COMMISSION STAFF WORKING DOCUMENT 2021 Rule of Law Report Country Chapter on the rule of law situation in Greece Accompanying the COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2021 Rule of Law Report The rule of law situation in the European Union
Date: 2021-07-20
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, 20.7.2021  SWD(2021) 709 final  COMMISSION STAFF WORKING DOCUMENT 2021 Rule of Law Report    Country Chapter on the rule of law situation in Greece Accompanying the COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2021 Rule of Law Report    The rule of law situation in the European Union {COM(2021) 700 final} - {SWD(2021) 701 final} - {SWD(2021) 702 final} - {SWD(2021) 703 final} - {SWD(2021) 704 final} - {SWD(2021) 705 final} - {SWD(2021) 706 final} - {SWD(2021) 707 final} - {SWD(2021) 708 final} - {SWD(2021) 710 final} - {SWD(2021) 711 final} - {SWD(2021) 712 final} - {SWD(2021) 713 final} - {SWD(2021) 714 final} - {SWD(2021) 715 final} - {SWD(2021) 716 final} - {SWD(2021) 717 final} - {SWD(2021) 718 final} - {SWD(2021) 719 final} - {SWD(2021) 720 final} - {SWD(2021) 721 final} - {SWD(2021) 722 final} - {SWD(2021) 723 final} - {SWD(2021) 724 final} - {SWD(2021) 725 final} - {SWD(2021) 726 final} - {SWD(2021) 727 final}  
 
 
ABSTRACT 

A number of measures aiming at improving the efficiency and the quality of the Greek justice 
system  are  under  way.  The  Code  of  Judicial  Staff  was  adopted  on  24  April  2021  and  the 
elaboration of the Code of Conduct for Administrative Justice is ongoing, though no draft has 
been  made  public.  Measures  are  being  implemented  to  improve  the  quality  of  justice,  in 
particular  as  regards  the  collection  of  judicial  statistics  and  the  creation  of  specialised 
chambers in courts and measures related to e-justice, although challenges remain namely as 
regards digital signatures and the full implementation of electronic filing. The reform of the 
judicial  map  is  a  priority.  Ongoing  reforms  in  the  civil  procedure  would  have  a  positive 
impact  on  the  administration  of  justice,  which  continues  facing  efficiency  challenges. 
Concerns relating to the procedure of appointments in the most senior positions of judges and 
prosecutors remain. 

A  wide  range  of  anti-corruption  reforms  that  Greece  has  embarked  on  in  the  past  years  is 
being taken forward. The 2019 Constitutional review of the immunity regime for members of 
the Parliament and Ministers resulted in an extension of the statutory limit for investigations, 
and  immunities  have  started  to  be  lifted  in  some  corruption  cases,  ending  an  important 
obstacle to the prosecution of high-level corruption. However, some practical issues remain, 
notably  as  regards  resources  for  investigating  corruption  and  delays  in  the  management  of 
court files.  Legislative  gaps have not  yet been  filled concerning the regulation  of lobbying. 
Significant  shortcomings  remain  in  the  effective  oversight,  in  particular  due  to  the  division 
among  four  oversight  bodies,  and  in  the  follow-up  of  the  provisions  concerning  asset 
disclosures, conflicts of interest and party financing. While asset declarations from members 
of  the  Parliament  and  the  Government  are  made  public,  this  is  done  in  a  non-machine 
readable  format  and  the  reports  on  the  outcome  of  the  checks  and  on  possible  breaches  or 
sanctioning procedures remain unavailable to the public. 

The Greek Government  has proposed new legislation to enhance the transparency of media 
ownership and public availability of media ownership information. The independence of the 
media regulator has been strengthened, while its financial capacity remains weak. The murder 
of  an  investigative  journalist,  currently  under  investigation,  has  highlighted  concerns  about 
the  safety  of  journalists  and  the  necessity  of  improving  their  protection.  The  working 
conditions of journalists have been impacted negatively by the COVID-19 pandemic and no 
significant measures supporting directly the media sector have been put in place.  

While there have been some improvements in the system of checks and balances in Greece, 
some  challenges  remain.  However,  improvements  are  noted  in  the  law  making  process,  in 
particular  as  regards  the  further  implementation  of  the  Executive  State  Law.  Specific 
initiatives  aim  at  improving  standardisation  and  uniformity  of  the  law-drafting  process, 
simplification  and  rationalisation,  as  well  as  the  introduction  of  a  higher  degree  of 
transparency and legal certainty. During the COVID-19 pandemic, Greece has not triggered a 
state of emergency and all relevant measures were taken according to the normal legislative 
procedure.  The  powers  of  the  Ombudsperson  were  reinforced.  The  registration  system  of 
NGOs active in the area of asylum, migration and social inclusion continues to be questioned 
by a number of civil society organisations. 

1 

 
I. 

JUSTICE SYSTEM  

The court system in Greece is based on the separation between the ordinary civil and criminal 
courts and the 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, mixed criminal courts composed by professional and lay 
judges1  and  the  Supreme  Court.  Administrative  courts  are  organised  into  30  administrative 
courts  of  first  instance,  nine  administrative  courts  of  appeal  and  the  Council  of  State.  The 
Court  of  Audit  has  a  dual  nature,  acting  partly  as  a  court  and  partly  as  an  administrative 
authority  entrusted  with  auditing  public  accounts.  There  is  no  formal  Constitutional  Court 
and  all  Greek  courts  have  competence  to  review  the  constitutionality  of  laws2.  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  prosecutors3.  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,  the 
offices  of  the  Prosecutor  for  Economic  and  Financial  Crime  and  of  the  Prosecutor  for 
Corruption  Offences  were  merged  in  a  single  prosecutorial  authority  in  20214.  Greece 
participates  in  the  European  Public  Prosecutor’s  Office.  There  are  63  bar  associations  in 
Greece, one at the seat of each court of first instance. 

Independence  

The level of perceived judicial independence is above average. Among the general public, 
55%  consider  judicial  independence  to  be  fairly  or  very  good,  a  share  that  increased 
compared  to  last  year  (53%).  The  corresponding  figure  among  companies  is  61%  and  has 
increased substantially compared to last year5 (53%). There is no clear trend identified during 
the last five years as regards the level of perceived independence6. 

Concerns relating to the procedure of the appointments in the most senior positions of 
judges and prosecutors persist. The three main branches of the judiciary enjoy a high level 
of self-administration. There are three supreme judicial councils, one for each of the branches 
of  the  judiciary,  in  which  the  executive  and  legislature  are  not  represented.  These  councils 
decide  on  appointments,  promotions,  transfers  and  secondments  of  judges  in  the  respective 
branches of the judiciary and prosecutors7. As regards the most senior positions of judges and 
prosecutors such as the President and Vice-President of the Council of State or the Supreme 
Court,  the  Constitution  stipulates  that  appointments  be  effected  by  presidential  decree, 

1   Constitution of Greece, Art. 97, para. 1: “Felonies and political crimes shall be tried by mixed jury courts 
composed of ordinary judges and jurors, as specified by law. The judgments of these courts shall be subject 
to the legal remedies specified by law”. 

2   Constitution  of  Greece,  Art.  93,  para.  4:  “The  courts  are  obliged  to  not  apply  a  law  whose  content  is 

contrary to the Constitution”.  

3   With the exception of lay judges participating in the mixed courts. 
4   Article 53 of Law 4745/2020 (OJ A 214) 
5   Figures 47 and 49, 2021 EU Justice Scoreboard.  
6   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%). 

7   2020 Rule of Law Report, country chapter on the rule of law situation in Greece, p. 2-3. 

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following a proposal  by  the Council of Ministers8.  In November 2020, GRECO in  its most 
recent report, raised once again concerns regarding the system of appointments for the most 
senior positions in the judiciary (including the Supreme Court President), notably that these 
positions are subject to  a potentially strong influence of the executive and recommended to 
revise  the  method  of  selection  and  ensure  the  involvement  of  the  judiciary  in  the  process9. 
The  Greek  authorities  do  not  have  any  plans  to  revise  the  appointment  procedure  in  the 
foreseeable  future10.  The  government  has  insisted  that  the  application  of  the  current 
legislation introduces additional elements of checks and balances11. In fact, there is a list of 
candidates established by the Minister of Justice based on objective criteria of seniority (such 
as  years  served  in  the  relevant  court)12.  The  list  is  discussed  by  the  conference  of  the 
Presidents (speakers) of the Parliament (current and former Presidents who are still members 
of  Parliament,  the  Vice-Presidents  of  the  Parliament,  the  Presidents  of  Parliamentary 
Committees,  the  Presidents  of  the  political  groups  and  one  independent  Member  of  the 
Parliament)13.  The  Minister  is  not  obliged  to  follow  the  opinion  of  the  Parliament14.  In 
practice, there has always been agreement between the executive and the legislature as of the 
choice  of  candidates  proposed  for  appointment.  Non-successful  candidates  do  not  have  the 
possibility  to  contest  before  an  independent  court  the  decision  not  to  propose  them  for 
appointment15. 

New  provisions  are  being  prepared  on  the  promotion  of  judges  and  prosecutors.  The 
Greek authorities indicated16 that a draft law17 is under preparation, in view of adoption in the 
third quarter of 2021, in order to amend the “Code on the organisation of the courts and the 
status of judges” so as to modernise the system of promotion for judges and prosecutors18. It 

8   Constitution  of  Greece,  Art.  90  para.  5:  “Promotion  to  the  ranks  of  President  or  Vice-President  of  the 
Council  of  State,  of  the  Supreme  Civil  and  Criminal  Court  and  of  the  Court  of  Audit  shall  be  effected  by 
virtue of a presidential decree issued on the proposal of the Cabinet, by selection among the members of the 
respective Supreme Court, as specified by law. Promotion to the rank of Public Prosecutor of the Supreme 
Civil and Criminal Court shall be effected by virtue of a similar decree, by selection among the members of 
the  Supreme  Civil  and  Criminal  Court  and  Deputy  Public  Prosecutors  of  this  Court,  as  specified  by  law. 
Promotion to the rank of General Commissioner of the Court of Audit shall be effected by virtue of a similar 
decree, by selection among the members of the Court of Audit and of the respective General Commission, as 
specified  by  law.  Promotion  to  the  rank  of  General  Commissioner  of  Administrative  Courts  shall  also  be 
effected  by  virtue  of  a  similar  decree,  by  selection  among  the  members  of  the  respective  General 
Commission and the Presidents of the Administrative Courts of Appeal, as specified by law”.   

9   GRECO, Fourth Evaluation Round - Second Compliance Report, recommendation xii (p.7). See also 2020 

Rule of Law Report, country chapter on the rule of law situation in Greece, p. 3.   

10   Input  from  Greece  for  the  2021  Rule  of  Law  Report,  p.  1.  In  this  context,  it  can  be  noted  that  there  is  a 
constitutional  ban  on  a  revision  of  the  Constitution  before  the  lapse  of  five  years  from  the  previous  one. 
Constitution of Greece, Article 110 para 6.  

11   Information received in the context of the country visit to Greece. 
12   Law  3841/2010  (OJ  55A/06.04.2010)  on  the  selection  of  magistrates  for  the  top  posts  of  Justice  and  the 

reinstatement of the self-governance on courts. 

13   Regulation of the functioning of the Greek Parliament, Art. 12 and 13. 
14   Regulation of the functioning of the Parliament, Art. 1. 
15   In  the  past,  very  few  non-successful  candidates  tried  to  challenge  the  final  decision  before  the  Council  of 
State,  which  rejected  their  recourse  as  lacking  the  legal  base.  Information  received  in  the  context  of  the 
country visit to Greece. 

16   Information received by the Ministry of Justice in the context of the country visit to Greece. 
17   The Greek authorities did not provide any details on this draft. 
18   Information received by the Ministry of Justice in the context of the country visit to Greece.  

3 

 
                                                 
is  important  that  this  draft  law  takes  into  account  Council  of  Europe  recommendations 
relating to judicial independence19. 

The preparation of a Code of Conduct for the Administrative branch of the Judiciary is 
ongoing. The President  of the Council of State decided in  November 201920, to  establish a 
committee for preparing a draft Code of Conduct, which completed its work in May 202121. 
Currently, there is no Code of conduct covering the judiciary and as reported by the Group of 
States against Corruption of the Council of Europe (GRECO), integrity in the judiciary is a 
challenge22.  

Quality  

New specialised court sections are in the process of being set up and are expected to take 
up  their  activity  shortly.  Legislation  adopted  in  June  202023  provides  for  the  set-up  of  a 
number of special chambers within civil and administrative courts to improve specialisation 
in particular in areas related to EU law on electronic communications, energy, protection of 
personal data, personal insolvency cases, and for certain types of administrative disputes24.  

Concrete  steps  have  been  taken  as  regards  digitalisation  of  justice  but  challenges 
remain. Building on past years’ achievements, new initiatives25 have been taken allowing in 
particular  for  submitting  cases  electronically  and  monitoring  the  different  stages  of 
proceedings26.  Although  the  distribution  of  digital  signatures  to  judges  and  clerical  staff  of 
courthouses  is  progressing27,  a  number  of  challenges  remain28.  The  full  implementation  of 
electronic filing is hampered by delays and its availability remains partial, inconsistent, and 
mainly  restricted  to  some  courts.  Even  in  those  courts,  the  actual  use  of  e-filing  remains 
minimal, partly due to a lack of familiarisation of stakeholders with the new tools29. A new 
electronic  recording  system  for  criminal  proceedings  is  being  progressively  introduced, 
starting  with  a  pilot  at  the  Court  of  first  instance  of  Athens,  which  has  been  applied  to  21 
courts30.  Other  relevant  measures  concern  the  electronic  issuing  of  certain  categories  of 
judicial certificates, including a polyvalent certificate on judicial solvency clearance recently 
made  available.  The  electronic  insolvency  registry  is  operational  and  linked  to  other  EU 

19   Recommendation CM/Rec(2010)12 of the Committee of Ministers of the Council of Europe.  
20   Act of the President of the Council of State of 21.11.2019.  
21   Input from  Greece for the 2021 Rule of Law  Report,  p. 3. The Code  is due to be published by  the end of 

2021. 

22   The Court of Audit has adopted a charter of ethics for its members. 
23   Law 4700/2020 (A΄ 127), Art. 359 and 360.  
24   Information received by the Ministry of Justice in the context of the country visit to Greece. 
25   2020 Rule of Law Report, country chapter on the rule of law situation in Greece, p.3. 
26   Figures 40, 43, 44, 47, 48, 2021 EU Justice Scoreboard. 
27   Information received by the Ministry of Justice in the context of the country visit to Greece. 
28   European Commission, Enhanced Surveillance Report for Greece 2021, pp.34-35. The representative of the 
Supreme  Court and the Representative of the association of judges also confirmed this during the Country 
visit  on  18  March  2021.  The  Athens  Bar  Association  considers  that  the  Minister  of  Justice  has  been 
unresponsive to requests for financial and logistic assistance, thus forcing lawyer associations to proceed as 
best  they  could  and  to  launch  a  call  for  bids  for  the  provision  of  digital  signatures  to  their  members; 
Information received in the context of the country visit to Greece by the Supreme Court. 

29.  The  availability  of  such  means  is  limited  to  the  Athens,  Piraeus,  Thessaloniki  and  Chalkis  courts  and 
functionality is mainly confined to the filing of legal documents initiating proceedings (Information received 
in the context of the country visit to Greece). 

30   There is also ongoing training of staff in 7 courts. Electronic issuance and availability of civil court decisions 

has also been made available currently in 16 courts and progressing swiftly to the remainder. 

4 

 
                                                 
registries. The e-platform for the conduct of electronic auctions has been upgraded. Extracts 
from  the  criminal  records are provided to  applicants  and criminal  complaints are processed 
electronically31.  

The  system  for  the  collection  of  judicial  statistics  is  progressing.  An  office  for  the 
collection and processing of judicial statistics was established32 in the Ministry of Justice at 
the  end  of  2020,  with  the  objective  of  systematic  collection  of  qualitative  and  quantitative 
statistical data. Implementing legislation is being drafted and the launch of a call for bids for 
the procurement of the relevant infrastructure and services is being prepared33.  

The new Code of Judicial Staff was adopted on 24 April 2021. Following completion of 
public consultation on the draft code on 21 January 202134, the legislation was adopted by the 
Parliament35. The legislation introduces new provisions on career and disciplinary procedures 
for clerical judicial staff. 

The  reform  of  the  judicial  map  is  a  priority  for  the  Government.  A  study  published  in 
2021  provides  a  detailed  analysis  of  the  shortcomings  of  the  current  judicial  map  and 
proposes  changes36  taking  into  consideration  current  demographics,  developments  in 
information  and  communication  technology,  and  other  relevant  parameters37.  In  the 
framework of the preparation of the Greek Recovery and Resilience Plan38, the Ministry of 
Justice  stated  its  intention  to  carry  out  such  reform  as  a  priority  on  the  basis  of  data  to  be 
collected by the office for the collection and processing of judicial statistics. The Council of 
State started in late 2020 revising the judicial map of the administrative courts nationwide39. 
As regards the civil and criminal courts, the Ministry of Justice intends to start the review of 
the judicial map with the assistance of a consultant. It is important that this reform takes into 
account relevant European standards40. 

In the context of the COVID-19 pandemic, court hearings and decisions continued to be 
issued for a category of cases.  During the lockdowns in 2020 and 2021, judicial decisions 
were  regularly issued  especially for the majority of civil  cases at  second instance or higher 
degree of jurisdiction41. Furthermore, during the second lockdown (starting on 7 November 
2020),  the  hearing,  including  with  the  use  of  teleconferences  or  remote  conferences,  of  a 
number  of  categories  of  cases  was  allowed  to  take  place  before  the  criminal,  civil  and 
administrative courts42. By virtue of a proposal from the Ministry of Justice and accepted by 

31   Input from Greece for the 2021 Rule of Law Report. More generally, the Government notes that as of 1 June 

2021 financial aid will be provided to self-employed lawyers for buying new IT equipment.  

32   Law 4700/2020 on certain competences of the Court of Audit, Art. 358. 
33   Information received by the Ministry of Justice in the context of the country visit to Greece. 
34  Draft law of the Ministry of Justice entitled “Code of Judicial Officers”. 
35   Law  4798/2021,  “Code  of  Judicial  Staff”.  See  also  European  Commission,  Enhanced  Surveillance  Report 

for Greece 2021, p.37. 

36   Dianeosis,  Justice  in  Greece,  Proposals  for  a  modern  judicial  system,  pp.  77-108.  The  issue  was  also 
discussed in the context of the virtual country visit to Greece with M. Pikramenos, Judge and Member of the 
Council of State. 

37   2020 Rule of Law Report, country chapter on the rule of law situation in Greece, p.4. 
38   A  number  of  reforms  including  those  related  to  e-justice  and  the  reviewing  of  the  judicial  map  will  be 

implemented with the assistance of the Recovery and Resilience Facility. 

39   Information received by the Council of State in the context of the country visit to Greece. 
40   GRECO, Fourth Evaluation Round - Evaluation Report. See also Recommendation CM/Rec(2010)12 of the 

Committee of Ministers of the Council of Europe, para. 52 
41   As there was no obligation to be present or to hear witnesses. 
42   Another halt has been marked in February 2021. 

5 

 
                                                 
the judiciary, hearings postponed during the COVID-19 pandemic will be rescheduled in the 
near future, without any additional fees placed upon the parties43. However, all enforcement 
proceedings,  including auctions, were suspended for most part of 2020 and remained so by 
virtue of consecutive Joint Ministerial Decisions until early April 202144. 

Efficiency 

The justice system continues to face challenges as regards its overall efficiency45. 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 
continued  to  increase  (637  days  in  2019  compared  to  559  days  in  2018)46.  In  addition,  the 
productivity  of  first  instance  courts  has  not  improved  as  regards  the  clearance  rate  for 
litigious  civil  and  commercial  cases  (86.2%  in  2019  compared  to  86.3%  in  2017)47,  which 
means  that  Greece  is  facing  a  clear  risk  of  building  up  additional  backlogs,  further 
exacerbated  by  the  consequences  of  partial  interruptions  of  work  due  to  the  COVID-19 
pandemic48. Postponements caused significant delays and backlogs, some cases having been 
scheduled for trial on remote future dates, up to 2026 or even later49. Stakeholders continue 
identifying a range of procedural challenges, which the previous reforms of the Code of Civil 
Procedure sought to address, but which persist to this day50.  

Steps are being taken for the review of the Code of Civil Procedure. The authorities are 
working on the finalisation of draft amendments to the Code of Civil Procedure, which will 
include improvements in judicial proceedings in all instances and in the execution of judicial 
sentences through the e-auction framework. The code is scheduled for adoption by July 2021 
to enable its entry into force at the beginning of the new judicial year in September 202151.  

II. 

ANTI-CORRUPTION FRAMEWORK  

Greece has in place a comprehensive anti-corruption strategic framework, called 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  under 
its jurisdiction52. A new anti-corruption strategy for 2022-2025 is under preparation. Drawing 
on the experience from the previous national  anticorruption plans, the new strategy aims to 
focus on high-risk sectors and activities.  

43   Information received by the Ministry of Justice in the context of the country visit to Greece. 
44   Input from Greece for the 2021 Rule of Law Report, pp. 4-6. 
45   2020 Rule of Law Report, country chapter on the rule of law situation in Greece, p.4. 
46   Figure 6, 2021 EU Justice Scoreboard. 
47   Figure 11, 2021 EU Justice Scoreboard.   
48   Figures 11 and 14, 2021 EU Justice Scoreboard.   
49   Information received during the  meeting  with  the High Jurisdictions, in the context of  the country  visit to 

Greece.  

50   Information received by the Bar Association.in the context of the country visit to Greece. 
51   European Commission, Enhanced Surveillance Report for Greece 2021, p.25.  
52   2020 Rule of Law Report, country chapter on the rule of law situation in Greece, p. 5. 

6 

 
                                                 
The perception among experts and business executives is that the level of corruption in 
the  public  sector  remains  relatively  high53.  In  the  2020  Corruption  Perceptions  Index  by 
Transparency International, Greece scores 50/100 and ranks 16th in the European Union and 
59th globally54. This perception has improved55 over the past five years56. 

is  gradually 

Administrative  capacity 
improving. 
in  anti-corruption  authorities 
Established in August 2019, the National Transparency Authority is an independent authority 
responsible  for  the  coordination  of  the  anti-corruption  plan  as  well  as  for  preventing, 
detecting  and  addressing  fraud  and  corruption  in  the  public  sector  and,  under  certain 
circumstances,  in  private  sector  entities.  The National  Transparency  Authority  continued 
recruiting additional personnel and has recently reached a total of 390 officers (including 260 
investigators  and  auditors,  70  experts  and  60  supporting  staff).  The  National  Transparency 
Authority  has  recently  released  a  fraud  risk-management  tool,  for  risk  mapping  in  public 
institutions.  The  prosecutor’s  office  of  economic  crime  has  merged  with  the  regional 
prosecutor’s offices of corruption of Athens and Thessaloniki.  

Shortcomings  remain  regarding  the  effectiveness  of  action  against  high-profile 
corruption.  The  challenges  for  the  prosecution  office  concern  in  particular  the  lack  of 
administrative and paralegal staff and as well as highly skilled investigators; a general lack of 
and delay in rolling out digital tools to detect sophisticated financial crimes; and absence of a 
system for case-management57. As a follow-up to the assessment in last year’s report of the 
consequences of successive amendments to the definition of active bribery and the applicable 
sanctions58, it was reported that, while there is no data on the number and type of corruption 
cases  affected  by  these  successive  changes,  in  2020  the  lex  mitior  (“most  favourable  law”) 
principle was applied in at least one high-profile case, which involved politicians59. 

Provisions regarding immunity were recently updated. The constitutional review of 2019 
on  the  modification  of  the  immunity  regime  for  members  of  the  Parliament  and  Ministers 
entered into force in 2020 and resulted in an extension of the statutory limit for investigations 
against these high-level officials and in a lifting of immunity for corruption cases60. 

53   Corruption Perceptions Index 2020, pp. 2-3. The level of perceived corruption is categorised as follows: low 
(the  perception  among  experts  and  business  executives  of  public  sector  corruption scores  above  79); 
relatively low (scores between 79-60), relatively high (scores between 59-50), high (scores below 50). 

54   Transparency International, Corruption Perceptions Index 2020 (2021). 
55   In  2015  the  score  was  46,  while  in  in  2020,  the  score  was  50.  The  score  significantly  increases/decreases 
when  it  changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5  points);  is  relatively 
stable (changes from 1-3 points) in the last five years. 

56   The Eurobarometer data on corruption perception and experience of citizens and businesses as reported last 
year is updated every second year. The latest data set is the Special Eurobarometer 502 (2020) and the Flash 
Eurobarometer 482 (2019). 

57   Information received in the context of the country visit to Greece. 
58   Last  year’s  report  referred  to  the  amendments  passed  in  June  2019,  which  downgraded  the  active  bribery 
offence  to  a  misdemeanour,  also  lowering  the  associated  sanctions  and  were  repealed  in  November  2019 
following  concerns  voiced  by  the  Group  of  States  against  Corruption  (GRECO)  and  the  Organisation  for 
Economic Co-operation (OECD).  

59   Information received by the Ministry of Justice in the context of the country visit to Greece. 
60   The  constitutional  provisions  on  immunity  for  Members  of  Parliament  and  of  Ministers  were  modified  in 
2019, in addition to the abolishment of the  special  statute  of limitations, 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 Ministers). The relevant provisions 
entered  into  force  on  28  November  2019  and  are  not  applicable  retroactively.  Information  received  in  the 

7 

 
                                                 
 
Legislative steps to reform the asset declaration framework are being undertaken, while 
the verification and publication of asset declarations for officials and parliamentarians 
continues  to  face  challenges,  despite  some  progress.  A  draft  law  is  being  currently 
developed, with the aim to reform the framework of the asset declarations61. The system of 
asset  declarations  is  divided62  among  four  oversight bodies63.  Audits  performed  in  2020  by 
the National Transparency Authority, which is also responsible for asset disclosures by civil 
servants,  auditors  and  inspectors,  have  revealed  several  breaches,  notably  15  cases  of  non-
declared revenues and two cases of possible conflict of interest. Data available for publication 
concerning asset declarations by members of Parliament, political parties and members of the 
judiciary is published. The Committee of Parliament for the Investigation of Declarations of 
Assets (CIDA) is competent for reviewing the asset declarations by members of Parliament, 
political  parties  and  members  of  the  judiciary.  The  CIDA  is  supported  by  a  secretariat  (a 
directorate  of  21  officers),  individual  accountants  and  a  prosecutor.  The  CIDA  secretariat 
manages an annual workload of several thousands of declarations. The authorities report that, 
in early 2021, CIDA had a backlog of approximately 20 000 declarations pending scrutiny64. 
Practice  shows  that  asset  declarations  by  members  of  Parliament  are  not  published  in  a 
machine-readable format65. Political parties are to submit their financial statements to CIDA 
indicating the amount and source of income and expenses, including financial obligations or 
debts.  Following  audits,  CIDA  has  found  financial  breaches  by  11  political  parties66. 
Recurrent violations concern state subsidies that are not properly spent (i.e. not on time or for 
the given purpose), and payments are not made from a party’s official bank account. Parties 
found in breach of financial provisions have had their state subsidies reduced accordingly. No 
data is available on the asset declarations by members of the judiciary67. CIDA publishes its 
yearly report online. Information on the results of the checks performed by CIDA as well as 
on the breaches or sanctions issued is not included in the public report68. 

The Internal Affairs Unit of the Police is competent for the follow-up of anti-corruption 
measures  in  the  police  and  other  public  security  services69.  The  audit  committee 

context of the country visit to Greece. No figures have been provided regarding cases handled under the new 
provisions. 

61   This draft law would replace law n. 3213 of 2003 (on Declaration and verification of assets for members of 
parliament, public officials and employees, media owners and other groups of persons) and it is expected to 
simplify  the electronic procedure and to promote further the  transparency and the fight against corruption. 
The draft of this initiative is expected to be submitted to the Quality Evaluation Committee within the law 
making procedure. Input from Greece for the 2021 Rule of Law Report.  

62   Information received in the context of the country visit to Greece. 
63   The Committee of Parliament for the Investigation of Declarations of Assets (CIDA), the Source of Funds 
Investigation  Unit  of  the  FIU;  the  Internal  Affairs  Unit  of  the  Police,  and  the  National  Transparency 
Authority. 

64   The  authorities report that in  July 2019 CIDA had to check approximately 20,000 declarations of  the past 
four  years,  which  were  resubmitted  following  a  court  order  in  2018.  Due  to  COVID-19  situation  and 
restrictions in 2020 and 2021, the check is expected to be completed at the end of 2021. Input from Greece 
for the 2021 Rule of Law Report. 

65   Information received in the context of the country visit to Greece. 
66   Information received by CIDA in the context of the country visit to Greece. 
67   Data on the asset declarations by members of the judiciary are expected to be included in the forthcoming 

reports. Input from Greece for the 2021 Rule of Law Report. 

68   The results of the checks performed by CIDA in case of breaches or sanctions issued are forwarded to the 
regular justice. The outcome of that procedure is beyond the competence of the CIDA, and it is not known 
beforehand. Input from Greece for the 2021 Rule of Law Report. 

69   Officers from the police and other services, such as guards and security forces (around 54 000 in total) are 
required  to  submit  their  asset  declarations  online.  In  2020,  more  than  half  of  the  officers  has  filed  asset 

8 

 
                                                                                                                                                        
 
responsible for checking the filed declarations, composed of 20 officers, has the capacity to 
verify  only  15-20%  of  the  declarations  filed  annually70.  No  clear  records  are  available  in 
relation  to  the  workload  and  effectiveness  of  the  internal  affairs  unit.  Similarly,  there  is  no 
evidence  of  specific  anti-corruption  training  or  educational  awareness  delivered  to  officers 
under the purview of the internal affairs unit. 

There has been no change as regards regulation of lobbying compared to the previous 
reporting  period.  The  National  Transparency  Authority,  together  with  the  Ministry  of  the 
Interior,  has  developed  a  draft  law  on  the  regulation  of  lobbying.  The  objectives  are  to 
establish  clear  rules  and  a  publicly  available  registry  of  lobbyists  and  lobbying  activities71. 
This draft is now subject to public consultation. 

Legislation  for  the  legal  protection  of  whistleblowers  is  in  preparation.  A  committee 
(consisting  of  a  judge,  lawyers,  law  professors,  the  National  Transparency  Authority,  the 
Ministry of Justice and the Ministry of Interior) has been set up by the Government, and it is 
tasked  with  preparing  draft  legislation  on  whistleblower  protection72.  For  the  time  being, 
whistleblower  protection  exists  in  administrative  law  for  the  protection  of  civil  servants 
against retaliation and in criminal law for the protection of ‘public interest witnesses’ in penal 
cases. 

Some amendments were made in the public procurement procedures in the context of 
the  COVID-19  pandemic.  Since  the  outbreak  of  the  COVID-19  pandemic,  the  Hellenic 
Single  Public  Procurement  Authority,  the  Greek  authority  for  the  effective  and  uniform 
implementation  of  the  public  procurement  framework,  has  declared  that  emergency 
procedures  should  be  followed  only  as  far  as  necessary,  and  always  within  the  legal 
framework73. In response to the higher risk of corruption linked to the COVID-19 pandemic, 
between  May  and  December  2020,  the  National  Transparency  Authority  has  performed 
10 678  audits,  and  it  has  issued  fines  for  an  amount  of  EUR  954  950,  and  suspensions  of 
operation for 109 business actors74. 

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

The  Greek  legal  framework  concerning  media  pluralism  is  based  on  a  set  of  constitutional 
safeguards and legislative measures. The Constitution provides for the protection of freedom 
of expression and the right to access public information and provides for a right of access to 
documents  held  by  public  bodies.  Legislation  was  adopted  to  transpose  the  revised 
Audiovisual  Media  Services  Directive  (AVMSD).The  National  Council  for  Radio  and 
Television  (NCRTV)  supervises  and  regulates  the  radio  and  television  markets.  Its 
independence  is  enshrined  in  the  Constitution75,  and  its  legal  framework76  is  set  out  in  the 
Media Law77. 

declarations.  For  those  not  disclosing  their  assets,  the  internal  affairs  unit  may  send  a  reminder  of  the 
obligation. In case of inaccurate or incomplete asset declaration filed, the case can be sent to the prosecutor 
(for  further  analyses,  and  possible  criminal  action),  or  be  assessed  by  the  internal  affairs  unit  under  a 
disciplinary procedure (for a possible fine of up-to EUR 5 000). 

70   Information received by the Internal Affairs Unit of the Police in the context of the country visit to Greece. 
71   Ibid. 
72   Information received by the National Transparency Authority in the context of the country visit to Greece. 
73   Hellenic Single Public Procurement Authority (2020), COVID-19 and Public Procurement.  
74   Input from Greece for the 2021 Rule of Law Report. 
75   Constitution of Greece, Art. 15(2). 

9 

 
                                                                                                                                                        
Greece  has  strengthened  the  independence  of  the  media  regulator,  but  its  financial 
resources  continue  to  be  a  matter  of  concern.  The  new  law78  transposing  the  revised 
AVMSD includes provisions aimed at reinforcing the independence of the NCRTV from the 
Government  and  other  state  entities.  However,  the  Greek  government  has  not  foreseen  any 
reinforcement  of  the  financial  capacity  of  the  NCRTV  nor  provided  adequate  resources  to 
have  it  perform  the  new  tasks  envisaged  in  the  AVMSD.  In  this  regard,  the  Greek 
Government  has  requested  the  NCRTV  to  submit  an  action  plan,  indicating  resources  and 
technical equipment needed for the new enhanced tasks79. 

New  legislation  aims  to  enhance  the  transparency  of  media  ownership  and  public 
availability of media ownership information. The new law80 introduces the obligation for 
media  service  providers,  linear  or  non-linear,  subscription  or  free-to-air,  to  register  in  the 
NCRTV Business Register. The registration information  includes the name of the provider, 
its registered office, the details of its legal representatives, full contact details and information 
on  the  provider’s  ownership  status.  Some  concern  remains  on  the  lack  of  systematic 
disclosure  of  ownership  information  to  the  public  by  news  media81.  Media  legislation 
contains  safeguards  against  high  horizontal  concentration  in  ‘information’  media  markets 
(TV, radio, newspapers and magazines) and cross-media concentration82. 

The Government has adopted certain measures to mitigate the effect of the COVID-19 
pandemic. Such measures were mainly centred around payment facilities for the licence and 
retransmission  fee,  reduction  of  the  rent  of  cinemas,  and  a  small  fund  to  support  the 
production of documentaries. In addition, further measures have been adopted which include, 
amongst  others,  exemptions  from  the  payment  of  the  advertising  contribution  and  tax  and 
facilities for the payment of the journalist’s contributions to their security fund83.  

Attacks  on  and  threats  to  the  physical  safety  of  journalists  continue.  Following  the 
concerns  described  in  the  last  report,  as  regards  journalists’  working  conditions  and  safety, 
there  were  further  attacks  on  journalists,  followed  by  an  immediate  reaction  from  the 
authorities. Four new alerts were created on the Council of Europe Platform to promote the 
protection of journalism and safety of journalists84. The most recent alert refers to the murder 
of  Greek  investigative  journalist  Giorgos  Karaivaz,  which  has  highlighted  concerns  in 
relation  to  the  safety  of  journalists  and  the  necessity  of  improving  their  protection85.  The 
Government condemned the murder and an investigation started immediately. Another alert 
refers  to  an  attack  by  police  officers  on  a  journalist  reporting  on  protests.  The  Greek 

76   Law 4339/2015; Laws 1866/1989, 2328/1995, 2644/1998, 2863/2000 etc., as amended. 
77   Greece has fallen five places down to 70th (24th place among the EU Member States), out of 180 monitored 

countries, in the 2021 World Press Freedom Index of Reporters Without Borders.  

78   Law 4779/2021.  
79   Input from Greece for the 2021 Rule of Law Report. 
80   Law 4779/2021. 
81   2021 Media pluralism Monitor, Greece, p. 15 
82   Availability  of  data  on  market  and  audience  shares  in  certain  media  markets  and  the  media  market  as  a 

whole appears to be an issue. See 2021 Media Pluralism Monitor, Greece, p.11. 

83   European Regulators Group for Audiovisual Media Services (ERGA), Report on the economic impact of the 
COVID-19 crisis on the audiovisual sector 2020 and information received in the context of the country visit 
to Greece. 

84   Council of Europe, Platform to promote the protection of journalism and safety of journalists, Greece.  
85   The  case  is  currently  under  investigation.  Pursuant  to  the  Greek  legislation  (art.  68,  70  and  156  of  the 
Presidential Decree 141/1991) protection by the Police is available for vulnerable targets, provided either ex 
officio or after the interested person’s request, when there is a threat against their life and physical integrity. 

10 

 
                                                                                                                                                        
Government has replied to this alert that an investigation has been ordered. Yet another alert 
concerns an assault  on the offices of  a TV station by  individuals protesting in support of a 
convicted  terrorist.  The  Government  condemned  the  “unacceptable  intimidation”  in  a 
statement,  calling  the  attack  “another  blow  against  the  free  press  and  the  republic  by  the 
supporters of the convicted terrorist”. The final alert concerns an arrest warrant issued against 
a journalist and publisher of a newspaper over an alleged violation of data privacy rights. The 
arrest warrant was never acted upon but the complaint by the police officers over an alleged 
violation  of  data  privacy  rights  is  still  active.  The  2021  Media  Pluralism  Monitor  (MPM 
2021) also indicates that journalists are not free from attacks on and threats to their physical 
safety. 

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  Constitution.  Legislative  power  is  vested  in  the  Parliament  and  the 
President  and  the  right  to  introduce  legislation  belongs  to  the  Parliament  and  the 
Government86.  

Further  steps  were  taken  to  improve  the  quality  of  the  legislative  process.  The 
implementation  of  the  Executive  State  Law87  is  ongoing  in  order  to  standardise  and 
streamline  the  preparatory  phase  of  the  legislative  process  and  to  improve  its  quality.  This 
law  introduced  a  new  executive  public  service,  the  Presidency  of  the  Government,  with  a 
more  active  role  in  the  legislative  process,  through  the  General  Secretariat  of  Legal  and 
Parliamentary  Affairs.  At  the  end  of  2020,  the  General  Secretariat  for  Parliamentary  and 
Legal Affairs issued guidance to all Ministries on the drafting of impact assessment reports 
accompanying  draft  legislation  and  on  the  methodology  and  codification  of  legislation.  An 
interdisciplinary body, the Committee for the Evaluation  of the  Quality  of the  Law-making 
Process88, has been established to carry out quality control of each draft law against the law-
making principles as well as the constitutionality of draft legislative provisions89. A Central 
Codification Committee has been established90 to coordinate the legal codification and for the 
development of the annual codification plan91. In September 2020, the Cabinet of Ministers 
endorsed the first annual plan and work is progressing92. According to national stakeholders, 
these reform initiatives have improved the quality of draft bills tabled in Parliament and have 
contributed  to  a  considerable  reduction  of  “last-minute”  amendments  containing  provisions 
unrelated  to  the  main  provisions  of  the  law93.  However,  stakeholders,  and  particularly  the 
Ombudsperson, often do not receive draft legislation in a timely manner and sometimes only 
when the draft becomes public94. The consultation of the Ombudsperson and stakeholders, is 

86   2020 Rule of Law Report, country chapter on the rule of law situation in Greece, p. 10. 
87   Law 4622/2019. 
88   The  Committee  is  composed  of  independent  and  highly  qualified  lawyers  and  economists  who  provide 

feedback on impact assessment. 

89   Information received by the Committee for the Evaluation of the Quality of the Law-making Process in the 
context  of  the  country  visit  to  Greece.  Since  October  2020,  the  Committee  has  been  reinforced  by  adding 
three members and dividing its operational structure in two chambers, so as to increase its efficiency. 

90   Law 4622/2019, Art. 65-67. 
91   In consultation with the line ministries under each policy area, and the coordination of the implementation of 
the annual codification plan, while the groundwork on the legal codification has been transferred to the line 
ministries. 

92   Information received by the Ministry of Justice in the context of the country visit to Greece. 
93   Reduced by 33% in 2020 and by 50% currently. 
94   Information received by the Ombudsperson.in the context of the country visit to Greece 

11 

 
                                                 
taking place for approximately half the proposed legislation95. Furthermore, the Government 
involved  NGO’s  with  a  variety  of  initiatives,  such  as  the  national  plan  for  persons  with 
disabilities or reforms to family law96. 

During  the  COVID-19  pandemic,  Greece  has  not  triggered  a  state  of  emergency.  All 
relevant  measures  were  taken  according  to  the  normal  legislative  procedure.  No  court  has 
been  reported  to  have  ruled  on  any  of  the  measures  taken  in  this  context  yet97.  During  this 
period,  Parliament  allowed  votes  to  be  cast  before  parliamentary  sessions  under  certain 
conditions,  by  letter  or  fax,  in  the  absence  of  more  developed  digital  systems,  with  the 
member’s signature and indication of the matter put to the vote98. Although the circumstances 
under which this  possibility can be used are limited, Parliament decided  to  make a  flexible 
interpretation  of  its  internal  rules,  accepting  the  non-physical  presence  of  its  Members,  to 
adapt to the context of the COVID-19 pandemic99. 

The powers of the Ombudsperson Institution have been reinforced. Pursuant to new legal 
provisions  adopted  at  the  end  of  2020100,  the  Ombudsperson  is  designated  as  the  National 
Mechanism for Investigating Incidents of Arbitrariness with the responsibility of collecting, 
recording,  evaluating  and  investigating  complaints  about  action  or  inaction  by  law 
enforcement agents. The new provisions have provided the Ombudsperson Institution with a 
set of tools and mechanisms, as well as with the necessary additional human resources. The 
Ombudsperson  monitors  continuously  the  level  of  compliance  of  the  public  administration 
with its recommendations101. In the COVID-19 pandemic context, the Ombudsperson has not 
been contacted formally by any State authority, but submitted on his own initiative a set of 
recommendations, mainly concerning vulnerable groups. As part of its Annual Report for the 
United  Nations  he  submitted  information  describing  the  COVID-19  related  restrictions102. 
Given  the  relevance  of  migration  and  asylum  in  Greece,  the  Ombudsperson  intervenes  on 
these issues and recently published an own initiative report on allegations of pushback103. 

The requirements for the registration of NGOs active in the area of asylum, migration 
and  social  inclusion  continue  to  raise  concerns.  These  concerns  regarding  the  ability  of 
NGOs  to  operate  in  Greece  and  to  receive  financial  support  in  light  of  the  rules  on  the 
registration and certification introduced in 2020104 have been highlighted in a recent report of 
the Council of Europe Expert Council on NGO Law105 by three UN Special Rapporteurs106, 

95   Ibid.  
96   Information received by the Ministry of Justice in the context of the country visit to Greece.  
97   Ibid. 
98   Standing Orders of the Hellenic Parliament, Art. 70A. 
99   As  explained  by  its  president  on  12  March  2020;  European  Parliamentary  Research  Service  (2020), 
Parliaments in emergency mode: How Member States' parliaments are continuing with business during the 
pandemic.  

100  Law 4662/2020, Art. 188. 
101  Information received by the Ombudsperson in the context of the country visit to Greece. 
102  Ibid. 
103  The Greek Ombudsman, Interim Report - Alleged pushbacks to Turkey of foreign nationals who had arrived 

in Greece seeking international protection, 31 December 2020, p. 21. 

104  2020 Rule of Law Report, country chapter on the rule of law situation in Greece, p.12.  
105  Expert  Council  on  NGO  Law,  Addendum  to  the  opinion  on  the  compatibility  with  European  standards  of 
recent and planned amendments to the Greek legislation on NGO registration, 23 November 2020; See also 
Expert  Council  on  NGO  Law  of  the  Conference  on  INGOs  of  the  Council  of  Europe,  Opinion  on  the 
compatibility with European standards of recent and planned amendments to the Greek legislation on NGO 
registration, 2 July 2020;  

12 

 
                                                 
by  the  European  Union  Agency  for  Fundamental  Rights107  and  by  an  NGO  specialised  in 
asylum, migration and social inclusion issues108. The aim pursued by the legislation, namely 
ensuring  transparency  on  registration109,  can  be  considered  as  legitimate.  Nevertheless,  the 
registration requirements  should not  go beyond what  is  strictly necessary  and proportionate 
and  in  particular  should  not  be  excessively  burdensome.  An  appeal  is  pending  before  the 
Council of State on some aspects of the legislation and a complaint has been filed with the 
Ombudsperson by NGOs, which have been refused registration for not fulfilling either formal 
or substantial criteria110. 

106  UN Special Rapporteur on the rights to freedom of peaceful assembly and of association, Special Rapporteur 
on the situation of human rights defenders and Special Rapporteur on the human rights of migrants, letter of 
31 March 2021, OL GRC 1/2021. 

107  Contribution  from  the  European  Union  Agency  for  Fundamental  Rights  (FRA)  to  the  2021  Rule  of  Law 
Report, Chapter on Greece, “Legal environment and space of civil society organisations in Greece”, pp: 6-8. 
108  Contribution  from  Refugee  Support  Aegean  (RSA)  for  the  2021  Rule  of  Law  Report,  pp:  6-9.  See  also 
Amnesty  International,  “Greece:  Worrying  legal  developments  for  asylum-seekers  and  NGOs”  of  4  May 
2020 and “Greece: Regulation of NGOs working on migration and asylum threatens civic space” of 31 July 
2020.  

109  I.e.  the  objective  of  ensuring  transparency  in  the  way  NGOs  active  in  the  area  of  international  protection, 
migration and social inclusion operate, and thereby optimizing the services provided by them, as well as of 
enabling the human rights of refugees and migrants to be safeguarded and for reasons of public interest. In 
April  2021  the  Ministry  of  Migration  and  Asylum  provided  an  official  briefing  note  presenting  the 
explanation and the aims of the legislation.  

110  Information received by the Ombudsperson in the context of the country visit to Greece. 

13 

 
                                                                                                                                                        
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2021 Rule of Law report 
can  be  found  at  https://ec.europa.eu/info/policies/justice-and-fundamental-rights/upholding-rule-
law/rule-law/rule-law-mechanism/2021-rule-law-report-targeted-stakeholder-consultation. 

Amnesty  International  (2020),  Greece:  Regulation  of  NGOs  working  on  migration  and  asylum 
threatens civic space. 

Amnesty International (2020), Greece: Worrying legal developments for asylum-seekers and NGOs  

Centre  for  Media  Pluralism  and  Media  Freedom  (2021),  Media  pluralism  monitor  2021  (link  to  be 
added when available). 

Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  – 
Greece (https://www.coe.int/en/web/media-freedom/greece) 

Dianeosis 
(https://www.dianeosis.org/wp-content/uploads/2019/02/justice_study.pdf) 

in  Greece:  Proposals 

(2019), 

Justice 

for 

a  modern 

judicial 

system 

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 Commission (2020), Rule of Law Report, Country Chapter on the rule of law situation in 
Greece.  

European 
(https://ec.europa.eu/info/sites/info/files/economy-finance/ip145_en.pdf). 

Commission 

Surveillance 

Enhanced 

(2021), 

Report 

for 

Greece 

European  Parliamentary  Research  Service  (2020),  Parliaments  in  emergency  mode:  How  Member 
States' 
pandemic 
(https://www.europarl.europa.eu/thinktank/en/document.html?reference=EPRS_BRI(2020)649396).  

parliaments 

continuing 

business 

during 

with 

are 

the 

European  Union  Agency  for  Fundamental  Rights  (FRA),  Contribution  from  the  European  Union 
Agency for Fundamental Rights to the 2021 Rule of Law Report. 

Expert Council on NGO Law of the Conference on INGOs of the Council of Europe (2020), Opinion 
on  the  compatibility  with  European  standards  of  recent  and  planned  amendments  to  the  Greek 
legislation  on  NGO  registration  (https://rm.coe.int/expert-council-conf-exp-2020-4-opinion-ngo-
registration-greece/16809ee91d).  

recent  and  planned  amendments 

Expert Council on NGO Law, Addendum to the opinion on the compatibility with European standards 
of 
registration 
(https://rm.coe.int/expert-council-conf-exp-2020-5-addendum-to-the-opinion-on-the-
compatib/1680a076f2).  

legislation  on  NGO 

the  Greek 

to 

GRECO (2015), Fourth Evaluation Round - Evaluation Report on Greece on Corruption prevention 
in respect of members of parliament, judges and prosecutors. 

GRECO  (2020),  Fourth  Evaluation  Round  -  Second  Compliance  Report  on  Greece  on  Corruption 
prevention  in  respect  of  members  of  parliament,  judges  and  prosecutors  (https://rm.coe.int/fourth-
evaluation-round-corruption-prevention-in-respect-of-members-of/1680a06121). 

Greek Council of State (2021), Contribution from the Greek Council of State to the 2021 Rule of Law 
Report.  

Greek Government (2021), Input from Greece for the 2021 Rule of Law Report. 

Greek Ombudsman, Annual reports (https://www.synigoros.gr/?i=stp.el.annreports). 

Hellenic  Single  Public  Procurement  Authority  (2020),  COVID-19  and  Public  Procurement 
(https://www.eaadhsy.gr/index.php/en/51-english-version/523-covid-19-and-public-procurement).  

14 

 
Panagiotis  Pikramenos  (2021),  Reforms  in  the  three  main  domains  of  the  Judicial  System 
(Μεταρρύθμιση σε Τρεις Κρίσιμους Τομείς του Δικαστικού Συστήματος). 

Refugee Support Aegean (2021), Contribution from Refugee Support Aegean to the 2021 Rule of Law 
Report.  

Reporters  Without  Borders 
(https://rsf.org/en/greece).  

(2021),  2021  World  Press  Freedom 

Index  –  Greece 

Transparency International (2021), Corruption Perceptions Index 2020. 

UN  Special  Rapporteur  on  the  rights  to  freedom  of  peaceful  assembly  and  of  association,  Special 
Rapporteur on the situation of human rights defenders and Special Rapporteur on the human rights of 
migrants (2021), Letter of 31 March 2021, OL GRC 1/2021. 

15 

 
Annex II: Country visit to Greece 

The Commission services held virtual meetings in March 2021 with: 

  Ministry of Justice 
  Supreme Court  
  Court of Audit 
  Council of State 
  Prosecutor's Office to the Supreme Court 
  Prosecutor for Financial Crimes and the Financial Police Division 
  Association of Judges 
  School of Judges 
  Bar Association 
  Committee for the Evaluation of the Quality of the law-making process 
  Central Codification Committee 
  National Transparency Authority 
 
  Committee of Parliament for the Investigation of Declarations of Assets (CIDA, or 

Internal Affairs Unit of Law Enforcement Bodies 

Committee 3-A) 

  National Audio-visual regulator 
 
Journalists’ union ESIEMTH 
  Greek Ombudsman 
  Transparency International 
  Refugee Support Aegean 
  PRAKSIS 

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

  Amnesty International 
  Center for Reproductive Rights 
  CIVICUS 
  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 
  European Federation of Journalists 
  European Partnership for Democracy  
  European Youth Forum 
  Front Line Defenders 
  Human Rights House Foundation  
  Human Rights Watch  
 
ILGA-Europe 
 
International Commission of Jurists 
 
International Federation for Human Rights 
 
International Planned Parenthood Federation European Network (IPPF EN) 
 
International Press Institute 
  Netherlands Helsinki Committee  
  Open Society European Policy Institute 

16 

 
 
  Philanthropy Advocacy 
  Protection International  
  Reporters without Borders 
  Transparency International EU 

17