COMMISSION STAFF WORKING DOCUMENT 2020 Rule of Law Report Country Chapter on the rule of law situation in Greece Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2020 Rule of Law Report The rule of law situation in the European Union
Date: 2020-09-30
Institutions: European Commission, Secretariat-General
Subjects: Greece, administrative transparency, coronavirus disease, corruption, democracy, epidemic, independence of the judiciary, infringement of EU law, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.9.2020  SWD(2020) 307 final  COMMISSION STAFF WORKING DOCUMENT 2020 Rule of Law Report  Country Chapter on the rule of law situation in Greece Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS  2020 Rule of Law Report       The rule of law situation in the European Union {COM(2020) 580 final} - {SWD(2020) 300 final} - {SWD(2020) 301 final} - {SWD(2020) 302 final} - {SWD(2020) 303 final} - {SWD(2020) 304 final} - {SWD(2020) 305 final} - {SWD(2020) 306 final} - {SWD(2020) 308 final} - {SWD(2020) 309 final} - {SWD(2020) 310 final} - {SWD(2020) 311 final} - {SWD(2020) 312 final} - {SWD(2020) 313 final} - {SWD(2020) 314 final} - {SWD(2020) 315 final} - {SWD(2020) 316 final} - {SWD(2020) 317 final} - {SWD(2020) 318 final} - {SWD(2020) 319 final} - {SWD(2020) 320 final} - {SWD(2020) 321 final} - {SWD(2020) 322 final} - {SWD(2020) 323 final} - {SWD(2020) 324 final} - {SWD(2020) 325 final} - {SWD(2020) 326 final}  
 
 
ABSTRACT 

Greece  has  adopted  a  significant  number  of  justice  reforms  initiated  in  the  context  of  the 
three  economic  adjustment  programmes.  Reform  activities  included  changes  in  the 
organisation of courts, measures to improve the management of courts, the broadening of the 
use  of  information  technology  tools  in  courts  and  the  promotion  of  alternative  dispute 
resolution  mechanisms.  However,  the  implementation  record  shows  mixed  results  and  the 
justice  system  continues  to  face  challenges  as  regards  its  quality  and  efficiency.  Ongoing 
efforts  to  ensure  the  effective  implementation  of  the  recent  reforms  and  further  progress  in 
the  digitalisation  of  the  justice  systems  are  particularly  important  for  achieving  concrete 
results. 

Greece embarked on a wide range of anti-corruption reforms in the past years and continues 
implementing  a  comprehensive  national  anti-corruption  plan.  Efforts  have  been  made  to 
streamline  the  institutional  framework  and  improve  coordination  of  various  agencies  and 
bodies tasked with fighting corruption. A modern legal framework for asset declarations and 
political  party  financing  is  in  place,  but  implementation  still  shows  some  gaps.  Some 
obstacles to the prosecution of high-level corruption were eliminated by way of constitutional 
review  in  2019,  as  procedures  regarding  immunity  regimes  and  statutes  of  limitation  were 
modified.  A  revision  of  the  criminal  legislation  in  June  2019  raised  a  number  of  concerns, 
most notably as regards the criminalisation of bribery. While subsequent revisions remedied 
this  situation,  ongoing  cases  remain  affected.  Lobbying  in  Greece  remains  largely 
unregulated and the whistle-blower protection framework is incomplete. 

The Constitution provides for the protection of freedom of expression and the right to access 
public  information.  Structures  to  ensure  media  pluralism  and  press  rights  are  in  place. 
However,  some  questions  exist  with  regard  to  the  effectiveness  of  rules  geared  at  ensuring 
transparency of media ownership. Key concerns relate to insufficient mechanisms to ensure 
respect  for  professional  standards  in  the  practice  of  journalism,  and  precarious  working 
conditions  for  journalists  resulting  from,  among  other  things,  the  economic  and  financial 
crisis. 

The system of checks and balances in Greece has been facing some challenges in practice. In 
particular, the process for enacting laws has been under considerable pressure in past years, 
mainly  due  to  the  consequences  of  the  economic  and  financial  crisis.  Better  regulation 
principles were not fully adhered to, but recent comprehensive legislation in this field aims at 
addressing  these  challenges  and  is  gradually  being  implemented.  Fundamental  and 
constitutional rights are protected through the courts and independent authorities. There is no 
specific  enabling  framework  for  civil  society  in  Greece,  and  there  are  civil  society 
organisations  active  in  the  field  of  migration  which  have  expressed  concerns  that  the  civic 
space to operate on the ground has narrowed. 

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I.   JUSTICE SYSTEM  

The court system in Greece is based on the separation between the ordinary civil and criminal 
courts  and  the  administrative  courts.  There  are  no  distinct  commercial,  labour,  financial  or 
social  security  courts.  Such  cases  all  fall  under  the  normal  jurisdiction  of  civil  or 
administrative courts. Civil courts are organised into 154 magistrate courts, 63 courts of first 
instance, 19 courts of appeal and the Supreme Court, which is a court of cassation. Criminal 
courts  are  organised  into  41  courts  for  less  serious  offences,  63  courts  of  first  instance,  19 
courts  of  appeal  and  the  Supreme  Court.  Administrative  courts  are  organised  into  30 
administrative  courts  of  first  instance,  9  administrative  courts  of  appeal  and  the  Council  of 
State.  The  Greek  Constitution  also  foresees  a  certain  number  of  special  courts1.  Special 
departments  have  been  established  in  some  courts  for  specific  matters,  e.g.  on  maritime 
disputes  and  on  trademark  and  intellectual  property  disputes.  The  Court  of  Auditors  has  a 
dual nature, acting partly as a court and partly as an administrative authority entrusted with 
auditing public accounts2. There is no formal Constitutional Court and all Greek courts have 
competence  to  review  the  constitutionality  of  laws.  Judges  and  prosecutors  form  a 
consolidated  body  of  “magistrates”  subject  to  a  system  of  recruitment,  career,  rights  and 
obligations, which is largely homogeneous for all. The Greek system is exclusively composed 
of  career  judges  and  prosecutors.  They  are  appointed  to  civil  and  penal  jurisdictions  or  to 
administrative  courts.  As  regards  prosecution  authorities,  they  are  organised  into  63 
prosecution  offices  at  the  courts  of  first  instance,  19  prosecution  offices  at  the  courts  of 
appeal  and  the  General  Prosecutor  of  the  Supreme  Court.  Additionally,  there  is  also  a 
Prosecutor  for  Economic  and  Financial  Crime  and  a  Prosecutor  for  Corruption  Offences. 
There are 63 bar associations in Greece, one at the seat of each court of first instance. 

Independence 

The three branches of the judiciary enjoy a high level of self-administration. There are 
three  supreme  judicial  councils,  one  for  each  of  the  main  branches  of  the  judiciary3.  The 
executive  and  legislature  are  not  represented  in  the  composition  of  these  bodies4.  These 
councils  decide  on  appointments,  promotions,  transfers  and  secondments  of  judges  in  the 
respective  branches  of  the  judiciary  and  prosecutors,  as  far  as  the  Judicial  Council  of  Civil 
and  Penal  Justice  is  concerned.  As  regards  the  most  senior  positions  of  judges  and 

1   European e-Justice Portal, Judicial systems in Member States – Greece. 
2   The  Court  of  Audit,  one  of  the  three  Supreme  Courts,  has  exclusive  jurisdiction  to  audit  the  State 
expenditures  and  related  cases,  for  example  the  cases  arising  from  the  audit  of  the  unjustified  growth  of 
assets of the persons liable to asset declaration (Referred to in Art. 1 of law 3213/2003)  and charge to the 
detriment of those responsible. 

3   Special courts established in accordance with the Constitution may also have their own judicial council. 
4   The  composition  of  the  three  supreme  judicial  councils  (SJC,  one  for  civil  and  criminal  justice,  one  for 
administrative justice and one for the Court of  Audit)  are composed by the president of  the relevant court 
(Supreme Court, Council of State and Court of Audit respectively) and members of that court selected by the 
drawing of lots, as well as two judges from the relevant branch of the judiciary (with no right of voting); in 
addition,  regarding  the  SJC  for  civil  and  criminal  justice,  it  also  includes  the  prosecutor  and  two  vice-
prosecutors  of  the  Supreme  Court,  while  the  SJCs  for  administrative  justice  and  for  the  Court  of  Audit 
include  the  General  Commissioner  of  the  State  serving  at  the  Council  of  State  and  the  one  serving  at  the 
Court of Audit respectively (see article 90(1)-(4) of the Constitution, read in connection with articles 67, 72 
and 78 of the law 1756/1988 - Code on the Organization of courts and the status of magistrates. Enhanced 
formations  of  above  councils  are  foreseen  with  regard  to  promotions  to  senior  posts,  i.e.  at  the  Supreme 
Court (judges and prosecutors), the Council of State and the Court of Audit (for the posts of Councillor and 
of  the  General  Commissioner)  and  at  the  Court  of  Appeal  (for  the  posts  of  section  presidents  and 
prosecutors).  

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prosecutors in Greece, such as the President and Vice-President of the Council of State or the 
Supreme  Court,  the  Greek  Constitution  stipulates  that  appointments  are  effected  by 
presidential decree, following a proposal by the Council of Ministers. This has been subject 
to some criticism by the Council of Europe's Group of States against Corruption (GRECO), 
but so far Greece has not amended the relevant framework5. A change in the selection method 
would  also  require  a  constitutional  revision,  given  that  the  manner  of  appointment  to  the 
courts in question is prescribed by the constitution6.  

The level of perceived judicial independence is average. Among the general public, 53% 
consider judicial independence to be fairly and very good, a share which has been decreasing 
in the recent years. The corresponding figure among companies is 51% and has been stable7.  

Quality 

A  significant  number  of  reforms  have  been  initiated  in  the  context  of  the  economic 
adjustment programmes in the past years, but the implementation record shows mixed 
results.  Reform  activities  included  inter  alia  the  following  changes  in  the  organisation  of 
courts:  the  reduction  of  the  number  of  magistrate  courts,  measures  to  improve  the 
management of courts and to  accelerate the  administration of justice, the broadening of the 
use  of  information  technology  (IT)  tools  in  courts8,  the  introduction  and  promotion  of 
alternative  dispute  resolution  mechanisms,  the  revision  of  codified  legislation  of  major 
importance9,  as  well  as  embarking  on  reforming  and  consolidating  the  complex  legislative 
framework10. However, reform implementation has had a mixed record so far. A number of 
challenges  remain,  such  as  the  lack  of  availability  of  online  information  about  the  judicial 
system  to  the  general  public,  the  lack  of  arrangements  for  machine-readable  judicial 
decisions,  or  the  absence  of  surveys  conducted  among  court  users  or  legal  professionals11. 
Improvements  have  been  registered,  however,  for  example  as  regards  the  availability  of 
means to submit cases electronically or to monitor the different stages of proceedings, and the 
promotion  of  and  incentives  for  using  alternative  dispute  resolution  methods12.  The 
authorities also reported positive trends as regards the uptake of mediation in commercial and 
family/parental disputes13. As regards resources, the general expenditure of the Government 
for the justice system seems to almost exclusively cover wages and salaries14. 

5   GRECO Fourth Evaluation Round - Compliance Report, para. 57, where it is considered that these positions 
are  subject  to  a  potentially  strong  influence  of  the  executive  and  recommended  to  revise  the  method  of 
selection concerning the most senior positions of judges and prosecutors to involve the peers in the process. 
6   Constitution of Greece, Article 90(5). In February 2019, the Parliament rejected a revision of this provision. 
7   Figures 44 and 46, 2020 EU Justice Scoreboard. The level of perceived judicial independence is categorised 
as  follows:  very  low  (below  30%  of  respondents  perceive  judicial  independence  as  fairly  good  and  very 
good); low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%). 
8   Technical  support  is  being  provided  by  the  European  Commission  under  the  Structural  Reform  Support 
Programme to the Greek Ministry of Justice as regards the improvement of the courts administration and the 
modernisation of the system for the evaluation and promotion of judges. 

9   Code  of  Civil  Procedure,  Code  of  Criminal  Procedure,  Code  of  Administrative  Processes,  Code  of 
Administrative  Procedure,  Statute  on  the  Court  of  Audit,  Rules  of  Procedure  of  the  Court  of  Audit,  Penal 
Code,  Insolvency  Code,  Code  for  the  Administration  of  Justice  (ongoing)  and  the  Status  of  Magistrates 
(ongoing), Code of Judicial Employees (ongoing). 

10   For further detail, see European Commission, Country Report Greece 2019, SWD(2019) 1007 final, pp. 57 -

58; Country Report Greece 2020, SWD(2020) 507 final, p. 62. 

11   Figures 22, 29, 31, 41, 2020 EU Justice Scoreboard. 
12   Figures 27, 30, 2020 EU Justice Scoreboard. 
13   Information received in the context of the country visit to Greece. 
14   Figure 34, 2020 EU Justice Scoreboard. 

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In  the  context  of  the  COVID-19  pandemic,  Greece  has  made  efforts  to  accelerate  the 
digitalisation  of  the  public  administration15.  In  May  2020,  the  Ministry  of  Justice,  in 
cooperation  with  the  Ministry  of  Digital  Governance,  made  available  the  digital/electronic 
issuance  of  15  certificates,  such  as  different  certificates  in  the  field  of  inheritance16  and 
commercial law, through the existing network of Citizen Service Centres. It also unified 20 
insolvency law-related certificates into a single one, electronically available from the General 
Commercial Registry.  

The authorities recently launched an initiative of creating specialised chambers in civil 
and administrative courts. The new chambers would deal with specific categories of cases, 
such  as  cases  involving  claims  for  damages  based  on  the  transgression  of  national  and  EU 
legislation  on  electronic  communication,  energy  and  the  protection  of  personal  data17.  A 
debate about a more systematic reform of the judicial map to better take account of current 
demographics,  developments  in  information  and  communication  technology  and  other 
relevant parameters is ongoing among members of the legal community18. 

Efficiency 

The justice system continues to face challenges as regards its overall efficiency. Judicial 
statistics show that in particular the civil court system continues to face efficiency challenges, 
as  the  time  needed  to  resolve  litigious  civil  and  commercial  disputes  in  first  instance  has 
increased  again  (559  days  in  2018  compared  to  479  days  in  2017)19.  In  addition,  the 
productivity of first instance courts is falling as regards the clearance rate for litigious civil 
and  commercial  cases  (86.3  %  in  2018  compared  to  96.0  %  in  2017)20,  which  means  that 
Greece is facing a clear risk of building up new backlogs21. Stakeholders identified a range of 
procedural  challenges,  which  the  reformed  Code  of  Civil  Procedure  sought  to  address,  but 
which persist to this day. For instance, these challenges concern the duration of litigious civil 
and  commercial  proceedings  or  enforcement  proceedings.  An  implementation  report  on  the 
Code  of  Civil  Procedure  is  ongoing  and  a  number  of  recommendations  have  already  been 
formulated22.  Stakeholders  reported  that  criminal  justice  also  faces  similar  problems  and 
extensive  delays  in  processing  cases23.  The  administrative  branch  of  courts  continues  to 
improve its performance, maintaining a high resolution rate (163.5% in 2018), reducing the 
time  needed  to  resolve  administrative  disputes  in  first  instance  and  lowering  existing 
backlogs  by  resolving  more  cases  than  are  incoming24.  However,  both  the  time  needed  to 

15   Greece did not impose a state of emergency in the context of COVID-19 pandemic. 
16   Communique of the Ministry of Justice of 25 May 2020.  
17   European Commission, Enhanced Surveillance Report May 2020, pp. 28 and 106. 
18   Pikrammenos,  ‘Judicial  territorial  planning:  a  choice  of  the  legislator  with  a  major  import  for  the  judicial 
system’, in: ‘Justice in Greece’, Dianeosis 2019 (‘Δικαστική Χωροταξία: επιλογή του νομοθέτη με μείζονα 
σημασία για το δικαστικό σύστημα', στο συλλογικό έργο ΄Η Δικαιοσύνη στην Ελλάδα’, Διανέοσις 2019).  

19   Figure 6, 2020 EU Justice Scoreboard. 
20   Figure 11, 2020 EU Justice Scoreboard. 
21   Figures 11 and 14, 2020 EU Justice Scoreboard. 
22   European Commission, Enhanced Surveillance Report May 2020, Institutional Paper Series 127, p. 73. 
23   Contribution  from  the  Transparency  International  for  the  2020  Rule  of  Law  Report,  p.  11.  According 
information received in the context of the country visit to Greece, this regularly causes that misdemeanour 
cases  are  terminated  by  ad-hoc  legislative  measures,  leading  to  de  facto  impunity  for  a  wide  range  of 
misdemeanours (see e.g. Article 63 of law 4687/2020, for a recent example of this practice). 

24   Figures 12, 8, 15, 2020 EU Justice Scoreboard. 

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resolve administrative cases in first instance (601 days in 2018) and the number of pending 
cases remain comparatively high25. 

II. ANTI-CORRUPTION FRAMEWORK 

Greece  has  set  up  a  comprehensive  anti-corruption  strategic  framework,  the  National  Anti-
Corruption Action Plan (NACAP). The National Transparency Authority, which oversees the 
implementation of the Plan, was established in 2019 with a view to improve cooperation and 
coordination  among  different  audit  authorities  and  inspection  bodies.  In  the  past  years,  the 
country undertook a number of steps to revise its anti-corruption legal framework. The most 
recent  Constitutional  review  in  2019  modified  the  immunity  regime  for  Members  of 
Parliament and Ministers. Several anti-corruption laws that were revised in recent  years are 
currently  being  implemented,  such  as  in  the  area  of  party  financing  and  asset  declarations. 
Regarding  the  latter,  an  online  system  for  submitting  declarations  is  now  fully  operational. 
The  whistle-blower  protection  regime  is  currently  under  discussion.  Lobbying  remains 
unregulated. 

Whereas  Greece scored 36/100  in 2012 on the Transparency International  Corruption 
Perceptions Index, its score increased to 48/100 in 201926, placing Greece 17th in the EU 
and 60th globally. 95% of the respondents to the latest Eurobarometer survey on corruption 
think that corruption is widespread in their country (EU average: 71%)27. 95% of businesses 
see  corruption  as  a  widespread  and  more  than  half  (58%)  say  that  corruption  is  a  problem 
when  doing  business28.  Then,  36%  of  people  consider  that  there  are  enough  successful 
prosecutions  to  deter  people  from  corrupt  practices  (EU  average  of  36%)  while  20%  of 
companies  believe  that  people  and  businesses  caught  for  bribing  a  senior  official  are 
appropriately punished, against a EU average of 31%. 

A  recent  revision  of  the  criminal  legislation  took  place  and  some  further  amendments 
are  envisaged.  In  the  past  years,  Greece  undertook  a  number  of  steps  to  revise  its  anti-
corruption legislative framework, criminalise corruption offences and include sanctions that 
are proportionate and dissuasive. Amendments passed in June 2019, which downgraded the 
active bribery offence to a misdemeanour, and lowered the associated sanction, were repealed 
in  November  2019.  This  repeal  was  a  reaction  to  concerns  voiced  by  the  Group  of  States 
against  Corruption  (GRECO)  and  the  Organisation  for  Economic  Co-operation  (OECD), 
which  also  issued  a  series  of  recommendations  in  this  regard29.  However,  due  to  the 
applicable  lex  mitior  principle30  in  Greek  criminal  law,  a  number  of  ongoing  cases  will  be 
affected due to a shortened statute of limitation or more lenient sanctions31.  

The  cooperation  and  coordination  among  different  audit  authorities  and  inspection 
bodies has been strengthened. The National Transparency Authority (NTA), established in 

25   Figures 9, 15, 2020 EU Justice Scoreboard. 
26   Transparency International Greece: https://www.transparency.org/en/countries/greece. 
27   Flash Eurobarometer 502 (2020), Corruption. 
28   Flash Eurobarometer 482 (2019), Businesses’ attitudes towards corruption in the EU. 
29   GRECO  Ad  hoc  Report  on  Greece  (Rule  34);  European  Commission,  Country  Report  for  Greece  2020, 

(SWD(2020) 507 final). 

30   The lex mitior principle is the principle of applying the less severe law and constitutes a general principle of 

national criminal laws as well as a general principle of EU law. 

31   For more details, see European Commission, Country Report for Greece 2020, (SWD(2020) 507 final) pp. 

64, 65. 

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August 201932, merged six previously separate audit bodies under its umbrella, with the aim 
of  addressing  institutional  fragmentation  and  lack  of  coordination.  NTA  has  six  regional 
offices and is  responsible for the overall planning, coordination, supervision and evaluation 
of  the  effectiveness  of  all  control  mechanisms.  Preventing,  detecting  and  addressing  fraud 
and  corruption  in  the  public  sector  also  falls  within  the  NTA’s  responsibilities,  as  well  as 
raising  awareness.  The  authority  is  responsible  for  the  overall  coordination  of  the  National 
Anti-Corruption  Action  Plan  (NACAP),  which  has  been  the  framework  for  planning  and 
monitoring the efforts for preventing and combating corruption since 201333. NTA cooperates 
with other administrative bodies and with prosecution services, being endowed with powers 
to impose administrative sanctions, while its inspectors-auditors may carry out a preliminary 
examination  or  an  investigation  following  a  public  prosecutor’s  order.  The  Authority’s 
operational  independence  and  administrative  and  financial  autonomy  are  enshrined  in  law, 
and its activity is subject to parliamentary scrutiny.  

Two specialised anti-corruption units are responsible for tackling corruption committed 
by  politicians  and  high-ranking  officials.  The  prosecution  service  in  charge  of  economic 
crimes  and  the  prosecution  service  in  charge  of  corruption  cases  are  supported  by  special 
investigative  agencies,  such  as  the  General  Directorate  for  Financial  and  Economic  Crime 
Unit (SDOE) and the Financial Police. Following specific recommendations from the OECD, 
Greece is making efforts to equip the investigating and prosecuting authorities with adequate 
human and technical resources34. 

Important  steps  to  address  obstacles  to  prosecuting  high-level  corruption  have  been 
taken  through  constitutional  amendments.  The  constitutional  provisions  regarding  the 
immunity  regime  for  Members  of  Parliament  and  of  serving  or  former  Ministers  were 
modified in 2019. Under the previous legal regime, the possibility to prosecute serving and 
former  members  of  government  was  severely  restricted  by  a  complex  and  time-constrained 
procedure for parliamentary approval at various steps of the criminal procedure. The special 
statute of limitations has also been abolished, thus lifting some important legal obstacles to 
the prosecution of high-level corruption, notably as regards the removal of the time limit for 
the Parliament to adopt a motion for prosecution against serving or former Ministers35. The 
relevant provisions entered into force on 28 November 2019 and will not apply retroactively 
for already pending cases. 

Several  important  anti-corruption  reforms  completed  in  the  past  are  currently  being 
implemented.  After  a  series  of  legislative  reforms,  a  modern  law  on  party  financing  is  in 
place36. It seems, however, that its full implementation is a matter of concern, as the control 
mechanisms  is  not  yet  fully  effective  and  no  sanctions  have  been  imposed  to  date  by  the 
competent audit committee of the Parliament on any political party37.  

Greece has carried out several reforms to improve and strengthen the legal framework 
of  the  asset  declarations  system.  As  of  2016,  asset  declarations  for  all  categories  covered 
are submitted online38 and the system is now fully operational. However, the relevant Law on 

32   Law 4622/2019.  
33   National  Transparency  Authority  (2018):  Anti-corruption  action  plan  2018-2021.  Greece  adopted  its  first 

NACAP in March 2013, which was further updated in August 2015.  
34   OECD (2018): Phase 3bis follow-up: additional written report by Greece. 
35   European Commission, Country Report for Greece 2020, (SWD(2020) 507 final). 
36   Law 3023/2002 as amended by the Laws 4304/2014, 4472/2017, 4475/2017, 4509/2017. 
37   European Commission, Country Report for Greece 2020, (SWD(2020) 507 final). 
38   Asset disclosure rules are provided in L. 3213/2003 as it stands after the enactment of L. 4571/2018. 

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the  Submission  of  the  Declarations  of  Assets  and  Financial  Interests  by  Liable  Individuals 
has  been  amended  once  more  in  2018,  stipulating  that  all  persons  covered  would  have  to 
submit again their asset declarations for the years 2015, 2016 and 201739. There are four main 
authorities  in  charge  of  receiving  and  auditing  asset  declarations:  i)  the  Committee  of 
Parliament for the Investigation of Declarations of Assets (CIDA), the so-called Committee 
3-A,  which  consists  of  11  members  and  is  responsible  for  the  oversight  and  sanctions  on 
political  entities’  (such  as  parties  and  persons)  financing,  and  on  asset  declarations.  It  is 
supported  by  a  Special  Service,  composed  of  20  staff  members  and  headed  by  a  specialist 
seconded from the Special Secretariat of the Financial Investigative Body; ii) the Source of 
Funds  Investigation  Unit  of  the  FIU  (Anti-Money  Laundering  Authority),  which  is 
responsible for the audit of asset declarations of several categories of public officials, as well 
as  for  individuals  performing  management  duties  in  specific  private  legal  entities;  iii)  the 
Internal Affairs Unit of the Police, which is responsible for the audit of asset  declaration of 
police officers, and (iv) the Head of the National Transparency Authority who is responsible 
for  receiving  and  verifying  the  asset  declarations  of  administrative  control  authorities 
(inspectors, auditors, investigators). The four authorities are independent from each other and 
no  formal  cooperation  mechanism  exists  to  coordinate  their  activities.  Additionally,  other 
oversight bodies can verify an asset declaration on an  ad hoc basis, in  case they received a 
complaint40.  

A recent reform introduces new provisions on conflicts of interest. They cover members 
of  the  Government,  the  general  and  special  secretaries,  as  well  as  coordinators  of 
decentralised  administrations,  the  presidents  or  heads  of  independent  authorities  and 
presidents, vice presidents, governors, deputy governors and CEOs of public and private legal 
entities41, except for those enshrined in the Constitution, who answer only to Parliament and 
not  to  the  Government.  The  Civil  Servants’  Code  outlines  several  restrictions  and 
incompatibilities for civil servants. Similar provisions exist for members of parliament within 
the  Code  of  Conduct  for  Members  of  Parliament42.  The  violation  of  these  provisions  may 
result in a disciplinary offence43. 

Lobbying  in  Greece  remains  largely  unregulated  and  the  whistle-blower  protection 
framework is incomplete. At present, there are no specific obligations for the registration of 
lobbyists or the reporting of contacts between public officials and lobbyists. However, a draft 
law  is  currently  under  preparation.  There  is  no  overall  legal  framework  for  whistle-blower 
protection.  Some  provisions  exist  under  the  framework  for  ‘public  interest  witnesses’44, 
which introduce limited protection against criminal prosecution for persons disclosing certain 
crimes, including corruption. Some steps have been taken to introduce guidelines for whistle-

39   Government Gazette 186 /A/ 30.10.2018. Law 4571/2018 requested that all categories of obligors submitted 

again their assets declarations for the years 2015, 2016 and 2017.  

40   Furthermore,  the  Court  of  Audit  adjudicates  on  cases  arising  from  the  audit  of  the  unjustified  growth  of 
assets of the persons liable to asset declaration (Referred to in Art. 1 of law 3213/2003), which are filed in 
the  form of a law suit by the General Prosecutor’s Office at the Court of Audit, following an audit by the 
competent  administrative  bodies.  The  aim  of  the  audit  is  to  locate  assets  growth  deemed  to  be  product  of 
corruption  and  claim  it  back  (Art.  3Β  par.  4  and  12  of  law  3213/2003,  Art.  118  law  4700/2020)  to  the 
detriment of those responsible. 

41   Art. 71 Law 4622/2019. 
42   Art. 3 of the Code of Conduct for Parliamentarians.  
43   United  Nations  –  Office  on  Drugs  and  Crime  (2018)  Thematic  Compilation  of  Relevant  Information 

Submitted by Greece – Asset and interest Disclosure systems. 

44   Law 4254/2014. 

7 

 
 
                                                 
blower protection in the private sector45, and a legislative initiative for the establishment of 
an effective mechanism for whistle-blower protection is part of the 2018-2021 National Anti-
Corruption Action Plan, but an overall framework remains to be developed.  

As regards ‘revolving doors’, the legal framework has been amended in 2019. Previously 
the legislation provided that senior public officials must abstain from any private professional 
activity  similar  to  their  previous  duties  for  a  period  of  2  years.  The  infringements  of  the 
provisions were punished by several sanctions such as fines, prohibition of being appointed 
as  public  administration  officials  for  a  period  of  ten  years  and  removal  from  the  relevant 
National  Registry46.  However, 
through  new 
amendments, which introduced a reduced cooling off period from two years to one year and 
removed sanctioning provisions47. An independent Ethics  Committee established within the 
National Transparency Authority is responsible for granting this permission (or for allowing 
this activity under specific conditions) and for proposing sanctions within the framework of 
the law, to be imposed by the Head of the National Transparency Authority. 

these  provisions  have  been  abolished 

III.  MEDIA PLURALISM 

The  Greek  legal  framework  concerning  media  pluralism  is  based  on  a  set  of  constitutional 
safeguards and legislative measures. In particular, freedom of expression is recognised by the 
Constitution. Structures to ensure media pluralism and press rights are in place. Greek media 
has been affected by the economic crisis, resulting in an increased financial vulnerability of 
media companies and journalists48.  

Independence  of  the  regulator  for  audio-visual  media  services  is  ensured,  but  it  lacks 
resources.  The  National  Council  for  Radio  and  Television  (NCRTV)  supervises  and 
regulates the radio and television markets. Its independence is enshrined in the Constitution49 
and  its  legal  framework  set  out  in  the  Media  Law50.  NCRTV  is  a  nine-member  body, 
consisting  of  a  President,  a  Vice-President  and  seven  members,  who  are  appointed  by  the 
Plenary of the Presidents, a special body of the Parliament in charge of the nominations to the 
independent authorities in which all political parties are represented51. Its independence and 
effectiveness  has  been  assessed  to  be  at  low  risk  by  the  Media  Pluralism  Monitor  2020 
(‘MPM 2020’). However, the MPM 2020 also indicates that there are no specific safeguards 
to avoid arbitrary decision-making on behalf of the state as regards the budgetary resources of 
the  authority.  It  also  claims  that,  whilst  rules  on  incompatibility  exist,  the  appointment 
procedures are not sufficiently transparent, and the qualifications required are determined in 
general  terms,  which  does  not  preclude  member  selection  on  the  basis  of  political 
considerations52. It was raised during the country visit that NCRTV lacks adequate financial 
and  staffing  resources  to  perform  all  its  tasks,  notably  when  it  comes  to  monitoring  audio-
visual media services that originate from the regions and islands located furthest from Athens 

45   OECD  (2018)  Guidelines  on  Whistle-blower  Protection  for  Companies  in  Greece.  These  guidelines  have 

been developed with EU support. 

46   Art. 23 of Law 4440/2016. 
47   Law  4622/2019  (art.  119)  on  the  “Executive  State:  organisation,  operation  and  transparency  of  the 
Government, government bodies and central public administration” which came into force in August 2019.  
48   In  2020,  Greece  was  at  65th  position  worldwide  in  the  Reporters  Without  Borders  World  Press  Freedom 

Index. 

49   Article 15(2) of the Constitution. 
50   Law 4339/2015 and also Laws 1866/1989, 2328/1995, 2644/1998, 2863/2000 etc., as amended. 
51   Input from Greece for the 2020 Rule of Law Report. 
52   2020 Media Pluralism Monitor. 

8 

 
 
                                                 
and cannot be viewed from the capital. The authorities have started the process of transposing 
the revised Audio-visual Media Services Directive (AVMSD)53. This Directive reinforces the 
independence of audio-visual media regulators by ensuring that they are legally distinct from 
their  government  as  well  as  functionally  independent  from  the  government  and  from  any 
other public or private body.  

Transparency  of  media  ownership  is  ensured  only  partially,  notably  for  audio-visual 
media  services.  Whilst  audio-visual  media  are  mandated  to  report  on  their  ownership 
structures to the NCRTV54, the print media are not required to indicate their owner on their 
copies. It is worth noting, however, that in order to register with the Registry of the Regional 
and  the  Local  Press,  media  operators  must  provide  domestic  authorities  with  ownership 
information55. Disclosure of news media ownership to  the public takes place only partially, 
especially  as  regards  the  ultimate  beneficial  owners56.  The  MPM  2020  has  assessed 
transparency  of  media  ownership  as  being  at  medium  risk,  indicating  that  “domestic 
legislation  is  not  characterized  by  clear  provisions  on  the  disclosure  of  news  media 
ownership”. As regards transparency of online media ownership, the Greek Authorities report 
that  the  Secretariat-General  for  Media  and  Communication  launched  an  online  media 
registry,  called  “e-media”57.  This  registry  is  addressed  to  all  media  owners  with  online 
presence (website), encouraging them to register their online activities.  

The criteria for the distribution of indirect state subsidies are reported to be fair.  The 
MPM  2020  reports  that  the  criteria  for  indirect  state  subsidies,  such  as  postal  distribution 
subsidies, reduced value added tax and rates for electronic communication services, are fair. 
However,  stakeholders  have  reported  concerns  about  the  lack  of  financial  support  from  the 
Government for journalists and the non-transparency of allocation of pandemic-related state 
advertising58. The Greek authorities indicate that the Secretariat-General for Communication 
and  Media  supervises  the  implementation  of  the  communication  programs  and  actions  of 
public  services  and  organisations.  Each  service  or  organisation  that  runs  a  communication 
program  with  a  budget  exceeding  EUR  30  000  is  obliged  to  submit  an  application  to  be 
approved  by  the  Secretariat-General.  Yet,  according  to  the  MPM  2020,  the  transparency  of 
the  policy  is  problematic,  as  the  amounts  received  by  eligible  print  media  outlets  are  not 
publicly disclosed.  

Freedom  of  expression  is  recognised  by  the  Constitution.  Recent  modifications  to  the 
Criminal Code have abolished the criminal offence of blasphemy. Imprisonment is among the 
possible sanctions for defamation. The right to information is enshrined in the Constitution. It 
also  provides  for  a  right  of  access  to  documents  held  by  public  bodies.  Restrictions  are 
defined in accordance with international standards and appeal mechanisms are in place. The 
regulatory framework for the protection of whistle-blowers, who are often important sources 

53   Directive (EU) 2018/1808 of the European Parliament and of the Council of 14 November 2018 amending 

Directive 2010/13/EU. 

54   The revised AVMSD encourages Member States to adopt legislative measures providing that media service 
providers  under  their  jurisdiction  make  accessible  information  concerning  their  ownership  structure, 
including the beneficial owners. 

55   Articles 20 and 22 of Law 4557/2018 on the provisions for a Central Beneficial Ownership Registry. 
56   2020 Media Pluralism Monitor. According to the Greek authorities, a new Ministerial Decision (667/2020) 
now  obliges  all  entities  performing  business  in  Greece  to  keep  a  Special  Beneficial  Ownership  Registry 
disclosing their ultimate beneficial owners and the whole beneficiary chain. This applies to media companies 
as well. 

57    The E-media registry can be found here: https://emedia.media.gov.gr/. 
58   Information received in the context of the country visit to Greece. 

9 

 
 
                                                 
for  journalists,  remains  incomplete.  According  to  the  MPM  2020,  key  concerns  include 
insufficient  mechanisms  to  ensure  respect  for  professional  standards  in  the  practice  of 
journalism.  Stakeholders  reported  that  ethical  bodies  in  the  journalists’  unions  are  not  very 
active and not  able to  effectively monitor ethical journalism  or other issues, but  pointed, at 
the same time, to a relatively healthy online media landscape in Greece, in particular at local 
level59.  

Journalists  face  challenges  as  regards  their  working  conditions  and  safety.  Working 
conditions  remain  problematic  and  journalists  are  not  free  from  attacks  and  threats  to  their 
physical integrity. Several attacks on journalists have been reported in the recent past60. The 
European Centre for Press and Media Freedom (ECPMF) indicates that, with few exceptions, 
the main threat to journalists’ safety in Greece comes from far-right extremists61. In 2019 and 
2020, the Council of Europe’s Platform to promote the protection of journalism and safety of 
journalists62 and Mapping Media Freedom63 reported nine alerts linked to smear campaigns 
against  journalists,  attacks  targeting  journalists  covering  migration  and  refugees  issues  and 
Covid-19  state  funding  to  media.  Journalists’  unions  in  Greece  provide  legal  assistance, 
limited financial support, and training for journalists.  

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Greece is a parliamentary democracy with a unicameral Parliament. The separation of powers 
is  enshrined  in  the  Constitution64.  Legislative  power  is  vested  in  the  Parliament  and  the 
President65  and  the  right  to  introduce  legislation  belongs  to  the  Parliament  and  the 
Government.  

The  legislative  process  is  undergoing  reform  efforts  to  standardise  and  streamline  the 
preparatory  phase  and  to  improve  its  quality.  The  Greek  legislative  reality  until  very 
recently was characterised by a lack of coherence and a large degree of fragmentation. This 
has  become  known  under  the  terms  of  ‘polynomia’  or  even  ‘kakonomia’,  and  was  further 
exacerbated by the lack of authoritative and comprehensive codification of legislation66. To 
deal  with  these  challenges,  a  2019  legislative  initiative67  redefined  and  elaborated  the 
normative  framework  for  good  legislation  and  codification  practices.  This  resulted  in  the 
recent development and adoption of standardised methods, set out in respective manuals that 
were distributed throughout the administration and are available online68.  

59   2020 Media Pluralism Monitor. 
60   In  December  2018,  a  bomb  attack  on  the  SKAI  TV  station  in  Athens  caused  extensive  damage.  In  May 
2019, the car of a reporter for CNN Greece reporter was destroyed in an arson attack. The European Centre 
for Press and Media Freedom (ECPMF) reports that, also in 2019, anarchists stormed into the headquarters 
of the newspaper Athens Voice and smashed office equipment, computers and furniture.  

61   European Centre for Press and Media Freedom (2019), Greece: New democracy – new press freedom? 
62   Council of Europe, Platform to promote the protection of journalism and safety of journalists.  
63   ECPMF, Mapping Media Freedom.  
64   Article 26 of the Constitution. 
65   See previous note. 
66   Sotiropoulos/Christopolous,  ‘Polynomia  and  Kakonomia  in  Greece’,  Dianeosis  2017  (‘Πολυνομία  Και 
Κακονομία Στην Ελλάδα’); see also European Commission, Country Report Greece 2019, SWD(2019) 1007 
final, p. 55. 

67   Law 4622/2019 on the ‘Executive State’, section 3, chapter C, ‘Law-drafting process and  good legislation 

practices’, articles 57-64 and chapter D, ‘Codification and Law Review’, articles 65-67.    

68   Manuals on legal codification, legislative methodology and impact assessments. 

10 

 
 
                                                 
A comprehensive reform of law-making procedures aims at strengthening the quality of 
legislation. Until recently, conducting impact assessments and consulting stakeholders were 
not  well-established  practices  for  enacting  legislation.  The  Executive  State  Law  of  201969 
aims  at  a  comprehensive  reform  of  law-making  procedures,  based  on  better  regulation 
principles and techniques, with an emphasis on strengthening the role of impact assessments. 
The law also created an independent scientific evaluation body with the participation of both 
lawyers  and  economists,  and  strengthened  the  institutional  setup  for  legal  codification  and 
reform.  Implementation  of  the  Executive  State  Law  is  ongoing.  The  authorities  recently 
adopted  a  detailed  legislative  methodology  manual  and  a  template  for  a  comprehensive 
impact assessment70. Stakeholders, such as the Greek National Human Rights Institution71 or 
the Greek Ombudsman72 pointed to the fact that they do not receive the draft laws in advance, 
and  are  thus  lacking  sufficient  time  to  comment  on  the  provisions  in  detail.  Moreover,  the 
time allowed for public consultation is often very short. The new law-making process aims at 
addressing  these  shortcomings.  In  addition,  authorities  reported  on  efforts  taking  place  in 
order to limit recourse to fast-track procedures and emergency ordinances in the law making 
process. 

Respect for fundamental and constitutional rights is ensured in several ways, including 
independent  authorities.  As  there  is  no  formal  constitutional  court  in  Greece,  the  Greek 
Constitution  enables  every  judge  to  establish  whether  the  constitutional  rights  of  a  person 
have been breached by a law in breach of the constitution73. Due to the existence of such a 
system  of  diffused  constitutional  review,  all  courts  have  competence  to  review  the 
constitutionality of laws74. However, under the 1975 Constitution, a special ad hoc court was 
created, the Supreme Special Court75.  Its  limited jurisdiction includes the  ex post review of 
constitutionality of legislation in the event of a disagreement between the Supreme Courts. Its 
judgments  on  the  constitutionality  of  statutory  provisions  that  come  under  its  scrutiny  are 
binding  for  all  courts.  The  Greek  Ombudsman,  which  is  an  independent  administrative 
authority established in 1997, has the task of mediating between citizens and public services, 
local authorities, bodies governed by public law and utilities, to protect civil rights, combat 
maladministration and ensure compliance with due process76. Greece has further established a 
National  Commission  for  Human  Rights  as  National  Human  Rights  Institution  in  1998, 
acting  as  an  independent  advisory  body  of  the  State  on  issues  related  to  the  protection  and 
promotion  of  human  rights.  It  was  reaccredited  with  A-status  in  line  with  the  UN  General 
Principles77 in March 2017. 

69   Law 4622/2019. 
70   This  was  prepared  with  technical  support  provided  by  the  European  Commission,  see  European 

Commission, Enhanced Surveillance Report May 2020, pp. 27, 103. 

71   Information received in the context of the country visit to Greece. 
72   ENNRHI, The rule of law in the European Union, p. 115. 
73   Article  87(2)  of  the  Constitution,  which  stipulates  that  judges  are  not  obliged  to  comply  with  provisions 
enacted in violation of the Constitution. Article 93(4) of the Constitution stipulates that the courts are bound 
not to apply a statute whose content is contrary to the Constitution. 

74   See  e.g.  Contiades,  Papacharalambous  and  Papastylianos,  The  Constitution  of  Greece:  EU  Membership 
Perspectives, in: National Constitutions in European and Global Governance: Democracy, Rights, the Rule 
of Law, 2019, pp. 642 – 643. 
75   Article 100 of the Constitution. 
76   The  Greek  Ombudsman  is  also  the  national  equality  body  with  a  mandate  to  combat  discrimination  and 
promote  the  principle  of  equal  treatment  irrespective  of  gender,  racial  or  ethnic  origin,  family  or  social 
status, religion or belief, disability or chronic illness, age, sexual orientation and gender identity. 

77   Principles  relating  to  the  Status  of  National  Institutions  (The  Paris  Principles),  adopted  by  UN  General 

Assembly resolution 48/134 on 20 December 1993 

11 

 
 
                                                 
information, 

including  to  administrative  decisions, 

is  secured  and 
Access  to 
transparency  is  safeguarded  through  a  policy  on  access  to  governmental  information. 
Since  2010,  Greece  is  operating  an  electronic  platform  (‘Di@vgeia’)  to  which  all  public 
authorities  have  to  upload  every  administrative  act,  including  inter  alia  appointment 
decisions,  awards  of  grants,  transfers  of  personnel  and  decisions  on  state  subsidies  to 
citizens78. Relevant legislation further stipulates that no act is deemed to be valid, unless it is 
first  uploaded  and  shown  on  the  electronic  platform  to  which  every  interested  person  has 
direct access79.  

The freedom of association is enshrined in the Constitution, although there is no specific 
enabling framework for civil society. The Greek authorities reported that the current legal 
framework  does  not  provide  for  specific  provisions  on  the  establishment  and  operation  of 
NGOs80. In 2018, however, a ‘Greek and Foreign NGO Members Registry’ was established 
by  a Joint Ministerial  Decision81, which was subsequently  further regulated in  202082. This 
latter  law  introduced  and  gradually  extended  rules  on  the  registration  and  certification  of 
Greek  and  foreign  NGOs  active  in  the  area  of  asylum,  migration  and  social  inclusion, 
provides for the terms and conditions for the registration of organisations and grants power to 
the  Ministry  of  Migration  and  Asylum  to  lay  down  additional  requirements  for  the 
registration  of  NGOs.  This  is  subject  to  criticism  from  a  number  of  stakeholders,  as  they 
consider  that  the  regulations  on  the  operation  of  NGOs  include  too  stringent  and 
disproportionate  requirements  for  registration  and  certification83.  Also,  a  rise  in  attacks  on 
NGOs working with refugees and migrants in Greece has been reported84, and concerns have 
been expressed that the ‘civic space’ for civil society to operate in Greece has narrowed since 
201985.  

78   The electronic platform is available here: https://diavgeia.gov.gr/en.  
79   Law 4210/2013. 
80   Input from Greece for the 2020 Rule of Law Report, point 45. 
81   Joint Ministerial Decision 7586/18. 
82   Law 4662/2020, further amended by Law 4686/2020. 
83   Refugee Support Aegean, New Rules on Civil Society Supporting Refugees and Migrants in Greece, 2020, 
pp.  1  –  3;  Expert  Council  on  NGO  Law,  Conference  of  INGOs  of  the  Council  of  Europe, 
CONF/EXP(2020)4, p. 23. 

84   Contribution from the Front Line Defenders for the 2020 Rule of Law Report, pp. 2-3. 
85   Contribution from Greenpeace for the 2020 Rule of Law Report, p. 2; see also Rating by CIVICUS Monitor 
–  Tracking  Civic  Space;  ratings  are  on  a  five-category  scale  defined  as:  open,  narrowed,  obstructed, 
repressed and closed. 

12 

 
 
 
 
 
                                                 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2020 Rule of Law report 

can be found at (COM website).  

Centre  for  Media  Pluralism  and  Media  Freedom  (2020),  2020  Media  pluralism  monitor. 

https://cmpf.eui.eu/media-pluralism-monitor/mpm-2020. 

Centre  for  Media  Pluralism  and  Media  Freedom  (2020),  2020  Media  Pluralism  Monitor  – 

decriminalisation of defamation infographic.  https://cmpf.eui.eu/wp-
content/uploads/2019/01/decriminalisation-of-defamation_Infographic.pdf.  

CIVICUS Monitor – Tracking Civic Space. https://monitor.civicus.org/country/greece/.  

Contiades, Papacharalambous and Papastylianos (2019), The Constitution of Greece: EU Membership 

Perspectives.  

Council  of  Europe:  Committee  of  Ministers  (2016),  Recommendation  CM/Rec(2016)4  of  the 
Committee of Ministers to member States on the protection of journalism and safety of journalists 
and other media actors. 

Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  – 

Greece. https://www.coe.int/en/web/media-freedom/greece.  

Council  of  Europe,  Conference  of  INGOs,  Expert  Council  on  NGO  Law,  Opinion  on  the 
compatibility with European standards of recent and planned amendments to the Greek legislation 
on  NGO  registration,  2  July  2020.  https://www.coe.int/en/web/ingo/-/greek-legislation-on-ngo-
registation  

Directorate-General for Communication (2019), Standard Eurobarometer 91. 

Directorate-General  for  Communication  (2019),  Flash  Eurobarometer  482:  businesses’  attitudes 

towards corruption in the EU. 

Directorate-General for Communication (2020), Special Eurobarometer 502: corruption.  

European  Centre 

for  Press  &  Media  Freedom,  Mapping  media 

freedom:  Greece. 

https://www.mappingmediafreedom.org/country-profiles/greece/.  

European  Centre  for  Press  and  Media  Freedom  (2019),  Greece:  New  democracy  –  new  press 

freedom? https://www.ecpmf.eu/greece-new-democracy-new-press-freedom/.  

European Commission (2019), Country report Greece, SWD(2019) 1007 final.  

European Commission (2020), Country report Greece, SWD(2020) 507 final.  

European Commission (2020), Enhanced surveillance report: institutional paper 127.  

European Commission (2020), The EU justice scoreboard.   

European  e-Justice  Portal, 

Judicial 

systems 

in  Member  States  –  Greece.  https://e-

justice.europa.eu/content_judicial_systems_in_member_states-16-el-en.do?member=1.  

European  Network  of  National  Human  Rights  Institutions  (2020),  Contribution  from  the  European 
Network of National Human Rights Institutions for the stakeholder consultation for the 2020 Rule 
of Law Report.   

Front Line Defenders (2020), Contribution from the Front Line Defenders for the 2020 Rule of Law 

Report.  

GRECO (2018), Fourth evaluation round, on Greece on corruption prevention in respect of members 

of parliament, judges and prosecutors, Compliance report.   

GRECO (2019), Ad hoc report on Greece (Rule 34).  

Greek Government (2020), Input from Greece for the 2020 Rule of Law Report.  

13 

 
 
Greek Government, Online media register. https://emedia.media.gov.gr/.  

Greek Government, Online platform Di@vgeia. https://diavgeia.gov.gr/en.  

Greenpeace (2020), Contribution from Greenpeace for the 2020 Rule of Law Report.   

Ministry 

of  Digital  Governance,  Di@vgeia:  The 

transparency 

program 

initiative. 

https://diavgeia.gov.gr/en.  

Ministry of Justice (2020), Communique of 25 May 2020. https://www.ministryofjustice.gr/?p=5108. 

National 

Transparency  Authority 

anti-corruption 
http://www.gsac.gov.gr/attachments/article/234/National%20Anti-
Corruption%20Action%20Plan%202018-2021.pdf.   

(2018) 

action 

plan 

2018-2021. 

OECD (2018), Assessment and Review of Asset Recovery Institutional Arrangements in Greece.  

OECD 

(2018): 

Phase 

3bis 

follow-up: 

additional  written 

report 

by  Greece. 

https://one.oecd.org/document/DAF/WGB(2018)43/en/pdf.  

OECD 

(2018)  Guidelines  on  Whistle-blower  Protection 

for  Companies 

in  Greece. 

https://www.oecd.org/corruption/anti-bribery/OECD-Guidelines-Whistleblower-Protection-
Companies-in-Greece-ENG.pdf. 

Pikrammenos (2019), Judicial territorial planning: a choice of the legislator with a major import for 

the judicial system.  

Refugee  Support  Aegean  (2020),  New  rules  on  civil  society  supporting  refugees  and  migrants  in 
Greece. https://rsaegean.org/wp-content/uploads/2020/05/RSA_Comments_NGO_Registry.pdf.  

Reporters Without Borders (2020), World Press Freedom Index. https://rsf.org/en/ranking. 

Reuters 

and  University 
http://www.digitalnewsreport.org/survey/2020/greece-2020/.  

Institute 

of  Oxford,  Digital  News  Report:  Greece. 

Sotiropoulos and Christopolous (2017), Polynomia and Kakonomia in Greece.  

Transparency International (2020), Contribution from Transparency International for the 2020 Rule of 

Law Report. 

Transparency 

Corruption 
International, 
https://www.transparency.org/en/countries/greece.  

Perceptions 

Index: 

Greece. 

United Nations – Office on Drugs and Crime (2018) Thematic Compilation of Relevant Information 
systems. 

Disclosure 

Submitted 
https://www.unodc.org/documents/corruption/WG-
Prevention/Art_8_Financial_disclosure_declaration_of_assets/Greece.pdf. 

interest 

Greece 

Asset 

and 

by 

– 

Virtual country visit to Greece in the context of the 2020 Rule of Law Report. 

14 

 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Country visit to Greece 

The Commission services held virtual meetings in June 2020 with: 

  3A Committee 
  Athens Bar Association 
  Council of State 
  Court of Audit 
  Deputy Minister’s Cabinet  
  Financial Intelligence Unit 
  General Secretary for Legal and Parliamentary Affairs 
  Hellenic National Audio-visual Regulator  
 
  Ministry of Justice 
  National Transparency Authority 
  Ombudsman  
  Prosecutor’s Office for Financial Crimes and the Financial Police Division  
  Special Agency supporting the Political Financing Audit Committee  
  Supreme Court 

Journalists’ Union of Macedonia and Thrace 

* The Commission also met the following organisations in a number of horizontal meetings:  

  Amnesty International 
  Civil Liberties Union for Europe 
  Civil Society Europe 
  Conference of European Churches  
  EuroCommerce 
  European Center for Not-for-Profit Law  
  European Centre for Press and Media Freedom 
  European Civic Forum  
  Free Press Unlimited 
  Front Line Defenders 
 
ILGA-Europe 
 
International Commission of Jurists 
 
International Federation for Human Rights  
 
International Press Institute  
  Lifelong learning Platform  
  Open Society Justice Initiative/Open Society European Policy Institute 
  Reporters without Borders  
  Transparency International EU  

15 

 
 
 
 
 
 
 
 
 
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