EN   EN 
 
 
 EUROPEAN  
COMMISSION   
Brussels, 23.2.2022  
SWD(2022) 50 final  
 
COMMISSION STAFF WORKING DOCUMENT  
Enhanced Surveillance Report - Greece, February 2022  
Accompanying the document  
COMMUNICATION FROM THE COMMISSION  
Enhanced Surveillance Update - Greece, February 2022  
{COM(2022)  78 final}   
 
1 
 Progress with the implementation of due specific commitments and relevant continuous commitments (*) given to the Eurogroup 
(Annex to the Eurogroup st atement , 22 June 2018)  
Commitment  State of play and next steps  
(*) Fiscal.  
Achieve a primary surplus of 3.5% of GDP over the medium -term.  The 2022 budget, voted in December 2021, expects the deficit 
monitored under enhanced surveillance to reach 1.2% of GDP in 2022, 
which is aligned with Commission 2021 autumn forecast . The fiscal 
policy setting planned for 2022 takes into account the continued application 
of the general escape clause in 2022. The General Escape Clause allows 
for a temporary departure fro m the budgetary requirements, including 
Greece’s fiscal targets monitored under enhanced surveillance, provided 
that this does not endanger fiscal sustainability in the medium term. A full 
update of the fiscal forecast will be prepared in spring in the con text of the 
assessment of the 2022 Stability Programme.  
Public financial management.  
Extend the Chart of Accounts reform to General Government entities 
by mid -2022.  The work on developing the 2nd level of functional classification (mid -
2022 specific commitment) is ongoing. It is expected to be finalised by 
end of April and published in the annual update of the Medium Term Fiscal 
Strategy. The development of the 2nd level of functional classificatio n is 
assisted by a working group consisted of representatives from Hellenic 
Statistical Authority, Ministry of Finance and Ministry of Development 
and Investment.  
(*) Arrears.  
The authorities will implement the arrears clearance plan and avoid 
the accumu lation of new arrears.  
Complete the implementation of reforms identified by the Hellenic 
Court of Auditors.  The stock of non-pension arrears has decreased significantly since the 
last report  but remained above the target . In December 2021, the stock 
of non -pension arrears amounted  to €238 million , down by €316 million 
compared to its September level . The gap to the December  target set in the 
March 2021 clearance plan  narrowed to  €73 million . The decrease can 
mainly  be attributed to the actions undertaken in the previous period to 
accelerate the clearance of arrears . In particular, t he capital increase to 
support public entities in the defence sector and payments to public 
transport companies in relation to the conduct of public sector obligations  
 
2 
 Commitment  State of play and next steps  
increased their liquidity and resulted in a significant decrease of their 
arrears. In addition, the envisaged measures in the sector of public hospitals  
contributed to the clear ance of  the biggest part  of hospitals ’ arrears. On the 
other hand, the results from the application of the mechanism for the 
prevention of arrears accumulation in local governments are yet to be 
shown. Some payments  already took place in December 2021 but the full 
impact is expected in the coming months  in view of the time lag observed 
between the activation of the mechanism and the actual clearance of 
arrears.  The non -pension arrears are expected to be materially cleared by 
end of February  2022 .  
The clearance of pension arrears also shows some positive 
developments . The stock of pension arrears in December  amounted to 
€267 million, down by €93 million compared to the stock in September. 
This translates to a limited deviation from the target set in October 2021 of 
€17 million.  The observed improvement  is a result of a number of factors, 
including the implementation of the IT system for the processing of pension 
claims (‘Atlas ’), the introduction of automated procedures in the pension 
processing workflow, and the use of smart Business Intelligence tools and 
analytics. On the other hand,  some other  initiatives are behind schedule . 
This concerns in particular  the efforts  to involve in certified lawyers and 
accountants  into the processing of pensions, where delays occurred partly 
due to lower-than-expected rates of passing qualification tests and the 
belated delivery of software automations , which would allow new types of 
pensions  claims (i.e. self -employed, public sector, etc.)  to be processed by 
the IT system . The authorities reiterated t heir intention to fully clear the 
pension arrears by mid -2022, as agreed in the twelfth report . 
The implementation of the recommendations made by the Hellenic 
Court of Auditors and the simplification of fiscal procedures are on 
track . The vast majority of reforms identified by the Hellenic Court of 
 
3 
 Commitment  State of play and next steps  
Auditors have already been completed and the authorities continue their 
efforts to finalise the remaining ones. Notably , the authorities have 
amended  the regulatory framework for the fixed ex penses , which allows 
for the simplification of payment and control procedures  and will help the 
prevention of new arrears . In addition, t he authorities have prepared the 
Ministerial decision which simplifies the framework of the multi -annual 
obligations and is expected to be adopted  with a delay,  by end of February.  
Tax administration.  
Make the end -to-end IT collection systems fully operational.  The new IT collection system for the Independent Authority for Public 
Revenue has encountered  delays  due to the contractor not submitting 
a final version of all parts of the IT system on time, as a result the full 
operationalisation is now expected to take place by September 2022 . 
Some progress has been made, as t he Independent Authority , in 
cooperation with the Ministry of Digital Governance , has set up an IT 
platform  that will host the new IT system (‘EISPRAKSIS’). While its full 
operationalisation was planned by end -April 2022 , the Independent 
Authority still expects a number of its central and special decentralised 
services, including the directorate of collection and refund, the collection 
operation unit and  the Attica debt collection centre, to start using its core 
functions (e.g. debtor and debt management, risk analysis and management 
of insolvency procedures ) by the n. The final submission by the contractor 
of the complete IT system is scheduled for  end- June 2022 . By 
end-September 2022 , the complete IT system will be fully operational and 
utilised throughout the Independent Authority, including its local tax 
offices  with a collection function , with some 1  100 staff having received 
training and been assigned as users . 
Tax policy.  The authorities have reached the final stage of preparation of the 
ENFIA property tax reform allowing for the 2022 bills to be sent out  
in April 2022 . The application of the new market -related property tax 
values will widen the tax base and improve the fairness and economic 
 
4 
 Commitment  State of play and next steps  
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.  efficiency of the property  tax. An agreement has been reached on the 
detailed tax rate structure and fiscal cost of the reform that will be legislated 
in February 2022 . Owing to technical factors,  the tax assessment  will take 
place with a minor delay in  April 2022 .  
(*) Health care.  
The authorities will complete the full offsetting and collection of the 
clawback by June every year for the previous calendar year.  The collection of the 2020 clawback is progressing according to 
schedule for pharmaceuticals and providers.  The administrative 
procedure for the collection of the 2020 clawback for pharmaceuticals  and 
for providers has been completed, fulfilling the milestones for the current 
review. For pharmaceuticals, t he authorities have finalised the instalment 
plan for 2020 , which has been notified to the companies . For providers, the 
instalment schemes were finalised during January . A total of €35 millions 
is not covered by instalments and will be collected  in one single payment .  
There is overall good progress in both categories for  2021 and the new 
collection methodology for providers is proving effective. The 
calculation  of the pharma ceuticals  clawback for the first semester of 2021 
was completed timely and the quantification stands at €425 million , rather 
stable compared to the same semester of the previous year ( €435 million) . 
The new methodology implemented in 2 021 for the collection of the 
providers  clawback is delivering good results, although with some delays.  
The target of 50% of the 2021 to be collected by the time of the current 
review will be fully met only in March. However, considering the delay in 
the intr oduction of this new system, progress so far can be considered 
satisfactory.  
Health care.  
Greece will ensure the rollout of the primary health care system, in 
particular by opening all 240 primary health care units.  The planned adoption of the revised  legislative framework  for primary 
health care  was postponed to April  2022  and also the openings of the 
additional primary healthcare units ( TOMY ) is delayed beyond the 
current review . The reform envisages patient registration and gatekeeping 
based on a system of financial incentives, whereby patients who are not  
 
5 
 Commitment  State of play and next steps  
register ed with a family doctor or do not follow  the referral pathway would 
bear increased cost s. Providers would be reimbursed per registered patient 
based on age -band -specific coefficients reflecting the expected intensity of 
care required. The model may also envisage means -tested entry fees into 
the primary health care system. Lastly, n ew contracts for family doctor s 
contracted by t he Single Healthcare Fund (EOPYY)  will be implemented 
as part of the package . There are delays in the planned opening of the 
60 additional primary healthcare units , which shifts beyond the current 
review.  
Some key parameters of the system  are still under definition . The 
outcome of the implementation of this model hinges on elements such as 
the size of the financial incentives and on the compulsory registration of 
the whole population, as l imited cost differences  between self -referring and 
being referred by a family doctor  may not succeed in discouraging self -
referrals . There is also an intrinsic risk to equality in access to healthcare, 
linked to the implementation of a system based on  financial incentives. 
Similarly, the element of entry fees may represent  a barrier to access, 
depending on its final design.  Lastly, the stock of public family doctors is 
still inadequate and it s improvement may be affected by the revised 
contracts for family doctors  contracted by the Single Healthcare Fund . 
Health care.  
Achieve a 40% share of centralised procurement in total hospital 
expenditure by mid -2022.  The procurement activity by the  centralised health procurement body 
EKAPY is on track for the 40% target to be achieved by end-April 
2022. Following the  adoption of the revised legislative framework in 
December of last year, the centralised health procurement body EKAPY  is 
progressing towards the recruitment of procurement specialists making use 
of the increased flexibility provided by the new law. EKAPY will meet its 
staffing needs through a combination of fixed -term contracts , of permanent 
positions and secondments. According to the existing timeline of 
procurements, the objective to reach a value of at least €320 million by end -
 
6 
 Commitment  State of play and next steps  
April 2022 in terms of completed tenders  (i.e. signed contracts)  appears 
within reach . This amount represents the 40% of total hospital spending 
that can be subject to centralised procurement, i.e. €800 million.  In fact, 
current estimates  suggest that  contracts of a value between €350 million 
and €370 million could be signed by mid -2022, which may however 
include  some from tenders launched in 2021.  
Social welfare.  
Apply to all disability benefits the new approach for disability 
determination based on both medical and functional a ssessment.  Secondary legislation is expected to be adopted by end -March  2022  
allowing the application of a new disability assessment approach for 
granting personal assistance benefits based on both medical and 
functional criteria. A Joint Ministerial Decision by the Minist ers of 
Labour and Social Affairs and Health setting out the new disability 
assessment approach to apply for social assistance benefits  in April 2022 
is underway and is expected to be adopted by the end of March . At 
operation level, an agreement has been reached between the Ministry of 
Labour and Social Affairs and the Ministry of Digital Governance’s TA 
framework contract ‘Information Society S.A.’ that will undertake the 
implementation of the personal assistance scheme.  
Social welfare.  
Complete the set -up of the single pension fund EFKA.  The authorities completed the setup of the Single Pension Fund 
(EFKA ), fulfilling the commitment under enhanced surveillance . The 
completion of the setup of the Single Pension Fund  was a key commitment 
to the Eurogroup  monitored under enhanced surveillance . The objective of 
the reform was to improve the efficiency of the pension system and further  
reduc e its administrative costs . To this end , the Supplementary Pension 
Fund (ETEAEP) and EFKA were merged into e -EFKA  in 2020 . In parallel, 
the authorities pursued  an ambitious consolidation and digitalisation of all 
pension system data to speed -up the processing of pension applications. 
Important steps in th is consolidation proce ss included the operational 
integration of the funds into e -EFKA and the setting  up of a new structure 
for the local offices of e -EFKA . In June 2021, the authorities provided a 
 
7 
 Commitment  State of play and next steps  
timeline for the opening of the network of local offices , which would mark 
the completion of the organizational setup , while the finalisation of the IT 
infrastructure is progressing well . While originally planned for t he first 
quarter of 2022 , the opening of local units was finalized ahead of schedule 
in December 2021. Over and above the efforts envisaged under enhanced 
surveillance, the authorities recently put into public consultation a bill that 
is expected to further support the operation of e -EFKA . The bill envisages 
incentives for increasing productivity  of staff , while strengthen ing the 
accountability of its employees and provid ing more flexible recruitment 
and procurement  rules . 
(*) 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 insolvenc y, 
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 t he 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 early warning platform completed the 
electronic infrastructure of the new insolvency framework and only 
the set -up of the sale and lease -back mechanism is still pending . All the 
necessary secondary legislation has been adopted, with the  exception of 
five ministerial decisions that concern the sale and lease -back mechanism. 
The early warning platform became fully operational at the start of 
December, complementing the existing platforms for the debt restructuring 
of medium and large busin esses, the bankruptcy of households and 
businesses, the out -of-court workout, the insolvency registry and the 
verification of the status of vulnerable debtors. The out -of-court workout 
scheme attracted initially strong interest by debtors, which was follow ed 
by a more moderate but constant flow of new application initiations in the 
platform. However, out of the 43  795 applications initiated as of end -
December 2021, only 393 applications or 0.9% of those initiated had been 
submitted and not recalled by that date, while another 28 141 applicants are 
waiting for the collection of data from institutional creditors. As a response 
to this low percentage of applications completed so far, the authorities are 
preparing a new round of workshops, including dedicated in -depth training 
sessions to familiarise users with the workings of the platform. In parallel, 
 
8 
 Commitment  State of play and next steps  
the authorities intend to engage in March in a dialogue with stakeholders 
on the initial results from the implementation of the new framework.  
The concessionary p rocess for the setup of the sale -and-lease -back 
entity is expected to be  launched in Febr uary, following past delays. 
According to the latest update from the authorities, the final step following 
a three -stage concessionary process, i.e. the ratification o f the conclusion 
of the selection procedure by the parliament, is now not expected to be 
taken earlier than mid -February 2023, while the full operationalisation of 
the new entity is not expected before end -March 2023. The call for the 
expression of interes t is expected to be  launched in February 2022  and is 
due to be completed, with the preselection of eligible candidates, by mid -
April 2022, to be followed by the conduct of the competitive dialogue and 
the bidding phase.  
An interim scheme is being considered by the authorities to ensure a 
smooth transition until the sale -and-lease -back entity commences 
operations and mitigate litigation risks.  The Insolvency Code  provides  
for the protection of vulnerable debtors under the sale -and-lease -back 
mechanism. In view of the delays with the establishment  of the mechanism , 
an interim scheme is being designed, according to which the state will 
provide financial support to vulnerable debtors until the initiation of 
operation of the sale-and-lease-back entity  or for a maximum period of 15 
months . This financial support will take the form of a partial state subsidy 
on the servicing of loans, encumbered with the primary residence of 
vulnerable debtors that are certified as such under the condition s of the new 
insolvency code and have been declared bankrupt, or whose primary 
residence is about to be auctioned.  Putting in place strong safeguards will 
be instrumental in counter ing unintended use of the scheme  and mitigate 
legal risks.   
 
9 
 Commitment  State of play and next steps  
The assignment of new hearing dates for  pending household insolvency 
cases is picking up but clearance of the backlog still falls short of 
expectations  and is not envisaged before end -2023 . The authorities 
have taken steps to increase processing capacity. The latest set of 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  (1). Given that, 
apart from pandemic -related reasons, the high number of unprocessed 
applications are mainly a result of the limited case -processing capacity of 
courts, the authorities reported the secondment of 14 judges to courts facing 
difficulties, of whom twelve have taken up their posts , with the remaining 
two expected to follow  suit in March and April 2022 respectively . 
Moreover, in order to further accelerate the proceedings by appointing 
hearing dates as close to the present as possible, the authorities confirmed 
that the adoption of amendments to the internal working regulations of  
courts facing the most acute situation is being considered , with a view  to 
allow ing the inscription of up to 60 household insolvency cases in the daily 
docket in stead of the current maximum of 30 cases . 
The recent entry into force of numerous revisions of the Code of Civil 
Procedure is expected to have a positive impact on the case -processing 
capacity in general and increase the efficiency of enforcement 
proceedings. Given that the amendments to the Code entered into force on 
1 January 2022, it will not be possible to assess their impact before the end 
                                                           
(1) Out of the 49  031 submitted applications, 43  104 were validated by 31 December 2021 (representing a 4% increase since November 2021) and 
15 703, or 32% of the total, were assigned a new hearing date (representing a 20% increase since November 2021), while 32 820 cases are yet 
to receive a hearing date. Of all cases that have received a hearing date, 14  562 (92.7%) are scheduled for a hearing within 2022, 1  081 (6.9%) 
within 2023 and 60 (0.4%) up to September 2024.  In addition to these cases, the authorities have also reported 1  245 instances where only an 
interlocutory decision (i.e. postponing the issuance of a final decision for need of additional evidence) has been issued by the court and a new 
hearing is still pending, with 945 cases planned to be heard in 2022, 259 in 2023 and 41 in 2024.  
 
10 
 Commitment  State of play and next steps  
of the current judicial year in mid -June 2022. Regarding enforcement 
proceedings, the procedure for the automatic adjustment of the r eserve 
price in the context of the conduct of auctions should eliminate significant 
delays in the relevant proceedings. The authorities committed to take 
statistical surveys of the relevant procedural streams and report to the EIs 
in the course of the next  enhanced surveillance mission.  
The conduct of auctions continues to increase since its resumption in 
September 2021.  According to the aggregated data for 2021 provided by 
the authorities, out of the 23  073 auctions planned, 11  318 (49%)  were 
concluded, while 11  658 (50.5%) were suspended. A very small number of 
auctions was cancelled. 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, de spite some signs of increased interest from 
third parties.  
Work is advancing regarding the introduction of enhancements to the 
e-auctions platform and the adoption of legislation is planned to 
remove perceived legal impediments. The two working groups ref erred 
to in the previous two enhanced surveillance reports  were merged and the 
relevant proposals will be submitted to the Ministry of Justice on a date yet 
to be defined  by the authorities . Finally, the authorities reported being in 
the process of adoptin g legislation to expressly expand the territorial scope 
for the conduct of auctions by Athens notaries in the neighbouring area of 
Piraeus, thus removing a perceived impediment to such schedulings; the 
relevant provision is expected to be adopted by end-March 2022 . 
The authorities remain committed to meet the agreed targets 
concerning the processing and clearance of the backlog of called state 
guarantees  by mid-2023 and mid-2024 , respectively . The revised action 
plan of the authorities envisages the full examination of accumulated called 
loan guarantees by the third quarter of  2022 for corporate claims and 
 
11 
 Commitment  State of play and next steps  
second quarter  2023 for natural persons’ claims, followed by the 
completion of all payment s by the second quarter 2024.  There was a 
material increase in the number of claims examined and the value of 
expected payments in fourth quarters  2021, but the rate of increase was 
lower than expected. Moreover, while the processing of claims has 
accelera ted, this is only partially reflected in actual payments, resulting in 
regular revisions to the intermediate quarterly targets. Meeting the set 
targets for 2022 will require almost a threefold increase in the claims 
examined per quarter compared to what was achieved in the fourth quarter  
2021 and a more than commensurate increase in payments. This increase 
will depend on the smooth execution of planned recruitment  and training 
of the additional 35 employees, which is not expected to be completed 
before the end of the first quarter of 2022. The authorities have committed 
to provide monthly updates on the pace of clearance and will assess if 
further corrective action s would be required.   
Discussions progress ed well  on the future of the Hellenic Financial 
Stability Fund . 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 in the coming months and will be reported on in the  14th report .  
(*) Labour market.  
Greece will safeguard competitiveness through an annual update of 
the minimum wage in line with the provisions of Law 4172/2013.  Following the 2% increase in the gross statutory minimum wage that 
came into effect on 1 January 2022, discussions are underway for a 
possible second adjustment of its level in May 2022 in light of the recent 
price hikes . Secondary legislation setting out the new gross statutory 
minimum wage le vel from 1 January 2022 was adopted on 27 December. 
The new level brings about a 2% increase  compared to its level on 
1 January 20 19 when it was last changed (e.g. from €650 to €663 per month 
on a 14-month  basis or €773.5 per month on a 12 -month basis for workers 
 
12 
 Commitment  State of play and next steps  
of up to three years of work experience). A possible second increase in the 
gross statutory minimum wage is expected to take place in May  2022  
following an amendment of Law 4172/2013  that sets out the relevant 
revision process . The  legal amendment shorten s the timeline of the 
consultation process that will apply in 2022 only (from February -July to 
January -April) allowing for any change in the minimum wage to take place 
already on 1 May 2022 . The process itself and its various steps , including 
the established consultations with research, scientific and social partners 
and the involvement of an independent Committee  of economic experts  
have remain ed unchanged.  See the section on macroeconomic 
developments for further assessment.  
 
Investment licensing.  
Greece will finalise inspection legislation.  Secondary  legislation for the inspection reform in the last remaining 
area of environmental protection  has not been finalised in time for this 
review but is expected to be adopted shortly . The authorities are 
finalising secondary legislation to enable the activation of the enforcement 
management model , which  is necessary to facilitate a harmonised approach 
in the application of enforcement. Adoption of this last piece of legislation , 
which ha s been delayed due to the necessary consultations to ensure 
constitutional conformity of the reform,  is now expected shortly , as the 
consultations have recently been completed . This will m ark the complet ion 
of the e nvironmental inspections  reform  and the commitment .  
Investment licensing.  
Greece will finalise the simplification of investment licensing 
procedures in the agreed remaining sectors.  The authorities successfully completed the commitment to finalise the 
simplification of investment licensing in the agreed sectors.  The 
authorities completed the last step through  the adoption of the secondary 
legislation for the simplification of licensing procedures for education 
activities, i.e. private institutes for vocational training, colleges, private 
tutoring centres and language centres.  Complet ing the technical setup of 
the new simplified processes for all recently reformed activities  would 
allow for a swift implementation  of the simplified procedures . This reform 
 
13 
 Commitment  State of play and next steps  
has led to streamlined licensing requirements and has reduced the extent of 
ex-ante control currently imposed for several economic activities on the 
basis of a risk -assessment approach.  In addition to the abovemen tioned 
activities related to education, the reform covered the  areas of transport and 
transport -related services, social welfare,  tourism,  physical well -being, 
personal and health services, leasing of maritime leisure equipment, 
lifeguard training, livesto ck installations, aquaculture, veterinary clinics 
and pet breeding  and trading.  With support from the EU’s Recovery and 
Resilience Facility, the reform will be further extended to new economic 
activities, including canteens, internet rooms, organization of  conventions 
and trade shows, child day -care activities, social care housing facilities for 
the elderly and disabled, tourist ports and ski resorts . A new licensing 
framework will also be developed in line with the principles of the reform 
for non-therapeutic spas and massage centres, artificial tanning units, and 
storage of boats in land areas.   
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 and the transition to the full establishment of 
the Hellenic Cadastre  continued  to progress in the past three months.  
The tender for the digitalization of the mortgage offices has been launched 
and offers were received on 1 1 January 2022. The collection of property 
rights has reached 84% of the total property rights of the country. Out of 
these, 35% are in operating cadastre and 1 9% in public display, which 
means that 54% of the country’s total property rights a re at the stage of 
public consultation or at a later stage. It is expected that 60% of total 
property rights will be in operation or publicly displayed (uploaded) by 
end-April 2022. This figure will reach 71% in October 2022.  
The ratification of the last 5 0% of forest maps will start in May 2022 
and will be completed by July 2022.  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 
 
14 
 Commitment  State of play and next steps  
February 2021. These maps were due to be ratified by April 2022. The 
authorities have granted a n extension of the objections period of four 
additional months in October 2021. The extension was justified by the 
impact of the wild fires of summer 2021 which destroyed  130 000 ha of 
forest land and stretched  the capacity of the forest services  which 
additionally triggered a major reorganisation of the services.  According to 
the revised plan, it is expected that by July 2022, 95% of the forest maps 
would  be ratified and 96% would be achieved by October 2022.  The 
ratification  of the forest maps  is necessary for the completion of the 
cadastral mapping.  
Regarding the tr ansition to the new entity, 9  cadastral o ffices (out of 
17) and 38 branches (out of 7 5) have opened and the  corresponding 
mortgage offices have been closed.  Opening of new offices continues at 
a rate of two per month and it is estimated that by April 2022, 55 -57 
cadastral offices  and branches  will be in operation. However, the rate of 
further openings may be affected by a lack of managerial staff . Recruitment 
of 28 specialists for the positions of Heads of Cadastral offices was 
launched in January 2022 through the High Council for Selection of  Staff 
(ASEP ). The recruitment process is expected to last about a year, which 
could  affect the  timely  completion of the transition.   
(*) Hellenic Corporation of Assets and Participations (HCAP).  
The Strategic Plan of HCAP will be implemented on a continuous 
basis.  The strategic plan was approved by the General Assembly on 
31 January 2022 and started to be implemented by the Corporation.  
The Plan sets out the top -level key performance indicators by which  the 
Corporation will track its performance, as well as detailed actions for the 
Corporation to act  as an investor and a reformer in the state -owned 
enterprises in its portfolio.  Within the framework of the enhanced 
engagement of the Corporation in its subsidiaries, it  is planning to monitor 
closely the alignment of the business plans of the subsidiaries to the 
Strategic Plan, including the close monitoring of the set for each 
 
15 
 Commitment  State of play and next steps  
state-owned enterprise  key performance indicators. Key for improving the 
performance of the state -owned enterprises under the Corporation is the 
adoption of a set of changes that are needed to modernise the legal 
framework applicable to state -owned enterprises. The necessary ch anges 
are set out in the Strategic Plan. They include enabling state -owned 
enterprises’ boards to exercise the typical responsibilities of public limited 
companies (sociétés anonymes) , including in relation to staffing and 
internal organisation, as well as  strengthening internal controls and 
utilising synergies. The changes are expected to be reflected in the 
forthcoming legislation setting out broader modernisation of the legal 
framework applicable to state -owned  enterprises (see dedicated paragraph 
below) . 
Shortly before the closure of this report, the Council of State provided 
its decision relating to the Corporation’s ownership of the majority 
stakes in the water utilities of Athens and Thessaloniki.  The Council of 
State ruled in February 2022 the transfer of these stakes to the Corporation 
in 2018 unconstitutional. The decision and its implications for the 
Corporation’s portfolio is currently under assessment . 
The Corporation has begun implementing th e updated strategic plan, 
in particular in relation to asset valuations.  It has begun the process of 
tendering advisors to provide valuations of all assets to give a reliable 
valuation of the whole portfolio. For state -owned enterprises this valuation 
is expected to  be completed by the end of 2022. For the Public Real Estate 
Company (ETAD), which comprises the main part of the valuation given 
its extensive real estate portfolio, the valuation is scheduled for completion 
by the end 2023 – though the process will be structured to provide initial 
actionable information soon after the process begins.  
The Corporation finalised updates to the Investment Policy and this 
was approved by the shareholder on 31 January 2022 . The Investment 
 
16 
 Commitment  State of play and next steps  
Policy will be supplemented by a Technical Supplement covering technical 
matters, which is expected to be finalised by end -February.  
Following the conclusion of the work of the Steering Committee set up 
under the Coordination Mechanism on the preparation of a 
performance contract for  the Athens Urban Transport Organisation 
(OASA), the competent Government Committee approved the 
performance contract, which was subsequently signed by the Athens 
Urban Transport Organisation and the competent ministries on 2 
December 2021.  The performance  contract is intended to clarify the 
financial relationship between the Athens Urban Transport Organisation 
and the state and link financial transfers by the state to the performance of 
specific policy objectives. Budgetary appropriations have been made by  
the Ministry of Infrastructure and Transport for the implementation of the 
contract in 2022. The next step for the full implementation of the contract 
is the issu ance of a joint ministerial decision that would make possible the 
payment on a monthly basis,  in 12 instalments of the budgeted amount. The 
joint ministerial decision is expected to be issued by end-February.  
Also in relation to the Coordination Mechanism, the Statements of 
Commitments of each state -owned enterprise will now need to be 
updated fol lowing the approval of the strategic plan . This is expected 
during the first quarter of 2022. The Statements of Commitments set out 
key objectives for state -owned enterprises as agreed between the 
state-owned  enterprise and the Corporation, and will need t o be updated to 
reflect the strategic priorities set out in the strategic plan.  
The authorities prepared components of a first draft of the legislation 
for the modernisation of the institutional framework for state -owned 
enterprises. The draft legislation aims at the codification, improvement 
and modernisation of the current legal framework applicable to the 
state-owned enterprises inside and outside the Corporation. The draft 
 
17 
 Commitment  State of play and next steps  
legislation is divided in two sections (i) a section on pub lic limited 
companies in which the state has at least 50% of the share capital but which 
are not held by the Corporation and (ii) a section on the indirect subsidiaries 
of the Corporation. The institutions look forward to a constructive 
engagement with the  authorities in the final elaboration of the specific 
legislation, following the sharing of the draft legislation with the 
institutions. The Corporation has specified a set of reforms to the 
framework in its Strategic Plan that are all necessary for the ef fective 
functioning of the enterprises in the Corporation's portfolio.  
 
There has not been material progress in improving the manag ement  of 
the real estate portfolio. The holistic strategy from the Public Real Estate 
Company (ETAD ) aimed at accelerating  the development of the 
company’s assets remains pending. The Public Real Estate Company has 
continued its efforts  to improve the performance of specific assets and has 
seen some success on those projects. However, systemic improvements 
across the portfoli o as a whole , with a view to  delivering an overall yield 
for its portfolio that is comparable to peers , are not evident . Turning this 
situation around, and delivering value from the real estate portfolio, is a 
critical responsibility of the Public Real Est ate Company and key to the 
success of the Corporation. To achieve this turnaround, it is fundamental 
for the Public Real Estate Company to be viewed as, and operate like a 
private sector real estate manager. The valuation exercise that will unfold 
over the  coming 18 months is also intended to create a clear basis for 
performance measurement and improvement.  
With regard to the transfer of the eligible real estate assets included in 
the 2018 package to the Public Real Estate Company, a working group 
has been set up to accelerate the process of final verification of the 
eligible for transfer assets and resolve potential issues . The working 
group is composed of representatives from the General Secretariat for Tax 
 
18 
 Commitment  State of play and next steps  
Policy and Public Property, the General Secretar iat for Coordination, the 
Hellenic Corporation of Assets and Participations and the Public Property 
Company (ETAD ). The final verification process is expected to be 
concluded by end -May 2022 and the eventual transfer of the eligible assets 
by end -June 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. A study setting the guidelines for the financial sustainability of the 
facility, that 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 increasi ng the site’s amenity to citizens and tourists 
and at ensuring the financial sustainability of the facility, is expected to be 
finalised by end-February. Separately, the authorities are preparing a tender 
for a detailed feasibility study (including a relev ant business plan) based 
on the guidelines and strategy depicted in the consultants’ preliminary 
study  under finalisation , looking at issues such as market depth in order to 
evaluate the financial feasibility of the various uses under consideration.  
This f easibility study/business plan is expected in March 2023.  It is 
reiterated that it is crucial that the overall strategy for the site ensures that 
the site can generate enough revenue to ensure the financial sustainability 
of a high quality civic facility o ver 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, The Government Pending Actions List was updated by the Fund in 
January 2022.  Prog ress with specific transactions since the last report has 
been as follows:  
Egnatia: The authorities reiterated their commitment 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. In line with the submitted 
during the last review timetable, the  authorities launch ed the construction 
 
19 
 Commitment  State of play and next steps  
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 infrast ructure 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.  works for two lateral toll stations (Chalastra) in mid -February  2022 , and 
the construction works on four additional toll stations (three lateral and one 
frontal) continued. Pending is the launching of the construction in the last 
two lateral toll stations , whereby the technical resolution of an open issue 
needs to be decided.  In total,  17 out of 1 8 frontal toll stations and 3 1 out of 
40 lat eral toll stations  are currently in operation . With regard to the 
licensing of the remaining 16 tunnels under category E (i.e. excluding the 
transport of dangerous cargo), a study has been finalised in January 2022, 
providing clarity as to what additional  works will be  needed.  By end -April 
2022, it is expected that there will be the completion and operation of one 
frontal and three lateral  toll stations, the licensing under category E of 
seven  tunnels and the submission of the file to the Court of Audit. By  
end-October 2022, the two lateral toll stations in Chalastra  are expected to 
be put into operation , and the remaining tunnels licensed under category E. 
The financial closing is planned for the end of 2022.  
Regional ports of Alexandroupolis and Kavala:  The draft Concession 
Agreement for the port of Alexandroupolis was uploaded on the virtual 
data room for comments to the prequalified investors on 15 December 
2021. The expropriation process of the private properties in the upland zone 
area of the port of  Alexandroupolis is in progress. The competent 
Ministries of Finance and Shipping have decided on the next steps as 
regards the necessary budgetary resources to be made available for the 
expropriation. The submission of binding offers is scheduled for end-April  
2022.  The selection of the preferred investor is expected by end -July and 
the financial closing by end -December  2022.  For the port of Kavala, 
binding offers are expected by end -February  2022 , whereas the selection 
of the preferred investor is expecte d by end -April.  Financial closing is 
expected by end -December  2022 . 
 
20 
 Commitment  State of play and next steps  
Regional port of Igoumenitsa: The Concession Agreement document was 
finalised in December 2021 and sent to the competent Ministries for 
comments. It w as subsequently uploaded on the virtual data room to the 
pre-qualified investors for comments  on 9  February  2022 . The pending 
issue on the determination of the upland zone of Igoumenitsa port has been 
fully resolved as it is clearly specified in the concession agreement, and 
thus the ten der process can proceed . The submission of binding offers is 
scheduled for end-June 2022. The selection of the preferred investor is 
expected by September 2022.   
Regional port of Heraklion: The completion of the assessment of the 
Investors Expressions of I nterest and the short listing of the prequalified 
parties for the binding offers phase is expected by end -February  2022 , thus 
launching the binding offers phase for the transaction.  The submission of 
binding offers is scheduled by end -September 2022.  
Public Gas Corporation (DEPA) Infrastructure: Following the 
approval of the file by the Court of Audit on 11 November 2021, the Share 
Purchase Agreement between the preferred investor, and the current 
shareholders of DEPA Infrastructure (the Fund having a stake of 65% and 
Hellenic Petroleum with a stake of 35%) was signed on 10 December 2021. 
The next steps are the approval of the preferred investor by the Hellenic 
Competition Commission and its certification by the Regulatory Authority 
for Energy. The fina ncial closing of the transaction is expected by 
end-April  2022  for a financial offer  of €733 million (for the 65% stake of 
the Fund, this corresponds to €476 million) .  
Public Gas Corporation (DEPA) Commercial: The Fund decided to 
extend the suspension of the Binding Offers Phase of the tender further, so 
as to have more clarity on the outcome of pending issues.  
 
21 
 Commitment  State of play and next steps  
Underground Natural Gas Storage (UGS) South Kavala: Following the 
completion of all technical studies and their uploading on the virtual data 
room,  prequalified investors were granted access to the Virtual Data Room 
in December 2021. The first draft Concession Agreement is expected to be 
shared with prequalified investors by end -February 2022. The pending 
issue on clarity of the tariff setting framew ork is expected to be resolved 
via a decision of the Regulatory Authority for Energy expected by 
end-February 2022. Based on the envisaged timeline of the tender, 
submission of binding offers is expected by end -May 2022.  The selection 
of the preferred inve stor is expected by end -July 2022  and the signing of 
the concession agreement by end -December 2022 . 
Gournes Heraklion : Following the submission of binding offers on 15 
October 2021, an electronic auction was conducted with the participation 
of the prequalified for improved financial offer investors 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. On 9 
December, t he Board of Directors of the Fund approved the result of the 
electronic auction of improved financial offers for Gournes and nominated 
as preferred investor the highest bidder of the electronic auction process, 
with a total consideration of €42.2 million in nominal prices. The file of 
the tender process is expected to be sent to the Court of Audit by 
end-February  for pre -contractual review. The financial closi ng is expected 
by end -July 2022.  
Attiki Odos: The Attiki Odos is a modern motorway extending along 
70 km. It constitutes t he ring road of the greater metropolitan area of 
Athens and the backbone of the road network of the whole Attica 
prefecture. The tender for the award of a concession agreement for the 
 
22 
 Commitment  State of play and next steps  
operation and maintenance of the Attiki Odos for a period of 25 years  will 
be conducted in two phases: Phase A (submission of expression of interest 
and pre -qualification of investors) and Phase B (su bmission of binding 
offers and selection of the concessionaire). The tender for the submission 
of the expression of interest was launched on 20 January and the deadline 
for submission of expressions of interest is 20 April.  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 
concluded by end -June 2022 , thus launching the binding offers phase for 
the transaction. The submission of binding of fers is scheduled for the end 
of 2022.  
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 95% to all posts, thus 
completing this specific commitment. In total, more than 346 500 job 
descriptions have been prepared. Together with the digital organisation 
charts that are in place since January 2021  2 the job descriptions constitutes 
key elements in the establishment of an integrated human resources 
management system for the Greek public administration.  
Legal provisions paving the way for t he appointment of a Permanent 
Secretary at the Ministry of Education  and Religious Affairs  have been 
agreed and are expected to be adopted by end-February  2022 . The 
agreed legal provisions reflect the specificities of this Ministry, in 
particular relating to religious affairs, but overall these provisions are 
                                                           
2 9th Enhanced surveillance report, European Commission, February 2021.  
 
23 
 Commitment  State of play and next steps  
considered 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 with a view to 
adopting the Labour Law Code and Code of Labour Regulatory 
Provisions in May 2022 . A cooperation agreement has been reached 
between the Minist ry of Labour and Social Affairs and the Secretariat 
General for Legal and Parliamentary Affairs on the way forward. A first 
codified draft of the Labour Law Code and Code of Labour Regulatory 
Provisions is expected to be submitted by the Ministry to the Se cretariat 
General for Legal and Parliamentary Affairs by the end of March 2022. 
The Central Codification Committee will proceed with the review of the 
codified legislation as a priority . Adoption of the Labour Law Code and 
Code of Labour Regulatory Provisi ons is expected to take place in May 
2022 .  
 
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). Implementation of mandatory e -filing in administrative courts  is 
advancing and both parts of the project are expected to be concluded 
by April end of the first quarter of 2022.  The pilot phase for the 
interconnection with the Legal Council of State database was  completed on 
20 January 2022  and the authorities confirmed that the competent 
committee accepted delivery of the work on condition of correction of bugs 
within February, with the productive functioning of the interconnection 
being expected by the first week of March 2022 ; as for the extension  of the 
functionality of the administrative courts’ platform, the implementation of 
the contract was completed on 21 February 2022; the currently ongoing 
two-month pilot phase is due to lead to the full operationalisation of the 
project by end -April 2022, whereupon the e -filing of all kinds of 
documents and submissions is expected to become available , bringing the 
project to its conclusion . 
 
24 
 Commitment  State of play and next steps  
The launch of the call for bids for the integrated case management 
system for civil and criminal cases (‘OSDDY -PP’)  has been further 
delayed and is due to be launched in March 2022.  Following the expiry 
of the public consultation period on 16 November 2021, the finalised call 
for proposals was amended to incorporate selected feedback and is being 
finalized by the managing  authority; the authorities committed that the call 
will be launched in the first week of March 2022,  with a six-month delay . 
The European institutions reiterated their concern about the delay in the 
launch of the call for proposals tender and encouraged the authorities to 
ensure the efficient and unhindered conduct of the process going forward, 
so that the award of the contract will be effected as projected by the call of 
proposals.  
An e -docket platform has been launched in Athens and its 
functionality wi ll gradually extend across the territory of Greece.  
Regarding the digitisation of court dockets, for enabling stakeholders to 
register and monitor the progress of cases through the courts , an online 
platform was operationalized on 1 December 2021, covering  the Athens 
first instance court; citizens and legal stakeholders can henceforth query 
the platform, using a different search criteria, on the exact location of 
hearings and on the status of the civil or penal procedure of interest (heard, 
adjourned, cance lled etc.). The authorities intend to gradually extend the 
functionality of the platform to all courts across Greece, starting with the 
three remaining ‘OSDDY -PP (first phase) ’ first instance courts (Piraeus, 
Thessaloniki and Chalkis). The relevant draft contract is currently being 
reviewed by the Court of Audits and is expected to be finalized by the end 
of the first quarter 2022, enabling the gradual territorial roll -out of th e 
platform functionality, starting in late May 2022, with a projected 
completion date by end August 2023 . 
 
25 
 Commitment  State of play and next steps  
The e -divorce procedure is now fully functional.  Following the adoption 
of the Joint Ministerial Decision allowing for the operationalisation of the 
e-divorce platform on 31 December 2021  (3), the procedure entered its fully 
operational stage for the general public on  3 February  2022 . 
Further s elected improvements of court procedures have been planned 
and are to be implemented in the context of the Recovery and 
Resilience Facility.  The authorities intend to develop  and put into use e-
platforms for selected judicial procedures (small claims disputes, third -
party statements in enforcement proceedings, the consensual grant of 
collateral in the context o f loan agreements and payment orders) . In this 
context, they have solicited and received feedback by judges and 
contemplate implementing the relevant projects in the context of the second 
phase of the OSDDY -PP project , as part of the justice -related action s of the 
Recovery and Resilience Plan.  
Fight against corruption.  
Implement all recommendations addressed by the Group of States 
against Corruption (GRECO).  The authorities continued working towards implementation of the 
remaining recommendations from fourth evaluation round  of the 
Group of States against Corruption (GRECO) . 
1. Recommendation on the selection of senior positions of judges and 
prosecutors, and on disciplinary proceedings: The new Code for the 
Organisation of Justice and the Status of Off icers of the Courts aims at 
enhancing the process within the current constitutional framework. Its 
adoption has been delayed and it is now expected to be tabled to Parliament 
by the end of April 2022 (see also a specific section on Justice below).  
2. Recom mendation on providing guarantees against delays and improving 
caseload management: Work continues with additional measures to address 
                                                           
(3)  Ministerial Decision of the Ministers of Justice and the State No. 70057 OJ B 6390/31 December 202 1. 
 
26 
 Commitment  State of play and next steps  
this recommendation including: (i) implementation of IT case management 
systems; (ii) establishment of JustStat unit for judicial data collection; (iii) 
qualitative elements for guiding and assessing the work of the courts to be 
introduced in the new Code for the Organisation of Justice and the Status 
of Officers of the Courts; (iv) improvements to the Code of Civil Procedur e 
to simplify, digitalise and accelerate trial proceedings and to enhance legal 
certainty; (v) inclusion in the new Code of Criminal Procedure of tools such 
as criminal mediation and conciliation. The recommendation is expected 
to be implemented by April 2 022. 
3. Recommendation on setting clear standards of professional conduct and 
integrity: The Charter of Judicial Ethics was adopted by the administrative 
full plenary of the Council of State in December 2021.  
In its latest plenary meeting, the Group of Sta tes against Corruption 
terminated the Rule 34 procedure on Greece concerning bribery of 
public officials.  More specifically, the relevant recommendations were 
implemented through amendments to the Criminal Code and the Code of 
Criminal Procedure adopted in November 2021 that included the 
following: (1) rising the bribery of public officials sanction to 
impris onment; (2) limiting the scope of corruption clauses that can be 
subject to abstention of prosecution; (3) extending the concept of a public 
official as a subject of the crime of bribery to foreign officials; (4) repealing 
provisions on effective regret.  
 
 
27 
 Complementary commitments undertaken by Greek authorities in May 2020  
Complementary commitment  State of play and next steps  
Justice.  
Enact the new Code of Judicial Staff and present a timetable for the 
adoption of the New Code for the Organization of Justice and the 
Status of Officers of the Courts.  The Code for the Organisation of Justice and the Status of Officers of 
the Courts is expected to be tabled to Parliament by the end of April  
2022, and enter into force upon publication in the Official Journal  
shortly thereafter . The authorities assured the European institutions  that 
the new code will contain the newly elaborated chapters on disciplinary 
proceedings, evaluation and professional advancement of magistrates in 
their full and final form . The revised sections are expected to contribute to 
increasing the efficiency and effectiveness of courts by revising evaluation 
standards and mechanisms and by putting in place a fair and effective 
disciplinary framework . Among other things, the Code is expec ted to 
contribute to alleviating the challenges faced by courts in dealing with 
personal insolvency backlogs monitored under the financial policy 
commitment, in the sense that its revised disciplinary and promotion rules 
will foster a culture of stricter a dherence to high professional standards 
amongst the members of the judiciary. A quick progress with the key 
legislation is critical for a successful completion of the specific commitment 
on the fight against corruption.  The authorities committed to sharing  the 
text of the draft code  in early March 2022,  prior to the launch of the public 
consultation procedure.  
Justice.  
Present an action plan for the creation of a specialized ‘JustStat’ unit 
for data collection and processing to measure and improve the 
performance of the judicial system and introduce the relevant 
legislation.  The adoption of the requisite secondary legislation for the 
operationalisation of the JustStat unit of the Ministry of Justice is 
expected to be adopted with a nine-month  delay, by end-March 2022 . 
The draft presidential decree  to operationalise the JustStat unit was 
examined by the Council of State for conformity with the constitution and 
its remarks will shortly be addressed  to the Ministry of Justice; following 
the completion of the appropriate amendments to the text, it is expected to 
be adopted by end-March 2022 . The authorities confirmed that the members 
 
28 
 Complementary commitment  State of play and next steps  
of the supervisory committee will be appointed within two months from the 
adoption  of the preside ntial decree . 
Public administration.  
Strengthen the hiring control of the public sector through setting an 
annual ceiling of temporary staff.  A needs assessment of permanent and temporary teachers in the 
medium - to long -term will be completed by April 2022.  The authorities 
have assigned the Ministry of Interior to carry out this study with the 
support of an independent human resources auditor. The study is expected 
to include considerations regarding the 3  000 exceptional temporary staff 
hired for the 2 022-23 school year that have not been fully offset so far by 
reductions in permanent teaching positions.  The authorities have confirmed 
that a timeline and overall scope for the needs assessment has been set and 
an independent human resources auditor has b een assigned.  
As part of the authorities’ commitment to strengthen central control of 
hiring and salary provisions, a list identifying deviations from the 
unified wage grid has been finalised with relevant legal provisions to be 
adopted by April 2022.  The list setting out deviations from the unified 
wage grid cover s the period from 2016 until September 2021  will be  
presented to the Council of Ministers in February 2022. L egal provisions to 
address any deviation not considered justified  are expected to be adopted 
by April 2022.  Finally, a detailed report setting out the  revised methodology 
for the allowance for hazardous and arduous has been made publicly 
available . The revised framework , which  allows for greater transparency 
and predict ability  with the overall cost remain ing unchanged , is expected to 
be adopted by all ministries by  February 2022 . 
Management of public real estate.  
Draw up a holistic and coherent strategy aiming to optimize the 
protection, management and investment -oriented exploitation of The preparatory work on drawing up a holistic and coherent strategy 
is progressing. The collection of all the required information and the 
drafting of the request for proposal for the consultant that will work on the 
study for the elaboration of the real estate strategy is underway and it is 
expected to be finalised by end -February  2022 . The pr ocess for the selection 
 
29 
 Complementary commitment  State of play and next steps  
public real estate, including all organizations involved with public real 
estate management, without prejudice to their mandates.  of the consultant, who will undertake the study is expected to be concluded 
by mid-April  2022 , so that the work can start immediately thereafter and be 
completed by end -June 2022  with the finalisation of the strategy. As already 
reported in the 12th enhanced surveillance report, the agreed scope of the 
study includes the identification of international best practices and mapping 
of current situation / gaps, sustainable development of the public property 
and areas for reform of the fr amework for the development of public real 
estate assets.  
Public procurement.  
Adopt a new public procurement strategy for 2021 –2025 by end 2020.  The authorities adopted two pieces of secondary legislation critical for 
the implementation of newly int roduced elements of the new law , while 
the final one remains pending . The two adopted joint ministerial decisions 
concern the establishment of a certification framework to allow the 
deployment of private -sector engineers in the audit of certain value 
contr acts for public works and studies . However, the adoption of the third 
pending joint ministerial decision  to fulfil this commitment, which concerns 
the set -up of a new legal entity to develop and maintain a new integrated 
system for technical specifications  and costing of technical works , has been 
delayed and is now expected shortly . The latter constitutes an important 
first step to introducing a unified approach in the technical and financial 
management of all public works, in order to overcome distortions that lead 
to large  variations in the technical specifications and pricing of similar 
projects. The actual transition to the new system itself will take place 
following the achievement of the system’s full productive operation , which 
is expected by September 2022 . 
Education.  The draft law on higher education is advanced, but not at a pace that 
would allow a closer assessment . This means a further delay of this 
additional commitment compared with the agreement reached in the 
previous report, which was to have the  draft law ready by end -2021 and 
vote it in Parliament in the first quarter of 2 022. The delay is partly due to 
 
30 
 Complementary commitment  State of play and next steps  
Enhance the autonomy of higher education by strengthening the 
accountability and transparency framework and through the 
introduction of the University Council s. the substantial  effort that was needed to keep universities open during  the 
latest outbreak of the fourth COVID wave.  The revised timetable  is to put 
the bill in public consultation in March 2022 and adopt it in May  2022.  
The upcoming law foresees the establishment of a university c ouncil for 
each i nstitution to further strengthen the autonomy of the higher 
education institutions.  Apart from the reform of the governance, 
upcoming reforms will include the continuous educatio n of teachings staff, 
graduate tracking to follow -up on the graduates’ employability and the 
initial training of graduates for teaching in secondary education.  
The new Higher Education Act is also expected to cover technological 
education , which  was practi cally abolished in 2018 -19. Reinforcement 
of the technological sector of higher education institutions  is important to 
improve links between higher education and the labour  market and to create 
credible prospects for the professional integration of their graduates. The 
new legislation will increase diversification within the university sector to 
ensure that the orientation of studies in applied sciences and technology is 
provided and strengthened .  
E-governance.  
Develop the single digital portal (gov.gr) to integrate all electronic 
transactions for citizens and businesses with the state and related 
information, unify the legal framework on digital policy, and 
safeguard busi ness continuity by ensuring sufficiency of digital 
infrastructure mid -2021.  The authorities successfully completed the  set-up of the single digital 
(gov.gr) portal backed by relevant initiatives to ensure system 
interoperability and robustness, in line with the guidelines and 
priorities set out in the National Digital Transformation Strategy and 
the urgent needs arising from the evolution of the pandemic.  The portal, 
which brings to date more than 1  300 services, constitutes a key first step 
towards crea ting a digital public administration and improving the quality 
of services offered. At the same time, it paves the way for the creation of an 
extended innovation ecosystem with gov.gr acting as an open technology 
enabler for third parties. Recently added f unctionalities and applications 
include business intelligence to generate analysis on the use of services and 
 
31 
 Complementary commitment  State of play and next steps  
user traffic flows, a helpdesk platform for services hosted, and a digital 
repository for all Greek legislation since the establishment of the Gre ek 
state. Moreover, the authorities continue to implement initiatives to ensure 
interoperability and secure data exchange, which enable the provision of 
new services and ease the administrative for businesses and citizens. A 
recent initiative concerns the redesign and digitalisation of the procedure to 
enable the start -up of a private business without the need to visit any public 
service. Going forward, an ambitious set of interventions aimed at further 
enhancing the provision of customer -oriented digital s ervices is envisaged 
under Greece’s recovery and resilience plan.