COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, September 2020 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance update - Greece, September 2020
Date: 2020-09-23
Institutions: Directorate-General for Economic and Financial Affairs, European Commission
Subjects: Euro Group (euro area), Greece, coronavirus disease, epidemic, gross domestic product, macroeconomics, multilateral surveillance, public debt, stability programme, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 23.9.2020  SWD(2020) 208 final  COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, September 2020 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance update - Greece, September 2020 {COM(2020) 618}  
 
 
ABBREVIATIONS 

AIA: Athens International Airport 
ANFA: Agreement on Net Financial Assets 
ASEP: Supreme Council for Civil Personnel Selection 
CRR: Capital Requirement Regulation 
DEPA: Public Gas Corporation (Δημόσια επιχείρηση αερίου) 
DRU: Dispute Resolution Unit 
ECB: European Central Bank 
EFKA: Single Social Security Fund (Ενιαίος φορέας κοινωνικής ασφάλισης)  
EFSF: European Financial Stability Facility 
EIB: European Investment Bank 
EKAPY:  National  Central  Authority  of  Health  Procurements  (Εθνική  κεντρική  αρχή 
προμηθειών υγείας) 
ENFIA: Unified Property Tax (Ενιαίος φόρος ιδιοκτησίας ακινήτων) 
ERGANI:  Greek  Database  for  Unemployment  Registration  (Πληροφοριακό  σύστημα 
«ΕΡΓΑΝΗ») 
ERGOSE: Subsidiary company of OSE to implement railways infrastructure projects 
ESI: Economic Sentiment Indicator 
ESM: European Stability Mechanism 
ESOEL:  National  Coordinating  Body  for  Audit  and  Accountability  (Εθνικό  σώμα 
ορκωτών ελεγκτών λογιστών) 
ETAD: Public Properties Company (Εταιρεία ακινήτων δημοσίου Α.Ε.) 
ETEAEP: Supplementary Pension Fund  
EYATH: Thessaloniki Water  Supply  and Sewerage Company  (Εταιρεία ύδρευσης  και 
αποχέτευσης Θεσσαλονίκης Α.Ε.) 
EYDAP:  Athens  Water  Supply  and  Sewerage  Company  (Εταιρεία  ύδρευσης  και 
αποχέτευσης Πρωτευούσης A.E.) 
FEK: Government gazette (Φύλλο της εφημερίδας της κυβερνήσεως) 
GDP: Gross Domestic Product 
GPS: Global Positioning System 
GRECO: Group of States against Corruption 
HCAP: Hellenic Corporation of Assets and Participations 
HELEXPO:  Νational  institution  for  the  organisation  of  exhibitions,  congresses  and 
cultural  events  (Εθνικός  φορέας  διοργάνωσης  εκθέσεων,  συνεδρίων  και  πολιτιστικών 
εκδηλώσεων) 
HFSF: Hellenic Financial Stability Fund (Ταμείο χρηματοπιστωτικής σταθερότητας) 
HRADF/TAIPED:  Hellenic  Republic  Asset  Development  Fund  (Ταμείο  αξιοποίησης 
ιδιωτικής περιουσίας του δημοσίου) 
HRMS: Human resources management system 
IAPR: Independent Authority for Public Revenue 
ICT: Information and Communication Technologies 
IEK: Public professional schools (Ινστιτούτο επαγγελματικής κατάρτισης) 
IKE: Greek private company (Ιδιωτική κεφαλαιουχική εταιρεία) 
IMF: International Monetary Fund 
JASPERS: Assistance to Support Projects in European Regions  
KEK: Vocational training centres (Κέντρα επαγγελματικής κατάρτισης) 
KEPA: Disability assessment centres (Κέντρο πιστοποίησης αναπηρίας) 
KOMYs: Newly and swiftly deployed medical mobile units (Κινητές μονάδες υγείας) 

i 

 
KTEL: Joint-venture of Regional Transport 
LCR: liquidity coverage ratio 
LEPETE: Supplementary Pension Fund of the National Bank of Greece (Λογαριασμος 
επικουρισης προσωπικού εθνικής τράπεζας της Ελλάδος) 
MFIs: Monetary financial institutions 
NOME:  Nouvelle  organisation  du  marché  de  l’electricité  (New  organisation  of  the 
electricity market) 
NPEs: Non-performing exposures 
OAED: Public employment service (Οργανισμός απασχόλησης εργατικού δυναμικού) 
OASTH: Urban Transport of Thessaloniki 
OMED: Mediation and arbitration board (Οργανισμός μεσολάβησης και διαιτησίας) 
OSDDY:  Integrated Management System for Judicial Cases (Ολοκληρωμένο σύστημα 
διαχείρισης δικαστικών υποθέσεων) 
OSE: Organisation of railways of Greece 
PMI: Purchasing Managers Index 
SEPE: Labour inspections directorate (Σώμα επιθεώρησης εργασίας) 
SMP: Securities Markets Programme 
SURE: Support to Mitigate Unemployment Risks in an Emergency 
SYNERGASIA:  Temporary  short-time  work  scheme  (Μηχανισμός  ενίσχυσης  της 
απασχόλησης «ΣΥΝ-ΕΡΓΑΣΙΑ») 
TEPIX  II:  Envelope  for  co-financing  loans  to  small  and  medium-sized  enterprises 
(Δράση “Επιχειρηματική Χρηματοδότηση – ΤΕΠΙΧ ΙΙ”) 
TLTRO III: Eurosystem targeted longer-term refinancing operations (TLTRO III) 
VAT: Value added tax 

ii 

 
ACKNOWLEDGEMENTS 

This  report  is  prepared  as  an  enclosed  document  to  the  Commission's  assessment 
pursuant Article 3(5) of  Regulation  (EU) 472/2013  published as Communication  from 
the Commission – Enhanced Surveillance – Greece, September 2020. It was prepared in 
the  Directorate  General  Economic  and  Financial  Affairs,  under  the  direction  of 
Maarten Verwey, Director General, Declan Costello, Deputy Director General, and the 
coordination of Julia Lendvai, Head of Unit and Milan Lisicky, Deputy Head of Unit. 

Contributors: 

Chris  Allen,  Giuseppe  Carone,  Christos  Daoulas,  Fotini  Dionyssopoulou,  Matteo 
Duiella,  Sotirios  Giannoulis,  Christos  Gofas,  Andras  Hudecz,  Alexander  Ioannidis, 
Eloïse  Lecouturier,  Vasileios  Maroulis,  Benedetta  Martinelli,  Vasilis  Nikitas,  Zoltan 
Petrov,  Eleni  Polemidiotou,  Marie-Luise  Rud,  Alexandros  Tavoutsoglou,  Andreas 
Trokkos, Vasiliki Vasilopoulou, Irene Vlachaki, Veli Laine, Rainer Wichern and Alkistis 
Zavakou.  

The  European  Central  Bank  staff  participated  in  the  drafting  of  this  report  in 
accordance with the European Central Bank’s competences and thus provided expertise 
on  financial  sector  policies  and  macro-critical  issues,  such  as  headline  fiscal  targets 
and  sustainability  and  financing  needs.  Staff  of  the  European  Stability  Mechanism 
contributed  to  the  preparation  of  this  report  in  the  context  of  the  European  Stability 
Mechanism's  Early  Warning  System  and  in  accordance  with  the  Memorandum  of 
Understanding  of  27 April  2018  on  working  relations  between  the  European 
Commission and the European Stability Mechanism. International Monetary Fund staff 
participated in the context of its Post-Programme Monitoring framework. 

Comments on the report would be gratefully received and should be sent by post or e-
mail to: 

Julia Lendvai 

European Commission 

Unit ECFIN-F-2 

CHAR 14/103 

B-1049 Brussels 

e-mail: ECFIN-GREECE-REQUESTS@ec.europa.eu 

iii 

 
 
CONTENTS 

1. 

Introduction 

2.  Macroeconomic Developments 

2.1.  MACROECONOMIC OUTLOOK 

3. 

Fiscal and fiscal-structural policies 

FISCAL DEVELOPMENTS AND OUTLOOK 
TAX POLICY 

3.1. 
3.2. 
3.3.  REVENUE ADMINISTRATION 
3.4.  PUBLIC FINANCE MANAGEMENT 
3.5.  PUBLIC INVESTMENT 

4. 

Sovereign financing 

4.1. 

SOVEREIGN FINANCING 

5. 

Social welfare 

5.1.  PENSIONS 
5.2.  HEALTHCARE 
5.3. 

SOCIAL SAFETY NETS 

6. 

Financial sector 

FINANCIAL SECTOR DEVELOPMENTS 
FINANCIAL SECTOR POLICIES 

6.1. 
6.2. 
6.3.  HELLENIC FINANCIAL STABILITY FUND (HFSF) 

7. 

Labour and product markets 

LABOUR MARKET 

7.1. 
7.2.  PRODUCT MARKETS AND COMPETITIVENESS 

8.  Hellenic Corporation of Assets and Participations (HCAP) and privatisation 

8.1.  HELLENIC CORPORATION OF ASSETS AND PARTICIPATIONS 
8.2. 
IMPLEMENTATION OF THE ASSET DEVELOPMENT PLAN 

9. 

Public administration and justice 

9.1.  PUBLIC ADMINISTRATION 
9.2. 
9.3. 

JUSTICE 
FIGHT AGAINST CORRUPTION 

Annex 

LIST OF TABLES 

Summary of the main economic indicators 

2.1. 
3.2.  Key Performance Indicators of the Independent Authority for Public Revenue, second 

quarter 2020 (*) 

6.1.  Main financial stability indicators 

iv 

1 

3 

3 

7 

7 
12 
12 
15 
19 

23 

23 

25 

25 
26 
28 

31 

31 
38 
44 

45 

45 
47 

55 

55 
58 

63 

63 
68 
70 

74 

5 

15 
35 

 
 
LIST OF GRAPHS 

4.1.  5-year government bond spreads over the German Bund 
6.1.  Bank deposits (left) and total borrowing from the Eurosystem (right) 
6.2.  Non-performing loans as a % of total customer loans (left) and changes in their stock in the 

first quarter of 2020 (right: million EUR) 

6.3.  Bank credit to households and non-financial corporations 
6.4.  Bank interest rates on new loans to euro area residents (annual percentages %) 

LIST OF BOXES 

3.1. 

The Council of State ruling on pensions 

23 
31 

34 
37 
38 

9 

v 

 
 
 
 
 
1. 

INTRODUCTION 

Economic  developments  and  policies  in  Greece  are  monitored  under  the  regular 
economic  surveillance  framework  for  euro-area  Member  States  under  the 
European  Semester  for  economic  policy  co-ordination  and  under  the  enhanced 
surveillance  framework  according  to  Regulation  (EU)  No 472/2013 (1).  Following 
its  fourth  prolongation,  enhanced  surveillance  for  Greece  is  currently  in  place  for  six 
months  as  from  21 August  2020 (2).  The  implementation  of  enhanced  surveillance  for 
Greece acknowledges the fact that Greece needs to continue implementing measures to 
address  the  sources  or  potential  sources  of  economic  and  financial  difficulties,  while 
implementing structural reforms to support a robust and sustainable economic growth.  

Greece made a general commitment at the Eurogroup of 22 June 2018 to continue 
and  complete  reforms  adopted  under  the  European  Stability  Mechanism 
programme  and  to  ensure  that  the  objectives  of  the  important  reforms  adopted 
under  the  financial  assistance  programmes  are  safeguarded.  In  addition,  Greece 
made  specific  commitments  to  complete  key  structural  reforms  started  under  the 
programme in six key areas by agreed deadlines up to mid-2022, namely (i) fiscal and 
fiscal-structural  policies,  (ii)  social  welfare,  (iii)  financial  stability,  (iv)  labour  and 
product markets, (v) Hellenic Corporation of Assets and Participations and privatisation 
and (vi) the modernisation of public administration (3). 

This report is based on the findings of a mission held remotely on 13 and 14 July 
2020  and  regular  dialogue  with  the  authorities.  The  mission  was  conducted  by  the 
European Commission in liaison with the European Central Bank (4); the International 
Monetary  Fund  participated  in  the  context  of  its  Post-Programme  Monitoring 
framework,  while  the  European  Stability  Mechanism  participated  in  the  context  of  its 
Early Warning System and in line with the Memorandum of Understanding of 27 April 
2018  on  working  relations  between  the  European  Commission  and  European  Stability 
Mechanism.  

Enhanced  surveillance  provides  a  comprehensive  framework  for  monitoring 
economic developments and the pursuit of policies needed to ensure a sustainable 
economic  recovery.  To  this  end,  this  report  includes  an  assessment  of  economic 
conditions  in  Greece  (chapter  2);  an  assessment  of  implementation  of  reform 

(1)  Regulation (EU) No 472/2013 of the European Parliament and of the Council of 21 May 2013 on the 
strengthening of economic and budgetary surveillance of Member States in the euro area experiencing 
or  threatened  with  serious  difficulties  with  respect  to  their  financial  stability,  OJ  L  140,  27.5.2013, 
pp. 1. 

(2)  Commission  Implementing  Decision  (EU)  2020/1142  of  29 July  2020  on  the  prolongation  of 

enhanced surveillance for Greece, OJ L 248, 31.7.2020, pp. 20-23. 

(3)  https://www.consilium.europa.eu/media/35749/z-councils-council-configurations-ecofin-eurogroup-
2018-180621-specific-commitments-to-ensure-the-continuity-and-completion-of-reforms-adopted-
under-the-esm-programme_2.pdf 

(4)  European  Central  Bank  staff  participated  in  the  review  mission  in  accordance  with  the  European 
Central  Bank’s  competences  and  thus  provided  expertise  on  financial  sector  policies  and  macro-
critical  issues,  such  as  headline  fiscal  targets  and  sustainability  and  financing  needs.  The  review 
mission was preceded by a technical mission, also held remotely, from 2 July to 10 July 2020. 

1 

                                                 
Commission Staff Working Document -  

Chapter 1 - Introduction 

commitments  given  by  Greece  to  the  European  partners  (chapters  3  and  5-9);  and  an 
update on sovereign financing conditions (chapter 4).  

The  Eurogroup  on  22 June  2018  agreed  that  the  package  of  debt  relief  measures 
for  Greece  should  include  incentives  to  ensure  a  strong  and  continuous 
implementation of the reform measures agreed in the programme. To this end, the 
implementation  of  some  of  the  agreed  debt  measures  –  the  abolition  of  the  step-up 
interest  rate margin  related to  the debt  buy-back  instalment  of the European Financial 
Stability  Facility  (EFSF)  programme  as  of  2018  and  the  restoration  of  the  transfer  of 
equivalent amounts to the income earned by euro-area national central banks on Greek 
government bonds held under the Agreement on Net Financial Assets (ANFA) and the 
Securities  Market  Programme  (SMP)  –  will  be  made  available  to  Greece  subject  to 
compliance  with  its  commitments  on  reform  continuity  and  completion,  based  on 
positive  reports  under  enhanced  surveillance.  The  transfer  of  these  income  equivalent 
amounts would be made available to Greece in semi-annual tranches of €644 million up 
to  mid-2022.  The  waiver  of  the  step-up  interest  rate  margin,  for  part  of  the  loans 
extended by the European Financial Stability Facility, would reduce interest payments 
by about €104 million every half year. It would be waived on a semi-annual basis until 
2022 and permanently after 2022. The third tranche of policy-contingent debt measures 
was  released  following  the  Eurogroup  on  11 June  2020,  inter  alia  based  on  the 
assessment  of  the  implementation  of  Greece’s  commitments  for  end-2019  included  in 
the  enhanced  surveillance  report  adopted  by  the  Commission  on  20 May  2020 (5)  and 
considering  the  extraordinary  circumstances  posed  by  the  coronavirus  outbreak.  The 
current report assesses the implementation of Greece’s commitments to the Eurogroup 
including  specific  reform  completion  commitments  up  to  mid-2020,  the  continuous 
commitments and its general reform continuity commitment. This report is not linked to 
a  release  of  the  next  set  of  policy-contingent  debt  measures,  which  –  in  line  with  the 
agreed biannual schedule – could take place on the basis of the eighth report. The eighth 
report is expected to be published in November.  

(5)  https://ec.europa.eu/info/publications/enhanced-surveillance-report-greece-may2020_en 

2 

                                                 
2.  MACROECONOMIC DEVELOPMENTS 

2.1.  MACROECONOMIC OUTLOOK 

The coronavirus pandemic and measures to contain it are expected to take a strong 
toll on the Greek economy. Strict containment measures, which restricted movement, 
economic activity  and international  travel,  were in  place from  the last week of March 
until  end-May  with  travel  restrictions for a  group of mainly  EU  countries being lifted 
only  gradually  as  of  mid-June.  The  first  estimate  of  real  GDP  growth  in  the  second 
quarter  of  2020  showed  a  decline  of  -14%  quarter-on-quarter,  after  declining  by 
only -0.7% in the first quarter of the year. Given that containment measures affected the 
second  quarter  more  than  the  first  quarter,  the  strong  economic  impact  in  the  second 
quarter is in line with expectations. Assuming less strict measures to limit the spread of 
coronavirus in the coming months, economic activity is expected to recover somewhat 
in  the  second  half  of  the  year,  compared  to  the  first  half  and  particular  the  second 
quarter.  Overall,  economic  activity  in  2020  is  expected  to  remain  well  below  2019 
levels and only return to the 2019 levels in 2022, after a partial bounce back in 2021, 
with GDP growth rates reaching -9% in 2020, and 6% in 2021. This forecast is based on 
the  summer  interim  forecast  and  reflects  the  measures  adopted  or  credibly  announced 
until  early-July  and data released until  end-June. A full update on the macroeconomic 
and fiscal forecast will be prepared in autumn.  

The services sector was the most adversely affected by the containment measures. 
Among services, the private services sector, including tourism and transports, took the 
biggest  hit,  followed  by  agriculture  and  industry.  By  contrast,  construction  –  and  to  a 
lesser extent public services  – contributed positively to  growth. The travel  restrictions 
have  hit  the  tourism  industry  hard,  with  tourism  receipts  down  by  99%  in  April  and 
May  2020  and  by  97.5%  in  June  compared  to  the  same  months  in  2019.  Shipping 
services have been impacted as well by the restrictions in many countries and the lower 
overall  trade  volumes,  with  the  receipts  from  transportation  being  23%  lower  in  May 
and 18.7% in June 2020 than a year ago. 

Domestic demand is expected to contract in 2020. Lower disposable incomes due to 
short-time  work  and  job  losses  are  expected  to  lead  to  lower  domestic  demand. 
Furthermore,  consumers  are  expected  to  adjust  consumption  behaviour  in  order  to 
reduce  the  infection  risk,  depending  on  medical  advice,  which  can  lead  to  sudden 
demand shifts. The dramatic drop in economic activity also puts companies under stress 
and  is  likely  to  lead  to  a  significant  drop  in  investment.  In  addition,  the  uncertainty 
regarding  developments  of  the  pandemic  and  potential  economic  consequences  are 
expected  to  lead  to  the  postponement  of  investments,  while  lower  sales  and  profits 
increase the financial pressure and make it harder to finance investments through own 
resources.  

Service  exports  are  expected  to  be  severely  affected  by  the  travel  restrictions  as 
well  as  the  slow-down  in  international  trade.  With  the  country  cautiously  opening 
again mid-June to tourists, the main tourism season months July and August could see 
some limited tourism activity, but expectations remain very low overall for 2020, with 
revenues between 70-90% below the 2019 level. The high uncertainty regarding travel 

3 

Commission Staff Working Document -  

Chapter 2 - Macroeconomic developments 

restrictions and the high-perceived health risk, are expected to also lead to lower arrival 
numbers  in  the  second  half  of  the  year.  International  trade  is  strongly  affected  by  the 
economic  downturn  triggered  by  the  pandemic  and  is  expected  to  remain  well  below 
normal  levels.  The  negative  effects  for  Greek  shipping  service  exports  could  remain, 
even  if  EU  economies  recover  in  the  second  half  of  2020,  depending  on  the  global 
situation.  

Goods  exports  are  expected  to  suffer  somewhat  less  from  the  global  crisis.  Greek 
goods  exports  are  composed  of  a  comparatively  large  share  of  agricultural  products, 
foodstuffs and pharmaceuticals, which could help mitigate some of the negative effects 
of the global crisis on exports. Other industrial exports are likely to be affected by the 
drop  in  economic  growth  in  Greece  trading  partner  countries,  which  are  severely 
affected by the pandemic. 

Support  measures  have  helped  keep  the  unemployment  rate  in  check  so  far,  but 
signs  point  towards  a  frozen  labour  market.  Swift  labour  market  support  measures 
(see  sections  7.1  and  7.2)  have  so  far  prevented  major  job  losses  according  to  the 
available  data.  In  May  2020,  the  unemployment  rate  reached  17%,  up  from  15.9%  in 
February.  The  hiring  of  seasonal  workers  which  usually  takes  place  in  the  months 
March-May  has  been  dramatically  reduced  and  the  general  hiring  and  firing  activity 
during these months has been  extremely low. New hiring increased again in  June and 
July,  but  not  to  the  extent  that  could  counteract  the  developments  in  the  previous 
months. The average annual unemployment rate is expected to increase close to 20% in 
2020  and  to  gradually  decline  again  along  with  the  economic  recovery  in  2021, 
assuming that support measures will only be phased out progressively.  

Consumer price inflation is  expected to be negative in 2020 and only turn mildly 
positive  in  2021  during  the  economic  recovery.  Inflation  is  expected  to  remain 
negative in 2020 around -0.5%, driven by low energy prices and the general economic 
situation, with limited upward pressure potentially only stemming  from  processed and 
unprocessed foods. Downside risks are present in the short term, stemming mainly from 
lower energy prices and subdued services inflation, in particular in relation to the drop 
in tourism activity and value added tax cuts. The partial economic recovery in 2021 is 
expected to also lead to a slow increase in consumer price inflation, which is forecast to 
reach a mildly positive territory at 0.5%, as oil prices also increase. In the medium term, 
risks are tilted to the upside due to increasing energy prices. 

Government  support  measures  have  helped  protect  the  economy  against 
widespread bankruptcies and job losses. The  mix of government  support  consisting 
in a lowering of the tax burden with €3.1 billion (1.9% of GDP), protection of jobs and 
incomes  with  €4.1 billion  (2.4%  of  GDP),  and  easing  liquidity  constraints  with 
€5.9 billion (3.5% of GDP) is a balanced approach and is expected to be instrumental in 
maintaining  the  economic  fabric  and  thus  help  the  economy  recover.  While  income 
support  and  unrestricted  help  during  the  months  of  the  strictest  measures  helped  keep 
disposable  incomes  from  collapsing,  support  now  needs  to  shift  to  a  more  targeted 
approach  focusing  on  sectors  still  hit  by  hygiene  and  social  distancing  measures.  As 
soon as the pandemic and economic situation stabilises and allows for a more medium-
term planning horizon, supporting sustainable investment will be of high importance to 
speed up the economic recovery process.  

4 

Commission Staff Working Document -  

Chapter 2 - Macroeconomic developments 

Uncertainty  regarding  the  development  of  the  pandemic  and  thus  its  economic 
impact remain extraordinarily high. While economic activity in Greece is expected to 
cautiously  accelerate,  much  uncertainty  still  remains.  The  uncertainty  is  related  to  the 
pandemic  and  its  spread  within  Greece  and  globally,  future  measures  that  might  be 
necessary to contain the spread of the virus, and longer lasting economic effects due to 
restrictions,  changed  consumer  behaviour,  possible  bankruptcies  and  difficulties  for 
those who have recently became unemployed to re-join the labour market. In particular, 
the  large  tourism  sector  exposes  Greece  to  risks  stemming  from  the  pandemic  and 
changed  travel  behaviour.  Shipping  may  be  further  strongly  affected  by  the  spread  of 
the  virus  in  other  countries  that  are  not  even  important  direct  trading  partners  with 
Greece  due  the  global  nature  of  the  industry.  A  quick  uptake  of  the  new  EU  support 
programmes,  most  notably  the  Recovery  and  Resilience  Facility,  would  be  key  to 
counterbalance these effects and provide the needed support to reforms, investments and 
growth. The assessment is also taking place against the background of considerable geo-
political  tensions  and  growing  migration  flows,  which  add  to  uncertainty,  as  well  as 
economic and fiscal pressures. 

Table 2.1:  Summary of the main economic indicators 

Source: European Commission 2020 Summer Interim Forecast. 

5 

2018201920202021Real GDP1.91.9-9.06.0Harmonised index of Consumer Prices0.80.5-0.50.5Annual percentage change 
 
   
 
3. 

FISCAL AND FISCAL-STRUCTURAL POLICIES 

3.1.  FISCAL DEVELOPMENTS AND OUTLOOK 

As  a  result  of  the  new  measures  and  in  light  of  the  latest  macroeconomic 
developments as described in the Commission 2020 summer interim  forecast, the 
budget deficit is expected to reach 5.8% of GDP in 2020. The fiscal forecast for 2020 
has deteriorated since the last report. The current forecast is based on the Commission 
2020  summer  interim  macroeconomic  projection,  and  reflects  the  main  measures 
adopted  or  credibly  announced  since  May  2020.  It  does  not  include  the  impact  of  the 
Council of State’s pension ruling from 14 July, neither the pending ruling of the Court 
of  Auditors  (see  Box  3.1).  The  main  driver  of  the  deterioration  of  the  forecast  is  the 
fiscal impact of the new measures adopted since May 2020 to mitigate the consequences 
of the pandemic. The aggregate fiscal impact of the earlier measures remained broadly 
unchanged. On the one hand, the take-up of some of the measures has been lower than 
expected (e.g. temporary economic support to wage earners and self-employed and the 
social security coverage by the state), which led to an improvement in the forecast. On 
the other hand, since the publication of the previous report, due to the extension of the 
repayment  period  for  the  tax  deferrals,  these  deferrals  will  now  be  considered  as  an 
accrual loss for this year’s budget, as opposed to a budget-neutral revenue shift as it was 
treated  in  the  previous  report.  The  remaining  difference  is  due  to  the  changes  in  the 
macroeconomic scenario and updates in the social budget and state expenditure. A full 
update on the fiscal forecast will be prepared in autumn, in the context of the assessment 
of the 2021 Draft Budgetary Plan. 

The authorities have prolonged the application of some of the earlier measures for 
a  number  of  additional  months  and  adopted  further  temporary  measures  to 
address  the  crisis  (see  Table  3.1  for  a  summary).  In  the  first  package  of  measures, 
companies  were  eligible  for  a  total  amount  of  €2 billion  in  the  form  of  a  repayable 
advance.  After  two  rounds  of  applications,  the  take-up  of  these  amounts  was  almost 
complete until July 2020. Therefore the government decided to extend the measure and 
open the platform for a third round of applications, due in September, with an expected 
envelope  of  €1 billion,  thereby  increasing  the  total  envelope  of  the  scheme  to 
€2.8 billion.  Α  further  round  may  follow  by  the  end  of  the  year.  Furthermore,  the 
repayment of the tax and instalment deferrals has become eligible to be repaid in up to 
24 instalments, starting from January 2021. In addition, since May 2020, the authorities 
adopted a new set of measures, with the following main items:  

1.  Companies with a given drop in turn-over, may decrease their advance payments for 
the  corporate  income  tax  or  for  the  personal  income  tax  for  self-employed.  This 
measure is expected to have a fiscal impact of 0.9% of GDP in 2020. To recall, these 
advances  are normally calculated based on the previous  year’s taxable income and 
then  cleared  in  the  following  year,  when  the  actual  taxable  income  for  the  current 
year  becomes  known.  Since  this  year’s  taxable  income  is  expected  to  be 
substantially  lower  than  the  last  year’s,  this  measure  anticipates  the  lower  net 
clearances that the companies would be paying next year.  

7 

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2.  A  second  set  of  measures  was  introduced  with  a  view  to  protecting  employment. 
Following  the  provision  of  a  special  allowance  and  financing  of  social  security 
contributions of employees for companies affected by the coronavirus outbreak, the 
government  introduced  a  short-time  work  scheme.  Under  this  scheme,  the  state 
covers  part  of  the  employment  costs  for  employees  whose  working  time  has  been 
reduced, as long as the companies commit to keep them employed. The government 
undertook additional measures to sustain employment such as: (a) the provision of a 
special allowance for seasonal workers in the tourism sector, (b) the coverage by the 
state  of  seasonal  and  Christmas  bonuses  for  furloughed  employees  and  (c)  the 
financing  by  the  state  of  social  security  contributions  of  employees  of  seasonal 
companies, if they can prove that 50% of their yearly turnover was concentrated in 
the  third  quarter  of  the  year  in  2019.  The  fiscal  impact  of  these  measures  is 
estimated to reach 0.6% of GDP in 2020 and will be financed by the new European 
instrument for temporary support to mitigate unemployment risks in  an emergency 
(SURE) (6).  The  total  cost  of  measures  requested  by  the  authorities  to  be  financed 
under the SURE initiative amounts to 1.6% of GDP also including the payment of a 
special  allowance  and  the  financing  of  social  security  contributions  of  employees, 
for companies affected by the coronavirus outbreak.  

3.  A  third  set  of  measures  aim  to  mitigate  the  impact  on  tourism  through  dedicated 
social tourism programmes and an extended advertising campaign with an estimated 
fiscal impact of 0.1% of GDP.  

4.  A temporary decrease in VAT rates for transportation, beverages, tourism packages 
and  cinema  tickets  from  24%  to  13%  is  expected  to  bear  a  fiscal  cost  of  0.1%  of 
GDP. 

5.  A temporary instalment subsidy scheme for mortgage, consumer and business loans 
secured by a primary residence for debtors with mortgages on main residences that 
have  been  financially  affected  by  the  coronavirus  pandemic  has  been  introduced. 
Under this primary residence protection scheme, the state subsidises for nine months 
up to 90% of the monthly instalment for all performing loans related to the primary 
residence  but  also  a  significant  percentage  (from  60%  to  80%)  of  the  non-
performing loan instalment (see section 6.2). The fiscal cost is estimated at 0.3% of 
GDP for the period 2020-2021.  

The authorities also extended the previously taken measures that provide liquidity 
support to households and firms. In particular, the envelope for co-financing loans to 
small  and  medium-sized  enterprises  (TEPIX  2  scheme)  by  the  Hellenic  Development 
Bank  has  been  increased  by  €588 million,  totalling  €838 million.  Furthermore,  the 
deadline  for  certain  tax  payments  has  been  extended.  The  personal  income  taxes  can 
now be paid  in  8 monthly instalments,  instead of 3 bi-monthly instalments.  Similarly, 
the corporate income tax can now be paid in 7 or 8 instalments instead of the usual 5 or 
6 instalments. The single property tax (ENFIA) can now also be paid in 6 instalments 
instead of 5. These measures have around 0.9% of GDP impact on the cash balance, but 
no  impact  on  the  accrual  fiscal  balance,  due  to  the  time  adjustment  applied  in  the 
statistical recording of these revenue streams. 

(6)  Council Regulation (EU) 2020/672 of 19 May 2020. 

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Table 3.1:  Coronavirus response measures and their financing sources 

(1)  The  total  envelop  of  the  Hellenic  Development  Bank’s  co-financing  loans  to  small  and 
medium-sized  enterprises  is  €838 million  of  which  €250 million  were  disbursed  to  the  Hellenic 
Development  Bank  already  in  2019  from  the  public  investment  budget  and  €588 million  will  be 
financed by the flexibility offered by the Corona-response Investment Initiative. 

Source: European Commission. 

9 

million EURas % of GDPmillion EURas % of GDPmillion EURas % of GDPmillion EURas % of GDPBudgetary measures11 1756.69 3211 1796759 3215.5-1 156-0.7-677-0.4Temporary economic support to wage earners and self-employed1 6601.01 1085521 1080.700.000.0Repayable advance payment2 8611.71 8611 0001 8611.100.0-447-0.3Social security contributions paid by the state5410.35415410.300.000.0Interest payment on performing loans of small and medium sized enterprises1790.1017900.000.000.0Suspension of social security contributions instalment schemes by 3 months1930.11931930.100.000.0Additional support to the healthcare system2330.12332330.11360.11310.1Easter bonus state contribution for employees under labour suspension1300.11301300.100.000.0Temporary economic support to certain liberal professions 1030.11031030.100.000.0Extension of the regular and long-term unemployment benefit 3090.23093090.200.000.0Support of the primary sector of the economy1500.11501500.100.000.0Abolishment of local government levies1100.11101100.100.000.025% discount on tax and social security contributions obligations paid in expected deadlines2560.22562560.200.000.0Coronavirus' related expenditures of other ministries1940.11941940.100.000.0Clawback to hospitals190.019190.000.000.0Easter bonus to medical and other staff 900.190900.100.000.0Temporary economic support to long-term unemployed650.065650.000.000.0Special purpose leave for parents200.020200.000.000.0Compensation of passenger ships300.030300.000.000.0Other40.0440.000.000.0Reduction in rents00.0000.0360.000.0Deferral of VAT payments 4200.24204200.2-168-0.1-168-0.1Deferral of social security contributions payments 3150.23153150.2-126-0.1-124-0.1Deferral of payments of tax debt instalments 1730.11731730.1-690.0-690.0Return of taxes for property owners that receive reduced rent610.061610.000.000.0Reduction of advanced CIT payment1 5000.91 5001 5000.9-1 230-0.700.0Zero advanced CIT payment for airline companies530.053530.0-530.000.0Short-term employment scheme 4350.34354350.300.000.0Seasonal and Christmas bonuses state contribution for employees under labour suspension1010.11011010.100.000.0Social security contributions coverage for employees of seasonal enterprises 2400.12402400.100.000.0Social tourism programs of Ministry of tourism1000.1010000.000.000.0Social tourism program of employment fund (OAED)170.017170.0100.000.0EOT tourism advertizing campaign230.002300.000.000.0VAT reduction from 24% to 13%1240.11241240.100.000.0First residence subsidy cost for borrowers hit by coronavirus2100.12102100.13080.200.0Unemployment benefit to seasonal workers410.041410.000.000.0Special allowance for seasonal workers of tourism 1970.11971970.100.000.0Compensation of passenger seats for airline companies 60.0660.000.000.0Compensation to amateur sports clubs due to coronavirus120.012120.000.000.0Liquidity measures2 8381.705882 00000.000.000.0Cash collaterals (bank guarantees) by the Hellenic development bank to banks for loans to affected companies2 0001.202 00000.000.000.0HDB co-financing loans to small and medium sized enterprises /18380.5058800.000.000.0Total measures14 0148.29 3211 7672 6759 3215.5-1 156-0.7-677-0.4Expected additional impact of liquidity measures6 3453.700000.000.000.0Total impact 20 35912.09 3211 7672 6759 3215.5-1 156-0.7-677-0.4as % of GDP5.51.01.620212022SizeFinanced by2020Ordinary budgetCorona response investment initiativePIB reallocation in 20202020Fiscal impact 
   
 
 
 
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Box (continued) 

(Continued on the next page) 

10 

Box 3.1: The Council of State ruling on pensionsOn 14 July 2020, the Council of State issued a landmark ruling regarding legal claims for retroactive compensation for pension cuts introduced by previous pension reforms. While earlier rulings of the Council of State upheld the main features of the 2012 and 2016 pension reforms, they also gave rights for retroactive compensation to specific groups of pensioners. These partial recognitions left a large number of claims by other pensioners pending in various courts. The present ruling establishes clarity on those.   The Council of State addressed three issues that have arisen in relation to previous pension reforms.   1. Claims for the period January 2013-June 2015 (case 1 on Graph 1): A 2015 Council of State ruling judged the 2012 pension cuts unconstitutional from June 2015 onwards, but also granted a right for compensation to those who had actually filed a legal claim before the date of the publication of the decision. The present ruling clarified the rights of those who had not filed a petition before that date. It ruled that they do not have a right for compensation, in line with the Council of State’s earlier statement. 2. Claims for the period June 2015-May 2016 (case 2 on Graph 1): The 2016 pension reform kept pensions of incumbent pensioners at the levels effective on 31 December 2014, i.e. factoring in the pension cuts implemented in 2012. However, since, according to the 2015 Council of State ruling the 2012 pension cuts were unconstitutional from June 2015 onwards, legal uncertainty had been created regarding the period between June 2015 and May 2016, when the pension reform came into effect. The present ruling decided that pensioners need to be compensated for this 11-month period. However, the actual decision applies only to pensioners who have already filed a claim, leaving it up to the authorities to decide whether to compensate all pensioners.  3. Claims for the period May 2016-January 2019 (case 3 on Graph 1): The May 2016 pension reform put in place a new pension formula for future pensioners and introduced a new notional level of pensions for incumbent pensioners – to which actual pensions would adjust over time through an indexation freeze, or a payment if the actual pension was lower than the notional one. However, the amounts to be adjusted through the inflation freeze were ascertained only as of January 2019, giving rise to claims on retroactive payments from May 2016 to January 2019. The present ruling rejected all claims for this period. Graph 1: Pension reform timeline and court rulings  Source: European Commission. With the provisions of law 4714/2020, published at the end of July 2020, the authorities recognised the claims corresponding to the reductions of the main pensions for the 11-month June 2015-May 2016 period. Although the ruling applies only to pensioners who have already filed a claim, the government decided to recognise retroactive claims for all the private-sector pensioners with a fiscal cost estimated at €900 million. In addition, the government announced to recognise identical claims for the public-sector pensioners, if and when the respective decision of the Court of Auditors for public sector pensioners will be    
 
 
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The Prime Minister announced a number of additional measures on 12 September. 
These measures aim to provide support for the recovery next  year. Notably, the social 
security contributions rate will be temporarily reduced for private sector employees by 
three  percentage  points  and  the  special  social  solidarity  contribution  of  private 
employees  and  self-employed  will  be  abolished  for  2021.  The  package  also  includes 
prolongation of some of the earlier measures  and a new round of repayable advances. 
These measures will be assessed in the context of the 2021 Draft Budgetary Plan. 

Some  further  measures  recently  adopted  by  the  government  are  expected  to 
further  increase  the  deficit.  The  recalculation  of  the  objective  value  of  immovable 
properties  for  the  calculation  of  the  single  property  tax  (ENFIA)  in  2020,  has  been 
postponed due to  delays in  the valuation  exercise (see section 3.2). Hence, this  year’s 
declarations  for  the  single  property  tax  will  still  be  based  on  previously  used  values, 
which  will  have  a  negative  fiscal  impact  of  around  0.1%  GDP.  On  the  occasion  of  a 
temporary  loss  of  income,  the  authorities  reduced  the  personal  income  tax  rate  of 
aircraft pilots to 15%, thus introducing a permanent exemption to the tax system which 
contradicts the principles of a single and uniform tax system. Finally, in order to fiscally 
support businesses with  R&D operations,  the  authorities increased the deductibility of 
the related expenses (and their depreciation) at minimal fiscal cost.  

The  uncertainty  around  the  fiscal  forecast  remains  substantial.  While  the 
uncertainty around the fiscal impact of the emergency budgetary measures has subsided, 
the  macroeconomic  environment  remains  a  source  of  substantial  uncertainty.  Beyond 
the pandemic-related macroeconomic uncertainty, there are a number of fiscal and other 
risks  that  may  affect  the  future  evolution  of  the  fiscal  balances.  First,  Greece  is 
grappling with renewed migration pressures and geo-political tensions, which may give 
rise  to  additional  funding  needs.  Second,  a  part  of  the  state  guarantees  that  are  being 
extended through the Hellenic Development Bank may get called in the coming years, 
especially if the recovery turns out to be sluggish. Given the total amount of €2 billion, 
a call-rate of 10% would already impose a fiscal cost of over 0.1% of GDP. Third, the 

11 

issued to the same effect. This would increase the fiscal costs by €500 million. The total cost of the recognition of these claims could therefore amount to €1.4 billion on a gross basis, which corresponds to a net amount of €1.3 billion. This amount is expected to be paid in 2020.   In the same law, the authorities have declined to recognise the remaining claims that relate to seasonal bonuses and supplementary pensions for the same period, referring to fiscal constraints. More specifically, taking into account the current unfavourable fiscal situation, the law 4714/2020 declared that all the additional pension claims that correspond to reductions and abolitions of supplementary pensions and of the seasonal bonuses for the period between June 2015 and May 2016, are annulled.   The exclusion of supplementary pensions and seasonal bonuses from retroactive amounts carries fiscal risks. The full text of the Council of State ruling is not yet available and only summaries of the decision are published which are short and only refer to main pensions. Therefore, it is unclear if the government’s obligation for retroactive compensation is restricted to main pensions or if it should also be extended to supplementary pensions and seasonal bonuses. In case the decision also covers the latter categories, the non-recognition of the respective claims could lead to further claims from pensioners and possibly result in a significant fiscal cost, reaching over €2 billion in case of a verdict upholding the claims in question.   
   
 
 
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future  repayment  of  the  repayable  advances  will  depend  on  the  survival  rate  of  the 
receiving  companies.  A  slower-than-expected  recovery  would  therefore  jeopardise  the 
recovery  of  these  funds.  Furthermore  there  are  public  service  obligations  of  0.1%  of 
GDP to be paid to the Hellenic Post, which may materialise in the near future. On the 
positive  side,  Greece  is  expected  to  greatly  benefit  from  new  facilities  including  the 
Recovery  and  Resilience  Facility  that  aims  to  support  investments  and  reforms  in  the 
EU  over  the  next  programming  period,  and  is  expected  to  support  growth  and  public 
finances going forward. 

Greece’s public finances continue to face important fiscal risks related to pending 
court rulings. Fiscal pressures might be posed by the litigation cases against the Public 
Real  Estate Company (ETAD). The case is  ongoing, as the question of the validity of 
the recent arbitral awards is still pending before the Athens Court of Appeal following 
the petitions for the annulment by ETAD. The pending ruling of the Court of Auditors 
on  the  retroactive  compensation  of  public-sector  pensioners  for  cuts  identical  to  those 
that were ruled unconstitutional for the private-sector pensions creates additional fiscal 
risk. Finally, additional fiscal risks stem from the uncertainty as regards the Council of 
State  ruling  on  retroactive  compensation  for  cuts  in  supplementary  pensions  and 
seasonal bonuses introduced by previous pension reforms. (see Box 3.1). 

3.2.  TAX POLICY 

The  authorities  have  restarted  work  towards  completion  of  the  nationwide 
reassessment  of  property  tax  values,  a  mid-2020  specific  commitment,  whose 
finalisation has now been rescheduled for mid-2021. The inevitable delays occurred 
earlier  in  the  year  due  to  the  coronavirus  lockdown.  The  work  of  data  collection  and 
quality assessment, leading to the final determination of prices for existing value zones 
is expected to be completed by the end of the year. This year’s ENFIA single property 
tax  assessments  will  thus  mainly  be  based  on  the  previous  property  tax  values.  The 
agreed further expansion of the existing value zone system across the entire country will 
need  to  be  addressed  in  the  course  of  next  year  with  a  rescheduled  deadline  of  mid-
2021. Moreover, technical support is provided by the European Commission through a 
new  project  to  revisit  key  features  of  the  immovable  property  valuation  system, 
including a review of commercial properties valuation methodology, as well as support 
the steps towards further modernisation and digitalisation of the existing system, in line 
with best practices. 

3.3.  REVENUE ADMINISTRATION 

Staffing  levels  at  the  Independent  Authority  for  Public  Revenue  continued  to 
increase at a modest pace, although remaining well below the targets, an end-2019 
specific commitment, whereas limited progress has been made on the overarching 
human  resources  reform,  putting  in  doubt  if  it  will  be  operational  by  1 January 
2021.  Staffing  levels  at  the  end  of  the  second  quarter  stood  at  11 916,  compared  to 
12 500  set  as  the  target  by  end  of  2019.  Moreover,  the  authorities  have  adopted 
provisions (7)  that  have  resulted  in  staff  from  the  Independent  Authority  being 

(7)  OJ 134/09.08.2019 (Article 55), OJ A 167/30.10.2020 (Article 51) and OJ A 148/31.07.2020 (Article 

86). 

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transferred to other bodies, thus making the achievement of the set staffing targets even 
more difficult. The completion of the human resources reform, which – once in place – 
is  expected  to  greatly  facilitate  the  Independent  Authority’s  capacity  to  attract  and 
maintain the high calibre staff it needs, continues facing significant delays. Although the 
budget has been allocated for 2020, the draft legislation for the wage grid is yet to be 
prepared.  The  European  institutions  encouraged  the  authorities  to  adopt  it  during  the 
next  review  period.  It  is  noted  that  significant  technical  support  has  been  provided 
through the European Commission that is expected to continue also in 2021, which adds 
to the urgency of a timely implementation of this key reform. Adopting the wage grid 
legislation during the next  review period is  considered crucial to  help  with  addressing 
the  challenges  faced  by  the  Independent  Authority  to  fill  its  vacant  posts  (currently 
1 353 below the mid-2021 target).  

Mixed  progress  has  been  made  in  the  areas  of  the  Independent  Authority’s  IT 
framework and its headquarters, with further key steps expected to be adopted in 
the coming months. A jointly agreed roadmap for the IT framework has been prepared 
by  the  Independent  Authority  and  the  Ministry  of  Digital  Governance.  The  rollout  of 
myDATA (8), relating to electronic bookkeeping and other web services offered by the 
Independent  Authority,  is  expected  to  be  completed  by  October  2020.  The  needed 
budget for investment expenditures for other planned IT projects until 2022 is yet to be 
allocated  and  is  estimated  at  €25-30 million.  As  concerns  the  relocation  of  the 
headquarters of the Independent Authority into one single location, planning is moving 
ahead for a new building to be erected next to a building to host the Ministry of Finance 
in a location at the outskirts of Athens. The tender for the construction is expected to be 
launched by the first quarter of 2021 and the Independent Authority should be able to 
access the building during 2024. 

A  draft  law  to  strengthen  the  anti-smuggling  framework,  including  provisions  to 
strengthen  the  operational  capacity  of  the  Operational  Coordination  Centre,  has 
been  prepared  and  is  expected  to  be  adopted  by  October  2020.  The  draft  law 
includes a number provisions aiming to strengthen the anti-smuggling framework, such 
as the ratification of the World Health Organisation Framework Convention on Tobacco 
Control  and  GPS  tracking  system  for  fuels.  The  draft  law,  which  is  expected  to  be 
published for public consultation  during September, will need to  be further elaborated 
with a number of secondary legislation acts. It would be important to swiftly adopt these 
bills and ensure sufficient sourcing of the Independent Authority, to allow it to carry out 
its role efficiently, in particular as concerns the development and use of various digital 
tools. The European Commission is continuing providing technical support until the end 
of 2020. The capacity of the Operational Coordination Centre – which coordinates anti-
smuggling  efforts  –  will  be  strengthened  through  the  introduction  of  a  new  selection 
process  for  officials  that  extends  the  secondment  period  up  to  six  years,  while  the 
structure  remains  firmly  embedded  within  the  Independent  Authority.  Separately,  the 
implementation  of  the  new  organisation  structure  of  the  customs  department  is 
progressing, but there has been some delays in the full operationalisation of the mobile 
control units. 

(8)  Secondary 

legislation  setting  out  specific  provision  were  adopted 

in  June  2020  (OJ  B 

2470/22.06.2020). 

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The recently established debt collection centre moved into its new premises, while 
the  end-to-end  collection  project,  a  specific  commitment  for  mid-2021,  is  faced 
with  some  delays.  The  debt  collection  centre,  which  has  been  provided  technical 
support through the European Commission, still needs to be fully staffed, as it currently 
has filled 28 out  of  a total  of 126 posts. The implementation  study  for the end-to-end 
collection project (supported by EU funds) has been finalised and is expected to require 
a time extension of 8 months. Finally, two projects with technical support provided by 
the European Commission have recently been launched. The projects aims at improving 
taxpayer  services,  developing  and  implementing  a  comprehensive  compliance  risk 
management  framework,  standardising  the  audit  process  and  implementing  some 
practical guidelines on indirect audit methods.  

A  new  temporary  committee  for  settling  tax  debt  disputes  has  been  established 
under  the  competence  of  the  Ministry  of  Finance.  According  to  the  adopted 
provisions (9) the committee’s mandate ends by July 2021. Although the settlements to 
be  agreed  are  expected  to  alleviate  the  burden  on  the  judicial  system,  it  would  be 
important  that  the  mandate  of  the  new  committee  is  not  extended,  as  it  might  risk 
establishing  a  parallel  system  to  the  existing  Directorate  for  Settlement  of  Disputes, 
which is part of the Independent Authority.  

The  outcome  of  the  key  performance  indicators  for  the  second  quarter  of  2020 
reflects the impact of confinement measures imposed during this period, including 
for audits carried out by mobile units. As regards debt collection, the results for the 
second quarter is  yet to be published, but according to preliminary monthly results for 
the period January to May 2020, it seems that the payment culture was not significantly 
disrupted. In addition, the results from the large debtor unit (see Table 3.2), which saw a 
reduction but encouragingly not too sharp (27% reduction compared to the same period 
of  2019),  could  serve  as  an  additional  indication.  Looking  ahead,  the  expected  tighter 
liquidity conditions for both households and businesses is projected to provide pressure 
for deferrals to be further extended. Furthermore, the authorities’ intentions to establish 
a new settlement scheme for individuals directly impacted by the coronavirus pandemic 
are likely to raise expectations that could affect the timely repayment of debts.  

(9)  OJ A 148/31.07.2020 (Article 16). 

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Table 3.2:  Key Performance Indicators of the Independent Authority for Public Revenue, second 

quarter 2020 (*) 

(*) End-2020 target, as no quarterly target has been set. 

(1) DRU: Dispute Resolution Unit. 

Source: Independent Authority for Public Revenue. 

In  contrast  to  the  previous  periods,  the  Joint  Centre  for  the  Collection  of  Social 
Security  Debt  did  not  meet  its  targets,  which  were  set  prior  to  the  coronavirus 
pandemic.  The  reason  behind  the  reduction  in  debt  collection  by  the  Joint  Centre  is 
most  probably  due  to  the  impact  of  the  pandemic  and  the  deferrals  allowed  for  the 
period April to June 2020. For the second quarter €574 million was collected, while the 
target was for €671 million to have been collected. 

3.4.  PUBLIC FINANCE MANAGEMENT 

Arrears 

The coronavirus outbreak has affected the pace of clearance of arrears, adding to 
previous  implementation  difficulties.  The  authorities  appear  behind  schedule  in 
adhering  to  the  intermediate  targets  set  in  the  clearance  plan  adopted  in  October 
2019 (10).  In  June  2020,  the  stock  of  arrears  amounted  to  €1.5 billion,  that  is  to  say 
€241 million above its December 2019 level, €667 million above the targets set in the 
plan  and  €1.3 billion  above  the  target  set  for  December  2020.  This  development 
partially  reflects  disruptions  in  labour-intensive  processes  caused  by  the  pandemic. 

(10) According to the October 2019 plan, the remaining stock of arrears would be cleared by mid-2021 the 
latest. Most of the arrears would be cleared within 2020, with €140 million or €160 million pertaining 
to pension claims to be cleared by June 2021. 

15 

202020202019Q2Q2Q2TargetResultResultKPI 1Collection of tax debts as of the end of the previous year (million EUR)1 683N/A1 629KPI 2Collection of new debts in the current year (percent of new debt in the year)22.5%N/A23%KPI 3Collection of debts by the large debtor unit (million EUR)330261.7357.4Audits of fresh tax cases by the whole IAPRKPI 4Percent of fresh tax audit cases in total completed audits70% (*)65.5%64.7%Tax audits and collection of large tax payersKPI 5Collection after audits in the year (percent of assessed tax and penalties)40% (*)100.9%108.6%Tax audits and collection of high wealth individualsKPI 6Collection after audits in the year (percent of assessed tax and penalties)40% (*)28.6%807.2%Tax refundsKPI 7Percent of VAT tax refund claims processed within 90 days95%95%89.1%Compliance and enforcementKPI 8Percentage of total tax paid on time for VAT, income and property taxes84%N/A83.2%Percentage of total tax paid on time for VAT, income and property taxesKPI 9Percentage of debtors under enforcement measures68%77%68.9%Pre-litigation phaseKPI 10Percentage of cases closed by explicit decision of the DRU80%97.7%78.9%Prosecution audits by mobile unitsKPI 11Prosecution audits by mobile units  (customs administration)17 5006 55610 246Debt collectionKPI 
  
 
 
                                                 
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Among  the  major  drivers  is  the  increase  in  the  stock  of  unprocessed  pension  claims, 
which  grew  by  €300 million  between  December  2019  and  June  2020,  due  to  an 
unforeseen burden of new unprocessed pension claims that is reported to stem from the 
implementation  of  an  early-2019  law  according  to  which  self-employed  were  granted 
the  possibility  to  recalculate  their  debts  and  apply  for  pensions.  According  to  the 
authorities, this increase of pension claims would result in a remaining stock of arrears 
of  €400 million  by  end-December  instead  of  €160 million.  They  committed  to  update 
their  plan  by  end-October,  with  detailed  information  regarding  the  clearance  of  the 
additional pension backlog. Notwithstanding the unforeseen increase in pension claims, 
some  crucial  structural  measures,  including  the  automation  of  the  processing  and 
awarding of the new pensions claims as well  as the digitalisation of the Single Social 
Security  Fund  (e-EFKA,  see  section  5.1)  were  reported  to  be  broadly  on  track.  These 
measures  should  help  avoiding  the  accumulation  of  new  pension  claim  arrears  and 
should enable the personnel of the Single Social Security Fund to focus on clearing the 
stock of old pension claims.  

To counterbalance the delays and bring the implementation of the clearance plan 
back  on  track,  the  authorities  are  adopting  and  implementing  a  set  of  additional 
corrective measures in several subsectors. The authorities prepared a legal provision 
that  is  expected  to  substantially  decrease  the  value  of  unprocessed  pension  claims  by 
allowing  an  increase  in  temporary  pensions.  Moreover,  after  some  delays,  the 
e-platform, allowing for new arrear payment modalities towards health-sector providers, 
has  been  launched  in  August.  It  should  enable  the  authorities  to  clear  the  remaining 
health  arrears  stock,  which  had  already  dramatically  decreased  early-September. 
Specific targeted actions are undertaken on an ad-hoc basis to accelerate the reduction 
of  arrears  of  extra-budgetary  funds.  A  new  programme  has  been  adopted  for  the 
repayment  of  local  governments’ stock  of  arrears  alongside  measures  to  avoid  the 
creation  of  new  arrears  were  also  adopted (11).  The  Ministry  of  Interior  continues  its 
efforts  towards  improving  the  quality  of  the  statistical  reporting  of  arrears  and  is 
designing new IT tools in collaboration with the Ministry of Digital Governance, with a 
view  to  improving  the  payment  processes.  According  to  the  authorities,  the  impact  of 
these measures will be visible in the August data (12), which will be assessed in the next 
enhanced surveillance report.  

Implementation  of  structural  reforms  recommended  by  the  Hellenic  Court  of 
Auditors,  a  mid-2021  specific  commitment,  is  underway  in  order  to  improve  the 
payment  system  and  avoid  the  accumulation  of  new  arrears.  Challenges  remain 
regarding  the  central  procurement  system  of  the  health  sector  (see  section  5.2).  The 
Hellenic  Court  of  Auditors  identified  the  lack  of  internal  control  across  the  public 
administration as a major weakness of the Greek payment system. The Court is taking 
measures  to  increase  the  awareness  of  general  government  entities  of  their  legal 
obligations in terms of internal control. In the meantime, the authorities are finalising a 

(11) Local  governments  will  be  required  to  transfer  the  amount  corresponding  to  their  adjusted  arrears 
stock  to a  special account at  the  Consignment Deposits and Loans  Fund. If this does  not occur, the 
equivalent  amount  will  be  deducted  from  their  next  monthly  grant.  In  addition,  the  list  of  local 
governments and the amount of their respective arrears will be made public on a quarterly basis on the 
Ministry of Interior website. 

(12) Theses data will be communicated the institutions in November 2020.  

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new  law  which  will  cover  all  relevant  aspects  of  internal  control  and  internal  audit 
across the public administration in a single piece of legislation (see section 9.3). This is 
a  significant  step  forward.  The  National  Transparency  Authority  helps  the  public 
entities  comply  with  the  new  law.  Moreover,  the  Authority,  which  is  responsible  for 
designing  a  structured  internal  control  and  audit  framework  for  the  Greek  public 
administration, is working with the line ministries to fully establish internal audit units 
and  make  them  operational.  For  local  entities  that  are  too  small  to  have  their  own 
internal control system, a technical support project funded by the European Commission 
is  underway  to  investigate  avenues  for  inter-municipal  collaboration  on  the  matter. 
Moreover,  the  authorities  are  designing  a  new  accounting  IT  system (13),  also  with  a 
view to rationalising and speeding up the payment processes of the central government, 
except  for  the  Public  Investment  Budget  payments  which  are  handled  through  a 
different  IT  system  (see  section  3.4).  When  shifting  to  the  new  IT  system,  the 
authorities  intend  to  address  some  of  the  recommendations  made  by  the  International 
Monetary Fund in its technical support report from March 2020. 

Treasury Single Account 

The  authorities  have  continued  to  take  the  necessary  steps  for  the  full 
establishment  of  the  Treasury  Single  Account  at  the  Bank  of  Greece  to  enhance 
cash  monitoring,  a  mid-2020  specific  commitment.  The  Treasury  Single  Account 
system is operational and provides a useful overview of the cash situation of the state. A 
large  number  of  entities  is  already  participating  in  the  Treasury  Single  Account  and 
entities that remain outside of the scheme are not significant in terms of total liquidity. 
Although  the  process  has  stalled  since  April  2020,  the  authorities  are  taking  steps  to 
ensure  full  compliance  among  the  remaining  entities.  By  end-October  2020,  the 
Ministry  of  Finance  will  perform  an  assessment  of  the  entities’  compliance  with  the 
rules relatives to the monitoring of their relevant liquidity buffer in commercial banks, 
which, according to the law, should not exceed their fifteen days’ liquidity needs. The 
Ministry plans to perform an assessment of compliance with that rule by end October-
2020. The authorities are encouraged to set up dedicated tools for the close monitoring 
of  entities  deemed  to  face  difficulties  to  comply.  The  substitution  of  paper  payment 
orders by electronic ones continues to progress. The share of electronic payments in the 
entities that had joined earlier the e-payment platform of the Bank of Greece continued 
to  increase  and  a  few  more  entities  have  joined  the  platform  since  April  2020.  The 
authorities  plan  to  address  the  remaining  challenges,  such  as  the  rationalisation  of  the 
number  of  cash  accounts  with  low  balances  or  improving  the  monitoring  and  the 
recording of special accounts.  

Progress on cash forecasting, a mid-2020 specific commitment, has suffered delays 
due to the coronavirus pandemic, and will be reassessed under the next review. The 
results  of  the  ongoing  pilot  project  are  encouraging  since  the  entities’  projections  are 
meeting the expected quality standards. Progress had picked up in June, when 20 of the 
25 entities that were supposed to submit their forecasted cash needs to the Ministry of 
Finance did so. Nevertheless, at end-August, only two thirds of the entities were able to 
send their forecasted cash needs on a monthly basis. The Ministry of Finance adopted a 

(13) The project is referred as Government Enterprise Resource Management (Gov-ERP).  

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set of actions to ensure that the remaining third of the pilot entities will be able to report 
on their cash needs on a monthly basis as of September. 

Chart of Accounts 

The  implementation  of  the  Chart  of  Accounts  reform  is  broadly  on  track,  a 
mid-2021  and  mid-2022  commitment.  The  procurement  of  the  new  IT  system (14) 
supporting  the  accounting  reform  and  the  implementation  of  the  Chart  of  Account  is 
on-going.  In  addition,  the  authorities  have  taken  further  steps  to  underpin  progress  on 
this reform. The directorate in charge of the reform at the Ministry of Finance has been 
reinforced.  The  accounting  policy  for  the  implementation  of  the  new  General 
Government  Accounting  Framework  has  been  adopted,  following  three  necessary 
amendments of legal provisions (15); this was a precondition for the compilation and the 
closure  of  the  pending  2019  financial  statements  of  the  state,  and  for  an  orderly 
transition towards accrual accounting (16). The closely linked e-invoicing project in the 
public  sector  is  showing  encouraging  results.  Work  is  underway  on  the  functional 
classification of the Chart of Accounts, in accordance with the performance budgeting 
framework that is being developed. The five ministries that have not yet joined the pilot 
project  on  the  matter  are  expected  to  do  so  in  2021,  in  line  with  the  initial  timeline. 
Technical support is provided through two projects of the European Commission for the 
rollout of the accounting reform, as well as for further capacity building actions at the 
General Accounting Office. 

The  action  plan  on  the  implementation  of  the  Chart  of  Accounts  in  the  Public 
Investment Budget is reported to be on track, although the full implementation of 
the  Chart  of  Accounts  in  the  Public  Investment  Budget  remains  a  challenge.  The 
action plan will allow for the presentation  of the budget  execution in  accordance with 
the Chart of Accounts classifications. At the same time, the authorities consider that, at 
the budget preparation stage, the Public Investment Budget can only abide by the less 
detailed levels of administrative and functional classifications of the Chart of Accounts. 
The authorities  committed to  consider potential  ways for improving the  situation with 
the  help  of  technical  support  to  be  provided  by  the  European  Commission (17).  In 
addition,  the  action  plan  is  not  designed  to  deliver  on  accrual  accounting (18).  The 
authorities are encouraged to address this issue in the medium term. 

(14) Public Investments Budget’s payments are  made through a specific e-payment system, called ePDE, 
which is intended to interoperate  smoothly  with the  new central  government IT system  (Gov-ERP). 
According  to  technical  support  provided  through  the  European  Commission,  this  situation  is  not 
viewed as a critical issue as long as ePDE is used only as an e-payment system and will not substitute 
for the ledgers and the resource planning modules of the central government IT system. 

(15) Presidential Decree 54/2018 and law 4270/2014 
(16) In  accordance  with  Presidential  Decree  54/2018  the  whole  of  the  general  government  is  to  adopt 

accrual accounting by 2023. 

(17) In addition to the technical support project provided through the European Commission, the Ministry 
of  Development  has  requested  assistance  from  the  International  Monetary  Fund,  in  the  form  of  a 
Public Investment Management Assessment (PIMA), with a view to improving budgetary practices. 
(18) The  implementation  of  the  new  Chart  of  Accounts  and  double-entry  book-keeping  are  only  partial 
steps  towards  the  implementation  of  the  accrual  accounting  which  is  to  be  adopted  by  2023  in  the 
whole general government (Presidential Decree 54/2018). 

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Public procurement  

The  authorities  have  taken  stock  of  the  various  issues  in  the  public  procurement 
legal  framework  and  are  in  the  process  of  adopting  a  new  piece  of  legislation  to 
address  those  issues.  The  pandemic  greatly  affected  the  initial  timeline  of  the 
preparation and the adoption of the law, which addresses a number of important issues 
in  the  public  procurement  legal  framework,  including  the  frequent  phenomenon  of 
excessively low offers submitted in the tendering procedure. Simplifying and enhancing 
the  transparency  in  the  public  procurement  procedures  namely  through  e-procurement 
as  well  as  simplifying  and  accelerating  the  review  procedures  are  amongst  the 
authorities’ priorities. A legislative committee was established to amend the current law. 
The  new  law  is  planned  to  be  adopted  by  end-October.  Its  full  and  timely 
implementation  is  key  given that public procurement will play an  essential role in  the 
efficient management of the Recovery and Resilience Plan. To this end, the authorities 
are encouraged to adopt an action plan for the implementation of the new framework. 

The  authorities  plan  to  adopt  a  new  public  procurement  strategy  for  2021-2025, 
which would contribute to a more sustainable and efficient use of public resources. 
A committee has been created under the Hellenic Single Public Procurement Authority 
that is responsible for the national strategy on public procurement. It is working with the 
support of the General Secretariat for Coordination on the new strategy, the priorities of 
which  are  still  to  be  determined  and  which  will  encompass  a  component  on  fighting 
corruption  (see  section  9.3).  A  timeline  which  foresees  a  mapping  of  the  current 
situation  and  the  identification  of  political  priorities  has  been  established,  before  the 
envisaged finalisation of the strategic and action plan in February 2021. The authorities 
foresee  an  agreement  on  a  public  procurement  strategic  partnership  with  the 
Commission, with a view to supporting the necessary reforms. 

3.5.  PUBLIC INVESTMENT  

Public investment in Greece declined substantially in the aftermath of the financial 
crisis, assisted by a recurrent under-execution of the investment budget in recent 
past years. General  government  investment  was by 1.1% of GDP lower in  2019 than 
initially planned, marking 2019 as yet another year of very sizeable underspending. The 
lower  execution  was  accompanied  by  lower  drawing  of  EU  funds,  which  broadly 
neutralised  the  impact  on  the  general  government  balance.  The  investment  under-
execution in 2019 comes on top of the recent years’ undershooting and as a result, only 
62% of the public investment budget ceilings allocated to ministries were actually spent 
in the period 2017-2019, compared to an average of 88% in 2014-2016.  

The authorities estimate that the investment budget will be fully executed in 2020, 
also  confirmed  by  the  actual  data  for  the  first  half  of  2020.  The  state  investment 
expenditures  more  than  doubled  compared  to  the  corresponding  period  last  year, 
recording an increase of 1.5% of GDP. However, this increase cannot  be attributed to 
structural  measures  analysed  below  but  rather  to  the  fact  that  spending  from  the 
programming  period  2014-2020  is  reaching  maturity  and  to  the  fact  that  a  part  of  the 
measure undertaken in response to the coronavirus crisis will be financed by structural 
funds. 

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Chapter 3 - Fiscal and fiscal-structural policies 

The  authorities  have  started  implementing  measures  to  address  the  structural 
obstacles. These measures, including a detailed action plan to improve the monitoring 
and  forecasting  of  the  Public  Investment  Budget,  as  well  as  the  creation  of  a  Project 
Preparation Facility and the preparation of Strategic Project  Pipeline, aim to  make the 
best  use  of  available  resources  in  the  public  investment  budget  and  accelerate  the 
drawing of EU funds. In addition, the establishment of the Hellenic Development Bank 
has accelerated the disbursement of financial instruments and the simplification of the 
regulatory  framework  has  accelerated 
implementation  of  entrepreneurship 
programmes.  The  flexibility  of  the  State  Aid  rules  that  was  allowed  due  to  the 
coronavirus outbreak has  also  helped accelerate  the disbursements of the funds. Work 
continues  on  the  preparation  of  the  National  Development  Programme  that  will  start 
being implemented in January 2021. The implementation of these measures will also be 
crucial for a sustainable recovery from the coronavirus crisis. All the more so, in light of 
the  various  new  EU  facilities  including  the  Recovery  and  Resilience  Facility  that  will 
support investment in the EU over the next EU budget programming period, of which 
Greece could greatly benefit.  

the 

In  order  to  prepare  new  bankable  projects,  the  authorities  are  preparing  a 
Strategic  Project  Pipeline.  The  characteristics  and  role  of  the  pipeline  as  well  as  a 
timetable were agreed in July 2020. The Pipeline will be an independent  unit, outside 
the  core  structure  of  the  sectoral  ministries  to  avoid  conflicts  of  interest.  It  will  be 
coordinated  by  the  Presidency  of  the  Government.  Priority  infrastructure  investment 
projects  will  include  energy,  environment,  urban,  transport  and  digital  sectors,  with 
projects that have a budget over €10 million. Selected projects will have high relevance 
for/under  the  National  Growth  Strategy  and  the  sectoral  national  strategies.  The 
Strategic Project Pipeline will be particularly useful for mobilising funds under the EU 
Recovery and Resilience Facility. 

To help the preparation and implementation of priority infrastructure projects of 
the Strategic Project Pipeline, the authorities are setting up a Project Preparation 
Facility. The details and placement of the Project Preparation Facility is currently being 
worked out.  It will be important to ensure that  its placement safeguards the rights and 
competencies of established independent institutions. The facility aims at supporting the 
planning  and  execution  of  public  investment  projects,  including  giving  technical 
assistance and providing project management  

The  2019  action  plan  to  enhance  the  monitoring  and  forecasting  of  the  Public 
Investment  Budget  is  being  implemented  as  scheduled.  A  more  frequent  and 
enhanced  exchange  of  data  between  the  Ministry  of  Finance  and  Ministry  of 
Development,  as  well  as  monthly  updates  on  the  total  Public  Investment  Budget 
allocation of expenditure based on actual payments, are already in place. Other actions, 
such as the increase in frequency of Public Investment Budget revenue forecasts – from 
semi-annually  to  quarterly  –  and  the  technical  adjustments  of  the  Public  Investment 
Budget database to facilitate the budget preparation process, are still in progress, but in 
line with the timetable. Although the coronavirus outbreak resulted in minor delays, the 
authorities are planning to absorb any delay within the initial timeline, an effort that is 
welcomed  by  the  European  Institutions.  In  the  context  of  the  action  plan,  technical 
support  by  the  European  Commission  is  being  provided  on  two  projects:  (i)  the 
automation and streamlining of the implementation procedures, and (ii) support on the 

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collection,  handling  and  reporting  of  data  related  to  monitoring,  budgeting  and 
forecasting of Public Investment Budget expenses and revenue.  

21 

4. 

SOVEREIGN FINANCING 

4.1.  SOVEREIGN FINANCING  

The  Greek  government  bond  yields  and  the  yield  spreads  declined  close  to  post-
crisis  lows.  The  yield  spreads  over  the  German  Bund  on  the  long-term  bonds  have 
declined  by  around  250  basis  points  since  early  May  2020  and  stabilised  below 
1 percentage  point  in  August  for  the  5-year  tenure.  Benefiting  from  the  favourable 
financing  conditions,  the  Public  Debt  Management  Agency  issued  a  10-year  bond  in 
June 2020 of an amount of €3 billion. The auction attracted great interest, with a final 
order-book of close to €16 billion. The bond was issued with a coupon of 1.5% and a re-
offer yield of 1.6%. This bond auction was successfully reopened in September, raising 
another  €2.5 billion  with  a  1.2% yield,  which  is  the  lowest  yield  in  the  history  of  the 
Hellenic Republic for this tenure. 

Graph 4.1:  5-year government bond spreads over the German Bund 

Source: European Commission. 

The favourable market conditions described above are likely to have been strongly 
supported  by  the  Eurosystem’s  purchases  of  Greek  government  securities.  Under 
its  Pandemic  Emergency  Purchase  Programme,  the  Eurosystem  has  bought  Greek 
government securities for almost €10 billion by end-July. Even if market volatility has 
subsided, Greece’s market access conditions are likely to remain sensitive to the market 
sentiment. 

Financing risks are considerable, but there are safety nets in place.  The financing 
needs of the budget have increased markedly since the last report. The deterioration of 
the  budgetary  outlook  calls  for  vigilance.  Since  May  2020,  not  only  has  the  baseline 
primary balance deteriorated, but the state will face additional payment obligations due 
to  the  payment  of  retroactive  pensions  worth  €1.4 billion.  The  cash  reserves  of  the 
general government remain considerable and stood above €31 billion at the end of June, 

23 

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Chapter 4 - Sovereign financing 

about  €2.5 billion  lower  compared  to  March.  The  cash  buffer  account (19)  balance 
remained at €15.7 billion. The recent bond issuance, the space to increase repos by over 
€3 billion, the potential proceeds from the medium-term debt relief measures amounting 
to  €1.5 billion,  and  the  available  EU  funding,  could  alleviate  short-term  liquidity 
pressures.  

Preserving an adequate cash buffer will be crucial to sustain stable market access 
next  year,  taking  into  account  the  risks  that  selling  pressure  may  emerge  in  the 
sovereign bond market. Investor sentiment may be also affected by global risk appetite 
and by the perceptions of the management of the pandemics and progress with reforms, 
including  in  the  banking  sector.  Debt  servicing  needs  in  2021  are  limited,  but  further 
bond issuances will be required to maintain an adequate level of cash reserves.  

(19) The  cash  buffer  account  was  built  also  through  disbursements  under  the  European  Stability 
Mechanism programme and dedicated to debt service. Greece may use this amount for other purposes 
as well, following an approval of the European Stability Mechanism’s governing bodies. 

24 

 
                                                 
5. 

SOCIAL WELFARE 

5.1.  PENSIONS 

Despite  the  difficult  circumstances,  the  authorities  are  making  progress  in 
implementing  the  action  plan  to  finalise  the  setup  of  the  Single  Social  Security 
Fund  (EFKA),  a  mid-2020  specific  commitment.  The  main  aim  of  the  action  plan 
besides  finalising  the  organisational  setup  is  the  digital  transformation  of  the  Fund  by 
end-2020  (renamed  to  e-EFKA  as  of  1 March  2020).  The  first  stage  of  merging  the 
public  sector  and  supplementary  pension  functions  to  the  Single  Social  Security  Fund 
has already been implemented through the assignment of employees to new positions. 
The  physical  move  of  offices  has  been  delayed  by  the  pandemic.  The  moving  begun 
only in July with staff moving initially from five to two or three buildings with a view 
of moving all offices to one building by the end of 2020. Therefore the commitment is 
rescheduled to end-2020. The remaining organisational measures are the establishment 
of local subsidiaries for farmers and self-employed, which have seen delays due to the 
coronavirus outbreak. While the setup of the subsidiaries for farmers is foreseen to be 
completed  by  the  end  of  2020,  the  establishment  of  subsidiaries  for  self-employed  is 
foreseen  to  be  completed  by  mid-2021.  On  the  digital  processing  of  pension 
applications,  the  action  plan  foresees  moving  all  scattered  data  under  one  platform, 
which is now under a pilot phase. The results of the pilot are being currently analysed. 
According  to  the  authorities,  the  preliminary  results  indicate  that  the  target  of  30% 
coverage of digitally processed main pension applications (out of all digitally submitted 
main pension applications) by end-June 2020 has been met. 

Regarding  the  recent  ruling  of  the  Court  of  Auditors  granting  early  retirement 
rights  to  male  civil  servants  with  young  children,  the  authorities  expect  that the 
effects of this ruling will be small. The court ruling affects only those men with young 
children  who,  back  in  2010,  had  the  legal  requirements  to  apply  for  early  retirement 
(25 years of service and a child less than 18 years old) and had filed a claim for early 
retirement  back  then.  This  only  affects  a  small  number  of  claims.  All  other  persons 
applying  for  an  early  retirement  will  be  assessed  under  the  new,  reformed  and  less 
generous pension rules, not those that applied ten years ago. This significantly mitigates 
the fiscal impact of the ruling.  

The  recent  Council  of  State  ruling  on  the  2012  pension  cuts,  entitles  to  a 
compensation of those pensioners, who had filed a claim, for the 11-month period 
starting from the publication of the previous Council of State ruling in June 2015 
until  the  implementation  of  the  2016  reform  in  May  2016.  (see  Box  3.1  for  an  in-
depth  description  of  the  recent  rulings).  The  publication  of  the  court  decision  in  full 
detail may take a number of weeks and therefore not all technical details of the ruling 
are  fully  clear  at  this  stage.  To  comply  with  the  Court  ruling,  the  government  has 
submitted a law amendment on 29 July, which compensates all private sector pensioners 
(not only those who had filed a claim) for pension cuts incurred on their main pensions 
at a cost of 0.5% of GDP. The government has also pledged to compensate pensioners 
of  the  public  sector  in  case  the  Court  of  Auditors  issues  a  ruling  to  the  same  effect 
related  to  their  pension  cuts,  which  would  raise  the  total  cost  of  the  compensation  to 

25 

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Chapter 5 - Social welfare 

0.8%  of  GDP.  Being  a  one-off  compensation  for  pension  cuts  incurred  in  2012,  the 
measure has no impact  on the current functioning of the Greek pension system nor on 
future  pension  expenditure.  The  major  pension  reform  enacted  in  May  2016  remains 
thus intact.  

5.2.  HEALTHCARE 

To  respond  to  the  coronavirus  outbreak  in  spring  2020,  the  authorities  have 
substantially  strengthened  the  health-care  system  to  deal  with  the  pandemic, 
including  through  a  wider  use  of  digital  tools.  They  focused  their  efforts  on 
strengthening  the health-care system, increasing the availability of intensive care beds 
and recruiting about five thousand additional staff members, both doctors and nurses. In 
parallel,  to  cope  with  the  ongoing  challenge  to  manage  the  impact  of  the  pandemic, 
telemedicine  has  been  strengthened  both  on  the  side  of  consultations  and  on  that  of 
prescriptions,  to  ensure  access,  while  avoiding  any  unnecessary  contact  between 
potentially  infected  patients  and  other  patients  and/or  health-care  staff.  Greece  also 
deployed  a  number  of  digital  solutions,  in  order  to  deal  with  the  health  crisis  by 
investing in services that could ideally be utilised after the end of the pandemic as well, 
such  as  a  paperless  e-prescription  system,  a  National  Patient  Registry  with  a  tele-
consultation  platform  for  the  treatment  of  coronavirus  patients  that  are  restricted  at 
home,  supported  by  an  enhanced  business  intelligence  system.  Thanks  to  the  early 
implementation  of  this  and  other  measures,  Greece  to  date  successfully  managed  to 
contain  the  spread  of  the  virus  during  the  first  wave,  but  is  now  facing  an  increased 
number  of  new  cases,  mostly  related  to  the  tourist  season.  With  a  longer-term 
perspective,  the  Ministry  of  Health  has  revised  its  digital  strategy  and  progressed  on 
issues  such  as  the  design  of  the  national  e-health  interoperability  framework,  with 
technical support provided through the European Commission, and on the digital health 
action plan. 

The redesign of the primary health-care system, a mid-2020 specific commitment, 
will  take  a  substantially  longer  time  to  be  implemented,  to  reflect  changes  in  the 
delivery  of  some  of  its  main  elements  and  due  to  inevitable  delays  caused  by  the 
need  to  manage  the  response  to  the  pandemic.  Legislative  changes  are  still  at  a 
drafting  stage,  with  adoption  expected  not  before  spring  2021.  The  reform,  which 
started  in  2018,  aims  to  set  up  a  comprehensive  system  of  primary  health  care  with  a 
compulsory  registration  of  the  whole  population  with  a  family  doctor,  who  would 
become the first point of contact for the patient and implement compulsory gatekeeping. 
Based  on  available  information,  most  of  the  elements  of  the  reform  are  planned  to  be 
redesigned,  and  the  roll-out  of  the  system  is  suspended  until  a  new  delivery  model  is 
defined.  The  authorities  are  encouraged  to  preserve  the  elements  of  compulsory 
registration and  gatekeeping, which  are key  for  a successful  establishment of a robust 
and  well-functioning  system  of  primary  health  care,  as  they  help  ensure  equal  access 
and  protect  the  population  from  supply-induced  demand  and  its  avoidable  financial 
burden,  which  is  a  growing  source  of  concern  in  the  current  system.  Meanwhile, 
however, the system is planned to revert to the pre-reform model, going from capitation 
to fee-for-service reimbursement of family doctors (with a maximum of 200 visits per 
months), a step back deemed necessary to support the management of the pandemic that 
will  allow  to  double  the  number  of  family  doctors  contracted  with  the  Public  Health 
Fund.  The  authorities  intend  to  consistently  rely  on  public  private  partnerships  and 

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Chapter 5 - Social welfare 

contracted  private  doctors,  rather  than  creating  a  public  structure,  for  the  provision  of 
primary health-care services. The redesign of the reform will necessitate a rescheduling 
of the commitment to 2021. The authorities plan to resume the roll-out of the primary 
health care network no earlier than spring 2021 given the short-term need to focus the 
efforts  on  the  response  to  the  pandemic.  A  new  General  Secretariat  with  exclusive 
responsibility for the implementation of the Primary Healthcare transformation was set 
up within the Ministry of Health to speed up implementation. The reform became all the 
more relevant in light of the coronavirus crisis, given the key role of the primary health 
care  units,  including  the  newly  and  swiftly  deployed  mobile  units  (KOMYs),  in 
supporting the response to the pandemic so far and in light of its potential to improve 
equitable  and  affordable  access  that  rests  on  full  population  coverage  and  uptake 
through  compulsory  registration  and  gatekeeping  supported  by  a  comprehensive 
communication campaign. The aim should remain to set up a comprehensive system of 
primary health care that delivers full population coverage, compulsory registration and 
gatekeeping to counter supply-induced demand, improving both access and the overall 
efficiency of the health care system. 

Centralised procurement, a mid-2020 specific commitment, is already being partly 
implemented  and  the  overall  set  up  of  the  National  Health  Authority  for  Health 
Procurements (EKAPY) is progressing, but yet to be completed also due to delays 
caused by the pandemic. A new board is in place and the Authority is coordinating the 
procurement  strategy  at  regional  level,  with  a  focus  on  pandemic-related  needs. 
Centralised  procurement  is  mostly  implemented  at  regional  level,  with  a  coordination 
role from the Authority, but a relatively large share of tendering procedures finalised at 
centralised  level  were  launched  by  the  former  institution  several  years  ago.  Draft 
legislation,  defining  the  new  legal  framework  for  the  Authority  was  finalised  and  is 
currently planned to be submitted to the Parliament by the end of October and adopted 
by  December.  The  authorities  also  shared  an  operational  plan  for  procurements  to  be 
launched in 2020 according to which they estimate that up to 40% of the total hospital 
expenditure  would  be  centrally  procured  by  mid-2022,  a  mid-2022  specific 
commitment, with approximately €305 million worth of items to be tendered out during 
the first quarter of 2021 with the aim to reach 30% by the first quarter of 2021. Even 
though the central authority is reported to have helped the regional authorities to ensure 
that items  were procured at  the best  price, the authorities are encouraged to  reactivate 
the Price Observatory, a monitoring tool intended to increase procurement transparency 
and  efficiency,  as  from  January  2021.  At  present,  recruiting  the  necessary  skills  to 
complete the staffing of the Authority is progressing, although some challenges remain, 
but the newly finalised legal framework, soon to be legislated, may facilitate the filling 
of permanent posts. Up until September the authorities plan a substantial increase by 50 
fixed-term appointments in the National Health Authority for Health Procurements, of 
which 33 were already recruited.  

The clawback amounts, especially for what concerns the area of pharmaceuticals, 
and delays in its collection are a cause of concern. For pharmaceuticals, the collection 
of  2019  has  only  been  completed  for  50%  of  the  total,  with  the  remaining  part  to  be 
collected  starting  in  November  2020  through  36-monthly-instalments  planned  to  be 
legislated by October 2020 (while by this time the overall collection should have been 
finalised). Equally  worrisome are the increasing  trends: the  clawback for 2019, which 

27 

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Chapter 5 - Social welfare 

amounts to almost €800 million, is 36.2% higher than in 2018 and almost 65% higher 
than  in  2017.  The  clawback  for  the  first  semester  2020  has  been  quantified  at 
€364 million. For private health-care providers, collection has not started for 2018 and 
2019  despite  important  delays  and  is  expected  to  resume  in  November 2020  which 
implies  that  €600 million  are  currently  uncollectable.  Adoption  of  the  necessary 
legislation  to  finalise  collection,  expected  by  October  2020,  would  help  preserve  the 
fiscal credibility of the clawback.  

Revision  and  consistent  implementation  of  the  previously  adopted  structural 
measures would support efficiency and access to quality health care. The authorities 
are encouraged to reduce supply-induced demand and waste, and to take urgent further 
action to and fully enforce the tools currently available. The insufficient implementation 
of structural measures has repercussions also on patients’ access. Introducing a means-
tested structure could be key to protect vulnerable citizens from catastrophic payments, 
both from outpatients and inpatients. Furthermore, a review of the current definition of 
the clawback introducing a risk-sharing component would be instrumental in enhancing 
the efforts to avoid the creation of new clawbacks and to curb supply-induced demand, 
which leads to high out-of-pocket payments. 

5.3.  SOCIAL SAFETY NETS 

The review of the system of subsidies for local public transport, a mid-2020 specific 
commitment, is close to being concluded. The revised primary legislation for the new 
system  was  adopted  in  July  in  law  4714/2020.  The  secondary  legislation  to  allow  a 
regular  and  objectively-based  reimbursement  of  subsidised  public  transport  tickets  to 
operators in Athens and Thessaloniki is expected to be adopted in September 2020. 

The  reform  of  the  disabilities  benefit  framework  is  progressing  according  to  its 
previously agreed redesign, a mid-2019 specific commitment that will take longer 
to be completed. Following a further review of EU best practices, the initial approach 
of a functional assessment of disability based on a self-assessment has been abandoned 
in favour of a functional approach based on physical examination by qualified experts. 
Such assessments by experts are widely used in other Member States with the dual role 
of  assessing  benefit  eligibility  and  making  specific  proposals  for  disability  mitigation 
and  rehabilitation.  For  this  aim,  a  working  group  and  a  steering  committee  have  been 
established.  A  policy  paper  is  expected  to  be  adopted  in  September  2020,  including  a 
proposal for a pilot project to be launched in the first quarter of 2021. The assessment 
process  will  involve  a  preliminary  questionnaire,  a  testing  process,  and  an  interview. 
With  regards  to  the  administrative  procedures  related  to  the  granting  of  disability 
benefits  themselves,  the  electronic  system  for  processing  the  applications  is  now 
available in three regions (Athens, Thessaloniki, Patras). At the same time, the operation 
of  the  disability  assessment  centres  (KEPA)  has  been  severely  affected  due  to  the 
restrictions imposed following the coronavirus outbreak. 

The social impact of the coronavirus crisis is not yet reflected in the take up of the 
Social  Solidarity  Income  benefit,  as  eligibility  rules  are  based  on  the  previous 
year’s incomes. This  is a broader problem of the social  benefits  system  in  Greece, as 
for most benefits, income is assessed based on tax returns for the previous year that are 
submitted  in  June  each  year.  For  this  reason,  social  assistance  has  not  played  a  major 

28 

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Chapter 5 - Social welfare 

role in providing income support at the beginning of the coronavirus crisis. In contrast, 
benefit  eligibility  and  payments  are  likely  to  increase  substantially  next  year.  This 
highlights  the  need  of  upgrading  the  benefits  system,  to  address  more  accurately  the 
actual  needs  of  households  based  on  the  assessment  of  the  current  income  situation, 
making the benefits system more responsive to short-term shocks of a large scale.  

The  design  of  the  ‘labour  market  reintegration’  pillar  of  the  Social  Solidarity 
Income  (third  pillar)  is  being  adapted  in  view  of  the  coronavirus  crisis,  and  the 
rollout of the new framework, an end-2019 specific commitment, is  scheduled for 
autumn  2020,  contingent  on  health-related  developments.  The  Social  Solidarity 
Income  scheme  should  combine  income  support  with  the  provision  of  social  services 
(second  pillar)  and  labour  market  reintegration  services  (third  pillar).  During  2019,  a 
pilot  project  to  ensure  the  provision  of  social  support  and  labour  market  activation 
services was implemented in 32 municipalities across the country. The findings of the 
pilot project have been evaluated in view of its national implementation in 2020 and the 
terms of the rollout for the third pillar, based on a new delivery model for active labour 
market  policies,  were  being  discussed  before  the  lockdown.  However,  following  the 
Covid-19  outbreak,  there  was  a  need  to  adapt  the  business  processes  of  the  public 
employment service (OAED) to the new situation, and, in turn, adjust the terms of the 
national rollout of the new framework. The rollout should be launched in autumn 2020. 

29 

6. 

FINANCIAL SECTOR 

6.1.  FINANCIAL SECTOR DEVELOPMENTS 

Greek banks have continued to build up their liquidity buffers. They were able to 
keep  the  cost  of  funding  manageable,  even  though  the pandemic  has  temporarily 
increased  the  cost  of  long-term  unsecured  funding.  Greek  banks  have  been  able  to 
reduce  their  funding  cost  by  replacing  repo  funding,  with  increased  liquidity  from 
Eurosystem’s  refinancing  operations.  This  has  been  facilitated  by  the  easing  of 
conditions for Eurosystem targeted longer-term refinancing operations (TLTRO III) and 
a  temporary  easing  of  collateral  requirements  for  Eurosystem  credit  operations,  in 
particular  the  waiver  to  accept  Greek  sovereign  debt  instruments  as  collateral.  As  a 
result, Eurosystem borrowing of Greek banks has gone up by €29 billion over the period 
end-February to end-July 2020, increasing from 3.1% of their total liabilities to 13.9% 
(see  graph  6.1(right)).  Moreover,  their  liquidity  position  benefited  from  a  continued 
upward  trend  in  private  sector  deposits,  in  particular  from  corporates  seeking  to 
accumulate liquidity to  weather the uncertainties from the coronavirus pandemic. This 
outweighed a decrease in general government deposits, as the state proceeded with the 
disbursements related to its support measures to the overall economy. As a result, Greek 
banks  improved  their  liquidity  coverage  ratios  (LCR),  having  in  most  cases  already 
returned  above  the  regulatory  requirement  of  100%.  Nonetheless,  despite  this  positive 
development,  the  cost  for  long-term  unsecured  subordinated  funding  has  not  yet 
returned  to  the  levels  seen  prior  to  the  pandemic (20)  and  is  only  gradually  declining 
despite supportive trends in Greek sovereign debt yields.  

Graph 6.1:  Bank deposits (left) and total borrowing from the Eurosystem (right) 

(1) MFIs: Monetary Financial Institutions, HH: Households, NFC: Non-Financial Corporations. 

Source: European Central Bank, International Monetary Fund. 

The loan moratorium measures put in place by banks and servicers, coupled with 
the flexibility announced by the supervisory authorities, imply  that the impact of 

(20) It  is  indicative  that  the  yields  of  two  10-year  Tier  2  issuances  of  Greek  banks  that  had  taken  place 
shortly  before  the  onset  of  the  coronavirus  outbreak  (February  2020),  with  a  yield  at  the  point  of 
issuance of 4.25% and 5.5%, were still trading at high yields at the end of June 2020 (8.6% and 14.8% 
respectively). 

31 

0501001502002503003504001011121314151617181920MFIsHHNFCCentral Governmentbillion EUR0510152025303540455002040608010012014016018008101214161820Borrowing from the ECBbillion EUR %  
 
                                                 
Commission Staff Working Document -  

Chapter 6 - Financial sector 

the pandemic on the quality of the banks’ loan books will be limited this year. The 
moratoria are applicable for debtors affected by the coronavirus outbreak and apply to 
interest  payments  for  business  and  principal  and/or  interest  for  natural  persons. 
According to the data submitted by the Greek systemic banks as of 31 May 2020, on the 
loan exposures affected by the moratoria offered to debtors, non-legislative moratorium 
arrangements  had  been  granted  to  €18.9 billion  of  loans,  out  of  332  thousand 
applications worth €22.8 billion of loans. Moratoria granted represent above 10% of the 
banks’ total loan portfolio and 14% of all performing loans (moratoria granted to small 
and  medium-sized  enterprises  accounts  for  20%  of  performing  loans).  In  terms  of 
allocation of the moratoria granted across different asset classes, 59% of moratoria was 
granted to households (mainly for collateralised residential loans) and 41% of moratoria 
granted  to  corporates  (of  which  26%  to  small  and  medium-sized  enterprises) (21). 
However,  the  Hellenic  Bank  Association  has  already  announced  on  7 July  that  the 
moratoria  granted  will  be  extended  until  the  31 December  for  both  legal  entities  and 
natural  persons,  subject  to  the  same  conditions  as  applied  until  now.  The  criteria 
published by the European Banking Authority allow public and private moratoria not to 
be automatically classified as forbearance measures for the purposes of the International 
Financial Reporting Standard 9 and the definition of default. Thus, the main impact of 
the  pandemic  could  start  being  reflected  in  supervisory  asset  quality  indicators  only 
after the moratoria expire. 

The  authorities’  efforts  to  sustain  access  to  finance  during  the  coronavirus  crisis 
for affected businesses, are starting to bear fruit and are expected to mitigate the 
impact on the  corporate loan book this year. The two schemes implemented by the 
Hellenic  Development  Bank,  i.e.  a  guarantee  scheme  and  the  interest  subsidy  scheme 
for  new  corporate  loans,  co-financed  by  the  Hellenic  Development  Bank  (TEPIX  II), 
have  been  particularly  successful  in  attracting  strong  demand.  The  guarantee  scheme 
consists of two tranches of €1 billion of guarantees each, aiming to leverage €7 billion 
of loans. Until the beginning of July, €3.1 billion of loans had been approved under the 
first  tranche,  corresponding  to  4 406  small  and  medium-sized  enterprise  loans 
(€1.3 billion)  and  270  large  corporate  loans  (€1.8 billion),  while  actual  disbursements 
were expected to gradually pick up throughout the summer. The TEPIX II scheme has 
also  been  successful  in  attracting  demand  via  a  new  sub-product  (aimed  at  providing 
support  to  companies  affected  by  the  coronavirus  outbreak)  offering  a  2-year  interest 
grace period, financed jointly by the commercial banks and an expanded total envelope 
of  €838 million  by  the  Hellenic  Development  Bank.  As  a  result,  the  scheme  has 
mobilised 12 783 loans worth €1.8 billion (€1.4 billion of which related to the new sub-
product)  and  was  recently  expanded  by  €180 million,  aiming  to  leverage  another 
€800 million of new loans, to cover the demand in excess of the initial envelope. Both 
schemes  attracted  a  higher  number  of  applications  than  the  available  budget,  which 
points to the existence of strong demand. Nonetheless, the authorities are assessing the 
adequacy of existing schemes on a continuous basis, as evident by the extension of the 
TEPIX  II  scheme.  Beyond  these  two  programmes,  interest  subsidies  to  existing 
performing  loans,  bonds  or  bank  overdrafts  of  corporates  affected  by  the  coronavirus 
crisis  for  the  5  month  period  April  -  September  are  also  offered  in  the  form  of  direct 
grants  by  the  government  (with  a  total  envelope  of  €750 million,  of  which  only 

(21) In  terms  of  sectors  to  which  moratoria  have  been  granted,  these  are  mainly  towards  trade  (26%), 

accommodation and food (24%) and construction & real estate (29%). 

32 

                                                 
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Chapter 6 - Financial sector 

€179 million  had  been  utilised  by  the  beginning  of  July)  with  the  aim  to  provide 
working  capital  to  viable,  primarily  small  and  medium-sized  enterprises,  under  the 
condition  of  maintaining  their  number  of  employees.  These  schemes  are  expected  to 
provide  support  to  lending  growth  to  businesses  over  the  coming  months,  supporting 
employment and, to some extent, asset quality in the banking sector. 

Although the stock of non-performing loans continued to decline in the beginning 
of 2020 and the potential negative impact of the coronavirus crisis on asset quality 
will  only  start  becoming  evident  after  the  expiry  of  the  moratoria,  the  banks  are 
proceeding  to  book  extraordinary  expected  credit  loss  provisions  to  reflect  the 
worsening macroeconomic environment. The stock of non-performing loans of Greek 
banks  has  continued  its  downward  path  in  the  first  quarter  of  2020,  dropping  from 
€68.5 billion  at  the  end  of  2019,  to  €60.9 billion  in  March  2020 (22).  The  intragroup 
transfer  of  €7.5 billion  of  predominantly  non-performing  loans  by  a  systemic  bank,  in 
the context  of their securitisation under the Hercules asset protection scheme, was the 
key driver. In the absence of this transaction, the stock of non-performing loans still fell 
by  €1.1 billion,  mainly  on  the  back  of  write-offs,  while  organic  resolution  of  non-
performing  loans  remains  marginal.  However,  as  the  positive  effect  of  the  concluded 
securitisation under the Hercules scheme will only formally appear in the consolidated 
banking group figures next quarter (23), the improvement in the share of non-performing 
loans to total customer loans is less pronounced, dropping to 39.6% at the end of March 
2020, from 40% at the end of 2019 (24). Despite this significant improvement, it remains 
by a large margin the highest ratio in the euro area, with a cash coverage ratio of 44.9%, 
slightly  lower  than  the  EU  average  of  47.4%.  The  four  systemic  banks  significantly 
increased  the  impairments  booked  in  their  first  quarter  results  of  2020,  as  they 
proceeded to reflect the expected deterioration in the macroeconomic outlook due to the 
pandemic. However, banks’ estimated provisions for 2020-2021 do not yet incorporate 
the more detailed aspects affecting the customers’ ability to repay their loans, as these 
will  only  become  evident  after  the  expiry  of  the  moratoria.  This  implies  a  potentially 
material  downside  risk  for  additional  credit  provisions  in  2021,  particularly  if  the 
baseline  scenario  of  a  V-shaped  recovery  does  not  materialise.  Going  forward,  the 
impact of the pandemic on asset quality could be exacerbated by (i) the large exposure 
of the banks’ performing loan book to some of the sectors most affected by the current 
containment measures, e.g. tourism and hospitality, shipping, transport and storage and 
commercial  real  estate  and  (ii)  the  potential  adverse  impact  of  the  moratoria  on  the 
payment culture.  

(22) Source: Bank of Greece, consolidated level. 
(23) The deconsolidation of the securitised NPL portfolio will take place in the second quarter of 2020. 
(24) Source: Bank of Greece, solo level.  

33 

                                                 
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Chapter 6 - Financial sector 

Graph 6.2:  Non-performing loans as a % of total customer loans (left) and changes in their stock 

in the first quarter of 2020 (right: million EUR) 

(1) NPEs: Non-performing exposures. 

Source: Bank of Greece. 

Following an initial freeze of the secondary non-performing loan market, some of 
the  previously  planned  transactions  have  been  successfully  finalised.  This  is 
evidenced by the conclusion of the first securitisation under the Hercules securitisation 
scheme (25) as well as two transactions outside it. Two more systemic banks are moving 
on  to  conclude  their  ‘hive  downs’ (26)  this  year,  as  well  as  all  other  preparations  to 
facilitate  their  planned  securitisations  under  the  Hercules  scheme,  with  an  aim  to 
conclude them by the first quarter of 2021.  

Nonetheless, the banks’ non-performing loans reduction strategies are affected and 
their  internal  capacity  to  viably  restructure  loans  remains  low.  Greek  systemic 
banks have made use of the flexibility awarded to them by the supervisory authority and 
will  submit  their  2020  revised  non-performing  loan  strategies  at  the  latest  by  March 
2021, in order to reflect the new status quo. Despite the large amount of non-performing 
loans under forbearance measures (€22.3 billion at the end of March 2020), few of these 
restructuring efforts prove sustainable, with 24% of long-term restructurings and 51.6% 
of  short-term  restructurings  becoming  non-performing  again,  only  a  quarter  after  the 
implementation  of  the  restructuring.  These  ratios  further  increase  to  48%  and  88% 
respectively,  after  four  quarters,  suggesting  that  the  banks’  internal  capacity  to  viably 
restructure loans remains low.  

The already weak profitability outlook for Greek banks will come under pressure 
by  an  increase  in  expected  credit  loss  provisions.  At  the  end  of  2019,  Greek  banks 

(25) The  transaction  involved  the  securitization  of  a  €7.5 billion  portfolio  consisting  mainly  of  non-
performing  exposures.  It  made  use  of  €2.4 billion  of  state  guarantees  out  of  the  total  €12 billion 
envelope  available  under  the  Hercules  scheme.  The  scheme,  which  is  open  and  voluntary  for  all 
banks, runs over an 18-month period from October 2019. Two other  systemic banks are  moving on 
with preparations to facilitate their planned securitizations under the scheme, with an aim to conclude 
them by the first quarter of 2021. 

(26) Under the hive-down process, the initial entity will transfer its banking business, with its assets and 
liabilities – including all deferred tax credits – to an operating company, the New Bank, which will be 
licensed  as  a  credit  institution  and  shall  be  an  100%  subsidiary  of  the  original  entity  (which  will 
become a holding company without a banking licence). 

34 

3540455055606570Dec 2014Dec 2015Dec 2016Dec 2017Dec 2018Dec 2019% NPL ratioConsumer LoansResidential LoansBusiness Loans68 5251 2801 24836204254191465626 46560 902 010 00020 00030 00040 00050 00060 00070 000   
 
                                                 
Commission Staff Working Document -  

Chapter 6 - Financial sector 

exhibited  one  of  the  lowest  return-on-equity  in  the  EU,  with  their  profitability 
underpinned by non-recurring trading gains and a cost-income ratio well below the EU 
average.  It  is  burdened  by  high  provisioning  and  the  lowest  commission  income  as  a 
ratio of total income among EU banks. At the same time, the large amounts of accrued 
interest  from  non-performing  loans,  can  be  difficult  to  collect  and  may  also  imply  a 
material  fall  in  net  interest  income  from  non-performing  loan  deleveraging.  In  this 
context,  with  the  onset  of  the  crisis,  the  four  systemic  banks  experienced  in  the  first 
quarter of 2020 a drop of 87% in pre-tax profits relative to the same period a year ago, 
mainly affected by exceptional provisioning and subdued operational profits net of one-
off trading gains (-7% relative to the same period last year).  

Table 6.1:  Main financial stability indicators 

(1) 
As 
(2) Annualised data. 

% 

of 

total 

loans. 

(3) HH: Households, NFC: Non-Financial Corporations. 

Source: European Central Bank - Consolidated Banking Data 2; own calculations. 

Low  profitability  coupled  with  the  cost  of  upcoming  securitisations  may  pose 
challenges  for  the  banks’  capital  position  in  the  near  future.  Banks’  average 
common  equity  tier  1  ratio  on  a  consolidated  basis  fell  from  15.9%  of  risk-weighted 
assets  at  the  end of 2019, to  14.6% after the  first  quarter of 2020, in  line with  capital 
requirements, mainly due to the implementation of prudential transitional rules applied 
in the first quarter of each year (27). Going forward, banks’ capital position is exposed in 
the medium-term to (i) the implementation of new rules on the treatment of own funds 
held  under  Pillar II  Guidance (28)  and  (ii)  the  further  phasing  out  of  transitional 
prudential  arrangements (29),  while  the  recently  adopted  Regulation  EU  2020/873 

(27) However, the impact in total  capital terms  was less pronounced (a reduction  from 17.0% to 16.2%) 

thanks to the two Tier II issuances that took place in early February. 

(28) From January 2021, banks' own funds held under Pillar II Guidance will no longer be eligible to meet 

any other regulatory requirement. 

(29) These transitional arrangements refer to the  phasing in of  the new International  Financial Reporting 
Standard 9 on impairments of financial assets and the implementation of new rules leading banks to 
more  quickly  write  down  non-performing  exposures,  according  to  Regulation  (EU)  2019/630 
amending  Regulation  (EU)  No  575/2013,  as  complemented  by  further  supervisory  guidance  by  the 
Single Supervisory Mechanism. In the medium-term, banks will also need to issue bail-in-able debt in 
order  to  meet  the  minimum  requirement  for  own  funds  and  eligible  liabilities  set  by  the  resolution 
authorities. 

35 

2014201520162017201820182018201820192019201920192020Q4Q4Q4Q4Q1Q2Q3Q4Q1Q2Q3Q4Q1Non-performing loans (1)39.746.846.345.045.444.943.541.641.639.637.835.534.4o/w foreign entities-------------o/w NFC & HH sectors41.849.550.449.449.248.447.346.345.643.842.340.640.0o/w NFC sector44.752.553.951.451.149.447.946.144.542.840.538.237.1o/w HH sector38.545.946.347.147.047.346.646.546.845.144.443.543.4Coverage ratio43.548.548.246.749.549.047.848.047.746.745.044.544.9Return on equity (2)-10.6-24.2-7.5-1.30.7-2.4-0.8-0.41.62.62.90.71.3Return on assets (2)-1.0-2.8-0.9-0.20.1-0.3-0.1-0.10.20.30.40.10.1Total capital ratio14.116.517.017.116.416.416.316.015.616.516.917.016.2CET 1 ratio13.816.316.917.015.815.815.715.314.915.615.915.914.6Tier 1 ratio13.816.316.917.015.815.815.715.314.915.615.915.914.6Loan to deposit ratio79.172.375.983.578.878.476.074.775.874.376.874.872.8 
   
 
 
                                                 
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Chapter 6 - Financial sector 

(“CRR  Quick  Fix”) (30)  will  bring  only  limited  relief  for  Greek  banks.  Upcoming 
securitisations aimed at scaling down non-performing loans in the banks’ balance sheets 
will  also  come  at  a  capital  cost.  At  the  same  time,  the  impact  of  the  pandemic  is 
expected to amplify these challenges in the near future, when EU banks stop benefiting 
from the flexibility temporarily offered by the regulators for all euro-area banks.  

The  sovereign-bank  nexus  has  increased  and  this  trend  may  continue  over  the 
coming months. The quality of banks’ capital remains low, due to the high amount of 
deferred  tax  credits (31)  representing  a  substantial  part  of  the  banks’  Common  Equity 
Tier  1  capital  (€15.5 billion  or  60.4%  as  of  March  2020).  This  share  risks  growing 
further  in  the  near  future,  as  banks’  overall  capital  will  have  to  bear  the  cost  of  the 
upcoming  securitisations  of  non-performing  loans.  This  could  lead  to  an  increasing 
sovereign-bank  nexus,  further  reinforced  by  a  recent  rise  in  the  banks’  Greek 
Government  bond  holdings  and  Treasury  bills (32),  as  well  as  retained  senior  notes  of 
the  securitisations  benefiting  from  the  guarantee  under  the  Hercules  asset  protection 
scheme.  

Data  up  to  July  2020  show  that  the  recovery  in  bank  credit  to  non-financial 
corporations has gained pace, due to both supply and demand conditions. Since the 
outbreak of the pandemic, the net flow of credit in Greece to non-financial corporations 
has increased significantly. As a result, in July 2020, the annual rate of growth in bank 
credit  to  non-financial  corporations  reached  a  solid  6.5%,  the  highest  value  attained 
since  mid-2009  (see  graph  6.3).  This  acceleration  continued  to  reflect  (i)  from  the 
demand  side,  the  firms’  high  liquidity  needs  during  the  lockdown  but  also  a  general 
preference  for  maintaining  high  liquidity  buffers  and  (ii)  from  the  supply  side,  the 
positive impact  of public measures, including those by the European Central  Bank, to 
support the provision of emergency liquidity by banks to the real economy, as well as 
the provision of public guarantees by the relevant scheme of the Hellenic Development 
Bank. The latter greatly supported the large net flow (above €1 billion) observed in July.  

Large  corporates  continue  to  drive  the  recovery  in  business  credit,  while  that  to 
small,  non-incorporated  firms  has  also  started  to  turn  rapidly  positive,  thus 
moderating  the  continued  contraction  of  bank  credit  to  households.  The  average 
gross flow of bank loans of fixed maturity towards both large corporates and small and 
medium-sized  companies  has  increased  substantially  during  January-July  2020 
compared to the previous year. This reflects both the efforts by the companies to build 
up liquidity buffers  and  the start  of disbursements of emergency support  measures.  In 
contrast, the annual rate of growth of loans to households remained negative in July (at -

(30) On  18 June  2020,  the  European  Parliament  approved  the  so-called  CRR  “quick  fix”  to  Regulation 
(EU)  575/2013  (Capital  Requirement  Regulation)  and  Regulation  2019/876  (Capital  Requirement 
Regulation 2) to mitigate the economic consequences of the coronavirus. The temporary measures are, 
inter alia, intended to enhance credit flows to companies and households, thereby supporting the EU’s 
economy. 

(31) Deferred tax credits may be converted into tax credits, i.e. irrevocable claims towards the Greek state, 
while  in  exchange  banks  would  need  to  issue  equity  in  favour  of  the  state,  thus  diluting  existing 
shareholders.  This  potential  dilution  of  banks’  shareholders  poses  a  further  complication  of  the 
framework, as it may discourage banks recognising losses on non-performing loans and is considered 
a disincentive for private investors to invest in banks’ equity. 

(32) Greek  banks’  domestic  government  bond  holdings  and  Treasury  bills  rose  by  €4.2 billion  (to 

€16.5 billion and €1.7 billion respectively) in the period from the end of 2019 to 24 June 2020. 

36 

                                                 
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Chapter 6 - Financial sector 

2.6%) but has recovered somewhat from the levels observed in previous quarters. The 
recovery  in  loans  to  households  since  May  2020  reflects  a  rapid  turn-around  in 
consumer credit and other lending, whose net flows became positive in June and July. 
The  turn-around  in  other  lending  was  almost  entirely  driven  by  lending  to  sole 
proprietors, the loans to which, as owners of non-incorporated businesses, are reported 
under  loans  to  households  instead  of  under  loans  to  non-financial  corporations.  By 
contrast, mortgage lending continued to contract, as it has been consistently the case in 
recent years (see graph 6.3).  

Graph 6.3:  Bank credit to households and non-financial corporations 

Source: Bank of Greece. 

Nominal  lending  rates  continued  their  downward  trend,  reaching  new  historical 
lows  in  May  for  non-financial  corporations  (see  graph  6.4).  The  average  nominal 
lending rate for non-financial corporations  in  the first  seven months  of 2020 has been 
3.3% compared to 3.9% in 2019, reflecting the very accommodative monetary policy, as 
well as the various targeted measures geared to support the flow of credit to households 
and firms. The same trend can also be observed for new loans without fixed maturity for 
small and medium-sized enterprises and new fixed maturity loans of small value (up to 
€250 000)  to  non-financial  corporations.  Regarding  the  nominal  rate  for  household 
credit, the decline observed in the first four months of 2020 was temporarily reversed in 
May,  possibly  reflecting  an  upward  revision  on  credit  risks,  reaching  its  highest  level 
(5.2%)  since  August  last  year,  before  falling  back  to  a  level  slightly  above  4.8%,  in 
June-July. 

37 

Jul 2020-2.7%Jul 20206.5%-6-4-2024682011201220132014201520162017201820192020%HouseholdsΝοn-financial corporationsJul 2020-2.9%Jul 2020-1.5%-7-6-5-4-3-2-102011201220132014201520162017201820192020%Housing loansConsumer loans  
 
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Chapter 6 - Financial sector 

Graph 6.4:  Bank interest rates on new loans to euro area residents (annual percentages %) 

Source: Bank of Greece. 

6.2.  FINANCIAL SECTOR POLICIES 

The authorities intend to adopt a major overhaul of the insolvency framework and 
targeted  amendments  to  the  existing  tools  for  the  resolution  of  non-performing 
loans,  which  are  very  welcome.  The  authorities  also  allowed  the  long-overdue 
expiry  of  the  Primary  Residence  Protection.  These  steps  are  well-timed,  as  the 
coronavirus  outbreak  implies  new  challenges  for  the  banks’  asset  quality  and  for  the 
accumulation  of  private  debt  in  the  economy  as  a  whole.  Therefore,  timely 
implementation  of  an  efficient  insolvency  framework  is  crucial.  Notwithstanding  the 
progress made, further reforms aiming in particular at improving the efficiency of the e-
auctions  framework,  would  support  the  normalisation  of  the  banking  sector  and  the 
financing  of  the  economy  during  the  recovery,  and  would  contribute  to  limiting  an 
increase  in  non-performing  loans.  The  actions  outlined  below  are  monitored  and 
assessed under the enhanced surveillance framework, as part of the continuous specific 
commitment  to  “continue  to  implement  reforms  aimed  at  restoring  the  health  of  the 
banking system, including resolution efforts for the non-performing loans”. 

Insolvency law reform 

The  unified  insolvency  framework  reform  is  a  major  step  forward,  inspired  by 
international best practices. The new insolvency code, following consultation with the 
European institutions and completion of the public consultation process, is expected to 
be  submitted  to  Parliament  shortly  and  will  enter  into  force  as  of  1 January  2021.  It 
integrates the corporate and personal insolvency regimes and transposes EU legislation 
on  preventive  restructuring  frameworks (33)  into  the  Greek  legal  order.  It  replaces  the 
hitherto existing mechanisms for facilitating debt restructuring schemes. 

(33) Directive  (EU)  2019/1023  of  the  European  Parliament  and  of  the  Council  of  20 June 2019  on 
preventive restructuring  frameworks, on discharge of debt and disqualifications, and on measures to 
increase the efficiency of procedures concerning restructuring, insolvency and discharge of debt, and 
amending Directive (EU) 2017/1132 (OJ L 172). 

38 

Jul 20203.2 %Jul 20204.8%012345678%Loans to non-financial corporationsLoans to households  
                                                 
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Chapter 6 - Financial sector 

The  Code  introduces  a  revised  framework  for  dealing  with  insolvency,  the 
collective satisfaction of creditors and the discharge of debts of any person, natural 
or  legal,  regardless  of  whether  they  pursue  a  business  activity.  It  implements  best 
practices to comprehensively prevent and address over-indebtedness in accordance with 
the requirements and recommendations of the Directive. Companies and entrepreneurs 
in financial difficulty will gain access to preventive restructuring frameworks enabling 
them to continue operating. The effectiveness of restructuring, insolvency and discharge 
proceedings  is  expected  to  be  increased  and  their  duration  shortened,  through  the 
simplification  of  procedural  requirements  and  the  creation  of  an  electronic  solvency 
register  that  will  serve  as  a  means  of  communication  of  the  court  and  insolvency 
officials  with  all  the  parties  involved  as  well  as  for  the  publication  of  the  relevant 
decisions.  

The overall aim is to accelerate the return of productive means to productive uses 
and faster  reimbursement  of  creditors,  through  the  sale  of  the bankruptcy  estate 
or parts thereof at market values, and also  to preserve viable businesses through 
the out-of-court settlement procedure or the resolution process. The former will be 
available to all types of debtors (legal  and natural persons, businesses and consumers) 
and aims to avoid the insolvency of very small and small enterprises; the latter will be 
addressed  to  larger  companies  facing  potential  insolvency  and  will  require  judicial 
ratification  of  the  respective  agreement  reached.  Facilitating  the  discharge  of 
entrepreneurs  will  prevent  their  exclusion  from  the  labour  market  and  offer  them  the 
opportunity to start anew, while the discharge of private debtors will enable them to re-
enter social and economic returns free of the burden of debts they cannot service.  

Work  on  the  requisite  secondary  legislation  is  ongoing,  ahead  of  the  envisaged 
entry into force of the new Insolvency Code on 1 January 2021. Given that the full 
implementation of the new code, upon its entry into force, will require the adoption of a 
significant amount of secondary legislation, work on the drafting of the relevant texts is 
underway;  said  texts  are  expected  to  be  shared  with  the  European  institutions  for 
consultation  ahead  of  finalisation  and  adoption.  As  for  the  IT  infrastructure  (e-
platform),  which  is  central  to  the  operation  of  several  proceedings  envisaged  by  the 
code,  the  relevant  work  stream  is  nearing  completion  in  order  for  the  platform  to  be 
operational for testing and training purposes by December. 

The  main  features  of  the  new  Insolvency  Code,  as  detailed  in  the  May  2020 
enhanced surveillance report (34), are the following: 

  Insolvency resolution proceedings are designed to operate on the basis of the size of 
the  bankruptcy  estate,  covering  all  kinds  of  business  ventures  as  well  as  personal 
insolvency. 

  Pre-bankruptcy  proceedings  are  available,  consisting  of  an  automated  out-of-court 
process and a pre-insolvency business recovery process; in the context of the former, 
vulnerable  debtors  (as  defined  by  the  housing  benefit  law  and  joint  ministerial 
decision),  who  have  a  loan  linked  to  their  primary  residence  and  have  suffered  a 
sudden loss of income, will be eligible for a temporary subsidy, intended to further 

(34) Enhanced Surveillance Report for Greece, May 2020, pp. 68-70. 

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Chapter 6 - Financial sector 

support  the  reduction  of  non-performing  loans  and  avoid  the  accumulation  of  new 
ones.  To  address  moral  hazard  concerns,  the  subsidy  will  be  available  to  i) 
performing  vulnerable  debtors  who  do  not  apply  for  pre-insolvency  out-of-court 
restructuring  and  ii)  those  performing  or  non-performing  vulnerable  debtors,  who 
apply for and undergo a viable restructuring of all their debts, with the exception of 
those non-performing debtors with loans which have been denounced for more than 
one  year.  The  participation  of  creditors  is  voluntary;  should  a  restructuring 
agreement  on  all  debt  not  be  reached  within  two  months,  the  application  will  be 
considered rejected. 

  A special sale-and-leaseback regime allowing vulnerable distressed debtors to remain 
in  their  primary  residence  as  tenants  will  be  instituted,  which  will  be  implemented 
through  a  private-sector  entity,  to  be  selected  by  the  Greek  authorities  through  a 
public tender procedure. However, if the tender procedure is unsuccessful, this will 
not impede the unhindered implementation of the bankruptcy proceedings. Provided 
the eligibility criteria are fulfilled, the entity will buy the primary residence at a price 
determined by an appraiser appointed by it. Once the residence is purchased, it will 
be  leased  back  to  the  debtor.  Several  aspects  of  the  sale-and-leaseback  regime  are 
still  subject  to  the  adoption  of  secondary  legislation  that  is  expected  to  be  issued, 
following consultation with the European institutions, during the coming weeks. The 
regime is restricted to the protection of vulnerable debtors, who will also be eligible 
to receive the already available housing subsidy to facilitate the payment of the rent. 
The private sector agency may benefit from a state guarantee to support its access to 
funding,  if  deemed  necessary.  Details  on  a  possible  form  of  support  remain  to  be 
determined. 

Overall,  the  new  draft  code  is  highly  satisfactory  and  contains  all  essential 
elements  of  a  modern  insolvency  framework;  however,  several  concerns  remain 
that will need to be addressed  mainly in the relevant secondary legislation. These 
include ensuring the viability of the out-of-court restructuring agreements. A carefully 
considered  balance  should  be  maintained  for  the  subsidisation  of  out-of-court 
restructuring  of  debt  for  natural  persons,  so  as  not  to  incentivise  defaults  on  the  one 
hand  and  avoid  an  adverse  effect  on  new  lending  on  the  other  hand.  Finally,  the  two 
schemes for the protection of primary residence, namely the subsidisation of borrowers 
at  the  pre-insolvency  stage  and  the  introduction  of  the  sale  and  lease  back  scheme, 
should operate in consistence with the objective of fostering a stronger payment culture. 
Therefore, a regular assessment  of the impact  of the changes after the adoption of the 
law will be key, also for monitoring the fiscal impact.  

The authorities granted no further extension to the Primary Residence Protection 
scheme  and  the  Out  of  Court  Workout  scheme,  given  the  set  up  of  alternative 
social protection schemes for vulnerable debtors. As a result, the regimes in question 
duly  expired  on  31 July  2020  and  30 April  2020  respectively.  Only  applications  that 
were  duly  submitted  up  to  the  expiry  of  the  regimes  are  being  processed  by  the 
authorities, covering loans or debts to the state and/or social security agencies that were 
in arrears up to 31 December 2018.  

In  order  to  alleviate  the  impact  on  social  groups  financially  affected  by  the 
coronavirus  pandemic,  the  authorities  adopted  a  temporary  instalment  subsidy 

40 

Commission Staff Working Document -  

Chapter 6 - Financial sector 

scheme  for  mortgage,  consumer  and  business  loans  secured  by  a  primary 
residence (35).  The  mechanism  is  distinct  from  the  above-described  new  sale-and-
leaseback scheme under the insolvency code, covers loans secured by primary residence 
and will operate for a limited period, up to nine months from the date of approval of the 
relevant request, which may be filed electronically until the end of September 2020. The 
mechanism is available to eligible physical persons (consumers, professionals and small 
business  owners)  affected  by  the  coronavirus  pandemic  according  to  specific  criteria 
and  covers  performing  loans,  forborne  non-performing  exposures  and  non-performing 
exposures (including denounced loans). Non-performing and denounced loans will need 
to be restructured in agreement with the credit institution, where the relevant offer will 
be  extended  by  the  banks  on  a  discretionary  basis.  The  subsidy  level,  which  is 
differentiated according to the classification of the exposure, will progressively decrease 
over  the  payment  period,  to  ensure  that  only  viable  loans  are  restructured  and  to 
mitigate the negative impact on payment discipline. Given the extended perimeter of the 
loans eligible for the scheme, and in order to ensure compliance with obligations under 
the restructuring agreement, the law foresees an observation period post-completion of 
the  state  subsidy  payments  (whose  length  varies  according  to  the  classification  of  the 
exposure) and a subsidy clawback. Until 9 September 2020, 125 590 applications have 
been initiated in the platform, of which 66 850 have been submitted, while only 1.3% of 
those have been considered so far as non-eligible under the scheme. 

Clearing the backlog of household insolvency cases 

The authorities intend to adopt measures, most notably the rescheduling of distant 
hearings  through  an  electronic  platform  and  the  introduction  of  procedural 
simplifications,  that  are  aimed  at  decisively  accelerating  the  clearance  of  the 
household  insolvency  backlog,  which  has  increased  further  as  a  result  of  the 
suspension of court proceedings during the pandemic. Following the completion of 
the public consultation process, the measures in question should be adopted shortly and 
are expected to palliate a number of observed procedural inefficiencies, by introducing 
strict  deadlines  to  various  procedural  steps  or  actions,  streamlining  the  conduct  of  the 
proceedings and making use of IT to facilitate notifications and the filing of documents.  

The main features of the measures are the following: 

  The  mandatory  rescheduling  to  near  dates,  by  electronic  means,  of  cases  with  a 
hearing date beyond 1 January 2021. This is a necessary measure towards achieving 
the  timely  elimination  of  the  backlog,  given  that  a  significant  number  of  cases  are 
scheduled to  be heard on dates extending to  several  years ahead. The cases will be 
rescheduled  progressively,  on  a  seniority  basis.  To  avoid  procrastination  as  part  of 
strategic default tactics, failure on the part of the petitioner to ask for a rescheduling 
within the term set by the law will be considered as if they had never been filed. Any 
suspensions of enforcement proceedings granted will be automatically revoked. 

  The  electronic  service  of  documents  to  institutional  creditors,  the  state  and  social 

security entities. 

(35) Law 4714/2020 (OJ A-148/31 July 2020), articles 71-83. 

41 

                                                 
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Chapter 6 - Financial sector 

  The use of mediation as a tool for resolving cases. 

  The  development  of  an  e-platform  for  the  rescheduling  of  distant  hearings.  The 
authorities  are  contemplating  enhancing  the  functionality  of  the  electronic  platform 
by  adding  modules  for  e-notification  to  all  parties  to  the  proceedings  who  have 
electronic  addresses,  so  as  to  minimise  time  and  expense;  also  for  uploading  and 
distribution  of  the  operative  part  of  court  decisions.  The  platform  should  be  fully 
operational by the end of September. 

Due to the coronavirus outbreak, which entailed an extended period of closure of 
the courts throughout the country prior to summer recess, no data on the evolution 
of  the  backlog  in  the  second  quarter  of  2020  were  submitted  by  the  authorities. 
Once  normal  operation  of  courthouses  resumes  in  mid-September  2020  and  given  the 
recent  creation  of  a  Justice  Statistics  Unit  in  the  Ministry  of  Justice,  the  punctual 
availability  of  standardized,  reliable  and  granular  data,  covering  the  entire  territory 
should  henceforth  be  facilitated.  The  use,  by  institutional  creditors,  of  the  electronic 
platform for eligibility control and for filtering out strategic defaulters is also expected 
to contribute to the efficient processing of the backlog. 

E-auctions 

The conduct of e-auctions had been halted as a result of the closure of courts and 
notarial offices due to the coronavirus pandemic. In view of their resuming as from 
1  September  2020,  the  authorities  are  expected  to  adopt  a  number  of  measures 
aiming  at  enhancing  the  functionality  and  user-friendliness  of  the  e-auctions 
platform  and  facilitating  the  relevant  processes.  These  measures  were  submitted  to 
public  consultation  and  should  be  adopted  in  October  2020.  Additional  measures, 
including  a  revision  of  the  mechanism  for  adjusting  the  reserve  price  and  the 
interoperability  of  the  e-auctions  platform  with  other  state  databases,  are  part  of  the 
project  for  the  revision  the  Code  of  Civil  Procedure  (see  below).  The  intermediate 
progress report on the work of the law-drafting committee envisages, inter alia, changes 
to the price correction process, ensuring that the value of the seized property is provided 
by  a  certified  appraiser.  Additionally,  an  automatic  price  reduction  of  20%  in  each  of 
the two subsequent auctions is contemplated, in cases where if the initial one failed due 
to the lack of bidders. 

 The main features of the envisaged measures are the following: 

  The  obligation  of  bailiffs  to  file  with  the  notary  officiating  as  an  auction  official  a 
copy  of  the  valuation  report  by  the  certified  expert  as  well  as  photographs  of  the 
property,  both  digitally  and  in  print,  to  be  uploaded  to  the  e-auctions  website, 
effective  as  of  1 October  2020.  This  measure  will  enhance  the  usability  and  user-
friendliness  by  enabling  prospective  purchasers  to  consult  the  relevant  valuation 
documentation  online  as  well  as  to  acquire  visual  information  on  the  property’s 
layout and state, in addition to the description contained in the titles of ownership.  

  The  amendment  of  the  technical  specifications  of  the  e-auctions  platform  to 
accommodate  the  extra  storage  space  requirements  for  the  addition  of  above-
described material to the platform, followed by the publication, by the Athens notary 

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Chapter 6 - Financial sector 

association,  of  an  explanatory  note  to  all  notaries  acting  as  e-auction  officials, 
regarding the new requirements. 

  The publication, by of a timeline for the implementation of accrued interoperability 
of  the  e-auction  website  with  other  government  and  non-government  operating 
frameworks (e.g. cadastre). 

The authorities have expressed their intention to suspend auctions of primary residences 
of vulnerable debtors (i.e. debtors who fulfil the criteria of the housing benefit) until the 
end of the year in view of the entry into force of the insolvency legislation and the entry 
into force of associated social policy measures in January 2021. 

Clearing the backlog of called state guarantees 

The  authorities  are  taking  all  necessary  actions  towards  fully  offsetting  any 
coronavirus related delays in clearing called state guarantees, while committing to 
further  frontload  the  overall  processing  and  payment  schedule.  The  examination 
and expected payments of claims for the second quarter of 2020 fell short of the original 
targets,  mostly  due  to  limits  on  the  number  of  staff  working  on  site  during  the 
containment period. In response, the authorities have upgraded the targets for the second 
half  of  2020,  in  principle  more  than  fully  counteracting  the  delay  by  increasing  the 
payment  target  for  2020  as  a  whole  by  33%.  At  the  same  time,  they  have  prepared  a 
revised  processing  and  payment  plan,  which  envisages  an  acceleration  of  the 
examination period of pending claims by six months for natural persons’ claims and by 
three  months  for  corporate  loans.  Under  this  revised  plan,  full  payment  of  all  called 
guarantees is expected to occur by mid-2023 for natural persons’ claims and by the end 
of the third quarter of 2024 for corporate loans. The longer deadline for corporate loans 
reflects additional documentation needs or allow for settling ongoing legal disputes. To 
achieve these targets, the authorities have upgraded their plan to enhance the workforce 
dealing with called state guarantees, by envisaging two additional temporary and seven 
permanent employees. Reducing further the delays between the call of a guarantee and 
its final processing, and completing the clearance of the existing backlog in the shortest 
time possible, would improve the effectiveness of the instrument. 

The  authorities  are  proceeding  as  planned  with  all  the  necessary  structural 
changes  in  the  clearance  process  of  the,  still  considerable,  backlog  of  called 
guarantees.  The  new  ministerial  decision  on  the  electronic  file  repository,  addressing 
previous shortcomings, was issued and entered into effect on 5 June 2020. All necessary 
technical  adjustments  have  taken  place.  In  the  same  vein,  the  system  ensuring 
interoperability  with  local  tax  offices  is  close  to  entering  its  testing  phase  before  it 
becomes  fully  operational  in  October,  while  relocation  of  the  State  Guarantees  and 
Capital Movement Directorate is scheduled to take place in October 2020, in line with 
the  original  timeline.  Cooperation  with  credit  institutions  is  ongoing  and  they  are 
expected  to  submit  all  new  claims  and  supporting  documents  electronically  and  to 
upload in the electronic file repository all the supporting documents for the old claims 
concerning natural persons’ loans by the fourth quarter of 2020. 

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Other initiatives 

Work on the adoption of targeted amendments to the Code of Civil Procedure is 
ongoing at the level of the law-drafting committee, following the submission of the 
conclusions of the three-year implementation review. Submission of draft legislation 
to  the  authorities  is  due  by  end-January  2021,  in  view  of  the  adoption  of  the  revised 
code  by  end-February  2021;  the  entry  into  force  is  projected  for  the  beginning  of  the 
next judicial year, in September 2021. Pending the submission of the draft legislation, 
the authorities shared with the institutions a partial intermediate progress report setting 
forth the main content of the enforcement section of the code.  

A targeted adjustment of the primary legislation on deferred tax credits to ensure 
operational  effectiveness  has  been  submitted  to  Parliament  and  is  expected  to  be 
adopted  shortly.  The  aim  of  the  legal  amendment  is  to  safeguard  the  loss-absorbing 
capacity  of  the  banks’  capital  in  all  cases.  Further  technical  and  procedural  aspects 
related  to  the  process  of  deferred  tax  credits’  use,  particularly  in  resolution,  will  be 
clarified via secondary legislation when appropriate, including on the possibility of sale 
of the state’s right to acquire a credit institution’s shares upon conversion to existing or 
new private shareholders. 

6.3.  HELLENIC FINANCIAL STABILITY FUND (HFSF) 

The Fund intensified its efforts to support the systemic banks in meeting their non-
performing-loan  reduction  and  business  enhancement  goals  in  the  current, 
pandemic-stricken environment. Following the proposal by the Fund to the Ministry 
of  Finance  to  amend  its  governing  law  in  order  to  protect  the  ownership  rights  of  the 
Fund / Greek state in case of hive-downs, the law was amended in June 2020. The Fund 
continued an ongoing steering dialogue with one of the banks, in order to shape a new 
transformational plan for the post-coronavirus era. In addition, the Fund is revising its 
shareholders’  and  business  strategy  expectations  for  two  of  the  four  systemic  banks, 
taking  into  account  the  impact  of  the  pandemic.  Furthermore,  the  Fund  concluded  the 
evaluation  and  closed  the  recommendations  related  to  Board/Bank  Governance  of  its 
second  governance  review  and  plans  to  launch  the  third  review  in  the  coming  weeks. 
The divestment  strategy  of the Fund still needs to  be finalised, including  the potential 
involvement  of  the  authorities  in  the  final  stage  of  the  divestment  and  the  legal 
protection  for  the  Fund’s  governing  bodies  and  staff.  Preserving  the  Fund’s 
independence  remains  a  cornerstone  in  the  process  toward  restoring  the  health  of  the 
banking sector.  

44 

 
7. 

LABOUR AND PRODUCT MARKETS 

7.1.  LABOUR MARKET 

The sudden plunge in economic activities following the coronavirus outbreak has 
not led to a sharp increase in unemployment, but rather to a ‘freeze’ of the labour 
market.  The  most  recent  data  on  labour  contract  registrations  indicate  a  sharp  fall  in 
both the number of new hirings and job separations over the period March-July 2020, 
with the former exceeding the latter and thus leading to a decline in total employment. 
The  limited  extent  of  job  destruction  can  be  explained  by  the  nature  of  the  shock 
(external,  and  supposedly  transitory)  and  by  the  effect  of  the  emergency  measures 
adopted to support businesses and protect jobs. The fall in employment has so far been 
accompanied  by  an  increase  in  inactivity  more  than  an  increase  in  unemployment  –  a 
common pattern observed across EU Member States that implemented strict lockdown 
measures.  

After a first set of emergency measures in March-April, the authorities introduced 
in  June  2020  a  new  temporary  short-time  work  scheme  (SYNERGASIA), 
providing  flexibility  to  companies  to  adjust  working  hours  and  compensation  to 
workers for the hours not worked. This scheme is expected to play an important role 
in allowing the labour market to adjust to the shock caused by coronavirus outbreak. It 
entered  into  force  on  15 June  2020  covering  all  sectors  for  an  initial  duration  of  four 
months, and is expected to reach 394 000 beneficiaries. Its  costs, estimated initially at 
€440 million,  are  eligible  for  financing  under  the  new  European  instrument  for 
temporary  support  to  mitigate  unemployment  risks  in  an  emergency  (SURE).  The 
Commission  will  allocate  to  Greece  €2.7 billion  of  financial  assistance  under  this 
instrument,  to  support  this  and  other  measures  protecting  the  employees  and  the  self-
employed. In view of a low initial take-up (36), the design of the scheme was amended 
in  July, increasing the share of social  security contributions  covered by  the state from 
60%  to  100%.  The  duration  of  scheme  has  also  been  extended  by  2  months,  until 
December 2020.  

In light of the coronavirus pandemic, the authorities decided in agreement with the 
social  partners  to  postpone  the  annual  update  of  the  statutory  minimum  wage, 
from June 2020 to January 2021. The coronavirus outbreak created high uncertainty 
and  directly  affected  the  timeline  of  the  consultation  process  for  the  revision  of  the 
statutory minimum  wage envisaged in  the legal  framework.  All  the actors involved in 
the  process  had  explicitly  requested  the  government  to  suspend  the  procedure, 
postponing  the  start  of  the  consultation  process  to  mid-September,  which  implies  a 
revision of the minimum wage level would take place in January 2021. 

(36) In  July,  some  5 500  companies  and  48 500  employees  benefited  from  the  scheme  (for  a  monthly 
expenditure  of  €11.2 million),  corresponding  to  a  coverage  rate  of  around  5%.  The  numbers  for 
August  (4 900  firms  and  41 200  beneficiary  employees)  show  a  decline  rather  than  an  increase  in 
take-up, but this also coincides  with a  resumption of economic activities at the peak of the touristic 
season. 

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Chapter 7 - Labour and product markets 

legislation  are  being  reviewed  and  modernised.  These 

In the context of the process of labour law codification, some aspects of the existing 
labour 
the 
establishment  of  a  new  framework  regulating  new  forms  of  work  (such  as  platform 
work, sharing economy), and changes to the role of the Labour Inspections Directorate 
(SEPE),  transferring  its  conciliation  competencies  to  the  Mediation  and  Arbitration 
Board (OMED), thereby disentangling its inspection and conciliation roles in line with 
the recommendations of the International Labour Office. Labour legislation is expected 
to be submitted to Parliament in October 2020 followed by its codification in November 
2020 (see section 9.1). 

include 

Education 

The authorities continue to pursue their comprehensive education policy plans, in 
line with the government’s growth strategy, with a public school reform adopted in 
June  2020  and  substantial  progress  made  on  vocational  education  and  learning. 
The bill for Upgrading Public Schools (June 2020, L.4692/2020) is targeted towards the 
cultivation  of  soft  skills,  digital 
the 
reinforcement  of  model  and  experimental  schools,  as  well  as  the  evaluation  of  school 
units. The comprehensive vocational education and training reform, which is currently 
being  developed,  aims  at  enhancing  the  quality  of  education  offered,  increasing  the 
percentage  of  students  choosing  this  path  and  better  linking  vocational  education  and 
lifelong learning with labour market needs. 

literacy  and  foreign 

language 

learning, 

Since the last report, there has been substantial progress  on the preparation of a 
vocational education and training reform in consultation with social partners and 
in collaboration with the Ministry of Labour notably on the market diagnostic. The 
authorities intend to table the bill in Parliament in October 2020. The bill addresses the 
following  issues:  a)  improving  the  quality  of  the  provided  vocational  education;  b) 
increasing  its  attractiveness;  c)  increasing  the  numbers  of  pupils  choosing  vocational 
training and the number of apprenticeships; d) facilitating the re-integration of students 
that  follow  the  professional  education  path  the  formal  education  and  e)  upgrade  the 
public professional schools (IEK) and lifelong learning. 

Key  features  of  the  reform  include  joint  strategic  planning  for  vocational 
education,  vocational  training  and  lifelong  learning.  The  reform  aims  at  removing 
overlaps  and  directly  linking  vocational  education,  training  and  lifelong  learning  with 
the labour market,  also  through  a more effective involvement of the social  partners in 
their design. Technical  support  will be provided  by the European Commission  for the 
development  of  social  partnerships  in  vocational  education  and  training.  Model 
professional  lyceums  will  be  created;  new  curricula  are  being  prepared  and  labour 
market diagnostics is being put in place in cooperation with the Ministry of Labour. The 
plan  foresees  upgrading  of  the  public  professional  schools.  An  important  issue  is  also 
the accreditation and quality control of the institutes that provide continuous education 
(KEK).  The  plan  foresees  the  creation  of  a  new  category  of  professional  schools 
providing vocational training at level 3 of the European Qualifications Framework for 
students attending compulsory education. 

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Chapter 7 - Labour and product markets 

Finally,  the  reform  also  improves  the  framework  for  apprenticeships.  Businesses 
will be able to choose the candidates and will benefit from public support based on the 
number of hours of work provided. 

7.2.  PRODUCT MARKETS AND COMPETITIVENESS 

The  authorities  continue  working  on  major  initiatives  improving  economic 
framework conditions, with a view to enhancing competitiveness and underpinning 
economic  recovery  following  the  coronavirus  outbreak.  To  this  end,  they  aim  to 
finalise  the  new  growth  strategy  shortly,  introducing  reform  measures  in  key  policy 
areas to boost private sector productivity and achieve sustainable growth. On the digital 
front,  work  on  simplifying  and  digitalising  electronic  transactions  for  businesses  and 
improving  the  digital  performance  of  the  economy  as  a  whole  continues  (see  section 
9.1).  Advances  in  specific  commitments  in  relation  to  the  investment  licensing 
framework,  namely  the  abolition  of  the  obsolete  nuisance  classification  system  which 
was  completed  significantly  earlier  than  the  specific  mid-2021  commitment  deadline, 
are  expected  to  materially  ease  the  licensing  burden  for  the  industrial  sector.  What  is 
more, the pursuit of further measures to improve other aspects of doing business by end-
2021  are  expected  to  further  contribute  to  the  creation  of  a  simplified  and  predictable 
framework for business activity and the development of investment projects. 

Investment licensing 

The investment licensing reform is steadily progressing despite some delays, with a 
widened  scope  of  ambition  and  longer  implementation  timelines  in  certain  areas. 
Continued  technical  support  through  the  European  Commission  and  delivered  by  the 
World  Bank  is  provided  in  all  remaining  areas.  This  comprehensive  reform  is 
particularly pertinent in supporting Greece’s efforts for a sustainable recovery.  

  The  full  deployment  of  the  relevant  IT  system  to  support  the  investment  licensing 
framework,  an  end-2019  specific  commitment,  is  delayed  for  reasons  outside  the 
authorities’  control.  The  successive  complications  in  the  tendering  process  for  the 
procurement  of  this  system  due  to  the  submission  of  an  appeal  against  the  award 
decision  were  recently  resolved.  Whilst  a  new  appeal  before 
the  Athens 
Administrative Court of Appeal cannot be excluded, the authorities expect to sign the 
contract shortly. 

  The  implementation  of  the  inspections  framework  law,  a  mid-2020  specific 
commitment,  steadily  progresses  with  respect  to  the  agreed  priority  areas  of  food 
safety, environmental protection and product safety, even though some work remains 
to  be  completed.  The  authorities  committed  to  extend  the  implementation  of  the 
framework  to  four  remaining  domains  by  end-2021.  In  relation  to  food  safety,  the 
authorities started deploying most tools. On environmental protection they finalised 
the  inspection  checklists,  and  aim  to  develop  the  risk  based  methodology  and 
complain management system shortly. On product safety, proposals on a number of 
checklists, the risk based methodology, and the complaint management system were 
delivered,  and  are  expected  to  be  finalised  shortly.  What  remains  pending  is  the 
enforcement management model and the amendment of the sanctions system in the 
said  three  domains,  once  all  tools  are  finalised  and  applied  by  inspectors.  The 

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Chapter 7 - Labour and product markets 

European institutions encouraged the authorities to develop a timeline for completing 
this work, including the adoption of all necessary enabling legislation, by the time of 
the  next  report,  in  order  to  fully  operationalise  the  inspections  framework  with 
respect  to  these  priority  domains.  What  is  more,  with  a  view  to  implementing  a 
comprehensive  reform,  the  authorities  committed  to  delivering  the  full  roll-out  of 
inspection  tools  across  the  remaining  domains  by  end-2021,  namely  on  consumer 
protection  and  safety  and  health  of  workers  by  March  2021,  and  public  health  and 
safety  of  infrastructures  and  construction  by  end-2021.  The  full  deployment  of  the 
inspection framework is expected to reduce the necessity for ex-ante controls without 
compromising  health  and  safety  standards.  The  authorities  also  adopted 
provisions (37) to define the roles and responsibility of inspection bodies for product 
safety  and  consumer  protection.  Corresponding  legislation  on  food  safety  and 
environmental protection is still pending. Clarifying the roles of inspection bodies in 
all domains is key so as to avoid overlaps and gaps. 

  The simplification of the investment licencing procedures in the remaining sectors, a 
mid-2020  specific  commitment,  is  progressing,  albeit  with  some  delays.  The 
authorities  adopted  primary  legislation  for  the  simplification  of  the  primary 
production  sector (38),  whilst  secondary  legislation  on  this  area  is  expected  shortly. 
With respect to most of the remaining sectors (39), the authorities delivered proposals 
for simplification, and are advancing with the drafting of primary legislation, which 
is  expected  to  be  adopted  shortly.  The  European  institutions  encouraged  the 
authorities, by the time of the next report, to develop a clear timeline for the adoption 
of  all  necessary  secondary  legislation  on  these  sectors,  as  well  as  for  the 
simplification of a few remaining activities not covered in the above context, so as to 
ensure full completion of this reform component. 

  The authorities successfully completed the commitment to revise/abolish the nuisance 
classification,  well  ahead  of  the  mid-2021  specific  commitment  deadline.  The 
authorities committed to proceed faster on this front already in the Development Law 
of  October  2019.  The  relevant  Joint  Ministerial  Decision  to  abolish  the  nuisance 
classification  and  categorise  economic  activities  according  to  their  environmental 
classification  was  issued  on  9  September  2020  (40),  on  the  basis  of  the 
recommendations of the technical advisor and key social partners. 

The  implementation  of  key  business  environment  reforms  initiated  under  the 
financial assistance programmes, which is a general commitment, continues, albeit 
with some delays in certain areas due to the coronavirus outbreak. Work continues 
on  setting-up  the  framework  for  the  certification  of  external  environmental  assessors, 
which  has  been  pending  since  the  European  Stability  Mechanism  programme,  and  for 
the  certification  of  external  inspectors,  however  the  adoption  of  necessary  secondary 
legislation is still outstanding since spring 2020. Further, the authorities are reviewing 

(37) Law 4712 (OJ A 146/29.07.2020). 
(38) Law 4711 (OJ A 145/29.07.2020). 
(39) Namely transport and transport-related activities (sale, repair and maintenance of vehicles), education 
(post-secondary  education,  vocational  training,  life-long  learning,  language  centres),  social  welfare, 
physical well-being, rent of leisure and sport equipment. 

(40) FEK 3833/09.09.2020. 

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Chapter 7 - Labour and product markets 

provisions legislated by the previous administration in the area of thematic tourism (41) 
to  identify  and  address  any  potential  deviations  with  the  principles  of  the  investment 
licensing  reform,  in  addition  to  secondary  legislation  on  measures  to  control  the  milk 
market (42)  with  a  view  to  streamlining  the  administrative  burden  on  producers  and 
buyers of milk. The amendment of the abovementioned legal texts is expected shortly. 
Enhanced  coordination  and  monitoring,  in  addition  to  actions  promoting  greater 
visibility of the reform across government stakeholders, would support the effectiveness 
of the investment licencing reform. 

Economic diplomacy  

A  new  strategy  for  promoting  Greece’s  extroversion  is  about  to  be  published, 
which is expected to strengthen the country’s export potential and facilitate inward 
foreign  direct  investment.  The  new  strategy  aims  at  effectively  combining  direct 
policy delivery with better coordination of relevant institutions and improved outreach 
to  stakeholders,  in  addition  to  identifying  priority  sectors  and  key  markets  for  the 
development of more targeted export strategies. To steer the implementation of the trade 
policy,  an  inter-ministerial  coordination  committee  has  been  set  up,  albeit  with  some 
delay.  However,  full  and  effective  implementation  of  this  strategy  hinges  on  the 
adoption  of  legislation  concerning  the  mandate  and  responsibilities  of  the  Ministry  of 
Foreign Affairs, and on the setting up of intergovernmental working groups at technical 
level on trade facilitation. Further, the establishment of other coordination committees, 
for  example  to  coordinate  policies  with  regard  to  important  sectors,  and  also  for 
facilitating foreign direct investment, would be useful to this end. In addition, budgetary 
constraints make operationalisation of the strategy objectives more difficult. On the IT 
front,  following  the  completion  of  the  tender  specifications  for  the  integrated  Single 
Window system for imports and exports, the launch of the tender has been postponed to 
end-September due to the pandemic.  

Doing business 

The authorities are gradually progressing with additional measures to further ease 
doing  business,  inter  alia,  with  technical  support  provided  by  the  European 
Commission  and  delivered  by  the  World  Bank.  The  authorities  made  the  registration 
through  the  electronic  one-stop  shop  mandatory  for  private  companies  (IKE)  except 
when  notarial  deeds  are  required.  Moreover,  to  improve  the  framework  for  the 
protection  of  minority  investors  that  applies  to  listed  companies,  the  authorities 
strengthened the policy framework for selecting and evaluating the suitability of Board 
Members  and  introduced  a  rule  that  the  Chair  of  the  Board  cannot  be  an  executive 
member  (in  the  opposite  case,  the  deputy  Chair  should  not  be  an  executive  member). 
The authorities also strengthened disclosure requirements for the candidates against the 
General  Assembly,  inter  alia  regarding  other  positions  they  may  hold  in  other 
companies.  Work  continues,  among  others,  with  the  support  of  the  next  inputs  of 
technical  assistance  on  the  areas  of  protecting  minority  investors,  enforcing  contracts 
and  contracting  with  the  government,  which  are  expected  to  be  delivered  shortly.  To 

(41) Law 4582/2018 (OJ Α 208/11.12.2018). 
(42) Joint  Ministerial  Decision  issued  by  the  Ministry  of  Finance  and  the  Ministry  of  Agricultural 

Development and Food on 21 March 2019. 

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Chapter 7 - Labour and product markets 

this  end,  the  design  of  broader  set  of  interventions,  capitalising  on  advances  on  the 
digital front such as the introduction of digital identity, would be particularly useful. 

Cadastre 

The  coronavirus  outbreak  has  affected  the  cadastre  project  and  slippages  of  the 
recently updated roadmap for its completion have occurred. The appointment of the 
three  Deputy  General  Managers  is  expected  to  be  completed  by  October  2020,  after 
several delays. The preparation of the Corporate Strategy – envisaged for June 2020 – is 
progressing and will be finalised in October 2020. The technical specifications for the 
archive digitisation have been completed and Terms of Reference for the procurement 
have been drafted. The tender is expected to be launched before the end of 2020. The 
purpose  of  the  project  is  to  design,  establish,  populate  and  operate  a  new  centralised 
digital  archive  that  will  replace  the  existing  paper-based  archives  located  in  the 
mortgage registry offices. 

The  commitment  to  the  Eurogroup  of  June  2018  specifies  that  Greece  will  fully 
establish  the  cadastral  agency  and  complete  45%  of  cadastral  mapping  by  mid-
2020.  As  of  today,  the  collection  of  rights  has  been  completed  for  82%  of  the 
country and the cadastral mapping has been completed for the 33% of the rights. 
By October 2020, the cadastral mapping completion will reach 35%. The authorities are 
preparing legislation to impose penalties to citizens who fail to declare their properties 
within  the  applicable  timeframe  in  order  to  accelerate  the  collection  of  the  remaining 
rights. The award of the final five cadastral mapping contracts, which was delayed due 
to judicial proceedings, is progressing. The contract for Rethymnon has been signed in 
June  2020.  The  contract  for  Cyclades  has  passed  all  stages  and  reached  the  signature 
stage. For the remaining two contracts, there was a decision of the Management Board 
on 6 August 2020 and are expected to be signed after the regular controls. The last one 
concerning Thesprotia and Kerkyra will not be signed before end December. 

Staffing of the Hellenic Cadastre proceeds according to plan. The recruitment of 49 
staff of the migration team for the transition from the mortgage offices to the cadastral 
offices has been approved and the call is underway. The weakness in the supervision of 
the  cadastral  mapping  contracts  due  to  lack  of  adequate  number  of  lawyers  has  been 
solved. Provisions for the recruitment of long-term staff have been included in the bill 
of the Ministry of Environment adopted on 5 May 2020. Therefore, the staffing of the 
Hellenic Cadastre is now adequate. 

The public presentation of all remaining forest maps, scheduled to be completed in 
June 2020, has been delayed following adoption of legislation to address problems 
related to building concentrations and other land uses in presumed forestland. This 
will impact on the commitment to ratify all forest maps before mid-2021, which could 
be  postponed  to  end  2021.  The  European  institutions  encouraged  the  authorities  to 
proceed  with  the  uploading  and  partial  ratification  of  the  maps  to  cover  the  whole  of 
Greece (already 53% is covered) and continue in parallel to address problematic areas, 
correct errors and complete the maps gradually. The authorities confirmed that for those 
areas that will not be the subject of changes and where no objections by citizens were 
raised,  they  will  not  upload  again  the  maps  for  public  consultation,  thereby  not 
reversing  the  partial  or  complete  ratification  of  the  forest  maps  for  those  areas.  The 

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Chapter 7 - Labour and product markets 

delays  in  the  uploading  of  the  maps  will  have  an  impact  on  the  completion  of  the 
cadastral mapping as a whole. The authorities have committed to upload all remaining 
maps  by  December  2020.  The  cadastral  mapping  is  planned  to  be  completed  by  May 
2022 and this could be delayed by as much as eight months. 

Finally,  the  coronavirus  outbreak  is  delaying  the  establishment  of  17  cadastral 
offices and branches. As of end of August only 1 out of 17 cadastral offices and 11 out 
of  75  cadastral  branches  had  been  established.  The  establishment  of  new  offices  is 
progressing at a pace of two offices per month. This pace is expected to increase as the 
recruitment of the migration team mentioned above progresses. By end October 2020, 
six additional mortgage offices will be abolished and one cadastral office (for Thrace) 
will opened. 

Energy 

The  Greek  government  has  continued  to  engage  constructively  on  a  set  of 
proposals that the Commission could submit for a market test in order to remedy 
the  anti-trust  case  and  deliver  on  an  end-2020  specific  commitment.  The  remedy 
proposal envisages the possibility for Public Power Corporation’s competitors to access 
a certain share of its baseload generation. Improvements to the remedies are still being 
discussed so as to allow the Commission to carry out a market test with stakeholders, a 
key step in view of finally implementing the remedy and closing this case. In particular, 
improvements  are  sought  in  terms  of  ensuring  that  (i)  there  is  a  transparent  selection 
process;  (ii)  smaller  players  in  the  Greek  retail  market  can  access  the  power  sold 
through the remedy; (iii) a detailed implementation mechanism, with direct involvement 
of the Greek Government, is in place for the mechanism. 

The  final  date  for  the  go-live  of  the  Target  Model  for  electricity,  a  mid-2020 
specific commitment, was announced by the energy regulator as 1 November. This 
followed an assessment of the dry-runs to test the market amongst market participants, 
which  revealed  more  time  was  needed.  The  European  institutions  will  report  on  the 
long-awaited  go-live  of  the  Target  Model  in  the  next  report.  The  necessary  legal 
framework  had  been  put  into  place  in  time  or  is  about  to  be  finalised,  as  well  as  the 
main  technical  work  by  the  transmission  operator  and  the  energy  market  operator, 
though some improvements are requested by market participants prior to the go-live. As 
mentioned  in  the  previous  report,  coronavirus  outbreak-related  working  constraints 
delayed the work beyond the authorities’ initial goal of the second quarter of 2020. The 
launch  of  the  Target  Model’s  three  related  markets  (day-ahead,  intra-day,  and 
balancing) is a huge step in setting up a modern energy market and will pave the way 
for  Greece  to  couple  with  neighbouring  electricity  markets  in  the  near  future.  The 
forward  market  was  launched  prior  to  this  but  so  far  seen  little  activity,  so  it  will  be 
interesting to see its interaction with the fully operational market. Following the market 
launch, the authorities are planning to set up a solid monitoring system. Greece carried 
out  flexibility  and  interruptibility  auctions  in  July  and  August,  which  met  with  good 
market interest as most of the offered volumes were taken up. 

Greece’s work towards achieving its ambition of transitioning away from lignite-
based generation continued with progress on its Master Plan, where a draft plan is 
ready for public consultation. This work represents the strategy for the economic and 

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social  transition  of  areas  most  affected  by  the  end  of  lignite  mining  and  lignite-based 
generation. European funding such as the Just Transition Fund can help these areas and 
their communities pivot away from this and find new forms of economic activity. Public 
Power Corporation’s plan for decommissioning plants has progressed according to plan, 
and furthermore, other lignite plants that are still commissioned are often not  entering 
the market,  showing  a big evolution  in  Greece’s generation mix with  other sources of 
energy filling in the gaps.  

Greece  is  looking  towards  electro-mobility  with  the  passing  of  an  ambitious  bill. 
The provisions aim to provide support for the growth of the electric vehicles market and 
the related infrastructure, in order to meet the goals laid out in its National Energy and 
Climate  Plan.  Other  incentives  such  as  free  parking  will  try  to  add  to  the  appeal  and 
grow what is currently a small market for alternative vehicles. Up to this point, Greece 
has been reliant  on road-based transport, and urban centres had seen air pollution and 
traffic problems.  Private sector interest  will be important  to  delivering on these  goals, 
and Public Power Corporation’s plan develop charging stations is encouraging news in 
this  respect.  The  recent  launch  of  an  online  platform  for  subsidies  related  to  electro-
mobility attracted lots of interest. 

As of June 2020, Public Power Corporation’s share of the electricity retail market 
stood at 67.7% (43). This is around the level of March indicated in the last report, and 
lower than the previous year’s share (73.5%) at the same time, showing the overall trend 
downwards,  but  remaining  far  from  the  programme’s  goal  of  50%  by  2020.  This 
declining share comes at a time when consumers are being offered different deals from 
providers, showing an element of competition in the market. Arrears remain a concern 
though  the  pandemic  did  not  seem  to  worsen  these  issues.  Regarding  Public  Power 
Corporation’s  arrears,  it  reached  securitisation  deals  for  packages  of  collectibles  and 
wrote off some longstanding payables. There has been an increase in ‘supply cut’ orders 
to  the  distribution  grid  in  recent  weeks;  stronger  action  towards  strategic  defaulters 
might  make  a  positive  impact  regarding  the  build-up  of  new  arrears.  As  far  as 
industrial/high  voltage  consumers  are  concerned,  Public  Power  Corporation  is  still 
dominant. 

Greece’s wholesale prices remained amongst the highest in the EU despite falling 
in  the  first  half  of  the  year (44),  though  its  rapidly-changing  energy  mix  might 
change this. Domestic wholesale prices fell in the first half of the year and as the Public 
power  Corporation’s  lignite  plants  come  out  of  the  market  (beyond  those  being 
decommissioned)  and  power  is  being  taken  up  by  different  sources,  particularly  gas. 
Retail prices are notably on the cheaper side at a European level. 

Regarding  infrastructure,  work  began  on  the  Crete-Greece  interconnector.  This 
project will be a major part of the country’s longstanding goal of connecting islands to 
the mainland, and could have positive impacts for the uptake of renewable energy and 
for  lessening  the  strain  of  the  Public  Service  Obligation.  On  an  international  level, 

(43) Henex Monthly Day-Ahead Scheduling Report, July 2020. 
(44) Market  Observatory  for  Energy,  DG  Energy  Volume  13  (issue  1,  first  quarter  of  2020),  Quarterly 

Report on Electricity Markets. 

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several plans are moving ahead such as developments with the Trans-Adriatic Pipeline, 
contributing to Greece’s development as an energy hub.  

The deficit in the Renewable Energy Source’s Special Account remains a concern 
for  the  future.  The  resulting  lower  wholesale  prices  and  Emission  Trading  Scheme 
allowance prices resulting from the coronavirus outbreak, whilst generally having some 
positive  impact  on  several  market  players,  had  a  negative  impact  on  the  accounts 
inflows.  The  renewables  market  operator  will  be  considering  a  new  methodology  for 
calculating inflows, to be more in line with the changing market. Finding a sustainable 
approach, which would ensure a balanced account also in the medium and longer term 
and  suitable  to  Greece’s  current  market  and  trajectory,  remains  very  important. 
Renewable energy auctions took place in August, which were efficient in the sense of 
low  prices  and  high  take-up.  The  authorities  plan  to  continue  with  auction  system  for 
another few years. The recent bill on licensing may already be reflected in the take up of 
new projects. 

Transport and logistics 

The transport sector is strongly impacted by the global dimension of the crisis and 
the  resulting  decline  in  global  trade.  In  2019,  24%  of  Greek  exports  were 
transportation  services,  making  them  the  second  largest  Greek  services  export  after 
tourism. Due to the global nature of the pandemic and the resulting slowdown in growth 
and trade, shipping services are strongly hit as well. The sector is experiencing negative 
growth  rates  since  March  (compared  with  the  same  months  in  2019).  In  May  2020, 
receipts from the transport sector declined by 24%, followed by 19% in June compared 
to the same months in 2019.  

In order to remedy the delays  encountered on the implementation  of the 2014-20 
transport and environment operational programme, the authorities have prepared 
a  pipeline  of  railway  projects  that  will  be  reviewed  by  the  European  Investment 
Bank  Joint  Assistance  to  Support  Projects  in  European  Regions  (JASPERS),  the 
European Commission and the Managing Authorities. The projects are in line with 
the  country-specific  recommendations  under  the  European  Semester  and  include  the 
installation of signalling on the line from Thessaloniki to the North Macedonian border, 
electrification and installation of signalling of a segment of the line Athens to Piraeus, 
and other projects. Particular attention will be given to the rail connection of the port of 
Thessaloniki. This project is delayed and needs to be revised to find a feasible technical 
solution.  Further  investments  are  still  required  to  upgrade  the  country’s  backbone 
network from Patras-Athens-Piraeus-Thessalonica to the borders. 

A condition for further EU investment in Greek railways is  the modernisation of 
Organisation  of  Railways  of  Greece  (OSE)  and  its  subsidiary  to  implement 
railways  infrastructure  projects  (ERGOSE),  responsible  for  the  development  of 
the rail network. The rate of execution of projects is extremely slow. The rail network 
is due to play a major role in the greening of transport and the upgrading of logistics in 
Greece.  The  reform  of  the  two  companies  should  be  implemented  in  2020-21.  The 
relevant ministerial decision for setting up the reform framework was signed in March 
2020 but the implementation of the reform has not started yet. The authorities have set 
up  a  committee  with  the  participation  of  the  European  Commission  to  rationalise  the 

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way that railway projects are delivered and make proposals  for new projects  covering 
both the current programming period and the period 2021-27. This committee that will 
also  set  the Terms of Reference for the reform of the Railway Companies has not  yet 
started working, but a road map for their implementation (with intermediate steps) will 
be prepared by October 2020. In order to facilitate the above reforms, implementation 
of technical support provided by the European Commission has been agreed. 

Regarding  the  opening  of  Thriassio  logistics  complex,  there  has  been  some 
progress. The European Commission has asked for corrective action, which the Greek 
authorities  intend  to  complete  by  end-September  2020.  In  the  meantime,  the 
Commission has initiated procedures for financial corrections related to the project. 

A draft strategic plan for the transformation of Urban Transport of Thessaloniki 
(OASTH) has been prepared and was shared with the European institutions. The 
company was nationalised by Law 4482/2017 and operates now as a public sector body, 
without  a  clear  objective  and  legal  framework  and  weak  corporate  culture.  In  August 
2019,  only  213  buses  were  in  circulation  (covering  only  40%  of  the  transport  needs). 
The  rolling  stock  is  obsolete  and  highly  polluting,  with  the  average  age  of  the  busses 
being  15  years  old.  Currently,  the  payroll  costs  represent  approximately  65%  of  the 
general  costs.  Following  its  nationalisation,  staff  were  transferred  to  the  public  sector 
and the salary is paid through the Single Payment Authority. In June 2020, the company 
tendered the lease of 180 to 450 diesel buses to cover the needs of the city for a period 
of 30 months during which time the Greek authorities are expected to finalise the future 
corporate scheme for the provision of urban transport services in Thessaloniki.  

54 

 
8.  HELLENIC CORPORATION OF ASSETS AND 

PARTICIPATIONS (HCAP) AND PRIVATISATION 

8.1.  HELLENIC CORPORATION OF ASSETS AND PARTICIPATIONS 

The authorities have continued their support for the Corporation. They continue to 
provide  support  for  corporate  turnaround  plans  at  key  state-owned  enterprises  where 
this  requires  government  involvement.  They  have  engaged  with  the  European 
institutions  as  part  of  drafting  the  updated  Ministerial  Guidance.  The  authorities  have 
also proposed the establishment of an innovative new entity under the umbrella of the 
Corporation,  fully  respecting  its  governance  principles  and  in  close  and  careful 
cooperation  with  the  European  institutions.  It  will  be  important  to  ensure  that  the 
Corporation’s  rights  and  competencies  are  safeguarded  with  respect  to  placing  further 
new structures or entities under its supervision. 

Managing the impact of the coronavirus pandemic on the Corporation’s portfolio 
companies continues to be a priority. The pandemic has led to adjustments and/or a 
change  of  priorities  for  the  Corporation  as  well  as  to  unavoidable  adjustments  of  the 
schedule of part of Greece’s commitments.  

As  reported 
in  the  previous  enhanced  surveillance  report,  the  negative 
repercussions  of  the  coronavirus  pandemic  have  been  particularly  severe  for  the 
Athens Urban Transport Organisation and the Hellenic Post. More specifically, the 
revenue  of  the  Athens  Urban  Transport  Organisation  declined  dramatically  due  to  the 
uncertainty  created  and  restrictions  on  the  movement  of  citizens  between  mid-March 
and  mid-May.  Also  the  operation  of  post  offices  was  disrupted,  whereas  the  Hellenic 
Post had to continue rendering universal services with the associated costs.  

the  commitments 

Despite the difficulties caused by the pandemic, the work of the Corporation in key 
areas  covered  by 
the  Eurogroup  continued.  The 
implementation of the strategic plan is ongoing, and the work on the finalisation of the 
updated business plan for 2020-2022, which had to be delayed due to the unprecedented 
events,  has  been  resumed  and  the  draft  business  plan  was  prepared  in  August  and 
approved by the  Board  of the Corporation. The  review and  replacement, if needed, of 
the boards of state-owned enterprises is close to being completed  (see below for more 
detail).  

to 

The authorities have continued their strong engagement with the Corporation. The 
authorities  and  the  Corporation  have  been  in  consultation  in  relation  to  measures 
necessary  for  ensuring  business  continuity  and  enterprise  viability  of  the  state-owned 
enterprises in the Corporation’s portfolio, particularly in the cases of the Hellenic Post 
and  the  Athens  Urban  Transport  Organisation.  These  companies  have  requested 
assistance  from  the  state  relating  to  the  losses  incurred  due  to  the  pandemic.  The 
authorities responded positively to  the Athens Urban Transport Organisation’s request 
for the months of March, April and May. A supplementary request has been submitted 
for June. The  corresponding request  by the Hellenic Post  is  under  examination by the 
European  Commission.  The  latter  company  requires  urgent  restructuring  to  reduce  its 

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cost base and to develop new and sustainable revenue streams over the medium to long 
term to ensure its viability. 

The authorities intend to clarify their expectations for the financial performance of 
the  portfolio  of  companies  held  by  the  Corporation  in  the  updated  Ministerial 
Guidance. This can be done by setting out targets and benchmarks per asset category in 
the  updated  Ministerial  Guidance,  as  provided  for  in  the  law  and  internal  regulation 
governing the functioning of the Corporation. The authorities had expected to  provide 
updated  Ministerial  Guidance  to  the  Corporation  during  the  first  quarter  of  2020.  Its 
release was postponed due to the coronavirus pandemic and is currently being drafted. 
The  authorities  have  advised  an  intention  to  set  out  robust  and  commercially-oriented 
benchmarks,  including  by  using  peer  analysis.  The  authorities  have  engaged  with  the 
European  institutions  during  the  early  drafting  process  for  the  Ministerial  Guidance. 
This is very welcome.  

The  authorities  have  chosen  the  Corporation  as  the  umbrella  entity  for  a  new 
venture capital fund specialising in investing in start-ups developing 5G platform 
technologies. The fund management company will be fully owned by the Corporation 
and  its  governance  will  fully  align  with  the  Corporation’s  governance  structure  for 
direct  subsidiaries.  The  authorities  have  engaged  very  thoroughly  with  the  European 
institutions  with  the  shared  goal  of  ensuring  high  professional  standards  and 
independence  on  how  the  fund  will  function,  and  also  ensured  that  enough  time  was 
made available for thorough consultations. The fund will be established with an initial 
commitment  from  the  State,  using  part  of  the  proceeds  of  the  upcoming  sale  of  5G 
spectrum.  The  fund  is  expected  to  include  private  sector  investors  and  will  operate 
under Greece’s legal framework for normal venture capital funds. 

Despite the difficulties encountered by the coronavirus outbreak, the Corporation 
continued  to  the  extent  possible  with  the  implementation  of  its  strategic  plan,  a 
continuous  commitment.  The  plan  incorporates  its  overall  approach  for  better 
management and use of the state assets in its portfolio. In particular, the Corporation is 
monitoring the key performance indicators it has set  for its direct  subsidiaries and the 
non-listed other subsidiaries (state-owned enterprises with majority participations). The 
key  performance  indicators  for  2020  were  adjusted  to  take  into  account  the  impact  of 
the pandemic along with setting their values for 2021 and 2022. The strategic plan will 
be  updated  following  the  issuance  of  the  Ministerial  Guidance.  The  key  performance 
indicators  cover  the  following  areas:  enhancement  of  economic  and  public  value, 
improvement  of  financial  performance,  corporate  governance,  and  improvement  of 
quality of services offered to customers, operational efficiency and innovation.  

The  next  phase  of  the  Coordination  Mechanism  will  be  carried  out  by  the 
Corporation  and  the  state-owned  enterprises  as  soon  as  there  is  sufficient  clarity 
on  the  impact  of  the  pandemic.  This  next  phase  is  to  develop  a  statement  of 
commitments  for  each  applicable  state-owned  enterprise.  It  follows  the  finalisation  of 
the  mandates  of  the  state-owned  enterprises  during  February  2020,  which  were 
approved by the Cabinet Committee on 12 March. The statement of commitments are to 
be  agreed  between  the  Corporation  and  each  state-owned  enterprise,  setting  out  the 
state-owned enterprise’s financial, operational and other objectives. Some delay on this 
is considered reasonable, as the impact of the pandemic has to be taken into account in 

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designing the financial and operational objectives. The key performance indicators for 
the subsidiaries have been finalised, but are subject to risks should the macroeconomic 
environment  deteriorate  compared  to  what  the  authorities  currently  assume.  Upon 
finalisation of both the key performance indicators for the subsidiaries and the Business 
Plan of the Corporation, the Corporation plans to proceed and finalise the statements of 
commitments  by  November  2020.  Following  that,  the  final  phase  of  this  initial 
implementation of the Coordination Mechanism will be the preparation of performance 
contracts  setting  out  public  service  obligations  for  a  limited  set  of  state-owned 
enterprises. The authorities have also stated their intention to support that third phase of 
the Coordination Mechanism with the preparation of performance contracts setting out 
public service obligations for a limited set of state-owned enterprises. 

The  Corporation’s  real  estate  portfolio  has  made  incremental  progress  but 
outcomes remain behind expectations. Strong performance of the real estate portfolio, 
which is  held  and managed by the Public Real  Estate Company  (ETAD), is  critical  to 
the  overall  long-term  success  of  the  Corporation  in  facilitating  investment  and  debt 
reduction. The returns on the portfolio had showed some signs of improvement during 
2019,  following  the  restructuring  of  the  Company.  The  Company  is  working  to 
complete  the  valuation  of  its  portfolio,  which  is  an  essential  step  toward  transparency 
and  improved  performance.  Despite  these  initiatives,  overall  results  and  the  rate  of 
improvement remain below expectations. In June 2020, a new Chairman of the Board of 
Directors  was  appointed.  While  the  commercial  environment  in  2020  will  pose  an 
additional  challenge,  improvements  should  remain  feasible.  Furthermore,  the  Public 
Real Estate Company continues to face certain legal cases, which go back many years 
and could lead to a significant fiscal impact. Addressing these significant challenges and 
achieving  the  full  potential  of  the  real  estate  portfolio  are  key  to  the  future  of  the 
Company. 

The  authorities  have  made  some  further  progress  in  evaluating  an  additional 
package of real estate assets included in the 10 119 real estate assets identified for 
transfer to the Public Real Estate Company in 2018 and are working on setting up 
a legally solid process for the transfer. The transfer will concern all assets eligible for 
transfer  except  those  that  are  excluded  via  the  relevant  provisions  of  the  Law  on  the 
Hellenic Corporation of Assets and Participations. The subsequent screening indicated 
that many of these 10 119 assets were ineligible for the transfer. Moreover, the Council 
of State decided at the end of May 2020 to cancel the transfer of these 10 119 assets to 
the Public Real  Estate Company, on the  ground that the process  followed was not  the 
correct  one,  because  the  eligibility  for  transfer  was  not  checked  by  the  competent 
administrative  authorities  in  advance.  The  authorities  intend  to  implement  the  transfer 
once  the  screening  of  the  package  is  finalised.  The  authorities  also  intend  to  proceed 
with  a  comprehensive  study  that  will  help  them  in  the  elaboration  of  the  holistic  and 
coherent  strategy  aiming  to  optimise  the  protection,  management  and  investment-
oriented exploitation of public real estate. 

The  Corporation  has  continued  its  work  on  corporate  governance,  in  particular 
regarding  the  review  of  the  boards  of  the  state-owned  enterprises,  a  mid-2019 
specific  commitment,  and  improving  internal  and  external  audit  capabilities.  A 
new  Chairman  was  appointed  in  the  Board  of  Directors  of  the  Public  Real  Estate 
Company  in  June  2020  as  well  as  new  Chair  of  the  Audit  Committee  of  the  Hellenic 

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Post and the Central Market of Thessaloniki in May 2020. Of the thirteen state-owned 
enterprises in the Corporation’s portfolio, only the assessment of the Board of Directors 
for the Hellenic Exhibition Organisation (HELEXPO) and the Greek Saltworks remain 
pending.  The  replacement  of  two  non-executive  positions  at  Hellenic  Exhibition 
Organisation  was  decided  by  the  Corporation’s  board  on  9 April  2020  and  the  new 
members were subsequently appointed. The assessment of two remaining positions was 
scheduled  to  be  launched  in  October  after  the  Thessaloniki  HELEXPO  Forum.  The 
appointment of a new Board of Directors for Greek Saltworks is expected to take place 
by the end of September. So far, the Corporation has identified and appointed more than 
70  board  members  (executive  and  non-executive)  in  its  portfolio  enterprises  through 
open, professional and transparent procedures. The Corporation is also preparing an e-
learning  compliance  programme  for  its  subsidiaries  to  promote  corporate  culture  and 
enhance alertness in compliance, conflict of interest and business ethics issues that will 
be  available  not  only  for  board  members  but  also  for  employees  of  the  portfolio 
companies.  During  the  pandemic,  the  Corporation  also  launched  an  e-learning 
programme for business continuity issues addressed to board of directors’ members and 
senior executives. 

The  transfer  of  the  Olympic  Athletic  Centre,  which  was  a  specific  end-2018 
commitment, proves to be very complex, involving multiple stakeholders as well as 
a series of administrative (including maintenance requirements) and procurement 
steps. These include procurement for the repair or overhaul of significant facilities, in 
order to ensure that the asset is provided in a satisfactory condition. Nonetheless, work 
has  continued  throughout  the  pandemic  and  there  is  material  progress.  At  the  end  of 
August  2020,  the  technical  advisor  for  the  project  submitted  detailed  reports  on  the 
immediate maintenance issues and restoration needs on all its sport facilities. The next 
steps,  by  the  end  of  September  2020,  include  the  preparation  of  the  files  (technical 
specifications,  budget,  etc.)  for  the  open  tender  documents  for  a  technical  consultant, 
who will perform the main technical study that will determine exactly the works needed 
for  maintenance  or  overhauling  of  each  installation  of  the  Athletic  Centre.  The 
authorities  are  planning  to  prepare  a  development  master  plan  for  this  extensive  and 
the  Hellenic  Corporation  of  Assets  and 
important  site 
Participations. 

in  coordination  with 

8.2. 

IMPLEMENTATION OF THE ASSET DEVELOPMENT PLAN 

Implementation  of  the  Asset  Development  Plan  of  the  Hellenic  Republic  Asset 
Development  Fund  (HRADF/TAIPED)  is  key  to  stimulating  private  investment, 
increasing  efficiency  and  providing  financing  to  the  state.  In  June  2018,  the 
authorities made specific commitments to the Eurogroup to implement the Plan, which 
will be updated every six months. Progress with the remaining transactions included in 
the  Asset  Development  Plan  has  been  affected  by  the  coronavirus  outbreak  but  has 
resumed as from June, for a number of transactions also thanks to the fact that the Fund 
was proceeding with the maturing of the various transactions during the pandemic. As a 
result of the delays created through the coronavirus pandemic, the only transactions that 
have a chance to be financially closed in 2020 are Hellinikon and the Marina of Alimos.  

The Asset Development Plan has been updated by the Fund, approved by its Board 
and  sent  to  the  authorities.  The  Plan  was  approved  by  the  Government  Council  for 

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Economic Policy on 10 September (FEK Β 3868/10.9.2020). It is noted that the updated 
Asset Development Plan includes also the transaction for a new long-term concession of 
Attiki  Odos.  The  current  concession  expires  in  2024  and  its  inclusion  in  the  updated 
Asset  Development  Plan  allows  for  the  timely  conclusion  of  a  new  long-term 
concession.  

Progress with specific transactions 

Hellinikon: Despite the strong engagement and efforts of the authorities to complete the 
prerequisites for the financial closing of the transaction, with the start of the demolition 
works  in  the  beginning  of  July,  the  financial  closing  did  not  occur  so  far  due  to 
complications in the casino licence tender process and other judicial cases, concerning 
administrative acts, set for discussion in September 2020. The current state of play on 
key elements is as follows:  

  The tender process for awarding the casino licence is still ongoing. The evaluation 
of the legal documents of the two bidders led to the exclusion of one of them, who 
subsequently  lodged  a  petition  for  annulment  along  with  interim  relief  measures 
before  the  Council  of  State.  The  Council  of  State  rejected  the  petition  for  relief 
measures  on  7 May  2020.  This  opened  the  way  for  a  continuation  of  the  process. 
However,  the  decision  on  the  petition  for  annulment  remains  pending.  The  hearing 
took  place  on  3 July  and  the  authorities  feel  confident  that  there  will  be  a  final 
decision soon. 

  The relocation of the public users is almost completed with only a few arrangements 
to be made for users staying on site. The pending legal issue with the only remaining 
private  user  will  continue  before  the  Supreme  Court  but  this  does  not  hinder  the 
enforcement process once the pending decision at a second instance court is issued.  

  The  partition  of  the  Hellinikon  site  agreed  in  February  2020  is  currently  being 
enshrined in a binding document (Partition Deed and Surface Rights Establishment 
Deed).  Following  the  enactment  of  the  enabling  provision  for  the  process  and  the 
specifics  of  the  partition,  the Deed  is  still  being  drafted  and  will  be  finalised 
following the review process by all parties. It is noted that the legislative provisions 
regarding the surface rights  have been agreed  and have been sent  for review to  the 
Hellenic Cadastre Office, before their submission to Parliament. 

  Pending  legal cases. Petitions  for annulment  have been filed before the  Council of 
State for a number of cases. All cases have been set for discussion in September and 
October 2020.  

  Demolition of current buildings on the site was launched on 3 July. An amendment 
to the relevant legislation from February 2020 was passed in June, for interpretative 
purposes  to  provide  the  technical  feasibility/possibility  for  the  preferred  investor 
(Lamda)  to  proceed  to  gradual  demolitions  of  the  first  cluster  of  buildings. The 
launching of the demolition process took place on 3 July. 

Marina of Alimos concession: The Marina of Alimos is one of the largest marinas in 
the  South-Eastern  Mediterranean,  located  on  the  South-Eastern  waterfront  of  Athens. 

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Following  the  signing  of  the  concession  agreement  on  13 May  2020,  the  financial 
closing of the transaction should have taken place within 120 days as provided for in the 
contract. The Board of the Fund extended on 3 September the 120 days for another 50 
days  (until  30 October  2020)  to  allow  adequate  time  for  the  completion  of  the 
transaction. 

Hellenic Petroleum: The financial closure is subject to significant delays following the 
failure  of  the  first  tender  in  mid-2019.  The  Fund  is  considering  all  options.  However, 
following  the  significant  fall  in  the  capitalisation  value  of  the  company,  the  Fund 
considered appropriate to delay further the launching of the transaction to a later point 
in time. 

Sale of 30% of Athens International Airport: The tendering process was proceeding 
well prior to the coronavirus outbreak. Ten investment parties expressed their interest to 
acquire  a  30%  stake  in  the  first  phase  of  the  process  concluded  in  October  2019. 
Following the evaluation of the investors’ proposals, on 31 January 2020 the Board of 
Directors of the Fund decided that nine investment parties were qualified to proceed to 
the binding offers phase. However, due to the impact of the pandemic on the economy 
in  general  and  on  the  air  transport  sector  in  particular,  it  was  considered  necessary  to 
delay the scheduled timeline for the second phase of the tender and the deadline for the 
submission  of  binding  offers.  The  Fund  is  monitoring  market  conditions  and  will 
determine  the  updated  tender  timeline  and  the  submission  of  the  binding  offers  date, 
once a normalisation of the situation takes place. This is not expected to be done prior to 
2021.  

Public Gas Corporation – DEPA: Tenders for both companies, launched in December 
2019  for  DEPA  Infrastructure  and  in  January  2020  for  DEPA  Commercial,  attracted 
strong  investment  interest.  Following  the  coronavirus  outbreak,  the  Fund  considered 
necessary to provide interested parties with some flexibility regarding the submission of 
the required documentation for their expression of interest. At the same time, the Fund 
and  its  consultants  continued  to  evaluate  the  proposals.  Six  interested  parties 
prequalified for the next phase for the 100% of DEPA Infrastructure and seven for the 
DEPA  Commercial.  In  June  2020,  the  Board  of  the  Fund  decided  to  proceed  to  the 
binding offers phase for both transactions. Access of prequalified bidders to the Virtual 
Data  Room  was  granted  in  late  August  for  DEPA  Infrastructure,  whereas  for  DEPA 
Commercial  it  is  expected  before  the  end  of  September.  It  is  further  noted  that  on 
22 June 2020, the Energy Regulatory Authority took a decision on a pending complaint 
against  DEPA  infrastructure,  which  is  a  welcomed  step  as  it  is  expected  to  draw  this 
long-standing  case  to  a  close.  For  both  transactions  there  is  a  number  of  issues 
remaining to be settled (45).  

(45) For DEPA Infrastructure, there is a (i)  need for clarity on  the regulatory  framework for distribution 
system operators and (ii) full clarity on the DEDA (distribution) asset perimeter to ensure it remains a 
cohesive and attractive asset. On DEPA Commercial there is (i) a pending issue on the outcome of the 
court case regarding an industrial customer of DEPA, who was awarded damages as compensation for 
DEPA  imposing  abusive  contractual  terms  upon  it  during  the  period  2010-2015,  (ii)  a  need  for  a 
resolution  between  the  State  and  the  Public  Power  Corporation  of  any  claim  (if  valid)  regarding  a 
potential call option for 30% in DEPA. 

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Egnatia:  The  privatisation  process  for  the  Egnatia  motorway  entails  the  award  of  a 
long-term concession for the operation and maintenance of the motorway and its three 
vertical axes. The deadline for the submission of binding bids has been further extended 
as significant open issues remained pending. The authorities have during the mission in 
July stressed their commitment to proceed with the transaction. Progress has been made 
with respect to the following actions: 

  Resolution  of  open  issues  related  to  the  motorist  service  stations  contracts  via  a 

relevant decision of the Board of Egnatia on 2 July 2020.  

  Regarding  the  works  needed  for  bridges  to  be  classified  as  safe,  the  Ministry  of 
Infrastructure informed the European institutions that the issue will be resolved via 
the assumption of the cost up to €80 million for the required works by the state 

  However,  the  progress  made  as  far  as  the  completion  of  the  construction  of  all 
remaining  frontal  and  lateral  toll  stations  and  the  required  works  so  that  the 
remaining 14 tunnels can be licenced under category E (i.e. excluding the transport 
of dangerous cargo) over the last three months has been very limited.  

  The authorities and Egnatia S.A. are expected to proceed with the acceleration in the 
implementation of the remaining pending actions in the coming weeks, namely:  

  Completion of the construction and operation of all remaining frontal and lateral toll 
stations: A significant number of toll stations are expected to be completed and put 
in operation by the end of October and an additional number before the date of the 
submission of binding bids (the date of submission of binding bids has been extended 
to  11 December  2020)  as  this  will  demonstrate  the  authorities’  commitment  to 
proceed  with  the  implementation  of  the  project  by  securing  its  revenue  streams. 
Furthermore,  the  Ministry  committed  to  putting  all  the  toll  stations  in  operation 
before the commencement of the concession agreement.  

  Licensing of  all tunnels by the Tunnel  Licensing Authority: The required works for 
the remaining 14 tunnels to be licenced under category E (i.e. excluding the transport 
of  dangerous  cargo)  are  expected  to  be  completed  by  the  end  of  October  and  the 
tunnels licenced by the end of November.  

Regional  Ports:  Following  a  delay  in  launching  of  the  transactions  for  a  number  of 
ports due to the pandemic, the Fund decided in  June to proceed with the launching of 
the  tender  process  for  the  sale  of  shares  for  the  ports  of  Alexandroupolis  and 
Igoumenitsa  (sale  of  a  majority  stake  of  at  least  67%  in  the  share  capital  of  the 
company)  and  the  sub-concession  of  a  multi-purpose  terminal  for  the  port  of  Kavala. 
The relevant tendering processes were launched on 17 July 2020 following the adoption 
of a new legislation, which passed the management of certain land areas to the relevant 
Port Authority. 

Underground Natural Gas Storage South Kavala: The South Kavala gas field is an 
almost depleted natural gas field located in the North Aegean Sea. On 22 June 2020, the 
Fund launched an international public tender for the award of a concession agreement 
for  the  use,  development  and  operation  of  the  Gas  Storage  for  a  period  of  up  to  fifty 

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years following the licensing of the project. The tender shall be conducted in two stages: 
Phase A (submission of Expression of Interest and Pre-qualification of Candidates) and 
Phase B (submission of Binding Offers and selection of the Concessionaire). The exact 
duration  and  terms  of  the  Concession  Agreement  shall  be  stipulated  in  the  draft 
Concession Agreement to be made available to the pre-qualified  Investors prior to the 
submission  of  their  Binding  Offers.  The  deadline  for  submission  of  Expressions  of 
Interest has been extended to 30 September 2020.  

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9. 

PUBLIC ADMINISTRATION AND JUSTICE 

9.1.  PUBLIC ADMINISTRATION 

Appointments of senior management positions in the public sector  

The  selection  process  for  senior  management  posts  is  continuing.  Following  the 
completion  of  appointments  of  Permanent  Secretaries  (13  in  total),  a  training 
course  that  had  been  postponed  due  to  the  coronavirus  pandemic  took  place  in 
July. Further, the selection process to appoint a Permanent Secretary at the Ministry of 
Migration  and  Asylum  has  been  launched  and  is  expected  to  be  completed  by  end  of 
September 2020. As some of the appointed Permanent  Secretaries previously held  the 
post of General Directors – a selection process for these vacant posts are expected to be 
launched in September. As concerns the Director posts, the selection boards have been 
re-established  to  include  the  recently  appointed  Permanent  Secretary,  whereas  the 
selection  process  –  which  had  been  paused  due  to  the  coronavirus  pandemic  –  is 
expected to be resumed. The schedule for launching the selection process for Heads of 
Division remains unclear. 

Draft  provisions  have  been  prepared  to  set  up  a  uniform  selection  process  for 
senior management posts at public sector entities (46) that is expected to be adopted 
in September and to come into effect in October 2020.  It  is  expected that selection 
procedures  for  around  30  posts  will  be  launched  during  this  year.  Clarity  about  the 
selection process for managers involved in the management of the EU structural funds 
(National  Strategic  Reference  Framework)  under  the  mandate  of  the  Ministry  of 
Development  and  Investments  is  expected  to  be  established  ahead  of  the  new 
programming period for EU funds (2021-2027). The ongoing selection process, which 
has encountered severe delays, concerns close to 200 posts of responsibility, which need 
to be completed timely so as to ensure a smooth start of the new programming period. 

Improving human resource management  

Continued  good  progress  has  been  made  in  developing  the  Human  Resources 
Management  System  (HRMS),  including  completion  of  a  significant  number  of 
digital organigrams and job descriptions, an end-2019 specific commitment that is 
expected to be completed by the end of 2020. Until August 2020, over 1 500 general 
government entities had completed its digital organigram, representing above 80% of all 
entities  and  85%  of  personnel,  including  most  of  the  large  entities.  During  the  next 
reporting  period,  the  focus  will  especially  be  on  the  remaining  entities  (150  in  total) 
with more than 20 employees that are yet to complete their digital organigrams and that 
are  currently  employing  around  6%  of  all  general  government  staff.  By  end-October 
2020,  the  majority  of  these  entities  are  expected  to  have  finalised  their  digital 
organigrams.  As  concerns  the  process  establishing  a  link  between  the  job  description 
and jobholder, it has been completed for around 75% of posts. The authorities plan to 
establish  this  link  by  end  of  2020  for  all  posts  at  central  government  level  and  legal 
entities of public law, which remains below average compared to the completion rate of 

(46) In  the  Greek  context,  these  public  sector  bodies  are  referred  to  as  legal  entities  of  public  law  and 

legal entities of private law. 

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other  general  government  entities.  Finally,  the  tender  on  Human  Resources  System 
Support  Services  (EU-funded  through  the  National  Strategic  Reference  Framework) 
was launched in July. 

A draft law to update the enabling law of the Supreme Council for Civil Personnel 
Selection  has  been  prepared.  The  draft  law,  which  aims  to  enhance  the  overall 
capacity of the Supreme Council and put in place a coherent and uniform procedure for 
recruitment, is expected to be published for public consultation shortly with adoption to 
follow  by  November  2020.  In  parallel,  work  is  continuing  on  streamlining  the  job 
classification  system  (‘klados’)  and  a  proposed  list  of  the  job  classification  categories 
has been prepared with  technical  support provided by the European Commission.  The 
relevant legislation (47) is expected to be revised later this year. This reform is directly 
related to  the hiring procedures  for public officials and is  expected to  reduce the time 
needed to prepare job announcements. 

The  authorities  are  carrying  out  a  comprehensive  review  of  the  mobility  scheme. 
Initial findings show that while each cycle seems to attract stronger interest in terms of 
vacant  posts  published, the proportion of actually filled posts at  the end of each cycle 
remains relatively low (close to 20%). As part of this exercise, the authorities are also 
taking stock of existing procedures for transfers and secondments of personnel outside 
the standard mobility scheme with a view to reducing their /number. At the same time, a 
recent  provision (48)  allowed  for  up  to  80  public  officials  to  be  seconded  outside  the 
mobility  scheme,  which  is  a  worrying  development  that  risks  sending  a  wrong  signal 
regarding  the  authorities’  commitment  to  uphold  the  mobility  scheme  and  could  set  a 
precedent  of  parallel  ad  hoc  hiring  procedures  being  established.  Finally,  the  third 
mobility cycle (a specific mid-2019 commitment) that was launched in August 2018 has 
been completed. Out of the 5 440 vacant posts, around 20% were filled (1 122 posts). 

The  performance  assessment  cycle  for  2019,  which  had  been  delayed  due  to  the 
coronavirus  pandemic,  was  launched  in  July  and  is  expected  to  be  completed  by 
the  end  of  this  year.  In  addition,  the  authorities  are  progressing  with  plans  to 
strengthen the assessment framework, including introduction of goals. 

Legal codification 

Following  the  re-establishment  of  the  Central  Codification  Committee  in  May 
2020, the manual for legal codification was finalised and published in July (49). The 
manual, which has been prepared with technical support provided through the European 
Commission,  set  outs  guidance  for  practitioners 
legal 
codifications,  in  order  to  facilitate  consistency  across  the  sectors.  The  Committee  has 
also prepared a draft annual codification plan for 2021 that is expected to be approved 
by  the  Council  of  Ministers  in  September.  The  Committee  is  also  taking  steps  to 
strengthen  the  governing  structure  to  ensure  that  allocated  EU  funds  (through  the 
National Strategic Reference Framework) for the preparation of legal codifications for 
various sectors are used in a timely manner, as the previously published call for tender 
has  been  cancelled.  During  the  next  review  period,  a  joint  regulatory  act  between  the 

in  preparing 

involved 

(47) Presidential Decree 50/2001. 
(48) OJ A 148/31.07.2020, Article 86. 
(49) https://gslegal.gov.gr/?p=7177 

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Secretariat  General  for  Legal  and  Parliamentary  Affairs  and  the  Ministry  of  Digital 
Governance is expected to be finalised. It will be important for the various tenders to be 
launched without further delays, as the funding available will have to be fully disbursed 
within the next two years. 

The  coronavirus  pandemic  has  slightly  delayed  the  adoption  of  the  re-codified 
Labour Law Code and Code of Labour Regulatory Provisions, a mid-2020 specific 
commitment.  The  authorities  plan  to  adopt  the  laws  by  September  2020.  The 
codification process, expected for November 2020, is used as an opportunity to review 
and modernise some areas  of the labour legislation, including new forms of work and 
the role of the labour inspectorate, which is most welcome (see section 7.1). 

The  tender  for  the  flagship  project  to  set  up  the  national  gateway  for  legal 
codification,  a  mid-2022  specific  commitment,  is  progressing.  The  tender  was 
launched  in  June  2020  and  offers  were  submitted  in  July,  which  are  currently  being 
assessed. Contract signature is expected to take place by the end of 2020.  

Implementation of the Executive State Law 

The delegation of competencies from the political to non-political level, which came 
into  effect  in  February  2020,  is  being  applied  efficiently  and  the  authorities  are 
considering  to  delegate  additional  competencies.  A  circular  on  the  role  of  the 
Permanent  Secretaries  and  a  presidential  decree  on  their  additional  competences  is 
currently  being  finalised.  Efforts  are  also  being  stepped  up  as  concerns  the 
establishment  of  three  new  job  categories (50):  political  analysts,  legal  drafters  and 
digital policy analysts. The authorities are attaching particular importance to these new 
categories of staff, who are expected to be involved in the preparation of draft laws and 
comprehensive impact assessments in accordance with the good law-making provisions 
that  are  part  of  the  Executive  State  Law.  As  a  next  step,  a  circular  is  planned  to  be 
published  in  September  2020  that  will  define  the  number  of  officials  per  category. 
However,  the  completion  of  all  steps  to  establish  these  three  new  executive  job 
categories,  including  the  necessary  primary  and  secondary  legislation,  is  currently 
expected to be finalised towards the end of 2021. Finally, as of 1 October 2020, all draft 
bills  will  be  accompanied  by  a  new  impact  assessment  analysis  that  consolidates  all 
existing  accompanying  reports  and  new  reports  on  legality  and  implementation  of 
proposed  legislation.  Work  is  ongoing  for  the  impact  analysis  report  to  be  completed 
digitally.  

Controlling the size and cost of the public sector 

The  evolution  of  personnel  in  2020,  both  permanent  and  temporary,  remains  in 
accordance with the hiring plans, but the envisaged reduction of temporary posts 
following their conversion to permanent positions is yet to materialise. As regards 
permanent  staff, it is  estimated that hirings in  2020 will  be approximately  40% below 
plan, as selection processes have been prolonged due to the coronavirus pandemic. Most 
of the new hirings aim at strengthening the public health system, military schools and 
the  Independent  Authority  for Public Revenue. The hirings that will not be completed 
during this year will be carried out in 2021. The average number of temporary personnel 

(50) OJ Α 133/07.08.2019, Article 104. 

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for the first half of 2020 remained stable compared to the respective period in 2019. It is 
encouraging that the increasing trend of the previous years has been reversed, however 
the number of temporary staff remains well above the level in 2018 when Greece exited 
the  European  Stability  Mechanism  programme.  Furthermore,  the  conversion  of 
temporary  contracts  into  permanent,  in  particular  for  municipalities  and  education 
sector (51),  has  to  date  not  resulted  in  the  corresponding  decrease  of  the  number  of 
temporary staff. The authorities have confirmed that the estimated decrease, at least for 
teachers  on  temporary  contracts,  should  be  visible  by  end-September 2020.  The 
European institutions encouraged the authorities to implement the expected reduction of 
the remaining temporary posts during the next review period.  

The  authorities  are  carrying  out  a  comprehensive  analysis  of  temporary  staff  to 
remove  posts  of  a  permanent  nature.  This  exercise  is  expected  to  be  completed  by 
October  2020  and  would  allow  for  an  annual  ceiling  on  temporary  staff  covering 
seasonal needs for 2021 and beyond to be defined by the end of this year. The annual 
ceiling  on  temporary  staff  is  expected  to  incorporate  completed  conversions  of 
temporary posts into permanent posts, as mentioned in the previous paragraph.  

The  inter-ministerial  committee  mandated  to  strengthen  central  control  over  the 
wage grid and hiring procedures has established three working groups (52) to focus 
on specific areas. These working groups cover (i) the development of methodology for 
planning the hiring of temporary staff; (ii) the detection of possible deviations from the 
current  recruitment  and  mobility  regimes;  and  (iii)  the  collection  of  all  regulations 
relating to wages and benefits adopted since July 2019. The inter-ministerial committee 
is expected to convene in September and set out specific time schedules for the work of 
the three working  groups. Following the completion of the work assigned to  the three 
working  groups,  it  is  expected  that  the  inter-ministerial  committee  will  proceed  to 
present proposals on how to reduce the number of deviations from the unified wage grid 
and hiring procedures.  In parallel, a study is carried out by technical support provided 
through  the  European  Commission  to  assess  appropriate  employment  levels  in  the 
public  sector  and  is  expected  to  be  completed  by  October  2020.  Further,  the  work  to 
establish an integrated IT system for the general government payroll is ongoing. This IT 
system is planned to be tested in a pilot phase by the Single Payment Authority between 
May  and  October  2021,  covering  300 000-350 000  public  sector  employees.  The 
deadline  for  the  coverage  of  the  remaining  public  sector  employees (53)  is  yet  to  be 
clarified  and  will  depend  on  the  outcome  of  the  pilot  phase.  Finally,  secondary 
legislation to define the new organisational structure of the Single Payment Authority is 
expected to be adopted in the coming months. 

Digital governance 

The  ambitious  digital  transformation  of  the  public  administration  and  the 
economy  as  a  whole  remains  a  key  priority  for  the  authorities.  To  underpin  these 
efforts,  they  aim  to  publish  the  new  comprehensive  national  digital  strategy  (‘Digital 

(51) Concerns  around  8 000  municipal  posts  (mainly  regarding  waste  management)  and  4 250  special 

teachers. 

(52) O.J. YODD Issue No 676/28.8.2020. 
(53) Once  the  IT  system  will  be  finalised  it  is  expected  that  all  staff  of  general  government  entities 

(approximately 700 000) will be covered. 

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Bible’)  for  public  consultation  shortly.  The  strategy  is  expected  to  lay  down  an 
ambitious and dynamic pipeline of some 300 horizontal and sectoral projects and set out 
a  portfolio  management  system  to  monitor  their  implementation.  Within  this  context, 
the authorities have already advanced with a number of projects.  

Key  projects  go  in  the  direction  of  upskilling,  simplifying  and  digitalising 
transactions and public sector data, enhancing the interoperability and robustness 
of  systems  in  the  public  administration,  and  promoting  connectivity  and  the 
development  of  5G  applications.  Through  the  development  of  a  National  Digital 
Academy,  citizens  enjoy  free  access  to  both  basic  and  specialised  digital  skills 
courses (54).  The  authorities  are  also  pursuing  the  simplification  and  digitalisation  of 
transactions with and within the public sector to ease the administrative burden, through 
the  implementation  of  the  National  Programme  for  Process  Simplification  and  the 
development  of  the  integrated  transactions  portal  (gov.gr).  Further,  they  continue  to 
enhance  the  interoperability  of  public  sector  systems  and  registries,  inter  alia  to 
accommodate  the  Simplification  Programme,  whilst  ensuring  the  sufficiency  and 
robustness  of  public  sector  IT  infrastructure,  including  through  security  enhancements 
for  electronic  transactions  and  expansion  of  the  public  sector’s  capacity  for  telework 
and  teleconferencing.  Amongst  other  initiatives,  the  final  offers  for  the  ‘Syzefxis  II’ 
project aiming at improving the telecommunication infrastructure of the existing public 
administration network are being evaluated, with a view to signing most of the contracts 
by the end of 2020. Concerning connectivity, the tender on the ‘Ultra-Fast Broadband’ 
project aiming to fill gaps in very-high-speed connectivity has entered the second phase 
and  the  authorities  expect  to  receive  binding  offers  by  November  2020.  Work  is  also 
proceeding  with  a  project  to  establish  fibre  interconnections  with  the  main  islands. 
Further, the authorities delivered an innovative proposal  for developing the ecosystem 
for  the  industrial  application  of  5G  technologies  (see  section  8.1).  Lastly,  through 
projects  such  as  the  creation  of  the  Single  Digital  Map  and  the  State  Infrastructures 
Registry,  the  authorities  aim  to  digitalise  geospatial  data  for  the  use  of  the  public 
administration and the private sector alike. 

As  regards  the  National  Programme  for  Process  Simplification,  the  authorities 
completed  the  necessary  legal  and  organisational  set  up  for  its  implementation, 
which is already underway. Specifically, they adopted secondary legislation to set out 
the responsibilities of the Ministry of Digital Governance, leading the reform, and other 
ministries.  With  the  help  of  technical  support  provided  by  the  European  Commission, 
they  also  prepared a Process  Design  and Simplification Guide intended for use across 
the government. Albeit with some delay due to the coronavirus outbreak, the authorities 
are  expected  to  deliver  shortly  an  annual  action  plan  to  prioritise  the  simplification 
domains and web services in each of the intervention areas to be launched over the next 
year.  Within  this  context,  a  number  of  Memoranda  of  Cooperation  and  Programmatic 
Agreements have already  been signed to  set  out  priority areas for the Programme (55). 

(54) To date, the National Digital Academy provides access to 214 free online basic and specialised digital 

upskilling programmes to all citizens, featuring more than 1 800 hours of free learning. 

(55) Inter alia, priority areas include the digitisation of courts (e.g. electronic delivery of certificates, digital 
signatures  for  court  staff  and  judges  and  online  tools  for  judicial  and  prejudicial  procedures), 
procedures  for  securing  Greek  citizenship,  and  the  creation  of  systems  for  monitoring  the 
implementation of sustainable urban mobility plans. 

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As regards the development of such agreements, close cooperation between the Ministry 
of  Digital  Governance  and  the  Ministry  of  Development  and  Investments  –  which  is 
leading  the  investment  licencing  reform,  including  the  simplification  of  licensing 
legislation – would help avoid any overlap between the two reform streams.  

Progress  is  recorded  with  respect  to  the  development  of  the  digital  transactions 
portal  with  the  government  (gov.gr)  and  the  establishment  of  a  unified  legal 
framework to encompass all digital policy elements. A dedicated unit was set up at 
the Ministry of Digital Governance as of July 2020 (56) to coordinate the development 
of  gov.gr,  which,  to  date,  offers  more  than  610  services  (i.e.  some  110  new  services 
since the last review). The authorities aim to introduce some further 40 new services by 
the  end  of  the  year.  To  this  end,  they  prepared  a  comprehensive  roadmap  for  the 
implementation  of  technical  functionalities  and  the  soon-to-be  digitalised  procedures, 
such as local  government  services, by  end-2021.  In addition,  the new Code of Digital 
Governance was published for public consultation in July and is expected to be adopted 
soon, whilst the authorities are working towards an action plan on the steps necessary 
for  the  operationalisation  of  provisions  of  new  law.  The  Code  aims  at  creating  a 
comprehensive  and  transparent  legal  framework  on  digital  policy,  while  establishing, 
amongst other objectives, a unique number for citizens to transact with the government. 
Lastly,  to  support  this  work  and  with  a  view  to  facilitating  the  business  continuity  of 
information  systems,  the  authorities  expect  to  launch  shortly  the  tender  to  provide 
Database  Private  Cloud  Computing  services  and  are  currently  preparing  the  tender 
documents for the Database Backup Infrastructure.  

The first steps in relation to the planning of projects in relation to the digitisation 
of  geospatial  data  have  been  completed.  These  refer  to  the  creation  of  the  Single 
Digital Map, aiming at increasing transparency for investors concerning land use rules 
across  Greece,  and  the  State  Infrastructures  Registry,  intended  to  encapsulate 
electronically technical and geospatial information on all public infrastructure projects. 
In  relation  to  the  State  Infrastructures  Registry,  the  authorities  delivered  a  two-year 
action  plan  for  the  development  and  pilot  implementation  of  this  tool  and  issued 
secondary legislation to define responsibilities for the development and oversight of this 
project  (57).  A  two-year  action  plan  for  the  creation  and  pilot  implementation  of  the 
Single Digital Map was also delivered. These projects are expected to facilitate private 
sector investment projects and the improvement of public infrastructure management. 

9.2.  JUSTICE 

Work on the transition to mandatory electronic filing and processing of documents 
in  civil  and  penal  jurisdictions  is  ongoing.  The  authorities  formed  a  working  group 
along with stakeholders, with the objective of planning and overseeing the deployment 
of  electronic  filing  and  processing,  in  both  jurisdictions.  A  list  detailing  digitalisation 
initiatives has been drafted, to serve as the basis for the planning of relevant activities. 
Among the tasks due for completion by end-September 2020 are the following: 

(56) Law 4704/2020 (OJ A 133/14.07.2020). 
(57) FEK B’ 3200/03.08.2020. 

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Chapter 9 - Public administration and justice 

  The  consolidation  of  a  number  of  different  insolvency-related  certificates  into  one 
that will be issued and delivered electronically by the General Commercial Registry;  

  The issuance of an electronic divorce certificate; 

  The issuance of a criminal record certificate. 

In  parallel,  efforts  are  now  underway  to  implement  a  reliable  and  effective 
mechanism  for  the  distribution  of  digital  signatures.  Discussions  are  ongoing 
between the Greek state on one part and the Athens bar and notarial associations on the 
other  for  the  provision  and  certification  of  over  30 000  signatures  is  being.  The  e-
signatures are to be made available to lawyers as well as notaries and bailiffs and their 
certification  should  be  carried  out  remotely,  dispensing  with  the  need  for  physical 
equipment.  Regarding  judges  and  court  secretaries,  the  electronic  platform  for  the 
distribution  of  e-signatures  has  been  delivered  to  the  Ministry  of  Digital  Governance, 
and  instructions  to  the  users  of  the  system  have  been  published  online (58).  The 
authorities are expected to provide a status report, documenting progress and next steps, 
by October 2020. 

The  distribution  of  digital  signatures  will  also  enable  the  implementation  of  a 
recently  introduced  amendment  to  the  Code  of  Civil  Procedure,  allowing  for 
electronic  notifications  of  legal  documents  by  judicial  bailiffs (59).  The  use  of  this 
new  procedure  will  significantly  enhance  the  efficient  and  speedy  conduct  of 
notifications,  increase  legal  security  and  reduce  the  use  of  resources  regarding  the 
processing  and  dissemination  of  notified  documents  that  concern,  in  particular,  major 
handlers such as administrative services, credit institutions and large corporates.  

Following  the  submission  of  bids  for  the  second  phase  of  the  Integrated  Judicial 
Case  Management  System,  the  authorities  are  in  the  process  of  evaluating  the 
offers  with  a  view  to  completing  the  tender  procedure,  a  mid-2020  specific 
commitment,  by  November  2020.  The  procedure  was  extended  in  view  of  the 
disruptions  caused  by  the  coronavirus  pandemic.  The  evaluation  of  offers  should  be 
completed shortly and the contract awarded by 15 December 2020. Completion of the 
projects is foreseen within 36 months from the signature of the contract. 

Mandatory  mediation  is  fully  in  force  as  of  1 July  2020  and  the  authorities  are 
engaged in planning the provision of training to stakeholders (mainly lawyers). The 
launch of a tender for the provision of the relevant know-how is planned – including the 
drafting  of  manuals  and  preparation  of  training  materials;  the  project  should  run  for  a 
period of eighteen to twenty four months and is aimed at training 60% of lawyers. An 
action plan detailing the deployment of the relevant activities should be presented by the 
authorities in November 2020.  

The authorities adopted legislation for the creation of specialised chambers in civil 
and administrative courts, with a view to increasing the effectiveness and efficiency 

(58) https://support.mindigital-shde.gr/faqs 
(59) Article 67 of law 4869/2020 (OJ A 105/27.5.2020), adding article 122A to  the Greek Code of Civil 

Procedure. 

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Chapter 9 - Public administration and justice 

of justice in the context of cases of major importance for the economy. The relevant 
provisions (60) allow for new chambers that will deal with specific categories of majorly 
significant cases. Special chambers in civil jurisdictions in Athens and Thessaloniki will 
deal with cases involving claims for damages, based on the transgression of national and 
EU legislation on electronic communication, energy and the protection of private data; 
the  addition  of  further  categories  of  cases  is  also  allowed.  Moreover,  the  creation  of 
special  chambers  dealing  with  categories  of  cases  to  be  defined  by  their  respective 
heads of administration is allowed in bigger administrative courts operating more than 
three  sections.  Lastly,  the  creation  of  specific  chambers  dealing  with  the  backlogs  of 
legacy  household  insolvency  cases,  is  allowed  in  Magistrate’s  courts  operating  more 
than one sections. A full report on the application of said provisions is expected by end- 
October 2020. 

The authorities adopted the code of procedure before the Court of Audit and are 
proceeding  with  the  adoption  of  the  Code  of  Judicial  (Clerical)  Staff  and  the 
revision of the Code on the Status of Judges and the Organisation of Courts, all of 
them  introducing  significant  revisions  that  should  contribute  to  enhancing  the 
function  of  justice.  The  code  of  procedure  before  the  Court  of  Audit  was  adopted  in 
June (61) and entered into force in the beginning of the new judicial year, in September 
2020. The Code of Judicial Staff should be adopted in December 2020. Regarding the 
Code  on  the  Status  of  Judges  and  the  Organisation  of  Courts  the  formation  of  a  law-
drafting committee, in November 2020, is being envisaged, for the purpose of assessing 
and  revising  its  provisions  on  training,  evaluation,  promotion  and  adding  new 
disciplinary measures to address excessive delays in caseload processing . Above issues 
are of importance for the effective functioning of justice, as they regulate the assessment 
of the performance of magistrates’ duties, their professional advancement, disciplinary 
matters,  etc.  The  success  of  other  justice-related  reforms  (Code  of  Civil  Procedure, 
Insolvency  Code,  the  functioning  of  special  chambers,  etc.)  relies  on  the  effective 
implementation of a modern set of rules for the performance of judicial duties.  

Following the adoption of legislation for the creation of the  ‘JustStat’ unit in the 
Ministry of Justice for statistical data collection and processing in June 2020, the 
authorities  will  proceed  with  the  drafting  of  the  relevant  Presidential  Decree  and  its 
submission  to  the  Council  of  State  by  end-December  2020;  concurrently,  a  working 
group will be established and entrusted with improving the quality of statistics collected 
by the Ministry of Justice. The deployment of the activities of the unit as described in 
the  law (62)  is  a  task  of  high  priority,  given  the  importance  of  standardised, 
comprehensive,  granular  and  reliable  statistics  for  monitoring  and  assessing  the 
performance  of  the  justice  system,  identifying  problems  and  shortcomings  and 
formulating proposals for addressing them. 

9.3.  FIGHT AGAINST CORRUPTION 

The  operational  capacity  of  the  National  Authority  for  Transparency  has  been 
enhanced. In line with the initial timeline, the Authority plans to be fully operational by 

(60) Articles 359 and 360 of law 4700/2020 (OJ A/29.6.2020). 
(61) Articles 1 to 356 of above law.  
(62) Article 358 of above law.  

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November 2020. The awareness raising- pillar of the Authority’s portfolio, which was 
rather  under-developed  so  far,  is  being  strengthened.  The  Authority  is  joining  forces 
with line ministries on sectorial plans that include an awareness-raising component. For 
instance,  a  Memorandum  of  Cooperation  has  been  drafted  with  the  Ministry  of 
Education,  with  the  aim  of  developing  a  culture  of  integrity  and  accountability  in  the 
educational sector. The National Authority for Transparency has offered to the Ministry 
of Education a set of proposals for integrity awareness actions for students.  

The  National  Anticorruption  Plan,  monitored  by  the  Authority,  is  showing 
encouraging results. Under the 147 actions of the plan, 68 are reported as completed, 
74  are  on-going  and  5  are  pending.  A  recent  significant  step  concerns  activities 
coordinating the fight against corruption, where the authorities fully operationalised in 
June  2020  the  National  Coordinating  Body  for  Audit  and  Accountability  (ESOEL), 
which is chaired by the National Authority for Transparency. The coronavirus pandemic 
has  impacted  the  on-going  technical  support  and  the  timelines  of  49  actions  linked  to 
these  projects  will  need  to  be  updated (63).  The  National  Anticorruption  Plan  for 
2018-2021 is scheduled to receive an external appraisal in early 2021. The timeline for 
launching the tender for the appraisal is on track and the authorities intend to build on 
the results of this assessment when designing their next plurennial plan.  

The National Authority for Transparency is working with a view to strengthening 
the  internal  control  systems,  to  implementing  a  sound  national  integrity  system 
and  to  regulating  lobbying  activities.  In  collaboration  with  the  Ministry  of  Interior, 
the Authority is drafting a new law on internal control that should be finalised shortly 
(see  section  3.4).  Moreover,  a  Memorandum  of  Cooperation  was  signed  between  the 
Authority  and  the  Ministry  of  Interior  for  the  design  and  the  implementation  of  a 
complete  national  integrity  system.  The  Memorandum  includes  an  action  plan  and  a 
detailed  timeline  with  milestones  such  as  adopting  a  protocol  for  handling  cases  of 
corruption  before  end-September.  Its  implementation  would  be  a  crucial  improvement 
of the institutional framework for fighting against corruption. Finally, the absence of an 
effective  legal,  and  institutional  framework  specifically  addressing  lobbying  activities 
has led the National Transparency Authority to proceed with a draft proposal of a law 
that regulates lobbying activities that should be adopted before June 2021.  

Sectoral  anti-corruption  plans  are  being  developed  in  the  health  and  public 
procurement  sectors  and  usefully  complement  the  existing  set  of  sectorial 
anti-corruption actions. In the health sector, the authorities have set up a committee to 
review the existing legislation regarding corruption. The institutional framework is also 
under review with a view to drafting a new anti-corruption policy by end-October and to 
getting  tangible  results  by  the  end  of  the  year.  On  the  public  procurement  side,  the 
National Strategy on Public Procurement includes a set of anti-corruption and anti-fraud 
provisions and measures. The National Authority for Transparency’s role is to monitor 
the progress made through the review of the annual report published by the Independent 
Authority for Public Procurement, which is the competent authority for the design, the 
monitoring,  the  evaluation  and  the  update  of  the  strategy.  However,  the  National 
Authority  for  Transparency  will  participate  in  the  upcoming  revision  of  the  National 
Strategy  on  Public  Procurement,  which  is  expected  to  take  place  in  2021  (see  section 

(63) The authorities foresee that the projects will be delayed by a maximum of 6 months.  

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3.4).  The  timely  adoption  and  operationalisation  of  these  plans  are  expected  to 
contribute  to  the  efficient  management  of  funds,  including  from  the  Recovery  and 
Resilience Facility. 

The  authorities  have  started  to  upgrade  the  framework  for  the  management  of 
seized  or  frozen  assets.  A  Legislative  Committee  has  been  set  up (64)  to  further 
strengthen  the  institutional  framework  for  the  management  of  seized  and  confiscated 
assets.  However,  despite  the  existence  of  relevant  legislation,  there  is  no  centralised 
monitoring mechanism for the management of frozen or seized and confiscated assets. 
The authorities requested EU funding for a project that would strengthen and modernise 
the institutional framework through an integrated IT system. The implementation of the 
project  would  improve  the  coordination  and  the  cooperation  between  the  competent 
authorities, accelerate the processes, put an end to the duplication of responsibilities and 
improve the management of the recovered and confiscated assets. 

The  report  on  political  party  financing  for  the  year  2018  has  been  made  public 
and, for the first time, triggered imposition of fines to nine political parties. This is 
a major move forward towards increasing transparency in the political sphere. For 
the  first  time,  the  report  of  the  committee  in  charge  of  controlling  the  political  party 
financing delivered detailed information on the misappropriation that were investigated, 
including  the  names  of  the  parties,  the  exact  breaches  of  the  regulation  as  well  as  the 
amounts of public funds that were misused. The findings flagged in the report for year 
2017 have not been followed up in such a transparent manner: the committee detected in 
its  3  previous  reports  a  series  of  cases  where  state  funding  was  used  inappropriately. 
However,  the  authorities  reported  that  the  legal  framework  did  not  allow  them  to 
follow-up in the report published mid-2020. The work of the committee for 2019, which 
was  a  multiple  election  year,  has  been  delayed  due  to  the  coronavirus  pandemic  and 
should  began  by  October  2020,  in  line  with  the  legislation (65).  The  legislative 
framework of party financing has been flagged by the authorities as an additional area 
for legal codification. The European institutions encouraged the authorities to include it 
in  the  annual  codification  plan  for  2021  that  is  expected  to  be  adopted  by 
end-September 2020  (see  section 9.1).  Moreover,  the  authorities  are  encouraged  to 
report  on  the  legal  and  practical  difficulties  that  prevent  them  from  following  a  risk 
based approach when performing their controls  on the  asset  declarations  of politically 
exposed people.  

A committee is in charge of taking into account the recommendations of the Group 
of  States  against  Corruption  (GRECO)  but  the  project  is  likely  to  fall  behind 
schedule. A committee has been set up with a view to offering some amendments to the 
Criminal  Code  and  the  Criminal  Procedure  Code  that  would  take  on  board  the 
recommendations made by the Group of States against Corruption. However, according 
to the authorities, it is likely that the initial timeline (December 2020) will be impacted 
by  the  coronavirus  containment  measures.  It  is  expected  that  the  Committee  will 
produce some initial results around June 2021.  

(64) Joint Ministerial Decision 58506/4-6-2019. 
(65) Law 3023/2020. 

72 

 
                                                 
ANNEX 

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

Commitment 

State of play and next steps 

(*)  Fiscal.  Achieve  a  primary  surplus  of  3.5%  of  GDP  over  the 
medium-term. 

Public  financial  management.  Complete  the  cash  monitoring  and 
forecasting for the General Government Treasury account system. 

(*)  Arrears.  The  authorities  will  implement  the  arrears  clearance 
plan and avoid the accumulation of new arrears. 

74 

Taking  into  account  the  European  Commission’s  2020  summer  interim 
forecast  and  the  main  measures  adopted  since  May  2020  to  mitigate  the 
consequences of the pandemic, the primary deficit is currently expected at 
around  5.8%  of  GDP  in  2020.  These  projections  do  not  yet  include  the 
impact of the Council of State’s pension ruling from 14 July, neither the 
pending  ruling  of  the  Court  of  Auditors,  the  total  cost  of  which  is 
currently  estimated  at  0.8%  of  GDP.  A  full  update  of  the  fiscal  forecast 
will  be  prepared  in  the  context  of  the  assessment  of  the  2021  Draft 
Budgetary Plans. 

The  Treasury  Single  Account  system  is  operational  and  the  entities  that 
remain outside of the scheme are not significant in terms of total liquidity. 
The  Ministry  of  Finance  will  perform  an  assessment  of  the  entities’ 
compliance  with  the  liquidity  buffer  rules  by  end-October  2020,  which 
would  effectively  complete  this  part  of  the  specific  commitment.  The 
authorities  are  encouraged  to  set  up  dedicated  tools  for  the  close 
monitoring of entities  deemed to  be at  risk. By contrast,  progress  on the 
currently  running  cash-forecasting  pilot  has  suffered  delays  due  to  the 
coronavirus pandemic and will be reassessed in the next report  

In June 2020, the stock of arrears amounted to €1.5 billion, that is to say 
€667 million  above  the  targets  set  in  the  clearance  plan  adopted  in 
October  2019.  These  developments  only  partially  reflect  disruptions  in 
labour-intensive  processes  caused  by  the  pandemic.  The  authorities 

Commitment 

State of play and next steps 

Tax administration. Reach the agreed permanent staffing positions 
at the Independent Authority of Public Revenue (IAPR) of 12 500. 

Tax policy. Greece will undertake a nationwide valuation  exercise 
of  property  tax  value  based  on  market  values  and  will  update 
property  tax  values  for  ENFIA  and  other  taxes  fully  in  line  with 
market values. 

committed  to  update  their  plan  by  end-October  2020,  with  detailed 
information  regarding  the  clearance  of  the  additional  pension  backlog. 
Nevertheless, some crucial structural measures – including the automation 
of the processing and awarding of the new pensions claims as well as the 
digitalisation of the Single Social Security Fund (e-EFKA) – are reported 
to be broadly on track.  

Staffing levels at the end of the second quarter stood at 11 916, compared 
to 12 500 set as the target by end of 2019. Moreover, the authorities have 
adopted legal provisions that have resulted in staff from the Independent 
Authority being transferred to other bodies, thus making the achievement 
of  the  set  staffing  targets  even  more  difficult.  The  completion  of  the 
human  resources  reform,  expected  to  greatly  facilitate  the  Independent 
Authority’s capacity to attract and maintain the high calibre staff it needs, 
hinges  on  the  adoption  of  the  wage  grid  legislation.  The  European 
institutions encouraged the authorities to  adopt  it during the next  review 
period. 

The  authorities  have  restarted  work  towards  completing  the  nationwide 
reassessment  of  property  values,  which  serve  as  base  for  the  single 
property tax (ENFIA). The inevitable delays occurred  earlier in  the  year 
due to the coronavirus lockdown. The work of data collection and quality 
assessment, leading to the final determination of prices for existing value 
zones  is  expected  to  be  completed  by  the  end  of  the  year.  This  year’s 
ENFIA single property tax assessments will thus mainly be based on the 
previous property tax values. The further expansion of the existing value 
zone  system  across  the  entire  country  will  need  to  be  addressed  in  the 
course of next year with a rescheduled deadline of mid-2021.  

(*)  Health  care.  The  authorities  will  complete  the  full  offsetting 
and collection of the clawback by June every year for the previous 

The  rising  clawback  amounts  and  delays  in  its  collection  are  a  cause  of 
concern. The European institutions encourage the authorities to adopt the 

75 

 
 
Commitment 

calendar year. 

Health  care.  Greece  will  ensure  the  rollout  of  the  primary  health 
care  system,  in  particular  by  opening  all  240  primary  health  care 
units. 

Health  care.  Achieve  a  share  of  centralised  procurement  in  total 
hospital expenditure of 30%. 

State of play and next steps 

necessary legislation to finalise legislative and administrative procedures 
necessary for the start of collection by October 2020 – in order to preserve 
the fiscal credibility of the clawback – and to review the current definition 
of the clawback with a view to introducing a risk-sharing component and 
enhancing the incentives to avoid the creation of new clawbacks and curb 
supply-induced demand, thus reducing high out-of-pocket payments. 

The redesign of the primary health-care system will take a longer time to 
be  implemented,  to  reflect  changes  in  the  delivery  of  some  of  its  main 
elements  and  due to  inevitable delays caused by the need to  manage the 
response to the pandemic. Legislative changes are still at a drafting stage 
but  their  adoption  is  expected  by  spring  2021.  The  authorities  are 
encouraged  to  speed  up  the  implementation  of  compulsory  registration 
and gatekeeping, which – as agreed – should remain core elements of any 
new system as they are key for a successful establishment of a robust and 
well-functioning  system  of  primary  health  care.  The  authorities  plan  to 
resume  the  rollout  of  the  primary  health  care  network  no  earlier  than 
spring 2021, given the short-term need to focus the efforts on the response 
to the current challenge to increase the available number of family doctors 
contracted by Public Health Fund. 

 Centralised  procurement  is  already  being  partly  implemented  and  the 
overall set up of the National Health Authority for Health Procurements is 
progressing,  but  yet  to  be  completed  also  due  to  delays  caused  by  the 
pandemic.  Draft  legislation  to  define  the  new  legal  framework  for  the 
Authority was finalised and is planned for adoption by the end of the year. 
The  authorities  also  shared  an  operational  plan  for  procurements  to  be 
launched  in  2020,  according  to  which  the  target  of  40%  of  centrally 
procured  total  hospital  expenditure,  a  mid-2022  specific  commitment, 
remains  achievable  and  the  authorities’  aim  is  to  reach  30%  by  the  first 

76 

 
 
Commitment 

State of play and next steps 

quarter of 2021.  

Social welfare. Complete the rollout of all three pillars of the Social 
Solidarity Income scheme. 

During 2019, a pilot project to ensure the provision of social support and 
labour  market  activation  services  was  implemented  in  32  municipalities 
across the country. The findings of the pilot project have been evaluated 
in  view  of  its  national  implementation  in  2020.  However,  due  to  the 
coronavirus outbreak, there was a need to adapt the business processes of 
the public employment service (OAED) to the new situation and, in turn, 
to  adjust  the  terms  of  the  national  rollout  of  the  new  framework.  The 
rollout should be launched in autumn 2020. 

Social  welfare.  Review  the  system  of  subsidies  for  local  public 
transport. 

Social  welfare.  Complete  the  set-up  of  the  single  pension  fund 
EFKA. 

The  revised  primary  legislation  for  the  new  system  was  adopted  in  July 
2020.  Secondary  legislation,  to  be  adopted  in  September  2020,  is  under 
preparation  to  allow  a  regular  and  objectively-based  reimbursement  of 
subsidised  public 
in  Athens  and 
Thessaloniki. 

to  operators 

transport 

tickets 

The authorities are making progress in completing the setup of the Single 
Social  Security  Fund  (EFKA).  Among  others,  the  digital  transformation 
of the  Fund into  ‘e-EFKA’ is  expected to  be implemented by  end-2020. 
The  first  stage  of  merging  the  public  sector  and  supplementary  pension 
functions  has  already  been  implemented  and  the  physical  move  of 
employees, initially delayed by the pandemic, should be completed by the 
end  of  the  year.  Therefore,  the  commitment  is  rescheduled  to  end-2020. 
The  follow-up  steps,  including  the  establishment  of  certain  regional 
offices, should be completed by mid-2021.  

(*) Financial stability. Greece will continue to implement reforms 
aimed at restoring the health of the banking system, including non-
performing  loans  resolution  efforts  by  ensuring  the  continued 
effectiveness  of  the  relevant  legal  framework  (i.e.  household  and 

  The  authorities  intend  to  shortly  submit  a  bill  to  Parliament  that  will 
lead to  a major overhaul  of the insolvency framework. The code will 
enter  into  force  on  1 January  2021  and  will  require  the  adoption  of  a 
significant  amount  of  secondary  legislation,  which  will  determine 

77 

 
 
Commitment 

State of play and next steps 

corporate  insolvency,  out-of-court  workout,  non-performing  loans 
sales, e-auctions) and taking all necessary actions to this effect.  

some aspects of the reform and the completion of the IT platform, both 
of which are underway.  

  At  the  same  time,  the  authorities  allowed  the  expiry  of  the  Primary 
Residence  Protection  scheme  and  the  Out  of  Court  Workout  scheme, 
while  setting  up  alternative  social  protection  schemes  for  vulnerable 
debtors.  In  the  context  of  the  pre-bankruptcy  proceedings,  vulnerable 
debtors will be eligible for a temporary subsidy, which should further 
support 
the 
accumulation  of  new  ones.  Moreover,  the  code  introduces  a  special 
sale-and-leaseback  regime  allowing  eligible  distressed  debtors  to 
remain in their primary residence as tenants, who may further benefit 
from a subsidy to facilitate the payment of the rent.  

the  reduction  of  non-performing 

loans  and  avoid 

  The authorities will also submit shortly to Parliament measures that are 
aimed  at  accelerating  the  clearance  of  the  household  insolvency 
backlog,  which  has  increased  further  as  a  result  of  the  suspension  of 
court proceedings during the pandemic. 

  The  authorities  intend  to  adopt  a  number  of  measures  aiming  at 
enhancing  the  functionality  and  user-friendliness  of  the  e-auctions 
platform  and  facilitating  the  relevant  processes.  The  measures  are 
expected to be adopted in October 2020 and include the obligation for 
auction  officials  to  upload  a  copy  of  the  valuation  report  and 
photographs of the property on the e-auctions website. Other measures 
will  be  introduced  as  part  of  the  revision  of  the  Code  of  Civil 
Procedure. The conduct of e-auctions resumed on 1 September but the 
intention  is  to  suspend  them  for  vulnerable  debtors  until  the  end  of 
December  2020  in  view  of  the  entry  into  force  of  the  insolvency 
legislation and the associated social policy measures in January 2021.  

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  Regarding the clearance of the backlog of called state guarantees, the 
authorities  are  taking  actions  towards  fully  offsetting  any  pandemic-
related  delays,  while  committing  to  further  frontload  the  overall 
processing and payment schedule.  

  Work  on  the  adoption  of  targeted  amendments  to  the  Code  of  Civil 
Procedure  is  ongoing.  The  law-drafting  committee  is  expected  to 
submit  a  draft  of  the  legislation  by  end-January  2021,  in  view  of  the 
adoption  of  the  revised  code  by  end-February  2021,  with  a  projected 
entry into force in September 2021.  

  A targeted adjustment of the primary legislation on deferred tax credits 
to  ensure  operational  effectiveness  has  been  submitted  to  Parliament 
and is expected to be adopted shortly.  

The  authorities  have  completed  the  implementation  of  the  2017-2019 
action plan to 

fight undeclared work. 

In light of the coronavirus pandemic, the authorities decided in agreement 
with  the  social  partners  to  postpone  the  annual  update  of  the  statutory 
minimum wage, from June 2020 to January 2021. 

The  deployment  of  the  IT  system  to  support  the  investment  licensing 
framework  is  delayed  due  to  complications  in  the  tendering  process. 
Nonetheless, in absence of further appeals at courts, the authorities expect 
to sign the contract shortly. 

  The  implementation  of  the  inspections  framework  law  steadily 
progresses with respect to the agreed priority areas, even though some 

79 

Labour market. Implement action plan on undeclared work.  

(*) Labour markets, product markets and competitiveness.  

Investment  licensing.  Complete  the  investment  licensing  reform, 
and to this end fully deploy the relevant ICT. 

Investment licensing. Greece will finalise inspection legislation. 

 
 
Commitment 

State of play and next steps 

work remains  to  be completed. The European institutions  encouraged 
the  authorities  to  develop  a  timeline  for  completing  this  work, 
including the adoption of all necessary enabling legislation, by the time 
of the next report. The authorities committed to extend the framework 
to four remaining domains by end-2021. Its full deployment would be 
a  major  step,  as  it  would  reduce  the  necessity  for  ex-ante  controls 
without compromising health and safety standards.  

Investment  licensing.  Greece  will  finalise  the  simplification  of 
investment licensing procedures in the agreed remaining sectors. 

  The  simplification  of 

the 

investment 

licencing  procedures 

is 
progressing, albeit with some delays. The authorities adopted primary 
legislation for the simplification of the primary production sector and 
secondary  legislation  is  expected  shortly.  Proposals  for  simplification 
of most remaining sectors have been delivered, and primary legislation 
is  expected  to  be  adopted  shortly.  The  authorities  are  encouraged  by 
the time of the next report to develop a timeline for the adoption of all 
necessary  secondary  legislation  on  all  sectors,  as  well  as  for  the 
simplification of the few remaining activities. 

Investment licensing. Greece will revise the nuisance classification 
(a  mid-2021  specific  commitment,  the  authorities  aim  to  complete 
this action by mid-2020). 

The authorities successfully completed the commitment to revise/abolish 
the  nuisance  classification,  well  ahead  of 
the  mid-2021  specific 
commitment deadline. 

Cadastre.  Greece  will  fully  establish  the  cadastral  agency  and 
complete 45% of cadastral mapping. 

Implementation  of  the  recently  updated  roadmap  towards  completion  of 
the cadastre project has restarted, following delays due to the coronavirus 
outbreak. The collection of land rights has been completed for 82% of the 
country and the cadastral mapping has been completed for the 33% of the 
rights, below the target to complete 45% of rights. By October 2020, the 
cadastral mapping completion is expected to reach 35%. By end October 
2020,  six  additional  mortgage  offices  are  expected  to  be  abolished  and 
one  cadastral  office  (for  Thrace)  will  open.  All  remaining  forests  maps 

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will be uploaded by December 2020. 

Energy.  With  a  view  to  completing  reforms  in  the  energy  sector, 
implement  the  measures  agreed  as  part  of  the  joint  assessment  on 
the NOME auction system. 

The Greek government has continued to engage constructively on a set of 
proposals  to  remedy the anti-trust  case. The proposals should eventually 
be  submitted  for  a  market  test  by  the  European  Commission,  a  step  in 
view of implementing the remedy and closing the case.  

Energy. Launch the Target Model. 

(*) HCAP. The Strategic Plan of HCAP will be implemented on a 
continuous basis. 

Privatisation. The Asset Development Plan will be implemented on 
a continuous basis.  

With a view to swiftly attracting investment to support a sustained 
economic  recovery,  complete  the  transactions  on  Egnatia,  DEPA 
commercial,  regional  ports  of  Alexandroupoli  and  Kavala,  AIA 
shares, EYDAP and EYATH. 

The  final  date  for  the  go-live  of  the  Target  Model  for  electricity  is 
expected  to  be  announced  shortly  by  the  regulator.  This  followed  an 
assessment  of  the  energy  regulator  on  the  dry-run  period  to  test  the 
market,  which  concluded  a  small  delay  from  the  originally  planned  date 
of  17  September  would  be  necessary.  The  European  Institutions  will 
report on the long-awaited go-live of the Target Model in the next report.  

Despite the difficulties caused by the pandemic, the implementation of the 
strategic  plan  is  ongoing  and  a  draft  business  plan  for  2020-2022  was 
prepared  in  August  and  approved  by  the  Board  of  the  Corporation.  Key 
performance indicators, which monitor the implementation of the strategic 
plan,  have  recently  been  adjusted  to  take  into  account  the  impact  of  the 
pandemic, along with setting their values for 2021 and 2022. 

Progress with the transactions included in the Asset Development Plan of 
the  Hellenic  Republic  Asset  Development  Fund  (TAIPED)  has  been 
affected by the coronavirus outbreak but has resumed for most of them as 
from June. A regular update of the Asset Development Plan was approved 
by  the  Government  on  10  September.  Progress  with  due  specific 
commitments for transactions is as follows: 

Hellinikon:  The  authorities  remain  strongly  engaged  and  undertake 
necessary efforts to complete the prerequisites for the financial closing of 
the  transaction,  having  launched  the  demolition  of  current  buildings  on 

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the site, on the 3rd of July. The financial closing of the transaction is still 
pending  the  resolution  of  legal  cases  against  the  casino  licence  tender 
process and other judicial cases.  

  Marina  of  Alimos  concession:  The  Board  of  the  Fund  extended  on 
3 September the 120 days for another 50 days (until 30 October 2020) 
to allow adequate time for the completion of the transaction. 

  Hellenic  Petroleum:  Following  the  failure  of  the  first  tender  in  mid-
2019 and considering the significant fall in the capitalisation value of 
the  company,  the  Fund  considered  appropriate  to  delay  further  the 
launching of the transaction to a later point in time. 

  Sale of 30% of Athens International Airport: The tendering process 
was  proceeding  well  prior  to  the  coronavirus  outbreak,  with  nine 
investment  parties  qualified  to  proceed  to  the  Binding  Offers  Phase. 
However,  the  deadline  for  the  submission  of  binding  offers  was 
delayed due to the impact of the pandemic on the air transport sector. 
The Fund will determine next steps once the situation improves, likely 
not before 2021.  

  Public  Gas  Corporation 

(DEPA):  The 

for  DEPA 
Infrastructure and DEPA Commercial, launched in December 2019 and 
January 2020 respectively, attracted strong investment interest. In June 
2020, the Board of the  Fund decided to  proceed to  the binding offers 
phase for both transactions. 

tenders 

  Egnatia:  The  privatisation  process  continued,  although  with  mixed 
progress.  Some  of  the  open  issues  have  been  resolved,  such  as  the 
uncertainty on the construction of the motorist service stations and the 
rehabilitation  cost  of  bridges  classified  as  unsafe.  However,  very 

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Public  administration.  Complete  the  integrated  HR  Management 
System  (digital  organigram  for  all  public  entities  and  link  with 
single payment authority). 

Legal codification. In view of enhancing legal certainty and access 
to  law through legal  codification, adopt  the  Labour  Law Code and 
Code of Labour Regulatory Provisions. 

limited  progress  has  been  made  over  the  last  three  months  on  the 
completion  of  the  construction  of  the  remaining  toll  stations  and  the 
required works  so that the remaining 14 tunnels can be licensed. The 
European 
to  significantly 
the  authorities 
advance on these areas by the time of the next report.  

institutions  encourage 

  Regional  Ports:  Following  a  delay  due  to  the  pandemic,  the  Fund 
decided in June to proceed with the launching of the tender process for 
the sale of shares for the ports of Alexandroupolis and Igoumenitsa and 
the sub-concession of a multi-purpose terminal for the port of Kavala.  

Good progress has been made during this review period in developing the 
Human Resources Management System. The process has been affected by 
the confinement measures due to the pandemic but overall good progress 
has  been  made.  Until  August  2020,  over  1 500  general  government 
entities had completed their digital organigram, representing around 80% 
of all entities and 85% of personnel, including most of the large entities. 
A majority of the remaining larger entities are set to be completed by end-
October  2020.  The  link  between  a  job  description  and  a  jobholder  has 
been  established  for  around  75%  of  posts  and  the  authorities  plan  to 
establish this link for all posts for general government entities by the end 
of 2020. 

The  coronavirus  pandemic  has  slightly  delayed  the  adoption  of  the  re-
codified  Labour  Law  Code  and  Code  of  Labour  Regulatory  Provisions. 
The  authorities  plan  to  adopt  the  laws  by  November  2020.  The 
codification  process  is  used  as  an  opportunity  to  review  and  modernise 
some areas of the labour legislation, including new forms of work and the 
role of the labour inspectorate, which is most welcome. 

Justice. In the context of implementing the Three-Year Action Plan  Work  on  the  transition  to  mandatory  electronic  filing  and  processing  of 

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on  Justice,  implement  the  electronic  filing  of  legal  documents 
throughout the Courts, having completed the tendering procedure. 

Justice. In the context of implementing the Three-Year Action Plan 
on  Justice,  complete  phase  II  of  the  establishment  of  the  e-justice 
system (OSDDY-PP). 

documents  is  ongoing.  The  tasks  due  for  completion  by  the  end  of 
September  2020  include  the  consolidation  of  a  number  of  insolvency-
related  certificates  and  the  issuance  of  electronic  criminal  record  and 
divorce  certificates.  In  parallel,  efforts  are  underway  to  implement  a 
mechanism for the distribution of digital signatures.  

The tender procedure for the second phase of the Integrated Judicial Case 
Management  System  is  now  scheduled  to  be  completed  by  December 
2020.  The  procedure  was  extended  due  to  disruptions  caused  by  the 
coronavirus  pandemic.  Following  the  submission  of  bids,  the  authorities 
are  in  the  process  of  evaluating  the  offers.  Completion  of  the  project  is 
foreseen within 36 months from the signature of the contract. 

Complementary commitments undertaken by Greek authorities in May 2020  

Complementary commitment 

State of play and next steps 

improvements 

Better  regulation.  Achieve 
the  regulatory 
framework for doing business in  the areas of construction permits, 
obtaining  access  to  electricity,  registering  property,  resolving 
insolvency,  accessing  credit,  protecting  minority 
investors, 
contracting  with  the  government,  enforcing  contracts,  starting  a 
business, paying taxes, and trading across borders by mid-2021. 

in 

Registration through the electronic one-stop shop has been made mandatory 
for  most  private  companies,  whilst  the  framework  for  the  protection  of 
minority  investors  was  strengthened  through  a  number  of  safeguards 
concerning the selection, appointment and evaluation of board members, and 
increased disclosure requirements. 

Labour law. Improve and modernize the framework for individual 
labour  law,  including  tackling  the  issues  of  highly  restrictive 
sectoral  differentiation,  white 
overtime 
collar/blue  collar  rules,  and  take  account  of  flexible  and  home 
working,  as  well  as  implement  these  measures  through  secondary 

rules,  unnecessary 

The  coronavirus  pandemic  has  slightly  delayed  the  adoption  of  the  re-
codified Labour Law Code and Code of Labour Regulatory Provisions. The 
authorities  plan  to  adopt  the  laws  by  November  2020.  The  codification 
process is used as an opportunity to review and modernise some areas of the 
labour  legislation,  including  new  forms  of  work  and  the  role  of  the  labour 

84 

 
 
 
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legislation, by September 2020. 

State of play and next steps 

inspectorate, which is most welcome. 

Justice.  Introduce  an  action  plan  for  the  creation  of  specialized 
court  chambers  for  specific  categories  of  cases  to  improve  the 
delivery  of  justice,  particularly  in  areas  of  high  economic  impact, 
and introduce the adequate legislation by mid-2020. 

The  authorities  adopted  legislation  for  the  creation  of  specialised  chambers 
in civil and administrative courts and are proceeding with a number of other 
important  initiatives.  A  full  report  on  the  application  of  said  legislation  is 
expected by end-October 2020. 

Justice.  Enact  the  new  Code  of  Judicial  Staff  and  present  a 
timetable for the adoption of the New Code for the Organization of 
Justice and the Status of Officers of the Courts by May 2020. 

The authorities are proceeding with the adoption of the Code of Judicial Staff 
and the Code on the Status of Judges and the Organisation of Courts, all of 
them introducing revisions that should contribute to  enhancing the function 
of justice and the success of other justice reforms.  

Justice.  Present  an  action  plan  for  the  Creation  of  a  specialized 
‘JustStat’  unit  for  data  collection  and  processing  to  measure  and 
improve  the  performance  of  the  judicial  system  by  mid-2020; 
introduce the relevant legislation by June 2020. 

The authorities adopted legislation for the creation of the ‘JustStat’ unit for 
collection  of  statistical  data  in  June  2020  and  plan  to  draft  the  relevant 
secondary legislation by December 2020. 

Justice. Present an action plan for the implementation of mediation 
legislation by mid-2020. 

Mandatory mediation is  fully in  force as of 1 July  2020 and  an action plan 
detailing the deployment of relevant activities is due by November 2020. 

Public  administration.  Strengthen  the  efficiency  of  the  personnel 
selection  system  through  improving  the  capacity  of  the  Supreme 
Council for Civil Personnel Selection (ASEP), including in the areas 
of  competition  procedures,  scoring  classification  procedures, 
temporary staff hiring procedures, and the Council’s organisation by 
end-2022.  

A  capacity-enhancing  reform  of  the  Supreme  Council  for  Civil  Personnel 
Selection (ASEP) is set to be adopted in November 2020. 

Public  administration. Strengthen the hiring control of the public 
sector through setting an annual  ceiling of temporary staff by end-
2020, which will be applied from 2021. 

The authorities are carrying out a comprehensive analysis of temporary staff, 
which  is  expected  to  be  completed  by  October  2020,  with  a  view  to 
removing  posts  of  a  permanent  nature  and  plan  to  set  an  annual  ceiling  on 

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Transport.  Adopt  and  implement  the  National  Transport  Master 
Plan  and  establish  a  priority  list  of  projects  for  railways  by 
June 2020.  

the 

legal  framework  for  approving 

Transport.  Revise 
the 
sustainable  urban  mobility  plans  according  to  best  European 
practices by September 2020. Following this revision, report on the 
progress  of  the  elaboration  of  sustainable  urban  mobility  plans  for 
the main urban centres by October 2020. 

temporary staff by end of the year. 

The National Transport Master Plan has been completed and approved by the 
Ministry  of  Infrastructure  and  Transport.  The  authorities  have  prepared  a 
pipeline of railway projects in order to remedy the delays encountered on the 
implementation  of  the  2014-20  transport  and  environment  operational 
programme.  

In  progress.  This  action  will  be  assessed  in  the  8th  enhanced  surveillance 
report. 

Management  of  public  real  estate.  Draw  up  a  holistic  and 
coherent  strategy  aiming  to  optimize  the  protection,  management 
and investment-oriented exploitation of public real estate, including 
all  organizations  involved  with  public  real  estate  management, 
without prejudice to their mandates, by September 2020. 

Strategic  project  pipeline.  Fully  develop  a  Strategic  Project 
Pipeline of large infrastructure projects with the objective to better 
coordinate  and  monitor  future  public  expenditures  and  maximize 
complementarities  between  private,  public  and  EU  funded  projects 
by January 2021. 

The authorities intend to proceed with a comprehensive study that will help 
them  in  the  elaboration  of  the  holistic  and  coherent  strategy  aiming  to 
optimise the protection, management and investment-oriented exploitation of 
public real estate. 

The  characteristics  and  role  of  the  Strategic  Project  Pipeline  as  well  as  a 
timetable for its implementation were agreed in July 2020. It will be set up as 
an  independent  unit  coordinated  by  the  Presidency  of  the  Government  and 
will deal with priority infrastructure projects worth over €10 million. 

Project  preparation  facility.  Develop  and  fully  operationalize  an 
improved  support  and  delivery  mechanism  for  project  preparation 
and implementation to ensure efficiency and quality of both public 
sector infrastructure projects  as well as Public Private Partnerships 

The  authorities  are  setting  up  the  Project  Preparation  Facility,  which  will 
help  the  preparation  and  implementation  of  the  projects  included  in  the 
Strategic  Project  Pipeline.  Its  placement  and  details  are  currently  being 
worked out.  It will be important to ensure that its placement safeguards the 

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by March 2021. 

rights and competencies of established independent institutions. 

Public procurement. Adopt a new public procurement strategy for 
2021–2025 by end 2020. 

E-Health.  Develop  an  electronic  Medical  Health  Record  to 
streamline the use of existing electronic medical record applications 
and  update  as  necessary  the  design  and  use  of  agreed  electronic 
medical  record  standard  across  public  (and  private)  healthcare 
institutions by end-2020. 

E-Health.  Extend  the  application  of  the  electronic  prescription 
project  (2nd phase), including through therapeutic protocols, back-
end  integrations,  artificial  intelligence  driven  inquiries,  necessary 
interconnection  with  information  systems,  and  enabling  electronic 
request  and  access  to  medicine  for  all  outpatients  with  chronic 
diseases by end-2020. 

E-Health.  Enable  the  provision  of  remote  health  care  through  the 
expansion  of  the  capacity  of  the  existing  telemedicine  network  by 
end-2020. 

The  authorities  are  preparing  a  legislative  amendment  to  address  the  most 
urgent issues in public procurement and have taken initial steps towards the 
adoption  a  new  public  procurement  strategy  for  2021-2025  that  would 
contribute to a more sustainable and efficient use of public resources. 

The  Ministry  of  Health  has  revised  its  digital  strategy  and  progressed  on 
issues such as the design of the national e-health interoperability framework, 
with  technical  support provided through the European Commission,  and on 
the digital health action plan. 

In  progress.  This  action  will  be  assessed  in  the  8th  enhanced  surveillance 
report. 

Telemedicine has been strengthened both on the side of consultations and on 
that  of  prescriptions,  to  ensure  access,  while  avoiding  any  unnecessary 
contact  between  potentially  infected  patients  and  other  patients  and/or 
health-care staff. 

Health  care  strategy.  Develop  a  National  strategic  policy 
framework for healthcare by end-2020. 

In  progress.  This  action  will  be  assessed  in  the  8th  enhanced  surveillance 
report. 

Health  care  planning.  Map  health  and  long-term  care  needs  with 
available  human  and  technical  resources,  and  take  measures  to 
ensure  the  efficiency,  sustainability,  accessibility  and  affordability 

In  progress.  This  action  will  be  assessed  in  the  8th  enhanced  surveillance 
report. 

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State of play and next steps 

of  health  and  long-term  care  services,  as  well  as  promote 
community-based services, by end 2020. 

Education.  Enhance 
the  autonomy  of  higher  education  by 
strengthening  the  accountability  and  transparency  framework  and 
through the introduction of the University Council by end-2020. 

Education. Improve vocational education through the establishment 
of  the  National  System  of  Vocational  Education  and  Training  by 
end-2020. 

Introduce 

Education. 
evaluations, 
internal 
institutionalize  external  assessment  of  schools,  and  design  new 
curricula for all subjects across all school levels by end-2021. 

school-unit 

E-governance.  Develop  the  single  digital  portal  (gov.gr)  to 
integrate all electronic transactions for citizens and businesses with 
the  state  and  related  information,  unify  the  legal  framework  on 
digital  policy,  and  safeguard  business  continuity  by  ensuring 
sufficiency of digital infrastructure mid-2021. 

In  progress.  This  action  will  be  assessed  in  the  8th  enhanced  surveillance 
report. 

A comprehensive vocational education and training reform is currently being 
developed. It aims at enhancing the quality of education offered, increasing 
the  percentage  of  students  choosing  this  path  and  better  linking  vocational 
education and lifelong learning with labour market needs. 

The authorities adopted a public school reform in June 2020. The Upgrading 
Public  Schools  bill  aims,  among  others,  at  promoting  soft  skills,  digital 
literacy, foreign language learning and the evaluation of school units. 

The  public  portal  gov.gr  offers  by  now  some  610  services,  more  than  110 
more since the last review, and some 40 new services are in the pipeline. The 
authorities  prepared  a  comprehensive 
the  portal’s 
implementation by end-2021. A new Code of Digital Governance, to create a 
comprehensive legal framework on digital policy is expected to be adopted 
shortly.  The  authorities  are  preparing  the  relevant  tender  procedures  to 
ensure business continuity. 

roadmap 

for 

E-governance.  Implement  the  National  Programme  for  Process 
Simplification in  key policy areas  and promote the interoperability 
of registries, data and IT systems to ease the administrative burden 
for businesses and citizens by end-2021. 

The  authorities  have  completed  the  set  up  for  the  National  Programme  for 
Process  Simplification,  which  aims  to  ease  the  administrative  burden  for 
citizens and businesses. 

Digitisation  of  geospatial  data.  Develop  a  State  Infrastructures 
Registry  to  encapsulate  technical  and  geospatial  information  about 

The  authorities  have  completed  the  first  steps  for  the  digitisation  of 
geospatial  data.  The  authorities  delivered  a  two-year  action  plan  for  the 

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all  public  infrastructure  projects  to  enable  better  planning  and 
management  of  these  projects,  including  for  construction  and 
maintenance purposes by end-2021. 

Digitisation  of  geospatial  data.  Develop  an  Integrated  Geospatial 
Data Mapping tool (Single Digital Map) to increase transparency to 
investors  concerning  land  use  rules  across  Greece  and  reduce 
unpredictability in relation to investment licensing decisions by end-
2021. 

development  and  pilot  implementation  of  the  State  Infrastructures  Registry 
and 
the 
development and oversight of this project. 

to  define  responsibilities  for 

issued  secondary 

legislation 

The  authorities  have  prepared  a  two-year  action  plan  for  the  creation  and 
pilot implementation of the Single Digital Map. 

89