government reshuffling, the reform has seen delays due to a lack of an adequate stock of family doctors. The additional staff that have recently been recruited will allow for the opening of about 60 new primary health care units, i.e. slightly less than a half of the total number of outstanding planned primary health care units. The authorities announced the intention to step up the efforts to increase the workforce that could better support the transition towards a stronger primary health care and committed to presenting a draft law by December 2021 with a view to adopting it by January or February 2022. Within the same date, in time for the publication of the 13th enhanced surveillance report, the authorities committed to issuing the secondary legislation needed to deliver on the key principles of gatekeeping and patient registration.

Health care. Achieve a 40% share of centralised procurement in total hospital expenditure by mid-2022. The new legislative framework is close to adoption and procurement activities are progressing towards the mid-2022 milestone of 40%. According to the information provided by the authorities, the legislative framework for the centralised health procurement body (EKAPY) is expected to be adopted shortly, with submission to parliament planned by 22 November and the vote expected within the first ten days of December, following the conclusion of the public consultation in early November. In parallel, procurement activities are progressing, after having reached the 30% procurement target in the past months. By the end of 2021, the authorities plan to launch additional tenders worth of approximately €280 million, which will contribute to reaching the next target of 40% in mid-2022.

Social welfare. Apply to all disability benefits the new approach for disability determination based on both medical and functional assessment. Adoption of secondary legislation for a trial Personal Assistance scheme that will apply the new approach for disability determination is expected for early 2022 allowing for the implementation of the trial scheme in March 2022. Following the adoption of primary legislation on 1 October 2021 that introduced a Personal Assistance scheme for persons with disabilities with an initial trial implementation period (law 4837/2021 published in Government Gazette No 178/A), the authorities are currently working on the secondary legislation that is expected to be completed by early 2022. This legislative framework will allow using a new approach for disability determination based on both medical and functional assessment to assess benefit eligibility for the purpose of the trial Personal Assistance scheme. The new functional assessment scheme will be used directly for in-kind benefit decisions from March 2022 when the trial scheme will start.

Social welfare. Complete the set-up of the single pension fund EFKA. The opening of remaining directorates of e-EFKA over the territory is progressing well, however the IT infrastructure is not mature yet. The authorities reported that the target for the current review is almost met, with nearly 90 directories opened since end-October 2021. Based on these reports, openings appear to be even ahead of schedule and are planned for completion around mid-December 2021. The interconnection of databases and IT systems of previous funds is not yet complete, but these outstanding issues are currently being tackled.

(*) Financial stability. Greece will continue to implement reforms aimed at restoring the health of the banking system, including non-performing loans resolution efforts by ensuring the continued effectiveness of the relevant legal framework (i.e. household and corporate insolvency, out-of-court workout, non-performing loans sales, e-auctions) and taking all necessary actions to this effect. Greece will implement the comprehensive action plan on household insolvency with the objective to eliminate the backlog of cases, including the process of pending applications. The decision on liquidation or extension of the mandate for the Hellenic Financial Stability Fund will be taken by mid-2022. Greece will continue the relaxation of capital controls in line with the published roadmap. The functioning of the insolvency framework is now supported by the relevant electronic infrastructure, with the sole exception of the early warning electronic platform, currently in testing mode. All the necessary secondary legislation has been adopted (with two of the joint ministerial decisions on the early-warning procedure pending publication in the Official Journal), with the exception of five ministerial decisions that concern the sale and lease-back mechanism. Regarding the relevant IT infrastructure, the electronic platforms are now interconnected with the IT systems of the banks, complementing the platforms for the debt restructuring of medium and large businesses, the bankruptcy of households and businesses, the out-of-court workout, the insolvency registry and the verification of the status of vulnerable debtors. As for the early warning platform, which will enable the fully automated handling of applications by creditors and the operationalisation of the early warning IT mechanism, it is currently in testing mode and is expected to be fully operational as of 1 December 2021. While the out-of-court workout scheme has attracted a strong interest, with 35 753 applications initiated as of the beginning of October 2021, only 512 applications or 1.5% of those initiated had been finalised and submitted by that date. The majority of the applications submitted concerned at least one denounced loan towards a credit institution, although approximately 9% of the applications was linked with loans with less than 30 days past due. On the whole, the first indications from the functioning of the out of court workout mechanism appear positive in terms of uptake, while the risk of abuse seems to be contained for the time being. The concessionary process for the setup of the sale and lease-back entity has been further delayed, although this does not seem to have affected the implementation of the insolvency framework. According to the latest update from the authorities, the final step following a three-stage concessionary process, i.e. the ratification of the conclusion of the selection procedure by the parliament, is now not expected to be taken earlier than mid-December 2022, i.e. with a 9-month delay in comparison to the previously agreed date (end-March 2022). The call for the expression of interest is expected to be launched by 15 December 2021 and is due to be completed, with the preselection of eligible candidates, by mid-February 2022, to be followed by the conduct of the competitive dialogue and the bidding phase. According to the relevant provision of the Insolvency Code, the procedures for the protection of vulnerable debtors under the sale and lease-back mechanism will commence upon operationalisation of the entity. The clearance of the backlog of household insolvency cases, a specific commitment, is progressing but at a slow pace. The authorities are preparing to take relevant steps to support the process, with a view to clearing the backlog largely within 2022, which remains challenging. The latest data received by the authorities confirm that the processing of household insolvency cases is advancing, effectively filtering out ineligible applications, albeit at a slower pace than initially expected. Up to 30 October 2021, 49 031 applications were submitted, of which 39 739 were subsequently validated and 9 552, or 19.5% of the total, were assigned a new hearing date. Of these, approximately 60% have been appointed within the third and fourth quarters of 2021, while the remaining ones have been appointed predominantly in the first half of 2022, with the rest extending as far as the second quarter of 2024. The high number of pending applications that have yet to receive a hearing date is partly attributable to pandemic-related reasons but mainly a result of the limited case-processing capacity of courts, and delays the processing of the backlog. In total, as of 30 September 2020, there are 61 798 cases pending, including cases that were heard but pending a final decision. To address chronic infrastructure and/or staffing insufficiencies, the authorities reported being in the process of developing an action plan for the secondment of judges to speed up the processing by the courts facing difficulties, which will be submitted for approval by the relevant judicial authorities and should start being implemented as from January 2022, allowing for the clearance of the backlog largely within 2022. Moreover, in order to facilitate the monitoring of new hearing dates scheduling, the authorities adopted a ministerial decision ( ) making compulsory the uploading of hearing date information onto the relevant electronic platform. The authorities committed to provide monthly updates on the progress with the clearance of the backlog. The recent adoption of an extensive revision of the Code of Civil Procedure is expected to accelerate the delivery of Justice and increase the efficiency of enforcement proceedings, including the conduct of e–auctions. The amendments to the Code, introducing the features described in the previous enhanced surveillance report, were adopted on 11 October 2021 ( ) and will enter into force on 1 January 2022. The conduct of auctions has resumed and is picking up. According to the data provided by the authorities, nearly 40% of the 5 561 e-auctions planned for the second quarter of 2021 were concluded, while the rest were suspended. A very small number of auctions was cancelled. In the third quarter of 2021 (which includes the August recess), of 3 414 out of 4 600 planned e-auctions were concluded, 1 163 were suspended and 23 were cancelled. However, even in the case of successful e-auctions, the majority of the auctioned properties still end up in the banks’ and servicers’ real estate property portfolios, despite some signs of increased interest from third parties. Work is ongoing regarding the introduction of enhancements to the e-auctions platform. The two working groups referred to in the previous enhanced surveillance report are expected to hand in their proposals to the Ministry of Justice by January 2022, for the identification of potentially needed legal amendments to be adopted and implemented. Their report will also include a list of the enhanced features that are already available but currently not operational due to the lack of online availability of information (mainly regarding energy certification of properties and building code violations) along with a timeline for their activation as soon as possible. The authorities also reported on the development of an electronic platform allowing notaries to obtain online information from the engineers’ professional associations, regarding building violations and other technical data of interest to prospective purchaser, as well as from municipalities and land registries and/or cadastral offices. The platform is currently running on a pilot basis and is expected to be operational by end-November 2021. The authorities also reported on developing an electronic platform aggregating and providing information to judicial bailiffs, in order for them to determine the price of seized properties, and to notaries involved in enforcement procedures. Additional information on the timeline of this initiative will be provided in the next enhanced surveillance report. Despite an acceleration of payments with regards to the backlog of called state guarantees in the third quarter of 2021, the pace of clearance still falls short of expectations. Although the number of claims examined and the value of payments has increased compared to previous quarters, it is considerably behind the targets set for the timely clearance of the backlog. This underperformance is partly explained by the gradual learning process of new personnel, the necessary replacement of seven employees and a temporarily low average value of claims examined with respect to corporate loans. In order to meet the high targets set under the current clearance plan and increase the processing rate, the authorities have decided to i) increase the number of new permanent personnel to be hired in late December 2021 to thirty five from thirty employees and ii) to put in place, in cooperation with one systemic bank, the electronic exchange of all necessary information on old, pre-2015 cases, not included in the e-repository, for which there is a pending lawsuit by that bank. Nonetheless, despite these initiatives, the target for 2021 as a whole had to be revised once again downwards. The authorities have committed to provide monthly updates on the pace of clearance and, based on the performance in the remainder of the year, will assess if further corrective actions would be required to ensure that the targets for 2022 and 2023 are met in full. Discussions are progressing on the future of the Hellenic Financial Stability Fund, for which the Greek authorities now expect the legal amendment to be adopted later in the year. The reform of the Fund’s legal framework is expected to focus on the duration, governance, divestment strategy and special rights of the Fund. Adoption of the legal amendment is now expected to take place by the end of the year. The recently adopted amendment of article 27 of law 4172/2013 will further facilitate sales and securitisations of non-performing loans by smoothening the amortisation of the related deferred tax assets.

(*) Labour market. Greece will safeguard competitiveness through an annual update of the minimum wage in line with the provisions of Law 4172/2013. Secondary legislation setting out the new statutory minimum wage level to apply from 1 January 2022 is expected for December 2021 in line with the respective legislation. The process for a possible update of the statutory minimum wage started in March 2021, following a one-year freeze due to the pandemic, and involved consultations with research, scientific and social partners, and independent experts. The outcome of the consultation led the Minister of Labour and Social Affairs to recommend to the Cabinet of Ministers a 2% increase in the statutory minimum wage (from €650 to €663 per month for workers of up to three years of work experience) to apply from 1 January 2022. Following the endorsement of the latter body at end‑July 2021, the respective Decision by the Minister of Labour and Social Affairs is expected for December 2021.

Investment licensing. Greece will finalise inspection legislation. Whilst the authorities made welcome steps on the commitment to finalise inspection legislation, specifically in the last remaining area of environmental protection, one element remains pending. Specifically, they adopted primary legislation to amend sanctions and enforcement powers of inspecting authorities in the said area, in effort to make the environmental inspections framework more transparent, friendly to businesses and conducive to self-compliance. However, secondary legislation to detail the enforcement management model that is necessary to facilitate a harmonised approach in the application of the enforcement system is still under elaboration. This would step would complete the environmental inspections reform.

Investment licensing. Greece will finalise the simplification of investment licensing procedures in the agreed remaining sectors. Substantial progress is recorded on the simplification of legislation in the agreed sectors, with the majority of the remaining elements now in place. Namely, all secondary legislation foreseen to operationalise the set of simplified licensing legislation adopted in April and June 2021, respectively, has been adopted. In the case of the economic activities in the tourism sector, the completion of technological enhancements in relevant IT tools has been set as a precondition for the simplified processes to come into force. Completing this work would help remove hurdles in a sector that is vitally important for Greece. In parallel, the authorities recently adopted further legislation to reform the economic activities relating to education that were not been included in the scope of the previous simplification rounds. These concern private institutes for vocational training, colleges, private tutoring centres, and language centres. Nonetheless, some delay is observed in the adoption of enabling secondary legislation for the simplification of licensing procedures for the said activities, which is now expected by January 2022.

Cadastre. Greece will fully establish the cadastral agency and complete 45% of cadastral mapping, with a view to ratifying the complete cadastral mapping and forest maps. The cadastral mapping continues to progress steadily. The collection of property rights has reached 83% of the total property rights of the country. Out of these, 52% are at the stage of public consultation or at a later stage out of which 34% are in operating cadastre. Regarding the transition to the new entity, 43 cadastral offices out of 95 have opened and the corresponding mortgage offices have been closed. The rate of new openings will increase when the on-going recruitment of the 77‑strong transition team will be done by the end of the year. The tender documentation for the digitalization of the mortgage offices was approved by the governing board of 6 October 2021 and is ready to launch. The road map that was agreed in July 2018 has been practically completed. The authorities have agreed to produce a quarterly report on the completion rate of the cadastral mapping and the transition to the new entity, divided by region. The ratification of the forest maps has encountered further substantial delay. The forest maps that were produced by the Hellenic Cadastre need to be ratified in order for the cadastre to be complete. About 50% of the country has ratified maps; another 45% of the maps were uploaded for public consultation (for the citizens to detect errors and raise objections) in February 2021. The maps were due to be ratified by April 2022 after an extension of the objection period. Nevertheless, the authorities decided to grant a further general extension of the period for objections by another four months (and twenty day for residents abroad) in October 2021. The authorities justified the extension by the impact of the fires of summer 2021, which destroyed 130 000 ha of forest land and are stretching the capacity of the forest services. They also noted that delay was partly due to a court case that was eventually dismissed by the Council of State and a major reorganisation of the forestry services that is currently underway. While these factors are acknowledged, they would justify a targeted exemption in specific areas affected by the fires or in particularly complex cases. The repeated horizontal extensions put the timely completion of the cadastre at risk. The authorities noted that the remaining forest maps will be ratified by mid-2022, which is subject to significant implementation risks.

Energy. With a view to completing reforms in the energy sector, implement the measures agreed as part of the joint assessment on the NOME auction system. The Hellenic Republic has transposed the antitrust remedy into Greek law. The measures adopted by the authorities allow the competitors of the Public Power Corporation (PPC), the Greek state-owned electricity incumbent, to purchase more electricity on a longer-term basis, which closes this long standing anti-trust case. This completes the reform of the energy sector, which was a specific commitment ().

(*) Hellenic Corporation of Assets and Participations (HCAP). The Strategic Plan of HCAP will be implemented on a continuous basis. The Corporation finalised the work on the update of its strategic plan. The Strategic Plan entails the strategic goals and the strategic levers of the Corporation. The Plan sets out a structured emphasis on the Corporation’s role as an active shareholder, in response to the Ministerial Guidance provided to the Corporation by the authorities in early 2021. As the Corporation continues its evolution and moves into the implementation of the new Plan, it remains critical for all parties to uphold the independence of the Corporation in line with its founding Law as this will contribute to the achievement of its mandate and the continued positive performance in terms of value creation of the assets of the Greek state. The Plan entails the Corporation acting as an investor in the Greek economy and as a reformer of the state-owned enterprises under it and broadly its transformation to a Public Wealth Fund, and sets out various overall Key Performance Indicators by which to track the Corporation’s performance. These Key Performance Indicators include overall portfolio performance indicators, which is an important step forward in developing financial accountability for the Corporation, as well as key social and sustainability indicators. The Plan also includes a set of changes that are needed to modernise the legal framework applicable to state-owned enterprises, which in turn are essential for the success of the Strategic Plan. A further feature is that the Plan includes benchmarks for state-owned enterprises performance, by comparing the Corporation’s state-owned enterprises with similar companies elsewhere in Europe, which should assist in objectively evaluating the progress of state-owned enterprises in delivering operational and financial outcomes. The Plan was approved by the Board of Directors of the Corporation and it is expected to be subsequently approved by its General Assembly by end‑November 2021. The Steering Committee set up under the Coordination Mechanism concluded its work on the preparation of a performance contract for the Athens Urban Transport Organisation (OASA). Following an agreement on the methodology to estimate the amount of compensation for the delivery of special obligations (that is, providing free or discounted transfer for specific groups), the Athens Urban Transport Organisation finalised the drafting of the performance contract, which was discussed and approved by the Steering Committee at the beginning of November 2021. The pending actions for its execution are expected to be completed by end‑November. The performance contract is a further important step forward in clarifying the financial compensation of the State for costs that accrue to Athens Urban Transport Organisation for the delivery of public policy, and toward the Organisation’s operational improvement, independence and financial sustainability. Moreover, the authorities consider that the performance contract for the Athens Urban Transport Organisation could become the pilot for other performance contracts in the public sector. As a general reform effort, performance contracts are intended to clarify the financial relationship between state-owned enterprises and the state, and link financial transfers by the state to the performance of specific policy goals. This should help the public understand whether state-owned enterprises are appropriately compensated and whether the state receives good value for money. The Corporation has, within the framework of the preparation of its Strategic Plan and as noted above, identified further changes that are needed to address legal and other impediments to the modernization and commercial operation of the state-owned enterprises in its portfolio. These changes include increasing the responsibility and accountability of state-owned enterprises’ boards and management for key corporate decisions and corporate performance, as well as a range of other changes related to human resources, governance, synergies and internal audit. These changes are all considered essential for state-owned enterprises to transition to high-performing companies delivering quality products and services, and financial performance. Addressing them is a key priority for the success of the Corporation in its endeavour towards ensuring that state-owned enterprises under the Corporation become operationally and financially independent, doing business in a customer-centric way and in line with private sector principles. The Corporation has presented a set of necessary changes in the Strategic Plan, and the authorities intend to prepare draft legislation in the coming months, including as noted below. The authorities continued with the work on the modernisation of the institutional framework for state-owned enterprises. Following the mapping of the state-owned enterprises and other public entities into 6 main categories based on a number of criteria, including the share of the state’s participation, fiscal consideration and board appointment procedures, the authorities are working on recommendations for each category of enterprises with a view to enhancing the state-owned enterprises' efficiency and performance, and rationalising the State's participation. The authorities expect a first draft of legislation to codify, improve and modernise the current legal framework applicable to state-owned enterprises to be ready for public consultation by end January 2022. The Public Real Estate Company (ETAD) will require more time to elaborate a comprehensive strategy to achieve an ambitious target yield across its portfolio. While the Public Real Estate Company has taken steps in relation to specific assets to improve their performance and has seen success on those projects, there is still significant work to be done by the company to achieve systemic improvements across the portfolio as a whole, and progress towards delivering an overall yield for its portfolio that is comparable to peers. Turning this situation around, and delivering value from the real estate portfolio, is a critical responsibility of the Corporation. With regard to the transfer of the eligible real estate assets included in the 2018 package to the Public Real Estate Company, following the completion of the screening process by the General Secretariat for Tax Policy and Public Property, a more detailed review by each relevant Ministry was launched in September 2021. Following this exercise, a final list of assets for transfer will be developed. The authorities clarified the timetable for the process with completion of the verification process by end‑January 2022 and the eventual transfer of the eligible assets by end‑March 2022.

HCAP. Complete the transfer of the Olympic Athletic Centre (OAKA) to HCAP. The authorities continued the work on the development of the master plan. With the assistance of external consultants, the authorities are preparing feasibility, market and financial studies, which will provide input to the plan for the future use of the facility as a civic park, leveraging its core athletics heritage, and adding various mixed-uses aimed at increasing the site’s amenity to citizens and tourists and at ensuring the financial sustainability of the facility. This analytical work is expected to be completed by the end of the year. It is important that the overall strategy for the site ensures that the site can generate enough organic revenue to ensure the financial sustainability of a high quality civic facility over the long term, covering not just maintenance, but expected improvements and capital investments.

Privatisation. The Asset Development Plan will be implemented on a continuous basis. With a view to swiftly attracting investment to support a sustained economic recovery, complete the transactions on HELPE, Egnatia, DEPA commercial, regional ports of Alexandroupolis and Kavala, AIA shares, EYDAP and EYATH. Complete the transactions on the regional ports Igoumenitsa and Kerkyra, PPC, DEPA infrastructure and Kavala underground storage. By mid-2022, complete the transactions on a number of other regional ports, based on the recommendations of the consultants of TAIPED. The updated Asset Development Plan, which constitutes the privatisation programme and lays down the next steps for the transactions included in it, was approved by the Board of the Hellenic Republic Asset Development Fund and endorsed by the Government Council for Economic Policy on 12 November 2021. Progress with specific transactions since the last report has been as follows: Egnatia: Good progress was made in the tender process for the long-term concession of Egnatia over the past months. The selection of the preferred investor was made on 26 August 2021, as reported in the 11th enhanced surveillance report, for a financial offer comprising of an upfront payment of about €1.5 billion and an annual payment amounting to 7.5% of the annual total gross revenue of the concessionaire. The authorities plan to proceed with the completion and operation of the toll stations as well as with the completion of the works and the licensing of all tunnels. Within this framework a specific timetable for the completion and operation of each one of the last toll stations (7 lateral and one frontal) as well as for the licencing of each one of the remaining 16 tunnels has been elaborated by Egnatia SA in October. Close monitoring will continue. Regional ports of Alexandroupolis and Kavala: The draft Concession Agreement for the port of Alexandroupolis is expected to be uploaded on the virtual data room for comments to the prequalified investors by end‑November 2021. The draft of the Sub Concession Agreement for the port of Kavala has been released to prequalified investors for their comments on 24 September 2021, and their comments were submitted on 18 October 2021. However, there is a pending issue that needs to be resolved before proceeding to the binding offers phase for the port of Alexandroupolis, namely the conclusion of the expropriation of private properties in the upland zone area of the port; the amounts concerned for the compensation of the expropriated land are to be determined by the competent courts. The hearing before the Court took place on 22 October 2021 and the decision was issued on 10 November, while next steps in the process are to be decided by the competent Ministries. Regional port of Igoumenitsa: The Concession Agreement document is expected to be finalised by the beginning of December 2021 and to be subsequently uploaded on the virtual data room to the pre-qualified investors for comments. The pending issue on the determination of the upland zone of Igoumenitsa port will be fully resolved as it will be clearly specified in the concession agreement, and thus the tender process can proceed. Regional port of Heraklion: The completion of the assessment of the Investors Expressions of Interest and the short listing of the prequalified parties for the binding offers phase is expected to be completed by end‑November 2021. Public Gas Corporation (DEPA) Infrastructure: The tender process is proceeding well. As already reported in the 11th enhanced surveillance report, the selection of the preferred investor took place on 9 September 2021 for a financial offer of €733 million. This corresponds to about €476 million for the 65% stake of the Fund in DEPA Infrastructure. The file was submitted to the Court of Audit for approval on 26 October 2021 and its approval was given on 11 November 2021. Public Gas Corporation (DEPA) Commercial: The Fund decided to extend the suspension of the binding offers phase of the tender at least until end‑December 2021, so as to have more clarity on the outcome of pending issues. Underground Natural Gas Storage (UGS) South Kavala: Based on the envisaged timeline of the tender, submission of binding offers is expected in the first quarter of 2022. The first draft Concession Agreement is expected to be shared with prequalified investors by end‑December 2021. The pending issue on clarity of the tariff setting framework, is expected to be resolved via the issue of the decision of the Regulatory Authority for Energy by end‑November 2021. Gournes Heraklion: On 15 October 2021 four interested parties submitted binding offers for the exploitation of part of the former American military base of Gournes in Heraklion, Crete (a beachfront land plot of 345 567 square meters located 13 km from the airport and 16 km from Heraklion). The development of Gournes is described by many as a smaller Hellinikon project. The selection of the preferred investor is expected by end‑November 2021. As reported in the previous reports, some transactions had to be delayed following a significant fall in the assets’ capitalisation value or the impact of the pandemic on the level of economic activity. This applies to the Hellenic Petroleum and the sale of 30% of Athens International Airport.

Public administration. Complete the integrated HR Management System (digital organigram for all public entities and link with single payment authority). Job descriptions have been completed for 81% of all posts, which constitutes a key element in the establishment of an integrated human resources management system. The authorities are expecting to have job descriptions in place for all posts by January 2022, which would close this commitment. The appointment of the Permanent Secretary at the Ministry of Education and Religious Affairs remains pending. The authorities informed that legal provisions to facilitate the completion of this appointment would be adopted by end-November 2021. These legal provisions are expected to be consistent with the principles of the Executive State Law in terms of delegation of signature powers to civil servants.

Legal codification. In view of enhancing legal certainty and access to law through legal codification, adopt the Labour Law Code and Code of Labour Regulatory Provisions. Work on the codification of labour legislation continues. A high-level legal scientific Committee has been set up under the Ministry of Labour and Social Affairs to work on the legal codification of the Labour Law Code and Code of Labour Regulatory Provisions that is now progressing in close collaboration with the Central Codification Committee. A first codified draft is expected to be submitted to the Secretariat General for Legal and Parliamentary Affairs in the first quarter of 2022. The Central Codification Committee will proceed with the review of the codified legislation as a priority with a view to adopting it as soon as possible.

Justice. In the context of implementing the Three-Year Action Plan on Justice, implement the electronic filing of legal documents throughout the Courts, having completed the tendering procedure. In the context of implementing the Three-Year Action Plan on Justice, complete phase II of the establishment of the e-justice system (OSDDY-PP). Further progress has been made with regard to the specific commitment on electronic e-filing. More specifically: (I)Regarding the implementation of e-filing in civil courts, the authorities reported further progress on the digitisation of court procedures. In the context of the digitization of judicial procedures, the authorities resolved to develop new electronic platforms relating to (a) the processing of small claims disputes, (b) the filing of third-party statements in the context of the enforcement proceedings, (c) the registration of consensually granted collateral in the context of loan agreements and (d) the issuance of payment orders. The authorities have drafted working documents regarding all four projects and formed corresponding working groups; upon receipt of feedbacks by the judges participating in the working groups regarding implementation questions and the need for the adoption of legislation, a maturity assessment will be made and further actions will be planned. A Joint Ministerial Decision allowing for the operationalisation of the e-divorce platform will be adopted by end-December 2021. (II)Regarding the implementation of mandatory e-filing in administrative courts, the tendering procedure for the extension of functionality and the pilot phase for the interconnection with the Legal Council of State database are advancing. Following the completion of the procurement competition launched June 2021, the managing committee of the Council of State awarded the contract to the successful candidate on 28 September 2021 and the contract was signed on 22 October 2021, initiating a four-month period for the implementation of the contract and a subsequent two-month period for the completion of the pilot phase and the full operationalisation of the project (expected in April 2022), whereupon the e-filing of all kinds of documents and submissions will be available. Furthermore, the pilot phase of the project for the interconnection between the IT systems of the Legal Council of State and the Council of State is ongoing and is expected to be concluded on 20 December 2021, making thus the project fully functional and operational. The preparatory stage for the launch of the call for bids for the integrated case management system for civil and criminal cases (‘OSDDY-PP’) has incurred additional delay, making the previous target for awarding the project in the first quarter of 2022 unattainable. The draft call for proposals was submitted to public consultation on 1 November 2021; following the expiry of the public consultation period on 16 November 2021, the finalised call for proposals is expected to be launched by 10 January 2022 (as opposed to end-September 2021 and end-October 2021 respectively according to the previous enhanced surveillance report). The European institutions expressed concern about the delay in the tender and encouraged the authorities to take the necessary actions to ensure the efficient conduct of the process going forward.