COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Greece Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for Greece
Date: 2021-08-04
Institutions: European Commission, Secretariat-General
Subjects: EU aid, EU loan, Greece, coronavirus disease, economic and social cohesion, economic recovery, economic reform, epidemic, investment, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.8.2021  SWD(2021) 155 final/2  CORRIGENDUM  This document corrects document SWD(2021) 155 final of 17.6.2021  Correction of some errors on page 2.  The text should read as follows: COMMISSION STAFF WORKING DOCUMENT Analysis of the recovery and resilience plan of Greece Accompanying the document Proposal for a COUNCIL IMPLEMENTING DECISION on the approval of the assessment of the recovery and resilience plan for Greece {COM(2021) 328 final}  
 
 
Table of contents 
1. 

Executive summary ............................................................................................................................... 2 

2.  Recovery and resilience challenges: scene-setter ................................................................................ 8 

2.1.  Macroeconomic outlook and developments since the 2020 country report ............................... 8 

Challenges related to sustainable growth, cohesion, resilience and policies for the next 
2.2. 
generation ............................................................................................................................................... 10 

2.3. 

Challenges related to the green and digital transition ............................................................... 14 

Green dimension ................................................................................................................................. 14 

Digital dimension ................................................................................................................................ 18 

3.  Objectives, structure and governance of the plan.............................................................................. 23 

3.1.  Overall strategy of the plan ........................................................................................................ 23 

3.2. 

Implementation aspects of the plan ........................................................................................... 27 

4. 

Summary of the assessment of the plan ............................................................................................ 33 

4.1. 

Comprehensive and adequately balanced response to the economic and social situation ...... 33 

4.2. 

Link with country-specific recommendations and the European Semester ............................... 41 

4.3.  Growth potential, job creation, economic, institutional and social resilience, European Pillar of 
Social Rights, mitigating the impact of the crisis, and social territorial cohesion and convergence ...... 52 

4.4. 

The principle of ‘do no significant harm’ .................................................................................... 62 

4.5.  Green transition .......................................................................................................................... 64 

4.6. 

Digital transition .......................................................................................................................... 69 

4.7. 

Lasting impact of the plan ........................................................................................................... 75 

4.8.  Milestones, targets, monitoring and implementation................................................................ 79 

4.9. 

Costing ........................................................................................................................................ 82 

4.10.  Controls and audit ....................................................................................................................... 85 

4.11.  Coherence ................................................................................................................................... 88 

5.  Annex .................................................................................................................................................. 91 

1 

 
 
 
 
 
 
 
1.  EXECUTIVE SUMMARY  

Greece  has  been  severely  affected  by  the  coronavirus  pandemic,  as  the  structure  of  its 
economy with a large share of tourism and transport services sector, and the high share of 
micro  enterprises  have  made  it  particularly  vulnerable  to  the  shocks  triggered  by  travel 
restrictions and social distancing measures.  At  the end of 2019, Greece’s recovery from  the 
decade-long financial crisis was taking hold, with business and consumer confidence at pre-2010 
levels,  and  disposable  income,  investment  and  consumption  steadily  increasing.  The  positive 
trends  that  had  started  to  materialise  as  a  result  of  the  reforms  implemented  under  the 
macroeconomic  adjustment  programmes  and  its  aftermath  were  largely  interrupted  by  the 
outbreak  of  the  pandemic,  which  put  the  challenges  related  to  Greece’s  high  public  debt, 
incomplete external rebalancing and high ratio of non-performing loans to the spotlight again. It 
also  highlighted  the  importance  of  addressing  the  large  investment  gap,  social  and  economic 
inequality and high unemployment, especially of women and young people.  

Greece submitted its Recovery and Resilience Plan, named “Greece 2.0”, on 27 April 2021. 
The cost of all projects in the plan amounts to EUR 31.164 billion, of which EUR 17.770 billion 
is  foreseen  to  be  financed  from  non-repayable  financial  support  and  EUR 12.728 billion  from 
loans up to 2026.  

Structured  around  four  pillars  and  encompassing  a  well-balanced  mix  of  reforms  and 
investments,  the  plan  aims  at  addressing  the  key  structural  challenges  Greece  faces  and 
pursues the objective of the Recovery and Resilience Facility (RRF) Regulation to promote 
the Union’s economic, social and territorial cohesion. The plan also contributes to effectively 
addressing  all  or  a  significant  subset  of  the  country-specific  recommendations  that  were 
addressed to Greece by the Council in 2019 and 2020, and provides a good balance across the six 
policy pillars referred to in Article 3 of the RRF Regulation1. The plan is also consistent with the 
challenges  and  priorities  identified  in  the  most  recent  euro  area  recommendation2.  The  four 
pillars  of  the  plan  are  (i)  green  transition  (EUR 6.2  billion3);  (ii)  digital  transition  (EUR 2.2 
billion);  (iii)  employment,  skills  and  social  cohesion  (EUR 5.2  billion);  and  (iv)  private 
investment and economic and institutional transformation (EUR 4.9 billion), comprising in total 
174  measures,  of  which  68  reforms  and  106  investments.  These  include  key  investments  in 
energy  networks  and  energy  efficiency  of  buildings,  environmental  protection  and  sustainable 

1  Greece  submitted  its  National  Reform  Programme  on  27 April  2021.  The  information  provided  in  the  National 
Reform  Programme  is  being  considered  and  jointly  assessed  in  this  Staff  Working  Document  together  with  the 
Recovery and Resilience Plan. 
2  Pending  final  adoption  by  the  Council,  after  endorsement  by  the  European  Council.  The  text  agreed  by  the 
Eurogroup  on  16 December  2020  is  available  at: https://data.consilium.europa.eu/doc/document/ST-14356-2020-
INIT/en/pdf. 
3 Figures in this paragraph refer to non-repayable financial support only. 

2 

 
 
 
                                                           
transport, investments in very high capacity networks and connectivity, the digitalisation of the 
public  and  the  private  sectors,  education,  reskilling  and  upskilling,  active  and  passive  labour 
market  policies,  social  services,  and  health  care.  The  plan  also  promotes  private-sector 
investments  through  the  RRF  Loan  Facility  (EUR 12.7  billion).  Investments  are  flanked  by 
ambitious  reforms  of  the  business  environment,  labour  market,  education  and  training,  and 
public administration, including tax administration, public procurement, and justice.  

The wide set of investments and reforms is expected to contribute to economic growth and 
thereby  support  the  correction  of  the  identified  macroeconomic  imbalances,  while 
promoting  a  more  inclusive  and  sustainable  growth  model.  The  plan  is  consistent  with  the 
Development  Plan  for  the  Greek  Economy  prepared  under  the  steer  of  the  Nobel  laureate 
Professor  Pissarides  in  2020.  The  measures  presented  in  the  recovery  and  resilience  plan  are 
especially targeted at addressing the large investment gap that has held back growth in Greece in 
the past decade, while also facilitating the green and digital transitions and the modernisation of 
the economy, with a view of promoting export-led growth.  

The  plan  projects  a  rebound  of  economic  growth  (+3.6%)  in  2021,  following  the  severe 
downturn  in  2020  (-8.2%).  Driven  by  both  domestic  and  foreign  demand  as  well  as  the 
supportive stimulus from the Recovery and Resilience Facility, GDP growth is expected to peak 
at  6.2%  in  2022  before  decreasing  to  4.1%  in  2023  and  4.4%  in  2024.  Unemployment  should 
remain  unchanged  at  16.3%  in  2021,  then  decline  progressively  to  reach  11.9%  in  2024.  The 
budget deficit (9.7% of GDP in 2020) is expected to remain broadly unchanged in 2021, mainly 
due to the prolongation of the measures meant to address the consequences of the pandemic, and 
to start improving from 2022. 

The plan ensures that the policies monitored under enhanced surveillance4 continue to be 
pursued  and  are  substantially  reinforced  through  the  support  of  necessary  investments 
under the recovery and resilience plan.  This applies in particular to key areas, such as fiscal 
structural including the tax administration and public procurement; labour market, social benefits 
and health care; the financial sector and business environment; and modernisation of the public 
administration, justice and fight against corruption. Reforms in these areas were essential to the 
emerging  economic  recovery  in  Greece  prior  to  the  outbreak  of  the  pandemic  and  to 
improvements  in  underlying  fiscal  conditions,  both  of  which  were  helping  to  improve  the 
confidence of investors and financial markets. Specific commitments given in the Eurogroup in 
June 2018 will continue to be monitored under enhanced surveillance and provide a basis for the 
release of additional debt support measures up to mid-2022. 

4 Enhanced surveillance supports the continuation, completion, and delivery of reforms agreed under the European 
Stability  Mechanism  stability  support  programme  (2015-2018).  See  Articles  2  and  3  of  Regulation  (EU)  No 
472/2013  of  the  European  Parliament  and  the  Council  of  21 May  2013  on  the  strengthening  of  economic  and 
budgetary surveillance of Member States in the euro area experiencing or threatened with serious difficulties with 
respect to their financial stability, OJ L140, 27.5.2013, p. 1.  

3 

 
 
                                                           
The  first,  green  pillar  of  the  plan  contributes  significantly  to  the  decarbonisation  of  the 
Greek energy sector and of the economy overall, and is consistent with the National Energy 
and  Climate  plan.  Underpinned  by  the  commitment  to  completely  phase  out  lignite-based 
electricity  production  by  2028,  with  all  existing  power  plants  to  be  closed  by  2023,  the  plan 
supports investment in energy networks and includes measures to promote energy efficiency and 
the energy renovation of buildings, reforms of the electricity market, of the licensing process and 
of the financing of renewable energy. It also includes the revision of urban policy and of spatial 
and  maritime  planning,  and  supports  infrastructure  for  electric  vehicles  as  well  as  the 
rehabilitation  of  land  currently  used  for  lignite  mining.  Finally,  the  plan  covers  environmental 
protection issues, such as waste and wastewater management, which have long been an issue for 
Greece, and includes an ambitious plan for reforestation, also supporting biodiversity. Together, 
the  measures  supporting  the  climate  change  objectives  account  for  37.5%  of  the  Greek  plan’s 
total allocation (non-repayable financial support and loans).  

The digital transition is supported through measures included in the second pillar, aiming 
at  enhancing  connectivity,  improving  the  digitalisation  of  public  administration  and 
businesses,  and  contributing  to  the  digital  transformation  of  public  services  and  of 
economic  sectors  and  industrial  activities.  The  plan  promotes  investment  in  fibre  optic 
infrastructure  in  buildings,  submarine  cables  and  5G  networks,  and  promotes  the  adoption  of 
digital technologies by the SMEs. It also includes important investments in the digitalisation of 
archives and digitalisation of public services, including the upgrading of the digital infrastructure 
of  the  Greek  public  administration,  alongside  reforms  to  simplify  and  improve  public 
administration  processes.  Together,  the  measures  supporting  the  digital  transition  objectives 
account  for  23.3%  of  the  Greek  plan’s  total  allocation  (non-repayable  financial  support  and 
loans).  

A  comprehensive  set  of  measures  presented  under  the  third  pillar  aims  at  addressing 
labour market deficiencies, delivering a structural increase in employment, upgrading the 
education and training system, improving social cohesion and increasing the resilience and 
efficiency  of  the  healthcare  sector.  According  to  the  estimations  included  in  the  plan,  the 
implementation of all the measures could lead to 180 000 – 200 000 new permanent jobs, i.e. an 
increase  of  around  5%  compared  to  pre-COVID  employment  levels.  Measures  aim  at 
modernising the labour market, fostering employment, including for women, and reducing long-
term  unemployment  through  hiring  incentives,  reskilling,  and  upskilling.  Investment  in 
upgrading vocational education and training as well as university education further contribute to 
human capital building. Social cohesion will be enhanced by improving access to healthcare and 
social  services,  and  fostering  active  inclusion,  also  addressing  the  challenges  identified  by  the 
Social Scoreboard, such as expanding access to early childhood education and care for children 
less than 3 years old. The plan contains a number of measures to promote deinstitutionalization 
of care for vulnerable children and adolescents, integration of refugees, persons with disabilities 
and other vulnerable groups, including the Roma, in the labour market. Access to social policies 
is  planned  to  be  improved  through  the  digital  transformation  of  the  social  security  system  and 
increased  support  for  persons  with  disabilities.  The  plan  envisages  significant  reforms  and 
investments  in  the  healthcare  sector,  upgrading  the  infrastructure  of  the  hospital  system  and 

4 

 
 
improving several of its operational aspects, while promoting access, efficiency and resilience of 
the healthcare sector more broadly. 

The  fourth  pillar  of  the  plan  combines  measures  to  strengthen  public  administration, 
including  tax  administration  and  justice,  improve  the  financial  system,  promote  research 
and  innovation,  and  enhance  competitiveness  in  key  sectors,  also  facilitating  private 
investment.  For  public  administration,  measures  are  geared  towards  the  improvement  of 
administrative  capacity,  the  enhancement  of  coordination,  a  better  public  procurement 
framework,  and  the  continued  modernisation  of  the  public  financial  management  framework. 
The measures to codify tax legislation and to improve the functioning of the tax administration, 
also  through  its  digitalisation,  will  support  fiscal  sustainability  through  more  effective  tax 
collection. The quality and the efficiency of the justice system will be increased by accelerating 
and digitalising judicial processes, while upgrading relevant infrastructures. Important measures 
are also included to strengthen transparency and fight against corruption and illicit trade. A set of 
financial  sector  reforms  will  address  private  indebtedness  and  strengthen  capital  markets.  On 
business environment, measures include tax incentives for private investment targeting the green 
economy,  energy  and  digitalization  of  businesses,  the  promotion  of  economies  of  scale  and 
extroversion  of  enterprises,  and  the  simplification  of  key  administrative  processes  and 
improvements  in  the  quality  of  regulation,  particularly  in  areas  such  as  manufacturing  and 
logistics. The pillar  also  includes important investments  in  the sustainable development  of key 
sectors, such as tourism, culture, transport and agriculture. Finally, the RRF Loan Facility aims 
at addressing the lack of affordable financing for companies, with loans passed on to the private 
sector  through  international  financial  institutions  and  commercial  banks.  This  could  help 
overcome the significant constraints in providing credit through the Greek banking sector, which 
suffers from the still high volume of non-performing loans and low profitability. 

All  measures  included  in  the  plan  have  passed  the  ex-ante  assessment  of  the  “do  no 
significant harm” principle. Greece has conducted an assessment for each measure indicating 
that  the  principle  is  followed.  Based  on  the  information  provided  by  the  Greek  authorities,  no 
measure  included  in  the  plan  is  expected  to  do  significant  harm  to  environmental  objectives 
within the meaning of Article 17 of Regulation (EU) 2020/852.  

The  implementation  of  the  plan  is  expected  to  bring  about  a  lasting significant  impact  to 
Greece.  It  is  set  to  provide  a  significant  contribution  to  the  green  transition  of  the  Greek 
economy  and  strongly  supports  the  decarbonisation  of  the  energy  sector.  The  quality  and  the 
efficiency  of  the  public  administration  at  large,  including  the  justice  system  and  tax 
administration,  will  benefit  from  investments  and  reforms  that  introduce  structural  changes. 
Enhancing and upgrading the digital tools and services is another essential element, coupled with 
strengthening the administrative capacity and improving the skills of employees. In addition, the 
strategic  investments  in  very  high  capacity  networks,  emerging  technologies  and  the  multi-
country  projects  could  help  achieving  scale,  networking,  interoperability  and  cooperation  with 
similar activities in other Member States. Measures to strengthen the functioning of healthcare, 
education  and  employment  services  are  expected  to  improve  labour  market  performance  and 
reduce inequalities, poverty and the risk of social exclusion. Finally, strengthening the national 

5 

 
 
frameworks for the fight against corruption, money laundering and terrorism will also be relevant 
steps positively affecting all sectors of the economy and the society at large.  

The  plan  defines  milestones  and  targets  for  each  investment  and  reform.  Greece  has 
designated  10  “top  investments”  and  8  “key  reforms”  based  on  value,  impact  and  maturity 
criteria, while the remaining measures were categorised in 28 groups based on their area of focus 
and the allocation of responsibilities across ministries. The milestones and targets are sufficiently 
clear, ambitious and realistic. Their indicators are relevant, as they provide a suitable measure of 
the actual implementation; acceptable, as they are sufficiently ambitious and their scope reflects 
the overall objective of the measures; and robust, as they are specific and trackable, facilitating 
effective verification. The authorities have designed a clear governance structure responsible for 
the  coordination  and  the  monitoring  of  the  plan’s  implementation.  The  structure  consists  of  a 
central RRF Coordination Agency, designated ministries responsible for the oversight of specific 
measures,  implementation  bodies  and  the  Financial  Audit  Committee  whose  mission  is  to 
safeguard the observance of the principles of sound financial management for programmes co-
financed with the EU. The structure is expected to be fully set up in time for the first payment 
request. 

The  Technical  Support  Instrument  (TSI)  provides  expertise  in  building  capacities  to 
implement the plan in a number of areas. These areas are clean energy, digital transformation, 
state aid, health system reform, non-formal education, customs, financial literacy, as well as for 
the overall implementation of the plan. 

The Greek authorities have presented detailed cost assessments for all investment projects 
and reforms where costs occur. The cost descriptions and methodologies vary across the plan, 
also  depending  on  the  nature  of  the  projects.  A  cost  analysis  was  produced  for  each  project, 
including  a  brief  description  of  the  main  characteristics,  an  overview  of  the  timeline,  and  a 
breakdown of the project budget. Greece provided an appropriate level of information, based on 
which it is possible for the European Commission to assess positively reasonability, plausibility, 
additionality  with  EU  funding,  and  how  commensurate  with  expected  national  economic  and 
social  impact  the  costs  are  for  a  large  majority  of  the  measures.  Cost  assessments  were  also 
validated by the independent National Productivity Board. 

The control and audit system developed by the Greek authorities is coherently designed to 
meet the RRF requirements. The proposed system is a tailored-made Management and Control 
System rooted within the RRF Coordination Agency, which has the overall responsibility for the 
implementation  of  the  plan  and  constitutes  the  single  point  of  contact  between  the  Greek 
authorities  and  the  European  Commission.  Overall,  the  solutions  identified  are  adequate  to 
effectively manage the complexity of the plan. 

The plan achieves a high degree of coherence and complementarity among its components. 
This is facilitated by the structure of the plan around four main pillars, which include mutually 
reinforcing  measures.  Notably,  the  inclusion  of  climate-related  and  sustainability  criteria  from 
the green transition pillar will also enable the deployment of digital technologies and reinforce 
the  impact  of  the  digital  pillar.  On  the  other  hand,  measures  such  as  demand  response,  which 

6 

 
 
enables consumers to adjust electricity demand during peak periods, are only possible because of 
investment  in  digital  technologies.  The  third  pillar  on  employment,  skills  and  social  cohesion 
includes  measures  ensuring  that  the  costs  and  benefits  of  digital  and  green  transitions  will  be 
fairly  distributed  across  different  parts  of  the  Greek  society.  To  this  effect,  the  third  pillar 
includes measures prioritising sustainable job creation, improvement of the education system and 
skills, and the provision of high quality and effective health and social care services. Finally, the 
fourth  pillar  presents  measures  for  boosting  competitiveness  and  innovation  by  mobilising 
private and public investment and setting up institutional frameworks that will be instrumental in 
supporting the digital and green transition in Greece. 

Table 1 Summary of the assessment of the plan under the RRF criteria 

(1) 
Balanced 
Response 
A  

(2) 
CSRs 

A 

(3) 
Growth, 
jobs… 
A 

(4) 
DNSH 

A 

(5) 
Green 
target 
A 

(6) 
Digital 
target 
A 

(7) 
Lasting 
impact 
A  

(8) 
Milestones 
& Targets 
A 

(9) 
Costing 

B 

(10) 
Control 
Systems 
A 

(11) 
Coherence 

A  

7 

 
 
 
 
2.  RECOVERY AND RESILIENCE CHALLENGES: SCENE-SETTER  

2.1. Macroeconomic outlook and developments since the 2020 country report 

The macroeconomic scenario underlying the Greek recovery and resilience plan projects a 
recovery of economic activity to the pre-pandemic levels of 2019 in 2022. According to the 
plan, GDP is expected to grow by 3.6% in 2021 and 6.2% in 2022, before decreasing to 4.1% in 
2023 and 4.4% in 2024. Growth is expected to be driven by domestic demand and the supportive 
stimulus from the Recovery and Resilience Facility. Net trade is forecast to recover ahead of the 
rebound  in  the  tourism  sector,  especially  in  2022,  also  improving  the  current  account  deficit. 
Inflation  is  expected  to  increase  but  to  stay  close  to  0%  in  2021  before  increasing  to  0.7%  in 
2022.  

The macroeconomic scenario under the plan foresees unemployment to remain unchanged 
at 16.3% in 2021, and to follow a downward trajectory towards 11.9% in 2024. Employment 
is forecast to grow marginally in 2021, due to a gradual return of hiring in the tourism industry, 
while  the  services  sector  is  still  constrained  by  the  containment  measures.  Long-term 
unemployment remains the highest in the EU, however, risks of a further increase are expected 
to  remain  contained  as  employment  support  measures  prevented  an  increase  in  unemployment 
during  the  pandemic.  Poverty  is  expected  to  slowly  ease  from  the  peak  recorded  during  the 
pandemic. The share of people at risk of poverty or social exclusion is among the highest in the 
EU (30% in 2019), albeit below its peak of 36% in 2014. Vulnerable groups are more likely to be 
at risk of poverty or social exclusion, including people with migrant background and low-skilled 
workers. The pandemic is expected to have further accentuated those gaps. The position of those 
struggling to find employment before the pandemic, low-skilled, young and women, is expected 
to  deteriorate  when  the  employment  support  measures  are  discontinued.  Further,  it  remains 
uncertain  whether  the  steady  improvement  seen  before  the  pandemic  will  resume  in  the 
following  years.  Greece  remains  a  ‘moderately  equal’  society  with  respect  to  the  fairness  of 
income distribution and income inequality is higher compared to the euro area average.  

Greece is experiencing excessive macroeconomic imbalances. Vulnerabilities relate to high 
government  debt,  incomplete  external  rebalancing  and  high  non-performing  loans,  in  a 
context  of  high  unemployment  and  low  potential  growth.  The  Greek  economy’s  potential 
growth has been in negative territory for over a decade, primarily due to the economy’s low total 
factor productivity and diminished capital stock. Since 2012, Greece has significantly narrowed 
its current account deficit, however the coronavirus pandemic has widened the country’s external 
imbalances  again.  The  pandemic  has  also  put  additional  pressure  on  the  non-performing  loan 
ratios for nonfinancial corporations and households. Support measures, including loan payment 
moratoria, provided a temporary cushion and while the initial signs following the expiry  of the 
moratoria  suggest  that  the  adverse  impact  on  asset  quality  may  be  contained,  downside  risks 
remain  as  the  state  support  programmes  are  gradually  phased  out.  In  the  context  of  the  2021 

8 

 
 
European  Semester  spring  package,  the  European  Commission  adopted  earlier  in  June  an  in-
depth  review  for  Greece,  in  accordance  with  the  respective  regulation  on  the  prevention  and 
correction of macroeconomic imbalances in Greece5.  

The  Commission  2021  spring  forecast  expects  real  GDP  in  Greece  to  grow  at  4.1%  and 
6.0%  in  2021  and  2022,  respectively.  Similar  to  the  scenario  underlying  the  plan,  the 
Commission  considers  domestic  demand  as  the  main  growth  driver  behind  the  recovery.  The 
Commission  expects  a  stronger  rebound  of  gross  fixed  capital  formation  in  2021  than  the 
scenario presented in the plan, with investments in equipment and construction receiving a strong 
boost from the foreseen projects. Private consumption is also likely to benefit from the measures 
foreseen in the plan, albeit less than investments. Both the Commission and the Greek authorities 
forecast  a negative contribution  from  the implementation  of the plan to  net  exports, due to  the 
strong  import  component  of  the  envisaged  investments.  The  Commission  foresees  inflation  to 
remain mildly negative in 2021, before gradually recovering in 2022.  

Table  2  Comparison  of  the  macroeconomic  forecast  under  the  plan  and  Commission’s  2021 
spring forecast 

2019 

2020 

2021 

2022 

2023 

2024 

2025 

2026 

COM  COM  RRP  COM  RRP  COM  RRP 

RRP 

RRP 

RRP 

RRP 

Real GDP (% change) 

HICP inflation (% change) 

Employment (15-74 yrs, % change) 

1.9 

0.5 

1.2 

-8.2 

-8.2 

4.1 

-1.3 

-1.3 

-0.2 

-1.3 

-1.3 

0.4 

3.6 

0.0 

0.7 

6.0 

0.6 

0.7 

6.2 

0.7 

2.3 

4.1 

1.3 

1.3 

4.4 

1.3 

1.3 

n.a. 

n.a. 

n.a. 

n.a. 

n.a. 

n.a. 

Unemployment rate (%) 

17.3 

16.3 

16.3 

16.3 

16.3 

16.1 

14.4 

13.2 

11.9 

n.a. 

n.a. 

General  government  balance  (%  of 
GDP) 

General  government  gross  debt  (% 
of GDP) 

1.1 

-9.7 

n.a. 

-10.0 

n.a. 

-3.2 

n.a. 

n.a. 

n.a. 

n.a. 

n.a. 

180.5 

205.6 

n.a. 

208.8 

n.a. 

201.5 

n.a. 

n.a. 

n.a. 

n.a. 

n.a. 

Sources: Greek recovery and resilience plan, Commission 2021 spring forecast 

The  general  government  budget  reached  a  deficit  of  9.7%  of  GDP  in  20206,  which  is 
expected  to  remain  broadly  unchanged  in  2021  before  improving  in  2022.  Discretionary 
policy measures taken in response to the pandemic amounted to some 6.3% of GDP in 2020. For 
2021,  the  Commission  2021  spring  forecast  expects  a  deficit  of  10%  of  GDP.  The  lack  of 

5 Communication from the Commission on Economic Policy Coordination in 2021: Overcoming COVID-19, 
Supporting the Recovery and Modernising our Economy, COM(2021)500. In-depth Review for Greece, 
COM(2021)403.  
6 Headline deficit in ESA terms, according to the latest EDP notification from Eurostat. 

9 

 
 
 
                                                           
improvement  compared  to  2020  is  mainly  attributed  to  the  prolongation  of  the  fiscal  measures 
that were adopted to address the pandemic.  

Despite  the  increase  in  the  debt-to-GDP  ratio  in  2020,  financing  conditions  remain 
favourable. The debt-to-GDP ratio increased by more than 25 percentage points in 20207 due to 
the combined effect of shrinking GDP and the fiscal stimulus in 2020. The liquidity position of 
the  general  government  is  adequate,  as  financing  conditions  remain  favourable  and  the 
government continues holding a large cash buffer. Gross financing needs will remain above 15% 
of GDP in 2021-2022. The debt sustainability analysis in the tenth enhanced surveillance report 
projects that, in the baseline scenario, the debt-to-GDP ratio remains on a downward path from 
2021  onwards  and  reaches  169%  by  the  end  of  the  decade8.  According  to  the  report,  the 
protracted pandemic increased fiscal sustainability risks, which are partly offset by the expected 
economic  recovery.  The  composition  and  maturity  profile  of  government  debt  mitigates  debt 
vulnerabilities, while additional risks could emerge from contingent liabilities. 

The  macroeconomic  scenario  underpinning  the  recovery  and  resilience  plan  projections, 
identical to the projections in the Stability Programme for 2021, is cautious in 2021, while 
the  projections  for  2022  are  plausible,  closely  in  line  with  the  Commission  2021  spring 
forecast. According to the Commission 2021 Spring forecast, real GDP  growth is estimated at 
around 0.5 percentage points higher in 2021 than according to the scenario presented in the plan. 
This  is  due  to  different  assumptions  on  the  development  of  the  pandemic,  the  uptake  of  funds 
under the Recovery and Resilience Facility and the outlook of key economic sectors, primarily 
tourism.  The  macroeconomic  and  fiscal  outlook  continue  to  be  affected  by  high  uncertainty 
related to the COVID-19 pandemic and its economic consequences. 

2.2. Challenges  related  to  sustainable  growth,  cohesion,  resilience  and  policies  for  the 

next generation  

Smart, sustainable and inclusive growth 

Despite  continued  improvements  in  the  past  years,  Greece  entered  the  pandemic  with 
sizeable legacy vulnerabilities that had been further deepened by the crisis. On 2 June 2021, 
the Commission published an in-depth review under Article 5 of Regulation (EU) No 1176/2011 
of  the  European  Parliament  and  of  the  Council  for  Greece.  Greece  is  experiencing  excessive 
imbalances.  Vulnerabilities  relate  in  particular  to  high  government  debt,  incomplete  external 
rebalancing  and  high  non-performing  loans,  in  a  context  of  high  unemployment  and  low 
potential growth.  

Potential  growth  has  been  very  low  in  the  last  decade.  Small  and  low  productivity  firms 
continue to play an outsized role in the economy. Economic activity, though shifting gradually to 

7 According to the latest EDP notification from Eurostat. 
8 10th Enhanced Surveillance Report on Greece, COM(2021)528. 

10 

 
 
                                                           
tradable  sectors,  is  still  concentrated  in  traditional  and  low-innovation  sectors,  contributing  to 
low  productivity  growth.  Despite  some  recent  progress,  the  high  tax  burden,  red  tape,  high 
regulatory burden, and a slow and inefficient justice system weigh on private investments, both 
domestic and foreign, create obstacles to companies’ growth and delay external adjustment. Low 
investment in research and development, skills mismatches weighing on productivity growth and 
low  labour  market  relevance  of  education  also  point  to  weak  growth  prospects  in  the  future. 
Finally,  the  lack  of  an  effective  planning  and  monitoring  system  for  implementing  large 
infrastructure  projects  weighs  on  rollout  of  public  investments,  including  public-private 
partnerships.  

The  Greek  banking  sector  has  become  more  resilient  since  the  end  of  the  European 
Stability Mechanism programme for Greece, but legacy risks and challenges related to the 
current  crisis  remain  high.  Safeguarding  the  overall  soundness  of  the  banking  system  and 
managing  financial  stability  risks  are  essential  for  recovering  from  the  current  crisis  and 
supporting the economy. The pandemic is posing strains on banks, through an increase in credit 
risk and pressure on profitability and capitalisation. Vulnerabilities and challenges stem from the 
high stock of non-performing loans (NPLs), which limit the scope of bank credit to support the 
real economy. The banking sector in Greece has the highest ratio of NPLs on total loans in the 
euro  area.  Considerable  challenges  lie  ahead,  as  support  measures  such  as  payment  moratoria 
and  associated  regulatory  forbearance  and  relaxation  of  loan  origination  requirements  expire. 
The timely and effective implementation by 1 June 2021 of the recent insolvency reform, will be 
key to enhance the use of restructuring solutions for viable firms and the quick resolution of non-
viable  businesses.  This  would  accelerate  the  clearance  of  the  existing  stock  of  non-performing 
loans, while avoiding the creation of new backlogs of bad loans and insolvencies.  

Sustainable  economic  recovery  could  be  fostered  through  alternative  ways  of  non-bank 
financing. This includes venture capital and deepening of the Greek capital markets, which are 
still  underdeveloped.  Sustainable  finance  combined  with  its  transition  to  a  Green  model  of 
economic growth could further favour economic recovery. State support may also be warranted 
to leverage private investors and foster lending to viable firms exposed to a shortfall of funding 
at  a  reasonable  cost,  through  the  design  of  financial  instruments,  which avoid  crowding-out  or 
moral hazard adverse effects.  

Social and territorial cohesion 

Unemployment  remains  very  high  and  the  slowly  declining  trend  was  interrupted  by 
the COVID-19 crisis.  Greece  has  persistently  the  highest  unemployment  rate  (16.3%  in  2020) 
and  the  lowest  employment  rate  (61.1%  in  2020)  in  the  EU.  Youth  unemployment  (35.0%  in 
2020),  the  gender  employment  gap  (19 percentage  points)  and  share  of  long-term  unemployed 
(around 70%) are also among the highest in the EU. The labour market is distorted by the large 
informal economy, estimated to account for some 20% of the GDP. Labour productivity (output 
per  person  employed)  remains  weak  and  the  modest  increases  starting  from  2017  have  been 
reversed  by  the  COVID-19  crisis.  Emigration  of  highly  skilled  people  raises  concerns  about  a 
brain-drain  and  adds  to  the  pressure  of  population  ageing.  While  several  short-time  work 
schemes implemented during the crisis have prevented an increase in unemployment, activation 

11 

 
 
support to help jobseekers reintegrate in the labour market is not effective enough. The limited 
capacity  of  the  Public  Employment  Services  to  provide  individualized  support,  as  well  as  the 
lack of monitoring and evaluation and quality assurance in upskilling programmes are the main 
bottlenecks.  Greece  spends  less  than  most  other  EU  Member  States  on  active  labour  market 
policies and their coverage is low. 

Prior  to  the  pandemic,  poverty  had  been  gradually  decreasing,  but  remained  among  the 
highest  in  the  EU,  with  children  and working-age  people  being  particularly  affected.  The 
introduction of the guaranteed minimum income (GMI) reform in 2017 had a visible impact in 
terms  of  poverty  reduction,  but  its  second  and  third  pillar  (access  to  complementary  social 
services and activation support) are still not sufficiently developed to face the challenges ahead. 
In-work poverty is above the EU average. The housing costs overburden rate, at 36.2% in 2019, 
is  by  far  the  highest  in  the  EU  and  contrasts  with  the  absence  of  a  social  housing  policy.  The 
pandemic is  likely to  exacerbate the social  situation again,  as reflected in  the rising number of 
GMI beneficiaries. The large influx of asylum seekers puts additional stress on the employment 
and social  services. The  integration of third-country nationals  in  the labour market  and society 
presents  particular  challenges.  There  are  large  regional  disparities,  notably  between  the  capital 
region and the rest of the country. Rural areas in Greece suffer from a very high poverty rate and 
one of the highest rural unemployment rates (especially in young people) in the EU. 

Health, and economic, social and institutional resilience 

The  Greek  health  system  still  has  several  structural  problems.  The  COVID-19  emergency 
confirmed the need to address remaining structural challenges to ensure unhindered access. The 
primary healthcare network is not strong enough, mainly due to the insufficient stock of family 
doctors and the lack of a comprehensive workforce strategy. Centralised procurement is still not 
mature  despite  recent  progress.  There  has  been  limited  progress  in  investment  in  the  health 
sector, which is significantly below the EU average (0.1% of GDP as opposed to 0.2% for the 
EU-27 in 20189). Investment seems to be insufficient especially in priority areas such as primary 
care,  which  could  significantly  increase  the  efficiency  of  the  health  system.  Despite  some 
improvement  in  the  recent  years,  unmet  needs  for  medical  care  linked  to  cost/distance/waiting 
times remained among the highest in the EU in 2019, with a wide gap between the lowest and 
the highest income group as well as between employed and not employed people. Co-payments 
have  not  been  sufficiently  means-tested  to  protect  vulnerable  groups.  This  is  aggravated  by 
persistent supply-induced demand in pharmaceuticals and diagnostics, which is also reflected in 
high and increasing clawbacks. While the share of people aged 65+ who face serious difficulties 
in personal care and/or household activities is considerably higher than the EU-27 average (22.6 
against 18.1 in 2014, the latest available year10), public spending on long-term care is very low 

9 Based on Eurostat, gross capital formation in health care (gov_10a_exp). 
10  Source:  Eurostat.  Severe  difficulties  in  personal  care  activities  or  household  activities  by  sex,  age  and  type  of 
activity where the severe difficulty is encountered (hlth_ehis_tadle). Last update: 08-02-2021. 

12 

 
 
                                                           
(less  than  2%  of  total  healthcare  spending).  Greece  has  the  lowest  number  of  long-term  care 
workers per 100 individuals aged 65 and over among the OECD countries.  

Concerning institutional quality, Greece still faces major challenges regarding its business 
environment,  as  evidenced  by  the  low  performance  in  several  areas.  As  for  business 
environment, Greece is one of the countries with the lowest business dynamism in the EU. High 
regulatory  barriers  and  inefficiencies  in  the  public  administration  especially  in  areas  such  as 
contract enforcement and registering property, licensing process, environmental permits, coupled 
with the time needed by the justice system to deliver its final decisions, as well as lack of clarity 
on  existing  tax  rules  hinder  productivity  growth.  Key  reforms  to  improve  Greece’s  digital 
performance are progressing, although it remains among the lowest in the EU.  

Greece  does  not  perform  well  compared  to  the  EU  average  in  terms  of  many  public 
administration indicators11. The public administration reforms over the past decade focused on 
a leaner and more efficient state and on the improvement of services. However, Greece remains 
one of the least decentralised administrative systems of the EU. While digital services available 
to  citizens  have been recently expanded (see Gov.gr) and the law-making processes have been 
reviewed (see Executive State Law), the challenge remains to properly implement and fully roll 
out  these  initiatives.  Furthermore,  the  overall  administrative  capacity  of  the  regional  and  local 
government  levels  is  very  uneven  with  unclear  and/or  overlapping  competencies.  Areas  where 
there  is  scope  for  improvement,  include  (i)  capacity  to  properly  design  and  implement  public 
policies; (ii) coordination, in particular evident for cross-cutting subjects; (iii) human resources 
under-utilised and inefficiently allocated; (iv) overly complicated regulatory framework; (v) low 
penetration  of  e-Government  services;  (vi)  low  continuity  in  administration  due  to  lack  of 
standardisation of operational procedures; and (vii) absence of modern methods, techniques, and 
management  tools.  Regulatory  quality  suffers  from  excessive  regulation,  low  use  of  evidence-
based instruments, and non-meritocratic or heavily politicised regulation.  

Despite  recent  reforms,  the  justice  system  faces  multiple  challenges  that  weigh  on  its 
efficiency  and  quality.  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.  In  addition,  the  productivity  of  first  instance  courts  has  not  improved  as  regards  the 
clearance rate for litigious civil and commercial cases, 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 pandemic12. Outdated infrastructure and manpower 
insufficiencies, along with an inefficient distribution of resources under the current judicial map 
explain part of the issues. Further improvements are needed in the system for the collection of 
judicial statistics. Shortcomings in the digitalisation of justice include the lack of availability of 

11 World Bank World Governance and EC Standard Eurobarometer’s annual indicators for example. 
12 2021 EU Justice Scoreboard (forthcoming). 

13 

 
 
                                                           
online information about the judicial system to the general public, the absence of digitalisation of 
judicial processes and of the digitalisation of archives and judicial decisions. 

Policies for the next generation, children and youth, including education and skills 

As  per  policies  for  the  next  generation,  improving  basic  educational  outcomes  and 
performance  in  basic  skills  is  a  priority.  Strengthening  the  teaching  profession,  reforming 
school  curricula  and  providing  adequate  support  to  disadvantaged  pupils  are  overarching 
challenges.  Increasing  participation  in  vocational  education  and  training  is  also  key,  alongside 
promoting  reskilling  and  upskilling  to  reduce  skills  mismatches  and  to  address  the  green  and 
digital  transition.  An  institutional  framework  to  update  skills’  supply  on  a  regular  basis  along 
with  a  modern  training  design  and  delivery  mechanism  is  missing,  hence  hampering  the  link 
between  the  education  system  and  labour  market  needs.  Availability  and  quality  of childhood 
education  and  care  (ECEC)  is  relatively  low,  in  particular  for  children below  the  age  of 
obligatory  pre-school  education.  The  integration  of  recently  arrived  migrants  into  the 
education system remains a significant challenge. 

2.3. Challenges related to the green and digital transition  

Green dimension  

The recovery and resilience plan should contribute to the green transition and at least 37% 
of the financial allocation needs to contribute to climate objectives. The measures in the plan 
shall  contribute  to  achieving  the  2050  climate  neutrality  objective,  and  the  2030  energy  and 
climate  targets,  taking  into  account  Member  States’  national  energy  and  climate  plans.  They 
should  also  contribute  to  meeting  environmental  targets  for  waste,  water,  pollution  control, 
sustainable  mobility,  biodiversity  protection  and  restoration,  marine  and  water  resources,  and 
support the transition to sustainable food systems as well as to a circular economy as appropriate, 
while  ensuring  that  nobody  is  left  behind.  For  Greece,  this  refers  in  particular  to  energy  and 
resource efficiency in buildings, transport, and industry; renewable energy; and the development 
of  relevant  technical  competencies  and  skills.  The  measures  should  also  contribute  to  meeting 
environmental  targets  for  waste,  water,  pollution  control,  sustainable  mobility,  biodiversity 
protection and restoration, marine and water resources, and support the transition to sustainable 
food systems as well as to a circular economy as appropriate, while ensuring that nobody is left 
behind. For Greece, investment in marine biodiversity and ecosystems are particularly important, 
as marine protected areas (MPAs) provide limited real protection and overfishing persists. 

Greece has been historically reliant on solid fossil fuels (lignite) for electricity generation. 
However, a combination of increased effectiveness of climate policies and higher carbon prices, 
inability to modernise plants so as to bring them in line with stricter environmental policies, and 
market  reforms,  which  are  expected  to  lead  to  increase  in  competition  of  alternative  energy 
sources, have significantly brought down the share of electricity produced with lignite, which in 
2020 was less than 20%. 

The Greek government committed to phase out existing lignite-based power plants by 2023 
already at the UN Special Climate Action Summit in 2019, and confirmed such commitment in 

14 

 
 
the  final  National  Energy  and  Climate  Plan  (NECP).  The  only  exception  is  the  Ptolemaida  V 
plant,  still  under  construction,  which  will  be  converted  by  2028.  The  phase-out  will  have 
significant  economic  and  social  consequences  for  the  regions  where  lignite  production  is 
concentrated,  notably  Western  Macedonia  and  –  to  a  lesser  extent  in  absolute  terms  – 
Peloponnese (Megalopolis). Security of supply and a smooth transition to clean energy sources 
need to be ensured. 

Renewable  energy  production  and  consumption  have  significantly  increased.  The  share  of 
consumption of energy from renewable sources has almost doubled between 2010 (10.08%) and 
2019  (19.68%).  Greece  has  therefore  gone  beyond  its  2020  target  of  18%  and  has  set  a  35% 
objective for 2030, which was assessed by the Commission as sufficiently ambitious in its final 
assessment of the NECP. Looking ahead, the decommissioning of existing lignite power plants 
by 2023 and the increased level of ambition for climate objectives at 2030 and 2050 will require 
further significant investment in this sector.  

Offshore wind in particular is still at early stages in Greece but a good potential has been 
identified,  also  for  other  forms  of  renewables.  Greece  has  announced  reforms  of  the 
framework for offshore wind parks, including regulatory, installation and support aspects, while 
maritime spatial plans will need to be prepared. Greece has also a high potential for other forms 
of  renewable  energy  from  waste  and  by-products  of  the  agriculture  and  forestry  sectors  (while 
taking into account the effects on air pollution and the waste hierarchy). Considering that Greece 
is particularly prone to forest fires, damage to forests needs to be prevented by supporting forest 
resilience and restoration in addition to afforestation.  

Energy efficiency remains a key issue, with a modest level of ambition for 2030 set for final 
energy consumption targets and a low level of ambition for primary consumption.  This is 
especially problematic for private and public buildings, which should undergo deep renovations 
to realise the significant potential savings. In its NECP, Greece has set out a target to annually 
renovate 3% of the total floor area of public buildings and a target of 40 000 homes per year to 
be  upgraded  by  2030  (equal  to  12-15%  of  total  housing  stock  by  2030),  while  according  to 
Greece’s long-term renovation strategy the final energy demand in buildings will be reduced by 
8% compared to 2015 levels through targeted policy measures. While such target is relevant, it is 
not ambitious enough. Ideally, this effort should be reinforced and accompanied by measures to 
alleviate energy poverty, a pressing social challenge for Greece. 

Greece  implemented  deep  reforms  in  its  energy  markets  in  the  context  of  the  economic 
adjustment programmes. They focused on opening up markets and increasing competition, and 
delivered  a  reduction  in  the  market  share  of  the  electricity  incumbent,  which  declined  in  the 
electricity retail market from 95% in 2015 to 66% in 2020. It will be important for competitors in 
this market to gain further traction and for competition to cover all market segments, including 
the different segments of the wholesale electricity market. Further reforms are pending under the 
post-programme enhanced surveillance framework and need to be implemented to make Greek 
electricity  markets  more  competitive,  by  enhancing  flexible  market  participation  (demand 
response)  and  complete  the  market  coupling  with  neighbouring  Member  States.  Further,  to 
enable  the  new  electricity  markets  to  function  properly,  a  monitoring  mechanism  is  being 

15 

 
 
finalised by the national regulatory authority, while it is essential that all market actors fulfil their 
role  and  responsibilities  in  a  transparent  and  non-discretionary  manner.  For  gas,  past  reforms 
brought  about  the full  liberalization of the market,  with  the breaking up  of the gas  distribution 
monopolies  and  the  separation  of  the  distribution  and  supply  activities.  The  building  of  the 
interconnector  with  Bulgaria  enhanced  possibilities  for  competition  and  improved  security  of 
supply. 

Full  ownership  unbundling  of  the  electricity  and  gas  transmission  network  operators  is 
having a significant impact on the level of investment in networks. Apart from the effect on 
economic  growth,  this  should  also  have  a  positive  effect  on  electricity  consumer  prices  as  the 
interconnection with the mainland is expected to bring down the cost of electricity in the islands.  

Enhancing interconnection capacity with neighbouring countries is also key. It will facilitate 
Greece’s  further  integration  in  the  European  markets  and  also  increase  competition. 
Interconnection with Cyprus is particularly relevant in this regard.  

Public  and  private  transport  also  require  strong  investment  to  improve  energy  efficiency 
and develop electro-mobility and sustainable transport. Greece is well behind in the adoption 
of electric vehicles (with a rate of 0.3% in new sales compared to an EU average of about 2%) 
and in the availability of sustainable public transport, especially in the two major cities of Athens 
and Thessaloniki. The Greek fleet is among the oldest in Europe, in particular the medium- and 
heavy-duty vehicles (18.7 years in Greece versus an EU-average of 11.7), which contributes to 
the transport system’s heavy dependence on oil and the low use of renewables, which accounted 
for only 1.7% in 2016, against an objective of 10% by 2020. This also contributes to a relatively 
poor  road  safety  record.  Major  reforms  should  be  also  undertaken  in  the  rail  sector  as  a 
fundamental pillar of promoting sustainable transportation, especially in the connection between 
Athens and  Thessaloniki. Major investments  are  also  required for the upgrade  and  greening of 
the fleet of vessels interconnecting the islands with the mainland.  

Waste management and circular economy remain an issue. Greece brings to landfill 80% of 
its municipal waste (versus an EU average of 24%13), and plans for improving reuse and recycle, 
in  line  with  circular  economy  principles,  are  lagging  behind.  The  country  is  going  to  miss  its 
recycling targets for 2020, and important investments and reforms are thus required to reach the 
post-2020 targets  and to fully implement  the EU environmental acquis.  Greece has  adopted its 
National Circular Economy Strategy in December 2018, however the circular material use rate is 
currently  at  2.4%,  far  below  the  EU27  average  (11.2%).  Following  the  update  of  the  National 
Waste  Management  Plan  in  2020,  the  13  Regional  Waste  Management  Plans,  also  have  to  be 
updated. 

Investments  are  still  needed  to  improve  water  treatment  and  water  infrastructure  in 
general.  About  10%  of  generated  wastewater  is  not  connected  to  collecting  systems, 

13 European Commission, Environmental Implementation Review 2019 - Greece. 

16 

 
 
                                                           
representing  close  to  half  of  the  Greek  municipalities.  This  load  is  treated  exclusively  through 
individual  or  ad-hoc  systems  (for  instance  septic  tanks,  storage  units  or  individual  treatment 
plants) and needs upgrading. The performance of the water supply services is poor, particularly 
with  regards  to  distribution  leakages.  Greece  submitted  its  second  River  Basin  Management 
Plans with a long delay. The third River Basin Management Plans are due end-2021 and should 
be submitted to the Commission by March 2022. The proper functioning of the sector requires 
reforms and the adoption of legislative and administrative measures to ensure the sustainability 
and operational viability of investments and quality services to the citizens. 

Greece  faces  challenges  with  water  abstraction  and  prolonged  periods  of  drought,  which 
are  projected  to  intensify  due  to  the  climate  change.  The  restoration  of  the  water  bodies  to 
good  status  as  provided  by  the  Water  Framework  Directive  remains  an  issue.  Reversing  soil 
erosion,  reducing  air  pollution  and  improving  water  use  efficiency  are  important  priorities. 
Prioritising  challenges  related  to  biodiversity,  soil,  air  and  water  (e.g.  catch  and  cover  crops, 
retention  of crop residues on fields,  switching to  less  water intensive crops and improved crop 
varieties,  improving  irrigation  efficiency  via  water-saving  systems  and  precision  farming) 
combined with  an enhanced  conditionality, will  be crucial to  the successful green transition  of 
Greek agriculture. 

The 
law  on  biodiversity  and  the  national  biodiversity  strategy  are  sound  and 
comprehensive,  but  neither  has  been  properly  implemented.  According  to  Greece’s  latest 
report  (2019)  on  the  conservation  status  of  habitats  and  species  covered  by  the  Habitats 
Directive,  only  48%  of  the  assessments  for  Mediterranean  habitat  types  and  35%  for  species 
show a good conservation status14. The country is  lagging behind in the implementation of the 
Regulation  on  invasive  alien  species15,  failing  to  establish  surveillance  systems  and  official 
controls  to  prevent  the  introduction  and  further  expansion  of  invasive  alien  species  of  Union 
concern.  

The  table  below  gives  an  overview  of  Greece’s  objectives,  targets  and  contributions  under 
Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 
on the Governance of the Energy Union and Climate Action. 

Table 3 Greece’s objectives, targets and contributions under regulation (EU) 2018/1999 

National targets and contributions  

Latest 
available 
data 

2020 

2030 

Assessment of 2030 
ambition level 

14 European Environmental Agency, Conservation status and trends of habitats and species 2019. 
15  Regulation  (EU)  No  1143/2014  of  the  European  Parliament  and  of  the  Council  of  22 October  2014  on  the 
prevention and management of the introduction and spread of invasive alien species, OJ L 317, 4.11.2014, p. 35. 

17 

 
 
 
                                                           
Binding target for greenhouse gas 
emissions compared to 2005 under the 
Effort Sharing Regulation (ESR) (%) 

-28  
(2017) 

-4 

-16 

National target/contribution for 

renewable energy: Share of energy from 
renewable sources in gross final 
consumption of energy (%) 

19.7 
(2019)  

18 
(target) 

35 

As in ESR, total 
GHG target implies 
higher reductions  

Sufficiently 
ambitious (31% is 
the result of the 
formula)  

National contribution for energy efficiency: 

Primary energy consumption (Mtoe) 

Final energy consumption (Mtoe) 

22.3 
(2019)  

16.2 
(2019) 

24.7 

20.55  Modest 

18.4 

16.51 

Low 

Level of electricity interconnectivity (%) 

10% 

13 

21 

N.A. 

Source: Assessment of the final national energy and climate plan of Greece, SWD (2020) 907 final. Eurostat where 
data is indicated for specific years. 

Digital dimension  

The  recovery  and  resilience  plan  should  contribute  to  the  digital  transition  and  at  least 
20% of the financial allocation needs to contribute to digital objectives. The measures in the 
plan should, inter alia, contribute to the digital transformation of the economic and social sector 
(including  public  administration,  public  services,  and  the  justice  and  health  systems).  The 
objective of the measures in the plan should be to improve not only the competitiveness, but also 
the  resilience,  agility  and  security  of  companies  and  public  actors,  all  while  ensuring 
inclusiveness. 

Greece  ranks  27th  out  of  the  28  countries  assessed  in  the  Digital  Economy  and  Society 
Index  (DESI)  for  2020.  This  indicates  large  gaps  regarding  all  aspects  of  the  digital 
transformation. Based on the data collected prior to the pandemic, Greece made limited progress 
across most of the sub-dimensions of the Digital Economy and Society index (DESI) and did not 
close its gap compared to other EU countries. The combination of shortfalls in connectivity, lack 
of digital skills and ICT specialists, limited digital uptake by companies, low digital public sector 
services provision, low digital related investment in R&D, and absence of smart public transport 
solutions  hinders  digital  transformation  of  the  Greek  economy  and  society.  However,  the 
pandemic acted in Greece as an accelerator in setting out an ambitious reform agenda for digital 
transformation and launching a range of new digital services (see gov.gr). 

Connectivity  remains  an  issue  in  Greece,  and  is  a  key  obstacle  to  the  digital  transition. 
While the country has started engaging in the deployment of very high capacity networks and its 
fixed very high capacity network coverage reached 10% in 2020, up from 7% a year before, it is 
still far below the EU average of 59%. The take up of the fixed broadband is improving slowly, 

18 

 
 
 
 
 
 
 
 
reaching 77% in  2020, up from  76% in  2019 (in line with  the EU average). While Greece has 
recently made progress to tackle long standing obstacles to investment in networks, more efforts 
are  needed,  in  particular  in  view  of  the  forthcoming  deployment  of  Fiber  To  The  Premises 
(FTTP)  and  5G.  Reforms  to  address  obstacles  to  investment  in  networks  i.e.  one-stop  shops, 
digitalisation  of  the  permit  granting  procedure,  are  needed  and  would  maximise  the  impact  of 
investments.  Low  broadband  coverage  in  rural  areas  is  increasing  the  rural  urban  divide  in 
particular in remote and less populated rural areas, hindering their integration in the knowledge 
based economy  and results in  an unattractive  environment making it difficult  for businesses to 
thrive.  The  5G  license  auction16  was  successfully  concluded  in  December  2020.  With  reforms 
and targeted investments, Greece needs to create the right conditions for the achievement of the 
2025  Gigabit  targets,  and  bridge  the  digital  divide  with  investments  such  as  the  fibre 
interconnection  of  main  islands,  the  cross-border  5G  corridors  and  interconnection  of  islands 
with submarine fibre cables, complemented by space-based solutions. 

Lack of digital skills, both at basic and advanced level,  remains an obstacle to the digital 
transition.  Despite  a  5  percentage  point  increase  since  the  previous  year,  the  share  of  citizens 
with at least basic digital skills remained low at 51% in 2019, when 90% of jobs require at least 
basic  digital  skills.  The  share  of  ICT  specialists  in  total  employment,  is  at  2.0%  in  2020,  well 
below the EU average of 4.3%17. The situation is critical as the share of ICT graduates in total 
graduates remains low as well. Skills mismatch is a major challenge in Greece with companies 
reporting difficulties  in  finding people with  the  right  skills.  A comprehensive digital  education 
action plan including the revision of curricula and teachers’ training has been launched in 2020. 
Other initiatives such as the ‘Greek National Coalition for Digital Skills and Jobs’ can contribute 
to  upskilling  and  reskilling  the  adults  and  the  workforce.  Nevertheless,  significant  efforts  in 
increasing both basic and digital skills remain necessary to close the gap to the EU average and 
facilitate the country’s digital transformation.  

Integrating  digital  technologies,  in  particular  in  small  and  medium-sized  enterprises 
(SMEs),  remains  an  issue  in  Greece.  Overall,  Greece  ranks  24th  regarding  the  integration  of 
digital  technologies  in  the  Digital  Economy  and  Society  Index  in  2020.  The  share  of  SMEs 
selling online was at 9% in 2019, i.e. half the EU average, and the share of turnover coming from 
e-commerce  amounted  only  to  4%  of  total  turnover  for  SMEs,  almost  one  third  of  the  EU 
average.  Limited  uptake  of  innovative  digital  solutions  by  SMEs  in  Greece  also  hinders 
innovation performance. 

Despite  the  provision  and  the  uptake  of  the  digital  public  services  in  Greece  remaining 
below  the  EU  average,  the  pandemic  acted  as  an  accelerator  of  the  use  of  digital  public 
services.  Digital  public  services  for  business  have  improved  as  well  in  recent  years  but  also 
remain below the EU average. Limited provision of digital public services undermines access to 

16 For all pioneer bands (700 MHz, 3400 -3800 MHz and 26 GHz) as well as of the 2 GHz band. 
17 Source: Eurostat - Labour Force Survey. 

19 

 
 
                                                           
key  social  services  such  as  healthcare  and  education/learning,  particularly  endangering 
vulnerable groups of society, especially during crisis times. 

The research and innovation activity in Greece remains low in general as well in the ICT 
sector. In 2019, R&D intensity amounted to 1.27% of GDP in Greece, compared to 2.19% at EU 
level18. At 2.5% of GDP in 2017, the ICT sector is small in relative size compared to other EU 
Member States and only accounts for 1.1% of total Greek R&D expenditure. Increasing Greece’s 
business  R&D  expenditure  would  be  instrumental  in  improving  its  research  and  innovation 
capacity.  

The  deployment  of  digital  advanced  technologies  across  all  economic  sectors  in  Greece 
remains slow, partly due to the large share of SMEs and the large services sector focused 
on  low  technology  intensive  services  such  as  tourism.  With  98%  of  enterprises  having  less 
than  20  employees  (2017)19  the  Greek  business  landscape  is  characterised  by  a  large  share  of 
micro and small enterprises, which in general are slower in adapting cutting-edge technologies. 
The  share  of  enterprises  using  new  technologies  such  as  artificial  intelligence  or  3D  printing 
technologies  therefore  remains  low  at  1%  and  2%  respectively  in  201820.  More  established 
advanced technologies such as cloud computing services and big data analytics are being used by 
a larger share of enterprises (7% and 13% respectively in 2019). Greece has expressed interest in 
investing  on  advanced  technologies  and  signed  the  declaration  on  Quantum  Communication 
Infrastructure (in December 2019)21. It is currently developing a national strategy on AI, while a 
strategy towards Industry 4.0 is still missing.  

Greece  is  significantly  lagging  behind  the  rest  of  the  EU  regarding  the  digitalisation  of 
urban  public  transport  and  other  smart  and  sustainable  city  initiatives.  The  digital 
transformation  of  Urban  Transport  Organisation  of  Athens  and  Thessaloniki  (OASA  and 
OASTH respectively), would be necessary in order to make public transport more attractive and 
other,  smaller  municipalities  are  also  lacking  as  regards  integrated  public  transport  systems. 
Making less polluting public transport alternatives  more attractive would also  contribute to  the 
country’s  green  transition.  Other  elements  of  smart  and  sustainable  city  initiatives  such  as  big 
data  analytics  technologies,  Artificial  Intelligence,  smart  water  utilities,  traffic  management, 
waste  management  solutions,  smart  lighting  and  smart  energy  solutions,  urban  planning, 
improved  social  participation  in  decision  making,  improved  service  delivery  to  vulnerable 
groups,  local  urban  centre  improvements,  and  the  improved  availability  of  digital  resources, 
training and skill upgrading are relatively limited. More activities based on the principles of the 

18 Source: Eurostat. 
19 Source: Eurostat. 
20 Source: Eurostat. 
21 https://ec.europa.eu/digital-single-market/en/news/nine-more-countries-join-initiative-explore-quantum-
communication-europe 

20 

 
 
                                                           
EU Living-in.eu declaration would further improve the life of citizens, with investments in smart 
data platforms and advanced digital services. 

Regarding  rural  communities  and  the  agricultural  sector,  connectivity  and  skills  for 
farming  communities  will  be  key  to  achieve  the  digital  transformation.  Knowledge  and 
innovation  have  a  key  role  to  play  in  helping  farmers  and  rural  communities  meet  future 
challenges.  Innovation  support  services  as  well  as  full  broadband  coverage  in  rural  areas  are 
needed  to  enable  the  development  of  digital  skills  through  appropriate  training.  Advisory 
services and operational groups will be essential to respond to the growing information needs of 
farms  regarding  economic,  environmental  as  well  as  social  aspects.  Further  actions  have  to  be 
undertaken  to  increase  knowledge  flows  and  strengthen  links  between  research  and  practice, 
including the creation of innovation support services, e-infrastructures, workshops and platforms 
for disseminating information. 

Figure 1 DESI 2020 - relative performance by dimension 

Note: EU aggregate corresponds to EU28, based on 2020 DESI report. 

Source: Greece’s ranking in the Digital Economy and Society Index 2020. https://ec.europa.eu/digital-single-
market/en/scoreboard/greece  

Greece  has  set  out  an  ambitious  reform  agenda  in  its  draft  national  digital  strategy.  The 
new  digital  strategy  (“Digital  Bible”),  which  is  under  revision  following  its  release  for  public 
consultation, presents over 450 projects focused on connectivity, digital upskilling, e-Commerce 
and  enhancing  the  interoperability  and  robustness  of  public  IT  systems.  The  new  Ministry  for 

21 

DESI1Connectivity2 Humancapital3 Use ofinternetservices4 Integrationof digitaltechnology5 DigitalpublicservicesDESI 2020 -relative performance by dimensionGreeceEUCountrywith  highest scoreCountrywith  lowest score 
 
 
Digital  Governance  is  overseeing  the  work  on  the  new  digital  strategy  and  is  pursuing  the 
objective to implement the ‘digital by default’ principle in Greece by 2023.  

Box 1 Progress towards the Sustainable Development Goals 

The  objectives  of  the  Sustainable  Development  Goals  (SDGs)  are  integrated  in  the  European 
Semester  since  the  2020  cycle.  This  provides  a  strong  commitment  towards  sustainability  in 
coordination  of  economic  and  employment  policies  in  the  EU.  In  that  respect,  this  section  outlines 
Greece’s  performance  with  respect  to  SDGs  with  particular  relevance  for  the  four  dimensions 
underpinning  the  2021  Annual  Sustainable  Growth  Strategy  and  of  relevance  to  the  recovery  and 
resilience  plans  (green  transition,  fairness,  digital  transition  and  productivity,  and  macroeconomic 
stability),  indicating  possible  areas  where  investments  and  reforms  in  line  with  the  objectives  of  the 
Recovery and Resilience Facility could further accelerate the progress on the SDGs. 

Sustainable  Development  Goals  and  the  four  dimensions  underpinning  the  Annual  Sustainable 
Growth Strategy  

In  an  EU  context,  Greece  has  made  substantial  progress  towards  meeting  the  Sustainable 
Development  Goals  (SDGs)  over  the  past  years  starting  from  a  relatively  low  position. By 
comparison  with  the  EU  average  performance,  Greece  has  taken  important  steps  based  on  several 
headline  indicators  included  in  the  EU  SDG  indicator  set  used  by  Eurostat  for  monitoring  progress 

22 

 
 
 
towards the SDGs in an EU. However, in several cases, this has been due to the relatively low starting 
position of Greece compared to the EU as a whole22.  

Greece  has  made  progress  with  meeting  certain  environmental  objectives  that  are  relevant  for 
the green transition. In the area of affordable and clean energy (SDG 7), Greece has fared particularly 
well in reducing the greenhouse gas emissions intensity (by 23% between 2014 and 2019). However, 
their level remain above the EU average. Access to affordable energy, an area where Greece lagged for 
long significantly behind other EU Member States (with almost 1/3 of population being unable to keep 
their home  adequately  warm  in  2014)  has  also  improved  markedly  in  more  recent  years,  although  at 
almost  17.9%  in  2019,  the  share  of  affected  households  remains  well  above  the  EU  average  (6.9%). 
Performance with regard to SDG 12 (responsible consumption and production) has been mixed. While 
resource productivity in Greece increased by 37% between 2014 and 2019, it remains below the EU 
average, while average CO2 emissions per km from new passenger cars in Greece saw a 7% increase 
during the same period, when in the EU they went down marginally. On the positive side, the circular 
material use rate (percentage of material input for domestic use) increased by three times (from 1.4% to 
4.2%), but remains below the EU average (11.9% in 2019), while generation of waste excluding major 
mineral wastes dropped by around 23% when it increased marginally in the EU. Some steps were also 
taken towards meeting climate action goals (SDGs 13) as reflected in the dramatic increase of the share 
of  renewable  energy  in  gross  final  energy  consumption  that  by  2019  had  reached  the  EU  average 
(19.7%), albeit starting from a lower level.  

In the area of labour market and social policy, progress has been mixed. The unfavourable trend in 
poverty rates and long-term unemployment, which reached a peak in 2013, had been reversed by the 
economic recovery that ensued after the decade-long financial crisis. The recovery has also supported 
job creation (SDGs 1, 2, 8). Nevertheless, given Greece’s relatively weaker starting position, its labour 
and social situation remains less favourable than in the EU as a whole based on almost all indicators. In 
the  same  vein,  fairness  aspects,  such  as  gender  equality  (SDGs  5,  10),  have  shown  some  signs  of 
improvement, but remain less positive than in the EU as a whole, given Greece’s still large gender gap 
in terms of employment and pay and the more prominent underrepresentation of women in economic 
and  political  life.  Meanwhile,  a  number  of  good  health  and  wellbeing  indicators  (SDG  3)  have 
remained relatively stable or even deteriorated in Greece during the reference period (such as smoking 
prevalence or people killed in accidents at work) as opposed to the positive trend that was observed in 
the EU as a whole. Despite improving during 2014-2019, access to health care also remains an issue, 
with  8.1%  of  the  population  aged  16  or  above  reporting  unmet  medical  needs  in  2019  due  to  cost, 
distance or waiting times as opposed to only 1.7% in the EU as a whole. 

Objectives  to  promote  the  digital  transition,  productivity  and  macroeconomic  stability  are 
gradually being pursued. Positive performance in several aspects of the education and R&D system 
such as early school leaving, tertiary education attainment, adult learning, and basic digital skills (SDG 
4), as well as higher R&D production (SDG 9) has supported the digital transformation of the economy 
and  society  and  reverted  the  negative  trend  in  productivity.  Macroeconomic  stability  (SDG  8) 
improved during the five years prior to the pandemic for which data are available, mainly thanks to the 

22 Progress towards meeting SDGs, as described in this Box, is assessed over the period 2014-2019 for which data 
on the various indicators are available. The impact of the pandemic is not reflected in this analysis.  

23 

 
 
                                                           
general  labour  market  and  economic  recovery  and  the  strengthening  of  institutions  as  reflected  in 
improved perceptions of citizens about personal security and the justice system (SDG 16). 

Financing  under  the  Greek  recovery  and  resilience  plan  can  further  support  progress  towards 
the  SDGs  and  the  four  dimensions  underpinning  the  Annual  Sustainable  Growth  Survey.  The 
proposed wide-range and thorough reforms and investments in the green and digital transition, social 
inclusion  and  macroeconomic  stability  are  expected  to  further  contribute  to  meeting  the  respective 
SDGs. Substantial EU funds already support actions in line with the Sustainable Development Goals in 
Greece. The European Structural and Investment Funds support 13 out the 17 SDGs and up to 92% of 
the funds’ expenditure is contributing to meeting the respective objectives. 

3.  OBJECTIVES, STRUCTURE AND GOVERNANCE OF THE PLAN  

3.1. Overall strategy of the plan  

Greece’s  recovery  and  resilience  plan  introduces  reforms  and  investments  that  aim  at  a 
considerable  improvement  in  economic  activity,  technologies  and  institutions.  These 
measures aspire to direct the country towards a more extroverted, competitive, green, and digital 
economic  model.  The  plan  also  aims  at  facilitating  cohesion  and  justice,  while  establishing  a 
more  efficient  public  administration  and  a  resilient  and  inclusive  social  safety  net.  Greece 
anticipates that the proposed measures will result in the creation of new and permanent jobs, and 
in  a  lasting  increase  of  real  GDP,  while  contributing  to  addressing  challenges  identified  in  the 
relevant Country Specific Recommendations. In this context, the plan is structured around four 
pillars,  encompassing  a  total  of  eighteen  components:  (i)  Green  Transition  (four  components); 
(ii)  Digital  Transformation  (three  components);  (iii)  Employment,  skills  and  social  cohesion 
(four  components);  (iv)  Private  investment  and  transformation  of  the  economy  (seven 
components). The timeline for the implementation of the plan ranges from the fourth quarter of 
2020  to  the  third  quarter  of  2026,  while  the  disbursements  are  proportionally  distributed 
throughout the lifetime of the facility. 

The  green  transition  pillar  focuses  on  energy  efficiency  and  buildings  renovation, 
renewables,  electro-mobility,  climate  resilience,  and  environmental  protection.  The 
objective of component 1.1 (Power Up) is to increase the resilience of the electricity network, its 
capacity  and  its  energy  storage  capabilities,  thus  allowing  for  greater  penetration  of  renewable 
energy  sources  in  the  energy  mix.  Measures  aim  to  reduce  energy  costs,  phase-out  oil-fired 
power generation, and increase the potential of the islands to support electricity generation from 
renewables. Component 1.2 (Renovate) introduces reforms and investments in urban and spatial 
planning, as well as in the renovation of residential, commercial, industrial and public buildings 
to improve energy performance and reduce the carbon footprint. Component 1.3 (Recharge and 
refuel)  contains  actions  that  enable  the  installation  and  operation  of  electric  vehicle  charging 
equipment,  and  promotes  investments  to  establish  the  required  infrastructure.  To  enhance 
environmental  protection  and  resilience  in  natural  risks,  component  1.4  (Sustainable  use  of 
resources,  climate  resilience  and  environmental  protection)  describes  measures  related  to 
reforestation  and  biodiversity  protection,  improvements  in  the  national  irrigation  network, 

24 

 
 
 
wastewater  and  water  management,  and  prevention  and  coordination  of  actions  against  natural 
disasters and climate change phenomena. 

The  digital  transformation  pillar  aims  at  improving  network  infrastructures  and 
facilitating the digital transition in the public and private sectors. In an effort to accelerate 
connectivity,  a  key  prerequisite  for  digital  transition,  the  main  objectives  of  component  2.1 
(Connect)  are  the  facilitation  of  fibre  optic  infrastructure  in  buildings,  the  switch  to  fast 
broadband  connections  and  5G  technology,  and  the  utilisation  of  space  technologies  and 
applications. Taking into consideration current challenges, component 2.2 (Modernise) includes 
the  incorporation  of  new  technologies,  tools  and  infrastructure  in  the  public  sector,  and  the 
provision of improved services to  citizens and businesses. It aims at increasing interoperability 
between  systems  and  data,  cybersecurity  and  data  governance  strategies  and  policies,  and 
extended use of advanced technologies, such as cloud computing, artificial intelligence and big 
data. Component 2.3 (Digitalisation of businesses) focuses on increasing the digital maturity of 
businesses  by  creating  a  digital  infrastructure  through  funding  and  digital  awareness  schemes, 
creating  the  appropriate  digital  business  ecosystem  (industrial  platform  and  data  spaces), 
encouraging  investments  in  modern  digital  technologies  (e.g.  using  tax  incentives),  and 
upgrading the cash registers and Point of Sale (POS) ecosystem. 

The  third  pillar  focuses  on 
labour  market,  education  and  training,  healthcare 
sustainability,  and  access  to  social  policies.  Component  3.1  (Increasing  job  creation  and 
participation  in  the  labour  market)  introduces  labour  market  policy  reforms  to  enhance  job 
creation, improve job quality, strengthen economic and social resilience, promote labour market 
inclusion, and reduce inequalities, poverty and exclusion. The aim of component 3.2 (Education, 
vocational education, training, and skills) is to increase long term employment and productivity 
through  reforms  and  investments  in  skills,  lifelong  learning,  vocational  education  and  training, 
research  performance  of  universities,  and  digitalisation  of  all  levels  of  education.  Component 
3.3’s  (Improve  resilience,  accessibility  and  sustainability  of  healthcare)  main  building  blocks 
include  redesigning  the  health  system  through  organisational  reforms,  optimising  financial 
resources,  reforming  the  primary  health  system,  and  reorienting  health  services.  Finally, 
measures in component 3.4 (Increase access to effective and inclusive social policies) pertain to 
active inclusion of vulnerable population groups, reinforcing early childhood education and care, 
and combating discrimination. 

The fourth pillar combines measures to strengthen public administration, justice, and the 
financial system, promote research and innovation, enhance competitiveness in key sectors, 
and  facilitate  private  investment.  Components  4.1  (Making  taxes  more  growth  friendly,  and 
improving tax administration and tax collection) and 4.2 (Modernise the public administration) 
describe tax policy and tax administration measures (including digitalisation) to contribute to the 
fight  against  tax  evasion,  as  well  as  actions  in  selected  areas  of  public  administration,  fight 
against  corruption,  public  finance  management,  and  public  procurement.  Component  4.3 
(Improve  the  efficiency  of  the  justice  system)  aims  at  accelerating  and  digitalising  judicial 
processes,  while  upgrading  relevant  infrastructures.  Component  4.4  (Strengthen  the  financial 
sector and capital markets) includes a set of financial system reforms, mainly to address private 
indebtedness, tackle information asymmetries between lenders and borrowers, as well as public 

25 

 
 
sector entities and banks, and strengthen capital markets. Component 4.5 (Promote research and 
innovation)  seeks  to  increase  R&I  public  and  private  investment,  strengthen  the  links  between 
science  and  business,  and  develop  R&D  infrastructure  through  a  series  of  investments  and 
reforms. A group of measures aiming to improve the competitiveness of key sectors of the Greek 
economy,  namely  tourism,  culture,  agriculture,  aquaculture,  manufacturing,  and  transport,  are 
provided  in  component  4.6  (Modernise  and  improve  resilience  of  key  economic  sectors)  as 
recently  promoted  by  the  Commission  Communication  “Updating  the  2020  New  Industrial 
Strategy: Building a stronger Single Market for Europe’s recovery”23. Component 4.7 (Improve 
competitiveness  and  promote  private  investment  and  trade)  regards  reforms  that  target  at  the 
improvement  of  the  business  environment  and  the  simplification  of  the  regulatory  framework, 
complemented by the provision of financial incentives to the private economy, using RRF loans 
(see below). 

RRF loans are intended to incentivise private investment in transformative sectors of the 
economy.  The  reforms  included  in  component  4.7  are  complemented  by  Greece’s  proposal  to 
use RRF loans to increase private investment in five strategic areas, namely a)  green transition, 
b) digital transformation, c) research and development, d) economies of scale through mergers, 
acquisitions  and  partnerships,  and  e)  trade  promotion,  using  three  different  channels.  First, 
funding  will  be  provided  through  corporate  bond  purchases  or  syndicated  loans  alongside 
financial  institutions  and  commercial  banks,  with  a  small  participation  by  the  beneficiaries. 
Second, the proposal includes the establishment of an equity platform targeting start-ups, scale-
ups and dynamic SMEs in important sectors of the Greek economy. Third, the proposal includes 
the utilisation of a part of Greece’s InvestEU national compartment. 

Table 4 Components and associated costs 

Component  

1.1 Power Up 

1.2 Renovate 

1.3 Recharge and refuel 

1.4 Sustainable use of resources, climate resilience and environmental 
protection 

Total Costs Pillar 1: Green Transition 

2.1 Connect 

2.2 Modernise 

2.3 Digitalisation of businesses 

23 COM(2021) 350 final 

26 

Costs (EUR million)  

1 200 

2 711 

520 

1 763 

6 194 

522 

1 281 

375 

 
 
                                                           
Total Costs Pillar 2: Digital Transformation 

3.1 Increasing job creation and participation in the labour market  

3.2 Education, vocational education, training, and skills 

3.3 Improve resilience, accessibility and sustainability of healthcare  

3.4 Increase access to effective and inclusive social policies 

Total Costs Pillar 3: Employment, skills and social cohesion  

4.1 Making taxes more growth friendly, and improving tax administration 
and tax collection  

4.2 Modernise the public administration, including through speeding up the 
implementation of public investments, improving the public procurement 
framework, capacity building measures and fighting corruption 

4.3 Improve the efficiency of the justice system  

4.4 Strengthen the financial sector and capital markets  

4.5 Promote research and innovation  

4.6 Modernise and improve resilience of key economic sectors  

4.7 Improve competitiveness and promote private investment and trade  

Technical Assistance 

Total Costs Pillar 4: Private investment and transformation of the 
economy 

Total Costs all Pillars 

RRF Loan Facility 

3.2. Implementation aspects of the plan  

Consistency with other programmes 

2 178 

776 

2 311 

1 486 

611 

5 184 

187 

189 

251 

21 

444 

3 743 

5 

40 

4 880 

18 436 

12 728 (loans) 

The  recovery  and  resilience  plan  provides  detailed  justification  for  its  alignment  to  the 
goals, priorities and policy and reform recommendations of other national broad plans. The 
recovery and resilience plan is part of the National Plan of Government Policies (NPGP) 2021. It 
is also interlinked and consistent with reforms from the National Reform Plan (NRP). In some 
instances, the reforms from the plan are broader than the corresponding ones presented in other 
national documents, covering more fields. The plan states that reforms that are listed only in the 
plan and are new to the NRP, range between 5-10% of the NRP (less than 15 reforms), but will 
be added to the NRP on its regular revision.  

The recovery and resilience plan is consistent with the National Energy and Climate Plan, 
which includes  reforms and investments that will facilitate reaching climate and energy targets 
for  2030  and  paving  the  path  towards  climate  neutrality  by  2050.  Notably,  the  “Green 
Transition” pillar of the plan supports the transition towards a low-carbon energy system, with 
increased  participation  of  renewable  energy  sources  in  energy  consumption,  improved  energy 
efficiency  of  the  domestic  building  stock  (household,  public  and  commercial  buildings),  and  a 

27 

 
 
“greener”  and  more  sustainable  transport  system  (with  emphasis  on  the  use  of  electromobility 
and electric vehicles).  

The Greek recovery and resilience plan is consistent with the National Transport Strategic 
Plan,  as  it  acknowledges  the  importance  of  developing  modern,  sustainable,  accessible  and 
climate change resilient transport infrastructures. It acknowledges the enhancement of resilience 
against threats and risks of any kind as a crucial element of economic and societal development 
and progress. As a result, it incorporates the strategic guidelines, objectives and detailed targets 
of the National Plan for Crisis Management and Hazard Mitigation. 

The  plan  also  takes  into  account  the  objectives  and  priorities  presented  in  the  draft 
National  and  Territorial  Just  Transition  Plans  and  facilitates  the  just  and  viable  socio-
economic  transition  of  the  coal-dependent  areas  through  dedicated  reforms  and 
investments.  The  “Green  Transition”  pillar,  and  specifically  Component  1.1,  includes 
investments  for  the  restoration,  rehabilitation  and  upgrading  of  lignite  zones  in  Western 
Macedonia  and  Megalopolis,  to  accommodate  new  uses  according  to  the  five  growth  pillars 
detailed in the draft Just Transition Plan: (i) clean energy, (ii) smart agricultural production, (iii) 
sustainable tourism, (iv) industry, handicrafts and trade, and (v) technology and education. These 
works are expected to create new jobs for the local workforce, as well as a range of novel growth 
opportunities. 

to  operate 

is  also  designed 

in  consistency, 
The  recovery  and  resilience  plan 
complementarity,  and  cooperation  with  the  new  Greek  Partnership  Agreement  for  the 
Development  Framework  for  the  2021-2027  Programming  Period  of  the  Cohesion  Policy 
funds,  and  its  sectoral  and  regional  programmes.  On  the  one  hand,  the  plan  incorporates  the 
strategic directions, objectives and priorities of the new draft Partnership Agreement, while on 
the other hand it draws from and builds on the outcomes and the experience from implementing 
the Partnership Agreement for the previous MFF period (2014 – 2020). Along with the Common 
Agricultural Policy, the three instruments contribute the bulk of investment funds to be deployed 
in the Greek economy in the following nine years. The new Partnership Agreement for the 2021 
–  2027  Programming  Period,  currently  in  draft  form,  is  structured  around  five  key  Policy 
Objectives  (PO)  and  a  Special  Objective  linked  to  the  Just  Transition  Fund,  presented  in  a 
manner  consistent  with  the  strategic  priorities,  the  goals  and  the  respective  components  of  the 
recovery  and  resilience  plan.  Throughout  the  implementation,  it  will  be  important  to  ensure 
appropriate  coordination  between  the  Recovery  and  Resilience  Plan  and  the  operational 
programmes co-financed by the Cohesion Policy funds, exploit synergies and avoid overlaps in 
order to maximise impact of the investments and safeguard efficiency. 

The  pillars  of  “Green  Transition,”  “Digital  Transformation”,  “Private  investments  and 
transformation  of  the  economy”  and  “Employment,  skills  and  social  cohesion”  comprise 
investments  and  reforms  which  contribute  directly  and  indirectly  to  job  creation,  to 
enhancing  youth  employment  and  interact  with  the  Youth  Guarantee  Implementation 
Plan. Reforms and investments included in the “Employment, skills and social cohesion” pillar 
aim at increasing long-term employment, employability and labour productivity through labour 
market reforms, modernization of active and passive labour market policies (including measures 

28 

 
 
targeted  to  the  young  unemployed  individuals),  upgrading  the  mechanisms  for  diagnosis  of 
labour  market  needs,  and  reforming  and  digitalizing  the  Public  Employment  Service  (OAED). 
These  reforms  and  investments  are  related  to  the  goals  and  priorities  of  the  National  Youth 
Guarantee  Implementation  Plan,  and  complement  its  activities,  while  they  are  expected  to 
operate  as  complements  in  mitigating  the  employment  and  social  impact  of  the  COVID-19 
pandemic. 

Consistency  with  the  challenges  and  priorities  identified  in  the  most  recent  euro  area 
recommendation24  

The  Recovery  and  Resilience  Plan  is  also  consistent  with  the  challenges  and  priorities 
identified  in  the  most  recent  euro  area  recommendations  and  the  European  Flagships 
identified  in  the  Annual  Sustainable  Growth  Strategy.  In  particular,  the  Recovery  and 
Resilience Plan includes reforms linked to improving the business environment, the efficiency of 
the public administration, and the quality and efficiency of the justice system through component 
4.7  (Improve  competitiveness  and  promote  private  investment  and  trade),  component  2.2 
(Modernise),  component  4.2  (Modernise  the  Public  Administration)  and  component  4.3 
(Improve  the  efficiency  of  the  Justice  System).  Reforms  regarding  the  anti-money  laundering 
framework, fight  against corruption and securing tax collection capacity  are  addressed through 
component 4.1 (Making  taxes more growth friendly, and improving  tax administration and tax 
collection)  and  component  4.2  (Modernise  the  Public  Administration),  which  will  enhance  the 
AML/CFT  framework,  as  well  as  modernize  and  digitalise  the  relevant  infrastructures  and 
databases.  In  this  context,  EU  directives  have  already  been  embedded  in  the  Greek  law  to 
enhance  transparency,  expand  the  application  of  anti-money  laundering  and  counter  terrorism 
financing,  such  as  through  the  transposition  of  the  AMLD5  in  October  2020  (Law  4734/2020 
amending Law 4557/2018). 

National arrangements for the implementation of the plan 

The  implementation  of  the  recovery  and  resilience  plan  will  be  coordinated  by  the 
dedicated  Coordination  Agency  (RRF).  A  tailored-made  Management  and  Control  System 
(hereafter  MCS)  has  been  set-up  to  control  the  implementation  of  the  plan.  The  System  is 
developed  under  the  direct  management  of  the  Recovery  and  Resilience  Facility  Coordination 
Agency, which has the overall responsibility for the implementation of the national recovery and 
resilience plan and constitutes the single point of contact (“the coordinator”) between the Greek 
Authorities and the European Commission (EC). (See also section 4.8).  

The  Greek  plan  foresees  the  use  of  the  Recovery  and  Resilience  Facility  to  support  and 
strengthen  the  management  and  control  system  of  the  Recovery  and  Resilience  Facility 

24  Pending  final  adoption  by  the  Council,  after  endorsement  by  the  European  Council.  The  text  agreed  by  the 
Eurogroup  on  16 December  2020  is  available  at: https://data.consilium.europa.eu/doc/document/ST-14356-2020-
INIT/en/pdf 

29 

 
 
                                                           
Coordination  Agency  to  meet  the  increased  obligations  of  the  national  plan  and  to  enable  its 
efficient  and  effective  implementation.  The  financial  support  of  specific  activities,  such  as  the 
close  monitoring  of  projects’  progress,  audits  and  on-the-spot  inspections,  certifications, 
provision of information and publicity actions, is considered essential for the achievement of the 
recovery and resilience plan’s purposes. 

Gender equality and equal opportunities for all 

Regarding the gender equality and equal opportunities for all, the plan addresses the needs 
of women and several disadvantaged groups, particularly via the measures proposed under 
pillar 3 (employment, skills, and social cohesion). In 2020 the labour market participation rate 
of women in Greece was 51.8%, against 70.7% for men. Female labour market participation in 
Greece is one of the lowest among EU Member States, and significantly lower than the European 
average (66.8%). The third pillar of the Greek plan includes policies and measures strengthening 
the work life balance for both genders, and promoting female labour participation, in particular 
through investment  in  childcare. The  creation of new  childcare units (with  emphasis  on places 
for  infants  and  children  up  to  2.5  years  old),  the  creation  of  childcare  facilities  in  private 
companies and development of a comprehensive learning curriculum will increase the coverage 
and quality of childcare services, thus enhancing equal opportunities for women to remain in the 
labour  market.  Equal  opportunities  are  further  addressed  by  labour  market  activation 
programmes  for  vulnerable  groups  such  as  persons  with  disabilities,  migrants  and  guaranteed 
minimum  income  recipients  as  well  as  by  initiatives  to  promote  diversity  awareness. 
Furthermore, the third pillar of the plan includes the strengthening of the Equality Observatory of 
the  Ministry  of  Labour  and  Social  Affairs,  in  order  to  support  data  collection  and  data 
processing, with a view to better describe inequalities and discrimination. This will also facilitate 
the assessment of progress made in the field of equality and equal opportunities for all. 

30 

 
 
Consultation process  

Greece carried out a consultation process before submitting their Recovery and Resilience 
Plan.  In  line  with  the  principle  of  good  governance,  Greece  carried  out  a  stakeholder 
consultation  after  the  submission  of  the  draft  plan  to  the  Commission  in  November  2020,  and 
posted  it  on  the  Ministry  of  Finance’s  website.  The  authorities  received  contributions  and 
opinions on the reforms and investment from the local and regional authorities, industry, NGOs, 
social  partners,  Economic  and  Social  Committee  of  Greece  and  other  economic  associations, 
totalling  24  bodies.  A  summary  of  the  public  consultation  was  published  following  the  input 
collected in the consultation process and the comments received from the European Commission, 
the plan was redrafted and endorsed by the Council of Ministers at the end of March 2021. Then, 
it  was  presented  to  the  public  by  the  Prime  Minister  and  a  presentation  was  posted  on  the 
dedicated webpage 25. Greece then submitted a summary of the updated draft plan for discussion 
in the Parliament a few weeks prior to the official submission. It is foreseen that the plan will be 
introduced before the Parliament to be debated and put into law, after the adoption of the Council 
Implementing Decision. Additional consultation with key stakeholders is foreseen, with a view 
to further engaging them in the implementation phase. At the same time, a series of public events 
are being planned to increase ownership of the Plan. 

Technical support and InvestEU  

Greece is planning to use the Recovery and Resilience Facility to request technical support 
from  the  Commission  through  the  Technical  Support  Instrument  (TSI),  Horizon  Policy 
Support  Facility  and  to  finance  the  national  compartment  of  InvestEU.  Greece  plans  to 
request technical support from the Commission through the Technical Support Instrument (TSI), 
with the support of the Recovery and Resilience Facility, according to Article 7(2) of the RRF 
Regulation. The technical assistance is expected to increase the resilience and response capacity 
of  the  Greek  healthcare  system  by  modernising  the  quality  of  healthcare  management 
framework, in particular by supporting the drafting of National Strategy for Quality Assurance, 
Patient  Safety  and  Patient  Engagement.  The  total  estimated  cost  for  the  technical  support 
requested  to  support  these  organizational  reforms  in  the  health  system  is  EUR 0.5  million. 
Greece  is  also  planning  to  use  the  Recovery  and  Resiliency  Facility  loans  to  finance  the 
Members State compartment of InvestEU for an amount of EUR 500 million. This is alongside 
the other ways of using the RRF loans, via international financial institutions, commercial banks 
and  an  equity  platform.  Sectoral  support  for  the  design,  implementation  and  evaluation  of 
research  and  innovation  policy  reforms  will  also  be  available  via  the  Horizon  Policy  Support 
Facility. 

The  Technical  Support  Instrument  (TSI)  provides  expertise  in  building  capacities  to 
implement the plan in a number of areas. These areas are clean energy, digital transformation, 

25 https://www.minfin.gr/web/guest/tameio-anakampses 

31 

 
 
                                                           
state aid, health system reform, non-formal education, customs, financial literacy, as well as for 
the overall implementation of the plan. 

Security self-assessment 

The Greek plan includes a security-self assessment for investments in digital capacities and 
connectivity, in line with the Article 18(4)(g) of the RRF Regulation. As regards investment in 
connectivity, in particular in 5G networks, the plan identifies the relevant security issues. It also 
details how those will be addressed, based on the common objective criteria included in the EU 
toolbox  for  5G  networks  Cybersecurity.  Strategic  measures  mentioned  in  the  security  self-
assessment would need to be closely monitored during the implementation of the plan. 

Cross-border and multi-country projects 

The plan includes several cross-border and multi-country projects, mainly under the digital 
pillar (see section 4.6). There are investment projects related to the digital and R&D, such as the 
‘5G  corridors’  investment,  that  will  also  support  the  cross-border  corridor  Thessaloniki-Sofia-
Belgrade and the ‘Small satellites’ investment, that will ensure interoperability with EuroQCI. In 
addition,  the  ‘Submarine  fiber  cables’  investment  project  will  support  the  installation  of 
submarine  fibre  cables  to  interconnect  mainland  Greece  with  its  islands  and  with  Cyprus.  The 
plan  also  includes  investing  in  a  new  high  performance  computing  system  (upgrading  the 
existing one of the National Infrastructures for Research and Technology) and its interconnection 
with  the EuroHPC supercomputers; the  creation  of a national  Cybersecurity Operations Centre 
and  its  networking  with  similar  centres  of  other  Member  States.  It  further  includes  the 
framework of the European Common Data Infrastructure Services and the interoperability of the 
cloud, i.e. the Supply of Central Cloud Computing Infrastructure and Services. 

Communication strategy 

The Communication Strategy described in the plan consists of:  

  Coherent  and  effective  information  to  multiple  audiences  regarding  the  reforms  and 
investments  undertaken  by  Greece  under  the  Recovery  and  Resilience  Facility,  giving 
emphasis  to  audiences  that  «need  to  know»  specific  information  to  respond  to  the 
opportunities,  obligations,  etc.  connected  to  the  national  recovery  and  resilience  plan 
(people directly  affected by investments or reforms included in the plan), including the 
wide dissemination of funding opportunities for potential recipients. 

  Increasing  awareness  of  the  plan’s  objectives,  tangible  benefits,  and  impact  on 

citizens’ daily life.  

  Information  access  on  funded  projects  and  reforms  of  the  plan,  facilitating  the 
opportunity of any interested citizen or group to follow up on its implementation and thus 
promote the efficiency and transparency inherent to the national recovery and resilience 
plan, throughout the implementation period. 

  Informing,  coordinating  and  supporting  recipients  to  design  and  implement  their 
own communication actions by providing guidelines, monitoring, and networking. 

32 

 
 
 

Introducing  a  citizen  focused  approach  by  telling  project  stories  “on  the  ground”  or 
locally to mobilize community participation and build up a sense of ownership of the 
plan. 

  Ensuring the visibility of EU funding and provide the opportunity to citizens to fairly 
judge the difference made in their lives by the Recovery and Resilience Facility as both a 
national and an EU policy instrument. 

A dedicated website for the national recovery and resilience plan and the related projects 
will  be  established  in  order  to  provide  a  single-entry  point  for  all  interested  parties 
(institutional organisations, recipients, enterprises, media, general public) who wish to get 
information. In an effort to increase the visibility of the plan and the EU role and funding, the 
Communication  Strategy  will  integrate  multiple  activities/channels,  such  as  communication 
through  traditional  media  and  with  a  strong  public  relations  communication  strategy,  through 
Digital Campaigns on different platforms. Moreover, the Communication Strategy seeks to bring 
the recovery and resilience plan closer to the citizens by translating technical terms into simple, 
clear and reliable messages. 

State aid 

State  aid  and  competition  rules  fully  apply  to  the  measures  funded  by  the  Recovery  and 
Resilience Facility. Union funds channelled through the authorities of Member States, like the 
RRF funds, become State resources and can constitute State aid if all the other criteria of Article 
107(1)  TFEU  are  met.  When  this  is  the  case  and  State  aid  is  present,  these  measures  must  be 
notified and approved by the Commission before Member States can grant the aid, unless those 
measures are covered by an existing aid  scheme or comply  with  the applicable conditions  of a 
block  exemption  regulation,  in  particular  the  General  Block  Exemption  Regulation  (GBER) 
declaring certain categories of aid compatible with the internal market in application of Articles 
107 and 108 TFEU26. When State aid is present and it requires notification, it is the duty of the 
Member  State  to  notify  State  aid  measures  to  the  Commission  before  granting  them,  in 
compliance  with  Article  108(3)  TFEU.  In  this  respect,  the  State  aid  analysis  carried  out  by 
Greece in the recovery and resilience plan cannot be deemed a State aid notification. In as far as 
Greece considers that a specific measure contained in the recovery and resilience plan entails de 
minimis aid or aid exempted from the notification requirement, it is the responsibility of Greece 
to ensure full compliance with the applicable rules. 

Irrespective of whether they comply with the EU’s State aid regime, measures taken under this 
framework  should  be  compatible  with  the  EU’s  international  obligations,  in  particular  under 
World Trade Organization rules. 

26 Commission Regulation 651/2014, OJ L 187, 26.6.2014, p. 1. 

33 

 
 
 
 
 
                                                           
4.  SUMMARY OF THE ASSESSMENT OF THE PLAN 

4.1. Comprehensive  and  adequately  balanced  response  to  the  economic  and  social 

situation  

The plan follows a holistic approach to achieve recovery, while enhancing socio-economic 
resilience. Overall, the plan is balanced and focuses on Greece’s main challenges that, besides 
the twin transition, relate to the country’s social and educational needs, the strengthening of the 
public administration and the justice and financial systems, the enhancement of competitiveness 
in key sectors, as well as the need to boost the productive potential of the economy by promoting 
research and innovation and improving the business environment. Greece submitted its National 
Reform  Programme  on  27 April  2021.  The  information  provided  in  the  National  Reform 
Programme  is  being  considered  and  jointly  assessed  in  this  Staff  Working  Document  together 
with the recovery and resilience plan. 

Table 5 Coverage of the six pillars of the Facility by the Greek RRP components 

Green 
transition 

Digital 
transfor
mation 

Smart, 
sustainable 
& inclusive 
growth 

Social 
and 
territorial 
cohesion 

Health, 
and 
economic, 
social and 
institution
al 
resilience 

Policies for 
the next 
generation 

1.1 Power Up 
1.2 Renovate 
1.3 Recharge and refuel 

1.4 Sustainable use of 
resources, climate 
resilience and 
environmental protection 
2.1 Connect 
2.2 Modernise 
2.3 Digitalisation of 
businesses 
3.1 Increasing job 
creation and 
participation in the 
labour market  
3.2 Education, vocational 
education, training, and 
skills 
3.3 Improve resilience, 
accessibility and 
sustainability of 
healthcare  
3.4 Increase access to 

● 
● 
● 

● 

● 

● 

● 

● 

○ 

○ 
○ 
○ 

● 

○ 

● 

● 

● 

○ 

○ 

34 

● 
● 
● 

● 

● 

● 

● 

● 
● 

● 

● 

● 

● 

○ 

● 

○ 

○ 

○ 

● 

● 

○ 

● 

● 

● 

● 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
● 

● 

○ 

● 

● 

● 

● 

○ 

● 

● 

● 

● 

○ 

effective and inclusive 
social policies 
4.1 Making taxes more 
growth friendly, and 
improving tax 
administration and tax 
collection  
4.2 Modernise the public 
administration 
4.3 Improve the 
efficiency of the justice 
system  
4.4 Strengthen the 
financial sector and 
capital markets  
4.5 Promote research 
and innovation  
4.6 Modernise and 
improve resilience of key 
economic sectors  
4.7 Improve 
competitiveness and 
promote private 
investment and trade 
Loan Facility 
Total number of 
components that 
significantly contribute 
to pillar 
Key: “●”component significantly contributes to the pillar; “○” component partially contributes to the pillar 

10 

14 

11 

 ● 

○ 

● 

● 

● 

● 

● 

○ 

● 

● 

● 

● 

● 

○ 

● 

8 

7 

○ 

○ 

● 

5 

Green transition 

The recovery and resilience plan is designed to contribute to Greece’s green transition. The 
plan seems aligned with the priorities of the European Green Deal, the 2030 climate targets and 
the  goal  for  climate  neutrality  by  2050.  The  plan  also  aims  to  address  the  specific  targets  of 
Greece’s  National  Energy  and  Climate  Plan,  and  to  incorporate  the  relevant  Commission’s 
recommendations.  In  synergy  with  the  draft  national  and  territorial  Just  Transition  Plans,  the 
recovery and resilience plan takes into account the need to ensure a just transition, in view of the 
planned phase-out of lignite, and to tackle the challenge of energy poverty.  

Reforms and investments in pillar 1 are the main drivers of Greece’s efforts towards green 
transition. Component 1.1 aspires for the transition to a low-carbon energy model, the reduction 
in  greenhouse  gas  emissions  and  the  increase  in  the  use  of  renewable  energy  sources. 
Investments in this area are expected to contribute to increasing the resilience of the electricity 
network,  and  to  enhancing  electricity  interconnections  between  the  islands  and  the  mainland. 
Further, the component is intended to promote Greece’s national target for the total phase-out of 
lignite, mainly through a measure to restore the land and promote its alternative use, including 

35 

 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
 
for  recreational  and  commercial  purposes.  Component  1.2  sets  energy  efficiency  and  climate 
mitigation and adaptation actions for Greece’s housing stock as a key priority. The component 
includes  reforms  and  investments  that  promote  the  energy-efficient  renovation  and  upgrade  of 
buildings,  with  specific  funds  allocated  for  energy  poor  households.  Further,  the  component 
covers measures on the  implementation  of urban and spatial  planning, and the development  of 
strategic green urban regeneration projects. The component is also expected to contribute to the 
national  and  EU  climate  objectives  linked  to  the  reduction  of  greenhouse  gas  emissions,  and 
overall improve the cities’ resilience to climate change. Component 1.3 introduces reforms that 
enable the installation and operation of charging infrastructure for electric vehicles, in an attempt 
to move towards more green and sustainable transport. It provides for financial support for the 
installation of publicly accessible charging points for electric vehicles and foresees investments 
enhancing the electrification of urban and public transport.  It  also  includes the development of 
the first CO2 storage facility in the country. Component 1.4 includes actions related to waste and 
water  management,  protection  of  the  environment  (reforestation  initiatives  and  protection  of 
biodiversity), and upgrading the capabilities of the civil protection mechanism. 

Components  in  other  pillars  also  contribute  in  a  complementary  manner  to  the  green 
transition. For example, component 2.2 supports the implementation of policies to reduce waste 
and  energy  consumption  by  setting  a  requirement  for  data  centres  to  be  compliant  with  the 
relevant  European  Code  of  Conduct.  Components  in  pillar  3  on  employment,  skills  and  social 
cohesion  contain  measures  that  are  intended  to  promote  circular  economy  upskilling  and 
reskilling programmes, and assist  the unemployed, the working-age population  and students  in 
developing green skills and competencies. Component 4.3, with renovations and constructions of 
new  energy-efficient  and  low-emissions  court  buildings,  is  expected  to  contribute  to  reducing 
Greece’s  energy  footprint.  Investments  in  component  4.6  concerning  infrastructure  and 
equipment  renovations  could  decrease  emissions  and  improve  energy  efficiency,  while  others 
target at the establishment of spatial and urban planning. Finally, the Loan Facility is designed to 
allocate at least 37% of the value of the loans’ portfolio towards the green transition, including 
biodiversity. 

Digital transformation 

The  recovery  and  resilience  plan  also  contributes  to  Greece’s  digital  transformation.  The 
plan  assigns  a  specific  amount  of  funds  to  digital  actions,  while  it  appears  aligned  with  key 
objectives  of ‘Shaping Europe’s digital  future’. These concern interoperability in  the design of 
public  services,  connectivity  and  enhanced  broadband  connections,  cybersecurity,  artificial 
intelligence, development  of digital  skills, availability of open data, and  the empowerment  and 
equal  participation  of  women,  older  people  and  vulnerable  groups  in  the  digital  age.  The 
measures are designed to improve Greece’s position in connectivity and broadband coverage, as 
well as its overall digital performance.  

Pillar  2  of  the  plan  includes  actions  that  enhance  connectivity,  and  the  digitalisation  of 
public  administration  and  businesses.  Component  2.1  contains  investments  to  facilitate  the 
installation of fibre optic in buildings, the development of 5G networks covering all major Greek 
highways, the deployment of submarine fibre cables to connect mainland Greece with the Greek 

36 

 
 
islands and Cyprus, and the utilisation of space technologies and applications. Reforms institute 
the framework needed to facilitate the switch to fast broadband connections and the transition to 
5G  technology.  Measures  in  component  2.2  target  the  digital  transformation  of  public  sector 
entities  (archives  and  enhanced  digital  services),  business  process  improvements,  increased 
interoperability  between  systems  and  data,  cybersecurity  and  data  governance  strategies  and 
policies,  as  well  as  extended  use  of  advanced  technologies  (cloud  computing  and  big  data). 
Component  2.3  aims  to  boost  the  adoption  of  digital  technologies  by  businesses  (in  particular 
SMEs) by tackling key challenges of digital inclusion.  Initiatives will allow for the creation of 
the  digital  business  ecosystem,  and  will  support  SMEs  in  obtaining  digital  services,  data 
platforms and spaces, and new technology cash registers and Point-Of-Sale (POS) terminals. 

Employment,  skills  and  social  cohesion  measures  further  contribute  to  the  digital 
transformation.  Investments  in  component  3.1  concerning  IT  system  integrations,  services 
upgrades,  and  systems  interoperability  contribute  to  the  digital  transition  in  key  sectors  of  the 
employment and social  security public services.  Component 3.2 aims at  the development  of e-
learning and digitised training content to support the digital transformation of the education and 
training  system,  and  at  the  establishment  of  new  systems  to  enable  the  workforce  to  acquire 
digital  skills.  Component  3.3  provides  for  investments  in  the  digital  transformation  of  health, 
which aim at facilitating the deployment of sustainable digital healthcare solutions (including to 
deal  with  pandemics),  the  development  of  digital  infrastructure  and  applications  to  utilise  the 
skills  of  the  medical  and  clinical  workforce,  and  the  modernisation  and  strengthening  of 
governance. Component 3.4 also provides for digital reform elements, including simplification of 
access  to  social  assistance  schemes,  enhancements  in  control  and  monitoring  systems,  and 
development of digital skills of staff in social welfare institutions. 

Measures  in  pillar  4  target  the  digitalisation  of  public  administration,  the  judicial  and 
financial systems, and key sectors of the economy. Component 4.1 foresees the digitalisation 
of the national tax authorities through the replacement and upgrade of core digital systems, the 
introduction of automated office and work processes, the digitalisation of audits and controls, as 
well  as  the  update  and  improvement  of  taxpayer  e-services.  The  creation  of  new  integrated  IT 
systems  in  the  public  administration,  through  the  upgrade  of  existing  digital  infrastructure,  as 
well as through enhanced systems’ interoperability, are described in component 4.2. Component 
4.3  contains  reforms  and  investments  focused  on  the  digitalisation  of  the  judicial  system, 
including the digital integration of the systems of courts and the Ministry of Justice, the upgrade 
of  control  management  mechanisms,  and  the  implementation  of  smart  infrastructures. 
Component  4.4  introduces  digital  systems,  technologies  and  infrastructures  (e.g.  credit  bureau, 
registries)  that  are  expected  to  assist  in  monitoring  financial  market  information  and  credit 
expansion,  removing  information  asymmetries,  and  improving  the  IT  infrastructure  of  the 
supervisory authority. Development of advanced digital technologies, and enhanced coordination 
of competent authorities for civil protection are envisaged through an investment in component 
4.5.  Component  4.6  contains  actions  on  digital  solutions  tailored  to  key  economic  sectors, 
namely  tourism,  culture,  agriculture,  manufacturing  and  aquaculture,  as  well  as  national 
transportation  and  logistics  infrastructure.  Finally,  the  Loan  Facility  is  designed  to  allocate  at 
least 20% of the value of the loans’ portfolio towards the digital transformation. 

37 

 
 
Smart,  sustainable  and  inclusive  growth,  including  economic  cohesion,  jobs,  productivity, 
competitiveness, research, development and  innovation, and a well-functioning internal market 
with strong SMEs 

Investments  in  the  plan  have  the  potential  to  enhance  productivity  and  foster  smart  and 
sustainable  growth.  The  plan  contains  a  series  of  measures  that  are  expected  to  directly  or 
indirectly  support  private  investments,  including  for  SMEs.  For  instance,  Public  Private 
Partnerships for large infrastructure projects on irrigation and flood mitigation, civil protection, 
and upgrading of rail network, are foreseen in components 1.4 and 4.6. Support measures under 
component  2.3  aim  towards  the  digital  transformation  of  SMEs,  including  through  digital 
upskilling  and  integration  of  new  technologies  to  support  e-commerce  and  e-invoicing.  A 
number  of  aid  schemes  and  upskilling  programmes  are  also  included  in  component  4.6,  which 
target  at  fostering  greater  productivity,  through  smart  and  energy-efficient  solutions  and 
promoting  trade  in  key  areas  for  Greece  (such  as  aquaculture,  processed  agricultural  products, 
cultural tourism, and manufacturing). Further, the Loan Facility will provide loans as incentives 
for private investments that will be distributed through financial institutions, the deployment of 
an  equity  platform,  and  InvestEU.  The  funds  will  be  directed  to  long-term  private  sector 
investments and finance projects with positive expected rate of return.  

With  reference  to  smart  and  inclusive  growth,  important  interventions  are  introduced  to 
stimulate R&D performance, increase employment, and link skills to jobs. Component 4.5 
targets  at  enhancing  public  and  private  investment  in  R&D,  strengthening  the  links  between 
science and business, developing R&D infrastructure, and encouraging innovative companies to 
invest in R&D. Through these, it is envisaged to increase competitiveness and the exploitation of 
intellectual  property  rights,  empower  the  start-up  innovation  ecosystem,  mobilise  R&D 
expenditure, while reversing the ‘brain drain’. Also related to job creation, component 3.1 aims 
at  facilitating labour market  activation to promote full-time  employment  and safeguard against 
unemployment. Finally, component 3.2 on education, training and skills, includes reforms at all 
levels  of  education  with  an  overall  aim  to  increase  long-term  employment  and  productivity  by 
effectively  addressing  skills  mismatch  and  creating  a  direct  link  between  qualifications  and 
labour market needs. 

These  measures  are  flanked  by  important  reforms  of  the  business  environment. 
Specifically,  component  4.7  provides  for  the  introduction  of  tax  incentives,  cooperation  to 
promote  economies  of  scale  and  extroversion  of  enterprises,  the  simplification  of  key 
administrative  processes  such  as  registering  property  and  obtaining  construction  permits,  and 
improvements  in  the  quality  of  regulation  particularly  in  areas  such  as  manufacturing  and 
logistics.  Among  others,  proposed  measures  aim  to  support  the  sustainable  development  of 
agriculture and the promotion of Greek agricultural  and food products.  In addition,  component 
4.6 contains a reform of the legal framework on the attraction of strategic investments, including 
the creation of a new category of investments with additional incentives, the simplification and 
consolidation of the licensing procedure, and the inclusion of new fields of economic activity. 

Broader  reforms  in  the  public  administration  and  justice  domains  further  contribute  to 
sustainable growth. The plan provides for measures aiming at enhancing the efficiency of the 

38 

 
 
public  administration  (mainly  in  component  4.2).  These  include  the  improvement  of 
administrative  capacity,  the  enhancement  of  coordination,  and  the  implementation  of  public 
investment  projects.  Other  reforms  in  this  area  target  the  public  procurement  framework,  the 
continued  modernisation  of  the  public  financial  management  framework,  the  strengthening  of 
transparency,  as  well  as  the  fight  against  corruption  and  illicit  trade.  The  plan  also  contains 
critical reforms to increase the efficiency of the judicial sector (component 4.3). These measures, 
in conjunction with the ones indicated in the previous paragraphs, are integral to sustain growth 
and support productivity, competitiveness and a well-functioning internal market. 

Social and territorial cohesion 

Components  in  pillar  3  are  designed  to  address  challenges  related  to  labour  market 
participation  and  skills  development.  Component  3.1  encompasses  the  redesign  and 
strengthening  of  active  labour  market  policies,  with  the  objective  to  promote  labour  market 
activation, facilitate the transition from unemployment to full-time employment, and provide an 
effective  safety  net  against  unemployment.  In  this  respect,  the  proposed  programmes  provide 
subsidies  for  private  sector  employment,  some  of  them  combined  with  training,  and  target  the 
most  vulnerable  segments  of  the  labour  force.  Increase  in  the  number  of  staff  of  the  public 
employment  service  is  expected  to  facilitate  individualized  approach  to  jobseekers.  These 
reforms are complemented by passive labour market policies, including an incentives-compatible 
framework  of  unemployment  benefits  to  disincentivise  inactivity,  and  encourage  employment-
enhancing  participation  in  upskilling  and  reskilling  programmes.  Component  3.2  includes  a 
reform  on  the  governance  of  training  provision  for  upskilling,  reskilling  and  lifelong  learning, 
combined with investment in training programmes that cover the entire labour force, and aim at 
reducing skill mismatches and supporting the green and digital transition. 

The  plan  contains  certain  measures  that  are  expected  to  contribute  to  addressing  the 
country’s  challenges  in  the  area  of  gender  equality  and  equal  opportunities  for  all.  These 
include several  measures to  enhance employment  of women, including by expanding childcare 
facilities in municipalities and creating childcare units in companies. Equal opportunities are also 
promoted  through  measures  to  support  labour  market  integration  of  the  most  disadvantaged 
groups  with  higher  barriers  to  employment,  such  as  refugees,  beneficiaries  of  the  guaranteed 
minimum  income,  homeless  people,  Roma  or  persons  with  disabilities.  The  plan  also  includes 
equality  considerations  in  other  measures,  for  example,  early  disability  detection  for  children, 
touristic infrastructures accessible for persons with disabilities, thermal renovation of buildings 
to tackle energy poverty, training for diversity awareness, strengthened equality data collection, 
and addressing issues of debt and insolvency for the most disadvantaged households. 

Investments  in  transport  infrastructure,  and  energy  and  climate  actions  are  expected  to 
contribute  to  territorial  cohesion.  Component  4.6  contains  a  number  of  infrastructure 
investments  across  Greece’s  regions,  which  are  intended  to  promote  high-quality,  multimodal, 
climate-resilient,  and  safe  transport.  Together  with  the  reform  of  the  regulatory  framework  of 
public contracts, this is expected to improve connectivity and ensure green transition in all parts 
of  the  country.  This  component  also  foresees  measures  to  boost  regional  growth  through 
interventions  in  the  culture,  tourism  and  agriculture  sectors.  In  addition,  the  plan  includes 

39 

 
 
investments  that  are  geographically  distributed  across  Greece,  such  as:  (i)  upgrades  in  the 
electricity  distribution  network  (component  1.1);  (ii)  green  urban  regeneration  projects  and 
energy  upgrades  in  public  sector  buildings  (component  1.2);  (iii)  reforestation,  protection  of 
biodiversity,  wastewater  management  and  treatment  infrastructure,  water  supply  and  saving 
infrastructure, irrigation networks, flood protection projects (component 1.4); (iv) promotion of 
smart cities (component  2.2). Moreover, component 1.1 aims to promote the total phase-out of 
lignite  and  oil,  while  introducing  integrated  support  measures  (e.g.  socio-economic  and 
environmental  rehabilitation)  for  the  redevelopment  of  affected  areas,  in  order  to  ensure  a  just 
transition. 

Health, and economic, social and institutional resilience, with the aim of, inter alia, increasing 
crisis preparedness and crisis response capacity 

Component 3.3 is the main vehicle to address long-term challenges of Greece’s healthcare 
system  that  were  exacerbated  by  the  pandemic.  The  component  mainly  focuses  on  a  set  of 
investments, supported by reforms, to strengthen the national health system, facilitate access to 
health  services,  and  promote  the  system’s  sustainability.  The  main  building  blocks  include:  (i) 
organisational  reforms  to  rationalise  the  medical  reimbursements,  and  establish  a  reliable 
performance framework; (ii) infrastructure investments in the primary health system, supported 
by measures to increase the present and future stocks of family doctors; (iii) the renovation and 
upgrade  of  the  infrastructure  of  the  national  health  system;  (iv)  the  digital  transformation  of 
healthcare; (v) a national public health prevention strategy; (vi) a set of measures to rationalise 
pharmaceutical spending, including a revision of the clawback system and measures to support 
pharmaceutical R&D. 

As  regards  social  resilience,  component  3.4  aims  at  increasing  access  to  effective  social 
policies.  This  is  planned  to  be  achieved  mainly  through  measures  to  promote  labour  market 
(re)integration  of  the  most  vulnerable  population  groups  and  to  increase  availability  of  early 
childhood  education  and  care.  The  component  also  foresees  the  enhancement  of  structures 
providing social assistance services, optimisation of social benefits and digital transformation of 
the  social  protection  system.  Diversity  training  in  the  public  and  the  private  sector  to  fight 
discrimination  is  also  envisaged.  In  addition,  there  are  pilot  projects  to  develop  personal 
assistance  services  for  persons  with  disabilities  and  social  housing.  The  aforementioned 
measures are expected to enhance access to social services, support vulnerable groups, improve 
their  labour  market  participation,  and  thus  mitigate  adverse  shocks  from  a  social  resilience 
perspective. 

The plan also introduces actions to mitigate economic shocks by fostering sustainability of 
public  revenues,  strengthening  financial  sector  resilience,  and  diversifying  economic 
activity.  Component  4.1  aims  at  fighting  tax  evasion,  increasing  public  revenues,  limiting  lost 
revenue from smuggling, and reducing the administrative burden for taxpayers. This is planned 
to  be  achieved  through  reforms  to  codify  tax  legislation,  combat  smuggling,  and  increase 
electronic  transactions,  as  well  as  investments  to  digitalise  tax  administration  and  audits. 
Component 4.4 includes upgrades to  the  IT infrastructure of the new insolvency framework to 
enhance  adequate  credit  provision.  The  component  also  contributes  to  addressing  information 

40 

 
 
asymmetries,  facilitating  credit  decision-making,  and  preventing  over-indebtedness  through  the 
establishment  of  a  credit  bureau  and  registries.  These  measures  are  complemented  by  the 
codification and modernisation of the capital markets regulatory framework and the digitalisation 
of the supervisory authority, which are expected to contribute to resilience by enhancing access 
to finance. Moreover, component 4.7 includes targeted measures to facilitate the diversification 
of output toward more high-tech and more extroverted economic activities, and to  improve the 
business  environment,  which  are  also  anticipated  to  contribute  to  Greece’s  shock  absorption 
capacity.  

Institutional  resilience  can  be  achieved  through  actions  to  ensure  efficient  public 
administration and sound governance. Component 4.2 leads this effort by introducing reforms 
to  streamline  the  governance  and  allocation  of  responsibilities  between  levels  of  the 
administration,  invest  in  its  human  resources,  modernise  hiring  procedures,  promote  upskilling 
and  reskilling,  and  introduce  a  reward  system  for  public  entities  and  civil  servants.  The 
component  also  contains  a  comprehensive  package  of  anti-corruption  measures,  including  the 
development  of  methods  for  the  detection  and  prevention  of  corruption,  new  legislative 
initiatives  against  corruption,  the  legal  framework  for  Anti-Money  Laundering  and  Combating 
the  Financing  of  Terrorism  (AML  /  CFT),  and  actions  to  protect  intellectual  property  rights. 
Component  4.3  also  aspires  to  promote  institutional  resilience  by  ensuring  better  and  faster 
contract  enforcement,  through  reforms  to  accelerate  the  administration  of  justice,  the 
introduction of e-justice, as well as reskilling and upskilling of judges and judicial staff.  

Policies for the next generation, children and the youth, such as education and skills 

Reforms  and  investments  across  all  levels  of  education  aim  at  digitalising  processes  and 
infrastructures,  developing  skills,  and  facilitating  cooperation  and  research.  As  regards 
primary and secondary education, component 3.2 features measures covering the digitisation of 
the  education  material,  the  integration  of  modern  digital  tools  in  schools,  as  well  as  financial 
support to disadvantaged students to acquire equipment. For vocational education and training, 
the main objectives concern the upgrade and alignment of relevant curricula with labour market 
needs,  in  particular  the  green  and  digital  transition.  In  addition,  the  component  foresees  the 
upgrade  of  laboratory  equipment  for  the  various  vocational  education  and  training  units.  The 
measures  extend  to  strengthening  the  apprenticeship  system,  updating  the  offered  modules  to 
increase their labour market  relevance, and establishing evaluation  systems  to  monitor training 
outcomes.  For  higher  education,  the  component  includes  interventions  to  foster  cooperation 
between  Greek  universities  and  universities  abroad,  enhance  research  activity  in  Greek 
universities  especially  in  cooperation  with  businesses,  and  strengthen  the  link  between  higher 
education  and  the  labour  market.  Moreover,  component  4.5  contains  measures  to  boost  R&D 
investment  and  reinforce  academia-business  linkages,  which  are  expected  to  improve  Greece’s 
performance  in  this  domain  and  benefit  future  generations.  For  example,  a  reform  in  this 
component  promotes  the  opening  up  of  the  research  and  innovation  ecosystem,  by  linking  the 
Greek  innovation  network  at  a  broader  scale,  including  research  centres,  innovation  clusters, 
competence centres and highly innovative local companies. 

41 

 
 
Component 3.4 includes reforms and investments targeted to children and the youth. A key 
reform  in  this  component  is  the  design  and  introduction  of  a  unified  and  comprehensive 
curriculum  for  preschool  units.  This  will  focus  on  early  intervention,  including  the  use  of 
psycho-technical tools for early diagnosis of learning and developmental disorders. The reform is 
also  linked  to  early  intervention  in  children  on  the  autism  spectrum,  which  aims  to  support 
psycho-emotional development, the quality of life, and social inclusion of children. Moreover, a 
strategic goal of this component is the deinstitutionalisation of children and adolescents through 
the  transfer  of  adolescents  to  supported  living  structures,  their  further  support  with  skills 
programs, and development of foster care to increase the placement of children with disabilities 
in  family  environments.  The  component  also  provides  for  digital  skills  programs  designed  for 
children from twelve to fifteen years old. 

Other  components  also  contribute  to  policies  for  the  next  generation.  Specifically, 
component 2.3 provides for a dedicated program to strengthen young entrepreneurship. Further, 
component 3.1 contains  actions for the digitalisation of the public employment service and the 
upgrading of the labour market needs’ diagnostic mechanism that are linked to the national youth 
guarantee implementation plan. 

Conclusion 

Taking  into  consideration  all  reforms  and  investments  envisaged  by  Greece,  its  recovery  and 
resilience plan represents, to a large extent, a comprehensive and adequately balanced response 
to the economic and social situation, thereby contributing appropriately to all six pillars referred 
to in Article 3 of the RRF Regulation, taking the specific challenges and the financial allocation 
of Greece into account. This would warrant a rating of A under the assessment criterion 2.1 in 
Annex V to the RRF Regulation. 

4.2. Link with country-specific recommendations and the European Semester  

In  line  with  assessment  criterion  2.2  in  Annex  V  to  the  RRF  Regulation,  this  section 
provides a factual overview of whether Greece´s recovery and resilience plan is expected to 
effectively  address  all  or  a  significant  subset  of  the  country’s  economic  and  social 
challenges.  These challenges  are identified in  the relevant  Country-Specific Recommendations 
(CSRs) addressed to Greece in July 2019 and July 2020, including the fiscal aspects thereof, and 
recommendations made pursuant to Article 6 of Regulation (EU) No 1176/2011, based on the in-
depth  review  for  Greece  under  Article  5  of  Regulation  (EU)  No  1176/2011  published  in  2019 
and 2020. 

The Commission Communication on the findings of the 2021 in-depth review, published on 
2 June,  concluded  that  Greece  is  experiencing  excessive  imbalances.  The  2021  in-depth 
review  concluded  that  Greece’s  vulnerabilities  continue  to  relate  to  high  government  debt, 
incomplete  external  rebalancing  and  high  non-performing  loans,  in  a  context  of  high 
unemployment  and  low  potential  growth.  Addressing  these  challenges  is  expected  to 
significantly boost the growth potential of the economy of Greece in a sustainable manner. The 
COVID-19 crisis  has interrupted the  adjustment  process  initiated in  previous  years. The recent 
crisis has also brought to the fore the importance of bolstering the country’s growth prospects in 
correcting the legacy imbalances and strengthening its economic and social resilience.  

42 

 
 
Against  this  background,  the  Country-Specific  Recommendations  addressed  to  Greece  in 
2019 and 2020 under the European Semester cover the following areas: 

(1) Public finances and health care: The authorities are called on to adopt appropriate fiscal 
response  measures  to  effectively  address  the  impact  of  the  pandemic,  sustain  the 
economy and support the ensuing recovery, including by strengthening the resilience and 
accessibility of the health system. When economic conditions allow, Greece is invited to 
pursue  fiscal  policies  aimed  at  achieving  prudent  medium-term  fiscal  positions  and 
ensuring debt sustainability, while enhancing investment.  

(2) Labour  market  and  social  policy:  The  recommendations  stress  the  need  for  measures 
such  as  short-time  work  schemes  and  the  provision  of  effective  activation  support  to 
mitigate the employment and social impacts of the crisis. 

(3) Public  and  private  investment:  Greece  is  invited  to  provide  continued  liquidity  to 
COVID-19  affected  businesses.  It  is  also  recommended  to  front-load  mature  public 
investment projects and promote private investment in areas that will facilitate the green 
and  digital  transition,  support  employment  and  raise  labour  productivity,  focusing,  in 
particular  on  the  areas  of  sustainable  transport  and  logistics,  clean  and  efficient 
production and use of energy, environmental infrastructures, digital technologies, human 
capital development and the renewal of urban areas. Within this context, improving the 
effectiveness  and  digitalisation  of the  public  administration  and  promoting  digital 
transformation of businesses would be key. 

(4) Structural  reforms  to  improve  the  functioning  of  the  economy:  The  authorities  are 
encouraged to implement structural reforms in particular in the areas of fiscal and fiscal-
structural policies, social welfare, financial stability, labour and product market, and the 
modernisation of public administration.  

to  growth  and 

thereby  support 

the  correction  of 

The  reforms  and  investments  to  be  implemented  under  the  Recovery  and  Resilience 
Facility,  along  with  other  EU  support,  represent  a  major  opportunity  to  remove 
impediments 
identified 
macroeconomic  imbalances,  while  promoting  a  more  inclusive  and  sustainable  growth 
model.  The  plan  builds  on  the  reform  agenda  initiated  under  the  economic  adjustment 
programmes  and  currently  monitored  under  enhanced  surveillance, 
tax 
administration  reform,  social,  healthcare  and  business  environment  reforms  as  well  as  reforms 
and investments strengthening the public administration and the justice system. The plan further 
contains  several  institutional  and  structural  reforms to  support  entrepreneurship,  private  and 
public  investment  and  productivity  growth.  It  provides  incentives  to  help  companies  grow, 
innovate and trade better, while tackling inefficiencies in public administration and promoting a 
more business-friendly tax system. The plan is centred on the objective of favouring a digital and 
green transition.  

including 

the 

the 

Public finances and health care 

The  increased  financing  needs  due  to  the  COVID-related  public  support  measures  have 
widened the government deficit and increased public debt. In 2020, the general government 
budget was in a deficit of 9.7% of GDP, while the government debt increased to 206% of GDP. 
Greece has responded swiftly  to  address  the impact  of the pandemic, sustain the economy  and 
support  the  ensuing  recovery.  The  authorities  have  put  forward  a  wide  range  of short-term 

43 

 
 
measures,  including  tax  and  social  security  contribution  deferrals,  fiscal  measures,  and  the 
provision of liquidity guarantees, to provide income support to individuals, maintain liquidity in 
the private economy and prevent job dismissals (Section 2.1).  

In  line  with  the  country-specific  recommendation,  the  plan  can  play  a  key  role  in 
promoting investments going forward. Given its strong focus on employment, investment and 
productivity-enhancing policies, the implementation of the plan is expected to raise growth and 
thus  contribute  to  putting  public  finances  on  a  sound  footing  in  the  medium  to  long  term. 
Moreover, the plan presents a range of reforms to make taxes more growth-friendly and improve 
the  tax  administration  and  tax  collection,  including  by  further  increasing  the  use  of  electronic 
transactions,  accelerating  refunds  of  the  value  added  tax,  and  limiting  the  misallocation  of 
resources  towards  the  informal  sector.  These  reforms  are  complemented  by  investments  to 
support  the  digitalisation  of  the  Independent  Authority  for  Public  Revenue  (IAPR)  and  tax 
audits, aiming to  eliminate lost revenue  from  smuggling, and  reduce the administrative burden 
for  taxpayers.  The  plan  also  envisages  measures  to  improve  public  financial  management, 
including  through  digitalisation,  reforms  of  public  procurement  and  a  modernisation  of  the 
institutional framework for state-owned enterprises. 

In  response  to  the  challenges  in  the  healthcare  system,  the  plan  envisages  significant 
investments in upgrading the infrastructure of the hospital system and improving several 
of its operational aspects, while promoting access, efficiency and resilience of the healthcare 
sector more broadly. Key weaknesses of the healthcare system are reflected in a still weak and 
understaffed primary healthcare sector and an underdeveloped long-term care sector, which lead 
to  unmet  needs.  This  is  aggravated  by  persistent  supply-induced  demand  for  healthcare  and 
weaknesses  in  the  centralised  procurement  system  for  healthcare  expenditure  (Section  2.2).  In 
view  of  these  challenges,  the  plan  aims  to  strengthen  the  primary  healthcare  sector,  promote 
prevention  services  with  a  comprehensive  national  programme  for  public  health  that  will  also 
support preparedness, increase the capacity of the health care system to deliver mental health and 
home  care  services,  rationalise  pharmaceutical  spending  and  support  pharmaceutical  R&D. 
Another  important  element  of  the  plan  are  the  ambitious  measures  to  digitalise  healthcare 
systems and services with a view to expanding access to services and improving public spending 
efficiency. 

Labour market and social policy 

While the pandemic has had a relatively limited impact on the unemployment rate thanks 
to the effective policy response, the labour market continues to face significant challenges. 
Unemployment remains  among the highest  in  the EU, while employment  is  among the lowest. 
The challenges further include high youth unemployment, a high gender employment gap and a 
large share of long-term unemployed. Despite the improvements ahead of the pandemic, labour 
productivity remains weak and the effectiveness of the activation support, beyond the short-time 
work  schemes  implemented  during  the  COVID-19  crisis,  is  low,  partly  due  to  capacity 
constraints of the Public Employment Service (Section 2.2). 

The plan contains a number of measures to support employment. The plan presents a series 
of targeted hiring subsidies, upskilling programmes including in the digital and green economy, 
and measures to enhance the administrative capacity of the Public Employment Service (OAED) 
including  by  expanding  its  digital  services.  These  measures  are  of  a  broad  scope  and  are 
expected to contribute to addressing the country-country specific recommendation that calls on 

44 

 
 
Greece  to  ensure  effective  activation  support  in  order  to  mitigate  the  employment  and  social 
impact of the health crisis. At the same time, there is further room to ensure effective provision 
of tailor-made activation support to the unemployed on a continuous basis. Furthermore, the plan 
envisages the adoption of a Labour Code reform to modernise key aspects of the labour market 
and  improve  its  functioning.  These  measures  are  complemented  by  reforms  of  passive  labour 
market  policies,  including  in  the  form  of  a  new  incentives-compatible  ‘mutual  obligations 
framework’,  which  aims  to  improve  adequacy  of  the  unemployment  insurance  system  while 
mitigating disincentives to participate to trainings.  

The  plan  effectively  addresses  most  of  the  challenges  facing  the  Greek  education  system 
and  puts  emphasis  on  labour  market  integration  of  vulnerable  groups.  To  recall,  Greece 
ranks low in basic skills partly due to teaching weaknesses, and education outcomes are highly 
affected  by  the  students’  socioeconomic  background,  while  the  education  system  does  not 
correspond  fully  to  the  needs  of  the  labour  market  (Section  2.2).  The  plan  includes  several 
measures  to  improve  the  quality  and  labour  market  relevance  of  education  at  all  levels  and  to 
expand  distance  learning  opportunities  as  a  means  to  improve  access  to  education.  The  plan 
further  contains  a  thorough  reform  of  the  lifelong-learning  system  and  a  large  volume  of 
investments  in  upskilling  and  reskilling  programmes  with  a  particular  focus  on  the  green  and 
digital transition. The effectiveness of these programmes will crucially depend on the reform of 
the life-long learning system and the extent to which it will help ensure high quality and labour 
market relevance of offered programmes, accountability of providers and appropriate selection of 
participants.  Among  others,  the  plan  aims  to  promote  diversity  awareness  and  support  social 
integration of vulnerable groups, including persons with disabilities and homeless people, Roma 
and  the  extremely  poor  through  labour  market  activation.  It  puts  high  emphasis  on  gender 
equality  and  promotes  participation  of  women  in  the  labour  market  including  through  targeted 
employment  subsidies  and  upskilling  programmes,  and  by  expanding  childcare  facilities.  Last 
but not least, the plan contains measures to ensure a socially just transition in areas where lignite-
based  electricity  generation  will  be  gradually  phased-out,  while  it  allocates  specific  funds  to 
support  energy  poor  households  through  investments  that  promote  energy-efficient  renovation 
and upgrading of buildings. 

Public and private investment 

The plan puts particular emphasis on front-loading mature public investment projects and 
promoting public and private investments in priority sectors, including those contributing 
to the digital and green transition.  Implementation  of large public infrastructure projects  has 
persistently suffered from the lack of an effective planning and monitoring system (Section 2.2). 
In  response,  the  plan  seeks  to  strengthen  the  policy  and  planning  coordination  framework  by 
modernising  public  administration,  procurement  and  the  public  accounting  system,  and  by 
strengthening  the  fight  against  corruption.  At  sectoral  level,  in  line  with  the  country-specific 
recommendation,  the  plan  presents  a  number  of  investments  promoting  renewable  energy  and 
electricity  interconnection,  increase  the  energy  performance  of  public,  residential  and  non-
residential  buildings,  the  renewal  of  urban  areas,  safe  and  sustainable  transport  and  logistics, 
environmental  protection  and  infrastructure,  very-high-capacity  digital  infrastructure,  the 
digitalisation of the public administration, the digital transformation of businesses, and research 
and  development.  These  measures  are  complemented  by  the  establishment  of  the  loan  facility, 
which caters for the distribution of the loan component of the plan through financial institutions, 

45 

 
 
an  equity  platform,  and  InvestEU,  and  creates  financial  incentives  for  the  private  sector  to 
increase private investments. 

Overall, the plan addresses the challenges related to energy efficiency and the renewal  of 
urban areas. Energy consumption of Greece's public and private buildings accounts for almost 
40% of total final energy consumption, which points to the need for deep renovations to achieve 
savings,  while energy poverty is  a pressing social  challenge (Section 2.3). To respond to  these 
challenges, the plan  aims to  enhance the energy  performance of buildings, with  a focus on the 
residential  sector, including energy poor households.  The plan  also  includes reforms  aiming to 
ensure  the  financial  sustainability  of  the  renewable  energy  sources  (RES)  system,  further 
simplify  the  RES  licensing  procedure  and  introduce  specific  energy  market  reforms,  including 
the  establishment  of  a  monitoring  mechanism  by  the  national  energy  regulator.  Moreover,  the 
plan  will  help  address  the  country-specific  recommendation  on  the  need  to  renew  urban  areas, 
mainly through the reform of local urban planning covering all territories of the country.  

The  plan  presents  measures  that  will  be  instrumental  in  addressing  challenges  related  to 
logistics 
sustainable  and  safe  transport,  with  complementing  efforts  to  expand 
infrastructures that are supported by other EU financing resources. Transport is responsible 
for 21% of the national greenhouse gas emissions and accounts for the largest share in the final 
consumption  of  energy  (41%).  The  Greek  fleet  is  among  the  oldest  in  Europe,  and  heavily 
dependent on oil, while the e-mobility market is at an early development stage. Greece also ranks 
low in terms of road safety (Section 2.3). The plan seeks to tackle both environmental and safety 
aspects of the transport system. It includes measures to install more than 8 000 charging stations 
for  electric  vehicles,  replace  a  number  of  busses  and  taxis  with  battery  electric  vehicles  and 
provide targeted support for new production-related activities in the e-mobility sector. The plan 
also contains a significant reform of the railways sector and several rail projects, contributing to 
switching  from  fossil  fuel  road-based  transport  into  more  sustainable  transport  modes. 
Furthermore,  Greece’s  competitive  advantage  in  maritime  transport  is  likely  to  be  enhanced 
through the development of a masterplan for the renewal of the Greek passenger shipping fleet 
and selected interventions in regional and tourist ports. Last but not least, the plan complements 
investments in logistics that are supported by EU financing resources other than the RRF, such as 
the European Structural Investment Funds (ESIF) or the Connecting Europe Facility (CEF). 

The  plan  includes  a  number  of  measures  aiming  to  strengthen  environmental  protection 
and  builds  synergies  with  complementary  measures  supported  by  other  EU  financing 
resources.  Greece  faces  substantial  challenges  in  this  area,  reflected  in  a  weak  solid  waste 
management  system  and  suffers  from  inadequate  supervisory  structures  and  the  lack  of 
appropriate  regulatory  frameworks  for  water  and  waste  management  (Section  2.3).  Several 
investments  are  envisaged  in  the  plan  to  improve  water  supply  and  wastewater  treatment  in 
several  territories  of  the  country.  The  setup  of  a  national  waste  management  supervisory  body 
and  a  national  water  regulatory  authority  will  increase  the  accountability  of  the  operators, 
strengthen the governance architecture and ensure financial sustainability in both solid waste and 
water  sectors,  respectively.  Moreover,  the  plan  contains  a  comprehensive  programme  of  civil 
protection and disaster management aiming both at improving resilience towards climate change 
and  natural  risks  and  at  responding  to  natural  disasters,  including  forest  fires,  floods  and 
earthquakes.  The  plan  also  includes  measures  aiming  to  ’green’,  modernise  and  enhance  the 
competitiveness  of  the  agricultural  sector  including  by  upgrading  the  irrigation  networks 
complementing  actions  under  the  Common  Agricultural  Policy.  Last  but  not  least,  the  plan 

46 

 
 
complements  investments  in  environmental  infrastructures  that  are  supported  by  EU  financing 
resources other than the RRF, notably the European Structural Investment Funds (ESIF). 

The  plan  is  likely  to  help  address  challenges  related  to  the  low  digitalisation  of  both  the 
public  administration  and  the  business  sector.  Albeit  improving  over  time,  Greece’s  digital 
performance  remains  among  the  lowest  in  the  EU  and  is  characterised  by  a  combination  of 
shortfalls in connectivity, digital skills, digital uptake by companies, provision of digital public 
services, low investment in  R&D, and the absence of smart public transport solutions  (Section 
2.3). Following up on the recent work to improve digital governance and the provision of digital 
public  services,  the  plan  contains  a  number  of  measures  to  digitally  transform  the  public 
administration,  including  the  justice  system  and  the  tax  and  customs  authority,  and  promote 
interoperability of public sector systems and registries, which is limited. The plan also presents 
investments  in  the  digitalization  of  businesses  through  the  deployment  of  advanced  digital 
infrastructure  and  relevant  technology  advisory  services,  the  development  of  digital  skills  in 
small and medium sized enterprises and the promotion of a business ecosystem conducive to the 
integration of new technologies and innovation. 

The  plan  builds  on  and  complements  efforts  to  ease  doing  business  and  facilitate  trade. 
Greece is one of the countries with the lowest business dynamism in the EU. Productivity growth 
faces  significant  obstacles  that  include  high  regulatory  barriers  and  inefficiencies  in  the  public 
administration  –  especially  in  areas  such  as  contract  enforcement  and  registering  property,  the 
licensing  process,  and  environmental  permits  –  coupled  with  the  time  needed  by  the  justice 
system to deliver its final decisions as well as lack of clarity on the application of tax rules. One 
of the key objectives of the plan is to facilitate trade and provide incentives for firms to grow and 
innovate.  Several  measures  support  private  investment  either  directly  by  encouraging 
investments  in  modern digital  technologies  and using tax incentives on tangible  and intangible 
assets, or indirectly, by promoting an improved business ecosystem conducive to innovation. The 
plan aims to lift excessive administrative burdens on businesses by expanding simplification of 
licensing procedures to  a number of economic sectors, while fostering compliance and a level-
playing field through effective market surveillance, and an improved regulatory framework. The 
plan  also  puts  emphasis  on  improving  the  framework  for  public  procurement,  building  on  a 
recent reform (law 4782/2021), and promoting public-private partnerships.  

Broader structural reforms to improve the functioning of the economy 

The plan builds on and complements key structural reforms that were initiated under the 
economic adjustment programmes to improve the broader functioning of the economy. The 
reform  agenda  emerging  from  the  plan  is  based  on  the  Development  Plan  for  the  Greek 
Economy,  prepared  by  a  committee  of  experts  chaired  by  Nobel-prize  economist  Professor 
Pissarides.  In  particular,  the  plan  contains  important  reforms  in  key  areas,  such  as  fiscal 
structural including the tax administration and public procurement; labour market, social benefits 
and health care; education, the financial sector and business environment; and modernisation of 
the public administration, justice and fight against corruption. Some of its key elements include 
the following reforms and supporting digital investments: a) the improvement and modernisation 
of  the  labour  law,  b)  the  establishment  of  a  National  System  of  Vocational  Education  and 
Training, c) the roll out of the primary health care system and e-health – including an electronic 
Medical  Health  Record  and  telemedicine,  d)  the  digitalisation  of  various  processes  of  the 
Independent Authority of Public Revenue including online cash registers and the acceleration of 
VAT  refunds,  as  well  as  the  codification  and  simplification  of  tax  legislation;  e)  the 

47 

 
 
implementation  of  the  electronic  filing  of  legal  documents,  completing  phase  II  of  the 
establishment of the e-justice system (OSDDY-PP) and the ‘JustStat’ unit for data collection and 
processing,  f)  the  implementation  of  reforms  aimed  at  bolstering  the  health  of  the  banking 
system,  including  non-performing  loans  resolution  efforts  by  ensuring  the  effectiveness  of  the 
relevant  legal  framework,  and  g)  initiatives  to  complete  the  investment  licensing  reform,  by 
finalising  the  simplification  of  procedures  in  the  agreed  remaining  sectors  and  inspection 
legislation. While these measures build on and complement reforms initiated under the economic 
adjustment programmes which are partly still ongoing, the reforms and investments included in 
the  recovery  and  resilience  plan  go  beyond  specific  commitments  made  by  Greece  in  the 
Eurogroup  in  2018  both  in  their  scope  and  in  their  timeframe.  Policies  addressing  specific 
Eurogroup commitments continue to be monitored under enhanced surveillance.  

Conclusion 

Taking  into  consideration  the  reforms  and  investments  envisaged  by  Greece,  the  recovery  and 
resilience  plan  is  expected  to  contribute  to  effectively  addressing  a  significant  subset  of 
economic  and  social  challenges  identified  in  the  country-specific  recommendations,  including 
the  fiscal  aspects  thereof,  and  recommendations  made  pursuant  to  the  Macroeconomic 
Imbalances Procedure27. This would warrant a rating of A under the assessment criterion 2.2 in 
Annex V to the RRF Regulation. 

27 These macroeconomic imbalances refer to the recommendations made pursuant to Article 6 of Regulation (EU) 
No 1176/2011 in 2019 and 2020. 

48 

 
 
                                                           
Table 6 Mapping of country challenges identified in 2019-20 country-specific recommendations and the 18 components of the Greek 
recovery 

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○ 

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49 

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Associate
d 
European 
Semester 
country-
specific 
recomme
ndations 
CSR 
(2019-
2020) 

2019.1, 
2020.1.1, 
2020.1.2 

2019.1, 
2019.2.8, 
2020.1.2, 

Country challenges 
(as identified in 
Section 2) 

Fiscal policy and 
fiscal governance, 
including measures 
to ensure long-term 
sustainability of 
public finances, 
while enhancing 
investment  
Health care and 
long-term care, 
including measures 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
to strengthen the 
resilience of the 
health system and 
ensure adequate 
and equal access to 
healthcare 

Implementation of 
employment-
supporting 
measures such as 
short-time work 
schemes 
Incentives to work, 
job creation, labour 
market 
participation and 
effective activation 
support. 
Poverty reduction 
and social inclusion 

a) Safe and 
sustainable 
transport and 
logistics 
b) Clean and 
efficient production 
and use of energy, 
including 
renewable energy 
and interconnection 
projects 
c) Environmental 
infrastructure 
d) Very-high 
capacity digital 
infrastructure and 

2020.1.3 

2019.1, 
2020.4, 
2020.2.1 

2020.2.2 

2019.1, 
2020.2.1, 
2020.4 

2019.2.1, 
2020.3.4 

2019.2.2, 
2020.3.5 

2019.2.2, 
2020.3.6 

2019.2.3, 
2020.3.7 

Labour market and social policies 

● 

○ 

○ 

● 

○ 

Policies supporting investment in digital and green transition and in particular, in the following areas 

● 

● 

● 

● 

○ 

○ 

● 

● 

○ 

○ 

○ 

○ 

50 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
digital technologies 
e) Promote digital 
transformation of 
businesses 
f) Education 
g) Skills, including 
digital skills and 
employability 
h) Research and 
Development 
i) Renewal of urban 
areas 

Front-load mature 
public investment 
projects  
Improve the 
effectiveness and 
digitalisation of the 
public 
administration 
Swiftly deploy 
measures to 
provide liquidity 
and continued flow 
of credit and other 
financing to the 
economy, focusing 
in particular on 
small and medium-
sized enterprises 
most affected by 
crisis.  
Promote private 
investment to foster 
the economic 
recovery  

2020.3.10 

2019.2.5 
2019.2.6, 
2019.2.7, 
2020.3.8 

2019.2.4 

2019.2.9 

2020.3.2 

2020.3.9 

2020.3.1 

2020.3.3 

● 

● 

● 

● 

● 
● 

● 

○ 
○ 

○ 

● 

○ 

● 

● 

Public administration and business environment 

○ 

● 

● 

● 

● 

● 

● 

● 

○ 

● 

● 

● 

● 

● 

○ 

● 

○ 

● 

○ 

● 

● 

● 

○ 

○ 

○ 

○ 

○ 

○ 

○ 

○ 

○ 

○ 

○ 

● 

Pursue structural 

2019.1, 

○ 

○ 

Broader functioning of economy 
● 

● 

○ 

51 

● 

● 

● 

● 

● 

● 

○ 

● 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2020.4 

reforms in key 
areas, such as fiscal 
structural including 
the tax 
administration and 
public 
procurement; 
labour market, 
social benefits and 
health care; 
education, the 
financial sector and 
business 
environment; and 
modernisation of 
the public 
administration, 
justice and fight 
against corruption. 

Note: “●” denotes that investments and reforms of the component significantly address the challenge; “○” denotes that investments and reforms of the component partially 
address the challenge. 

52 

 
 
4.3. Growth  potential,  job  creation,  economic,  institutional  and  social  resilience, 
European  Pillar  of  Social  Rights,  mitigating  the  impact  of  the  crisis,  and  social 
territorial cohesion and convergence  

In line with assessment criterion 2.3 in Annex V to the Regulation, this section summarises 
the  assessment  of  the  expected  contribution  of  the  plan  to  strengthening  the  growth 
potential,  job  creation,  and  economic,  social  and  institutional  resilience  of  the  Member 
State,  contributing  to  the  implementation  of  the  European  Pillar  of  Social  Rights,  including 
through  the  promotion  of  policies  for  children  and  youth,  and  to  mitigating  the  economic  and 
social  impact  of  the  COVID-19  crisis,  thereby  enhancing  the  economic,  social  and  territorial 
cohesion and convergence within the Union. 

The plan builds upon and is consistent with the comprehensive Development Plan for the 
Greek  economy,  prepared  in  2020  by  a  committee  led  by  the  Nobel  laureate,  Professor 
Pissarides.  As  such,  it  addresses  the  main  obstacles  affecting  long-term  growth  in  Greece, 
including notably the investment gap, measures required to increase productivity and the need to 
improve the quality of education and the efficiency of public administration and of justice. The 
plan’s strong emphasis on active labour market policies, reskilling and upskilling has a potential 
to  increase  labour  market  participation  and  employment  (including  that  of  women),  which  is 
welcome, considering the still high rate of unemployment.  

In  the  short  to  medium  term,  model  simulations  estimate  an  increase  in  the  baseline 
average  annual  GDP  growth  of  0.3-0.5  percentage  points  over  the  period  2021-2026  as  a 
result  of  the  implementation  of  the  recovery  and  resilience  plan,  without  the  possible 
positive impact of structural reforms (see Box 2). The overall increase in GDP is projected to 
reach  2.1-3.3%  by  2026.  Through  its  growth  impact,  the  recovery  and  resilience  plan  is  also 
expected  to  provide  support  for  Greece  to  achieve  the  planned  primary  surpluses  needed  to 
ensure the overall sustainability of Greece’s public finances.  

Box 2 Stylised NGEU impact simulations with QUEST - Greece 

Model  simulations  conducted  by  the  Commission  using  the  QUEST  model  show  that  the 
economic  impact  of the NGEU  in  Greece  could lead  to  an increase  of  GDP of  between  2.1  and 
3.3% by 2026.28 After 20 years, GDP could be 1.2% higher. Spillovers account for a large part of 
such impact.  

According  to  these  simulations,  this  would  translate  into  up  to  62 000  additional  jobs.  Cross  border 
(GDP)  spillovers account for  0.3  pps  in  2026,  showing  the  value  added  of  synchronised  expenditure 

28  RRF  amounts  to  roughly  90%  of  NGEU,  which  also  includes  ReactEU,  Horizon,  InvestEU,  JTF,  Rural 
Development and RescEU. 

53 

 
 
                                                           
across Member States (line 2). Even in a scenario with a lower productivity of NGEU funds, it would 
still lead to a significant impact (line 3)29. 

Table 1: QUEST simulation results (%-deviation of real GDP level from non-NGEU case, linear 
disbursement assumption over 6 years) 

Scenario 
Baseline 
   of which 
spillover 
Low 
productivity 

2021 

2022  2023  2024  2025  2026  2027 

2028 

2029  2030  2040 

1.6 

2.7 

2.7 

2.8 

3.0 

3.3 

2.3 

1.5 

1.7 

1.8 

1.2 

0.3 

0.4 

0.3 

0.3 

0.3 

0.3 

0.3 

0.2 

0.2 

0.1 

0.0 

1.4 

2.3 

2.1 

2.0 

2.1 

2.1 

1.1 

0.2 

0.4 

0.6 

0.5 

This stylised scenario does not include the possible positive impact of structural reforms, which 
can be substantial. A model-based benchmarking exercise shows that undertaking structural reforms 
that  would  result  in  halving  the  gap  vis-à-vis  best  performers  in  terms  of  indicators  of  structural 
reforms  could  raise  Greece  GDP  by  18%  in  20  years’  time,  more  than  the  11%  found  for  the  EU 
average, the difference reflecting the relatively larger gaps towards best performers in Greece30. 

Due  to  the  differences in  the  assumptions  and  methodology,  the  results  of  this  stylised  assessment 
cannot be directly compared to the numbers reported in chapter 4 of Greece’s RRP.  

The  plan  presents  a  detailed  analysis  of  the  overall  impact  of  the  proposed  reforms  and 
investments. In compliance with the guidance, it includes a macroeconomic and social outlook, 
which  is  followed  by  the  discussion  of  the  macroeconomic  and  social  impact  of  the  plan  as  a 
whole. The methodology of the macroeconomic  estimations is  described  in  detail,  both  for the 
estimations carried out by the Bank of Greece and for the one done by the Council of Economic 
Advisers. The document presents arguments on the sustainability of the planned investments and 
reforms,  but  it  does  not  elaborate  in  detail  on  the  aggregate  impact  on  social  and  territorial 
cohesion. The full impact is then compared to the investment baseline. 

Fostering economic growth and jobs 

The  plan  includes  a  wide  set  of  investments  and  reforms  that  contribute  to  economic 
growth and increasing employment. The growth stimulus provided by the measures financed 
by non-repayable financial support is estimated at over 1% of GDP already in 2021 which is an 
important contribution to the economic recovery in the aftermath of the pandemic. 

29 Technically, the low productivity scenario considers a significantly reduced output elasticity of public capital. 
30  Varga,  J,  in  't  Veld  J.  (2014),  “The  potential  growth  impact  of  structural  reforms  in  the  EU:  a  benchmarking 
exercise ", European Economy Economic Papers no. 541.  
http://ec.europa.eu/economy_finance/publications/economic_paper/2014/pdf/ecp541_en.pdf.  

54 

 
 
 
 
 
                                                           
Several  measures  aim  to  improve  productivity.  Even  before  the  pandemic,  Greece’s  growth 
performance  had  been  anaemic,  and  the  economy  was  facing  several  challenges  to  its  growth 
potential, which have been discussed in section 2.2 of this document. One of the main factors is 
the low productivity of Greek firms. Component 4.7 is expected to address several causes of this 
issue.  It  includes  actions  to  simplify  the  business  environment,  to  further  improve  the  ease  of 
doing  business  and  to  incentivise  productivity  growth  through  the  development  of  the  legal 
framework to facilitate the increase of average company size through mergers and acquisitions. 
Also,  the  plan  provides  important  financial  incentives  to  private  investment  under  the  loan 
facility, which the authorities expect to provide an additional percentage point increase in GDP 
growth already in 2021. These efforts are complemented by component 2.3, which is expected to 
improve the digitalisation of small and medium sized business and thus is expected to create a 
good  momentum  in  improving  productivity.  Finally,  component  4.5  provides  an  important 
contribution  through  the  promotion  of  research  and  innovation  through  strengthening  the 
relations  of  the  corporate  and  the  scientific  sectors  and  through  increased  public-private 
cooperation in research and development, including supporting of start-ups.  

Productivity is  also  expected  to improve by increasing the openness  of the economy, thus 
better  exploiting  Greece’s  comparative  advantages  and  exposing  the  economy  to  higher 
competition  thereby  incentivising  improvement  in  competitiveness.  Component  4.7  has 
elements that are expected to improve the extroversion of the economy through promoting larger 
company size, and component 4.6 takes important steps in this regard too. Recognising some of 
Greece’s  most  characteristic  industries:  tourism,  culture  and  agri-food,  it  promotes  important 
infrastructural  and  skill  upgrades  in  these  sectors  which  could  lead  to  increased  and  more 
diversified  added  value  from  these  sectors.  The  same  component  is  also  expected  to  improve 
trade  facilitation  and  includes  various  reforms  aiming  to  increase  investment  in  smart 
technologies in manufacturing, which could be key for productivity enhancement. 

The  plan  contains  measures  to  improve  public  investment  management.  Greece  has  been 
suffering  from  lack  of  planning  and  monitoring  system  for  implementing  large  infrastructure 
projects.  This  challenge  is  addressed  by  component  4.2  which  aims  to  speed  up  the 
implementation  of  public  investment  projects  through  enhancing  the  policy  and  planning 
coordination, and modernising public administration, procurement, and accrual accounting while 
also  strengthening  the  anti-corruption  framework.  These  are  expected  to  be  instrumental  in 
delivering all the public investments described in the plan in a timely and efficient manner. 

Important  steps  are  taken  to  improve  the  tax  administration  and  the  efficiency  of  the 
judicial system. High tax burden, tax compliance, red tape, regulatory burden and slow justice 
system  have  also  been  long-standing  challenges  for  potential  growth.  While  the  Recovery  and 
Resilience Facility cannot be used directly to reduce taxes, the plan submitted by the authorities 
includes reforms that pave the way towards a more efficient tax system through the reduction of 
tax  evasion,  spearheaded  through  the  digital  transformation  of  the  Independent  Authority  for 
Public  Revenue,  which  could  also  allow  for  creating  a  more  growth-friendly  tax  environment 
later on. In particular, component 4.1 introduces a set of wide-ranging reforms and investments 
that  are  expected  to  improve  tax  administration  and  collection  through  digitalisation  and 

55 

 
 
simplification  of  the  tax  legislation.  This  component  has  synergies  with  component  2.3  which 
promotes  the  digitalisation  of  businesses  which  will  facilitate  the  digitalisation  of  the  tax 
collection  and  oversight.  Component  4.2  includes  initiatives  that  reduce  administrative  and 
regulatory burden, while continuing the efforts to modernise the public administration. The plan 
also includes an ambitious agenda to improve the quality and the efficiency of the justice system. 
Component  4.3  is  expected  to  continue  the  digitalisation  of  judicial  procedures  and  foresees  a 
revision of the judicial map for administrative, civil and criminal courts to align it with the needs 
of the 21st century. This is accompanied by an upgrade the existing infrastructure and measures 
to improve the skills of judges and judicial staff and to accelerate justice administration. 

A  new  and  cheaper  pool  of  financing  will  become  available  for  Greek  firms.  The  Loan 
Facility (component 4.7) addresses the lack of available and affordable financing. Greek banks 
still face high non-performing loan ratios and other constraints, which limit their lending activity 
and increase the lending rates. The Loan Facility is expected to make financing both cheaper and 
more available. The amounts of the Recovery and Resilience Facility loans are passed on to the 
private  sector  principally  through  on-lending  via  international  financial  institutions  and 
commercial  banks.  By  passing  on  the  favorable  lending  rates  of  the  loans  of  the  Facility,  the 
average  interest  charged  to  companies  will  be  lower,  and  by  sharing  the  expected  losses  with 
banks and lending institutions, the availability of financing will increase. The participation of the 
beneficiary  with  a  small  amount  of  the  total  investment,  ensures  the  appropriate  incentive 
structure among all parties, mitigating any moral hazard concerns. This Loan Facility is expected 
to  provide  significant  boost  to  private  investments  with  a  focus  on  green  transition  and  digital 
transformation.  According  to  the  authorities'  estimation,  it  will  provide  larger  growth  stimulus 
than the investments financed through non-repayable financial support. The actual growth impact 
will crucially depend on the take-up rate of these loans, and also on the possible crowding out of 
bank lending. 

Beyond the measures directly addressing the challenges identified in section 2.2, and which 
are  mostly  covered  under  the  investments  and  reforms  of  the  fourth  pillar,  the  recovery 
and  resilience  plan  proposes  several  measures  that  are  conducive  to  growth  and 
employment.  Investments  under  pillar  one,  the  green  transition,  promote  growth  and 
productivity  through  cheaper  and  more  sustainable  energy  and  through  better  management  of 
natural  resources.  This  includes  the  reform  of  renewable  energy  sources,  the  renovation  of 
residential  buildings,  and  a  horizontal  scheme  to  support  industrial  units  being  established  to 
support  the  low-carbon  economy.  The  measures  under  pillar  two,  the  digital  transformation, 
generate the conditions for a number of other reforms to be more effective and efficient for both 
the  public  and  the  private  sector.  Measures  under  pillar  three,  employment,  skills  and  social 
cohesion,  aim  to  ensure  that  the  recovery  and  the  development  going  forward  happens  in  an 
inclusive manner. 

The Greek authorities have provided an estimation of the direct growth impact of the plan 
for  each  measure.  This  quantification  was  done  by  a  static  input-output  model,  excluding 
endogenous effects on total factor productivity and assigning little or no impact of reforms. This 
quantification  was  done  by  the  Centre  of  Planning  and  Economic  Research  (KEPE).  As  the 

56 

 
 
authorities  point  out,  these  calculations  should  be  treated  with  caution,  and  should  not  be 
considered  to  reflect  the  aggregate  impact  of  the  plan  which  was  estimated  by  the  Bank  of 
Greece.  The  calculations are nevertheless useful  in  showing the direct  impact  of each measure 
and the relative impulse of the different pillars. Based on the results, the measures under pillars 
one and four are expected to have the larger direct economic impact both in terms of GDP and 
employment,  while  the  measures  under  pillar  two  are  expected  to  have  the  smallest  direct 
economic impact. These impacts are broadly proportional to the cost allocation to the different 
pillars. On a measure level, KEPE’s estimation assigns positive growth and employment impacts 
to 140 measures out of the 167 measures included in the analysis. 

The investments foreseen under the recovery  and resilience plan are expected to increase 
public  investment  substantially.  Public  investment  in  Greece  has  been  low  since  the  global 
financial crisis. While public investment between 1995 and 2009 had been hovering around 5% 
of  GDP,  it  has  dropped  to  an  average  of  3%  between  2010  and  2020.  This  drop  is  to  a  large 
extent explained by the reduced national spending on investments due to  budgetary constraints 
and  to  the  low  absorption  rate  of  the  EU  structural  funds  in  the  early  years  of  the  2014-2020 
programming  period.  According  to  the  Commission’s  2020  autumn  forecast,  which  did  not 
include  the  investments  under  the  Recovery  and  Resilience  Facility,  public  investment  would 
have reached 4% of GDP in 2021-2022. Based on the analysis included in Table 4b of the plan, 
growth  enhancing  expenditure  as  a  share  of  GDP  would  be  on  average  1.6  percentage  points 
higher  due  to  the  measures  financed  through  non-repayable  financial  support  of  the  Recovery 
and  Resilience  Facility  compared  to  the  baseline.  This  is  broadly  in  line  with  the  additional 
impact assumed by the Commission’s 2021 spring forecast, which expects public investments to 
reach 5% of GDP in 2021 and 6% in 2022. 

Strengthening social cohesion 

The scars on employment caused by the global financial crisis had not been healed before 
the  current  pandemic  crisis.  Employment  and  participation  levels  have  been  low,  and 
unemployment  is  still  the  highest  in  the  EU  despite  its  downward  trend  since  2013.  Youth 
unemployment and long-term unemployment have been particularly and persistently high, which 
is detrimental to social cohesion. 

The  recovery  and  resilience  plan  presents  a  comprehensive  set  of  measures  to  address 
labour  market  deficiencies  and  to  improve  social  cohesion.  These  policies  include 
investments  in  human  capital,  activation  policies  and  social  services,  fighting  inequalities, 
modernising  the  labour  market,  and  increasing  social  inclusion.  The  plan  provides  a  detailed 
mapping  of  selected  interventions  to  address  the  vulnerabilities  identified  by  the  Social 
Scoreboard. According to the estimation of the plan, the implementation of all its measures could 
lead to 180 000 – 200 000 new permanent jobs. 

Measures under the  third pillar of the plan provide the backbone of  strengthening social 
cohesion  and  contribute  to  the  European  Pillar  of  Social  Rights  by  improving  several 
labour market and social indicators. The measures of component 3.1 aim to build capacities of 
employment  and  social  structures,  strengthen  institutions  and  reduce  vulnerabilities  to  shocks 

57 

 
 
to  remove  disincentives 

to  participation  are  conducive 

through  a  thorough  revision  of  the  labour  code,  and  improvements  in  public  administration 
efficiency  (digitalisation  of  employment  and  social  security  systems  and  better  labour  market 
monitoring).  The  investments  in  active  labour  market  policies  and  reforms  of  passive  labour 
to  reducing 
market  policies 
unemployment  and  increasing  employment.  They  include  programmes  of  hiring  incentives 
combined  with  upskilling,  designed  in  line  with  the  Commission  Recommendation  on  an 
effective active support to employment following the COVID-19 crisis (EASE). Component 3.2 
improves  the  quality  of  human  capital  through  increased  spending  on  education,  training, 
reskilling, and upskilling alongside a reform of the life-long learning system. This is expected to 
address  another  long-standing  vulnerability  of  the  Greek  economy:  skill  mismatches  which 
contribute  to  long-term  unemployment.  Component  3.4  promotes  labour  market  integration  of 
vulnerable  groups  such  as  persons  with  disabilities  refugees  and  Roma.  It  also  improves 
availability of early childhood education and care and access to effective social policies through 
digital transformation of the social protection system and development of social services, notably 
for vulnerable children and for persons with disabilities.  

Box  3  Employment  and  social  challenges  in  light  of  the  Social  Scoreboard  accompanying  the 
European Pillar of Social Rights 

The  Social  Scoreboard  supporting  the  European Pillar  of  Social  Rights  points to  a  number of 
employment and social challenges in Greece.  The COVID-19 crisis has halted the positive labour 
market developments observed in the past years and risks leading to an increase in the share of people 
at risk of poverty or social exclusion (AROPE). The unemployment rate, at 15.8% in December 2020, 
is  far  above  the  EU  average  (7.5%  at  the  same  point  in  time).  The  share  of  long-term  unemployed 
remains  extremely  high  in  Greece  (66.4%  in  Q4  2020).  The  overall  employment  rate  remains  the 
lowest in the EU at 61.5% in Q4 2020 and the employment rate of women is about 18 pps below that 
of men. This very large gender employment gap is only partly attributable to caring responsibilities of 
women. A remarkable increase has been observed in childcare enrolment rates in recent years, with 
32.4% of children aged less than 3 years in formal childcare in 2019 compared to 20.5% in 2017.  

58 

 
 
The employment situation of young people 
in  Greece  is  critical.  Despite  a  continued 
decline  in  recent  years,  the  share  of  young 
in  education, 
people  aged  15-29  not 
employment  or  training  (NEET)  remained 
among  the  highest  in  the  EU  and  has 
significantly  worsened  in  the  current  crisis 
(19.1% in Q4 2020). Of particular concern is 
the  situation  for  the  25-29  age  group,  for 
which the NEET rate in 2020 was double the 
one for the 15-24 age group.  

While  poverty  has  been 
gradually 
decreasing  in  the  years  before  the  crisis, 
the  pandemic  may  reverse  this  trend.  In 
2019, the at risk of poverty or social inclusion 
rate was among the highest in the EU at 30%, 
well  above  the  EU  average  (20.9%).  The 
transfers  on  poverty 
impact  of  social 
reduction,  at  22.8%,  is  much  below  the  EU 
average (32.4% in the EU).  

The recovery and resilience plan submitted 
by  Greece  addresses  a  multitude  of 
employment and social challenges relevant 
for  the  implementation  of  the  Pillar.  To 
foster  equal  opportunities  and  access  to  the 
labour  market,  the  plan  envisages  a  new 
strategy 
a 
modernisation of the upskilling and reskilling 
system.  The  reform  would  redesign  and  upgrade  the  current  fragmented  programmes,  establishing 
new  curricula  linked  to  labour  market  needs  and  an  assessment  framework  for  the  providers  of 
upskilling  programmes.  Investments  to  further  upgrading  vocational  education  and  training  are  also 
envisaged. To improve labour market dynamics and working conditions, Greece also plans a labour 
law  reform  aimed  at  improving  the  labour  market  functioning  and  significant  investments  in  wage 
subsidies  and  upskilling/reskilling  programmes  that  will  complement  activation  programmes 
supported  by  the  European  Social  Fund.  Reforms  improving  incentives  to  work  and  investments  in 
enhancing the public employment services are also foreseen. However, the structural reform needed to 
ensure  timely  and  tailored  delivery  of  active  labour  market  policies  to  jobseekers  nationwide  is  not 
sufficiently addressed.  

learning 

lifelong 

and 

for 

With more people likely to fall back on the basic safety nets due to the COVID-19 crisis, reforms 
on  social  protection  and  inclusion  are  important  in  order  to  provide  much  needed  support,  in 
synergy with European Social Fund funding. The plan includes a multitude of interventions in the 
social  area  aimed,  inter  alia,  at  expanding  access  to  early  childhood  education  and  care, 
deinstitutionalization  of  children  and  adolescents,  support  to  persons  with  disabilities  and  the  labour 

59 

 
 
market integration of vulnerable groups. Nonetheless, while relevant to address the investment needs 
related  to  social  inclusion,  the  interventions  lack  an  overall  framework  for  strengthening  access  to 
social  services,  including  housing.  Finally,  the  plan  includes  measures  aimed  at  reforming  and 
expanding primary health care and investing in the digitalisation of health services. These measures are 
important  to  help  further  reduce  the  still  high  self-reported  unmet  needs  for  medical  care  (8.1% 
compared to 1.7% in the EU in 2019). 

Reducing vulnerability and increasing resilience 

Several  measures  and  components  aim  to  reduce  the  country’s  vulnerabilities  and  to 
increase  its  capacity  to  absorb  shocks.  The  main  vulnerabilities  identified  by  the 
Macroeconomic Imbalances Procedure are: 1) high public debt, 2) high ratio of non-performing 
loans in the banking sector, 3) high stock of external liabilities, 4) low activity and employment 
rates and high unemployment especially among the  young, and 5) low growth potential. These 
vulnerabilities typically have inertia, and correcting them requires considerable amount of time. 
The  common  feature  of  these  imbalances  is  that  their  correction  requires  improving  growth 
potential and employment in a sustainable and inclusive manner. Most of the measures discussed 
in the previous two sub-sections are therefore highly relevant here too.  

The  capacity  to  withstand  shocks  crucially  depends  on  at  least  four  factors.  First, 
sufficiently flexible labour market complemented with well targeted and effective social safety 
net  is  necessary  to  limit  damages  to  employment  in  case  of  a  negative  shock.  Second,  fiscal 
policy  should  be  in  a  position  to  act  counter-cyclically,  allowing  the  automatic  stabilisers  to 
operate  freely,  while  safeguarding  sustainability  of  public  finances.  Third,  the  public 
administration  should  have  the  capacity  to  implement  coordinated  policy  responses  in  time  of 
need,  and  to  be  a  helpful  partner  of  the  private  sector  in  normal  times  too.  Finally,  a  well-
functioning financial market plays a crucial role in both preventing crises and in mitigating their 
impacts by avoiding financial acceleration.  

The  planned  reforms  in  the  labour  market  are  expected  to  improve  its  resilience.  As 
discussed above, the modernisation of the labour code under component 3.1 is expected to bring 
a  structural  reform  of  individual  labour  law,  collective  labour  law,  trade  union  law,  and  of 
monitoring  systems.  Under  the  same  component,  sizeable  investments  in  active  labour  market 
policies,  including  reskilling  and  upskilling  as  well  as  hiring  incentives,  accompanied  by 
enhancement of the public employment service will help reduce unemployment. Passive labour 
market policies will be redesigned to provide better incentives to return to work. Labour market 
resilience  is  also  expected  to  be  strengthened  by  further  reforms  and  investments  that  promote 
and support lifelong learning (component 4.3 and 3.2), vocational training (component 3.2) and 
other types of education (component 3.4). 

Further strengthening of the tax and public administration are expected to support a more 
resilient economy. Over the medium and long term, reducing tax evasion and creating a fair and 
growth-friendly  tax  environment  can  be  beneficial  to  provide  fiscal  space  for  necessary  policy 
interventions. Component 4.1 improves revenue collection and administration through incentives 
to  increase  electronic  transactions  and  through  the  digitalisation  and  automatisation  of  VAT 
refunds.  Furthermore,  there  are  several  sub-projects  that  increase  the  capacities  of  the 

60 

 
 
Independent  Authority  of  Public  Revenue,  which  shall  be  instrumental  in  fighting  tax  evasion. 
More  broadly,  there  are  several  measures  that  improve  public  administration  in  general,  for 
example reforms under component 4.2, which is the principal component of modernising public 
administration, but also under component 2.2 by making the public administration more digital, 
and  better  enabled  to  react  quickly  to  shocks,  by  quicker  reaction  trough  more  efficient  and 
digital processes and closer and more direct connection to citizens and businesses. 

The  plan  includes  a  number  of  reforms  to  strengthen  the  financial  sector  and  capital 
markets  Measures  aim  to  upgrade  the  necessary  digital  infrastructure  needed  to  support  the 
recently adopted insolvency framework that entered into force on 1 June 2021 and was assessed 
under  enhanced  surveillance.  Reforms  under  component  4.4  include  an  improved  monitoring 
registry for private debt, the development of a public credit bureau, a central credit register, and a 
credit  expansion  observatory.  These  are  all  beneficial  in  reducing  asymmetric  information 
between  public  entities,  financial  institutions,  households  and  businesses,  which  may  lead  to  a 
more  efficient  allocation  of  credit,  through  the  reduction  of  risk  premia,  as  well  as  facilitate 
further  growth  in  the  secondary  market  for  non-performing  loans.  The  capital  markets  are 
expected  to  be  strengthened  through  the  codification  and  modernisation  of  the  regulatory  and 
legislative  framework  for  capital  markets  and  the  digitalisation  of  the  internal  processes  and 
organization  of  the  Hellenic  Capital  Market  Commission.  These  efforts  aim  to  provide  a  more 
robust  regulatory  framework  for  the  capital  markets,  which  could  then  complement  bank 
financing. The Loan Facility proposed in the recovery and resilience plan is also expected to help 
both  the  financial  sector  through  risk  sharing  and  the  corporate  sector  by  providing  cheaper 
financing, which may improve the resilience of the economy as a whole. 

Resilience is also expected to be improved through investments in and measures supporting 
the health care system. The health care system in Greece currently has a number of structural 
problems including supplier-induced demand, lack of family doctors, insufficiently means-tested 
co-payments  and  limited  investments,  reflected  in  continually  increasing  public  health-care 
spending. Component 3.3 sets out to remedy some of the current deficiencies. Health-care costs 
and  their  monitoring  are  expected  to  be  rationalised  including  through  digitalisation  and  by 
implementing an organisational  reform  of the health care system  establishing an activity-based 
reimbursement  system  and  a  quality  assessment  framework.  Health  infrastructure  will  be 
upgraded  through  much-needed  investments,  and  providers  will  be  incentivised  to  carry  out 
R&D,  as  part  of  the  clawbacks  will  be  eligible  for  writing-off  against  R&D  expenditure.  The 
measures  to  strengthen  primary  health  care  and  the  creation  of  a  national  public  health 
prevention  strategy  can  contribute  to  the  general  improvement  of  the  health  state  of  the 
population and to increasing the efficiency and the sustainability and resilience of the health care 
system. 

Cohesion and convergence 

The  recovery  and  resilience  plan  is  expected  to  contribute  to  enhancing  economic,  social 
and  territorial  cohesion  and  convergence.  There  are  currently  considerable  economic,  social 
and  territorial  disparities  in  Greece.  The  problems  of  high  unemployment  and  the  resulting 
poverty  (especially  among  children  and  working-age  population)  persist  despite  improvements 

61 

 
 
brought  about  by  economic  recovery  prior  to  the  COVID-19  crisis  and  social  welfare  reforms 
including,  most  notably,  the  introduction  of  the  guaranteed  minimum  income  reform  in  2017. 
Economic disparities often translate to regional disparities as rural areas have typically moderate 
employment possibilities to offer. 

A  broad  set  of  growth-enhancing  measures  are  expected  to  deliver  growth,  thereby 
reducing  economic  disparities.  The  most  effective  policy  to  fight  against  poverty  is  to  create 
economic growth and permanent jobs. As discussed in previous subsections, the plan includes a 
wide range of measures that are expected to help kick-start the economy. Within these measures, 
the  ones  that  aim  to  support  small  and  medium  sized  enterprises  are  particularly  relevant  for 
reducing economic disparities. The simplification of business and tax administration (component 
4.1),  the  improvement  of  the  financial  markets  (component  4.4),  the  upskilling  of  cultural 
professionals,  the  development  of  tourism  (component  4.6)  and  improvement  of  the  business 
environment (component 4.7) are all expected to contribute to providing a better ground to grow 
for  smaller  enterprises  which  in  turn  can  generate  growth  in  the  underprivileged  parts  of  the 
population where these enterprises might operate.  

Most  of  the  measures  under  the  third  pillar  of  the  plan  are  expected  to  improve  social 
cohesion  and  reduce  poverty  and  inequalities.  The  labour  market  reforms  and  active  labour 
market policies under component 3.1 will be instrumental in this regard. The Plan also envisages 
investment  in  human  capital  and  skills  in  particular,  by  upgrading  education,  vocational 
education  and  training  and  life-long  learning  systems  under  component  3.2.  In  addition,  the 
public  health  prevention  programme  is  expected  to  help  in  improving  the  overall  health  of  the 
labour force. Finally, component 3.4 will improve access to social services and promote labour 
market integration of vulnerable groups, including refugees. Measures such as expanding early 
childhood education and care, child protection, diversity awareness, and support to persons with 
disabilities are all steps towards a more inclusive society of equal opportunities.  

The  plan  addresses  regional  disparities  primarily  through  investments  in  transportation 
infrastructure and programmes to develop tourism and the cultural sector. Greece’s current 
domestic transportation system faces a number of challenges, whereas the country’s geographical 
features  would  call  for  a  well-functioning  and  affordable  transport  network  in  order  to  reduce 
regional  disparities.  One  of  the  main  objectives  of  component  4.6  is  the  improvement  of  the 
transportation infrastructure. Measures include building of new highways, road safety upgrades, 
the development of the railway system, the upgrade of regional ports and the certification of 13 
regional  airports  with  the  European  Union  Aviation  Safety  Agency  (EASA)  compliance 
program. Further measures under this component aim to promote culture, tourism and agriculture 
as  engines  of  regional  growth.  Interventions  under  other  components  contribute  to  reducing 
regional  disparities  too:  the  revitalisation  of  territories  affected  by  the  termination  of  lignite 
mines  and  the  improvement  of  interconnections  should  provide  more  stable  and  affordable 
electricity for the islands, thus enhancing their potential as tourist destinations (component 1.1), 
the  establishment  of  a  strategic  National  Disaster  Management  system  (component  1.4),  the 
digital transformation of the health care sector (component 3.3). 

62 

 
 
Conclusion 

Taking  into  consideration  all  reforms  and  investments  envisaged  by  Greece,  its  recovery  and 
resilience  plan  is  expected  to  have  a  high  impact  on  strengthening  the  growth  potential,  job 
creation, and economic, social and institutional resilience of the Member State, on contributing 
to the implementation of the European Pillar of Social Rights, including through the promotion 
of  policies  for  children  and  youth,  and  on  mitigating  the  economic  and  social  impact  of  the 
COVID-19  crisis,  thereby  enhancing  the  economic,  social  and  territorial  cohesion  and 
convergence within the Union. This would warrant a rating of A under the assessment criterion 
2.3 of Annex V to the RRF Regulation. 

4.4. The principle of ‘do no significant harm’  

The RRF Regulation provides that no measure included in the recovery and resilience plan 
should  lead  to  significant  harm  to  any  of  the  six  environmental  objectives  within  the 
meaning of Article 17 of the Taxonomy Regulation31. In line with the RRF Regulation and the 
Technical  Guidance  on  the  Application  of  ‘do  no  significant  harm’32  (‘DNSH  Technical 
Guidance’),  Member  States  provide  a  ‘do  no  significant  harm’  (DNSH)  assessment,  on  which 
basis  the  Commission  assesses  whether  each  and  every  measure  (i.e.  each  reform  and  each 
investment)  included  in  the  plans  complies  with  DNSH.  DNSH  compliance  is  therefore  a 
necessary  condition  for  the  Commission  to  positively  assess  the  recovery  and  resilience  plan. 
Greece  has  included  a  DNSH  assessment  for  each  measure  included  in  its  plan  in  accordance 
with the template provided by the Commission, and in line with the DNSH Technical Guidance. 
The  Commission  has  assessed  whether  and  how  each  measure  in  Greece’s  plan  complies  with 
DNSH on that basis. 

The  Greek  plan  is  expected  to  ensure  that  no  significant  harm  is  done  to  environmental 
objectives  by  only  selecting  or  designing  measures  complying  with  DNSH.  By  selecting 
measures  that  either  contribute  substantially  to  environmental  objectives,  such  as  those  on 
reforestation,  or  have  no  or  an  insignificant  foreseeable  impact  on  environmental  objectives 
(such  as  those  on  labour  market,  social  policy,  or  public  administration),  many  measures  in 
Greece’s plan can be considered DNSH compliant from the outset. Other measures are designed 
to  ensure compliance with  DNSH, directly or by requiring  specific evidence and commitments 
through  milestones  and  targets  to  substantiate  that  they  will  not  lead  to  significant  harm  to 
environmental objectives. A summary of the most relevant issues is included below. 

DNSH-compliant  measures  facilitate  the  green  transition.  The  self-assessment  clarified 
compliance, in particular for investments in energy networks in component 1.1, where submarine 

31  The  six  environmental  objectives  comprise  (1)  climate  change  mitigation,  (2)  climate  change  adaptation,  (3) 
sustainable use and protection of water and marine resources, (4) the circular economy, (5) pollution prevention and 
control, and (6) protection and restoration of biodiversity and ecosystems. 
32 2021/C58/01. 

63 

 
 
                                                           
cables will be laid or the distribution network will be upgraded. The latter measure in particular 
is  meant  to  better  protect  the  environment,  for  example  by  putting  underground  cables  which 
currently  pass  through  forest  areas.  For  the  renovation  of  residential  and  public  buildings  in 
component 1.2 (as well as in pillar 3 for measures on healthcare and childcare) the respect of the 
principle  will  be  ensured  through  compliance  with  the  minimum  requirements  in  the  Energy 
Performance  of  Buildings  Directive,  and  respecting  the  circular  economy  principles  when  it 
comes to construction waste. This means in particular that 70% of the construction waste will be 
recycled.  Reforms  such  as  the  establishment  of  a  new  marine  spatial  planning  framework  are 
also  meant  to  directly  protect  the  marine  environment  and  biodiversity.  In  component  1.3, 
investment  in  public transportation vehicles has  been limited to  electric  vehicles, while for the 
development  of  a  “first  of  its  kind”  CO2  geological  storage  facility  in  Greece,  the  authorities 
have thoroughly analysed the possible environmental implications, also excluding the possibility 
that  technologies,  facilities  or  equipment  engineered  towards  enhanced  oil  recovery  are  used, 
ensuring  that  any  possible  extraction  of  oil  or  gas  is  limited  to  the  indispensable  needs  of 
managing pressure and ensuring safety of the storage sites. For irrigation, flood mitigation and 
water measures included in component 1.4, compliance with the DNSH principle will be ensured 
inter  alia  by  requiring  that  any  work  regarding  dams  is  in  line  with  the  Water  Framework 
Directive,  ensuring among others that new  extraction is  only allowed if  the status  of the water 
body  is  in  good  status  and  will  remain  so,  also  taking  into  account  the  projected  impacts  of 
climate change based on best science. In the same component, compliance of the purchase and 
upgrade of special purpose vehicles for civil protection and firefighting with DNSH is ensured 
by such vehicles being “best-in-class” from the environmental performance point of view.  

Measures included in pillar 2 (digital) or pillar 4 (investment) were also designed to ensure 
respect  with  the  DNSH  principle.  The  laying  of  fibre  submarine  cables  to  interconnect 
mainland  Greece  with  its  islands  and  with  Cyprus  will  be  subject  to  an  environmental  impact 
assessment, while investment in cloud computing will focus on energy efficient equipment. The 
investments  in  motorways  in  pillar  4  are  accompanied  by  flanking  measures,  such  as, 
investments  in  alternative  fuels  infrastructure  (8 000  charging  stations),  a  major  road  safety 
programme with interventions in more than 7 000 dangerous locations, road access reforms (such 
as electronic tolling), measures supporting the shift towards electric vehicles including buses and 
taxis,  a  reform  of  the  railway  sector  to  support  switching  from  road  to  rail,  and  railway 
investments in the TEN-T core network and suburban rail. Interventions in the rail infrastructure, 
including projects on the TEN-T core network and on suburban rail, are also meant to modernise 
and  electrify  the  network.  In  component  4.3,  for  the  construction  of  new  judicial  buildings 
compliance with the criteria defining near-zero energy buildings will be required. 

The  plan  also  includes  measures  of  a  horizontal  nature,  which  are  designed  to  be  DNSH 
compliant.  As  set  out  in  the  DNSH  Technical  Guidance,  measures  of  a  more  general  nature, 
such  as  broad  industry  support  schemes  (e.g.  financial  instruments  covering  investments  in 
companies  across  multiple  sectors),  should  be  designed  to  ensure  adherence  of  the  relevant 
investments with DNSH. The plan contains such broad measures, such as the use of RRF loans 
to  provide  loan  and  equity  funding  to  companies,  or  measures  to  support  the  development  of 
innovative products and services. For these – as for other more specific measures – Greece will, 

64 

 
 
inter alia, apply selection criteria that are based on an exclusion list that excludes from support 
investments  related  to  fossil  fuels,  activities  under  the  ETS  with  projected  CO2  equivalent 
emissions  that  are  not  substantially  lower  than  the  relevant  benchmarks  established  for  free 
allocation, investments in facilities for the disposal of waste in landfill, in mechanical biological 
treatment  (MBT)  plants,  and  incinerators  for  the  treatment  of  waste,  and  activities  where  the 
long-term  disposal  of  waste  may  cause  long-term  harm  to  the  environment.  Through  this 
approach, Greece ensures that the broad measures included in the plan are DNSH compliant. 

Conclusion  

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  no  measure  for  the 
implementation of reforms and investments projects included in Greece’s recovery and resilience 
plan  is  expected  to  do  a  significant  harm  to  environmental  objectives  within  the  meaning  of 
Article  17  of  Regulation  (EU)  No  2020/852  (the  principle  of  ‘do  no  significant  harm’).  This 
would warrant a rating of A under the assessment criterion 2.4 of Annex V to the Recovery and 
Resilience Facility Regulation. 

4.5. Green transition  

This  section  assesses  to  what  extent  the  proposed  measures  fulfil  the  elements 
corresponding  to  assessment  criterion  2.5  of  Annex  V  to  the  RRF  Regulation.  The 
assessment focuses in particular on whether the climate tracking methodology from Annex VI to 
the RRF Regulation has been applied correctly and the 37% target has been reached, while it also 
sets out the impact of the measures on the green transition, including biodiversity. 

Climate target 

Greece’s  recovery  and  resilience  plan  dedicates  EUR 11 428  million  to  the  climate 
objective, which represents 37.5 % of the plan’s total allocation in non-repayable financial 
support and loans. The investments financed by non-repayable financial support contribute by 
37.8 %  to  the  green  transition,  while  the  Loan  Facility  financed  through  the  loan  allocation 
contribute by 37.0 % to the climate objective. This exceeds the minimum climate target of 37% 
of the total allocation as set out in the Recovery and Resilience Facility Regulation and is based 
on a correct application of the methodology for climate tracking as set out in Annex VI to that 
Regulation, by identifying intervention fields, and corresponding coefficients for the calculation 
of support to climate change objectives. Greece’s plan does not use any uplifting or increase of 
certain climate coefficients for investments. 

The  main  pillar  contributing  to  climate  change  objectives  is  the  green  pillar,  which  is 
constituted of four components covering a total of 35 measures. The large majority of these 
measures contribute towards the climate change objective through a broad range of interventions, 
stretching from smart energy systems and renewable energy sources to cycling infrastructure and 
energy efficiency. 

Component 1.1, based on the ‘PowerUp’ flagship (overall estimated value: EUR 1.20 billion) 
includes a number of investments contributing towards the climate objective, such as the support 
for installation of storage systems to enhance renewable energy sources’ (RES) penetration. The 

65 

 
 
component also includes an important reform concerning the RES support scheme to producers 
that  aims  to  ensure  that  it  remains  viable.  Strong  emphasis  is  placed  on  electricity 
interconnections between the islands and the mainland, and in particular, the connection of the 
Cyclades Islands to the mainland’s grid. 

Component 1.2, based on the Renovation wave flagship (overall estimated value: EUR 2.71 
billion) covers significant investments in enhancing energy efficiency in Greece’s building stock, 
including a flagship investment in “Energy renovation of residential buildings” that is estimated 
at EUR 1.253 billion. The measures related to renovation and enhancing energy efficiency will 
result in  average primary  energy  savings or  greenhouse  gas  reduction of  30%. The component 
also  includes  an  important  reform  to  develop  urban  plans  in  order  to  set  a  comprehensive  and 
coherent  framework  for  urban  policy  and  the  relevant  planning  systems.  The  urban  plans  will 
include a dedicated chapter on adaptation measures at the municipal level to strengthen overall 
climate resilience. 

Component  1.3,  based  on  the  clean,  smart  and  fair  urban  mobility  flagship  (overall 
estimated  value:  EUR 520  million)  aims  to  make  urban  mobility  cleaner,  smarter,  safer  and 
fairer.  It  covers  measures  for  the  installation  of  more  than  8 000  charging  points  for  electric 
vehicles  and  replacement  of  2 000  taxis  and  220  public  transport  busses  with  battery  electric 
vehicles.  Further,  it  covers  the  development  of  Greece’s  first  Carbon  Capture,  Utilization  and 
Storage  Facility  (CCUS)  contributing  to  the  clean  energy  transition.  This  component  also 
contains key reforms, including revising the legislative framework for public urban and regional 
passenger transportation services and carrying out a feasibility study for the establishment of an 
electro-mobility agency. 

Component 1.4 (overall estimated value: EUR 1.76 billion) covers a range of measures related 
to  the  environmental  protection  ranging  from  reforestation  and  biodiversity  protection  to 
improving  the  irrigation  network  and  wastewater  management.  The  component  also  includes 
measures aiming to enhance the operational capabilities of Greece’s civil protection and disaster 
management systems in order to address climate related risks, such as floods and forest fires. 

The  second  pillar  (digital)  of  the  plan  also  contains  measures  contributing  towards  the 
climate objective. This pillar includes three components out of which component 2.2 aiming to 
modernise  and  enhance  the  digital  services  of  the  Greek  public  administration  contains  two 
measures  contributing  towards  the  climate  objective.  Both  measures  relate  to  the  supply  and 
upgrade of government cloud infrastructure and services and will follow the European Code of 
Conduct on Data Centre Energy Efficiency aiming to reduce energy consumption of data centres 
through applying best practices. 

The  third  pillar,  focusing  on  employment,  skills  and  social  cohesion,  contains  measures 
contributing towards the climate objective in three out of its four components. Components 
3.1  and  3.2  aiming  to  support  employment  and  strengthen  labour  force  upskilling  contain 
dedicated  funds  for  improving  green  skills  and  supporting  job  creation  in  the  green  economy. 
The  new  strategy  for  lifelong  skilling  includes  training  programmes  on  green  skills,  covering 
resource  efficiency,  low-carbon  industry,  climate  reliance  and  managing  natural  assets.  The 

66 

 
 
remaining  climate  related  measures  focus  on  energy  efficiency  renovations,  including 
infrastructure upgrades for hospitals under component 3.3. 

The  fourth  pillar,  covering  tax  policy,  private  investments  and  transformation  of  the 
economy, also includes a number of measures contributing towards the climate objective. 
In particular, the components “Modernise and improve resilience of key economic sectors” and 
“Improve  competitiveness  and  promote  private  investments  and  trade”  contain  significant 
investments  related  to  climate  change.  The  former  component  includes  measures  to  strengthen 
the  urban  and  national  rail  network  as  well  as  targeted  support  to  the  agricultural  sector  for 
climate  adaptation  measures.  The  latter  component  contains  a  Loan  Facility  for  EUR 12 728 
million that shall allocate at least 37% of its funds to activities supporting the climate transition, 
such  as  efficiency  and  demonstration  projects  for  the  private  sector  with  significant  energy 
savings or reduction of greenhouse gas emissions, new resources energy sources’ capacity (solar 
and wind) and smart energy systems. Finally, component 4.1 includes a reform introducing tax 
incentives  for  super-deduction  of  SME  expenses  on  green  and  digital  investments  and  is 
expected to increase investment for the green and digital transitions. 

Table 7 Climate contribution per component 

Component and name of the measure 

1.1. Power up 
1.2. Renovate 
1.3. Recharge and refuel 
1.4. Sustainable use of resources, climate 
resilience and environmental protection 
2.1. Connect 
2.2. Modernise 
2.3. Digitalisation of businesses 
3.1. Promote job creation and participation in 
the labour market 
3.2. Education, vocational education and 
training, and skills 
3.3. Improve resilience, accessibility and 
sustainability of healthcare 
3.4. Increase access to effective and inclusive 
social policies 
4.1. Making taxes more growth friendly and 
improving tax administration and tax 
collection 

Cost 
(EUR million) 

Climate 
contribution 
(EUR million) 

Climate 
contribution * 
(percentage) 

1 200.3 
2 711.5 
520.0 

1 762.7 

521.6 
1 280.6 
375.0 

776.3 

2 311.4 

1 485.7 

611.4 

187.2 

987.8 
2 532.5 
520.0 

1 065.1 

0.00 
63.2 
0.00 

100.00 

513.00 

204.7 

0.0 

0.0 

3.2% 
8.3% 
1.7% 

3.5% 

0.0% 
0.2% 
0.0% 

0.3% 

1.7% 

0.7% 

0.0% 

0.0% 

67 

 
 
0.0 

0.0% 

188.8 

4.2. Modernise the public administration, 
including through speeding up the 
implementation of public investments, 
improving the public procurement framework, 
capacity building measures and fighting 
corruption 
4.3. Improve the efficiency of the justice 
system 
4.4. Strengthen the financial sector and capital 
markets 
4.5. Promote research and innovation 
4.6. Modernise and improve resilience of key 
economic sectors 
4.7. Improve competitiveness and promote 
private investments and trade 
0.0% 
Technical assistance 
Total 
37.5% 
* Please note that the climate change contribution in percentage is calculated based on Greece’s total allocation of 
non-repayable financial support (EUR 17 769.9 million) and loans (EUR 12 727.54 million). 

40.0 
31 163.5 

0.00 
11 428.5 

12 733.7 

3 742.1 

4 709.6 

15.4% 

250.7 

443.6 

644.3 

50.00 

0.1% 

0.0% 

2.1% 

0.2% 

20.7 

0.00 

38.4 

Green transition  

The  recovery  and  resilience  plan  contributes  to  Greece’s  green  transition,  addresses  the 
related  challenges  and  is  overall  well  aligned  with  the  priorities  of  the  European  Green 
Deal and its 2030 climate target plan as well as the goal to make the EU climate-neutral by 
2050.  The  plan  contains  components  addressing  a  number  of  the  green  transition  areas  and 
making  contributions  to  achieving  those  goals.  On  clean  energy,  component  1.1  includes  both 
reforms  and  investments  aiming  to  increase  the  renewable  energy  sources  in  Greece’s  energy 
mix.  On  building  and  renovating,  sizeable  investments  are  planned  under  component  1.2  to 
improve  the  energy  efficiency  of  Greece’s  ageing  housing  stock,  complemented  by  actions 
targeting  energy  poor  households  as  well  as  reforms  and  investments  for  urban  plans 
development  and  interventions,  setting  a  framework  to  support  green  investments  and  enhance 
climate  resilience  of  cities.  On  sustainable  mobility,  component  1.3  includes  both  reforms  and 
investments aiming to improve urban public transport and enhance the infrastructure for electric 
vehicles. Component 1.4 includes measures to promote and support biodiversity as well, such as 
a  new  system  for  permanent  monitoring  of  species  and  habitat  types,  and  the  support  to  the 
reforestation of 16,500ha of degraded forest ecosystems, mainly through native species. Finally, 
on  sustainable  agriculture,  component  4.6  includes  a  measure  aiming  at  increasing  the  added 
value  of  agricultural  products,  promoting  innovation,  and  protecting  the  environment.  The  key 
objectives  of  the  measure  include  increasing  competitiveness,  with  a  greater  emphasis  on 
research,  technology,  and  digitisation,  improving  the  level  of  skills  in  the  rural/agricultural 
sector, improving the environmental profile of agricultural holdings and mitigating the effects of 
climate change. 

The  plan  is  in  line  with  the  strategic  priorities  of  Greece’s  National  Energy  and  Climate 
Plan (NECP) and its specific targets particularly Greece’s ambitious plan to decommission 

68 

 
 
its  lignite  plants,  while  it  also  addresses  to  a  large  extent  the  comments  raised  by  the 
Commission  as  part  of  the  assessment  of  Greece’s  NECP.  The  recovery  and  resilience  plan 
includes  reforms  and  investments  serving  all  five  dimensions  of  the  NECP  and  Greece’s 
ambitious  decarbonisation  goals  focusing  on  renewable  energy,  energy  efficiency  and  clean 
mobility.  Regarding  renewable  energy  sources,  the  plan  includes  investments  amounting  to 
additional  capacity  of  6.5  GW  by  2025.  This  equals  74%  of  the  set  target  by  2030  through 
frontloading investments and contributing towards achieving the increased 55% net greenhouse 
gas  emissions  reduction  target.  Further,  a  reform  promoting  RES  production  storage  and 
investments for storage, upgrading grids and to connect several non-interconnected islands with 
its 
the  mainland  are  significantly  contributing 
the 
interconnectivity  and  security  of  supply.  To  ensure 
decommissioning of existing lignite-fired power generation is met, the plan includes reforms and 
investments  aimed  at  completing  the  internal  energy  market.  This  entails  a  reform  for  the 
establishment of a market monitoring mechanism for the National Regulatory Authority (RAE) 
and  the  participation  of  demand-side  response  (DSR)  in  the  balancing  market  increasing 
completion  at  the  wholesale  level.  Further,  a  new  RES  licensing  simplification  reform  and  a 
maritime  spatial  planning  that  will  allow,  among  other,  for  energy  production  from  renewable 
sources in offshore and coastal areas, are also part of the plan. This reform is expected to further 
unlock  Greece’s  potential  on  offshore  and  facilitate  Greece’s  transition  from  lignite  to  cleaner 
energy sources, while respecting environmental protection, and in line with the European Green 
deal objectives. 

to  Greece’s  decarbonisation 

targets, 
timeline  of 

the  challenging 

Energy  efficiency  measures  are  also  a  priority  for  Greece  and  the  plan  dedicates  a 
significant  budget  to  energy  efficiency  measures.  In  the  NECP,  Greece  estimated  a  total 
planned budget for all energy efficiency measures of EUR 11 billion and the goals were assessed 
by  the  Commission  as  credible  but  not  sufficiently  ambitious 33.  In  line  with  the  ‘Renovation 
Wave’  Flagship,  the  Renovate  component  uses  EUR 2.19  billion  covering  a  part  of  the  NECP 
budget  and some of the  measures contained therein.  The plan proposes significant  support and 
additional funding for buildings renovation. At the same time, substantial amounts of additional 
public  funding  will  still  be  needed  to  mobilise  the  total  volume  of  investments  necessary  to 
deliver on the remaining of the energy savings required to achieve the objective set in the NECP 
and  the  long-term  renovation  strategy  for  2030.  Further,  as  the  Commission  pointed  out  in  its 
NECP  assessment,  energy  poverty  is  a  significant  problem  and  Greece  has  confirmed  its 
intentions to addressing it to a great extent over the next 10 years.  

Beyond  energy  efficiency,  the  recovery  and  resilience  plan  has  the  broader  objective  of 
promoting  the  green  transition  through  the  efficient  usage  of  natural  resources,  in 
particular through water and waste management and protection and restoration of natural 

33  Assessment  of  the  final  national  energy  and  climate  plan  of  Greece,  European  Commission  Staff  Working 
Document, Brussels, 14.10.2020 SWD(2020) 907 final, pages 9-10. 

69 

 
 
                                                           
environment.  In  doing  so,  the  recovery  and  resilience  plan  is  underpinned  by  a  number  of 
national plans beyond the NECP, including national waste management plan, reforestation plan, 
circular economy plan and biodiversity plan. On the environmental objectives as defined in the 
Taxonomy Regulation (EU 2020/852), the plan includes measures on climate change mitigation 
aiming  to  reduce  greenhouse  gas  emissions,  mainly  through  enhancing  energy  efficiency  of 
buildings.  Further,  the  plan  contains  a  measure  to  develop  Greece’s  first  carbon  capture, 
utilisation  and  storage  investment  by  developing  transportation  and  storage  on  CO2  into 
geological features. This will help with emissions of hard to abate sectors, while hydrogen could 
also be enabled with this measure, in line with the Union’s hydrogen strategy.  

Greece is a climate-vulnerable country, exposed to the impacts of climate change. The plan 
includes a number of measures related to climate change adaptation, including preparation 
of local urban plans aiming to facilitate urban renewal and make the cities more climate resilient. 
Further, investments in strengthening key electricity infrastructure, flood mitigation projects and 
emergency  response  address  concerns  around  forest  fires  and  extreme  weather  conditions  that 
could increase in coming years as the effects of climate change are becoming more evident. The 
plan contains measures on water supply and urban wastewater are linked with specific targets to 
reduce  water  leakage  and  energy  consumption,  thus  contributing  to  a  more  sustainable  use  of 
water resources. Finally, the plan covers a reforestation measure that is expected to contribute to 
an increase of the forest cover area by 16 500 ha, while species protection is expected to rise by 
8% and the overall quality of natural environment by 5%. 

The  plan  also  includes  measures  that  address  societal  and  economic  challenges  resulting 
from the green transition, particularly with Greece’s decommissioning plan in mind. These 
are measures that aim to strengthen labour force upskilling and lifelong skilling with a specific 
focus  on  improving  green  skills,  jobs  and  the  green  economy,  for  example,  through  training 
programmes  covering  resource  efficiency,  low-carbon  industry,  climate  reliance  and  managing 
natural  assets.  Taking  into  account  the  draft  Just  Development  Transition  Master  Plan  and  the 
draft  territorial  Just  Transition  Plans,  the  RRP  takes  into  account  the  need  to  ensure  a  just 
transition, in view of the phase-out of lignite, particularly in the areas of Western Macedonia and 
central Peloponnese (Megalopoli). Investments included in the plan, around the rehabilitation of 
industrial land, address partially the economic challenges of this transition in the most affected 
area, creating the basis for further development of green investments as announced in the draft 
Just Development Transition Master Plan.  

In line with Greece’s ambitious decommissioning plan, these measures should help Greece 
achieve  a  genuine  green  transition,  with  fundamental  changes  to  energy  production  and 
transport that should have a lasting impact. Such investments are necessary steps and provide 
the fundamental regulatory and infrastructure framework for a sustainable economy in line with 
Greece’s long term strategy. 

Conclusion 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  the  recovery  and 
resilience  plan  is  expected,  to  a  large  extent,  to  make  a  significant  contribution  to  the  green 

70 

 
 
transition or to address the challenges resulting from it and ensures that at least 37% of its total 
allocation contributes to the climate target. This would warrant a rating of A under criterion 2.5 
of Annex V to the RRF Regulation. 

4.6. Digital transition  

This section assesses whether and to which extent the proposed measures fulfil the elements 
corresponding to assessment criterion 2.6 of Annex V to the RRF Regulation. In particular, 
it  assesses  whether  the  methodology  for  digital  tagging  set  out  in  Annex  VII  to  the  RRF 
Regulation  has been  applied correctly and whether the measures in  the recovery and resilience 
plan that effectively contribute to the digital transition or to addressing the challenges resulting 
therefrom, account for an amount which represents at least 20 % of the plan’s total allocation.  

Digital tagging 

Greece’s recovery and resilience plan dedicates EUR 7 093 million to the digital transition, 
which  represents  23.3%  of  the  plan’s  total  allocation  in  non-repayable  financial  support 
and loans. The investments financed by non-repayable financial support contribute by 25.6% to 
the  digital  transition  while  the  Loan  Facility  financed  on  the  basis  of  the  loans  allocation 
contributes by at least 20% to the digital transition. This exceeds the minimum digital target of 
20 % of the total allocation as set out in the Recovery and Resilience Facility Regulation and is 
based on a correct application of the methodology for digital tagging set out in Annex VII to that 
Regulation, by identifying intervention fields and corresponding coefficients for the calculation 
of support to  digital  objectives. Greece’s plan does  not  use any uplifting or increase of certain 
digital coefficients for investments. 

is  pillar  2  on  ‘Digital 
The  main  pillar  contributing  to  the  digital  transition 
Transformation’,  whose  cost  estimation  is  worth  almost  EUR 2.2  billion  and  comprises  three 
components,  covering  a  total  of  32  measures.  All  the  measures  included  under  this  pillar 
contribute towards the digital transition through a broad range of interventions, stretching from 
measures aiming at enhancing connectivity to measures aimed at improving the digitalisation of 
public administration and businesses. 

The first component, component 2.1 ‘Connect’ (overall estimated value: EUR 521.6 million) 
contains  measures  that  aim  to  foster  and  facilitate  the  widespread  deployment  of  very  high 
capacity  networks,  including  5G  and  fibre,  and  the  development  of  a  constellation  of  small 
satellites  and  is  linked  to  the  European  flagship  ‘Connect’.  In  particular,  the  investments 
included under this component concern the installation of fibre optic infrastructure in buildings, 
the  development  of  5G  networks  covering  all  major  Greek  highways,  the  deployment  of 
submarine fibre cables to connect mainland with the Greek islands and Cyprus and the utilisation 
of space technologies and applications by developing a constellation of small-satellites that will 
support  secure  connectivity  services  coupled  with  multipurpose  applications  for  earth 
observation.  The  reforms  included  under  this  component  institute  a  framework  to  facilitate  the 
switch to fast broadband connections and the transition to 5G technology. Overall, all measures 
under this component significantly contribute to the digital transition.  

71 

 
 
The second component, 2.2. ‘Modernise’ (overall estimated value: EUR 1.3 billion), targets the 
digital  transformation  of  public  sector  entities  and  is  linked  to  the  European  flagship 
‘Modernise’. The measures included under this component aim in particular at modernising the 
public  administration  by  improving  its  operational  model  and  enabling  the  provision  of  high-
quality services to citizens and businesses, using as a catalyst to the improvement of the public 
administration’s digital performance. Reforms and investments target in particular: (a) the digital 
transformation  of  public  sector’s  organisations,  including  the  digitisation  of  archives  and 
enhanced digital  services;  (b) business process  improvements followed by  the incorporation of 
modern  IT  systems;  (c)  increased  interoperability  between  systems  and  data;  (d)  wide-ranging 
cybersecurity  and  data  governance  strategies  and  policies;  as  well  as  (e)  extended  use  of 
advanced technologies, such as cloud computing and big data. 

The third component, component 2.3 ‘Digitalisation of businesses’ (overall estimated value: 
EUR 375.0  million),  aims  to  boost  the  adoption  of  digital  technologies  by  businesses  (in 
particular SMEs) by tackling key challenges of digital inclusion, including the lack of awareness 
about the benefits of digitalisation and knowledge about how to adopt digital technologies. This 
support  is  in  particular  expected  to  help  these  businesses  to  adapt  to  new  challenges  and  take 
advantage  of  emerging  business  trends  through  the  creation  of  a  digital  business  ecosystem, 
promoting  the  digital  transformation  of  SMEs.  In  particular,  this  component  envisages  the 
establishment of a single digital marketplace that will provide advanced technologies´ products 
and services tailored for SMEs’ digital transformation and will be accessed both by SMEs and by 
the  suppliers  of  such  products  and  services.  The  component  also  aims  to  promote  the  use  of 
electronic payments and sales among SMEs, the upgrade of cash registers and the Point Of Sale 
ecosystem,  and  the  creation  of  industrial  data  platforms.  In  addition,  the  establishment  of  a 
central  supporting mechanism for SMEs is  envisaged, facilitating the provision of training and 
awareness programs so that they can make the most of the tools and services offered through the 
digital marketplace. Finally, the component envisages tax incentives on tangible and intangible 
assets to facilitate the digital transformation of SMEs, in synergy with those in component 4.1. 

Overall,  all  measures  contained  in  pillar  2  on  ‘Digital  Transformation’  significantly 
contribute  to  the  digital  transition  or  to  the  challenges  resulting  from  it  and,  on  this  basis, 
have been correctly associated with intervention fields with 100% digital coefficients. In addition 
to these measures, other measures under pillars 3 and 4, worth EUR 2.4 billion in total, are also 
considered to significantly contribute to the digital transition or to the challenges resulting from 
it and have been associated with intervention fields with 100% digital coefficients.  

Pillar 3 on ‘Employment, skills, and social cohesion’ comprises a number of measures, for a 
total  amount  of  EUR 1.5  billion,  which  are  expected  to  significantly  contribute  to  the  digital 
transition  and  is  linked  to  the  European  flagship  ‘Reskill  and  Upskill’.  For  instance,  the 
comprehensive  project  called  ‘A  New  Strategy  for  Lifelong  Skilling:  Modernising  and 
Upgrading Greece’s Upskilling and Reskilling System’ (overall estimated cost of EUR 1 billion), 
includes investment in digital skills training for 370 000 beneficiaries, with an estimated cost of 
EUR 690  million  notably  aiming  at  increasing  the  quality  of  upskilling  efforts  and  their 
relevance  with  labour  market,  including  by  placing  emphasis  on  the  digital  transition.  In 
addition, Pillar 3 also comprises measures envisaging the digital transformation (i) of education 

72 

 
 
(estimated  cost  EUR 365  million),  (ii)  of  the  health  care  system  (estimated  cost  EUR 278 
million),  (iii)  of  labour  systems  (estimated  cost  EUR 77  million),  (iv)  of  the  immigration  and 
asylum system (estimated cost  EUR 42 million) (v)  of the public employment service (OAED) 
(estimated cost EUR 17 million), and (vi) of the social support system (estimated cost EUR 12 
million).  

Pillar 4 on ‘Private investment and transformation of the economy’ also includes a number 
of  measures,  with  an  estimated  cost  of  EUR 890  million,  which  are  expected  to  significantly 
contribute to  the digital  transition.  These include in  particular the digitalisation of the Tax and 
Customs  Administration  (estimated  cost  EUR 180  million),  (ii)  the  transformation  of  fiscal 
management  and  supervision  in  governance  &  electronic  invoicing  (estimated  cost  EUR 102 
million),  (iii)  the  ‘electronic  tools’  project,  the  ‘smart  bridges’  project  as  well  as  subprojects 
related  to  digital  within  measure  ‘Smart  Infrastructure  with  environmental  and  cultural  focus’ 
(estimated  cost  EUR 90  million,  EUR 81  million  and  EUR 82  million,  respectively),  (iv)  the 
digital transformation of justice and a measure aimed at improving digital skills for judges and 
judicial  employees  (estimated  cost  EUR 81  million  and  EUR 32  million,  respectively),  (v)  a 
measure aimed at the acceleration of smart manufacturing (estimated cost EUR 75 million) (vi) 
the  TH2ORAX  project  under  component  4.5  (estimated  cost  EUR 50  million),  (vii)  the  digital 
transformation  of  the  agri-food  sector  (estimated  cost  EUR 48  million),  (viii)  the  digital 
transformation of the immigration and asylum system (estimated cost EUR 42 million), (ix) the 
digital  transformation  of  the  Hellenic  Railways  Organization  (estimated  cost  EUR 24  million), 
(x) a measure aimed at  enhancing  capital  market  supervision (estimated  cost  EUR 12 million), 
and (xi) the digitalization of the economic diplomacy network (estimated cost EUR 10 million). 
In addition, the EUR 12.7 billion of the Loan Facility included under component 4.7 contributes 
for  20%  to  the  digital  transition,  in  particular  through  investments  in  very  high  capacity 
broadband  networks,  investments  aimed  at  digitalizing  both  SMEs  and  large  enterprises, 
investments in the development and deployment of cybersecurity technologies, advanced digital 
technologies and other types of ICT infrastructure. 

Table 8 Digital contribution per component 

Component and name of the measure 

Cost 
(EUR million) 

Digital 
contribution  
(EUR million) 

Digital 
contribution* 
(percentage) 

1.1. Power up 
1.2. Renovate 
1.3. Recharge and refuel 
1.4. Sustainable use of resources, climate 
resilience and environmental protection 
2.1. Connect 
2.2. Modernise 

0.0 
0.0 
0.0 

0.0 

521.6 
1 280.6 

0.0% 
0.0% 
0.0% 

0.0% 

1.7% 
4.2% 

1 200.3 
2 711.5 
520.0 

1 762.7 

521.6 
1 280.6 

73 

 
 
2.3. Digitalisation of businesses 
3.1. Promote job creation and participation 
in the labour market 

3.2. Education, vocational education and 
training, and skills 

3.3. Improve resilience, accessibility and 
sustainability of healthcare 

3.4. Increase access to effective and 
inclusive social policies 
4.1. Making taxes more growth friendly 
and improving tax administration and tax 
collection 
4.2. Modernise the public administration, 
including through speeding up the 
implementation of public investments, 
improving the public procurement 
framework, capacity building measures and 
fighting corruption 
4.3. Improve the efficiency of the justice 
system 
4.4. Strengthen the financial sector and 
capital markets 
4.5. Promote research and innovation 
4.6. Modernise and improve resilience of 
key economic sectors 

4.7. Improve competitiveness and promote 
private investments and trade 
Technical assistance 
Total 

375.0 

776.3 

375.0 

93.8 

2 311.4 

1 055.0 

1 485.7 

611.4 

187.2 

277.6 

54.0 

185.1 

1.2% 

0.3% 

3.5% 

0.9% 

0.2% 

0.6% 

188.8 

108.2 

0.4% 

250.7 

20.7 

443.6 

3 742.2 

12 733.7 

40.0 
31 163.5 

113.0 

12.2 

50.0 

420.8 

2 547.0 

0.0 
7 094.1 

0.4% 

0.0% 

0.2% 

1.4% 

8.4% 

0.0% 
23.3% 

* Please  note  that  the  digital  contribution  in  percentage  is  calculated  based  on  Greece’s  total  allocations  in  non-
repayable financial support (EUR 17 769.9 million) and in loans (EUR 12 727.5 million). 

Digital transition 

The  recovery  and  resilience  plan  contributes  to  Greece’s  digital  transition,  addresses 
related challenges and is overall well aligned with the key objectives of the Digital Strategy 
of the Union and with the priorities related to digital set out by the Commission in the 2021 
Annual  Sustainable  Growth  Strategy.  These  measures  also  address  well  Greece’s 
shortcomings in the digital field as identified in the Digital Economy and Society Index (DESI). 
The  plan  encompasses  in  particular  (i)  measures  aimed  at  enhancing  connectivity,  by 
accelerating and facilitating the deployment of very high capacity networks, in particular 5G and 
fibre networks; (ii) measures aimed at improving the digitalisation of public administration, the 
judicial  and  financial  systems,  and  key  sectors  of  the  economy,  including  manufacturing,  agri-
food, culture and tourism, notably through a wider adoption of digital  capacities and advanced 

74 

 
 
 
digital technologies; (iii) measures aimed at fostering the digitalisation of Greek’s businesses and 
(iv) measures aimed at bridging the current gap in the human capital dimension, with a focus on 
digital  skills.  Overall, 
the 
competitiveness and resilience of the Greek economy, while ensuring inclusiveness. In addition, 
these measures are expected to bring a transformational change and have a lasting impact.  

these  measures  are  expected 

to  contribute 

improving 

to 

As  regards  connectivity,  component  2.1  includes  both  reforms  and  investments  aiming  to 
foster and facilitate the widespread deployment of very high capacity networks, including 
5G and fibre, in line with the EU 2025 connectivity objectives and with the 5G Action Plan. 
Reforms such as those which are included in the Connectivity Toolbox ,are expected to facilitate 
investments  in  very  high  capacity  networks  by  private  operators  in  particular  by  removing 
unnecessary  administrative  hurdles  to  investments  in  networks,  by  expediting  licensing 
procedures and by reducing the deployment cost and facilitating the whole network deployment 
process.  These measures also  complement and increase the impact  of existing national  support 
measures  such  as  the  “Ultra-Fast  Broadband”  (UFBB)  project  and  the  National  Fund  for  5G 
(called  “Phaistos  Fund”),  with  a  view  to  increasing  fixed  and  mobile  and  broadband  coverage 
and take-up by households and businesses.  

On  e-government  and  digital  public  services,  a  number  of  investments  and  reforms  are 
planned notably under component 2.2, but also under pillars 3 and 4. These reflect Greece’s 
strategic  goal  to  switch  into  a  “digital  by  default”  mode  by  2023  and  envisage  the  end-to-end 
redesign  and  simplification  of  many  government  services  to  citizens  and  businesses.  This  is 
particularly important to address the low supply and use of digital public services, both at central 
and decentralised level, by transforming Greek cities into smart city champions offering modern, 
customer-oriented  services.  The  digitization  of  key  archives  in  key  services  (justice,  urban 
planning  agencies,  cadastre,  immigration  &  asylum)  and  their  integration  in  the  relevant  IT 
systems, coupled with system interoperability initiatives that allow the application of the ‘once-
only’ principle, creates a solid foundation for the digital transformation of public sector entities, 
and the reduction of the administrative burden to citizens and businesses.  

This  is  also  complemented  by  reforms  and  investments  related  to  digital  capacities  and 
advanced  technologies,  such  as  the  envisaged  measures  on  cloud  infrastructures  and 
cybersecurity contained under component 2.2.  Investments in  cloud computing and big data 
are  aimed  in  particular  to  allow  linking  back  office  and  front  office  processes  to  ensure 
interoperability of systems, processes, applications and services, and are ultimately expected to 
improve  the  provision  of  public  services  to  government  actors,  citizens  and  businesses.  In 
addition,  the  component  envisages  the  development  and  implementation  of  a  cybersecurity 
strategy and a set of cybersecurity policies to increase the reliability and security of public sector 
systems  and  data  and  improve  citizens’  trust  in  their  interaction  with  the  public  sector,  the 
creation  of  a  National  Cybersecurity  Operations  Center  (SOC)  and  the  provision  of  advanced 
Security Services in G-Cloud critical infrastructure, to improve the security of the public sector’s 
central 
threats.  The 
implementation  of  this  comprehensive  set  of  measures  is  expected  to  significantly  step  up  the 
digital transformation of the public sector - central, regional and local government entities – and 

systems  against  cybersecurity 

infrastructures  and 

information 

75 

 
 
improve  the  provision  of  public  services  in  Greece  to  citizens  and  businesses.  This  is  in  turn 
expected to have a long-lasting impact for the public administration, as well as for citizens and 
businesses,  by  removing  existing  digital  barriers  and  providing  more  interoperable,  secure  and 
user-friendly digital public services.  

The  recovery  and  resilience  plan  also  encompasses  sizeable  measures  to  foster  the 
digitalisation of Greek’s businesses, notably SMEs, under component 2.3. The reforms and 
investments  included  in  the  plan  are  expected  to  foster  the  take  up  of  digital  technologies  by 
SMEs and enable them to adopt and develop innovative digital solutions, tailored to the specific 
needs of their industries, to expand SMEs’ digital presence, for instance through participation in 
e-commerce  platforms,  and  to  reduce  their  operating  costs,  for  instance  through  more  efficient 
data  processing.  Component  4.6  also  includes  a  measure  called  ‘Accelerating  Smart 
Manufacturing’,  which  aims  to  provide  financial  support  for  small  and  medium  manufacturing 
enterprises to enhance their technological infrastructure, upgrade their manufacturing equipment 
using  state-of-the-art  smart  technologies  with  low  environmental  impact  and  ultimately 
accelerate  the  industry’s  transition  to  Industry  4.0.  Although  these  measures  are  more  of 
horizontal  nature,  these  are  also  expected  to  contribute  to  the  digital  transition  of  the  Greek 
industry. 

The  plan  also  includes measures  aimed  at  bridging  the  current  gap  in  the  human  capital 
dimension,  by  modernizing  and  upgrading  the  life-long  learning  system  and  by  ensuring  an 
upskilling and reskilling system for the workforce that correspond to the need of the market, with 
a focus on digital skills. Such measures are expected to contribute to bridging the digital divide 
and to reinforce basic digital literacy across the entire population.  

Finally,  the  plan  includes  measures  which  also  have  a  cross-border/multi-country  digital 
dimension,  such  as  the  ‘5G  corridors’  investment  that  will  support  the  cross-border  corridor 
Thessaloniki-Sofia-Belgrade, 
that  will  allow 
the  ‘Submarine  fiber  cables’ 
interconnecting  mainland  Greece  with  Cyprus,  and  the  ‘Small  satellites’  investment  that  will 
ensure  interoperability  with  EuroQCI.  The  plan  also  includes  investing  in  a  new  high 
performance computing system, the creation of the national SOC and its networking with SOCs 
of  other  Member  States  and  the  adoption  of  a  national  eID  system  fully  compatible  with  the 
European one. 

investment 

Conclusion 

Taking  into  consideration  the  assessment  of  all  the  measures  envisaged,  the  recovery  and 
resilience  plan  is  expected,  to  a  large  extent,  to  make  a  significant  contribution  to  the  digital 
transition or to address the challenges resulting from it and ensures that at least 20% of its total 
allocation  contribute  to  support  digital  objectives.  This  would  warrant  a  rating  of  A  under 
criterion 2.6 of Annex V to the RRF Regulation. 

4.7. Lasting impact of the plan  

Structural change in administration and institutions 

76 

 
 
The  plan  presents  a  series  of  measures  to  modernise  and  digitalise  the  public 
administration, which are expected to contribute to the digital transition and to addressing 
the low level of digital public services. Component 2.2 is particularly relevant in this respect. It 
is expected to introduce structural improvements in the functioning of key services and to narrow 
the gap on the quality and use of digital public services, on which Greece ranked 27th among 28 
countries  assessed  in  the  Digital  Economy  and  Society  Index  in  2020.  Among  others,  the 
measures  included  in  the  component  aim  to  establish  more  efficient  processes  in  the  public 
sector, through process simplification and digitalisation initiatives, interoperable public systems, 
fully  digitised  registries,  and  electronic  repository  and  data  management  systems  (cloud 
infrastructure).  Furthermore,  the  measures  included  in  this  component  provide  for  the 
deployment  of  advanced  tools  such  as  on  cybersecurity,  artificial  intelligence  and  business 
analytics. Specific measures are included, aimed to improve digital performance at municipality 
level and to provide the tools and skills to transform Greek cities into smart city champions. The 
said initiatives are expected to have a lasting effect on the provision of smart, inclusive and more 
citizen-centric  digital  public  services,  and  reduce  the  administrative  burden  on  citizens  and 
businesses.  In  addition,  the  measures  directly  contribute  to  the  implementation  of  EU  policies 
such  as  open  data  policy  compliant  with  the  General  Data  Protection  Regulation,  European 
electronic identity, and data security.  

Complementary  to  the  above,  the  plan  aims  to  achieve  institutional  resilience  through 
further  actions  to  ensure  operational  efficiency  and  sound  financial  governance. 
Specifically, key measures under component 4.2  include capacity building and upskilling for a 
significant  part  of  civil  servants  (i.e.  more  than  40%  of  the  workforce),  the  introduction  of 
modern  hiring  procedures  and  a  reward  system  for  civil  servants,  and  the  establishment  of  a 
multilevel governance system to clarify responsibilities between public administration levels and 
to address current overlaps. These are complemented by measures to strengthen the national anti-
corruption  framework,  and  relevant  legislative  initiatives  to  facilitate  the  fight  against  money 
laundering  and  terrorism  financing.  The  component  also  introduces  modern  tools  on  e-
procurement  and  enterprise  resource  planning  to  address  structural  weaknesses  in  public 
financial  management,  including  payment  execution  and  effective  implementation  of  public 
investment  projects.  Lastly,  it  provides  for  the  modernisation  and  strengthening  of  the 
governance framework concerning state-owned-enterprises, which is expected to fundamentally 
improve  the  operation  and  services  of  such  enterprises.  Jointly  with  the  digital  pillar,  these 
measures are expected to fundamentally improve the Greek public administration across all five 
pillars of the public administration framework 34, namely (i) policy planning, policy coordination 
and policy development; (ii) civil service and human resource management; (iii) accountability; 
(iv) service delivery; and (v) public financial management. 

34  The  framework  has  been  developed  jointly  by  ECFIN  and  REFORM,  in  cooperation  with  other  Commission 
services. 

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Digital transformation initiatives under components 4.1 and 4.2 are expected to strengthen 
the ability of the State to collect taxes, thus tackling ongoing challenges relating to Greece’s 
fiscal  sustainability.  Measures  include  the  upgrade  of  core  digital  systems  in  the  tax 
administration,  the  introduction  of  automated  office  and  work  processes,  the  digitalisation  of 
audits  and  controls,  as  well  as  the  improvement  of  taxpayer  e-services.  These  are  expected  to 
improve the working methods and tools at the disposal of the tax authority in the fight against tax 
evasion and smuggling, and at the same time fortify its autonomy as an independent  authority. 
Coupled with measures to simplify and codify tax legislation, these are also expected to have a 
lasting impact on reducing the administrative burden for taxpayers and creating a level-playing 
field for businesses. 

A  wide-ranging  agenda  to  improve  the  efficiency  and quality  of  the justice  system  is  also 
provided under component 4.3, which is key to unblocking bottlenecks to investment. Inter 
alia,  measures  include  the  introduction  of  digital  processes  and  tools,  the  upgrade  of  control 
management mechanisms, and the training of judges and the judicial staff, with an emphasis on 
digital  skills.  The  said  measures  are  expected  to  contribute  to  structural  improvements  to  the 
administration  and  functioning  of  the  justice  system,  and  sustainably  reduce  the  backlog  of 
pending cases. 

Further, the plan aims to introduce long term structural changes in the effective delivery 
and  performance  monitoring  of  social  services,  including  for  vulnerable  social  groups. 
Specifically, investments in digital infrastructure and tools, including e-patient health record and 
therapeutic protocols  in  e-prescription, and the reform  of the primary health care system under 
component  3.3,  are  expected  to  improve  key  structural  weaknesses  currently  undermining  the 
capacity and resilience of the health care system. The digital transformation of the social support 
system  under  component  3.4,  is  expected  to  address  inherent  weaknesses  of  the  social  welfare 
system and facilitate the implementation of effective social safety nets.  Further, component 3.2 
provides  for  the  digital  transformation  of  education  in  terms  of  curriculum,  infrastructure  and 
services,  in  addition  to  a  new  framework  for  lifelong  learning.  Complementary  to  this, 
component  3.1  aims  to  address  structural  weaknesses  in  the  provision  of  public  employment 
services, by equipping them with modern, digital tools to enable them to carry out their mandate 
more  effectively.  Lastly,  component  1.2  aims  to  target  energy  poor  households  through  the 
adoption  of  an  energy  action  plan  while  allocating  a  dedicated  amount  from  the  planned 
investment to upgrade the energy efficiency of residencies to energy poor households. 

Structural change in policies 

Significant  measures  are  introduced  which  are  expected  to  improve  specific  policies  and 
regulation, in particular those relating to the ambitious decarbonisation and environmental 
protection goals. Regarding clean energy, component 1.1 includes measures that aim to increase 
the  share  of  renewable  energy  sources  in  Greece’s  energy  mix,  including  via  speeding  up  the 
licensing procedure for new RES plants, to introduce a monitoring mechanism for the recently 
established energy market, and to support the transition to a low-carbon energy model through 
enhancing  energy  efficiency  and  reducing  greenhouse  gas  emissions.  Initiatives  to  promote 
Greece’s  national  target  for  the  total  phase-out  of  lignite  by  2028  through  land  rehabilitation 

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measures  for  the  redevelopment  of  affected  areas  are  also  included.  Coupled  with  measures 
under  component  1.2  on  energy-efficient  renovation  and  upgrade  of  buildings  and  the 
development  of  strategic  green  urban  regeneration  projects,  the  plan  is  expected  to  sustainably 
contribute  to  emission  reduction  policy  objectives.  Further,  component  1.3  provides  for  the 
installation  and  operation  of  charging  infrastructure  for  electric  vehicles,  which  is  expected  to 
fundamentally  contribute  to  green  and  sustainable  mobility,  whilst  reforestation  initiatives  and 
measures to protect biodiversity are included under component 1.4. Lastly, measures to promote 
the  circular  economy  and  sustainable  agriculture,  as  well  as  improve  urban  planning  under 
component 4.6 are expected to credibly contribute to the long term objectives of environmental 
and climate adaptation policies.  

Further,  the  plan  is  expected  to  address  a  number  of  structural  changes  to  strengthen 
capital  markets,  the  business  environment,  and  the  extent  to  which  labour  policies  are 
effectively  implemented.  Component  4.4  introduces  measures  to  tackle  private  indebtedness, 
assist  the  monitoring  of  financial  market  information  and  credit  expansion,  and  remove 
information  asymmetries  that  are expected to  address  inherent  weakness  in  the financial sector 
and increase the resilience of the economy to future shocks. Measures under components 4.6 and 
4.7  are  expected  to  improve  the  regulatory  and  practical  environment  in  doing  business  and 
trading,  inter  alia,  by  reducing  entry  barriers,  improving  the  capacity  of  market  surveillance 
structures  and  rationalising  export  processes.  The  labour  market  reform  under  component  3.1 
aims to improve the functioning of the labour market, while investment in active labour market 
policies under the same component is expected to contribute to sustainable job creation. Under 
component  3.2,  the  upskilling  and  reskilling  of  the  workforce,  with  an  emphasis  on  green  and 
digital  skills,  is  expected  to  contribute  to  the  robustness  of  the  labour  market,  by  addressing 
challenges arising from the twin transition. 

Lasting impact 

The plan includes measures that aim to address the root causes of the identified challenges 
and not just the symptomatic issues, underpinned by proper analysis, and in a number of 
cases aim to establish a change in practices. The combination of energy efficiency and energy 
market  reforms  is  expected  to  tackle  problems  associated  with  energy  poverty  and  Greece’s 
excessive reliance on solid fossil fuels (lignite) for electricity generation. Measures such as the 
digital  upgrade  of  the  rail  network  are  aimed  to  tackle  the  absence  of  smart  public  transport 
solutions.  Further,  the  plan  is  expected  to  credibly  address  Greece’s  low  digital  performance 
compared  to  EU  peers,  in  particular  as  regards  the  low  provision  and  use  of  digital  public 
services  and  lack  of  digital  skills.  The  plan  also  aims  to  introduce  a  series  of  good  practices, 
including in the area of better regulation and impact assessment, and in IT system and process 
design  (i.e.  ensure  ‘interoperability  by  design’,  ‘once-only’  submission  of  citizen  information, 
open use of data, and customer-centric public services). Reforms and investments, including the 
upskilling  of  the  public  sector  staff,  the  deployment  of  digital  tools,  and  organisational 
improvements  are  expected  to  enhance  the  capacity  of  the  public  administration  to  implement 
and effectively monitor these policies. Further, the measures appear sustainable, as they take into 
consideration financial and budgetary implications and the possible risks to implementation. 

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The plan is in line with fundamental rights and EU and national policies, whilst it respects 
good governance. Specifically, the measures are conducive to key EU priorities provided in the 
European  Digital  Policy  and  European  Green  Deal.  They  also  aim  to  promote  social  inclusion 
and  equality.  Further,  in  line  with  the  principle  of  good  governance,  Greece  carried  out  a 
stakeholder consultation when the initial draft was submitted at the end of 2020 and submitted a 
summary of the updated draft plan for discussion at the Parliament a few weeks prior to official 
submission,  which  was  also  made  publicly  available  on  a  dedicated  website35.  Notably,  the 
content of the plan is broadly aligned with the key priorities included in the Greek Government’s 
National  Reform  Agenda  and  reflected,  in  great  part,  in  Development  Plan  for  the  Greek 
economy,  developed  in  2020  by  a  group  of  renowned  economists,  led  by  Nobel  Prize  laureate 
Christopher Pissarides. 

Conclusion 

Taking into consideration all reforms and investments envisaged by Greece in its recovery and 
resilience  plan,  their  implementation  is  expected,  to  a  large  extent  to  bring  about  a  structural 
change in the administration and in relevant policies and to have a lasting impact. This would 
warrant a rating of A under criterion 2.7 of Annex V to the RRF Regulation. 

4.8. Milestones, targets, monitoring and implementation  

Adequacy of the structure tasked with the implementation of the plan, monitoring of progress 
and reporting 

Greece’s structure tasked with carrying out the implementation of the plan, monitoring of 
progress  and  reporting  is  centred  around  four  main  bodies  that  will  each  have 
responsibility  to  execute  the  management  and  control  system  to  be  established.  First,  the 
Recovery and Resilience Facility Coordination Agency (RRF Coordination Agency), part of the 
Ministry of Finance, constitutes the lead national body tasked with the overall coordination and 
monitoring  of  the  recovery  and  resilience  plan,  including  performing  active  monitoring  on  the 
progress of the measures, on the basis of the milestones and targets set for each component and 
verify  their  achievement.  Second,  the  responsibility  for  the  implementation  of  each  specific 
measure is well defined and falls in most cases on the competent Ministry whose services will 
support  the  monitoring  of  the  projects’  progress  and  maintain  close  cooperation  with  the  RRF 
Coordination  Agency  and  the  implementing  bodies.  Third,  all  measures  in  the  plan  will  be 
implemented  by  national  bodies  (“implementation  bodies”)  appointed  by  the  competent 
Ministries  and  will  be  responsible  for  the  achievement  of  the  agreed  milestones  and  targets  as 
well as the reporting of all data and documentation to the RRF Coordination Agency through the 
management information system to be established for the Recovery and Resilience Facility. The 
implementation bodies will apply control systems that ensure compliance with EU and national 

35 https://www.minfin.gr/web/guest/tameio-anakampses 

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law, and the effective use of the Recovery and Resilience Facility funds, which will be further 
validated  by  an  independent  certified  auditor.  In  cases  of  material  delays,  the  implementing 
bodies  are  expected  to  provide  justification  and  a  remediation  action  plan(s)  to  the  RRF 
Coordination Agency. Finally, the control of the achievement of milestones/targets is assigned to 
an  external  independent  certified  auditor,  who  is  selected  and  appointed  among  the  ones 
registered in the official Register of the Hellenic Accounting and Auditing Standards Oversight 
Board. 

The fourth body is the Financial Audit Committee (EDEL). This Committee, which is part of 
the  General  Secretariat  for  Fiscal  Policy  (State  General  Accounting  Office)  of  the  Ministry  of 
Finance,  has  a  mission  to  safeguard  the  observance  of  the  principles  of  sound  financial 
management for programmes co-financed with the EU (e.g. European Structural and Investment 
Funds). The plan also refers to other bodies that, while not foreseen to have a formal role in the 
management and control system to be established for the Recovery and Resilience Facility, are 
expected to contribute in the monitoring and implementation. These bodies include the General 
Directorate of Financial Services in each Ministry, the General Directorate of Public Investments 
and  National  Strategic  Reference  Framework  (part  of  the  Ministry  of  Development  and 
Investments),  the  Hellenic  Court  of  Audit,  the  National  Transparency  Authority,  the  Central 
State  Aid  Unit  (part  of  the  Ministry  of  Finance)  and  the  Authority  for  the  Examination  of 
Preliminary Appeals. 

As  concerns  the  reforms  under  the  plan,  the  monitoring  role  is  assigned  to  the  General 
Secretariat for Coordination. The General Secretariat for Coordination (part of the Presidency 
of the Government) is assigned (Law 4622/2019) the mandate to monitor the implementation of 
all government’s reforms in general, and in the recovery and resilience plan it is stated that it will 
have  the  responsibility  to  confirm  the  successful  completion  of  its  reforms  and  the  relevant 
milestones  and  to  inform  the  RRF  Coordination  Agency  through  regular  and/or  exceptional 
reporting.  While  the  recovery  and  resilience  plan  indicates  that  the  General  Secretariat  for 
Coordination is not formally part of the bodies forming the management and control system of 
the plan, it does not contain details on how the General Secretariat for Coordination is expected 
to  engage  with  the  implementing  bodies  or  whether  it  falls  upon  the  General  Secretariat  for 
Coordination  or  the  RRF  Coordination  Agency  to  suggest  ways  of  solving  problems  that  may 
arise during the implementation of specific measures of the recovery and resilience plan. 

The recovery and resilience plan’s components fall, to a large extent, under the competency 
of a Ministry that will then appoint relevant implementing bodies depending on the scope 
of the measures included under the specific component. However, the measures under some 
broader components, such as components 1.2, 1.4, 4.2 and 4.6, involve multiple Ministries. 

The Greek plan presents a detailed overview of the monitoring and reporting  mechanism 
foreseen.  More  specifically,  the  management  and  control  system  includes  a  dedicated 
monitoring  phase  covering  the  whole  lifecycle  of  the  measures.  This  includes  analytical 
processes  that  will  be  established,  in  order  for  the  implementing  bodies’  to  notify  the  RRF 
Coordination  Agency  on  a  periodical  basis  on  the  progress  made  in  the  achievement  of  the 
milestones  and  targets.  The  recovery  and  resilience  plan  does  not  contain  any  specific 

81 

 
 
information  on  record  keeping,  neither  on  the  responsibility  of  the  bodies  involved  in  the 
implementation, nor how long these records will be kept. 

Milestones, targets and indicators 

The overall approach taken by Greece in defining milestones and targets over the life-cycle 
of  investments  and  reforms  is  as  follows:  (i)  10  investments  are  designated  as  “top 
investments” based on value and maturity criteria; (ii) 8 reforms are designated as “key reforms” 
based  on  impact  and  maturity  criteria;  and  (iii)  all  remaining  measures  are  categorised  in  28 
groups  based  on  their  area  of  focus  and  aiming  to  have  one  Ministry  assigned  the  overall 
responsibility of each group. The recovery and resilience plan defines milestones/targets for each 
investment and reform included in the plan.  

The milestones and targets of the Greek plan constitute an appropriate system to allow for 
an  efficient  monitoring  of  its  implementation.  The  proposed  qualitative  and  quantitative 
indicators used for the milestones and targets are sufficiently clear, realistic and comprehensive 
to ensure that their completion can be traced and verified. Further, the milestones and targets are 
relevant and acceptable, as their scope reflects the overall objective of the measures, which are 
assessed as reasonable and cost-effective.  

Overall organisational arrangements 

As  set  out  in  the  recovery  and  resilience  plan,  the  lead  body  tasked  with  the  overall 
coordination,  the  RRF  Coordination  Agency,  is  an  independent  special  public  service 
under  the  Minister  of  Finance,  set  up  according  to  the  Law  4738/2020.  The  RRF 
Coordination Agency constitutes the lead national body tasked with the overall coordination and 
monitoring of the plan. It is also assigned as the responsible body that submits twice a year the 
payment  request  to  the  Commission,  accompanied  by  a  management  declaration  of  sound 
financial  management  and  the  summary  of  the  Financial  Audit  Committee’s  (EDEL)  audits, 
including weaknesses identified and any corrective actions taken. 

On  the  overall  administrative  capacity,  the  recovery  and  resilience  plan  sets  out  that  the 
RRF Coordination Agency will be staffed with 40 posts and that all posts are expected to be 
filled before end of 2021. While the plan provides some details on staff profiles, including that 
the  majority  will  have  a  university  degree,  it  does  not  provide  details  on  how  the  resources’ 
needs  were  assessed  or  assurances  that  the  allocated  resources  will  be  sufficient  for  the  RRF 
Coordination Agency to successfully carry out its mandate. 

The legal mandate of the RRF Coordination Agency is already in place, and the recovery 
and resilience plan states that the mandate of other bodies involved in the implementation 
and  monitoring  of  the  implementation  will  be  established  through  a  dedicated  national 
legal  act.  This  legal  act  will  establish  the  overall  management  and  control  system,  including 
roles and responsibilities for key bodies, including the Financial Audit Committee (EDEL). The 
legal  act  is  expected  to  be  adopted  before  the  first  payment  request  will  be  submitted  to  the 
European Commission. 

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Whereas  the  plan  presents  comprehensive  coordination,  implementation  and  monitoring 
arrangements,  the  implementation  of  the  plan  will  crucially  hinge  on  the  administrative 
and  implementation  capacity  of  the  implementing  bodies  and  will  need  to  be  closely 
monitored.  The  majority  of  the  implementing  bodies  remains  to  be  identified;  hence,  it  is  not 
possible  to  assess  their  implementation  capacity.  This  includes  some  of  the  more  sizeable 
investments,  such  as  renovation  measures  under  component  1.2,  life-long  skilling  under 
component  3.2  and  for  some  measures  under  component  4.6  on  investment  and  economic  and 
institutional  transformation.  In  some  cases,  it  is  not  clear  how  the  public-private  partnerships 
foreseen  will  interact  with  the  local  organizations  (e.g.  on  irrigation  investments  under 
component 1.4). Further, the Hellenic Development Bank, which has been established recently, 
is  expected  to  contribute  to  the  implementation  of  some  measures  (e.g.  measures  under 
components 1.4 and 4.7) and it will be important to  ensure that it has sufficient  administrative 
capacity  to  carry  out  its  task.  Similarly,  the  technical  services  of  the  municipalities,  including 
municipal  companies,  are  expected  to  contribute  to  the  implementation  of  a  number  of 
components (e.g. components 1.2 and 1.4), and their administrative capacity, in particular for the 
smaller  municipalities,  is  usually  restricted  and  it  would  be  important  that  additional  support 
from the central level be made available when needed.  

The  authorities  have  recently  adopted  measures  to  improve  the  implementation  and 
enhance  administrative  capacity  and  the  recovery  and  resilience  plan  contains  further 
specific  measures  that  are  expected  to  contribute  to  that  objective.  In  particular,  the 
authorities have recently established a strategic projects pipeline for large infrastructure projects 
complemented by a project preparation facility that aims to improve and accelerate the planning 
and  maturation  of  major  public  investment  projects.  The  public  procurement  law  adopted  in 
March  2021  also  introduced  substantial  improvements  to  the  framework,  which  was 
complemented  by  the  adoption  of  an  action  plan  for  the  implementation  of  a  new  national 
strategy for public procurement for 2021-2025 in May 2021. Building on this national strategy, 
the  plan  contains  measures  to  further  improve  the  efficiency  of  the  public  procurement 
framework  (under  component  4.2),  including  the  digital  transformation  of  public  procurement 
processes  and  the  set-up  of  an  effective  governance  system.  In  addition,  component  4.2  also 
includes measures aiming to enhance the human resources of the public administration, including 
targeted action towards the technical services of the municipalities. Considering the size of the 
recovery  and  resilience  plan,  it  will  be  important  that  all  implementing  bodies  are  appointed 
swiftly and that the RRF Coordination Agency has a solid risk management strategy in place to 
address deviations/delays at an early stage.  

Conclusion 

The  arrangements  proposed  by  Greece  in  its  recovery  and  resilience  plan  are  expected  to  be 
adequate to ensure effective monitoring and implementation of the recovery and resilience plan, 
including the envisaged timetable, milestones and targets, and the related indicators. This would 
warrant a rating of A under the assessment criterion 2.8 of Annex V to the RRF Regulation. 

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4.9. Costing  

The  recovery  and  resilience  plan  presents  detailed  cost  assessments  for  all  investment 
projects and reforms  where cost occur. The cost  descriptions vary in  the methodology used, 
but  provide  an  appropriate  level  of  information,  based  on  which  reasonability,  plausibility, 
additionally  with  EU  funding  can  be  assessed.  Furthermore  in  combination  with  the  economic 
and social impact assessment provided in the plan, the cost assessment also allows an evaluation 
regarding  whether  the  overall  costs  are  commensurate  with  the  economic  and  social  impact 
expected from the measures as well as their cost efficiency. The Greek government followed a 
four step approach to determine and verify the cost per project  and then aggregate them to the 
total per component and pillar of the recovery and resilience plan. These steps are: 1) developing 
a specific report per project; 2) examination of available costing information and data; 3) detailed 
breakdown of all major cost items and decision on costing methodology; and 4) cost verification 
per project, per component and at plan level. 

A cost analysis report was produced for each project, which includes a short description of 
its  main  characteristics,  an  overview  of  the  timeline  and  milestones  or  targets  to  be 
achieved  and  a  breakdown  of  the  project  budget.  This  budget  breakdown  contains  the 
estimated  cost  excluding  value  added  tax,  and  includes  information  regarding  the  start  of  the 
project and assurances that none of the costs have been incurred before February 2020 as well as 
information  regarding  recurrence  of  the  cost.  The  budget  also  includes  information  regarding 
costs that are covered by other private parties or Union financing, in which case they have been 
taken out of the project cost to ensure there is no double funding. Furthermore, this part of the 
cost analysis reports also contains information regarding the methodology used for estimating the 
cost, the critical cost drivers, unit costs and the total number of units, and the estimation of the 
total  budget  per  project.  The  report  also  contains  references  to  supporting  material,  such  as 
relevant studies as well as historical and comparative costs of similar projects that were used to 
validate the project cost.  

In terms of costing methodology, the plan presents three different approaches (bottom up 
cost  calculation,  parametric  cost  calculation  and  top  down  cost  estimation)  depending  on 
the maturity of a project and the availability of data. The bottom up approach estimates the 
cost  of  each  granular  cost  driver  and  then  aggregates  the  cost  of  the  individual  units  to  an 
estimated  total  cost  of  the  project.  The  parametric  approach  relies  on  similar  projects  and 
historical  figures  to  estimate  the  project  cost;  and  the  top  down  cost  estimation  approach 
apportions  the  total  cost  to  individual  cost  parameters.  This  approach  also  heavily  relies  on 
historical  data  but  also  takes  into  account  expert  judgement,  especially  in  cases  where  there  is 
limited comparable costing information available. The cost analysis reports  have been prepared 
in collaboration with an external consultant, which cannot be seen as an independent body due to 
contractual  relationship  with  the  Greek  government.  The  cost  estimates  have  been  assessed  by 
Greece’s  National  Productivity  Board,  which  finds  them  to  be  reasonable,  plausible  and 
commensurate and in conclusion has validated the cost estimates.  

Reasonable costs 

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To justify the reasonability of the cost estimates provided, the Greek government provided 
detailed breakdowns of the project cost.  The cost estimates include costing tables that break 
down the overall cost into different items, and allow the identification of the main cost drivers 
and  how  the  overall  cost  of  the  project  has  been  estimated.  The  underlying  calculations  and 
assumptions for the cost estimations can be well understood and are sound for a majority of the 
measures.  The  detailed  costing  summaries  also  provide  an  overview  of  the  methodological 
approach used in the estimation of the cost, with the bottom up approach being the one used most 
frequently.  Some  of  the  investment  projects  are  expected  to  create  recurrent  cost,  due  to  the 
nature  of  the  investment,  but  these  cases  are  limited  in  number  and  duly  justified  and  well 
explained.  All  cost  breakdowns  only  include  cost  that  have  been  incurred  after  February  2020 
and the value added tax has been excluded from the cost calculations. Overall, the estimated cost 
across  the  investment  and  reform  projects  are  appropriate  for  the  specific  measures  and  have 
been sufficiently justified for the majority of the measures.  

Plausible costs  

The  Greek  government  provided  sufficient  information  and  evidence  regarding  the 
plausibility  of  the  cost  of  the  planned  reforms  and  investments  by  showing  that  the 
estimated  total  cost  of  the  plan  are  in  line  with  the  nature  and  type  of  the  envisaged 
projects. As part of the detailed project cost breakdown, the Greek government has included a 
justification why the estimated cost are in line with the nature and type of the project, and should 
be regarded as plausible. These justifications are generally supported by reference projects that 
are comparable and have been concluded recently either in Greece or other EU Member States, 
relevant studies, tender documentation of recently conceded tenders of comparable projects and 
average market rates. For some projects, that are of very innovative nature or will be supporting 
specific  action  for  instance  via  demand  driven  schemes  and  therefore  cannot  be  directly 
compared  to  other  existing  projects,  scientific  sources  and  input  cost  have  been  used  to 
substantiate the plausibility of the cost estimates. A limited number of projects is not sufficiently 
substantiated with cost of comparable project or the evidence cited could not be accessed. Where 
estimated  project  cost  exceed  the  project  cost  of  the  reference  projects,  the  excess  remains 
generally within an appropriate range.  

No double Union financing 

Most  of  the  measures  proposed  in  the  recovery  and  resilience  plan  are  funded  at  100% 
from the Recovery and Resilience Facility and in the few exceptions, where other funding 
sources  are  used,  sufficient  information  has  been  provided.  The  Greek  government  has 
provided  information  for  each  measure  regarding  the  funding  sources,  with  the  large  majority 
relying on 100% financing from the Recovery and Resilience Facility. In the few cases that also 
use  national  or  other  EU  funding  sources,  the  information  regarding  the  amounts  and  costing 
items that are not covered under the Recovery and Resilience Facility have been provided as part 
of  the  cost  breakdown  per  measure.  The  costs  that  are  covered  by  other  than  Recovery  and 
Resilience Facility funding sources have been taken out of the overall cost that will be supported 
by the Facility, therefore providing a clear delineation and avoiding double funding. Therefore 
the  plan  ensures  that  the  support  of  the  Recovery  and  Resilience  Facility  is  expected  to  be 

85 

 
 
additional to the support provided under other Union funds and programmes and does not cover 
the same cost. 

Commensurate and cost-efficient costs 

Due to its significant positive economic and social impact and positive assessment regarding 
the  reasonability  and  plausibility  of  the  cost,  the  total  cost  of  the  recovery  and  resilience 
plan can be assessed as  commensurate  to the  expected social  and economic impact of the 
envisaged measures. As outlined in section 4.3, the measures foreseen as part of the plan are, 
when assessed jointly, expected to have a significant economic and social impact, counteracting 
some of the adverse effects of the economic crisis caused by the coronavirus pandemic as well as 
fostering structural changes in the economy and society. The cost associated with these measures 
have  been  well  explained  and  assessed  as  reasonable  and  plausible  and  therefore  are 
commensurate to the expected social and economic impact.  

Conclusion 

The justification provided by Greece on the amount of the estimated total costs of the recovery 
and resilience plan is to a medium extent reasonable, plausible, in line with the principle of cost-
efficiency  and  commensurate  to  the  expected  national  economic  and  social  impact  on  the 
economy.  Greece  has  provided  sufficient  information  and  evidence  that  the  amount  of  the 
estimated cost of the reforms and investments of the recovery and resilience plan to be financed 
under the Facility is not covered by existing or planned Union financing. This would warrant a 
rating of B under the assessment criterion 2.9 of Annex V to the RRF Regulation. 

4.10. 

Controls and audit  

Robustness of internal control system and distribution of roles and responsibilities 

its 

implementation  system,  which 

The  Greek  plan  describes 
is  a  tailored-made 
Management  and  Control  System  defined  as  the  MCS.  The  coordinating  body  will  be  the 
Recovery and Resilience Facility Coordination Agency, which will perform active monitoring on 
the progress of the projects, and verify the achievement of the milestones and targets set for each 
component  and/or  reform  and  investment.  The  Recovery  and  Resilience  Facility  Coordination 
Agency will also submit the payment requests to the European Commission, upon verification of 
the achievement of the milestones and targets through the RRF Management Information System 
(MIS), accompanied by the management declaration, as well as a summary of the audits carried 
out, including weaknesses identified and any corrective actions taken. The Implementing Bodies 
(IBs) will undertake the management and implementation of the approved projects, which will be 
checked by independent certified auditors, while the Ministries will support the monitoring of the 
projects’ progress. EDEL, which is the competent Audit Authority for European Structural and 
Investment  Funds  since  2001,  will  be  responsible  of  auditing  the  entire  process  before  the 
payment claims will be submitted by the Recovery and Resilience Facility Coordination Agency. 

The system presents a robust process and structure, where the roles and responsibilities are 
clearly  defined  and  the  relevant  control  functions  are  appropriately  segregated.  The 
independence  of  the  control  bodies  is  ensured,  as  the  Recovery  and  Resilience  Facility 

86 

 
 
Coordination Agency is an independent special public service under the Minister of Finance, set 
up according to the Law 4738/2020. 

Adequacy of control systems and other relevant arrangements 

The  Management  and  Control  System  states  the  procedures  that  are  in  place  to  ensure 
compliance  to  applicable  Union  and  national  law,  throughout  the  implementation  of  all 
measures. Furthermore, it clearly addresses all serious irregularities (fraud, corruption, conflict 
of interest) and potential double funding by allowing for controls and audits to be implemented 
in  separate  and  distinctive  levels.  In  particular,  during  the  first  level,  independent  certified 
auditors will implement audits on behalf of the implementing bodies to verify i) the fulfilment of 
the  agreed  milestones  and  targets  that  are  associated  with  Recovery  and  Resilience  Facility 
funding requests, ii) the compliance with EU and national law and iii) the avoidance of serious 
irregularities  and  double  funding.  On  top  of  the  above  and  upon  discretion,  Recovery  and 
Resilience Facility Coordination Agency may entrust to external auditors to perform verification 
of milestones and targets achievement, on its behalf. Moreover, EDEL will carry out the second 
level audits, as part of its mandate/authority to exercise such tasks.  

The proposed measures give assurance that there is an adequate level of control to prevent, 
detect and correct irregularities identified when using funds provided by the Recovery and 
Resilience  Facility.  The  adoption  of  measures  for  the  prevention  and  management  of  the  risk 
concerns  either  individual  measures  that  will  be  implemented  by  an  Implementing  Body,  or  a 
proposal for horizontal measures that should be integrated in the prescribed procedures of RRP 
MCS  (e.g.  introduction  of  a  new  checkpoint  in  a  checklist).  The  Recovery  and  Resilience 
Facility  Coordination  Agency  will  put  in  place  a  policy  related  to  conflicts  of  interests  to 
mitigate the risks and to tackle possible cases. Therefore, analytical procedures will be designed 
as a part of the MCS, tools will be provided to help identify the existence of a possible conflict of 
interest  and  a  relevant  list  of  red  flags  will  be  available  to  detect  such  situations.  Financial 
corrections  will  be  applied  to  errors  with  a  financial  impact,  in  accordance  with  the  national 
regulatory  framework.  The  financial  corrections  relate  to  the  cancellation  of  all  or  part  of  the 
Union  and/or  national  participation  in  a  project,  within  the  framework  of  its  financing  by  the 
Recovery and Resilience Facility, and the correction is proportionate to the irregular expenditure 
found. 

There  are  also  no  specific  risks  identified  concerning  irregularities  to  each  components. 
Data  on  final  beneficiaries  are  stored  by  the  RRF  Management  Information  System  as  well  as 
contractors, sub-contractors, beneficial owners, and a list of any measures for the implementation 
of  reforms  and  investment  projects  under  the  recovery  and  resilience  plan.  In  addition,  the 
Commission needs reassurance that a system will be operational, that (a) ensure the collection of 
data and monitoring of the achievement of milestones and targets; (b) allow for the preparation 
of management declarations and the audit summary as well as payment claims and (c) establish 
the necessary procedures to  collect  and store data on beneficiaries, contractors, subcontractors, 
and  beneficial  owners  in  accordance  with  Article  22  of  the  Recovery  and  Resilience  Facility 
Regulation before the first payment request is made. A dedicated audit report on the system set 

87 

 
 
up  will  be  undertaken.  In  case  that  the  report  identifies  any  weaknesses,  the  audit  report  will 
recommend corrective actions. This will be implemented through a dedicated milestone.  

Adequacy of arrangements to avoid double EU funding 

The avoidance, detection and prevention of double funding will be ensured at all stages of 
the projects’ lifecycle, through robust procedures structured within the RRF Management 
and  Control  System.  First,  all  Implementing  Bodies  will  have  to  declare,  via  the  submitted 
Fiche  in  the  RRF  Management  Information  System,  that  no  previous  Union  funding  has  been 
granted for the same project (during the current or previous period). Moreover, the structure of 
RRF  Management  Information  System  shall  allow  for  the  cross-checking,  detection  and 
consolidation  of  all  possible  data  sources  that  are  related  to  the  IBs  funding  and  systemically 
shall  separate  their  different  EU  funding  streams.  This  level  of  consolidation  and  transparency 
will  ensure  the  early  detection  and  avoidance  of  double  funding  from  the  Recovery  and 
Resilience Facility and other EU programs, while it will act as a preventing factor for the IBs. 
The data collection and consolidation will heavily rely on synergies and interoperability between 
the different information systems, while double funding cases will be flagged through (existing) 
Business Intelligence tools. For example, the RRF Management Information System, which will 
be  developed  in  the  same  platform  as  the  existing  platform,  used  for  European  Structural  and 
Investment Funds, will be able to exchange data and apply cross-checks with all the different EU 
related  data  sources.  Accordingly,  the  RRF  Management  Information  System  will  be 
interoperable  with  other  information  systems  of  the  Public  Sector.  Further,  an  additional 
safeguard to  prevent  double-funding between the programs under the Recovery  and Resilience 
Facility,  will  be  the  assessment  of  the  use  of  electronic  invoices  on  the  basis  of  the  new 
OpenPEPPOL  protocol.  In  this  way  each  invoice  will  be  unified  within  the  Management 
Information  System  and  therefore  could  not  be  financed  from  another  source.  Finally,  the 
independent  external  auditors  will  also  examine  during  their  audits  the  existence  of  a  possible 
double funding. Audit reports will be performed at all phases of the projects and uploaded to the 
RRFA  Management  Information  System,  followed  by  a  declaration  of  non-receiving  double 
funding  for  the  same  project  (or  milestone).  Moreover,  EDEL  will  also  cover  the  above  issue 
during its audits. 

The arrangements put in place are sufficient and adequate in their description, thanks to 
the RRF MIS that will allow for cross-checking, detection and consolidation of all possible 
data  sources  that  are  related  to  the  EU  funding  under  the  remit  of  the  relevant  IBs.  The 
data collection and consolidation will heavily rely on synergies and interoperability between the 
different information systems, as well as the use of the new OpenPEPPOL protocol, as explained 
above.  

Legal empowerment and administrative capacity of control function 

Roles  and  responsibilities  of  the  actors  for  controls  and  audits  are  clear,  relevant  control 
functions are appropriately segregated and the independence of actors performing audits is 
ensured. The Recovery and Resilience Facility Coordination Agency is an independent special 
public  service  under  the  Minister  of  Finance,  set  up  according  to  the  Law  4738/2020,  and 

88 

 
 
constitutes  the  lead  national  body  tasked  with  the  overall  coordination  and  monitoring  of  the 
recovery and resilience plan. Regarding the Audit Authority, the mandate of EDEL to audit the 
plan will be provided in a dedicated national legal act, which will include all involved actors, as 
well as management and control system responsibilities and procedures. It is indicated that the 
Recovery and Resilience Facility Coordination Agency will have 40 staff positions in total that 
will  be  covered  mainly  (at  least  by  50  percent)  by  permanent  staff  of  the  Public  Sector, 
consisting  of  29  University  Education,  4  Technological  Education  and  5  Secondary  Education 
employees.  The  organizational  structure  and  responsibilities  of  the  Recovery  and  Resilience 
Facility Coordination Agency may be amended to fully reflect the processes of the Management 
Control System, as soon as it is finalized, but the current staffing plan gives reasonable assurance 
of the administrative capacity of the Recovery and Resilience Facility Coordination Agency.  

The  necessary  legislative  arrangements  in  the  organizational  structure  of  EDEL  will  be 
made to  establish a new dedicated Unit within the General Directorate for the Audits of Co-
financed  Programs,  under  the  Financial  Audit  Committee.  For  this  new  Unit,  additional 
dedicated staff positions will be foreseen, although the amount of staff is not clearly indicated. It 
is foreseen that the positions will be covered by transferring staff from existing positions of the 
General  Directorate  or  from  other  units  of  the  Ministry  of  Finance,  as  well  as  by  secondment 
from other services and entities of the General Government. The option of outsourcing some of 
the audit tasks is also foreseen. 

The pending mandate of EDEL to audit the recovery and resilience plan, which will only be 
provided  by  a  dedicated  national  legal  act  for  the  implementation  of  the  Recovery  and 
Resilience Facility, upon approval of the recovery and resilience plan is a shortcoming. This 
shortcoming is addressed through the implementation of a dedicated milestone. 

The chapter on audit and control gives a complete description of the arrangements for the 
implementation  and  control  of  the plan  in  Greece.  At  plan  level,  the report  is  very  detailed 
and  gives  the  Commission  reasonable  assurance  that  there  is  a  sound  structure  in  place  to 
monitor and implement the allocated funds from the RRF.  

Conclusion 

The arrangements proposed by Greece in the recovery and resilience plan to prevent, detect and 
correct  corruption,  fraud  and  conflicts  of  interest  when  using  the  funds  provided  under  the 
Facility, including the arrangements aimed to avoid double funding from the Facility and other 
Union programmes, are assessed to be adequate, provided that the pending issues are addressed 
before the first payment request, through the dedicated milestone. This would warrant a rating of 
A under the assessment criterion 2.10 of Annex V to the RRF Regulation. 

4.11. 

Coherence  

Mutually-reinforcing measures 

The recovery and resilience plan is based on the comprehensive Development Plan for the 
Greek economy, which ensures its coherence towards contributing to smart, inclusive and 
sustainable  economic  development.  It  is  structured  around  four  main  pillars  (“Green 

89 

 
 
Transition”,  “Digital  Transformation”,  “Employment,  skills  and  social  cohesion”,  “Private 
Investments  and  Transformation  of  the  economy”),  which  include  measures  that  are  mutually 
reinforcing, as they are supposed to generate synergies when implemented.  

The measures from the green and digital transition part of the plan are highly interlinked. 
They contain measures related to the digital transformation, which are key enablers for the green 
and circular transition of the Greek economy. For example, measures under the component 2.3, 
i.e.  digitalisation  of  businesses,  focuses  on  increasing  the  digital  maturity  of  businesses  by 
creating a digital infrastructure through funding and digital awareness schemes, which will also 
facilitate implementation of the measures under the green transition, for example electrification 
of the transport sector). Similarly, the inclusion of climate-related and sustainability criteria from 
the  green  transition  pillar  will  enable  deployment  of  digital  technologies  and  contribute  to  the 
digital transition. 

The third pillar on employment, skills and social cohesion includes measures ensuring that 
digital  and  green  transitions  will  be  fair  across  different  parts  of  the  Greek  society,  by 
prioritising  sustainable  job  creation,  improvement  of  the  education  system  and  skills,  and  the 
provision of high quality and effective health and social care services.  

The  fourth  pillar  presents  measures  for  boosting  competitiveness  and  innovation  by 
mobilising  private  and  public  investment  and  setting  up  institutional  frameworks,  which  will 
enable the digital and green transition to materialise in Greece. 

Complementarity of measures 

The Greek plan is coherent and exploits complementarity between measures and between 
components. The plan builds upon and is consistent with the comprehensive Development Plan 
for the Greek  economy,  prepared in  2020 by  a committee led by the Nobel  laureate, Professor 
Pissarides.  Measures  are  carefully  designed  to  satisfy  the  fulfilment  of  the  country-specific 
recommendations.  In  order  to  promote  wider  coherence  across  instruments,  notably  with  the 
European cohesion policy funds, a balanced territorial allocation of resources is encouraged. 

The  components  related  to  the  green  transition,  such  as  1.1,  1.2  and  1.3  reinforce  each 
other and act as  complementary reforms and investment as they jointly contribute to the 
energy transition. The objective of these measures is on the one hand, producing cleaner energy 
and on the other, saving on the final consumption of the energy, while ensuring EU climate and 
energy goals by 2030. The aim of the reforms of component 1.1 – “Power up” - is to contribute 
to  the  climate  and  energy  plans  through  investments  and  reforms  that  intend  to  accelerate  the 
development of renewables as well as their integration through upgraded networks and enhanced 
interconnectivity.  All  this  is  complementary  to  the  sustainable  development  of  the  Greek 
economy,  contributing  to  healthier  and  cleaner  future  for  the  Greek  society.  The  reforms  and 
investments of “Renovate” under component 1.2 aim to increase energy efficiency and increase 
the  energy  performance  of  the  building  sector,  and  are  coherent  with  enhancing  economic 
growth, creating job opportunities and promoting social resilience. The reform “Energy Poverty 
Action  Plan”  is  linked  with  the  investment  “Energy  renovation  on  residential  buildings”  as  it 
aims  to  provide  a  framework  for  the  energy  upgrade  of  the  residential  buildings  of  energy-

90 

 
 
vulnerable  households  and  other  social  groups.  The  reforms  and  investments  of  “Recharge  & 
Refuel”  under  component  1.3  aim  to  increase  sustainable  mobility,  enhance  economic  growth, 
create job opportunities and promote social resilience. The reform “E-mobility - Framework for 
installation  and  operation  of  EV  charging”  is  linked  with  the  investment  “Electromobility” 
aiming to provide legislative amendments towards the electrification of the Greek transportation 
sector.  The  reforms  and  investments  from  component  1.4  on  “Sustainable  use  of  resources, 
climate  resilience  and  environmental  protection”  aim  to  improve  sustainable  management  and 
are  coherent  with  the  protection  of  natural  environment,  the  development  of  the  circular 
economy and the enhancement of civil protection. 

The Greek plan also presents measures for the digital transition under components 2.1, 2.2 
and  2.3,  which  are  complementary  to  the  measures  under  the  public  administration 
(component  4.2),  research  and  innovation  (component  4.5),  as  well  as  modernising  key 
economic  sectors  (component  4.6)  components.  Measures  linked  to  digital  transformation 
reforms  and  investments,  together  with  simplified  taxation  system  are  also  coherent  and 
consistent with the better and more functional justice system (component 4.3) and strengthening 
the  financial  sector  and  capital  markets  under  component  4.4.  Measures  and  investment  under 
the former two components will contribute to improved business environment, creating friendlier 
conditions  for  the  investors  and  companies  by  modernising  procedures  and  institutional 
frameworks. Component 2.1 “Connect” presents the necessary reforms for the transition to fast 
broadband connections and pave the road towards 5G technology; and components 2.2 and 2.3 
aim to modernise the Greek public sector by improving its operational model, and achieving the 
provision  of  enhanced,  quality  services  to  citizens  and  businesses.  These  measures  coherently 
contribute  to  the  digital  transformation  of  the  public  sector  and  SMEs,  improving  business 
process,  increasing  interoperability  of  systems  and  data,  ensuring  cybersecurity  and  extending 
the use of advanced technologies such as cloud computing and big data. Socio-economic policies 
and measures, related to the labour market (component 3.1), job creation and education, training 
and skills (component 3.2), are complementary and go hand in hand with the green and digital 
transition.  For  instance,  there  are  measures  promoting  digital  skills  and  training  on  green 
transition,  such  as  on  circular  economy.  Those  will  notably  create  new  job  opportunities  and 
demand new skilled and educated citizens, which are issues covered with the measures under the 
respective components under pillar 3. 

Measures  and  policies from  the  digital  transition  and  modernising  business  environment, 
improving  competitiveness  and  promoting  private  investment  are  expected  to  create 
sustainable  and  better  growth  prospects.  They  are  also  coherent  with  the  health  and  social 
measures presented in the plan. Here it is worth mentioning the final component 4.7, which seeks 
to  reform  the  Greek  business  environment,  and  is  paired  with  the  provision  of  the  relevant 
financial  incentives  for  private  investment.  Those  will  simplify  the  business  environment  and 
upgrade its quality and safety, while at the same time ensuring targeted interventions, a business-
friendly  ecosystem  and  the  reduction  of  administrative  costs.  They  are  complemented  with 
financial incentives for private investments (the loans from the Recovery and Resilience Facility, 
utilised  in  ways  that  are  compatible  with  fiscal  sustainability  and  limit  exposure  to  taxpayers) 

91 

 
 
that  will  be  used  to  promote  investment  with  eligibility  firmly  grounded  on  economic 
foundations, including the green and digital economic transition.  

Conclusion 

Taking into consideration the qualitative assessment of all components of Greece´s recovery and 
resilience  plan,  their  individual  weight  (importance,  relevance,  financial  allocation)  and  their 
interactions,  the  plan  contains  measures  for  the  implementation  of  reforms  and  public 
investments which, to a high extent, represent coherent actions. This would warrant a rating of A 
under the assessment criterion 2.11 of Annex V to the RRF Regulation. 

92 

 
 
 
 
5.  ANNEX 

Table 9 Climate tracking and digital tagging 

Note: While the total cost of Greece’s Recovery and Resilience Plan exceeds the total allocation of non-repayable 
financial support and loans to Greece, Greece will ensure that all spending related to the measures mentioned in 
this table as contributing to climate objectives are fully financed by the funds from the Recovery and Resilience 
Facility. 

Climate 

Digital 

Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

16926 

16871 

16870 

16901 

16900 

16899 

16865 

16872 

Support of the installation 
of storage systems to 
enhance RES penetration 

Revitalization actions of the 
most affected 
territories_Nature and 
biodiversity protection 

Interventions for the 
electricity interconnection 
of islands and the 
upgrading of the electricity 
network 

HEDNO network upgrades 
aiming at enhancing 
resilience and protecting 
the environment 

HEDNO overhead network 
upgrading in forest areas 

Installed capacity increase 
in Hellenic Electricity 
Distribution Network 
Operator (HEDNO) 
HV/MV substations for 
new RES connection 

Restructuring and 
enhancement of the RES 
CHP Account revenues 

Energy renovation on 
residential buildings 

450 

033  

100% 

74 

050 

40% 

195 

033 

100% 

60 

037 

100% 

40 

037 

100% 

12 

028 

100% 

202 

028 

100% 

1 253 

025bis 

100% 

93 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16873 

16873 

16873 

16873 

16873 

16873 

16874 

16876 

Green Interventions - 
Interventions in residential 
areas and in the building 
stock_Adaptation and 
climate resilience measures 

Eleonas/ Votanikos - 
Interventions in residential 
areas and in the building 
stock_Energy efficiency 
measures 

Athens Reviera - 
Interventions in residential 
areas and in the building 
stock_Cycling 
infrastructure 

Other Strategic 
Interventions - 
Interventions in residential 
areas and in the building 
stock_Nature and 
biodiversity protection 

Other Strategic 
Interventions - 
Interventions in residential 
areas and in the building 
stock_Energy efficiency 
measures 

Other Strategic 
Interventions - 
Interventions in residential 
areas and in the building 
stock_Construction of new 
energy efficient buildings 

Energy and 
entrepreneurship 

Energy upgrade of public 
sector buildings 

160 

037 

100% 

116 

026 

40% 

44 

075 

100% 

31 

050 

40% 

77 

024ter 

100% 

47 

025ter 

40% 

450 

024ter 

100% 

200 

026bis 

100% 

94 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16875 

16932 

16879 

16831 

16924 

16924 

16924 

16898 

16849 

16846 

Infrastructure development 
and buildings’ restoration 
in former royal estate in 
Tatoi 

Olympic Athletic Center of 
Athens 

Preparation of Urban Plans 
in implementation of the 
urban policy reform 

Produc- E Green 

Charging Points – 
Electromobility_Alternative 
fuels infrastructure 

Electric busses – 
Electromobility_Clean 
urban transport: rolling 
stock 

Electric taxis - 
Electromobility_Battery 
driven vehicles 

Water Supply Projects 

National Reforestation Plan 
and Parnitha flagship 
investment 

Renovated infrastructure - 
Urban Wastewater and 
Sludge Management 

40 

026 

40% 

11 

026 

40% 

250 

036 

100% 

300 

80 

027 

077 

100% 

100% 

100 

074 

100% 

40 

N/A 36 

100% 

290 

224 

039bis 

40% 

037 

100% 

45 

041bis 

40% 

36 The ‘Methodology for climate tracking’ annexed to the Recovery and Resilience Facility Regulation (2021/241) does not set 
out  intervention  fields  that  would  allow  for  climate  or  environmental  tracking  of  electric  vehicles  or  plug-in  hybrid  vehicles, 
except for vehicles for urban transport falling under intervention field 074. According to Article 18(4)(e) of the Regulation, the 
methodology should however ‘be used accordingly for measures that cannot be directly assigned to an intervention field listed in 
Annex VI’. In this context, the Commission has applied a 100% climate contribution coefficient for zero-emission vehicles of all 
categories (this includes battery electric and fuel cell/hydrogen-powered vehicles). 

95 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16285 

16850 

16911 

16882 

16912 

16851 

16909 

16910 

16283 

16855 

16834 

Infrastructures from 
Wastewater 
Treatment_Compliant with 
energy efficiency criteria 

Investments in the national 
irrigation network through 
PPP schemes 

Drinking Water Supply and 
Saving Infrastructures 

Aerial means for crisis 
management 

Flood mitigation projects 

Forest firefighting, 
prevention and response 
equipment 

Biodiversity protection as a 
driver for sustainable 
growth 

Infrastructure - 
Establishment of a strategic 
National Disaster Risk 
Management 

Monitoring and 
Management System 

Implementation of Regional 
Civil Protection Centers 
(PEKEPP) through PPP 
schemes 

Small-satellites 

5G Corridors – Develop 5G 
networks that will provide 
coverage of all Greek 
motorways that are part of 
the Trans-European 

200 

040 

40% 

200 

039bis 

40% 

155 

036 

100% 

110 

115 

035 

036 

100% 

100% 

100 

050 

40% 

74 

036 

100% 

45 

036 

100% 

19 

025ter 

40% 

200 

160 

96 

055 

100% 

054bis 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16962 

16818 

16778 

16810 

16780 

16736 

16742 

16826 

16791 

16823 

16779 

16965 

16964 

Transport Networks 

Submarine fiber cables 

Fiber optic infrastructure in 
buildings 

Digitisation of archives and 
related services 

30 

131 

598 

CRM for the General 
Government 

Further Modernisation of 
Public Administration’s 
One-Stop Shops 

New system for Public 
Procurements 

Digital transformation of 
the Ministry of Foreign 
Affairs 

Digital skills upgrade 
programs for conscripts 

Digital Transformation of 
the Greek National Tourism 
Organisation 

Cybersecurity strategy and 
policies for the Public 
Sector & advanced security 
services for national critical 
infrastructures 

Interoperability and web 
services development 

Data Classification Studies 
for Public Sector’s 
Information Systems 

Next-Generation 
Interoperability Centre 

56 

19 

17 

49 

32 

8 

49 

72 

2 

3 

97 

051 

053 

100% 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

108 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Climate 

Digital 

16824 

16785 

16854 

16853 

16955 

16287 

16956 

16827 

16842 

16738 

16706 

16750 

16747 

(KED) 

ERegistries 

Tourism Registry e-MHTE 

Smart cities 

Supply of Central Cloud 
Computing Infrastructure 
and Service 

Upgrade of Cloud-
computing infrastructure 
and services of the National 
Infrastructures for Research 
and Technology (GRNET) 

Enhancement of Public 
Sector's Business 
Continuity 

Expansion of Syzefksis II 

Data Governance strategy 
& policies for the Public 
Sector 

Central BI - Data Analytics 

Central Document 
Management System 

Digital Transformation of 
SMEs 

Digital Transformation of 
Labour Systems 

Green skills, jobs, economy 
- Active Labour Market 
Policies 
Reform_Contributing to 
green skills and jobs and 
the green economy 

Coeff. 
% 

100% 

100% 

100% 

011 

011 

055 

24 

8 

73 

95 

011bis 

40% 

011bis 

100% 

63 

011bis 

40% 

011bis 

100% 

011 

100% 

011 

011 

011 

011 

100% 

100% 

100% 

100% 

010 

100% 

011 

100% 

39 

26 

26 

16 

5 

375 

77 

100 

01 

100% 

98 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Climate 

Digital 

Budget 
(EUR 
m) 

Int. 
field 

17 

690 

Coeff. % 

Int. field 

011 

108 

Coeff. 
% 

100% 

100% 

350 

01 

100% 

108 

026bis 

100% 

55 

01 

100% 

Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

OAED Digitalization 

A New Strategy for 
Lifelong Skilling: 
Modernising and 
Upgrading Greece’s 
Upskilling and Reskilling 
System_Digital upskilling 

Green skills, jobs, economy 
- A New Strategy for 
Lifelong Skilling: 
Modernising and 
Upgrading Greece’s 
Upskilling and Reskilling 
System_Contributing to 
green skills and jobs and 
the green economy 

Green Schools - 
Strengthening the 
Apprenticeship 
System_Energy efficiency 
renovation or energy 
efficiency measures 
regarding public 
infrastructure 

Labor force skilling, 
reskilling and upskilling 
through a reformed training 
model (Vocational 
Education & Training 
Reform)_Contributing to 
green skills and jobs and 
the green economy 

16942 

16913 

16913 

16794 

16792 

16676 

16755 

Digital transformation of 
Education 

365 

011 

100% 

Green investments - 
Reform of the Primary 
Health Care 
System_Energy efficiency 

189 

026 

40% 

99 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16795 

16752 

16793 

16925 

16763 

16611 

16616 

16291 

16705 

16940 

renovation or energy 
efficiency measures 
regarding public 
infrastructure 

NHS Hospital Renovation 
and Infrastructure Upgrade 

317 

026 

40% 

Digital Transformation of 
Health (DigHealth) 

278 

095 

100% 

Project for the construction 
of a building dedicated to 
Cellular & Gene Therapies 
and Hematology Clinic 
Laboratories within the 
General Hospital of 
Thessaloniki 
“Papanikolaou” 

Digital Transformation of 
the social support system 

Digital transformation of 
the immigration and asylum 
system 

Digital transformation of 
tax audits 

Adoption of measures and 
incentives to increase 
electronic transactions 

Digital Transformation of 
the Tax and Customs 
Administration 

Digital Transformation of 
Fiscal Management and 
Supervision in Governance 
& Electronic Invoicing 

Modernise the Hellenic 
Consignment Deposit and 

6 

025ter 

40% 

12 

42 

5 

0.5 

180 

102 

7 

100 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

011 

100% 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16292 

16292 

16727 

16733 

16581 

16654 

16975 

16960 

16960 

16960 

16959 

Loans Fund 

New Judicial 
Buildings_Construction of 
new energy efficient 
buildings 

New Judicial 
Buildings_Energy 
efficiency renovations 

Digital Transformation of 
Justice (E-Justice) 

Skills and digital skills for 
judges and judicial 
employees (judicial staff) 

Enhanced capital market 
supervision and 
trustworthiness 

TH 2 ORAX: Trellis 
Holistic & Hybrid 
Operational Ruggedized 
Autonomous eXemplary 
system 

Upgrade Interventions for 
Regional Ports 

69 

025ter 

40% 

27 

026 

40% 

81 

32 

12 

011quater 

100% 

108 

100% 

011 

100% 

50 

037 

100% 

011 

100% 

20 

081bis 

40% 

Smart Infrastructure with 
environmental and cultural 
focus_Digital sub-projects 

82 

011 

100% 

Smart Infrastructure with 
environmental and cultural 
focus_ Nature and 
biodiversity protection 

Smart Infrastructure with 
environmental and cultural 
focus_Air quality measures 

Digital Transformation of 
the Hellenic Railways 

65 

050 

40% 

27 

048 

40% 

24 

070 

40% 

070 

100% 

101 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16954 

16950 

16949 

16937 

16931 

16931 

16931 

16931 

16892 

16786 

Organization 

Interventions for the 
upgrade and redeployment 
of the Greek rail network 
system and infrastructure 

Electronic Tolls 

Smart Bridges 

Digital Integrated Program 
Management System for 
the Administration of the 
Technical Works and 
Structural Assets of the 
Ministry of Infrastructure 
and Transport 

Tourism 
Development_Energy 
efficient measures 

Tourism 
Development_Energy 
efficient measures for 
public infrastructure 

Tourism 
Development_Renewable 
energy (wind) 

Tourism 
Development_Energy 
efficient measures for 
public infrastructure 

Upgrading suburban 
railway of West Attica 

Simplification of the 
Procedures of the Ministry 
of Infrastructure & 
Transport 

130 

064 

100% 

90 

81 

10 

063bis 

40% 

063bis 

100% 

063 

011 

100% 

100% 

111 

024 

40% 

7 

026 

40% 

7 

1 

028 

100% 

026 

40% 

81 

073 

100% 

1 

011 

100% 

102 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16721 

16653 

16634 

16634 

16634 

16634 

16634 

16634 

16626 

16626 

16626 

Acceleration of smart 
manufacturing 

Digital Transformation of 
the Agri-Food Sector 

New Industrial 
Parks_Construction of new 
energy efficient buildings 

New Industrial Parks_ 
Water management and 
water resource conservation 

New Industrial Parks_ 
Waste water collection and 
treatment compliant with 
energy efficiency criteria 

New Industrial Parks_ 
Renewable energy (solar) 

New Industrial Parks_ 
Alternative fuels 
infrastructure 

New Industrial Parks_ 
Water management and 
water resource conservation 

Climate related - Economic 
transformation on the 
Agricultural Sector_Energy 
efficiency and 
demonstration projects in 
SMEs 

Climate related - Economic 
transformation on the 
Agricultural 
Sector_Renewable energy 
(solar) 

Climate related - Economic 
transformation on the 

75 

47 

010bis 

100% 

011 

100% 

7 

025ter 

40% 

4 

040 

40% 

25 

041bis 

40% 

5 

3 

5 

029 

100% 

077 

100% 

040 

40% 

62 

024 

40% 

35 

029 

100% 

7 

077 

100% 

103 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16626 

16599 

16593 

16593 

16584 

16536 

Agricultural 
Sector_Alternative fuels 
infrastructure 

Climate related - Economic 
transformation on the 
Agricultural 
Sector_Support to 
environmentally-friendly 
production processes and 
resource efficiency in 
SMEs 

170 

047 

40% 

Digitilization of Economic 
Diplomacy Network & 
Exporters Training Program 

10 

011 

100% 

45 

027 

100% 

40 

025ter 

40% 

35 

047 

40% 

3 

024bis 

40% 

Amendment of the legal 
framework for the 
attraction of strategic 
investment_Support to 
enterprises that provide 
services contributing to the 
low carbon economy 

Amendment of the legal 
framework for the 
attraction of strategic 
investment_Construction of 
new energy efficient 
buildings 

Proposals for actions in the 
Aquaculture Sector 

Upgrade of infrastructure, 
renewal of equipment and 
upgrade of quality of 
services provided by 
HOCRED Stores – former 
ARF Stores (On-spot and 
electronic) 

16486 

Museum of underwater 

54 

026 

40% 

104 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16433 

16293 

16980 

16980 

16980 

16980 

16980 

16980 

16980 

16980 

antiquities 

Protection of cultural 
monuments and 
archaeological sites from 
climate change 

Culture as a driver of 
growth 

RRP Loan Facility_Energy 
efficiency and 
demonstration projects in 
SMEs or large enterprises 

RRP Loan 
Facility_Renewable energy 
(solar) 

RRP Loan 
Facility_Renewable energy 
(wind) 

RRP Loan 
Facility_Commercial, 
industrial waste 
management 

RRP Loan Facility_Smart 
Energy Systems 

RRP Loan Facility_Support 
to enterprises that provide 
services contributing to the 
low carbon economy 

RRP Loan Facility_Other 
renewable energy 

RRP Loan 
Facility_Research and 
innovation processes 
focusing on the low carbon 
economy, resilience and 
adaptation to climate 

20 

037 

100% 

30 

026 

40% 

1 398 

024ter 

100% 

1 189 

029 

100% 

843 

028 

100% 

634 

044 

40% 

445 

033 

100% 

254 

027 

100% 

206 

032 

100% 

102 

022 

100% 

105 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure/Sub-
Measure ID 

Measure/Sub-Measure 
Name 

Budget 
(EUR 
m) 

Int. 
field 

Coeff. % 

Int. field 

Coeff. 
% 

Climate 

Digital 

16980 

16980 

16980 

16980 

16980 

16980 

16980 

16980 

change 

RRP Loan 
Facility_Renewable energy 
(biomass) 

RRP Loan Facility_Very 
High Capacity Networks 

RRP Loan 
Facility_Digitalisation of 
large entreprises 

RRP Loan Facility_ 
Digitalisation of SMEs 

RRP Loan Facility_Other 
ICT infrastructure 

RRP Loan 
Facility_Cybersecurity 

RRP Loan 
Facility_Advanced 
technologies 

RRP Loan Facility_Other 
ICT infrastructure 

47 

030 

40% 

912 

770 

330 

208 

120 

118 

89 

054 

100% 

010bis 

100% 

010 

100% 

055 

100% 

021quinquies 

100% 

021quater 

100% 

055 

100% 

Int. Field = intervention field 
Coeff. = Coefficient for the calculation of support to climate change objectives and to digital transition, 
on the basis of Annex VI and Annex VII to the RRF Regulation 

106