Special Report No 19// 2015#More attention to results needed to improve the delivery of technical assistance to Greece #(pursuant to Article 287(4), second subparagraph, TFEU)
Date: 2015-11-11
Institutions: European Court of Auditors
Subjects: EU aid, EU programme, Greece, economic recession, economic recovery, economic reform, financial aid, technical cooperation

EN 

2015 

NO 19

Special Report  More attention to results 

needed to improve the 
delivery of technical 
assistance to Greece

EUROPEAN
COURT
OF AUDITORS

 
EUROPEAN COURT OF AUDITORS 
12, rue Alcide De Gasperi 
1615 Luxembourg 
LUXEMBOURG

Tel. +352 4398-1

Email: eca-info@eca.europa.eu 
Internet: http://eca.europa.eu

Twitter: @EUAuditorsECA 
YouTube: EUAuditorsECA

More information on the European Union is available on the Internet (http://europa.eu).

Luxembourg: Publications Office of the European Union, 2015

Print 
PDF 
EPUB 

ISBN 978-92-872-3450-6 
ISBN 978-92-872-3470-4 
ISBN 978-92-872-3448-3 

ISSN 1831-0834 
ISSN 1977-5679 
ISSN 1977-5679 

doi:10.2865/879030 
doi:10.2865/026924 
doi:10.2865/314082 

QJ-AB-15-020-EN-C
QJ-AB-15-020-EN-N
QJ-AB-15-020-EN-E

© European Union, 2015
Reproduction is authorised provided the source is acknowledged.

Printed in Luxembourg

EN 

2015 

NO 19

Special Report

More attention to results 
needed to improve the 
delivery of technical 
assistance to Greece

(pursuant to Article 287(4), second subparagraph, TFEU)

Audit team

02

The European Court of Auditors (ECA) special reports set out the results of its performance and compliance audits of 
specific budgetary areas or management topics. The ECA selects and designs these audit tasks to be of maximum impact 
by considering the risks to performance or compliance, the level of income or spending involved, forthcoming develop-
ments and political and public interest.

This performance audit was produced by Audit Chamber IV — headed by ECA Member Milan Martin Cvikl — which 
specialises in auditing revenue, research and internal policies, financial and economic governance and European Union’s 
institutions and bodies. The audit was led by ECA Member Baudilio Tomé Muguruza, supported by the head of his private 
office, Daniel Costa de Magalhães and Ignacio García de Parada, attaché; Zacharias Kolias, director; Kamila Lepkowska, 
team leader; Giuseppe Diana, Mirko Gottmann, Efstathios Efstathiou, Theodoros Karantanos, auditors.

From left to right: T. Karantanos, D. Costa de Magalhães, K. Lepkowska, Z. Kolias, 
B. Tomé Muguruza, G. Diana, M. Gottmann, I. García de Parada, E. Efstathiou.

Contents

03

Paragraph

Acronyms and abbreviations

I–IX 

Executive summary

1–8 

1–2 

3–4 

5–8 

Introduction

The Greek crisis and the economic adjustment programmes

Technical assistance to support implementation of the programmes

Scope and methods of technical assistance

9–14 

Audit scope, objectives and approach

9–11 

Audit scope and objectives

12–14 

Audit approach

15–26  Part I — The TFGR had a functional operational structure but lacked a single 

strategic orientation and dedicated budget

15–18 

The TFGR was established late compared to the launch of the programme and without considering 
alternatives

19–22 

No single strategic document

23–24 

The TFGR was not given a dedicated budget

25–26 

The TFGR had a flexible internal organisation, but staff needs were not defined based on a proper 
analysis

 
Contents

04

27–54  Part II — The TFGR fulfilled its mandate overall, but there were shortcomings

28–29  Major challenges in a difficult context

30–32 

Coordination system performed satisfactorily

33–34 

The role of the TFGR significantly varied for the audited projects

35–37 

The TFGR applied a mix of TA delivery modes, but some of them did not match with the nature of 
assistance

38–41 

Selection of TA providers was not always based on a thorough analysis of alternatives

42–45 

Support to accelerate the take-up of EU funds was properly structured

46–47 

Support was sufficiently attuned to key reform needs but not always based on a comprehensive 
needs analysis

48–50 

Terms of reference of some contracts not clearly defined

51 

52 

Technical assistance was appropriate to programme requirements

The TFGR effectively monitored the progress of TA …

53–54  … and, to varying degrees, the deliverables of external service providers

55–73  Part III — The technical assistance achieved mixed results

55–57 

The TFGR did not systematically monitor the results and impacts of TA

58–59 

Satisfactory outputs but some late delivery

60–73 

A varied contribution to the reform process

61–63 

Public administration

64–65 

Business environment

66 

Structural Funds

67–71 

Taxation (revenue administration)

72–73 

Capacity building

Contents

05

74–79  Conclusions and recommendations

75 

76 

Organisation and planning of technical assistance

Meeting the TFGR mandate

77–79 

TA results

Annex I  —  Overview of TA projects by policy field

Annex II  —  Overview of audited TA projects

Annex III  —  Bodies visited in the course of the audit

Annex IV  — 

 Contribution Agreement between the Ministry of Administrative Reform and 
e-Governance and the OECD on the reduction of administrative burden in Greece

Annex V  —  Role of the TFGR in the provision of technical assistance by policy field

Reply of the Commission

 
 
 
 
 
 
Acronyms and 
abbreviations

06

AROP: ‘Administrative reform’ operational programme

DG Economic and Financial Affairs: European Commission Directorate-General for Economic and Financial Affairs

DG Employment, Social Affairs and Inclusion: European Commission Directorate-General for Employment, Social 
Affairs and Inclusion

DG Regional and Urban Policy: European Commission Directorate-General for Regional and Urban Policy

ERDF: European Regional Development Fund

ESF: European Social Fund

Fiscalis programme: EU cooperation programme for national tax administrations

GLF: Greek loan facility

GSCO: General Secretariat for Coordination of the Hellenic Republic

IMF: International Monetary Fund

IRS: Internal Revenue Service (United States government agency responsible for tax collection and tax law 
enforcement)

MoU: Memorandum of Understanding

OECD: Organisation of Economic Cooperation and Development

TAIEX: Technical Assistance and Information Exchange Instrument

TFGR: Task Force for Greece

Executive  
summary

I
In spring 2010, facing severe financial crisis, Greece 
requested financial assistance from the international 
community. The response by the euro-area Member 
States and the IMF was to put in place two successive 
economic adjustment programmes. In summer 2011 
the Commission launched a programme of technical 
assistance (TA) to be coordinated by a body known as 
the Task Force for Greece (TFGR), to help implement 
the reforms agreed by the Commission and the Greek 
authorities.

II
The TFGR focused on supporting implementation of 
the reforms required by the economic adjustment pro-
grammes and accelerating the absorption of EU funds. 
TA was delivered by TFGR staff and experts from the 
civil service in other Member States, from interna-
tional organisations and from the private sector. It 
took a variety of forms: from ongoing support to the 
Greek authorities by resident experts, through studies, 
reports and dedicated workshops.

III
The aim of our audit was to analyse how the TFGR 
had fulfilled its goals. Specifically, we examined 
the TFGR’s organisational and financing arrange-
ments, how TA was actually delivered and monitored, 
and its contribution to the progress of reforms. We 
audited 13 TA projects in detail and obtained other 
evidence through visits to the Commission, service 
providers, Greek government departments and other 
stakeholders.

07

Good action but …

IV
The TFGR provided the Commission with a flexible 
mechanism for coordinating a broad programme of 
technical assistance. TA was effectively delivered to 
the Greek authorities but it did not always influence 
the progress of reforms. However, this assessment 
has to be seen in the context of the volatile political 
situation in Greece and the urgency imposed by the 
required reforms.

An incomplete entity

V
The urgency of responding to the crisis in Greece 
meant that the TFGR was set up very rapidly, without 
a full analysis of other options and without a dedi-
cated budget. It had no single comprehensive stra-
tegic document for the delivery of TA or for deciding 
between competing priorities, despite the TFGR’s 
mandate to identify and coordinate the TA. In the 
absence of such a document, the TFGR worked with 
the Greek authorities ‘on demand’ and based on the 
programmes’ conditionality.

Relevant TA

VI
Notwithstanding the shortcomings affecting the set-
ting-up of the TFGR, we found that, in all the areas we 
audited, the delivery of TA was relevant and broadly in 
line with the programme requirements. By November 
2014, the TFGR had coordinated 118 TA projects in 12 
policy fields. In doing so, and though always pressed 
for time, the TFGR had developed a flexible and diver-
sified system for the delivery of TA.

Executive summary 

08

Weak procedures in some projects

Our recommendations

(a)  The establishment of any entity for delivering TA 
should be based on a strategy with well-defined 
objectives.

(b)  The Commission should create a pool of external 

experts who could be deployed on an ad hoc basis 
on TA projects in Member States.

(c) 

In view of ensuring the coherence of TA and reduc-
ing the coordination effort, in specific policy fields 
the Commission should aim at streamlining the 
number of partners.

(d)  TA should be prioritised and focused and operate 
through the most appropriate and effective imple-
mentation mode in accordance with the existing 
legislative and regulatory framework.

(e)  The Commission should select service providers 

based on a comparative analysis and clearly define 
the scope of deliverables in TA contracts.

(f)  The Commission should ensure that the imple-

mentation of TA is systematically monitored and 
evaluated in the light of objectives set, and lessons 
learned fed back into the process.

(g)  TA should focus on strengthening the capacity of 
national administrations with a view to business 
continuity and the sustainability of reforms.

VII
Overall, the TFGR’s coordination of the complex TA 
delivery process was functional and even innovative, 
but at project level the system did not always prove 
effective. Procedures to select service providers were 
not always based on a thorough analysis of the avail-
able alternatives. Some long-term assistance projects 
had design flaws, in that the contracts signed with 
service providers did not clearly state what they were 
expected to deliver.

Monitoring could be improved

VIII
The TFGR’s system for monitoring the progress of TA 
was effective, but the breadth of checks carried out 
with respect to the work of external providers was 
highly variable. Moreover, it did not systematically 
monitor either the way the Greek authorities followed 
up recommendations or the broader impacts of TA, 
although it would be useful for TA planning.

Looking beyond technical assistance

IX
The impact of TA on the overall progress of reforms 
was mixed. Progress in the area of structural spending 
was good, but TA was often only partially effective in 
public administration and taxation reform. However, 
the implementation of reforms was outside the TFGR’s 
control and subject to a number of external factors.

Introduction

09

The Greek crisis and the 
economic adjustment 
programmes

Technical assistance to 
support implementation 
of the programmes

03 
To support implementation of the re-
forms required by the MoU and to ac-
celerate the absorption of EU funds, in 
summer 2011 the Commission created 
the Task Force for Greece (TFGR). The 
TFGR’s mandate is shown in Box 1. The 
Commission’s plan of devising a ‘com-
prehensive programme of technical 
assistance for Greece’ was endorsed 
by the Council at its meeting on 23-24 
June 2011.

01 
In spring 2010, facing severe crisis in 
its public finances, Greece requested 
financial assistance from the interna-
tional community. Support was pro-
vided by the euro-area Member States 
in the form of a ‘Greek loan facility’ 
(GLF) under a first economic adjust-
ment programme (signed in May 2010). 
This was followed by a loan from the 
European Financial Stability Facility 
(EFSF) under a second adjustment 
programme (agreed in March 2012). 
The initial amount committed to the 
GLF by euro-area countries was 80 bil-
lion euro, with a further 30 billion euro 
to come from the IMF. Total commit-
ments from the euro area and the IMF 
under both programmes currently add 
up to 245.7 billion euro.

02 
The financial support package was 
accompanied by a comprehensive 
programme of reforms agreed by the 
Troika (the Commission, the IMF and 
the European Central Bank (ECB)) and 
the Greek authorities and laid down 
in a memorandum of understand-
ing (MoU). This sets out the specific 
terms of financial support and was 
subject to regular review (the first 
programme was reviewed five times, 
the second four times — most recently 
in April 2014). The logic of intervention 
was based on three objectives:

 ο

 ο

 ο

restoring financial market confi-
dence and fiscal sustainability,

promoting economic growth and 
restoring competitiveness,

safeguarding financial sector 
stability.

Introduction

10

1
x
o
B

TFGR mandate

The task force was charged with the following.

(1) 

Identifying and coordinating, in close cooperation with Greece and benefiting from input from other 
Member States, the technical assistance that Greece needs to deliver the EU/IMF adjustment programme.

(2)  Assisting the relevant Greek authorities in defining the details of the kind of technical assistance to be 

provided.

(3)  Recommending legislative, regulatory, administrative and if necessary (re)programming measures for an 

accelerated take-up of EU funds (…).

(4)  Preparing clear terms of reference for all technical assistance assignments which specify the nature and 

scope of the technical assistance (…) the budgetary and human resources, and the expected results, with 
milestones and delivery deadlines.

(5)  Providing quarterly progress reports to the Commission and the Greek authorities as well as, on a need 

basis, more frequent alert reports.

04 
The TFGR was established as an 
organisational entity attached to 
the Commission’s Director-General 
of Human Resources and Security. 
The head of the task force was given 
director-general status and reported 
directly to the Commission president 
under the guidance of the Commis-
sioner for Economic and Monetary 
Affairs. Under a Commission decision 
of 18 April 2012, the TFGR was placed 
within DG Economic and Financial Af-
fairs on 1 May 2012 in order to ‘ensure 
the highest possible levels of syner-
gies, coordination and coherence of 
the Commission’s work to support the 
adjustment programme of Greece’. The 
TFGR operated from offices in Brussels 
and Athens and, as of February 2015, 
employed 65 staff. Its organisational 
structure is shown in Chart 1.

 
Introduction

11

1 Organisational structure of the TFGR

t
r
a
h
C

DG ECFIN

Vice-President for Economic 
and Financial Aﬀairs and the Euro

Reporting to the President of 
the European Commission

Director-General of DG ECFIN

Head of TFGR

ECFIN.DDG1
Responsible for country surveillance

ECFIN.G
Director for Economies of the
Member States II — Troika Principal

ECFIN.G.3
Unit for Greece
(MoU monitoring)

TFGR
Special Adviser

TFGR thematic teams
(clusters)

Head of ECFIN
Athens Oﬃce

Head of
representation

Leader of MoU
monitoring team

Leader of TFGR team
(TFGR Principal Adviser)

Source: ECA, based on Commission data.

 
Introduction

12

08 
The providers of TA addressed their 
deliverables — primarily expert stud-
ies and ongoing hands-on support — 
to the appropriate Greek authorities. 
It was then up to the authorities to 
implement the recommendations in 
line with the programme conditions 
and their own reform agendas. The TA 
process is shown in Chart 2.

Scope and methods of 
technical assistance

05 
The concept of TA was not defined in 
the specific context of the TFGR or the 
support provided to Greece. Accord-
ing to the definition laid down in the 
financial regulation ‘Technical assis-
tance shall mean ‘support and capac-
ity-building activities necessary for 
the implementation of a programme 
or an action, in particular preparatory, 
management, monitoring, evaluation, 
audit and control activities.’ TA is typi-
cally delivered by international organi-
sations through expertise and advice 
to assist states with development 
programmes.

06 
For Greece, the TA activities covered 
a wide range of subjects: 118 single pro-
jects in 12 policy fields (see Annex I). 
The TFGR focused on the reform of 
public administration, improvements to 
the tax system and a return to growth 
through promotion of the business 
environment.

07 
In practice the TA process started with 
the request for support defined by 
the Greek authorities. The scope of 
the request reflected the conditional-
ity of the programme. The TFGR was 
responsible for identifying and making 
available TA resources and coordinat-
ing the implementation. Support was 
then provided by the staff of the TFGR 
or by external experts, and took the 
form of short-term missions, low-value 
contracts and long-term assistance. 
In some instances, a national govern-
ment with a strong track record in 
a policy field assumed responsibility as 
‘domain leader’ (or ‘reform partner’).

Introduction

13

2 The technical assistance process

t
r
a
h
C

Identiﬁcation
of needs

Greek TA requests

MoU

Coordination

Implementation

High level Meetings
    Member States 
    International 
    organisations 
    Greek authorities 
    Stakeholders

International 
organisations

Individual experts

TFGR quarterly reports

National agencies

Commission inter-
service consultation

Source: ECA, based on TFGR data.

Studies

Ongoing support

Greek authorities

Structural reforms 
MoU

 
14

1  Not related to specific policy 

fields.

2 

The policy field ‘access to 
finance’ was subject to the 
audit, but it did not result in 
relevant findings.

Audit scope, objectives 
and approach

Audit scope and 
objectives

Audit approach

09 
This audit addresses the EU technical 
assistance provided to Greece under 
the coordination of the Task Force for 
Greece. The main objective was to 
assess the extent to which this assis-
tance was managed effectively and 
contributed positively to the process 
of reforms in Greece.

10 
We addressed this objective by exam-
ining the following:

 ο

 ο

 ο

the TFGR’s organisational arrange-
ments and the financing and plan-
ning of TA (paragraphs 15 to 26);

the delivery of TA based on the 
TFGR mandate (paragraphs 27 to 
54); and

the contribution made to the 
progress of reforms (paragraphs 55 
to 73).

11 
The report did not cover assessment of 
the design, monitoring or implemen-
tation of the economic adjustment 
programmes.

12 
We analysed horizontal aspects1 linked 
to the set-up of the TFGR and the 
overall management of TA, as well as 
a sample of 13 projects (see Annex II 
for an overview). The sample covered 
five policy fields that were of consid-
erable significance to the success of 
the reform process in Greece (public 
administration, revenue administra-
tion, business environment, access to 
finance2 and Structural Funds).

13 
Individual TA projects were selected 
on the basis of the following criteria: 
relevance of the subject to the reform 
process, an advanced stage of im-
plementation, coverage of all modes 
for delivering TA and all financing 
mechanisms.

14 
The main audit work involved visits 
to the TFGR and other relevant Com-
mission services. Evidence was also 
gathered through audit and informa-
tion visits to service providers, Greek 
authorities and other stakeholders. 
Annex III lists the bodies visited during 
the audit.

Part I 
The TFGR had a functional operational 
structure but lacked a single strategic 
orientation and dedicated budget

15

16 
By that time, the fifth review of the 
first economic adjustment programme 
(launched initially in May 2010) was 
already ongoing and six loan disburse-
ments had been made worth 65 bil-
lion euro, out of the total of 73 bil -
lion euro that would be disbursed by 
the GLF and the IMF through the first 
programme (see Chart 3).

The TFGR was established 
late compared to the 
launch of the programme 
and without considering 
alternatives

15 
In correspondence between the Greek 
Prime Minister and the Commission in 
early summer 2011, the establishment 
of the TFGR was referred to as a key 
instrument for successful delivery of 
the initial economic adjustment pro-
gramme. Basic arrangements, includ-
ing the scope of the TFGR’s mandate 
(see Box 1), were decided by the 
Commission on 20 July 2011. According 
to this decision the first appointments 
were to take effect on 1 September 
2011. Nine staff members assumed 
their duties on that date (including 
key senior staff), and they were joined 
by 30 more during the next 2 months, 
giving the TFGR 39 staff as at the end 
of October 2011.

3 Establishment of the TFGR vs financial disbursements

t
r
a
h
C

European Council welcomes the Commission’s 
intention to prepare a TA programme for Greece

Operational start of TFGR

o
r
u
e
n
o

i
l
l
i

B

140

120

100

80

60

40

20

0

4th programme
review

5th programme
review

First economic 
adjustment 
programme

3rd programme
review

2nd programme
review

1st programme
review

Second economic
adjustment programme

May 2010

September 2010

December 2010

January 2011

March 2011

Financial support disbursed

Source: ECA, based on TFGR and MoU data.

July 2011
September 2011

October 2011

November 2011

December 2011

February 2012

March 2012

 
 
16

3 

The framework for 
cooperation included, for 
example, the Permanent 
Representation of the 
European Commission in 
Athens, a technical task force 
set up at DG Employment, 
Social Affairs and Inclusion to 
support implementation of 
the Structural Funds, and 
permanent programme 
monitors from DG Economic 
and Financial Affairs.

17 
The TFGR was expected to remain 
operational for as long as support was 
needed for programme implementa-
tion. On 1 July 2015 the TFGR was 
replaced by a new ‘structural reform 
support service’ to coordinate growth-
enhancing administrative and structur-
al reforms at EU-level. The new entity 
was designed by the Commission to 
benefit from the expertise, practi-
cal know-how and working methods 
developed over time by both the TFGR 
and the support group for Cyprus, and 
it consists of staff formerly working in 
those two bodies.

18 
When establishing the TFGR, the 
Commission did not analyse alterna-
tive options for the delivery of TA. In 
particular, it did not demonstrate that 
the institutional set-up and mandate 
of the TFGR were best suited to ad-
dress existing capacity weaknesses. 
Urgency and political uncertainty may 
explain the lack of critical analysis 
underlying the establishment of the 
TFGR. In this respect, the Commission 
stated that it drew on the experience 
gained through providing support to 
Greece within the framework of exist-
ing instruments and legal acts3. The 
TFGR’s operational procedures have 
never been subject to review, although 
an annual review was decided by the 
Commission on 20 July 2011.

No single strategic 
document

19 
While the TFGR’s priorities were to 
some extent set out in internal docu-
ments and presentations, its activities 
were not underpinned by a single 
comprehensive strategic document. 
For example, the TFGR did not draw 
up a strategic plan setting out, over 
a medium term perspective, the details 
of the arrangements for delivering TA, 
the prioritisation of TA actions and the 
necessary resources. In practice the 
strategic orientation of the TFGR was 
based on the economic adjustment 
programme and prioritisation of ac-
tions was dependent on the requests 
of the Greek authorities.

20 
The TA activities coordinated by the 
TFGR were mainly provided ‘on de-
mand’. Following consultation with the 
TFGR, the Greek authorities submitted 
detailed requests on two occasions in 
2011 and 2012 and then updated them 
individually for specific policy fields. 
This reactive ‘on demand’ approach is 
at odds with the TFGR’s more active 
mandate to ‘identify and coordinate 
TA in close cooperation with the Greek 
authorities’.

Part I — The TFGR had a functional operational structure but lacked a single strategic orientation and dedicated budget17

The TFGR was not given 
a dedicated budget

23 
The TFGR never had a dedicated 
budget, but its operations and TA 
activities were financed from a num-
ber of budget lines (notably within the 
European Social Fund, the European 
Regional Development Fund and the 
Commission’s administrative budget). 
In the context of public administration 
reform, we found that the financing 
possibilities offered by the Structural 
Funds were not fully exploited for TA 
purposes. The budget of an opera-
tional programme relevant to the TA 
(AROP) was significantly reduced and 
reoriented toward actions not di-
rectly linked with reform of the central 
administration.

21 
The TFGR did not itself carry out 
a systematic needs assessment to 
determine which specific issues or 
areas should be addressed by TA and 
in which order of priority. In line with 
the TFGR’s mandate, the priorities 
were derived from the MoU. However, 
given its very broad scope, the MoU 
could not serve the purpose of direct 
guidance for the delivery of TA in view 
of the limited resources of the TFGR 
and the administrative capacity of the 
Greek authorities. Notwithstanding 
these constraints, the TFGR occasion-
ally offered TA that went beyond the 
initial requests of the Greek authori-
ties, mainly under the headings of 
‘innovation’ and ‘guaranteed minimum 
income’.

22 
The TFGR did not maintain an over-
view of TA projects carried out in 
Greece and financed from sources 
other than the EU budget managed 
directly by the Commission (includ-
ing those supported by the Structural 
Funds, e.g. ESF, under shared man-
agement). Although the TFGR had no 
responsibility for implementing or 
monitoring Structural Funds projects, 
such an overview would have been 
helpful for the planning and coordina-
tion of TA. Given the similar objectives 
of TA and Structural Funds, considera-
tion of the preparatory works carried 
out for projects implemented under 
the operational programmes, would 
also help to achieve full synergies with 
TA projects.

Part I — The TFGR had a functional operational structure but lacked a single strategic orientation and dedicated budget24 
Due to the financing from different 
budget lines, the Commission was 
not able to precisely determine the 
total commitments (and therefore 
total potential cost) of TA activities in 
Greece. Based on information from the 
TFGR, commitments to TA activities4 
under centralised direct management 
totalled 11.2 million euro in 2011-2013.
On top of that budget, some TA activi-
ties were financed using the Structural 

Funds under shared management5. 
According to information presented 
at the high-level meeting6 in March 
2014, the total amount committed to 
these activities was 14.2 million euro 
in 2011-2014. Taking both sources of 
financing into consideration, the most 
heavily-funded policy field was public 
health. Revenue administration and 
the business environment received 
most funding under centralised man-
agement (see Chart 4).

18

4 

Excluding staff and 
administrative costs and 
commitments of the Fiscalis 
programme.

5  Centralised direct 

management means that 
money is spent directly by 
Commission staff (contractors 
selection, grants, transfers of 
funds, monitoring, etc.). Under 
shared management, budget 
implementation is delegated 
to the Member States.

6  Meetings regularly organised 
by the TFGR to co-ordinate 
and discuss progress of TA. 
Participants included Member 
States, service providers and 
stakeholders.

4 TA commitments by policy field (2011-2013)1

t
r
a
h
C

0

2

4

6

8

10

12

(million euro)

Public health 
Business environment and reform of product and service markets, 
public procurement, better regulation

Revenue Administration and Public Financial Management

Labour market and social security

Administrative reform at central level, e-Government

Administrative reform at regional and local level

Structural funds and sectoral issues

Privatisation, land use and land registry 

Other

Centralised direct management

Shared management

1  2011-2014 for commitments under shared management.

Source: ECA, based on TFGR data.

Part I — The TFGR had a functional operational structure but lacked a single strategic orientation and dedicated budget 
19

The TFGR had a flexible 
internal organisation, but 
staff needs were not 
defined based on a proper 
analysis

25 
The TFGR’s work was organised around 
11 policy-related ‘clusters’ and one 
horizontal team responsible for coor-
dination and management of TA. The 
clusters reflected the structure of the 
MoU and the main challenges facing 
Greece in the reform process. Each 
cluster was chaired by a coordinator, 
who took overall responsibility for the 
internal organisation of work, commu-
nication and contributions to general 
TFGR documents. Coordinators were 
also expected to identify projects of 
potential interest to other clusters and 
manage contacts with DG Economic 
and Financial Affairs’ geographical 
desk. The cluster structure allowed 
staff (including coordinators) to work 
in more than one team and gave 
the TFGR management flexibility to 
quickly readjust its resource allocation.

26 
The TFGR’s overall ceiling of 67 staff 
members, established in April 2012, 
was not based on an underlying 
analysis of actual needs. As at 1 Febru-
ary 2014, the total number of staff 
fell significantly short of the ceiling 
(nine vacant posts). By February 2015, 
following finalisation of recruitment 
procedures, there were only two va-
cant posts. As of 1 July 2015 the TFGR 
was incorporated into the ‘Structural 
Reform Support Service’.

Part I — The TFGR had a functional operational structure but lacked a single strategic orientation and dedicated budgetPart II 
The TFGR fulfilled its mandate overall, 
but there were shortcomings

20

27 
The mandate of the TFGR covered five 
main components (see Box 1). This 
part of the report analyses the extent 
to which each of these components 
has been fulfilled.

TFGR mandate

(1)  Identifying and coordinating, in 
close cooperation with Greece 
and benefiting from input 
from other Member States, the 
technical assistance that Greece 
needs to deliver the EU/IMF 
adjustment programme.

Major challenges in 
a difficult context

28 
The TFGR faced the major challenge 
of putting together a comprehensive 
programme of TA to support imple-
mentation of the adjustment pro-
grammes and the overall sustainability 
of Greek reforms. Between May 2010 
and October 2011 the first adjustment 
programme was reviewed five times. 
By the time the TFGR was set up, the 
programme contained a large num-
ber of detailed conditions, which was 
the basis for the Greek authorities’ TA 
request.

29 
During its first 3 months of existence 
the TFGR began TA initiatives in most 
of the policy fields for which Greek 
authorities had solicited support. Its 
first quarterly report (November 2011) 
showed that TA was being implement-
ed at the time in nine fields, including 
such key areas such as budget and 
taxation, public sector and the busi-
ness environment. As at November 
2014, the TFGR was active in 118 TA 
projects. In providing TA the TFGR 
faced tight deadlines derived from the 
implementation of the conditions at-
tached to the adjustment programme. 
Furthermore, the TFGR had to work in 
the context of the highly volatile politi-
cal situation, necessitating frequent 
adjustments of the approach and 
content of TA projects.

Coordination system 
performed satisfactorily

30 
The complex system of TA provision, 
involving a large number of Member 
States, international organisations and 
EU entities, required enhanced coordi-
nation measures. To this end, the TFGR 
held regular ‘high-level meetings’ to 
coordinate the delivery of assistance. 
Ten such meetings were held up to 
mid-2014. As the main coordination 
tool, the meetings were useful for 
pooling TA resources (particularly in 
the initial period) and streamlining its 
delivery. The high-level meetings gath-
ered a large number of participants 
representing all types of TA partners.

21

In the area of the Structural Funds, 
it became necessary to carry out 
a comparative analysis of the 
cohesion policy implementation 
procedure. To this end, in Sep-
tember 2013 the TFGR initiated 
cooperation with the authorities 
of one Member State, but the ar-
rangement later stopped for no 
clear reason.

7 

E.g. in the fields of public 
sector reform, business 
environment (liberalisation of 
professions), budget and 
taxation.

31 
In addition to the high-level meetings, 
the TFGR developed three main chan-
nels of overall coordination with the 
Greek authorities:

 ο

 ο

high-level political meetings in-
volving the head of the TFGR,

 ο weekly meetings at cluster level 
(TFGR staff responsible for a spe-
cific policy field) with the corre-
sponding Greek authorities.

 ο working contacts of TFGR staff 

with the Greek authorities (includ-
ing contacts with experts working 
on a day-to-day basis in the Greek 
administration).

32 
At project level, the TFGR was able to 
demonstrate enhanced coordination 
with both the Greek authorities and 
service providers. In all projects TFGR 
staff led and/or participated in meet-
ings with their opposite numbers. 
However, in some cases this coordina-
tion did not prove effective.

 ο

In the case of the ‘Administra-
tive burden’ project, we identi-
fied implementation weaknesses 
linked to the cooperation between 
the OECD and the Greek authori-
ties and specifically the quality 
of inputs provided by the Greek 
experts. The TFGR coordination ef-
forts did not prove to be sufficient 
in order to overcome delays and 
implement the project in line with 
the initial concept (see Annex IV).

The role of the TFGR 
significantly varied for 
the audited projects

33 
The role of the TFGR’s work varied 
greatly from one project to another 
(see Annex V for a more detailed anal-
ysis of the TFGR’s role). It made a clear 
difference when it was responsible 
for pooling resources from Member 
States or managing external service 
providers7. In such cases the TFGR was 
responsible for, among other things, 
designing terms of reference, selecting 
service providers (in consultation with 
DG Employment, Social Affairs and 
Inclusion) and monitoring their work. 
It therefore had a marked influence 
of the TFGR on the scope and quality 
of TA actually delivered to the Greek 
authorities.

34 
In contrast, the TFGR’s role in the 
‘Administrative burden’ project was 
less clearly defined. It was not in-
volved in the selection of the service 
provider, the contractual arrange-
ments between the OECD and the 
Greek authorities or the monitoring of 
implementation. It served primarily as 
a facilitator, but with limited effective-
ness (see paragraph 32).

Part II — The TFGR fulfilled its mandate overall,  but there were shortcomings22

TFGR mandate

(2)  Assisting the relevant Greek 
authorities in defining the 
details of the kind of technical 
assistance to be provided.

The TFGR applied a mix 
of TA delivery modes, 
but some of them did not 
match with the nature 
of assistance

35 
In order to fulfil its mandate, the TFGR 
had recourse to a number of modes for 
the delivery of TA (see Chart 5). The 
predominant way of providing TA was 
through external contractors, partly 
due to administrative constraints 
which prevented the Commission from 
employing experts directly. Once a TA 
project had been validated, it was usu-
al to apply a combination of long-term 
and short-term experts to address the 
specific needs of the Greek govern-
ment beneficiaries.

5 TA delivery modes

t
r
a
h
C

TFGR’s own staﬀ 

Oﬃcials, contract staﬀ and national experts 
provided direct support to the Greek authorities, 
either on an ad hoc basis or in the capacity 
of experts resident in the Greek institutions. 
The latter approach was used in the ﬁelds of public 
administration, taxation and structural funds.

Expert missions 

Short-term expert visits or workshops aimed 
at sharing experience and the exchange of best 
practices and provided by experts delegated by 
international organisations or Member States. 
Expert missions were extensively used as 
a mode of TA provision in the area of public 
administration and taxation.

Low-value contracts 

Long-term contracts 

Support for speciﬁc short-term projects. 
Contracts worth less than 15 000 euro were ﬁnanced 
directly by the European Commission through the 
central TA budget of the ESF. This type of support was 
typically used e.g. in the business environment cluster.

Support from international or national 
organisations with speciﬁc know-how. Contracts 
were either signed directly by the Commission, 
using the central ESF budget, or managed by 
the Greek authorities and charged to 
the structural funds.

Source: ECA, based on TFGR data.

Part II — The TFGR fulfilled its mandate overall,  but there were shortcomings 
23

8  National development 

agencies are public entities to 
which a Member State 
entrusts the task of providing 
expertise and assistance in 
other (primarily developing) 
countries.

9  Based on a total budget of 

600 000 euro.

10  Primarily through financing 

decisions.

36 
In the case of TA delivered by means 
of long-term contracts with national 
development agencies8 (in the fields 
of taxation and public administration), 
the TFGR was responsible for selecting 
and negotiating with experts. While 
financed by the agencies, the experts 
largely worked independently (e.g. 
without the agencies’ methodologi-
cal guidance). The agency active in 
the field of taxation charged a 7 % 
administrative fee9 for its services. In 
the case of these two contracts, this 
division of responsibilities shows that 
the national agencies were used pri-
marily to finance the hiring of external 
contractors. The actual input of the 
agencies was limited to formal issues 
(no substance-related advice) and the 
Commission had to pay administrative 
charges.

37 
In areas with complex legal environ-
ments, such as revenue administration 
and the public administration, better 
results were achieved when resident 
experts were placed in the national 
authorities at an early stage. These 
experts were well placed to identify 
and address practical obstacles and 
constrains such as in the write-off of 
debt procedures and facilitating com-
munication in the event of delays in 
the legislative process.

Selection of TA providers 
was not always based on 
a thorough analysis of 
alternatives

38 
Of the audited long-term TA pro-
jects, four were directly contracted 
by the Commission (two to the IMF in 
the area of taxation, two to national 
development agencies in the fields of 
public administration and taxation). 
In the business environment (reduc-
tion of administrative burden) field, 
the contribution agreement with the 
OECD was concluded by the Greek 
authorities.

39 
The selection of TA providers for 
long-term contracts signed directly 
by the Commission was documented 
as required by the financial regula-
tion10. No tender procedures were 
required, but the selected providers 
were first vetted by the DG for Interna-
tional Cooperation and Development 
and approved to conclude contracts 
with the Commission. In the case of 
the contribution agreement with the 
OECD, the Greek authorities carried 
out the award procedures and the law 
did not require competitive tender-
ing. However, the selection was not 
based on a thorough and documented 
analysis comparing the relative merits 
of alternative providers. That applied 
to procedures managed both by the 
Commission and the Greek authorities.

Part II — The TFGR fulfilled its mandate overall,  but there were shortcomings24

Support to accelerate the 
take-up of EU funds was 
properly structured

42 
The TFGR provided Greece with 
a comprehensive support package in 
the field of the Structural Funds. As of 
November 2014, eight projects aimed 
at improving management of the 
Structural Funds were either ongoing 
or had been completed. They covered 
both horizontal issues (monitoring, 
simplification of procedures) and 
specific support for the implementa-
tion of designated priorities (e.g. waste 
management, energy, tourism).

43 
We found that, with regard to the 
monitoring of the priority projects, 
examined in detail by the audit, the 
use of TA fell into three categories: (i) 
problem-solving on horizontal is-
sues, (ii) development of a functional 
monitoring system in Greece, and (iii) 
directly monitoring 40 of the priority 
projects selected based on a robust 
risk assessment system. The final 
activity stopped by mid-2012, due to 
the fact that the Greek side imple-
mented an appropriate monitoring 
mechanism.

40 
The decision to sign contracts with na-
tional development agencies reflected 
the strategy of involving Member 
States in the delivery of TA. For ex-
ample, the Commission considered 
selection of the national development 
agency in the field of public adminis-
tration as a logical choice due to the 
organisation’s prior cooperation with 
the domain leader.

41 
Organisationally, the agency included 
a dedicated ‘thematic unit’ for ‘public 
finance and state modernisation’, but 
it could not demonstrate prior experi-
ence in TA projects similar in scope to 
the reform of Greek central administra-
tion. The agency was typically involved 
in developing countries (notably 
sub-Saharan Africa and the Balkans). 
In 2013-2014, support for Greek public 
administration reform was the only 
project implemented by the agency 
in the EU. The other national develop-
ment agency, contracted to provide TA 
in the field of taxation, had previously 
focused on poverty reduction and 
was mainly active in under-developed 
countries in Asia and Africa.

TFGR mandate

(3)  Recommending legislative, 

regulatory, administrative and 
if necessary (re)programming 
measures for an accelerated 
take-up of EU funds (…).

Part II — The TFGR fulfilled its mandate overall,  but there were shortcomings25

44 
Regarding the division of responsibili-
ties in the field of the Structural Funds, 
cooperation between the TFGR and 
DG Regional and Urban Policy was an 
example of good internal coordina-
tion at the Commission. Under a clear 
division of responsibilities, the TFGR 
did not intervene in everyday monitor-
ing activities, which were carried out 
by DG Regional and Urban Policy, but 
took care of horizontal issues impact-
ing the implementation of the Struc-
tural Funds. Horizontal concerns were 
identified in November 2011 (e.g. sim-
plification of legislation, organisation 
of the land register) and continued to 
be addressed as such throughout the 
life of the TFGR.

45 
The TA in the area of Structural Funds 
was provided through TFGR staff (resi-
dent in the ministry of transport and 
working from the TFGR office). In this 
case the TFGR played a  well-defined 
role that led to positive outputs (see 
paragraphs 41 to 42). It should be 
noted that a task force dedicated 
to the implementation of Structural 
Funds existed prior to the creation 
of the TFGR. It was composed of one 
Commission official and three other 
experts appointed by the European 
Investment Bank. The Commission of-
ficial was responsible for coordinating 
the implementation of the programme 
in the area of the Structural Funds, 
helping the Greek authorities with the 
submission of applications and regu-
larly reporting on progress.

TFGR mandate

(4)  Preparing clear terms of refer-

ence for all technical assistance 
assignments which specify the 
nature and scope of the techni-
cal assistance (…) the budget-
ary and human resources, and 
the expected results, with mile-
stones and delivery deadlines.

Support was sufficiently 
attuned to key reform 
needs but not always 
based on a comprehen-
sive needs analysis

46 
For the audited projects we found the 
scope of assistance to be overall in line 
with the main problems identified by 
external experts. In the field of taxa-
tion, the technical analysis underlying 
the TA was appropriate in terms of 
the indicators developed and areas 
selected. The scope of TA was also well 
defined in the field of Structural Funds. 
The monitoring system, designed with 
the help of TA, was based on a sound 
risk analysis and followed by dedicated 
TA aimed at supporting implementa-
tion of individual projects.

Part II — The TFGR fulfilled its mandate overall,  but there were shortcomings26

11  The road map was agreed 
between TFGR, the Greek 
authorities and the domain 
leader (Member State that 
assumed the responsibility of 
being the main reform partner 
in a specific policy field) as an 
instrument to keep the global 
vision and a coherent follow 
up of the TA in the field of 
public administration. It 
described the global 
architecture and the strategy 
to implement administrative 
reform.

Terms of reference of 
some contracts not 
clearly defined

48 
Despite the well-defined scope of TA, 
the design of the terms of reference 
or road maps underlying the TA was 
in some cases not satisfactory. There 
were particular weaknesses in one of 
the contribution agreements signed by 
the Commission with the IMF and the 
road map11 for public administration 
reforms.

49 
The contribution agreement ‘Strength-
ening public financial management 
and tax administration in Greece’ 
(signed in December 2011) did not pre-
cisely define the scope of the work to 
be carried out by the IMF. The agree-
ment laid down only a very broad divi-
sion of responsibilities between the 
partners involved in the TA process, ac-
cording to which the IMF was to lead, 
coordinate and supervise the TA effort 
in tax administration. Outcome indica-
tors were not linked to the specific 
responsibilities of each party. Those 
responsibilities were defined in more 
detail in a later amendment to the 
agreement (2 years after signature).

47 
We did, however, identify weaknesses 
with regard to the scope of TA in the 
fields of administrative burden reduc-
tion and public administration.

(a)  As regards administrative burden 
reduction, the scope of TA was 
less than that of a similar project 
initiated by the Greek authorities 
in 2010. That project, designed in 
the framework of the ‘Adminis-
trative reform’ operational pro-
gramme (AROP), was subsequently 
put on hold and replaced by the 
agreement with the OECD on the 
delivery of TA. Among other differ-
ences, the initial project covered 
a complete assessment of all regu-
lations in the field, whereas the 
OECD agreement focused on 20 % 
of the most burdensome regula-
tions. There was no documented 
justification of the reasons for the 
modified approach.

(b)  TA in the area of public adminis-

tration was not based on a needs 
analysis carried out by the TFGR 
itself, but drew on the findings and 
recommendations of the OECD 
public governance review ‘Greece: 
review of the central administra-
tion’. However, the TA did not take 
up the key recommendation relat-
ing to anticipating impediments to 
reforms and systematically follow-
ing them up.

(c)  Synergies with the Structural 

Funds were not fully exploited. The 
specific needs and scope of the TA 
were defined without consulting 
the AROP managing authority or 
DG Employment, Social Affairs and 
Inclusion, although the operational 
programme and the TA shared 
similar objectives. Some core AROP 
actions were put on hold and im-
plemented (in a limited way) as TA 
projects under direct centralised 
management.

Part II — The TFGR fulfilled its mandate overall,  but there were shortcomings27

50 
The road map to the reform of public 
administration comprised 58 actions to 
be completed in 2012-2013. Some ac-
tions lacked an implementation sched-
ule, and the road map did not always 
define deliverables/outputs or mile-
stones. In some cases the design was 
poor and overambitious about plan-
ning (see Box 2). However, planning 
was defined by the deadlines set in the 
relevant laws by the Greek authorities 
at the end of 2011 and in line with the 
MoU. It must be noted that in some 
cases the road map did set indicators 
with which to measure results.

Technical assistance 
was appropriate to 
programme requirements

51 
The substance of the TA provided 
was largely in line with the condi-
tions of the programme, laid down 
in the MoU. However, 11 TA projects 
(in the financial institutions, health 
and home affairs policy fields) out of 
the total of 118 could not be linked to 
specific provisions in the adjustment 
programmes. The home affairs policy 
field was specifically mentioned in the 
TFGR’s mandate despite not featuring 
in the MoU.

TFGR mandate

(5)  Providing quarterly progress 

reports to the Commission and 
the Greek authorities as well as, 
on a need basis, more frequent 
alert reports.

2
x
o
B

Examples of overambitious design in the Central public administration reform road 
map

The road map envisaged that transformation scenarios for the structures of the first five ministries under 
reorganisation would be produced within 4 months (May 2012). In practice it took 9 months (October 2012) 
to produce evaluation reports for two of the five, which were then used as ‘pilot’ exercises. When the road 
map was drafted in January 2012, it did not specify the date that the whole restructuring exercise should be 
completed. In reality the restructuring exercise of all ministries (including the two pilots) was completed two 
and a half years later, in August 2014.

According to the road map, the reform in the job classifications of all employees in the central administration 
should have been completed within 6 months (i.e. July 2012). This deadline was set despite the legal and or-
ganisational complexity of the exercise (including the need to assess staff in almost 1 500 types of posts) that 
had already been recognised by the OECD in its mapping exercise of the Greek central administration. The 
deadline was not met and the reform of job classifications was completed 2 years later in autumn 2014.

Part II — The TFGR fulfilled its mandate overall,  but there were shortcomings 
28

The TFGR effectively 
monitored the progress 
of TA …

… and, to varying 
degrees, the 
deliverables of external 
service providers

52 
The key tools for the TFGR’s overall 
monitoring of TA progress were quar-
terly reports, which included annexed 
‘TA tables’.

(a)  The quarterly reports provided 
a comprehensive description of 
developments in key policies and 
overall progress of reforms, not 
only the achievements linked di-
rectly to the TA. They were there-
fore well adapted to the purpose 
of presenting the context and 
scope of TA, but not the impact of 
individual projects. Although the 
TFGR’s mandate specifically men-
tioned that the reports were to 
be provided on a quarterly basis, 
between autumn 2011 and sum-
mer 2015 only seven (out of 15 to 
be expected) were produced. The 
TFGR published the last report in 
July 2014.

(b)  The TA tables provided informa-

tion on the progress of TA projects, 
focusing on the overall objectives, 
general developments in the field, 
the TA provided during the report-
ing period and what was planned 
next.

(c)  There was more detailed moni-

toring at cluster level. Overall 
progress was discussed at regular 
meetings with the head of the 
TFGR and properly documented.

53 
For small value contracts the TFGR 
received and reviewed interim reports 
from the service providers. The com-
ments were clear and raised issues of 
coherence, completeness and compli-
ance with EU law. Following submis-
sion of the final deliverables, the TFGR 
assessed compliance with the terms of 
reference. This resulted in a note to DG 
Employment, Social Affairs and Inclu-
sion which was used for the approval 
of payment.

54 
In the case of long-term contracts, the 
TFGR was able to demonstrate that 
it closely monitored the progress of 
TA and was in regular contact with 
all providers of long-term assistance. 
This was ensured through frequent 
meetings, resident experts and joint 
missions with the IMF (for taxation). 
However, we identified weaknesses in 
the monitoring procedures for some 
long-term contracts.

(a)  Monitoring not linked to verifiable 
indicators — the follow-up of the 
contract with the IMF was not sys-
tematically documented in respect 
of assessing the achievement of 
the objectives laid down in the 
agreement. The TFGR did not 
systematically analyse the actual 
TA outcomes in the light of the ini-
tially agreed objectives or indica-
tors. Consequently, the follow-up 
did not lead to a change of initial 
project deadlines or performance 
indicators, when this was needed 
to reflect the rapidly changing 
external situation.

Part II — The TFGR fulfilled its mandate overall,  but there were shortcomings29

12  The TFGR commissioned an 
external evaluation of TA 
activities from a consortium of 
two consulting companies. 
The scope of the evaluation 
was limited, covering only tax 
and central administration 
reforms for the period 
2011-2013. In December 2014, 
the TFGR launched a further 
tender for the assessment of 
TA under the road map for the 
Hellenic Court of Audit.

Part III 
The technical assistance achieved 
mixed results

56 
Although the TFGR did not systemati-
cally monitor implementation of TA 
recommendations, the quarterly re-
ports included some result indicators:

 ο

absorption levels of the Structural 
Funds,

 ο market liquidity (financing in-
struments available to Greek 
enterprises),

 ο

tax-related indicators (e.g. out-
standing tax debt, number of 
audits, VAT filing compliance).

57 
In two cases related to the audited 
policy fields, the Greek authorities 
themselves established effective moni-
toring systems (see Box 3).

(b)  Limited TFGR involvement — un-

der the ‘Administrative burden’ 
project, TA was provided on the 
basis of a bilateral agreement be-
tween the OECD and the Greek au-
thorities. Therefore the TFGR was 
not directly involved in monitoring 
the compliance of deliverables 
with the contractual requirements.

The TFGR did not 
systematically monitor 
the results and impacts 
of TA

55 
In the context of impact assessment 
the implementation of TA recom-
mendations remained the task of the 
Greek authorities. The TFGR did not 
systematically seek feedback from the 
recipients of TA or monitor the TA im-
plementation or its broader impacts. 
The impact assessment was to some 
extent covered by the external evalua-
tions commissioned by the TFGR12 and 
in specific policy fields e.g. taxation 
there were examples of monitoring 
activities. However, a systematic over-
view of implementation would help 
to assess the absorption capacity of 
the Greek authorities and improve the 
planning of TA.

3
x
o
B

Examples of effective monitoring systems established by the Greek authorities

—  Reduction of administrative burden: the ministry responsible created a database to follow up all 86 rec-

ommendations in 13 policy fields.

—  The TFGR helped the Greek authorities to establish an IT tool for monitoring implementation of the Struc-
tural Funds at project level. This tailor-made tool performed as required by the criteria set in the MoU.

 
30

Satisfactory outputs but 
some late delivery

58 
By November 2014, the TFGR had coor-
dinated 118 TA projects (see Chart 6), 
out of which 104 were active (82) or 
completed (22). The remaining 14 pro-
jects were dormant, but some prepara-
tory work had started. The assistance 
had been provided in 12 policy fields 
which were instrumental to the reform 
process in Greece; these included very 
complex policies such as public admin-
istration reform and taxation.

59 
While the quality of outputs delivered 
by external service providers was in 
line with the respective terms of refer-
ence, we identified some delays in the 
implementation of the TA. For instance 
the contract with the OECD was signed 
in November 2012 and scheduled to 
start within 2 months after signature. 
The signature of the contract had 
already been delayed compared to 
the programme which set an initial 
deadline of Q3 2011. Due to delays 
during the preparatory phase, the 
contracting parties (Greek authorities 
and the OECD) postponed the start of 
the project to end of March 2013. The 
final deliverable was submitted by the 
OECD in April 2014, which was in line 
with the amended project schedule. 
The final version of the report was 
published in September 2014.

6 Number of projects by policy field

t
r
a
h
C

Budget and taxation

Business environment

Financial institutions

Anti-money laundry/anti-corruption

Labour and social security
Health

Cohesion Policy
Privatisation and land register

Public sector
Judicial reform

Home aﬀairs

17

16

14

13

13

10

8

7

7

6

5

State aid management and infrigements

2

2

0

Source: ECA, based on TFGR data.

4

6

8

10

12

14

16

18

Part III — The technical assistance achieved mixed results  
31

A varied contribution to 
the reform process

60 
The ultimate objective of the TA was to 
help achieve effective and sustainable 
reform in the policy fields it addressed, 
even if responsibility for implementing 
reform lay with the Greek authorities 
(and not the TFGR or the Commission). 
The resulting reforms are therefore 
an important indicator of the success 
of the TA. This section of the report 
analyses the progress of the reforms 
resulting from the TA projects audited 
(see Annex II), and demonstrates sig-
nificant variations between them.

62 
To address the situation of poor 
inter-ministerial coordination, TA was 
used to facilitate the establishment of 
a general secretariat for coordination 
(GSCO). However, the GSCO was not 
made fully operational until November 
2013. The general coordinator was ini-
tially intended as a ‘permanent’ senior 
public post with a 5-year mandate to 
ensure the continuity of the state. In 
fact, in the 2 years following the es-
tablishment of the GSCO, the post was 
occupied successively by three politi-
cal appointees. This was at odds with 
the TA-recommended model aiming at 
addressing business continuity risk.

63 
In contrast with the organisation 
charts introduced as part of the reor-
ganisation of central administration, 
the creation of the new GSCO did not 
result in efficiency gains in the organi-
sation of the services under the prime 
minister. Initial proposals by the TFGR, 
the domain leader and the Greek 
working group were not adopted, 
and since 2013 there have been three 
administrative structures, which have 
faced problems with overlaps and 
duplication of responsibilities (see 
Chart 7). The three general secretariats 
were given over two hundred diverse 
but detailed responsibilities.

Public administration

61 
As part of the reform of public admin-
istration, TA was provided to help the 
Greek authorities with evaluating and 
reorganising the structure of public 
entities. However, the evaluation exer-
cise had little impact on the organisa-
tion of some entities, notably govern-
ment ministries, and job descriptions 
were not developed in a systematic 
manner. As a result, although the 
overall number of managerial posts 
was reduced by 40 %, the number of 
staff and functions in each ministry 
did not change significantly. Thereby, 
the reform did not achieve significant 
improvements in terms of higher mo-
bility and flexibility in the operation of 
the civil service.

Part III — The technical assistance achieved mixed results 32

7 Overlaps at the centre of government

t
r
a
h
C

General Secretariat
of the Government

13 units for the coordination
of government work
3 units of administrative support
3 private political oﬃces
8 strategic units
4 law services

General Secretariat
of Coordination

General Secretariat 
of the Prime Minister

Source: ECA.

Business environment

64 
Of the 86 OECD recommendations on 
reducing the administrative burden, 
60 required amendments to primary 
legislation. As at end of November 
2014, the necessary regulations had 
been adopted in 52 cases. In seven 
cases the legislative work was still on-
going or had been postponed.

65 
Out of the required 32 cases for 
amendments of secondary legisla-
tion, 19 had not been implemented 
by the end of November 2014. These 
cases represented various sectors (in 
particular energy — seven cases) and 
jointly accounted for 22.5 % of the to-
tal administrative burden (of this 12 % 
was attributable to a single regulation 
in the area of VAT law).

Part III — The technical assistance achieved mixed results  
33

13  Enhanced provision of TA was 
not the only instrument 
applied by the Commission 
with a view to increasing 
absorption of the Structural 
Funds. In July 2011 the 
Structural Funds co-financing 
rate was raised to 85 %, and in 
December 2011 there was 
a further 10 % ‘top-up’.

Structural Funds

66 
In terms of the overall absorption rate, 
during the period 2010 to September 
2014 Greece’s ranking among all EU 
Member States improved from 17th 
to 6th. DG Regional and Urban Policy 
data show that at the end of 2011 (i.e. 
3 months after the creation of the 
TFGR) the overall absorption rate of 
the Structural Funds in Greece (based 
on payment claims) was 1.5 % above 
the EU average, and the country was 
ranked 18th. In 2014, the absorp-
tion rate exceeded the EU average 
by 11.5 %. The target for 2012 was 
not achieved, but in 2013 the ab-
sorption rate significantly exceeded 
the MoU target (by a cumulative 
258 million euro over the financing 
perspective)13.

Taxation (revenue 
administration)

67 
Through the ‘debt collection’ pro-
ject, new collection methods were 
introduced in 2014 and improved 
effectiveness. However, the Greek 
administration still offered no effective 
legal support for staff in charge of the 
recovery procedures. Further, the large 
debtor unit, created with the help of 
TA, was understaffed (fewer than 30 
people at the end of 2013, and 57 in 
October 2014, compared with a recom-
mended full complement of 90).

68 
The Greek legal framework still re-
quires the tax authorities to perform 
cumbersome procedures on debt 
deemed not collectable, instead of 
concentrating resources where collec-
tion is more likely. In this respect the 
TA focused on simplifying procedures 
and addressing the issue of uncollect-
able debt, but the Greek authorities 
took limited actions in this respect.

69 
The number of staff assigned under 
the ‘control of large taxpayers’ assign-
ment was still unsatisfactory. The unit 
suffered from high staff turnover, and 
its efficiency was further hampered 
by the fact that insolvent companies 
were still subject to audit procedures. 
TA in this field was intensified from 
April 2014. According to the joint mis-
sion reports by the IMF and Commis-
sion staff, the overall performance 
remained unsatisfactory with too few 
audits performed compared to MoU 
targets, lack of capacity building in the 
field and scare resources dedicated 
to tasks which are not likely to lead to 
high levels of revenue.

70 
Results linked to the ‘Developing 
control of high-wealth individuals and 
high-income self-employed’ project 
were also very limited. The High-
wealth individuals audit centre was 
not established until June 2013. In 2013 
approximately 450 audits were com-
pleted. The increase in tax assessments 
brought in 108 million euro, at a collec-
tion rate of only 22 %. Productivity was 
low, with each auditor dealing with 
fewer than three cases per annum on 
average and overall slow progress.

Part III — The technical assistance achieved mixed results 34

71 
The slow progress made and diffi-
culties experienced in providing TA 
through taxation projects were also 
attributable to several exogenous fac-
tors, both political (fresh elections in 
spring 2012) and organisational (high 
turnover and vacant positions of key 
management personnel). These factors 
jointly impeded the TA process.

Capacity building

72 
Capacity building within the Greek 
administration was considered a hori-
zontal goal of TA in a number of pro-
jects. In the context of administrative 
burden reduction, the OECD ran a two-
day training programme for 44 civil 
servants from various departments, 
mostly in sectors relevant to the scope 
of the project. According to the OECD 
assessment, the ‘capacity-building’ 
component of the project was not fully 
exploited owing to the limited time 
available for training activities.

73 
In the field of public administration, 
the national school for public admin-
istration confirmed that it benefited 
from TA by establishing contacts with 
international experts (primarily spe-
cialising in anti-corruption training). 
Furthermore, 1 200 civil servants par-
ticipated in training organised by the 
national centre for public administra-
tion and local government. A majority 
of the courses followed (84 %) covered 
the issues of money-laundering and 
corruption.

Part III — The technical assistance achieved mixed results Conclusions and 
recommendations

35

74 
In the TFGR the Commission created 
a flexible mechanism for coordinat-
ing a broadly-based programme of 
technical assistance. TA was largely 
delivered in line with the requirements 
of the Greek economic adjustment 
programmes. The TFGR achieved its 
mandate overall. However, there were 
shortcomings and mixed results in 
terms of its influence on the progress 
of reforms. This assessment has to 
be seen in the context of the volatile 
political situation in Greece and the 
urgency imposed by the required 
reforms.

Organisation and 
planning of technical 
assistance

75 
As the TFGR was established in sum-
mer 2011, more than a year had passed 
since the start of the first economic 
adjustment programme and signifi-
cant amounts of financial support had 
already been disbursed. In this context 
the Commission created an entity spe-
cifically for the delivery of TA without 
investigating alternative solutions. 
Assistance was provided ‘on demand’ 
following a request from the Greek au-
thorities and in line with the MoU but 
not based on a single comprehensive 
strategic document. The TFGR was not 
given a dedicated budget (paragraphs 
15 to 26).

Recommendation 1

The establishment of any entity for de-
livering TA should be based on a strat-
egy with well-defined objectives. The 
strategy should define the nature and 
division of responsibilities between 
parties. It should be formally endorsed 
by the beneficiary Member State to 
guarantee ownership and efficient 
implementation.

Meeting the TFGR 
mandate

76 
The TFGR was established with the aim 
of supporting the Greek reform pro-
gramme based on a specific mandate 
that defined its responsibilities and the 
scope of work. The TFGR was overall 
successful in meeting this mandate, 
but there were shortcomings.

 ο

Identifying needs and coordi-
nating TA delivery: the TFGR 
established a varied system for 
TA delivery, mainly using exter-
nal contractors — partly due to 
administrative constraints which 
prevented the Commission from 
employing experts directly. The 
system generated an increased 
need for coordination. Overall, the 
TFGR managed this well, despite 
deficiencies at project level (para-
graphs 28 to 34).

Conclusions and recommendations

36

 ο Definition of TA details: the 

Recommendation 2

TFGR applied a mix of TA deliv-
ery modes, which in some cases 
were not the most appropriate, 
given the nature of the services 
to be provided. Service providers 
were not selected on the basis of 
a comparative analysis of available 
options (paragraphs 35 to 41).

 ο

Supporting take-up of EU funds: 
the TFGR offered a balanced 
basket of measures to support the 
implementation of EU funds in 
Greece. This support was provided 
by the TFGR staff themselves 
and was well-coordinated with 
other Commission services (para-
graphs 42 to 45).

 ο Designing terms of reference: 

the scope of TA was on the whole 
in line with the conditions at-
tached to the Greek economic 
adjustment programme, but there 
were weaknesses in the design of 
the terms of references of some 
contracts. Some agreements with 
service providers did not clearly 
specify the scope of the work to be 
delivered (paragraphs 46 to 51).

 ο Progress reporting: the TFGR 

used the quarterly reports as 
one of its means of reporting on 
the progress of its work; how-
ever, these were published less 
frequently than required (para-
graphs 52 to 54).

The Commission should create a pool 
of external experts who could be 
deployed on an ad hoc basis on TA 
projects in Member States.

Recommendation 3

When designing TA programmes the 
Commission should analyse the com-
plexity that arises from involving mul-
tiple partners and the increased need 
for coordination resulting thereof. In 
specific policy fields it should aim at 
streamlining the number of partners in 
order to ensure a coherent methodol-
ogy for the provision of TA.

Recommendation 4

TA actions should be prioritised follow-
ing an assessment of their potential to 
bring about the strategic objectives. 
TA should be focused and operate 
through the most appropriate and 
effective implementation mode, in ac-
cordance with the existing legislative 
and regulatory framework, and taking 
into account the political context.

Conclusions and recommendations

37

Recommendation 5

The Commission should select service 
providers based on a comparative 
analysis of the available options. Con-
tracts should clearly define the scope 
of deliverables and set measurable 
performance indicators.

TA results

77 
The TFGR did not systematically moni-
tor the implementation or impact of TA 
recommendations. We understand that 
the implementation of reforms was the 
responsibility of the Greek authorities 
and that monitoring took place in the 
context of the economic adjustment 
programme. However, monitoring by 
the TFGR could serve the purpose of 
measuring the effectiveness of TA and, 
if necessary, adjusting its scope or 
means of implementation (paragraphs 
55 to 57).

79 
In terms of its impact on the overall 
progress of reforms in Greece, the 
TFGR achieved mixed results. There 
was good progress with regard to the 
implementation of Structural Funds. 
On the other hand, in the areas of pub-
lic administration and taxation TA was 
often only partially effective, i.e. it was 
not implemented by the Greek author-
ities as widely or rapidly as intended 
(paragraphs 60 to 73).

Recommendation 6

The Commission should seek feedback 
from the beneficiary Member State(s) 
on the provision of TA. The implemen-
tation of TA should be systematically 
monitored in the light of objectives 
set. With regard to the activities of the 
TFGR, the Commission should carry 
out a comprehensive ex-post evalua-
tion. These actions are crucial for as-
sessing effectiveness and/or adjusting 
the delivery of TA.

78 
Good progress was made in all the 
audited policy fields. By November 
2014, the TFGR had coordinated 118 
TA projects in 12 policy fields. The 
TFGR effectively delivered relevant TA 
to the Greek authorities in a climate 
of considerable political uncertainty 
(paragraphs 58 to 59).

Recommendation 7

Aiming at the achievement of sus-
tainable results, TA should focus on 
strengthening the capacity of national 
administrations. It should be delivered 
with a view to business continuity and 
the sustainability of reforms, which 
means anchoring them in local gov-
ernment practices.

Conclusions and recommendations

38

This Report was adopted by Chamber IV, headed by Mr Milan Martin CVIKL, Member 
of the Court of Auditors, in Luxembourg at its meeting of 11 November 2015.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

 
 
 
Annexes

39

I
x
e
n
n
A

Overview of TA projects by policy field

Reform of the administration at central level

Public sector reform

1. 

2. 

3. 

4. 

Creation of a permanent inter-ministerial general secretariat for coordination and implementation of the reform.

Adoption of a 2-year strategy and action plan for central administrative reform.

Assessment and reorganisation of the internal structure of Greek ministries (central and decentralised levels).

 Definition of an HR strategy (recruitment procedures, career management, training, mobility, etc.) drafting of instructions for the organisation of all 
HR services across ministries, under MAREG coordination.

Reform of the administration at regional/local level

5. 

6. 

7. 

Voluntary mobility scheme for municipal staff.

Intra-community mobility and evaluation process.

e-government strategy (key component of the Greek digital strategy).

Revenue administration

Budget and taxation

8. 

9. 

10. 

11. 

12. 

13. 

14. 

Organisation and management.

Strengthening debt collection and management.

Revamping the taxpayer audit function.

Enhancing control of large corporate taxpayers.

Developing control of high-wealth individuals and high-income self-employed.

Strengthening the tax dispute resolution system.

Swiss-Greek tax agreement.

Tax policy

15. 

16. 

Improving the legislative framework, notably via work on the income tax code, tax procedure code and tax property legislation.

Review of VAT legislation and progress on VAT fraud.

Public financial management

17.  Modernising budget preparation.

18. 

19. 

20. 

21. 

Improving payment processes.

Enhancing fiscal reporting.

Strengthening PFM laws, institutions and systems.

Code of books and records and accounting legislation.

Hellenic Court of Audit

22. 

23. 

24. 

Strengthening HCA relations with the parliament and other relevant stakeholders.

Preparation and implementation of an annual audit program.

Building financial audit capacity through pilot audits.

 
Annexes

40

I
x
e
n
n
A

Money-laundering and tax evasion

Measures to counter money-laundering and corruption

25. 

26. 

27. 

28. 

29. 

30. 

 Draw up a road map indicating the objectives, goals, priorities and timing of actions to be taken by several government departments, law enforce-
ment entities, prosecution services and supervisory authorities to use money-laundering prevention tools to detect tax evasion.

Strengthen reporting on tax evasion to the Financial Intelligence Unit by financial institutions and other reporting entities.

Strengthen the analytical tools and skills of the Financial Intelligence Unit in the area of tax evasion.

Strengthen financial investigation and law enforcement in relation to tax evasion.

Strengthen coordination between authorities involved in the anti-money laundering network.

Strengthen exchange of information.

Corruption

31. 

32. 

33. 

34. 

35. 

36. 

37. 

Draw up a road map indicating the objectives, goals, priorities and timing of actions to be taken.

Set up a global national anti-corruption strategy

Strengthen coordination, including via a national coordinator.

Strengthen prevention, awareness-raising and public integrity.

Strengthen the financial investigation and prosecution of corruption, in particular in high-risk sectors.

Strengthen the exchange of information.

Strengthen the legal framework.

Business environment

38. 

 Improve doing business indicator scores by simplifying business procedures (for three indicators: business start-ups, registering property and 
obtaining construction permits).

Trade facilitation

39. 

40. 

41. 

42. 

43. 

44. 

 Simplification of pre-customs procedures (obtaining certificates and export licences) and creating an interconnected electronic system  
(single window) for exports.

Simplification of customs procedures.

Customs: reorganisation and reform of customs administration.

Export promotion.

Reduction of administrative burden for businesses.

Screening of regulations restricting business

45. 

Public procurement.

46. 

47. 

48. 

49. 

50. 

Public works.

Simplification of investment approvals and licences.

Business parks.

Economic analysis of business environment reforms.

 SME policy: remove regulatory, administrative and legal bottlenecks that hamper the operation of SMEs, including aspects related to access to 
finance.

 
Annexes

41

I
x
e
n
n
A

Liberalisation of regulated professions and activities

51. 

52. 

Screening of amendment to regulation liberalising regulated professions.

 Project evaluating the effects of the liberalisation of professions: lawyers and notaries, architects and engineers, plumbers and electricians, char-
tered accountants, stevedores.

53. 

Abolition of certain reserved and shared activities.

Financial institutions

Banking

54. 

Implementation of resolution processes in the banking and insurance sector.

Insurance

55. 

56. 

Reform of insurance guarantee schemes.

 The Greek administration (Bank of Greece) is analysing the capacity of the insurance sector to cover social security/pension schemes in compliance 
with enhanced requirements under the EU legislative framework.

57. 

Development of policy and preparation by the Bank of Greece of a legislative proposal on occupational pension schemes.

Access to finance

58. 

59. 

60. 

61. 

62. 

63. 

64. 

Institution for growth in Greece.

ETEAN risk management.

Targets for lending.

Banks/SMEs dialogue platform.

 Improvement of the information portal (espa.gr) on the availability of funding for SMEs/ creation of a management flow tool to process funding 
requests from SMEs.

Support development of a financial instrument support scheme to substitute lacking collateral and thus facilitate lending to SMEs.

Support development of financial instrument support schemes.

65.  Microcredit/microfinance: launch of pilot projects.

66.  Microcredit/micro finance: establish microcredit institutions outside the banking sector.

67.  Microfinance legislative framework.

Privatisation and land register

68. 

69. 

70. 

71. 

72. 

Real estate.

Land register.

Land use and land planning.

Airports.

Ports.

Water

73. 

74. 

Establishment of regulatory framework, pricing policy and licence amendment (EYDAP), settlement of receivables from the state.

 Alignment of EYATH pricing policy with that of other water companies, staffing and operations of the special secretariat for water, strengthen the 
regulator for water.

 
42

Annexes

I
x
e
n
n
A

75. 

e-Justice.

76.  Mediation.

77. 

Collection of statistics in the field of justice.

78. 

Review of the code of civil procedure.

79. 

80. 

Access to the legal profession.

Introduce out-of-court settlement in administrative matters.

81. 

Priority projects.

82.  Waste management.

Judicial reform

Cohesion policy

83. 

84. 

85. 

86. 

87. 

88. 

Simplification of the Structural Fund management and control system and development of a new law for 2014-2020.

Energy.

Aviation.

Tourism.

Logistics.

Electronic communications.

89. 

Supporting the development of a social economy in Greece.

90.  Modernising the work of the public employment service (OAED).

Labour and social security

91. 

92. 

93. 

94. 

95. 

96. 

97. 

98. 

99. 

Developing the work of the labour inspectorate (SEPE).

Fight against youth unemployment.

Employment action plan.

Temporary work agencies.

Collective dismissals.

Social security contributions;

Social security system review;

Social welfare safety net; and

Education.

Innovation

100.  Adoption of new law on research and innovation.

101.  Development of a road map for innovation, with particular emphasis on ‘smart specialisation strategy’.

 
Annexes

43

I
x
e
n
n
A

Health reform

102. 

Implementation of a comprehensive programme of public health sector reform (‘Health in action’).

Health

103.  Pharmaceutical policy  —  pricing and reimbursement.

104.  e-Health.

105.  Diagnosis-related groups (DRGs) and hospital management.

106.  Health tourism.

107.  Primary health care.

108.  Administration, organisation, duties and responsibilities of the national organisation for healthcare services provision (EOPYY).

109.  NHS human resources.

110.  Public health.

111.  Procurement.

Home affairs

112.  Reform of the department of asylum and migration.

113. 

Improve Greece’s capacity to absorb SOLID funds.

114.  Procurement in relation to SOLID funds.

115.  Accelerate and improve appeal processes related to migration.

116.  Capacity building of the authorities to use the Structural Funds in the field of migration.

State-aid management and infringements

117.  State-aid management.

118. 

Infringements.

Source: TFGR project list by policy field.

 
Annexes

44

Overview of audited TA projects

Policy fields

Description

TA modes

I
I
x
e
n
n
A

Public administration 
(public sector reform)

Establishment of the general secretariat for government 
coordination (GSCO).

Adoption of a 2-year strategy and action plan for central 
administrative reform.

Assessment and reorganisation of the internal structure 
of Greek ministries (central and decentralised levels).

Definition of an HR strategy (recruitment, career 
management, training, mobility, recruitment of 
managers, staff assessment).

Revenue administra-
tion (budget and 
taxation)

Strengthening debt collection and management.

Enhancing control of large corporate taxpayers.

Developing control of high-wealth individuals and high-
income self-employed.

Business environment

Reduction of administrative burden for businesses.

Two resident experts in Greek central administration

Low-value contract:
Support services to reform central administration  
(contract value 15 000 euro, actual expenditure 10 500 euro).

Large contracts:
Contract with a national development agency 
(contract value 750 000 euro, actual expenditure 304 000 euro).

Missions:
Expert missions funded through ESF central budget, further missions 
financed through AROP and under the contract with the national 
development agency.

Three resident experts in Greek central administration

Missions:
Expert missions funded through Fiscalis and ESF central budget.

Large contracts:
IMF, financed through ESF central budget, covering e.g. debt collection 
(total contract value 3.25 million euro).

National development agency, financed through ESF central budget 
(budget 600 000 euro).

Large contract:
Contribution agreement with the OECD, signed by the Ministry of 
Administrative Reform and e-Governance, funded from Administrative 
Reform OP (value 1.2 million euro).

Low-value contract:
Contract for legislative work with Greek law firm (value 15 000 euro).

Low-value contracts:
Four contracts with individual service providers (total value 
50 000 euro).

Liberalisation of regulated professions and activities: 
screening and amendment of secondary legislation.

Liberalisation of regulated professions and activities: 
evaluating the effects of the liberalisation of 
professions.

Abolition of certain reserved and shared activities.

Institution for Growth in Greece.

Direct support by TFGR staff.

Monitoring 40 out of the 181 priority projects.

Direct support by TFGR staff.

Business environment

Access to finance  
(financial institutions)

Structural Funds  
(cohesion policy)

 
Annexes

45

I
I
I
x
e
n
n
A

Bodies visited in the course of the audit

Entity

Task Force for Greece

Type of visit

Audit visit

Purpose of visit

Interviews and collection of audit evidence relating to TA projects and 
horizontal questions.

Secretariat-General of the European 
Commission

Directorate-General for Employment,  
Social Affairs and Inclusion

Directorate General for Taxation and 
Customs Union

Directorate-General for Regional and  
Urban Policy

Ministry of Administrative Reform and  
e-Governance of the Hellenic Republic

Ministry of Administrative Reform and 
e-Governance of the Hellenic Republic 
(MAREG)

General Secretariat for Coordination  
of the Hellenic Republic (GSCO)

National Centre for Public Administration 
and Local Government (EKDDA)

Institute for Regulatory Policy Research 
(INERP)

Audit visit

Interview and collection of audit evidence relating to horizontal questions.

Audit visit

Audit visit

Audit visit

Audit visit

Interview and collection of audit evidence relating to TA projects in the fields 
of Structural Funds and public administration.

Interview and collection of audit evidence relating to TA projects in the field 
of taxation.

Interview and collection of audit evidence relating to TA projects in the field 
of Structural Funds.

Interview and collection of audit evidence relating to the TA contract signed 
by the ministry with the OECD in the field of administrative burden reduction.

Information-gathering visit

Interview relating to TA projects and horizontal questions.

Information-gathering visit

Interview relating to TA projects and horizontal questions.

Information-gathering visit

Interview relating to TA projects in the field of public administration.

Information-gathering visit

Interview relating to TA projects.

National development agency

Audit visit

Interview and collection of audit evidence relating to the delegation agree-
ment in the field of public administration.

OECD

IMF

Source: ECA.

Information-gathering visit

Interview on the contribution agreement in the field of administrative 
burden reduction.

Audit visit

Audit of two contribution agreements in the field of taxation.

 
Annexes

46

V

I
x
e
n
n
A

Contribution Agreement between the Ministry of Administrative Reform and 
e-Governance and the OECD on the reduction of administrative burden in Greece

Profile and tasks of  
the Greek experts

 ο Project methodology assumed close cooperation with the Greek public administration.
 ο 13 teams of experts (75 members in total) selected through an open invitation procedure.
 ο Required skills included good knowledge of the regulatory framework in a given area, very good English language skills 

and the capacity to present complex material.

 ο Greek experts were charged with providing input on the relevant regulatory framework for mapping of the 

administrative burden and served as contact points in line ministries.

Quality of deliverables  
by the Greek experts

 ο Profiles of the selected experts did not entirely fit initial requirements:

i.  Limited drafting skills of complex material in English.
ii. 

Insufficient knowledge of the Greek legal system and the specific legislation (only 4 of the 13 team leaders 
represented line ministries in charge of the specific regulations).

iii.  Part-time involvement in the project.

 ο Poor quality of data delivered by the Greek experts was a major challenge for the project, even though according to the 

OECD the project was eventually successfully finalised with data collection complemented by other means.

 ο As a mitigating action, the OECD decided to subcontract the mapping of regulations in all 13 sectors to four local law firms.

 ο Participation in working groups, intermediation between the Greek authorities and the service providers aimed at the 

TFGR involvement

improvement of contract management (considered unsatisfactory by the TFGR).

 ο Coordination of inter-services consultations with the aim of verifying the compliance of regulations with EU law.

 
Annexes

47

V
x
e
n
n
A

Role of the TFGR in the provision of technical assistance by policy field

Administrative burden 
reduction  
(business environment)

 ο Primarily a facilitator, with the aim of improving coordination between the Greek authorities, the OECD and other 

Commission services.

 ο Not involved in selecting the service provider, the contractual arrangements between the OECD and the Greek 

authorities, or monitoring implementation.

 ο Took part in four out of eight high-level committee meetings.
 ο Overview of project implementation, participation in working meetings, provision of comments on the draft report and 

organisation of inter-service consultations with 11 Commission DGs.

 ο Provision of dedicated TA to support implementation of the recommendations, following finalisation of the project.

Liberalisation of  
regulated professions  
(business environment)

 ο Defined the terms of reference on the basis of MoU requirements and the Greek authorities’ demands.
 ο Support for the award procedure (preselection of service providers, communication with candidates).
 ο Monitoring of report deliverables (comments on draft reports, final evaluation).
 ο Close cooperation with the Greek authorities (regular meetings, exchange of correspondence, adapting the TA to their 

Public administration 
(public sector reform)

needs and expectations).

Overall

 ο Continuous support in setting up the general secretariat for coordination (GSCO), among other things through a resident 

expert.

 ο Support for the process of defining the ‘2-year strategy and action plan for central administrative reform’ primarily 

through a resident TFGR expert (involved in drafting the initial strategy).

 ο Support for the ‘assessment and reorganisation of Greek ministries’ through an external long-term contract that, 

however, featured low execution (55 % 1.5 years after signature) due to the lack of specific TA requests.

 ο Monitoring and coordination of TA activities in the field of HR strategy; direct input provided by the domain leader and 

the external contractor.

Contract with the national development agency

 ο Provided the contractor with all relevant information and documents.
 ο Liaised with the Greek authorities and promoted the visibility of the EU as a source of support and financing for the 

implemented actions.

 ο Channelled the experts’ reports and deliverables received by the national development agency to the relevant Greek 

authorities.

 ο Supported the selection of experts by defining selection criteria.

Revenue administration  
(budget and taxation)

 ο Overall: defined the terms of reference, recruited experts, introduced them to the TA assignments and fed the results of 

their work into the overall provision of TA.

 ο IMF contracts: drafted the terms of reference and kept an overview of developments in the field. No comprehensive 

structured analysis of outcomes, provided only informal feedback to the contractor (with no reference to performance 
indicators).

Structural Funds  
(cohesion policy)

 ο Direct provision of TA through TFGR staff (including resident experts), which translated into high impact on the scope and 

quality of the TA actually provided to the Greek authorities.

 
Reply of the  
Commission

48

Executive summary

I
The Commission welcomes the ECA special report 
on the delivery of technical assistance (TA) to 
Greece.

The Commission decided the set-up of the Task 
Force for Greece (TFGR) on the basis of an analysis 
of the following baseline scenario.

— 

— 

In May 2010, the Greek government asked the 
international community for financial assis-
tance. The Eurogroup agreed in 2010 to provide 
bilateral loans of 80 billion euro under the first 
financial assistance programme. The IMF com-
mitted an additional 30 billion euro.

In return, Greece was requested to implement 
a series of structural reforms and fiscal meas-
ures to modernise the state, ensure financial 
and fiscal stability and strengthen the economy 
in line with the conditionalities underpinning 
the first financial assistance programme: the 
macroeconomic adjustment programme.

—  However, the initial actions of the Greek au-

thorities proved to be insufficient and progress 
in the implementation of structural reforms was 
not as successful as expected, despite Greece 
having all the existing legislative, regulatory 
and financial EU instruments (e.g. Structural 
Funds, Fiscalis programme, etc.) at its disposal.

—  The Greek authorities acknowledged the weak-
nesses of their administrative capacity and the 
difficulties encountered in delivering a compre-
hensive reform programme under intense time 
pressure, and asked the Commission to support 
their efforts and to assist with the required 
delivery of structural reforms.

On this basis the Commission considers that com-
prehensive needs analysis was thereby available, 
allowing the Commission to take a political deci-
sion to answer the urgency of the Greek request: 
the President of the Commission took the initiative 
to coordinate the efforts undertaken at the Com-
mission level by proposing a comprehensive set 
of technical assistance (TA) measures managed 
directly by the Commission to support the delivery 
of the EU/IMF adjustment programme and to accel-
erate the absorption of the EU funds.

In this framework, the creation of the TFGR was 
decided. It coordinated the various TA efforts and 
supported the Greek authorities in the manage-
ment of the TA funds directly under the latter’s 
responsibility.

In the view of the Commission, the concept of 
‘a programme of TA’ is to be interpreted in the con-
text of the mission assigned to the TFGR.

The set of TA measures decided by the Commission 
to be coordinated by the TFGR does not include the 
funds and contracts managed directly by the Greek 
authorities, which are therefore not under the 
Commission’s responsibility. The funds managed 
directly by the Greek authorities are their direct 
responsibility.

The TA activities under the Commission’s respon-
sibility are financed by the European Social Fund 
(ESF) and the European Regional Development 
Fund (ERDF) at central level (TA activities on which 
the Commission signed direct contracts with 
international organisations, national agencies and 
experts from Member States) under Art 58 of the 
Common Provision Regulation (EU) No 1303/2013. 
This needs to be distinguished from the operational 
programme funds for TA used by the Greek authori-
ties under Art 59 of the Common Provision Regu-
lation (EU) No 1303/2013 in order to contract and 
finance TA activities under shared management. 
As such, the latter cannot be considered as part of 
a ‘single technical assistance programme’.

Reply of the Commission 

49

The TFGR monitored the implementation of TA 
activities under its direct responsibility. Under 
shared management, the responsibility for design-
ing, monitoring and implementing individual pro-
jects lies with the Member States. The Commission 
monitors the achievement of agreed milestones 
based on Member States’ reports submitted for the 
programmes.

IV
On ‘a broad programme of technical assistance’, see 
the Commission reply to paragraph I.

The Commission acknowledges that the TFGR 
did not always influence the progress of reforms 
but this needs to be seen in the broader politi-
cal context and taking into account the division 
of competences between Member States and the 
European Union institutions. The implementation of 
the structural reforms was and remains the respon-
sibility of the Greek authorities, whereas the TFGR 
was available to advise/assist the Greek authorities 
where requested.

The TFGR never had the mandate or the authority 
to implement reforms irrespective of the wishes of 
the Greek authorities.

Commission reply to the heading ‘An 
incomplete entity’ before paragraph V
The TFGR was a flexible entity taking into account 
its ability to adapt in a rapidly evolving environ-
ment and its proven delivery modes of TA.

The Commission therefore does not agree that the 
TFGR should be described as an ‘an incomplete 
entity’.

V
Concerning the Commission strategy when setting 
up the TFGR, the macroeconomic adjustment pro-
gramme for Greece provided the overall strategic 
orientation for the mandate and work of the TFGR, 
while the structure and management of its opera-
tions were designed to allow for a swift reaction 
to challenging and changing circumstances. Any 

other option which was different from the setting-
up of the TFGR would have implied entering into 
a lengthy legislative process modifying the already 
existing regulations on providing funds that could 
be used for implementing reforms.

The Commission established the TFGR with the pri-
mary objective of supporting the Greek authorities 
with technical assistance for the implementation of 
key elements of the programme, including improv-
ing the absorption of the EU Structural Funds. The 
establishment of the TFGR substantially upgraded 
the quality and expanded the scope of existing 
assistance available to Greece.

The TFGR was explicitly tasked with assisting the 
Greek authorities in implementing the conditions 
of the macroeconomic adjustment programme, as 
negotiated with their creditors. (See the relevant 
parts of the TFGR mandate: (1) ‘Identifying and 
coordinating, in close cooperation with Greece and 
benefiting from input from other Member States, 
the TA that Greece needs to deliver the EU/IMF 
adjustment programme’; (2) ‘assisting the relevant 
Greek authorities in defining the details of the kind 
of TA to be provided’).

Therefore, the setting-up of the planning cycle 
inside the TFGR responded to this general context 
by including different options for delivery of TA in 
the decision process, thus ensuring the flexibility 
needed. The prioritisation of actions was depend-
ent on: (1) the requests of the Greek authorities; and 
(2) the conditions specified in the macroeconomic 
adjustment programme; and had to be adjusted 
according to the outcomes of negotiations.

Given the political volatility in Greece, the TFGR 
managed to preserve the global coherence of the 
TA framework, in cooperation with domain-leaders 
for collaborative TA actions.

VI
The Commission established a robust set-up for 
the TFGR which adequately took into account the 
underlying mandate and the context of the techni-
cal assistance. This proved to be successful in deliv-
ering technical assistance. See also the Commission 
replies to paragraphs IV and V.

Reply of the Commission 

50

VII
The financing and budgeting of TFGR activities 
were implemented in full respect of the legal 
framework and the existing Commission rules 
and procedures. The financing of TFGR technical 
assistance projects agreed with the Greek authori-
ties came from the funds under the central man-
agement of the Commission and was endorsed by 
successive Commission financing decisions. As such, 
the financing of the TA activities followed the usual 
transparency standards and the respective Commis-
sion decisions were made public.

In the same way, the procedures followed by the 
TFGR for the assignment of long-term contracts to 
international organisations or national agencies 
were compliant with the procedures foreseen in the 
financial regulation, its rules of application and the 
decision-making process, including analysis of the 
technical level of expertise required and the level of 
specialisation of the service providers. All national 
agencies and international organisations selected 
had been audited at Commission level (4- and 6- 
pillars assessment) confirming their satisfactory 
experience in the management of contracts funded 
by the EU budget.

The Commission agrees to the need for the defini-
tion of the deliverables and expected results of 
contracts. Actually the financial regulations and 
the Framework Agreements with 6-pillar organisa-
tions insist on results-based projects, following the 
logical framework description and for which value 
for money is to be established at the beginning 
of the contracting process. However, it should be 
noted that for embedded experts, as for all con-
tracts for which the actions are related to coaching 
functions, the deliverable could not be predefined 
because the report on the actions is always done 
a posteriori.

VIII
The TFGR can only ‘systematically monitor’ the TA 
that is conducted under its direct responsibility 
as contracting authority. The Commission notes 
that, under shared management, the responsibil-
ity for designing, monitoring and implementing 
individual projects lies with the Member States. The 
national authority in the Member State appoints 
auditing bodies to oversee the efficient running 
of the management and monitoring system in the 
country concerned. The Commission monitors the 
achievement of agreed milestones based on Mem-
ber States’ reports submitted for the programmes 
(information on progress in implementing indi-
vidual policy priorities was requested on an ad-hoc 
basis from the Member States). Therefore, while 
the TFGR monitored the implementation of the 
technical assistance under its direct responsibility 
as contracting authority, the implementation of the 
reforms remains under Greek responsibility.

IX
The Commission acknowledges that the impact of 
TA on the overall progress of reforms was mixed. 
This needs to be seen in the broader political con-
text and taking into account the division of compe-
tences between Member States and the European 
Union institutions. The implementation of the 
(structural) reforms was and remains the respon-
sibility of the Greek authorities, whereas the TFGR 
was available to advise/assist the Greek authorities 
where requested.

Our recommendations
See also the Commission replies to recommenda-
tions 1-7 below.

Our recommendation (a)
The Commission accepts recommendation 1.

Our recommendation (b)
The Commission accepts recommendation 2.

Reply of the Commission 

51

Our recommendation (c)
The Commission accepts recommendation 3.

Introduction

Our recommendation (d)
The Commission accepts recommendation 4.

The Commission needs to deliver TA in accordance 
with the legislative and regulatory framework.

Our recommendation (e)
The Commission accepts recommendation 5.

Procedures to select the service providers are 
those stated in the financing regulation and those 
followed by all the Commission services involved 
in the provision of technical assistance to Greek 
authorities.

See also the Commission reply to paragraph VII.

Our recommendation (f)
The Commission accepts recommendation 6 and 
will systematically monitor the TA that is con-
ducted under its direct responsibility as contracting 
authority.

03
On the ‘a comprehensive programme of tech-
nical assistance’, see the Commission reply to 
paragraph I.

The creation of the TFGR was meant to set up a new 
approach to overcome the shortfalls of the existing 
instruments, to improve the impact of the Commis-
sion contribution in the context of the crisis, and to 
help Greece to implement the reforms needed.

07
For the operation of the TFGR, the Commission put 
together a dedicated team of experts, pooled from 
across the Commission services and the Mem-
ber States, and put it at the disposal of the Greek 
authorities. Depending on the needs and circum-
stances, the TFGR chose the most appropriate 
approach and use of resources, including, among 
other things, the embedding — in Greek ministries 
and administrations — of experts from the Commis-
sion, international organisations, national agencies 
and/or high-level civil servants from other Member 
States, the organisation of workshops and the pro-
vision of short-term experts.

Our recommendation (g)
The Commission accepts recommendation 7.

Part I

The future Structural Reform Support Service (SRSS) 
action will stress this capacity-building aspect.

Commission reply to the heading 
‘Part I — The TFGR had a functional 
operational structure but lacked 
a single strategic orientation and 
dedicated budget’ before paragraph 15
The Commission considers that the TFGR’s strategic 
orientation was derived from the Memorandum of 
Understanding (MoU) and the Greek TA request. See 
the reply to paragraph V and the paragraphs below 
linked to this section.

Reply of the Commission 

52

Commission reply to the heading 
‘The TFGR was established late 
compared to the launch of the 
programme and without considering 
alternatives’ before paragraph 15
The Commission chose an appropriate set-up for 
the delivery of technical assistance in the context of 
the crisis in Greece.

As soon as Greece had submitted a request for TA 
to the Commission and a political decision by the 
Commission was made to deliver such TA to Greece, 
the TFGR was established.

In order to better appreciate the set-up framework 
of the TFGR and the grounds for its establishment, 
it is worth recalling that the Commission reacted 
as soon as problems became evident and acted 
in a situation of urgency while facing capacity 
constraints.

17
Winding down and recreating ad hoc TA groups, 
as in the case of Greece or Cyprus, may result in an 
important loss of expertise, practical know-how and 
efficiency. This is why, given the reform challenges 
ahead, the Commission decided to create the SRSS 
as a permanent, but very flexible, capacity in the 
Commission with a wider mandate, offering tailored 
expertise and practical technical support for the 
design and implementation of growth-enhancing 
administrative and structural reforms to any Mem-
ber State that may request it.

18
The Commission chose an appropriate set-up for 
the delivery of technical assistance in the context 
of the crisis in Greece. The Commission recognised 
the clear need to expand the existing technical 
support available to Greece by providing the Greek 
administration with an enhanced technical assis-
tance (TA) in order to speed up the implementation 
of reforms. The TFGR built on the extensive knowl-
edge and expertise existing in the Commission.

Given the limited duration of its mandate, alterna-
tive options of its operational procedures were not 
considered. However, a review took place at least 
once a year as regards administrative and staffing 
arrangements within the framework of the setting 
-up of the draft budget and budgetary procedure, 
as well as the clearing exercise.

Commission reply to the heading 
‘No single strategic document’ 
before paragraph 19
When setting up the TFGR, the Commission consid-
ered the macroeconomic adjustment programme 
for Greece to be an overall strategic orientation for 
its mandate and work. The structure and manage-
ment of the TFGR operations were designed to 
allow for a swift reaction to challenging and chang-
ing circumstances. The Commission established the 
TFGR with the primary objective of supporting the 
Greek authorities with technical assistance in the 
implementation of key elements of the programme, 
including improving the absorption of the EU Struc-
tural Funds. The establishment of the TFGR substan-
tially upgraded the quality and expanded the scope 
of existing assistance available to Greece.

19
In addition to the strategic orientation of the TFGR 
which was based on the macroeconomic adjust-
ment programme, the Commission recalls that 
the TFGR presented a general outline of the pro-
grammed activities per thematic area and working 
modalities to the College of Commissioners as early 
as 11 October 2011, where the organisation, the 
possible financing and the modalities of provision 
of TA were clearly identified and explained; this was 
completed by a clear presentation to all stakehold-
ers (Member States, international organisations 
and national agencies, Euro working group) on the 
financing modalities, the available amounts (in cen-
tral and shared management) and on the ‘accelera-
tion’ possibility under the EU financial regulation for 
the implementation of TA activities going forward. 
These approaches have informed the TFGR’s work in 
a consistent way throughout its duration.

Reply of the Commission 

53

24
The multiplicity of the budgetary lines, which are 
under full control of the Commission management, 
cannot be considered as a weakness. The use of 
several budget lines for the financing of horizontal 
actions is a common practice at Commission level.

Moreover, it should be underlined that the TFGR’s 
mandate does not include a systematic financial 
overview of those TA activities financed by the 
Greek authorities via the Structural Funds and man-
aged through the AROP.

The general overview of the operational pro-
gramme on TA is the responsibility of the opera-
tional Commission services while the detailed list 
of individual list of projects is held by the Member 
State, which should make it available to the Com-
mission Services upon request as foreseen in the 
regulatory framework.

Commission reply to the heading 
‘The TFGR had a flexible internal 
organisation, but staff needs were not 
defined based on a proper analysis’ 
before paragraph 25
The Commission considers that this heading should 
be better framed in the following context: due to 
the political situation and the need for flexibility 
in view of changing needs in an environment of 
profound crisis and urgency of action, it was impos-
sible to decide ex ante on certain parameters such 
as exact staff allocation.

26
The fact that staff did not always include all the 
possible staff foreseen in the ceilings did not affect 
the normal functioning of the TFGR.

20
The Commission considers that the TFGR complied 
with its mandate by assisting the Greek authorities 
in identifying the technical assistance needs.

This is also a key issue of the fundamental principle 
of ‘national ownership’ of reform delivery.

21
See the Commission reply to paragraph V for 
detailed argumentation.

22
As regards the project under shared management, 
the responsibility for designing, monitoring and 
implementing individual projects lies with the 
Member States. The Commission monitors the 
achievement of agreed milestones based on Mem-
ber State reports submitted for the programmes 
(information on progress in implementing indi-
vidual policy priorities was requested on an ad-hoc 
basis from the Member States).

Concerning the activities financed under the cen-
trally managed TA budget, an eligibility check was 
performed with the managers of the Administra-
tive reform operational programme (AROP) before 
launching the negotiation with the contractor, in 
particular to avoid overlaps.

23
The Commission acknowledges that the exist-
ence of a dedicated budgetary allocation in the EU 
budget would have made the planning of technical 
assistance easier. Still, the TFGR made the best use 
of the funding available.

The Commission considers that the Greek authori-
ties have not fully exploited the financing possibili-
ties offered by the Structural Funds for TA purposes, 
despite all assistance offered by the TFGR to sup-
port this usage. However, it should be noted that 
the budget of the AROP was reduced in agreement 
with the Commission services only when it became 
clear that those funds (committed to specific years) 
would otherwise be lost for Greece.

Reply of the Commission 

54

Part II

28
On the wording ‘comprehensive programme of TA’, 
see the Commission replies to paragraphs I and 3.

32 First alinea
In line with the conditionality set out in the macroe-
conomic adjustment programme, the Greek author-
ities signed two contracts for technical assistance 
with the OECD. While the Commission, namely DG 
Employment, Social Affairs and Inclusion, is moni-
toring the everyday activities under the operational 
programme, the implementation and the monitor-
ing of the contracts with the OECD remained under 
the responsibility of the Greek authorities, and the 
OECD retained full ownership of the content of their 
deliverables. At the request of the Greek authori-
ties, the TFGR assisted the Greek authorities and the 
OECD on the fine-tuning of the deliverables fore-
seen in the agreement, inter alia through outsourc-
ing of legal drafting and providing relevant exper-
tise on VAT and company law, as was done in the 
case of the Administrative burden reduction project 
examined by the Court.

32 Second alinea
In the area of the Structural Funds, the Commission 
facilitated support from Portugal to Greece. The 
two Member States agreed that some exchange of 
experience would be useful. The non-implementa-
tion of the possible cooperation did not involve any 
financial loss for either side or for the Commission.

34
On the TFGR role in the Administrative burden pro-
ject, see the Commission reply to paragraph 32.

Commission reply to the heading ‘The 
TFGR applied a mix of TA delivery 
modes, but some of them did not 
match with the nature of assistance’ 
before paragraph 35
The Commission considers that the TFGR delivery 
modes were adequate and served the purposes for 
which they were selected in full respect of the exist-
ing regulatory and legislative frameworks.

35
The decision to enlist support from external entities 
to deal with some aspects of the work is justified 
in terms of operational needs and associated both 
with timing of assignments and with the highly spe-
cific nature of the tasks and technical skills required.

36
The agency active in the field of taxation, to which 
the Court refers, assumed a series of tasks which 
proved its added value.

—  Together with the TFGR, preselection of suit-
able experts within or outside Member-State 
administrations.

— 

— 

— 

In cases of service contract, elaboration of the 
tender specification, launch of the call to suit-
able candidates, analysis of the offers received, 
award of the contract.

In cases of secondment from a national admin-
istration, elaboration of a secondment agree-
ment template, negotiations with the Member 
State administration.

In all cases, financial management and follow-
up of implementation of the contract (invoices 
from the Member-State administration or 
contractor, time sheets, reports) and, whenever 
needed, amendments to the agreement.

Reply of the Commission 

55

39
The financing and budgeting of TFGR activities 
were implemented in full respect of the legal 
framework and the existing Commission rules and 
procedures.

See the Commission reply to paragraph VII for the 
argumentation.

40
The role of the domain leader goes far beyond 
a punctual cooperation: it implies a constant dia-
logue and support in the referred domain through 
expertise, studies, benchmarking, etc. Conse-
quently, the involvement of the national agencies 
in the implementation of the projects is a natural 
choice substantiated by the unique expertise and 
competence and the high degree of specialisation 
of such agencies (article 190.1 (f) of the Rules of 
application of the financial regulation).

41
All the EU experts provided to the Greek authori-
ties through this agency had significant experience 
in administrative reforms in their own respective 
countries (France, England, Germany, Spain, etc.).

The experience of the national development 
agency in the Balkans was relevant to the reform 
of public administration in Greece. The agency was 
also involved with pre-accession countries. Much of 
the administrative organisation and the Greek insti-
tutions are also historically inspired by this Member 
State’s system, which also encouraged the Greek 
authorities to look jointly for this support of the 
national development agency at the operational 
level in cooperation with the TFGR and the reform 
partner.

Commission reply to the heading 
‘Support was sufficiently attuned to 
key reform needs but not always based 
on a comprehensive needs analysis’ 
before paragraph 46
The Commission considers that the Court’s head-
ing ‘Support was sufficiently attuned to key reform 
needs but not always based on a comprehensive 
needs analysis’ needs to be put into context. For 
an argumentation, see the comments on section 
Commission reply to paragraphs V and 19 of the 
introduction and to the paragraphs following this 
heading.

47 (a)
In January 2012, the road map for administrative 
reform defined by the Greek authorities was drawn 
up on the findings and recommendations of the 
OECD public governance review ‘Greece: Review of 
the central administration’. The TA provided by the 
TFGR in 2012-2013 was based on this road map, as 
well as on the priorities set in the macroeconomic 
adjustment programme.

Starting 2014, through the work of the TFGR in help-
ing the Greek administration draft the documents, 
technical assistance was based on the reform strat-
egy and a 2-year action plan for the administrative 
reform.

47 (b)
The OECD recommendations were all relayed in 
the different road maps and the seven-pillar table 
provided to the Court. This, together with the MoU, 
systematically helped to build up the background 
for the TA request. This is notable in the drafting 
of the reform strategy and the 2-year action plan 
which was prepared with the Greek administra-
tion and which uses the recommendations of the 
OECD as a starting point for identifying projects to 
address the shortcomings.

47 (c)
In terms of state-level governance, the inter-minis-
terial coordination was an important element when 
creating the general secretariat and the Council of 
Reform; this was a central recommendation of the 
OECD.

Reply of the Commission 

56

49
The agreement was drafted taking into account 
initial uncertainties in the scope of the work to be 
carried out by the IMF, on the side of the Commis-
sion, and at a very early stage in the Commission TA 
efforts, uncertainties on the Commission’s ability to 
provide a resident advisor presence in the field of 
tax administration to effectively support work on 
the ‘core functions’ (debt collection, tax audit, HWI 
audit, dispute resolution etc.). As it happened, the 
creation of the General Secretariat for Public Rev-
enue  in late 2012 increased activity in the strand 
of TA, which was assumed by the IMF (institutional 
reform and organisation), while the Commission 
(with the arrival of a second resident for debt collec-
tion in early 2013) was able to take over most of the 
work in this area.

This new division of responsibilities was already 
clarified in the February 2013 annual report sub-
mitted by the IMF FAD, covering the period until 
December 2012 (see notably paragraph 16).

50
The TFGR deployed significant efforts to set clear 
deadlines deliverable through the development of 
the 2-year action plan, which led to the develop-
ment of more detailed planning. These documents 
have been provided to the Court.

TA requests were adapted during the initial period 
to help Greece to respond to and focus with priority 
on the MoU requirements. In this field, adapting the 
TA needs was an obvious political reality.

Box 2
The Commission would like to point out thatal-
though in many instances the TFGR expressed 
internal concerns about the capacity of the Greek 
authorities to meet these deadlines, the TFGR did 
not have any authority to modify them.

To comply with the deadlines set in Greek law and 
the MoU, according to the road map, the reform 
of the job classifications of all employees in the 
central administration should have been completed 
within 6 months (i.e. July 2012). This deadline was 
set despite the legal and organisational complexity 
of the exercise, which had already been recognised 
by the OECD in its mapping exercise of the Greek 
central administration. Despite an agreed planning 
with the TFGR/domain leader having been initially 
set up, the reform of the system of klados still has 
not been initiated by the Greek authorities.

The road maps were fully in line with the MoU 
requirements.

The monitoring of reform progress in this field was 
not under TFGR responsibility.

54 (a)
In particular, with respect to the TA provided by the 
IMF, follow-up was done by the joint stock-taking 
reports of the Commission-IMF, which were under-
taken on a quarterly basis between 2012 and 2014, 
and which were very much used to analyse TA out-
comes and project future TA needs and plans.

Given the breadth of changes in the Greek situa-
tion and also the interaction with evolving MoU 
requirements, these reports were a more useful 
and operational tool than a systematic updating of 
the very general action plans captured in the initial 
agreement.

54 (b)
See the Commission reply to paragraph 32. The 
implementation and monitoring of the contract 
related to the administrative burden project with 
the OECD remained under the responsibility of the 
Greek authorities.

Reply of the Commission 

57

60
The division of competences between Member 
States and the European Union entail that the 
responsibility for the implementation of structural 
reforms lie with the Member State. Therefore, the 
actual implementation of the structural reforms was 
and remains the responsibility of the Greek authori-
ties, whereas the TFGR was available to advise/assist 
the Greek authorities where requested.

Common reply to paragraphs 61 to 65
See the Commission reply to paragraph 60.

66
Greece achieved a high rate of absorption with 
respect to the 2007-2013 programming period, 
arriving in a good position at the EU level. This 
was achieved through close cooperation between 
officials from the Commission and Greek ministries 
and managing authorities in order to support them 
in administrative terms, setting deadlines, providing 
technical support where necessary.

Common reply to paragraphs 67 to 70
See the Commission reply to paragraph 60.

71
The Commission shares the analysis of the Court 
concerning the reasons for the slow progress made 
and the difficulties experienced in providing TA 
through taxation projects. See also the Commission 
reply to paragraph 60.

72
See the Commission reply to paragraph 60.

Part III

Commission reply to the heading 
‘Part III  —  The technical assistance 
achieved mixed results’ before 
paragraph 55
The Commission is of the opinion that the heading 
‘Part III — the technical assistance achieved mixed 
results’ should be placed into the context, in view of 
the distinctive role of the Greek authorities and the 
Commission in relation to the impact of technical 
assistance on the overall progress of reforms. The 
division of competences between Member States 
and the European Union entail that the responsibil-
ity for the implementation of structural reforms 
lie with the Member State. Therefore, the actual 
implementation of the structural reforms was and 
remains the responsibility of the Greek authorities, 
whereas the TFGR was available to advise/assist the 
Greek authorities where requested.

Common reply to paragraphs 55 
and 56
The need for monitoring the implementation of TA 
activities and recommendations should take into 
account the monitoring role of the institutions in 
the context of the programme, and not only the 
TFGR role.

56
In the Commission’s view, the TFGR monitored the 
implementation of TA activities under its direct 
responsibility.

59
Concerning the delay in delivering TA projects 
under shared management, the Commission wishes 
to highlight that in line with the conditionality set 
out in the macroeconomic adjustment programme, 
the contract with the OECD was signed by the 
Greek authorities; thus the implementation and the 
monitoring of the contracts remained under full the 
responsibility of the Greek authorities.

See also the Commission replies to paragraphs 32 
and 47.

Reply of the Commission 

58

Conclusions and recommendations

74
For the Commission interpretation of ‘a broadly-
based programme of technical assistance’, see the 
Commission reply to paragraph I.

Recommendation 1
The Commission accepts recommendation 1.

The new SRSS service will take this recommenda-
tion into account for new TA assignments.

The Commission intends to incorporate the recom-
mendation of the Court in the definition of the 
framework for the SRSS activities.

76
The Commission considers that the TFGR has ful-
filled its mandate. See the Commission reply to part 
II of this report.

76 First alinea
The Commission considers that the TA was shown 
to be optimal through a combination of embedded 
experts and short-term experts, local and interna-
tional, in order to fully embrace complex areas of 
reform, while always taking into account the highly 
specific nature of the tasks and technical skills 
required.

Among the different mechanisms for TA provision, 
the use of external contractors is of the utmost 
importance for the delivery of technical assistance 
in cases where the expertise was not available 
within the Commission.

The Commission therefore used the existing instru-
ments to contract experts who fulfilled the neces-
sary requirements.

Based on the provisions in the staff regulations, 
the Commission employed experts directly also on 
a non-permanent basis; the use of external exper-
tise was based on a needs assessment.

Therefore, the Commission employed only the 
resources needed in the framework of the urgent 
solutions to be provided in the Greek context, 
including the number of service providers and 
external expertise.

76 Second alinea
The Commission selected the service providers in 
full respect of the legal framework and the existing 
Commission rules.

76 Fourth alinea
The Commission considers the design of the terms 
of reference adequate. The Commission adopted 
different and specific approaches when design-
ing terms of reference and action plans depending 
on the type of project, the conditionality of the 
macroeconomic adjustment programme, the type 
of intervention to be carried out, the circumstances 
under which the contractor had to contribute to the 
action and the state of advancement of the project.

See also the Commission replies to paragraphs 49 
and 50.

Recommendation 2
The Commission accepts recommendation 2.

Reply of the Commission 

59

Recommendation 3
The Commission accepts recommendation 3.

Recommendation 5
The Commission accepts recommendation 5.

Taking into account the important number of 
efforts deployed by Member States (euro area or 
non-euro area), the Commission, international and 
national organisations in order to support Greece 
in facing the crisis and undertaking the necessary 
reform planning and implementation, the Com-
mission considers that the number of stakeholders 
involved was appropriate.

Therefore, the number of partners reflected the 
actions that were necessary in order to fully address 
the purpose of the assistance.

Recommendation 4
The Commission accepts recommendation 4.

The TFGR’s strategy characterised by a high degree 
of flexibility to allow for a quick and efficient 
response to the changing needs in an environment 
of profound crisis and urgency to act proved to be 
well adapted to the circumstances. The Commis-
sion would like to point out that, depending on the 
needs and circumstances, the TFGR chose the most 
appropriate approach and use of resources, includ-
ing, among other things, by embedding in Greek 
ministries and administrations experts from the 
Commission, international organisations, national 
agencies and/or high-level civil servants from other 
Member States, by organising workshops and by 
providing short-term experts.

Therefore, the setting-up of the planning cycle 
inside the TFGR responded to this general context 
ensuring the flexibility needed in the decision 
process on different options for delivery of TA. 
The prioritisation of actions was dependent on 
the requests of the Greek authorities and on the 
economic adjustment programme’s conditions and 
had to be adjusted according to the outcomes of 
negotiations.

The procedures followed by the TFGR for the 
assignment of long-term contracts to international 
organisations or national agencies were compli-
ant with the procedures foreseen in the financial 
regulation, its rules of application and the decision-
making process.

All national agencies and international organisa-
tions selected had been audited at Commission 
level (4- and 6- pillar assessments) confirming their 
satisfactory experience in the management of con-
tracts funded by the EU budget.

The Commission would like to stress that an addi-
tional effort has been made in the results-based 
approach after the entry into force of the new finan-
cial regulation in 2013: new Framework Agreements 
were signed with 6-pillar organisations insisting on 
results-based projects, following the logical frame-
work description and for which value for money is 
to be established at the beginning of the contract-
ing process.

77
The Commission monitored the overall imple-
mentation of the technical assistance. The specific 
projects to implement the reforms were conducted 
under the responsibility of the Greek authorities 
and were therefore not subject to monitoring by 
the Commission.

79
See the Commission reply to part III of this report 
and to paragraph 55.

Reply of the Commission 

60

Recommendation 6
The Commission accepts recommendation 6 and 
will systematically monitor the TA that is con-
ducted under its direct responsibility as contracting 
authority.

In setting up the new framework that will be the 
basis for the SRSS actions, the Commission will con-
sider, in its ex-ante analysis, the lessons learned and 
the experience gained during the implementation 
of the TA actions by the TFGR. Moreover, the Com-
mission considers launching a call for tender for an 
ex-post evaluation of the activities implemented in 
Greece, once all TA activities are completed.

Recommendation 7
The Commission accepts recommendation 7.

Future SRSS action will stress this capacity-building 
aspect.

HOW TO OBTAIN EU PUBLICATIONS

Free publications:

(cid:127) 

one copy: 
via EU Bookshop (http://bookshop.europa.eu);

(cid:127)   more than one copy or posters/maps: 

from the European Union’s representations (http://ec.europa.eu/represent_en.htm);  
from the delegations in non-EU countries (http://eeas.europa.eu/delegations/index_en.htm);  
by contacting the Europe Direct service (http://europa.eu/europedirect/index_en.htm) or  
calling 00 800 6 7 8 9 10 11 (freephone number from anywhere in the EU) (*).

(*) 

The information given is free, as are most calls (though some operators, phone boxes or hotels may charge you).

Priced publications:

(cid:127) 

via EU Bookshop (http://bookshop.europa.eu).

 
The Task Force for Greece was established in 2011 by the 
European Commission to support implementation of the 
Economic adjustment programme with a broad range of 
technical assistance. This report examines whether the 
task force fulfilled its mandate and whether the assistance 
provided for Greece made an effective contribution to the 
reform process. We found that overall the task force 
proved itself as a functioning mechanism for delivering 
and co-ordinating complex technical assistance activities. 
However, there were weaknesses in the design of some 
projects and only mixed results in terms of influence on 
the progress of reform.

EUROPEAN
COURT
OF AUDITORS