COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, September 2021 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance update - Greece, September 2021
Date: 2021-09-22
Institutions: Directorate-General for Economic and Financial Affairs, European Commission
Subjects: Euro Group (euro area), Greece, coronavirus disease, economic recovery, epidemic, gross domestic product, macroeconomics, multilateral surveillance, stability programme, structural adjustment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 22.9.2021  SWD(2021) 273 final  COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, September 2021 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance update - Greece, September 2021 {COM(2021) 598 final}  
 
 
STAFF WORKING DOCUMENT 

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

Commitment 

State of play and next steps 

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

Public financial management.  

Complete  the  chart  of  accounts  for  the  central  administration  by 
implementing  the  fund  and  functional  classifications  in  the  2022 
State budget by mid-2021. It is noted that the implementation of the 
fund classification is subject to a provision of technical assistance. 

Extend the Chart of Accounts reform to General Government entities 
by mid-2022. 

The  authorities  continue  to  provide  timely,  targeted  and  temporary 
support  to  the  economy,  the  re-opening  of  which  has  been  more 
gradual than assumed in April. According to the Council opinion on the 
Greece’s  2021  Stability  Programme,  the  measures  taken  by  Greece  in 
2020  and  2021  have  been  in  line  with  the  Council  Recommendation  of 
20 July 2020 (1). The General Escape Clause remains active in 2022. The 
General  Escape  Clause  allows  for  a  temporary  departure  from  the 
budgetary  requirements,  including  Greece’s  fiscal  targets  monitored 
under enhanced surveillance, provided that  this does not  endanger fiscal 
sustainability in the medium term.  

The implementation of the 1st level  of the functional  classification, a 
mid-2021 specific commitment, is on track for completion by October 
2021. The authorities are taking the necessary actions to complete the 1st 
level  of  the  functional  classification  by  October and  publish  it  in 
November  in  the  2022  budget.  In  addition,  a  simplified  version  of  the 
economic classification of the public investment budget will be published 
for the first time in the 2022 budget.  

The  authorities  have  also  started  developing  the  2nd  level  of  the 
functional  classification,  a  mid-2022  specific  commitment.  It  is 

(1) Council Recommendation of 18 June 2021 delivering a Council opinion on the 2021 Stability Programme of Greece, OJ C 304, 29.7.2021, p. 33–37. 

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Commitment 

State of play and next steps 

(*) Arrears.  

The authorities will implement the arrears  clearance plan  and  avoid 
the accumulation of new arrears. 

Complete  the  implementation  of  reforms  identified  by  the  Hellenic 
Court of Auditors. 

expected to be finalised in April 2022, in time for the annual update of the 
Medium Term Fiscal Strategy. A working group for the preparation of the 
2nd level of the functional was established in August with the participation 
of representatives from Hellenic Statistical Authority, Ministry of Finance 
and Ministry of Development and Investment.  

The target to materially clear the non-pension arrears by June 2021 
has  not  been  met.  According  to  July  data,  the  stock  of  the  net  non-
pension arrears amounted to €564 million, €274 million above the targets 
set in the updated clearance plan agreed with the European institutions in 
March  2021.  Broadly,  half  of  the  slippage  is  observed  in  local 
governments and extra-budgetary funds. This deviation can be attributed 
both to delays in implementing actions designed to accelerate the arrears 
clearance  such  as  granting  a  special  allocation  to  entities  with  liquidity 
constraints  and  to  the  accumulation  of  new  arrears  despite  the  effort  of 
supporting  their  liquidity  with  this  special  grant.  According  to  the 
authorities,  part  of  the  decrease  in  the  arrears  through  the  special  grant 
will be shown in the following couple of months. In addition, the defence 
industries,  continue  to  hold  a  high  stock  of  arrears.  The  authorities  are 
trying to address all the technical and legal issues in order to improve the 
liquidity of these defence companies and clear their arrears.  

The pension arrears stand above the target by €139 million. The stock 
in  July  reached  €359  million  which  falls  behind  the  monthly  target  of 
€221 million. This deviation is mainly explained by the delay in issuing 
the  Ministerial  Decision 
lawyers  and 
accountants  to  participate  in  the  process  of  issuing  pension  awards. 
Despite  the  delay,  the  authorities  reiterated  their  commitment  to  fully 
clear the pension arrears by end-2021. 

that  would  allow  certified 

The significant deviation from the targets, following shortly after the 

2 

 
 
Commitment 

State of play and next steps 

adoption of the new clearance plan, raises concerns. The divergence is 
observed  across  subsectors  and  cannot  be  fully  explained  by  unforeseen 
idiosyncratic factors. Delays stem notably from coordination deficiencies 
at  a  ministerial  level,  time-consuming  procedures  and  delays  in 
implementing actions which are expected to have a long-lasting effect in 
decreasing  arrears  such  as 
local 
governments.  The  current  delays  make  the  target  to  materially  clear  the 
stock of non-pension arrears, which was due in June 2021, challenging to 
be met  even by  end-September. The authorities  are invited to  accelerate 
the implementation of all actions that facilitate the arrears clearance and 
prevent  the  accumulation  of  new  ones,  in  order  to  avoid  any  future 
slippages from the agreed targets.  

incentive  mechanism 

the 

for 

The  vast  majority  of  reforms  identified  by  the  Hellenic  Court  of 
Auditors have been completed. Most of them relate to improvements in 
the  recording,  management  and  monitoring  of  the  accounting  systems, 
updates  of  the  IT  systems  and  improvements  of  the  human  resource 
these 
management.  The 
recommendations  are  mostly  big  entities  such  as  the  Independent 
Authority for Public Revenue, the Single Social Security Fund, hospitals 
and  ministries,  where  most  arrears  had  been  created  in  the  past. 
Therefore,  it  is  expected  that  the  implementation  of  these  reforms  will 
contribute significantly to the prevention of new arrears.  

responsible 

implement 

entities 

to 

Some  of  the  remaining  recommendations  are  in  progress  and  are 
expected to be completed in the coming period and by April 2022 at 
the  latest.  Most  notably,  the  recommendations  related  to  the  update  of 
Ministry of Development’s IT system (e-PDE) is planned to be finalised 
by  October 2021,  while  improvements  of  the  legal  framework  for  some 
types of tax arrears and interest paid, which are not clearly defined by the 

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State of play and next steps 

current  legal  framework,  are  expected  to  be  completed  by  April 2022. 
Despite  the  overall  good  progress,  some  of  the  recommendations 
concerning the defence industries, which hold a high stock of arrears, are 
behind  schedule.  The  authorities  are  expected  to  clarify  which  actions 
will be taken in order for these recommendations to be completed in time. 

Other reforms  recommended by the Hellenic Court of Auditors will 
be fulfilled and further broadened through ongoing wider structural 
reforms  included  in  Greece’s  recovery  and  resilience  plan.  These 
reforms,  most  notably  the  development  of  the  Single  Social  Security 
Fund’s  IT  system  in  the  context  of  the  digitalization  of  the  pension 
awards,  the  establishment  of  a  coherent  and  functioning  internal  control 
system  in  public  administration,  the  rollout  of  the  accrual  accounting 
reform in the general government entities and the development of new IT 
systems’  functionalities  of  certain  central  administration  entities  in  the 
context  of  new  central  government  IT  system  (GOV-ERP)  shall  be 
completed at a later date. These reforms will be monitored under Greece’s 
recovery  and  resilience  plan.  Finally,  some  of  the  reforms  became 
obsolete  such  as  the  recommendations  concerning  the  supplementary 
pension fund (ETEAEP) after it was incorporated in e-EFKA. 

Along  with  the  implementation  of  the  recommendations  by  the 
Hellenic  Court  of  Auditors,  the  working  group  responsible  for  the 
simplification  of  the  legislative  framework  for  the  conduct  of  fiscal 
procedures has concluded its work, which is expected to help further 
the  prevention  of  new  arrears.  The  report  prepared  by  the  group 
included proposals for reforming, updating, simplifying and codifying the 
legislative  framework  governing  the  fiscal  management  of  the  central 
administration.  The  proposals  address  the  recommendations  of  the 
International Monetary Fund technical support report published in March 

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State of play and next steps 

2020 (2). The authorities have prepared a timetable with a view to adopt 
the majority of the proposed actions by the end of the year while some of 
them  are  planned  to  be  implemented  earlier  by  October 2021.  The 
proposals  that  need  further  evaluation  and  coordination  with  other 
stakeholders are scheduled to be adopted before May 2022.  

The evaluation of the public financial management component of the 
internal control framework was completed. It concluded that the public 
financial  management  component  operates 
successfully,  having 
satisfactory levels of management and supervision. The main features of a 
functional  and reliable internal  control system for financial management 
are already in place, but can be further improved. For instance, one of the 
main  findings  was  the  parallel  use  of  a  variety  of  information  systems, 
which  creates  additional  administrative  burden  but  also  prolongs  the 
execution  of  procedures.  This  problem  is  expected  to  be  addressed  with 
the implementation of a new central government IT system (GOV-ERP), 
a project that is included in Greece’s Recovery and Resilience Plan. The 
evaluation  also  highlighted  the  need  to  ensure  appropriate  staffing  of 
financial services, including of specialized staff, and to develop a process 
of  identifying,  evaluating  and  dealing  with  the  risks  that  threaten  the 
achievement  of  the  objectives  set  in  annual  plans  issued  by  line 
ministries. Finally, the establishment and the operationalisation of internal 
control  units  in  line  ministries  is  on  track  for  completion  by  the  end  of 
September 2021.  

2  Some  of  the  legislative  proposals  concern  the  modification  of  the  institutional  framework  in  order  to  allow  the  payment  of  certain  types  of  costs  through  simplified 
procedures, the review of the framework of fixed advances and the adoption of modern payment methods (e.g. through the use of prepaid or debit cards), the revision of 
the  parameters for the approval of multiannual commitments, the possibility of granting  to legal entities part of the annual  grant at the beginning of the financial  year 
without the need to prior submit the annual report of the previous year. 

5 

 
 
                                                 
Commitment 

Tax administration. 

Reach  the  agreed  permanent  staffing  positions  at  the  Independent 
Authority of Public Revenue of 12 500 by  end-2019 and 13 322 by 
mid-2021. 

Make the end-to-end IT collection systems fully operational by mid-
2021. 

State of play and next steps 

The  supplementary  wage  grid,  a  key  element  of  the  overall  human 
resources  reform  for  the  Independent  Authority  of  Public  Revenue, 
which came into effect on 1 June 2021, has been successfully rolled-
out  to  a  significant  number  of  its  staff,  thus  completing  this 
complementary  commitment.  The  number  of  staff  of  the  Independent 
Authority remains well below the targets set, but has increased to 11 821 
at  the  end  of  June  2021  compared  to  11 736  in  March  2021.  The 
comprehensive human resources reform is expected to reverse the trend in 
the  medium  run  by  making  it  easier  for  the  Independent  Authority  to 
attract  and  retain  high  calibre  staff.  It  is  recalled  that  as  the  set  staffing 
targets  were  not  being  met,  the  authorities  agreed  to  undertake  three 
complementary  commitments,  namely  (i)  adopt  a  supplementary  wage 
grid  linked  to  job  descriptions;  (ii)  enhance  the  autonomy  of  the 
Independent  Authority  as  concerns  its  IT  system/resources;  and  (iii) 
moving  the  central  services  of  the  Independent  Authority  into  one 
location. The supplementary wage grid is now in place, while the Prime 
Minister announced plans in April 2021 of the construction of a Ministry 
Park  that  will  be  completed  by  2026  and  host  nine  Ministries  and  the 
Independent Authority in one single location.  

The  measures  to  ensure  autonomy  of  the  Independent  Authority  as 
concerns  its  IT  system/resources  will  be  implemented  in  the  context 
of Greece’s recovery and resilience plan. Specifically, the plan includes 
a measure to develop new IT tools for the Independent Authority. As part 
of this measure, one of the steps covers the development of a new service 
level  agreement  between  the  Independent  Authority  and  the  Ministry  of 
Digital  Governance (Directorate-General  for  Information Systems  of the 
Public Administration). It is noted that technical support will be provided 
by the European Commission for this specific action that is expected to be 

6 

 
 
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State of play and next steps 

completed by June 2022.  

IT  collection 

system,  a  mid-2021 

specific 
The  end-to-end 
commitment, is in a testing phase and the final system is expected to 
be  in  place  by  end-2021.  In  preparation,  a  number  of  staff  of  the 
Independent  Authority  has  received  training  on  the  new  IT  system,  in 
order  to  ensure  that  the  Independent  Authority  will  be  in  a  position  to 
fully utilise this new IT system once ready. 

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

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

As announced in the 10th report, the authorities adopted in May 2021 
the new property tax values based upon the nationwide revaluation, 
with the new values coming into effect for all property-related taxes 
in  January  2022.  Work  is  currently  being  undertaken  to  improve  the 
efficiency  and  fairness  of  the  ENFIA  tax  based  on  the  wider  tax  base. 
Legislation  is  expected  in  November  2021  with  the  2022  ENFIA  tax 
assessment expected to be brought forward to March 2022.  

The  clawback  collection  is  now  progressing  broadly  according  to 
schedule, following delays due to the pandemic. Collection resumed in 
the  past  months  and  is  now  progressing  almost  according  to  the  regular 
schedule, although the accumulated delay has not been absorbed yet. This 
is to some extent due to the collection method that relies on offsets, which 
requires  new  transactions  to  reclaim  the  clawback  amounts  from 
payments. Clawback collected under very long repayment plans (granted 
to  providers,  not  to  pharmaceutical  companies),  that  in  some  cases  will 
lead  to  a  full  clawback  repayment  only  after  10  years,  is  technically 
considered  as  being  collected.  However,  this  practice  deteriorates  the 
liquidity of the national health insurance body (EOPYY). 

Based  on  current  progress,  most  of  the  2020  clawback,  for  both 
pharmaceuticals  and  providers,  could  be  collected  by  end-2021. 

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State of play and next steps 

the 

the  authorities  have  collected 

Currently, 
first  semester  of 
pharmaceutical clawbacks for 2020, which was quantified at €795 million 
for  the  whole  year,  and  they  have  started  the  collection  of  the  second 
semester. The clawback for the second semester is lower than the one for 
the  first  semester,  which  reflects  the  effect  of  price  negotiations  and 
therapeutic  protocols,  as  well  as  the  exclusion  of  vaccines  from  the 
budget. For providers, the authorities have almost finalised the calculation 
and  communication  to  providers,  of  the  instalment  plan  for  the  2020 
clawback (€280 million), which allows to start  the collection procedure. 
They have also started the collection of the 2021 clawback based on the 
recently  legislated  methodology  that  will  allow  to  collect  70%  of  each 
year’s  clawback  on  a  rolling  basis  (with  the  remaining  30%  to  be 
collected over the following 12 months). 

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

The  authorities  are  further  advancing  with  the  revised  draft  of  the 
Primary  Health  Care  law,  despite  considerable  delays  due  to  the 
vaccination campaign. The campaign to vaccinate the population against 
Covid-19 is progressing and this is still absorbing considerable capacity. 
The work on the revised law is progressing, although key elements of the 
commitment such as gatekeeping and compulsory patient registration are 
still being defined. The authorities committed to submitting the draft law 
to public consultation by mid-October and to adopting it by end-2021. 

The authorities made progress on the number of doctors, which is a 
main  bottleneck  to  the  rollout  of  a  comprehensive  primary  health 
care  system  in  Greece.  According  to  the  information  provided  by  the 
authorities, a sufficient  number of new staff members were recruited by 
July to allow for the opening, over the coming months, of 50 new health 
units (the TOMYs), mostly in remote areas. However, the exact number 
of  newly  recruited  family  doctors  and  a  planned  timeline  for  the  new 

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State of play and next steps 

openings are not yet available.  

Health  care.  Achieve  a  40%  share  of  centralised  procurement  in 
total hospital expenditure by mid-2022. 

Social welfare. Apply to all disability benefits the new approach for 
disability  determination  based  on  both  medical  and  functional 
assessment. 

The  adoption  of  the  revised  legislative  framework  for  the  National 
Centralised  Health  Procurement  Authority  (EKAPY)  has  been 
postponed  to  the  next  review,  but  procurements  are  progressing. 
Despite  the  challenges  posed  by  the  pandemic,  progress  on  centralised 
procurement has so far been steady and the new legislative framework for 
the  centralised  procurement  body  was  finalised,  but  its  adoption  is 
planned for the next review, due to recent changes in the government. The 
new  framework,  now  submitted  to  Parliament,  introduces  innovations 
such  as  financial  incentives  supporting  the  achievement  of  procurement 
targets that are expected to facilitate the achievement of the 40% target by 
mid-2022. Meanwhile, after successfully achieving the 30% target due by 
the 10th review, procurement activities are progressing with the launch of 
additional tenders. 

The  authorities  are  advancing  with  the  adoption  of  the  primary 
legislation and are committed to completing secondary legislation by 
the  end  of  the  year,  allowing  for  the  use  of  the  functionality-based 
disability  assessment  system  to  assess  benefit  eligibility  for  the 
purpose  of  their  new  trial  Personal  Assistance  scheme  for  persons 
with disabilities. Following the public consultation process that ended on 
3 September, the authorities are about to submit to Parliament a draft law 
on social protection that, among others, introduces a Personal Assistance 
scheme for persons with disabilities where the new approach for disability 
determination  based  on  both  medical  and  functional  assessment  will 
apply as a rule. Secondary legislation to set out the details is expected to 
follow by the end of the year and the new functional assessment scheme 
will be used directly for in-kind benefit decisions from March 2022.  

Social  welfare.  Complete  the  set-up  of  the  single  pension  fund  The  openings  of  the  single  pension  fund’s  (e-EFKA)  directorates, 

9 

 
 
Commitment 

EFKA. 

(*)  Financial  stability.  Greece  will  continue  to  implement  reforms 
aimed  at  restoring  the  health  of  the  banking  system,  including  non-
performing  loans  resolution  efforts  by  ensuring  the  continued 
effectiveness  of  the  relevant  legal  framework  (i.e.  household  and 
corporate  insolvency,  out-of-court  workout,  non-performing  loans 
sales, e-auctions) and taking all necessary actions to this effect.  

Greece will implement the comprehensive action plan on household 
insolvency  with  the  objective  to  eliminate  the  backlog  of  cases, 
including the process of pending applications, by end-2021. 

The  decision  on  liquidation  or  extension  of  the  mandate  for  the 
Hellenic Financial Stability Fund will be taken by mid-2022. Greece 
will  continue  the  relaxation  of  capital  controls  in  line  with  the 
published roadmap. 

State of play and next steps 

which fully operationalise the merger of the many pre-existing small 
pension funds into a single national one, are progressing according to 
schedule.  According  to  the  timetable,  e-EFKA  directorates  openings 
reached 60 during the month of August, after which openings are planned 
at 15 per month. A slight delay was due to a change in the management of 
e-EFKA,  which  now  has  a  new  governor,  however,  the  pace  of  new 
openings has increased and, based on current progress, the finalisation by 
March 2022 was confirmed as feasible.  

The  initial  signs  from  the  use  of  the  new  insolvency  framework  are 
encouraging  but  it  is  too  early  to  assess  the  effectiveness  of  the  new 
process.  The  new  Insolvency  Code  has  fully  entered  into  force  as  of 
1 June  2021.  By  end-August,  practically  all  of  the  necessary  secondary 
legislation had been published or was pending publication in the Official 
Journal,  with  the  exception  of  8  ministerial  decisions  that  concern  the 
early  warning  mechanism  and  the  sale  and  lease-back  mechanism. 
Moreover,  a  number  of  amendments  to  the  text  of  the  new  Insolvency 
Code were adopted and  published on 18 July, aiming at  completing and 
clarifying  specific  provisions  of  the  law  to  ensure  its  unhindered 
implementation (3).  Work  on  the  relevant  IT  infrastructure,  which 
involves  the  out-of-court  workout,  the  insolvency  register  and  the 
vulnerable debtors’ verification electronic platforms, has been completed 
on  time  and  the  platforms  are  operational.  A  second  phase  of  work, 
allowing for the fully automated handling of applications by creditors and 
the operationalisation of the early warning  IT platform, is  planned to  be 
completed by the end of September 2021. The new out-of-court workout 
has  attracted  strong  interest,  with  23 996  active  applications  for  which 

3 Law 4818/2021 (OJ A 24/18.07.2021), articles 34-38. 

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State of play and next steps 

data  have  been  requested  from  institutional  creditors  as  of  end-August, 
corresponding predominantly to debtors with at least one non-performing 
loan. 

The  concessionary  process  for  the  setup  of  the  sale  and  lease-back 
entity has been further delayed, although this does not seem to have 
affected  the  implementation  of  the  other  aspects  of  the  insolvency 
framework.  Following  the  initial  delay,  due  to  the  reflection  of 
procedural  steps  in  line  with  legal  requirements  for  concessions,  further 
time was needed to conduct a public consultation on the draft request for 
proposals and start the consultation with the statistical authorities on the 
interplay  between  the  design  of  the  new  entity  and  its  statistical 
classification, which will be a key factor for the determination of the cost 
of the scheme. Under the revised time plan, the five ministerial decisions 
related  to  the  sale  and  lease-back  mechanism  will  be  drafted  by  end-
February  2022  and  adopted  by  early-April  2022,  while  the  entity  is 
expected to  be in  place  by  end-September 2022, following a three-stage 
concessionary  process.  According  to  the  relevant  provision  of  the 
Insolvency Code, the procedures for the protection of vulnerable debtors 
under  the  sale  and  lease-back  mechanism  will  commence  upon  its 
operationalization.  

The  processing  of  the  backlog  of  household  insolvency  cases,  an 
end-2021 specific commitment, has resumed but is likely to take longer 
than  initially  expected,  on  account  of  several  months  of  court 
suspensions  related  to  the  pandemic  and  a  low  case-processing 
capacity  in  a  number  of  courts.  Up  to  end-August,  new  hearing  dates 
had  been  appointed  for 
just  7.5%  of  almost  50 000  submitted 
applications. This unsatisfactory situation is partly attributable to reasons 
linked to the pandemic, but it is also related to the limited case-processing 

11 

 
 
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State of play and next steps 

capacity  in  courts.  The  pandemic  led  the  authorities  to  authorise  all 
parties  requesting  a  new  hearing  date  to  file  a  request  by  15 July  2021, 
irrespective  of  the  initial  date  of  expiry  of  their  right  to  do  so.  The 
authorities presented this step as an extraordinary measure to address the 
unforeseen  disruption  caused  by  the  pandemic,  stating  that  they  do  not 
intend  to  proceed  to  any  further  extension  henceforth.  Given  that  the 
appointment  of  a  new  hearing  date  can  only  be  made  75  days  after 
validation of the request by the court, and keeping in mind that deadlines 
in  most  areas  of  Greece  had  been  suspended  until  5 April  2021,  the 
setting of new hearing dates would have begun at the earliest by end-June 
2021 for most cases. Under the circumstances, the end-2021 deadline for 
the  specific  commitment  for  processing  the  backlog  is  no  longer 
attainable. While the European institutions encouraged completion of the 
commitment  by  April  2022,  the  specific  date  can  only  be  determined  in 
the  next  enhanced  surveillance  report,  based  on  data  for  the  number  of 
still  pending  cases  to  be  provided  by  the  authorities.  Finally,  the 
authorities  plan  to  enact  by  end-September  2021  a  Joint  Ministerial 
Decision making mandatory the uploading of new hearing dates onto the 
relevant electronic platform. 

While the revised Code of Civil Procedure will facilitate the conduct 
of  e-auctions  and  other  enforcement  proceedings,  the  deferral  of  its 
adoption and entry into force will delay its expected positive impact. 
Originally  projected  for  operationalization  at  the  beginning  of  the  new 
judicial  year in  mid-September and despite repeated reassurances by the 
authorities regarding adherence to schedule, the Code is now expected to 
be  adopted  by  30 September,  with  a  projected  entry  into  force  on 
1 January 2022. With respect  to  enforcement proceedings, the new draft 
Code is expected to introduce a system for the automatic adjustments of 
the  reserve  price  (initial  and  subsequent)  of  properties  following  an 

12 

 
 
Commitment 

State of play and next steps 

unsuccessful auction and will allow several prospective purchasers to bid 
in common for properties. These are welcome elements, as they will (a) 
remove  the  element  of  arbitrariness  in  revising  the  reserve  price  (thus 
increasing the effectiveness of the auction process and alleviating the case 
burden  of  courts)  and  (b)  encourage  the  pooling  of  resources  of  several 
bidders in view of the acquisition of high-value properties. Beyond these 
changes, the new draft Code is also expected to introduce enhancements 
aiming  at  accelerating  the  conduct  of  trials,  by  further  streamlining 
procedures  and  integrating  and  broadening  the  use  of  IT  by  courts  and 
legal  professionals.  It  is  also  expected  to  introduce  the  feature  of  pilot 
trials in civil justice. 

An  additional  work  stream  has  been  launched  with  respect  to 
increasing  the  efficiency  of  procedural  aspects  of  the  conduct  of  e-
auctions  of  debtors’  property.  Following  the  recent  introduction  of 
enhanced  features  to  the  platform  (such  as  photographic  data  and 
valuation  reports),  as  well  as  the  establishment  of  a  firm  deadline  for 
redressing building permit transgressions, the authorities have set up two 
working  groups  entrusted  with  formulating  proposals  for  further 
simplifying  and  streamlining  the  methods  for  producing  accurate 
valuations  of  properties.  The  working  groups  intend  to  propose  changes 
aligning valuation criteria with best international practices (first working 
group)  and  enabling  judicial  bailiffs  to  access  information  available  on 
the  e-property-transfer  tax  platform,  as  well  as  a  number  of  other 
parameters  from  other  public  registries  affecting  the  valuation  of  the 
property (second working group). The first working group is expected to 
submit  its  proposals  by  end-November  2021  and  the  relevant  measures 
would be adopted by mid-April 2022; information on the progress of the 
second  working  group  will  be  made  available  in  the  course  of  the  next 
enhanced surveillance mission. The authorities were encouraged to make 

13 

 
 
Commitment 

State of play and next steps 

the  above-mentioned  information  readily  accessible  to  prospective 
purchasers  through  the  e-auction  platform,  in  order  to  increase  its 
transparency and facilitate the assessment of the auctioned properties. 

The  clearance  of  the  backlog  of  called  state  guarantees  remained 
delayed in the second quarter of 2021 but recent data have provided 
encouraging  signs  of  an  acceleration.  Although  new  staff  has  been  in 
place  since  early  April  2021,  the  time  needed  for  training  did  not  allow 
for  a  satisfactory  pace  of  clearance  before  June  2021,  with  actual 
payments  falling  short  of  the  second  quarter  target  by  84%.  The  overall 
target for 2021 has therefore been revised downwards by 43%. The new 
target also reflects a slower roll-out of the planned hiring of 30 additional 
new  permanent  staff,  which  is  not  expected  to  take  place  earlier  than 
November 2021. Despite this downward target revision and a much better 
pace of clearance in the period June-July, meeting the revised targets set 
for 2021 remains challenging. This revision of the intermediate targets is 
not  expected  to  affect  the  overall  target  of  full  examination  of 
accumulated  called  loan  guarantees  by  mid-2023  for  natural  persons’ 
claims and by the third quarter of 2022 for corporate claims.  

The necessary secondary legislation to ensure full  operationalisation 
of  the  deferred  tax  credits  framework  was  adopted  in  July  2021, 
while  the  relevant  primary  law  will  be  amended  shortly  to  further 
facilitate  securitisations  and  sales  of  non-performing  loans.  The 
adoption  of  the  relevant  secondary  legislation  is  a  welcome  step,  as  it 
safeguards the loss-absorbing capacity of the banks’ capital in  all  cases, 
including  in  the  context  of  resolution  and  special  liquidation.  The  new 
framework  has  been  activated  by  a  less-significant  credit  institution, 
which has registered annual losses on a solo basis, triggering conversion 
of  deferred  tax  credits.  At  the  same  time,  the  expected  amendment  of 

14 

 
 
Commitment 

State of play and next steps 

article  27  of  law  4172/2013  will  enable  the  acceleration  of  sales  and 
securitisations of non-performing loans by smoothening the amortisation 
of the related deferred tax assets, while preserving their recoverability for 
the originating credit institutions. The European Central Bank has issued 
a  formal  opinion  on  the  amendment,  following  a  request  by  the  Greek 
authorities. 

The  recent  destructive  fires  have  led  to  relief  measures  for  fire-
stricken debtors. A six-month suspension of all enforcement actions on 
both  movable  and  immovable  property  has  been  granted  for  affected 
debtors,  in  application  of  Law  4797/2021  for  State  support  in  natural 
disasters.  This  may  delay  a  more  comprehensive  assessment  of  the 
effectiveness of the upcoming enhancements to the e-auctions framework. 
Moreover,  banks  may,  on  a  voluntary  basis,  provide  a  payment 
moratorium of up to six months for all performing debt of debtors whose 
primary  residence  or  business  premise  has  been  damaged  by  the  fires, 
subject to an assessment of the debtor’s relevant application. 

Discussions  have  started  on  the  future  of  the  Hellenic  Financial 
Stability  Fund.  A  legal  amendment,  touching  upon  the  duration, 
governance, divestment  strategy and special rights  of the Fund, is  under 
preparation, with the aim to be adopted by October 2021. 

The  procedure  for  updating  the  statutory  minimum  wage,  put  on 
hold following the outbreak of the pandemic, was completed leading 
to a 2% increase in its level as of 1 January 2022. The process involved 
consultations with research, scientific and social partners and their review 
by five independent economic experts set by the Ministers of Labour and 
Social Affairs, Finance and Development. The outcome of the process led 
the government  to  decide on increasing the statutory minimum  wage by 
2% (from €650 to €663 per month) as of 1 January 2022. All material of 

15 

(*) Labour market: Greece will safeguard competitiveness through 
an annual update of the minimum wage in line with the provisions of 
Law 4172/2012. 

 
 
Commitment 

State of play and next steps 

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

Investment licensing. Greece will finalise inspection legislation. 

the consultation  process  was made publicly  available by the Ministry of 
Labour and Social Affairs as envisaged by the legislation.  

Despite  long  delays  in  the  tendering  procedure,  the  contract 
regarding  the  full  deployment  of  the  relevant  IT  system  to  support 
the  investment  licensing  framework  was  recently  signed,  thus 
fulfilling this specific commitment. Given the size of the project and the 
anticipated length of the tendering procedure, it was agreed at the launch 
of  enhanced  surveillance  monitoring  that  the  commitment  would  be 
assessed  on  the  basis  of  the  conclusion  of  the  relevant  tendering 
procedure and the drawing of a 34-month implementation timeline for the 
completion  of  the  project,  which  was  included  in  the  tender  documents. 
The preparatory work for the development of the project is underway. 

The authorities completed the reform in two out of the three priority 
areas,  namely  food safety  and  product  safety,  whilst progress  in  the 
last  area,  i.e.  environmental  protection,  is  slower  than  expected 
mainly  on  account  of  ongoing  wider  environmental  reform 
undertaken and the highly technical nature of the work that remains 
to be completed. Specifically, the authorities recently adopted secondary 
legislation to set in force the remaining part of the complaint management 
model  on  the  safety  of  non-processed  food,  thus  fully  completing  the 
reform  in  the  area  of  food  safety.  As  regards  environmental  protection, 
which  was  due  to  be  completed  by  end-May  2021  according  to  the  10th 
enhanced surveillance report, the authorities drafted primary legislation to 
amend sanctions and enforcement powers of inspecting authorities. Work 
on secondary legislation to detail the enforcement management model in 
line  with  EU  best  practices  and  to  be  used  as  a  guide  to  inspectors’ 
decisions is also ongoing. The said legal texts are expected to be adopted 
by  October  2021.  As  agreed  at  the  launch  of  enhanced  surveillance 

16 

 
 
Commitment 

State of play and next steps 

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

monitoring,  and  considering  the  wide  scope  of  the  reform,  the 
commitment is assessed on the basis of completing the inspections reform 
in the said three priority areas.  

The  roll-out  of  the  reform  in  the  remaining  four  areas,  namely 
consumer  protection,  occupational  health  and  safety,  safety  of 
infrastructures,  and  public  health,  which  go  beyond  the  specific 
commitment,  will  be  further  followed  up  under  Greece’s  recovery 
and resilience plan.  

Progress is recorded on the simplification of legislation in the agreed 
sectors.  Following  the  set  of  simplified  licensing  legislation  adopted  in 
April  2021,  the  authorities  adopted  further  primary  legislation  in  June 
2021  to  reform  the  licensing  of  economic  activities  in  all  agreed 
remaining  sectors.  Further,  they  also  drafted  primary  legislation  to 
simplify the economic activities relating to education that have not been 
included in the scope of the previous simplification round, with a view to 
adopting it shortly.  

At the same time, the  authorities have been proceeding more slowly 
with  the  adoption  of  secondary  legislation,  which  is  necessary  to 
make  the  new  provisions  of  the  above-mentioned 
laws  fully 
operational.  Specifically,  while  the  first  batch  of  joint  ministerial 
decisions concerning the April legislation has been put  in  place, the full 
adoption  of  the  second  and  third  batches,  in  addition  to  secondary 
legislation  acts  concerning  the  June  legislation,  is  slightly  behind 
schedule  and  expected  to  be  adopted  shortly.  Similarly,  secondary 
legislation  concerning  the  education  activities  is  expected  to  be  adopted 
by end-October- 2021. 

It is welcome that the authorities issued, in July 2021, the presidential 

17 

 
 
Commitment 

State of play and next steps 

Cadastre.  Greece  will  fully  establish  the  cadastral  agency  and 
complete  45%  of  cadastral  mapping  by  end  2021,  with  a  view  to 
ratifying  the  complete  cadastral  mapping  and  forest  maps  by  mid-
2022. 

decree  for  the  creation  of  the  registry  of  certified  external 
environmental assessors.  This  is  a key step towards the deployment  of 
private  resources  in  the  environmental  licensing  process,  and  a  pending 
requirement since the end of the third programme. 

The  implementation  of  the  road  map  for  the  implementation  of  the 
cadastre  project  progresses  satisfactorily.  The  corporate  strategy  has 
been approved by the governing board and is under implementation. The 
IT  strategy  has  also  been  completed.  The  contract  with  the  World  Bank 
was  signed  on  30  June.  The  opening  of  cadastral  offices  progresses 
steadily  with 
the 
corresponding  mortgage  offices  are  closing  down.  As  of  the  end  of 
August,  there  are  9  cadastral  offices  in  operation  and  28  branches.  The 
objective of having 44 cadastral offices and branches (out of a total of 95) 
in operation by October 2021 and 50 in December 2021 is in reach. 82% 
of the total property rights of the country have been collected until  end-
August and are in operation or being processed.  

two  new  offices  per  month.  Consequently, 

Regarding forest maps, the recent legislation extending by six months 
the period in which citizens may raise objections resulted in a delay 
of the ratification of the remaining 50% of maps. The authorities’ view 
is  that  the  corrections  that  were  recently  made  to  include  administrative 
acts  that  clarify  the  forestry  legislation  in  some  areas  –  in  particular  in 
islands  in  the  southern  part  of  the  country  –  where  grassland  was 
registered  as  forest,  will  improve  the  quality  of  maps  and  reduce 
objections. The ratification of the remaining maps will start at the end of 
the  year  and  is  expected  to  be  completed  by  April  2022,  in  accordance 
with the revised road map. It is estimated that by that date, 90-95% of the 
territory  will be covered by  ratified maps. The delay in  ratification does 
not  impede  the  completion  of  the  cadastre  as  the  Council  of  State  has 

18 

 
 
Commitment 

State of play and next steps 

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

(*)  Hellenic  Corporation  of  Assets  and  Participations  (HCAP). 
The  Strategic  Plan  of  HCAP  will  be  implemented  on  a  continuous 
basis. 

recently  adjudicated that the completion of the forest  maps is  not  a pre-
condition  for  the  operation  of  the  cadastre  and  that  forest  maps  may  be 
drawn in parallel. 

The authorities have adopted a new law on the cadastre. The objective 
of this law is  the acceleration of the cadastral  mapping by including the 
objections period in the operation of the cadastre, making the objections 
visible to all interested parties and gaining substantial time. Another part 
of the law concerns the upgrading the internal organisation and operation 
of  the  Hellenic  Cadastre  and  a  third  part  is  the  introduction  of  the 
“Electronic  Real  Estate  Transfer”  system,  a  novelty  aiming  to  simplify 
and significantly reduce the total duration of the property transfer process 
and thus improve Greece’s position in the World Bank’s Doing Business 
indicator. 

A final text for the remedy has been agreed with the authorities and 
was  made  binding  on  the  Hellenic  Republic  by  a  Commission 
Decision.  Following  the  implementation  of  the  necessary  legislative 
measures into Greek law, and the adoption of all necessary regulatory and 
corporate measures, the first milestone under the remedies is expected to 
be  accomplished  by  28  September  2021,  thus  completing  this  specific 
commitment. 

The  Corporation  intensified  the  work  on  the  update  of  its  strategic 
plan. Two strategy workshops were held in late June and early July 2021 
for the members of its Board, with a view to clarifying the Corporation’s 
responsibility as an active shareholder in terms of the engagement of the 
Corporation  in  the  state-owned  enterprises.  The  Corporation  has  also 
launched  a  consultation  process  with  the  Boards  of  Directors  of  its 
subsidiaries  regarding  its  strategic  plan.  The  completion  of  the  strategic 

19 

 
 
Commitment 

State of play and next steps 

plan is expected by end-October.  

the  Coordination 
The  Steering  Committee  envisaged  under 
Mechanism intensified its work on the preparation of a performance 
contract  for  the  Athens  Urban  Transport  Organisation  (OASA). 
Following  the  agreement  reached  on  the  detailed  list  of  special 
obligations to be subject to the performance contract, the Committee has 
reached  an  agreement  on  the  methodology  to  estimate  the  amount  of 
compensation for the assumption of special obligations. The performance 
contract  is  expected  to  be  finalised  by  end-October.  The  performance 
contract will be a further important step forward in clarifying the financial 
contribution  of  the  State  to  public  policy  costs,  and  toward  the  Athens 
Urban  Transport  Organisation’s  operational  improvement,  independence 
and financial sustainability.  

The Corporation will need more time for the conclusion of the work 
of identifying legal and other impediments to the effective operation 
of the state-owned enterprises in its portfolio.  The elimination of key 
impediments  is  part  of  an  overall  mind-set  shift  towards  ensuring  that 
state-owned  enterprises  under  the  Corporation  become  commercially 
oriented  and  financially  self-sufficient  operations,  and  do  business  in  a 
customer-centric  way  and  in  line  with  private  sector  principles.  This 
mind-set  shift  also  implies  a  degree  of  commercial  risk  taking  and  risk 
management,  and  proactive  and  autonomous  decision-making  in  the 
corporate  interest  and  in  pursuit  of  each  state-owned  enterprise’s 
mandate. The authorities have confirmed their strong support for pursuing 
this  measure,  which  is  consistent  with  the  more  general  project  for 
reforming  the  framework  applicable  to  state-owned  enterprises  set  out 
below.  The  Corporation  has  sought  input  from  its  portfolio  companies 
and  committed  to  prepare  a  more  comprehensive  list  of  the  e  necessary 

20 

 
 
Commitment 

State of play and next steps 

changes  by  end-October.  The  authorities  have  engaged  from  an  early 
stage with the institutions on these initiatives, which is very welcome. 

The  authorities  continued  the  work  on  the  modernisation  of  the 
institutional framework for state-owned enterprises. Over the past two 
months, the authorities embarked on mapping the state-owned enterprises 
and  other  public  entities  into  6  main  categories  based  on  a  number  of 
fiscal 
criteria, 
consideration  and  board  appointment  procedures.  Following 
the 
completion  of  the  mapping  exercise,  the  authorities  will  prepare 
recommendations  for  each  category  of  enterprises  with  a  view  to 
enhancing  the  state-owned  enterprises'  efficiency  and  performance,  and 
rationalising the State's participation.  

the  state’s  participation, 

the  share  of 

including 

The Public Real Estate Company (ETAD) is expected to elaborate a 
comprehensive strategy to achieve an ambitious target yield across its 
portfolio  the  soonest  possible.  While  some  projects  at  the  Public  Real 
Estate Company are progressing, an overall approach to delivering value 
from  the  whole  portfolio  and  attempts  to  achieve  a  step-change  in  the 
Company’s  performance  have  not  produced  systemic  results.  The 
problems at Public Real Estate Company appear significant. Turning this 
situation around, and delivering value from the real estate portfolio, is a 
critical responsibility of the Corporation. 

With regard to the transfer of the eligible real estate assets included 
in the 2018 package to the Public Real Estate Company, following the 
completion  of  the  screening  process  by  the  General  Secretariat  for 
Tax  Policy  and  Public  Property,  a  more  detailed  review  by  each 
relevant  Ministry  is  planned.  Following  this  exercise,  a  final  list  of 
assets  for  transfer  will  be  developed.  The  authorities  are  expected  to 

21 

 
 
Commitment 

HCAP.  Complete  the  transfer  of  the  Olympic  Athletic  Centre 
(OAKA) to HCAP. 

State of play and next steps 

clarify the timetable for the process. 

The  authorities  continued  with  the  development  of  the  master  plan, 
which is close to its finalisation. The details of the future of the facility 
will be worked out as part of subsequent processes. With the assistance of 
external consultants, the authorities are preparing feasibility and financial 
studies  that  are  expected  to  be  completed  by  the  end  of  the  year,  and 
which  will  provide  input  to  ensuring  the  financial  sustainability  of  the 
facility. The financial sustainability of the facility is essential to guarantee 
a high-quality civic facility for the Greek public over the long term. 

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

The  Government  Pending  Actions  List  was  updated  by  the  Fund  in 
June 2021. 

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

commercial, 

the 

By  mid-2021,  complete  the  transactions  on  the  regional  ports 
Igoumenitsa  and  Kerkyra,  PPC,  DEPA  infrastructure  and  Kavala 
underground storage. 

By  mid-2022,  complete  the  transactions  on  a  number  of  other 
regional  ports,  based  on  the  recommendations  of  the  consultants  of 
TAIPED. 

Progress  with  specific  transactions  since  the  last  report  has  been  as 
follows: 

Hellinikon:  The  agreement  for  the  transfer  of  the  shares  from  the 
Hellenic Republic Asset Development Fund (Seller) to Hellinikon Global 
(Buyer) was signed on 25 June 2021, achieving the financial conclusion 
of the transaction. Within this framework, the Fund received on 25 June 
2021 the amount of €300 million as the first instalment payment out of a 
total  financial consideration  of  €915 million.  Prior to  that, all remaining 
pending  legal  cases  were  resolved  via  relevant  decisions  issued  by  the 
Council  of  State  on  16  June  2021,  whereas  the  two  main  contracting 
parties, i.e. the preferred investor and the Fund, with a view to preventing 
further delays, agreed on 16 June 2021 to waive the condition precedent 
with regard to the casino licence.  

Egnatia: Good progress was made in the tender process for the long-term 
concession of Egnatia over the past months. Following the rejection of the 

22 

 
 
 
Commitment 

State of play and next steps 

application for interim measures, the Fund proceeded with the unsealing 
and review of the technical  offer, whereas the unsealing of the financial 
offers  took  place  on  15  July  and  the  selection  of  the  preferred  investor 
was  made  on  26  August  for  a  financial  consideration  comprising  of  an 
upfront payment of €1.4961 billion and an annual payment amounting to 
7.5%  of  the  annual  total  gross  revenue  of  the  concessionaire.  A  fourth 
cluster of 8 lateral toll stations was put in operation in July, whereas the 
remaining 7 lateral and one frontal toll stations are expected to be put in 
operation  in  the  coming  months.  The  pending  works  for  most  of  the 
tunnels  have  progressed  further,  whereas  the  licensing  of  the  remaining 
16 tunnels to category E (i.e. excluding the transport of dangerous cargo) 
is  planned  to  be  completed  before  the  concession  commencement  date 
expected in late 2022. Close monitoring will continue. 

Regional  ports  of  Alexandroupolis  and  Kavala:  The  Fund,  in 
cooperation  with  the  Ministries  of  Finance  and  Shipping,  proceeded  to 
drafting  (a) the  Concession  Agreement for  the  port  of  Alexandroupolis, 
and (b) for the Sub-Concession Agreement for the port of Kavala, and the 
drafts are expected to be given for comments to the prequalified investors 
of  each  tender  respectively  in  the  coming  weeks.  However,  there  is  a 
pending issue that needs to be resolved before proceeding to the binding 
offers phase for the port of Alexandroupolis, namely the conclusion of the 
expropriation of private properties in the upland zone area of the port; the 
amounts concerned for the compensation of the expropriated land are to 
be determined by the competent courts, and this could lead to a delay of 
the transaction.  

Regional port of Igoumenitsa: The Fund drafted the Sale and Purchase 
Agreement  and  the  Shareholders  Agreement  and  the  specific  documents 
were given to the prequalified investors in the tender at the end of July for 

23 

 
 
Commitment 

State of play and next steps 

comments.  The  Concession  Agreement  document  is  expected  to  be 
finalised  in  the  coming  weeks  and  it  will  be  subsequently  given  to  the 
pre-qualified  investors.  The  pending  issue  on  the  determination  of  the 
zone  of  Igoumenitsa  port,  which  will  be  subject  to  the  concession 
agreement,  is  expected to be resolved in  the coming weeks and thus  the 
tender process can proceed.  

Regional port of Heraklion: The tender process is proceeding. Interested 
parties submitted their expression of interest on 17 September 2021. 

Public Gas Corporation (DEPA) Infrastructure: The tender process is 
proceeding  well.  The  pending  issues  have  been  resolved  with  the 
ratification  of  the  required  law  amendments,  on  29  June,  which  provide 
further  clarity  on  the  framework  for  the  operation  of  the  distribution 
system operators. Binding offers were submitted by two investor schemes 
on  15  July  2021,  whereas  the  selection  of  the  preferred  investor  took 
place on 9 September 2021 for a financial consideration of €733 million. 
This corresponds to about €476 million for the 65% stake of the Fund in 
DEPA Infrastructure.  

Public  Gas  Corporation  (DEPA)  Commercial:  The  Fund  decided  to 
suspend  the  Binding  Offers  Phase  of  the  tender  at  least  until  end-
September  2021,  so  as  to  have  more  clarity  on  the  outcome  of  pending 
issues. 

Underground  Natural  Gas  Storage  (UGS)  South  Kavala:  Following 
the  assessment  of  the  Investors  Expressions  of  Interest,  two  interested 
parties prequalified for the Binding Offers Phase. Based on the envisaged 
timeline of the tender, submission of binding offers is expected in the first 
quarter of 2022. The authorities plan to clarify the regulatory framework, 
including  the  tariff  setting  framework,  in  advance  of  the  binding  offers 

24 

 
 
Commitment 

State of play and next steps 

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

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

Complete  the  National  Gateway  for  Codification  and  Reform  of 
Greek Legislation by mid-2022. 

date.  

As reported in the previous reports, some transactions had to be delayed 
following a significant fall in the assets’ capitalisation value or the impact 
of  the  pandemic  on  the  level  of  economic  activity.  This  applies  to  the 
Hellenic Petroleum and the sale of 30% of Athens International Airport. 

A  link  between  a  job  description  and  a  jobholder  has  been 
established for close to all occupied posts (97.6%), which constitutes 
an  important  step  towards  the  establishment  of  an  integrated  HR 
Management  System.  The  successful  completion  of  this  exercise  will 
facilitate the management of human resources in the public administration 
through  interconnecting  the  records  on  each  jobholder  in  the  census  of 
public  officials,  the  Single  Payment  Authority  and  the  human  resources 
departments.  Furthermore, 80% of all job  descriptions are planned to  be 
completed by end-October, up from 71% at end-August, and all posts are 
planned  to  have  an  assigned  job  description  by  end-2021,  which  would 
complete this specific commitment. Finally, the appointment process for 
the Permanent Secretary post at the Ministry of Education and Religious 
Affairs  remains  ongoing.  The  authorities  are  expected  to  complete  the 
process the soonest possible. 

labour 

Following  the  adoption  of  the 
legal 
codification of the Labour Law Code and Code of Labour Regulatory 
Provisions  is  now  progressing  and  the  initial  draft  is  expected  to  be 
submitted to the Central Codification Committee by early 2022. The 
Committee  will  proceed  with  the  review  of  the  codified  legislation  as  a 
priority. 

law  reform,  the 

The  contract  for  the  development  of  the  National  Gateway  for 
Codification  and  Reform  of  Greek  Legislation  has  been  awarded, 

25 

 
 
Commitment 

State of play and next steps 

effectively  closing  this  specific  commitment.  It  was  agreed  in  the 
context of the 4th enhanced surveillance report in November 2019 that the 
completion of the National Gateway within the original timeline by mid-
2022 is not feasible. The commitment is therefore assessed as completed 
on  the  basis  of  award  of  the  underlying  tender,  the  implementation  of 
which  is  supported  through  EU  funds.  It  is  recalled  that  the  National 
Gateway  for  Codification  and  Reform  of  the  Greek  Legislation  aims  to 
establish  a  platform  where  codified  legislation  that  is  thematically 
classified can be accessed by the general public. In particular, through the 
National Gateway for Codification, citizens, businesses and public bodies 
will  have  direct  and  free  electronic  access  to  updated  and  codified 
legislative  and  regulatory  texts.  This  process  is  expected  to  improve  the 
quality  of  laws  and  regulations  as  well  as  the  systematic  updating  of 
legislation directly in  the codified law, which will  enhance transparency 
and  reduce  the  risk  of  overlapping  or  contradictory  provisions  being 
adopted.  The  contract  has  a  duration  of  36  months  and  is  EU-funded 
through the National Strategic Reference Framework.  

The authorities have made good progress on the specific commitment 
on electronic e-filing in the current reporting period. In particular: 

(i)  Regarding  the  implementation  of  e-filing  in  civil  courts,  the 
authorities  reported  further  progress  regarding  the  electronic 
issuance  and  distribution  of  court  documents  and  certificates.  More 
specifically,  five  first-instance  courts  were  added  to  the  list  of  courts 
henceforth issuing their decisions electronically. Moreover, the integrated 
e-insolvency  certificate  is  now  available  throughout  the  territory  of 
Greece.  A  Joint  Ministerial  Decision  is  being  drafted  to  allow  for  the 
operationalization of the e-divorce platform.  

26 

Justice 

In  the  context  of  implementing  the  Three-Year  Action  Plan  on 
Justice, 
legal  documents 
the  electronic  filing  of 
throughout the Courts, having completed the tendering procedure. 

implement 

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

 
 
 
 
Commitment 

State of play and next steps 

the 

implementation  of  mandatory  e-filing 

(ii)  Regarding 
in 
administrative  courts,  the  service  is  currently  operational,  with  an 
extensive functionality that will be further extended on completion of 
a  recently  launched  call  for  proposals.  Currently,  the  lodging  of  all 
introductory  submissions  (civil  claims  against  the  state  and  public 
entities,  appeals,  annulment  petitions  and  cassation  petitions,  as  well  as 
interim  protection  requests)  and  the  issuance  of  court  certificates  are 
supported; moreover, the interoperability of the administrative courts’ IT 
system with the IT system of the Legal Council of State is being tested in 
pilot  mode  as  of  the  beginning  of  September  2021;  upon  full 
operationalisation it will enable the written submission of memoranda by 
the administrative services in the context of pending procedures. In order 
to further expand the system’s functionality, ensuring full interoperability 
with the bar associations’ portal and introducing the lodging of additional 
categories  of  written  submissions  through  the  existing  infrastructure,  a 
competition for the provision of services was launched on 10 June 2021. 
The deadline for the submission of the necessary documentation in view 
of  the  awarding  of  the  contract  expired  on  13  September  2021  and  the 
next steps are the signature of the contract and the implementation of the 
project. The authorities intend to put the completed project on a pilot trial 
in February 2021 and in fully operational mode by end-March 2022. This 
entailed  a  transposition  of  the  initially  contemplated  August  2021 
deadline for the pilot phase.  

(iii)  The  project  of  the  distribution  of  e-signatures  to  judges  and 
clerical judicial staff has been completed. 10 000 e-signatures (out of a 
total of 11 000) have been handed over, with the remaining 1 000 already 
available and awaiting for the submission of certification requests by their 
recipients.  

27 

 
 
 
Commitment 

State of play and next steps 

Greece’s recovery and resilience plan includes a number of welcome 
follow-up  measures  that  will  further  pursue  and  broaden  the 
objectives of this reform. For instance, in administrative courts, the plan 
includes a project for the addition of further functionality, to support the 
lodging  of  all  documents  (including  evidence)  at  all  stages  of  judicial 
procedures, as well as the electronic issuance, service and dissemination 
of  court  documents  and  the  conduct,  in  general,  of  all  procedures 
performed by all administrative courts.  

While the preparatory stage for the launch of the call for bids for the 
integrated  case  management  system  for  civil  and  criminal  cases 
(‘OSDDY-PP’)  has  incurred  some  delay,  the  authorities  confirmed 
that the project remains on track for completion in the first quarter 
of  2022.  The  Memorandum  of  Understanding  between  the  Ministry  of 
Justice  and  the  Society  of  Information  (the  procurement  authority)  was 
concluded in July 2021, and the draft call for proposals is expected to be 
finalised  and  submitted  to  public  consultation  by  end-September  2021; 
the  authorities  intend  to  launch  the  call  for  proposals  by  end-October 
2021  and  are  expecting  that  the  contract  is  expected  to  be  awarded,  as 
planned, in the first quarter of 2022. 

The  authorities  have  put  forward  measures  to  address  the  three 
remaining  recommendations  from  GRECO’s  fourth  evaluation 
round.  

1.  Recommendation  on  the  selection  of  senior  positions  of  judges  and 
prosecutors  and  disciplinary  proceedings:  The  new  code  on 
the 
organisation of justice and the status of officers of the courts will aim at 
enhancing  the  process  within  the  current  constitutional  framework.  The 
code is planned to be adopted by the Parliament by December 2021 and 

28 

Fight  against  corruption. 
addressed by the Group of States against Corruption (GRECO). 

Implement  all 

recommendations 

 
 
 
Commitment 

State of play and next steps 

to enter into force upon publication in the Official Journal (see below).  

2.  Recommendation  on  providing  guarantees  against  delays  and 
improving  caseload  management:  A  number  of  actions  is  under  way  to 
address  this  recommendation,  such  as  the  establishment  of  e-justice 
systems,  relevant  provisions  and  improvements  in  various  codes  (e.g. 
organisation  of  justice  and  the  status  of  officers  of  the  courts,  judicial 
clerks,  civil  procedure,  criminal  procedure,  procedural  code  for  court  of 
audit), the establishment of JustStat unit  for judicial data collection, and 
legislative  initiatives  already  in  force  (mediation  law,  family  law).  This 
recommendation is expected to be implemented by April 2022. 

3.  Recommendation  on  setting  clear  standards  of  professional  conduct 
and integrity: The authorities adopted a charter of ethics for the judges of 
the  Court  of  Audit  (November  2020),  and  plan  to  adopt  codes  of  ethics 
for judges of administrative and criminal courts by December 2021. 

The  set  of  recommendations  concerning  bribery  of  public  officials, 
included in GRECO’s ad-hoc report, have not been implemented yet, 
but  the  adoption  of  a  legislative  initiative  to  address  them  is 
progressing. The recommendations followed amendments in the criminal 
code  and  the  criminal  procedure  code  in  June  2019  that  softened 
sanctions  for  criminal  offences  for  bribery  of  public  officials. 
Specifically,  these  recommendations  concern  the  penalty  framework  for 
active bribery, abstention of prosecution, prosecution of foreign officials, 
and  provisions  of  effective  regret.  A  legislative  proposal  to  address  this 
set of recommendations is foreseen to go through public consultation by 
October  2021  and  the  submission  to  the  Parliament  is  expected  by 
December 2021. 

Implementation  of  actions  that  go  beyond  the  scope  of  this  specific 

29 

 
 
Commitment 

State of play and next steps 

commitment,  namely  the  National  Anti-corruption  Plan,  asset 
declarations,  political  parties  financing  and  of  the  new  law  on 
internal control will be further followed up under Greece’s recovery 
and resilience plan. 

Complementary commitments undertaken by Greek authorities in May 2020  

Complementary commitment 

State of play and next steps 

improvements 

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

in 

Decisive  steps  to  simplify  the  regulatory  framework  and  lay  the 
grounds  for  the  creation  and  expansion  of  competitive  firms  have 
been taken until mid-2021. Notably, the interconnection of the General 
Commercial  Registry  (GEMI)  with  other  public  systems,  such  as  the 
social  security  system  (e-EFKA),  is  expected  to  further  facilitate  the 
process  of starting a business. Moreover, through the recent  introduction 
of  the  electronic  property  file  and  the  online  platform  for  the  property 
transfer tax, the authorities expect to halve the total time taken to transfer 
a  property,  whilst  ensuring  that  professional  service  groups  such  as 
engineers, notaries, lawyers, as well as citizens would have easy access to 
the relevant information. 

These  actions,  including  in  the  areas  of  improving  the  process  for 
obtaining  construction  permits,  connecting  to  electricity,  accessing 
credit,  and  enforcing  contracts  will  be  further  followed  up  under 
Greece’s recovery and resilience plan. 

Labour  law.  Improve  and  modernize  the  framework  for  individual 
labour  law,  including  tackling  the  issues  of  highly  restrictive 
overtime rules, unnecessary sectoral differentiation, white collar/blue 

The reform of the labour legislation was adopted in June, as expected 
in  the  10th  report.  The  implementation  of  the  actions  envisaged  in  the 
reform will be further followed up under Greece’s recovery and resilience 

30 

 
 
 
Complementary commitment 

State of play and next steps 

collar rules, and take account of flexible and home working, as well 
as  implement  these  measures  through  secondary  legislation,  by 
September 2020. 

plan. 

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

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

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

Following  the  Athens  and  Thessaloniki  courts  of  appeal  and  the 
Thessaloniki  court of first instance,  the authorities reported that the 
administrative plenary formation of the Athens court of first instance 
resolved the creation of special chambers on in July 2021 and is in the 
process of amending its internal regulation to that effect. The amended 
regulations  need  to  be  approved  by  the  Supreme  Court;  once  approved, 
they  will  be  published  in  the  Official  Journal  and  will  enter  into  force, 
marking the full completion of this initiative.  

Work is ongoing on the Code for the Organisation of Justice and the 
Status  of  Officers  of  the  Courts.  The  revised  draft  code  was  submitted 
by the law-drafting group to the Ministry of Justice and, following review 
by  the  plenary  formations  of  the  supreme  courts,  it  is  currently  being 
finalized with a view to conducting a public consultation. The authorities 
confirmed  that  the  Code  is  planned  to  be  adopted  by  Parliament  by 
December  2021  and  enter  into  force  upon  publication  in  the  Official 
Journal. 

The  authorities  expect  to  have  adopted  the  requisite  secondary 
legislation to operationalize the JustStat unit by October 2021, with a 
4-month  delay  compared  with  the  timeline  presented  in  the  10th 
report,  and  are  proceeding  with  the  appointments  of  staff  and 
supervisory  body  members.  The  relevant  secondary  legislation  is 
expected to be adopted by means of a Presidential Decree by end-October 
2021. According to the authorities, the Justice Statistics entity within the 
Ministry  of  Justice  will  be  fully  staffed  by  end-September  2021;  by  the 

31 

 
 
Complementary commitment 

State of play and next steps 

same date, the members of its supervisory committee will be appointed.  

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

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

for 

civil 

servants, 

effectively 

A  detailed  action  plan  has  been  finalised  through  technical  support 
provided  by  the  European  Commission  aiming  to  strengthen  the 
hiring  process 
this 
complementary  commitment.  The  action  plan  sets  out  over  20  actions 
under three main components (1. Planning of selection procedures cycles; 
2.  Modernizing  Admission  Testing;  and  3.  Conduct  selection  procedures 
cycles)  that  aim  to  modernise  the  personnel  selection  system,  including 
specific actions targeting the organisational transformation of the Supreme 
Council for Civil Personnel Selection (ASEP). This step effectively closes 
this  complementary  commitment.  The  implementation  of  these  actions 
will be followed up under Greece’s recovery and resilience plan. 

closing 

The authorities have completed the assessment of existing temporary 
staff categories and adopted relevant legislation, which will facilitate 
the definition of an annual ceiling that will be set by October 2021 and 
be  applied  as  of  2022.  The  annual  ceiling  will  be  defined  through  the 
adoption  of  a  Joint  Ministerial  Decision  that  will  set  a  ceiling  on  the 
recruitment  of  temporary  staff  for  2022  onwards.  Further,  the  hiring  of 
in  a 
10 500 
corresponding  reduction  of  temporary  teachers.  The  authorities  have 
confirmed  that  this  reduction  of  temporary  staff  will  be  evident  as  of 
October 2021 in the following staffing category as reported in the census 
(‘Apografi’),  “fixed  term  with  limited  duration,  hourly  paid,  project 
contract that burdens the state budget”. 

teachers  on  permanent  posts 

is  expected 

to  result 

As  part  of  the  authorities’  ongoing  efforts  to  strengthen  central 
control  of  human  resources  management,  legal  provisions  have been 
adopted to address a number of deviations identified related to hiring 
provisions.  The  adopted  provisions  address  more  than  70  exceptions 

32 

 
 
Complementary commitment 

State of play and next steps 

concerning  the  mobility  scheme  that  were  considered  obsolete  and/or 
unjustified.  At  the  same,  following  the  completion  of  an  exercise  listing 
all  deviations  to  the  mobility  scheme,  the  authorities  assessed  that  the 
majority of the exceptions granted (around 150) were justified and should 
therefore  be  maintained.  Further,  a  complete  list  of  deviations  from  the 
unified wage grid covering the period from 2016 until today is expected to 
be  finalised  by  November  2021.  Following  this,  legal  provision(s) 
addressing these deviations in a systematic manner will follow by the first 
quarter  of  2022.  Finally,  the  inter-ministerial  committee  has  finalised  its 
is  currently  working  on  defining  specific 
technical  work  and 
recommendations  to  be  presented  to  the  Council  of  Ministers  on  the 
revision of the methodology for the allowance for hazardous and arduous 
work.  The 
finalised  by 
recommendations  are  expected 
end-September with legal provisions being adopted by end-2021. 

to  be 

Preparatory  work  on  drawing  up  a  holistic  and  coherent  strategy 
continued. The Hellenic Corporation of Assets and Participations is in the 
process of collecting all  the required information for drafting the request 
for  proposal  for  the  consultant  that  will  work  on  the  study  for  the 
elaboration  of  the  real  estate  strategy.  The  agreed  scope  of  the  study 
includes  the  identification  of  international  best  practices  and  mapping  of 
current  situation  /  gaps,  sustainable  development  of  the  public  property 
and areas for reform of the framework for the development of public real 
estate assets. The strategy is expected to be finalised in the second quarter 
of 2022.  

The  Government  Committee  for  Contracts  of  Strategic  Importance 
became  fully  operational  mid-July.  The  preparation  of  the  first 
Development Programme of Contracts of Strategic Importance is expected 
to  be  concluded  by  mid-October.  With  the  preparation  of  the  first 

33 

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

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

expenditures 

public 

future 

 
 
Complementary commitment 

State of play and next steps 

by January 2021. 

Project  preparation  facility.  Develop  and  fully  operationalize  an 
improved  support  and  delivery  mechanism  for  project  preparation 
and  implementation  to  ensure  efficiency  and  quality  of  both  public 
sector infrastructure projects as well as Public Private Partnerships by 
March 2021. 

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

Development  Programme  of  Contracts  of  Strategic  Importance,  the 
commitment will be considered as completed. 

Despite  minor  delays,  the  Project  Preparation  Facility  is  gradually 
becoming  operational.  The  Facility  is  intended  to  prepare  strategic 
projects  included in  Greece’s  recovery and  resilience plan, EU structural 
funds and the national investment programme. The initial list of recovery 
and  resilience  plan’s  projects  to  be  assigned  for  maturation  is  under 
preparation and it is expected to be finalised by end-September, whereas 
the  tender  process  for  framework  contracts  for  consultants  will  be 
launched  immediately  upon  the  finalisation  of  the  list  of  projects. 
Regarding  projects  funded  under  the  Recovery  and  Resilience  Facility, 
funding will be made available upon assignment of the projects; for other 
projects,  there  are  ongoing  discussions  between  the  Fund,  the  Hellenic 
Corporation of Assets and Participations and the Ministry of Finance so as 
to  ensure  adequate  prefunding.  Further,  by  the  end  of  August,  the 
authorities completed the staffing process of the unit with the core team, 
whereas  the  additional  required  staffing  will  take  place  following  the 
finalisation  of  the  said  list  of  projects.  The  Fund  has  concluded  the 
technical  work  on  its  accounting  system  and  is  in  a  position  to  have 
separate  accounts  for  the  project  preparation  facility.  The  Fund  has 
engaged a private consultant to support it in the setting up and the staffing 
of  the  unit.  The  unit  is  expected  to  become  fully  operational  by  mid-
October.  

The authorities adopted a new national  public procurement strategy 
for  2021-2025  and,  albeit  with  few  delays,  are  expected  to  complete 
the  adoption  of  the  remaining  secondary  legislation  identified  as 
critical  for  the  operationalisation  of  the  new 
law  on  public 
procurement  soon,  following  steady  progress  over  the  past  months. 

34 

 
 
Complementary commitment 

State of play and next steps 

Key  elements  of  the  said  reform  initiatives  include  the  digitalisation  of 
public  procurement  processes  and  upgrade  of  relevant  systems,  the 
introduction  of  modern  tools  and  e-services  in  the  public  procurement 
lifecycle,  improvements  in  the  governance  and  control  framework  and 
professionalization of involved staff, strengthening of central purchasing, 
and  the  promotion  of  greener  technologies  in  public  infrastructure 
projects. Further, they completed the mapping of all remaining secondary 
legislation  deriving  from  the  law,  to  be  implemented  as  part  of  the  new 
strategy.  An  oversight  and  coordination  structure  for  the  implementation 
of  the  new  strategy  is  also  in  place,  following  the  recent  adoption  of  a 
secondary legislation act. With a view to ensuring economies of scale and 
efficient  procurement  procedures  for  infrastructure  projects  and  related 
services,  the  authorities  issued  secondary  legislation  to  define  the 
categories  of  contracts  to  be  undertaken  by  the  Central  Purchasing 
Authority  under  the  Ministry  of  Infrastructure,  as  a  first  step  towards 
achieving  centralised  procurement  in  this  area.  According  to  the 
authorities,  priority  projects  for  centralised  procurement  comprise  of  the 
development  and  maintenance  of  road  infrastructure,  and  studies  for  the 
development of climate-resilient infrastructures. 

Implementation of the new strategy, including adoption of remaining 
secondary  legislation  of  the  new  law,  which  is  a  dedicated  action 
under  this  strategy,  will  be  monitored  under  Greece’s  recovery  and 
resilience plan. 

The  authorities  have  presented  in  July  a  policy  paper  indicating  the 
main directions of a new law on higher education. The draft law itself 
will  be  voted  in  Parliament  at  the  end  of  the  year,  somewhat  later  than 
what was envisaged under the 10th report. The reason for the delay is that 
four  major  education  laws  were  adopted  in  2021,  which  strained  the 

35 

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

 
 
Complementary commitment 

State of play and next steps 

Introduce 

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

school-unit 

the  administrative  and  educational  autonomy  of 

resources  of  the  Ministry.  The  authorities  are  expected  to  clarify  the 
timeline for the adoption of the law by October. The main priorities to be 
addressed  in  the  new  law  include  a)  a  way  forward  following  the 
abolishment of the technological education that effectively happened with 
the absorption  of the technological  institutions by the universities, b) the 
increase  of 
the 
universities and c) the governance of the universities, where the principle 
of  separation  of  the  governing  council  from  the  management  of  the 
university  (dean,  rector,  senate)  is  expected  to  ensure  the  necessary 
transparency and accountability following the higher degree of autonomy. 
In  particular,  the  coming  bill  is  expected  to  include  among  others,  the 
following  components:  a)  internal  restructuring  of  Higher  Education 
Institutions, b) governance model, c) degree structure (1st, 2nd, 3rd cycle 
study programmes), as well as general academic issues and teaching staff 
issues. 

A  new  comprehensive  law  on  school  education  was  adopted  in 
Parliament  in  August  2021  and  will  be  applied  in  the  coming 
academic  year  2021-22.  This  completes  the  commitment  on  school 
education.  The  basic  axes  of  the  new  law  are  a)  autonomy,  b) 
organisational  changes  and,  c)  evaluation  of  teachers  and  education 
executives.  

a) Regarding autonomy, the law foresees the transfer of powers from the 
central  government  to  the  school  units.  An  important  innovation  is  the 
introduction of multiple schoolbooks. The powers of the schoolmaster will 
increase.  The  law  also  allows  for  more  flexibility  on  student  evaluation, 
based  on  standards  developed  by  the  Institute  of  Education  Policy.  The 
schools  will  be  allowed  to  develop  extra-curricular  activities  such  as 
chess, theatre etc., after the end of the formal school hours. The premises 

36 

 
 
Complementary commitment 

State of play and next steps 

of  the  schools  will  be  able  to  be  used  for  extra-school  activities  and  the 
earnings will top-up the budget of the school. Finally, an anonymous Pisa-
type examination is  introduced that will give feedback to  the  Institute of 
Education Policy.  

b)  Regarding  the  organisational  framework  in  education,  the  reform 
intends to bring the education executives closer to the schools in order to 
better monitor the educational programmes and to carry out the evaluation 
of  the  teachers.  The  new  structures  will  have  13  peripheral  directorates 
and  13  peripheral  supervisors.  There  will  be  116  education  directors  (58 
directorates  of  primary  education  and  58  directorates  of  secondary 
education)  and  116  quality  supervisors.  The  school  counsellors  will 
increase from 540 to 800 and 1 100 new posts of psychologists and social 
workers will be established.  

c)  Finally,  individual  teacher  evaluation  is  introduced  with  the 
objective  of  improving  the  qualifications  of  the  teaching  staff.  The 
education  executives  will  be  assessed  every  two  years  and  the  teachers 
every four years. Regarding the auto-evaluation of schools, it has already 
started being implemented this year with many schools submitting reports, 
but the exercise has been impeded by the pandemic. 

The  implementation  of  the  law,  in  particular  the  appointment  of 
education executives in a transparent and de-politicised way and the 
assessment of the education staff, will be a critical step. 

The digital ecosystem of public services is being continually expanded, 
with more than 1 250 digital public services integrated to date in the 
single  digital  portal  (gov.gr),  backed  by  initiatives  to  ensure  the 
robustness  of  infrastructure  to  support  hosted  information.  The 
authorities  revised  the  implementation  roadmap  for  the  single  digital 

37 

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

 
 
Complementary commitment 

State of play and next steps 

infrastructure mid-2021. 

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

Digitisation of geospatial data.  

Develop a State Infrastructures Registry to encapsulate technical and 
geospatial  information  about  all  public  infrastructure  projects  to 
enable  better  planning  and  management  of  these  projects,  including 
for construction and maintenance purposes by end-2021.  

Develop an Integrated Geospatial Data Mapping tool (Single Digital 
Map) to increase transparency to investors concerning land use rules 

portal  (gov.gr)  which  is  due  to  be  completed  by  end-2021,  in  order  to 
prioritise new interventions, in particular, the European Digital Certificate, 
and  the  COVID-19  vaccination  and  self-testing  platforms.  Further,  key 
interoperability initiatives enabled the development of new web services, 
for instance to facilitate electronic controls by public services, including in 
the  areas  of  employee  testing  for  COVID-19  in  businesses,  and  the 
establishment  of  sole  proprietorships.  Lastly,  in  order  to  ensure  smooth 
system operation and business continuity with respect to such services, the 
authorities  awarded  the  contract  to  provide  Database  Private  Cloud 
Computing  and  Database  Backup  Infrastructure  services,  which  is 
expected to allow the databases of all the entities to operate more securely 
and  in  a  cloud  environment.  Implementation  of  secondary  legislation  of 
the  Digital  Code,  which  is  a  precondition  to  implementing  many  key 
reforms  and  investments  included  in  Greece’s  recovery  and  resilience 
plan, such as in the areas of open data policy, provision of gov.gr services, 
and cloud infrastructure, will be further monitored under the plan. 

These measures will be further followed up under Greece’s recovery and 
resilience plan. 

These measures will be further followed up under Greece’s recovery and 
resilience plan. 

38 

 
 
Complementary commitment 

State of play and next steps 

across  Greece  and  reduce  unpredictability  in  relation  to  investment 
licensing decisions by end-2021. 

39