COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, November 2021 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance Update - Greece, November 2021
Date: 2021-11-24
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, 24.11.2021  SWD(2021) 364 final  COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, November 2021 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance Update - Greece, November 2021 {COM(2021) 916 final}  
 
 
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 

(*) 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.  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. 

(*) Arrears.  

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

1 

State of play and next steps 

On 15 October 2021, Greece submitted the Draft Budgetary Plan for 
2022,  which  expects  the  primary  deficit  monitored  under  enhanced 
surveillance to decrease from 7.6% of GDP in 2021 to 1% of GDP in 
2022.  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  mid-2021  specific  commitment  to  implement  the  first  level  of 
functional  classification has been completed and the development of 
its second level (a mid-2022 specific commitment) is on track. The first 
level of functional classification for both ordinary and public investment 
budget was finalised in October 2021 and will be presented in November 
2021 in the context of 2022 budget along with a simplified version of the 
economic  classification  of  the  public  investment  budget.  The  authorities 
are  progressing  with  the  development  of  the  second  level  with  the 
assistance of a working group consisted of representatives from Hellenic 
Statistical  Authority,  Ministry  of  Finance  and  Ministry  of  Development 
and Investment. The second level of functional classification is expected 
to be completed in time by April 2022 and presented in the annual update 
of the Medium Term Fiscal Strategy. 

The  gap  to  the  target  to  materially  clear  the  non-pension  arrears, 
which was due in June 2021, has marginally narrowed. The stock of 
net  non-pension  arrears  reached  €555  million  in  September  2021, 
€251 million above the targets set in the March 2021 clearance plan. This 
is slightly lower than the July 2021 outcome reported in the 11th report (a 

 
 
Commitment 

State of play and next steps 

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

stock  of  €564 million).  Deviation  from  the  targets  are  observed  across 
subsectors  except  for  arrears  on  the  payments  of  tax  refunds.  The  most 
problematic sectors remain the extra-budgetary funds, local governments 
and  hospitals.  The  divergence  results  from  a  number  of  factors,  most 
notably  delays  in  implementing  the  actions  agreed  in  the  March  2021 
clearance plan, accumulation of new arrears and a smaller-than-expected 
impact of other initiatives.  

The  authorities  have  taken  actions  to  remedy  the  situation  with  a 
view to materially clear the non-pension arrears by the end of 2021. 
These actions aim to further improve the liquidity of some entities and are 
expected  to  help  the  clearance  of  their  arrears  in  the  coming  period.  A 
capital  increase  took place in  the public entities  in  the defence sector in 
October 2021 under the precondition that they will clear their arrears by 
the  end  of  the  year  while  the  public  transport  companies  will  receive 
during  November  2021  the  amounts  owed  to  them  in  relation  to  the 
conduct  of public sector obligations.  In addition,  the regular instalments 
of  hospitals’  grants  were  brought  forward  and  an  additional  grant  of 
€115 million  was  paid  to  hospitals  in  October  2021.  Regarding  local 
governments,  the mechanism  for  the  prevention  of  arrears  accumulation 
entered  into  force  in  October  2021  and  the  first  results  are  expected  to 
materialise in the December 2021 arrears data. The mechanism envisages 
that 
list  of  their  remaining  arrears 
accompanied  by  a  justification  for  their  non-payment  and  transfer  the 
amounts to a special account at the Consignment Deposits and Loan Fund 
earmarked for arrears payment.  

local  governments  submit  a 

The  clearance  of  pension  arrears  also  continues  to  underperform. 
According  to  September  2021  data,  the  stock  of  net  pension  arrears 
remained  stable  at  €360 million  compared  to  €359 million  in  July  2021 

2 

 
 
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State of play and next steps 

presented in the last report. This translates to a deviation from the target 
of  €251  million.  The  main  drivers  behind  the  underperformance  are  the 
delays in the implementation of actions which would increase the pace of 
pension  awards,  as  well  as  a  higher  number  of  new  pension  application 
compared to what was expected in the March 2021 clearance plan.  

The  authorities  currently  expect  pension  arrears  to  be  fully  cleared 
only  by  mid-2022.  Following  the  delays  in  meeting  the  targets,  the 
authorities  appointed  a  Project  Manager  from  the  private  sector  who,  in 
cooperation  with  the  dedicated  Task  Force  already  established  at  the 
ministry, is mandated to coordinate the efforts to fully clear the stock of 
unprocessed  pension  applications.  The  main  new  initiative  taken  by  the 
authorities is the creation of a centralised facility in September 2021, with 
cross-functional teams focused on resolving complex cases and aiming at 
process  optimization  and  creation  of  a  vertical  pension  award  structure, 
which  will  be  able  to  deal  with  all  problematic  cases  of  the  previously 
scattered  branches  of  the  Single  Social  Security  Fund  (e-EFKA), 
including the Agricultural  Insurance Organization, Self-employed Social 
Security  Fund,  and  the  main  Social  Insurance  Institution  for  the  private 
sector (IKA). Concerning  earlier actions, delays  occurred in  the training 
of certified lawyers and accountants, envisaged to support the processing 
of  pensions.  They  should  become  fully  operational  in  November 2021. 
Other initiatives to the acceleration of pension awards include legislative 
simplification  of  procedures  and  the  implementation  of  smart  Business 
Intelligence  tools  and  analytics  and  the  new  automation  in  pension 
processing.  

A  monthly  monitoring  mechanism  will  be  set  up  to  support  the 
achievement  of  the  agreed  targets.  The  objective  of  this  detailed 
monitoring  is  to  obtain  a  better  overview  of  the  progress  made  on  the 

3 

 
 
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State of play and next steps 

implementation  of  agreed  actions,  detect  early  any  deviation  and 
understand  the  reasons  for  the  accumulation  of  new  arrears.  This 
mechanism  will  involve  a  monthly  exchange  on  the  basis  of  a  policy 
action table concerning both pension and non-pension arrears.  

Implementation  of  the  recommendations  of  the  Hellenic  Court  of 
Auditors  and  the  simplification  of  fiscal  procedures  continued  as 
planned. The vast majority of reforms identified by the Hellenic Court of 
Auditors have already been completed. Additional recommendations were 
finalised  by  October  2021,  notably  the  ones  related  to  the  update  of 
Ministry of Development’s IT system (e-PDE). Finally, the simplification 
of  procedures  related  to  the  payment  of  grants  to  legal  entities  was 
adopted as planned. The law amendments of the regulatory framework for 
the conflict of interest of accounting officers  and the payment of certain 
types  of  costs  through  simplified  procedures  were  submitted  to  the 
parliament  and  are  scheduled  to  be  voted  until  the  end  of  November. 
These  initiatives  are  expected  to  further  help  the  prevention  of  new 
arrears.  

The  testing  phase  of  the  end-to-end  IT  collection  system  has  been 
successfully completed, but its full operationalisation is now expected 
to  be  achieved  only  by  April  2022.  The  Independent  Authority  for 
Public  Revenue  is  in  parallel  training  its  staff  and  the  IT  platform 
arrangements with the Ministry of Digital Governance will be in place by 
January 2022, in order for the new collection system and its web portal to 
be fully operational by April 2022. 

The  authorities  have  committed  to  make  a  reform  the  ENFIA 
property  tax  based  upon  the  new  wider  property  tax  base  with 
payments  starting  in  March  2022.  The  new  property  tax  zonal  values 
for  all  property  taxes  will  enter  into  force  on  1  January  2022.  The 

Tax administration. 

Make the end-to-end IT collection systems fully operational. 

Tax policy.  

Greece  will  undertake  a  nationwide  valuation  exercise  of  property 
tax value based on market values and will update property tax values 

4 

 
 
Commitment 

State of play and next steps 

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. 

Authorities  are  still  working  on  the  finalisation  of  a  revenue-neutral 
ENFIA  property  tax  reform.  They  have  provided  a  timetable  to  bring 
forward the 2022 property tax assessment with first instalments made in 
March 2022. 

Despite long delays in the past, clawback collection has resumed and 
currently  progresses  almost  regularly  for  clawbacks  accumulated  in 
2021, with larger difficulties for the ones accumulated in the past. In 
particular: 

  As  regards  2021,  the  newly  introduced  methodology  to  collect 
clawbacks for services providers on a rolling basis is bearing fruit 
and  approximately  20%,  i.e.  60  million  of  the  clawback  of  2021 
has already been collected after three months from the start of its 
implementation. 

to  a  combination  of 

  Collection  of  clawback  from  2020  is  behind  schedule  for 
pharmaceuticals and has not started for health services providers, 
due 
technical  constraints  and  new 
administrative procedures. For pharmaceuticals, the new measure 
allowing  for  clawback  discounts  against  companies’  investments 
in  research  and  development  of  pharmaceuticals  has  delayed  the 
finalisation  of  the  instalment  plans  (at  present,  as  a  result, 
approximately €230 million, i.e. one third, are not yet collected or 
covered  by  instalment  plans);  for  other  providers,  an  increase  in 
the ceilings for certain categories called for a recalculation of the 
amounts due, so instalment plans are not  yet in  place for the full 
amount of 2020, which is €280 million. Based on the information 
provided  by  the  authorities,  the  Ministerial  Decision  for  the 
amended  2020  ceilings  for  providers,  needed  to  enable  the 

5 

 
 
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State of play and next steps 

collection, will be issued shortly.  

level  of  the  clawbacks  remains  high,  at  approximately 
The 
€700 million  and  €300 million  for  pharmaceuticals  and  services 
providers,  respectively.  A  minor  decrease 
the  clawback  for 
pharmaceuticals has been achieved, mostly due to the recent exclusion of 
vaccines  from  the  budget  under  expenditure  ceiling.  This  underlines  the 
need for a more consistent implementation of existing structural measures 
in  place  and  for  additional  supporting  measures.  A  stronger  negotiation 
and  health  technology  assessment  (HTA)  capacity,  together  with  more 
numerous and compulsory protocols would support a faster reduction. 

in 

The reform of the primary health care is currently still on hold, with 
little  progress  over  the  past  months  partly  on  account  of  the 
pandemic.  The  planned  revision  of  the  legislative  framework  for  the 
primary health care system, announced already in 2019, has seen further 
delays. Apart from the severe challenges posed by the pandemic and the 
additional  time  that  has  become  necessary  in  light  of  the  recent 
government  reshuffling,  the  reform  has  seen  delays  due  to  a  lack  of  an 
adequate stock of  family doctors. The additional staff that have recently 
been recruited will allow for the opening of about 60 new primary health 
care units, i.e. slightly less than a half of the total number of outstanding 
planned  primary  health  care  units.  The  authorities  announced  the 
intention to step up the efforts to increase the workforce that could better 
support  the  transition  towards  a  stronger  primary  health  care  and 
committed  to  presenting  a  draft  law  by  December  2021  with  a  view  to 
adopting  it  by  January  or  February  2022.  Within  the  same  date,  in  time 
for the publication of the 13th enhanced surveillance report, the authorities 
committed  to  issuing  the  secondary  legislation  needed  to  deliver  on  the 
key principles of gatekeeping and patient registration. 

Health care.  

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

6 

 
 
Commitment 

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. 

Social welfare.  

7 

State of play and next steps 

The new legislative framework is close to adoption and procurement 
activities  are  progressing  towards  the  mid-2022  milestone  of  40%. 
According  to  the  information  provided  by  the  authorities,  the  legislative 
framework  for  the  centralised  health  procurement  body  (EKAPY)  is 
expected to be adopted shortly, with submission to parliament planned by 
22  November  and  the  vote  expected  within  the  first  ten  days  of 
December,  following  the  conclusion  of  the  public  consultation  in  early 
November.  In  parallel,  procurement  activities  are  progressing,  after 
having  reached  the  30%  procurement  target  in  the  past  months.  By  the 
end  of  2021,  the  authorities  plan  to  launch  additional  tenders  worth  of 
approximately  €280 million,  which  will  contribute  to  reaching  the  next 
target of 40% in mid-2022. 

Adoption  of  secondary  legislation  for  a  trial  Personal  Assistance 
scheme that will apply the new approach for disability determination 
is expected for early 2022 allowing for the implementation of the trial 
scheme in March 2022. Following the adoption of primary legislation on 
1 October 2021 that introduced a Personal Assistance scheme for persons 
with  disabilities  with  an  initial  trial  implementation  period  (law 
4837/2021  published  in  Government  Gazette  No  178/A),  the  authorities 
are currently working on the secondary legislation that is expected to be 
completed  by  early  2022.  This  legislative  framework  will  allow  using  a 
new  approach  for  disability  determination  based  on  both  medical  and 
functional  assessment  to  assess  benefit  eligibility  for  the  purpose  of  the 
trial Personal Assistance scheme. The new functional assessment scheme 
will be used directly for in-kind benefit decisions from March 2022 when 
the trial scheme will start.  

The opening of remaining directorates of e-EFKA over the territory 
is progressing well, however the IT infrastructure is not mature yet. 

 
 
Commitment 

State of play and next steps 

Complete the set-up of the single pension fund 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. 

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. 

The  authorities  reported  that  the  target  for  the  current  review  is  almost 
met, with nearly 90 directories opened since end-October 2021. Based on 
these  reports,  openings  appear  to  be  even  ahead  of  schedule  and  are 
planned for completion around mid-December 2021. The interconnection 
of  databases  and  IT  systems  of  previous  funds  is  not  yet  complete,  but 
these outstanding issues are currently being tackled.  

The functioning of the insolvency framework is now supported by the 
relevant electronic infrastructure, with the sole exception of the early 
warning  electronic  platform,  currently  in  testing  mode.  All  the 
necessary  secondary  legislation  has  been  adopted  (with  two  of  the  joint 
ministerial decisions on the early-warning procedure pending publication 
in  the  Official  Journal),  with  the  exception  of  five  ministerial  decisions 
that  concern  the  sale  and  lease-back  mechanism.  Regarding  the  relevant 
IT infrastructure, the electronic platforms are now interconnected with the 
IT  systems  of  the  banks,  complementing  the  platforms  for  the  debt 
restructuring  of  medium  and  large  businesses,  the  bankruptcy  of 
households  and  businesses,  the  out-of-court  workout,  the  insolvency 
registry and the verification of the status of vulnerable debtors. As for the 
early warning platform, which will enable the fully automated handling of 
applications  by  creditors  and  the  operationalisation  of  the  early  warning 
IT mechanism, it is currently in testing mode and is expected to be fully 
operational  as  of  1 December  2021.  While  the  out-of-court  workout 
scheme has attracted  a strong interest,  with  35 753 applications initiated 
as  of  the  beginning  of  October  2021,  only  512  applications  or  1.5%  of 
those initiated had been finalised and submitted by that date. The majority 
of  the  applications  submitted  concerned  at  least  one  denounced  loan 
the 
towards  a  credit 
applications was linked with loans with less than 30 days past due. On the 
whole,  the  first  indications  from  the  functioning  of  the  out  of  court 

institution,  although  approximately  9%  of 

8 

 
 
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State of play and next steps 

workout mechanism appear positive in terms of uptake, while the risk of 
abuse seems to be contained for the time being.  

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 insolvency framework.  According 
to the latest update from the authorities, the final step following a three-
stage  concessionary process,  i.e. the ratification of the conclusion of the 
selection  procedure  by  the  parliament,  is  now  not  expected  to  be  taken 
earlier than mid-December 2022, i.e. with a 9-month delay in comparison 
to  the  previously  agreed  date  (end-March  2022).  The  call  for  the 
expression  of  interest  is  expected  to  be  launched  by  15 December  2021 
and is  due to  be completed, with  the preselection of  eligible candidates, 
by mid-February 2022, to be followed by the conduct of the competitive 
dialogue and the bidding phase. According to the relevant provision of the 
Insolvency Code, the procedures for the protection of vulnerable debtors 
under 
lease-back  mechanism  will  commence  upon 
the  sale  and 
operationalisation of the entity. 

The clearance of the backlog of household insolvency cases, a specific 
commitment,  is  progressing  but  at  a  slow  pace.  The  authorities  are 
preparing to take relevant steps to support the process, with a view to 
clearing the backlog largely within 2022, which remains challenging. 
The latest data received by the authorities confirm that the processing of 
household  insolvency  cases  is  advancing,  effectively  filtering  out 
ineligible applications, albeit at a slower pace than initially expected. Up 
to 30 October 2021, 49 031 applications were submitted, of which 39 739 
were  subsequently  validated  and  9 552,  or  19.5%  of  the  total,  were 
assigned  a  new  hearing  date.  Of  these,  approximately  60%  have  been 
appointed  within  the  third  and  fourth  quarters  of  2021,  while  the 

9 

 
 
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State of play and next steps 

remaining  ones  have  been  appointed  predominantly  in  the  first  half  of 
2022,  with  the  rest  extending  as  far  as  the  second  quarter  of  2024.  The 
high  number  of  pending  applications  that  have  yet  to  receive  a  hearing 
date is partly attributable to pandemic-related reasons but mainly a result 
of  the  limited  case-processing  capacity  of  courts,  and  delays  the 
processing  of  the  backlog.  In  total,  as  of  30 September  2020,  there  are 
61 798 cases pending, including cases that were heard but pending a final 
decision. To address chronic infrastructure and/or staffing insufficiencies, 
the authorities reported being in the process of developing an action plan 
for  the  secondment  of  judges  to  speed  up  the  processing  by  the  courts 
facing  difficulties,  which  will  be  submitted  for  approval  by  the  relevant 
judicial  authorities  and  should  start  being  implemented  as  from  January 
2022,  allowing  for  the  clearance  of  the  backlog  largely  within  2022. 
Moreover,  in  order  to  facilitate  the  monitoring  of  new  hearing  dates 
scheduling,  the  authorities  adopted  a  ministerial  decision (1)  making 
compulsory  the  uploading  of  hearing  date  information  onto  the  relevant 
electronic  platform.  The  authorities  committed  to  provide  monthly 
updates on the progress with the clearance of the backlog. 

The  recent  adoption  of  an  extensive  revision  of  the  Code  of  Civil 
Procedure  is  expected  to  accelerate  the  delivery  of  Justice  and 
increase  the  efficiency  of  enforcement  proceedings,  including  the 
conduct  of  e–auctions.  The  amendments  to  the  Code,  introducing  the 

(1) Article 7 of Joint Ministerial Decision of the Ministers of Finance, Justice and State (OJ B 4455/29.09.2021). 

10 

 
 
                                                 
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State of play and next steps 

features  described  in  the  previous  enhanced  surveillance  report,  were 
adopted  on  11 October  2021 (2)  and  will  enter  into  force  on  1 January 
2022. 

The conduct of auctions has resumed and is picking up. According to 
the data provided by the authorities, nearly 40%  of the 5 561 e-auctions 
planned  for  the  second  quarter  of  2021  were  concluded,  while  the  rest 
were suspended. A very small  number of auctions was cancelled.  In the 
third quarter of 2021 (which includes the August recess), of 3 414 out of 
4 600 planned e-auctions were concluded, 1 163 were suspended and 23 
were  cancelled.  However,  even  in  the  case  of  successful  e-auctions,  the 
majority  of  the  auctioned  properties  still  end  up  in  the  banks’  and 
servicers’ real estate property portfolios, despite some signs of increased 
interest from third parties.  

Work  is  ongoing  regarding  the  introduction  of  enhancements  to  the 
e-auctions platform. The two working groups referred to in the previous 
enhanced surveillance report are expected to hand in their proposals to the 
Ministry of Justice by January 2022, for the identification of potentially 
needed  legal  amendments  to  be  adopted  and  implemented.  Their  report 
will also include a list of the enhanced features that are already available 
but  currently  not  operational  due  to  the  lack  of  online  availability  of 
information  (mainly  regarding  energy  certification  of  properties  and 
building code violations) along with a timeline for their activation as soon 
as  possible.  The  authorities  also  reported  on  the  development  of  an 
electronic  platform  allowing  notaries  to  obtain  online  information  from 
the engineers’ professional associations, regarding building violations and 

(2) Articles 1-82 and 119-120 of Law 4842/2021 (OJ A 190/13.10.2021)  

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State of play and next steps 

other technical data of interest to prospective purchaser, as well as from 
municipalities and land registries and/or cadastral offices. The platform is 
currently  running  on  a  pilot  basis  and  is  expected  to  be  operational  by 
end-November  2021.  The  authorities  also  reported  on  developing  an 
electronic  platform  aggregating  and  providing  information  to  judicial 
bailiffs, in order for them to determine the price of seized properties, and 
to  notaries  involved  in  enforcement  procedures.  Additional  information 
on  the  timeline  of  this  initiative  will  be  provided  in  the  next  enhanced 
surveillance report. 

Despite  an  acceleration  of  payments  with  regards  to  the  backlog  of 
called  state  guarantees  in  the  third  quarter  of  2021,  the  pace  of 
clearance  still  falls  short  of  expectations.  Although  the  number  of 
claims  examined  and  the  value  of  payments  has  increased  compared  to 
previous quarters, it is  considerably behind  the targets  set  for the timely 
clearance  of  the  backlog.  This  underperformance  is  partly  explained  by 
the gradual learning process of new personnel, the necessary replacement 
of  seven  employees  and  a  temporarily  low  average  value  of  claims 
examined  with  respect  to  corporate  loans.  In  order  to  meet  the  high 
targets  set  under  the  current  clearance  plan  and  increase  the  processing 
rate,  the  authorities  have  decided  to  i)  increase  the  number  of  new 
permanent personnel to be hired in late December 2021 to thirty five from 
thirty employees and ii) to put in place, in cooperation with one systemic 
bank,  the  electronic  exchange  of  all  necessary  information  on  old,  pre-
2015 cases, not included in the e-repository, for which there is a pending 
lawsuit by that bank. Nonetheless, despite these initiatives, the target for 
2021 as a whole had to be revised once again downwards. The authorities 
have committed to provide monthly updates on the pace of clearance and, 
based  on  the  performance  in  the  remainder  of  the  year,  will  assess  if 
further corrective actions would be required to ensure that the targets for 

12 

 
 
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State of play and next steps 

2022 and 2023 are met in full. 

Discussions  are  progressing  on  the  future  of  the  Hellenic  Financial 
Stability  Fund,  for  which  the  Greek  authorities  now  expect  the  legal 
amendment to be adopted later in the year. The reform of the Fund’s legal 
framework is  expected to  focus on the duration, governance, divestment 
strategy and special rights of the Fund. Adoption of the legal amendment 
is now expected to take place by the end of the year.  

The recently adopted amendment of article 27 of law 4172/2013 will 
further facilitate sales and securitisations of non-performing loans by 
smoothening the amortisation of the related deferred tax assets. 

Secondary  legislation  setting  out  the  new  statutory  minimum  wage 
level to apply from 1 January 2022 is expected for December 2021 in 
line with the respective legislation. The process for a possible update of 
the statutory minimum wage started in March 2021, following a one-year 
freeze  due  to  the  pandemic,  and  involved  consultations  with  research, 
scientific  and  social  partners,  and  independent  experts.  The  outcome  of 
the  consultation  led  the  Minister  of  Labour  and  Social  Affairs  to 
recommend  to  the  Cabinet  of  Ministers  a  2%  increase  in  the  statutory 
minimum wage (from €650 to €663 per month for workers of up to three 
years  of  work  experience)  to  apply  from  1 January  2022.  Following  the 
endorsement of the latter body at end-July 2021, the respective Decision 
by  the  Minister  of  Labour  and  Social  Affairs  is  expected  for  December 
2021. 

Whilst  the  authorities  made  welcome  steps  on  the  commitment  to 
finalise inspection legislation, specifically in the last remaining area of 
environmental protection, one element remains pending. Specifically, 
they  adopted  primary  legislation  to  amend  sanctions  and  enforcement 

(*) Labour market. 

Greece  will  safeguard  competitiveness  through  an  annual  update  of 
the minimum wage in line with the provisions of Law 4172/2013. 

Investment licensing.  

Greece will finalise inspection legislation. 

13 

 
 
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State of play and next steps 

powers  of  inspecting  authorities  in  the  said  area,  in  effort  to  make  the 
environmental  inspections  framework  more  transparent,  friendly  to 
businesses  and  conducive  to  self-compliance.  However,  secondary 
legislation to detail the enforcement management model that is necessary 
to facilitate a harmonised approach in the application of the enforcement 
system  is  still  under  elaboration.  This  would  step  would  complete  the 
environmental inspections reform. 

Substantial progress is recorded on the simplification of legislation in 
the agreed sectors, with the majority of the remaining elements now 
in place. Namely, all secondary legislation foreseen to operationalise the 
set  of  simplified  licensing  legislation  adopted  in  April  and  June  2021, 
respectively, has been adopted.  In the  case of  the  economic activities in 
the  tourism  sector,  the  completion  of  technological  enhancements  in 
relevant  IT  tools  has  been  set  as  a  precondition  for  the  simplified 
processes  to  come  into  force.  Completing  this  work  would  help  remove 
hurdles  in  a  sector  that  is  vitally  important  for  Greece.  In  parallel,  the 
authorities  recently  adopted  further  legislation  to  reform  the  economic 
activities relating to education that were not been included in the scope of 
the  previous  simplification  rounds.  These  concern  private  institutes  for 
vocational  training,  colleges,  private  tutoring  centres,  and  language 
centres. Nonetheless, some delay is observed in the adoption of enabling 
secondary legislation for the simplification of licensing procedures for the 
said activities, which is now expected by January 2022. 

The cadastral  mapping continues to progress  steadily. The collection 
of  property  rights  has  reached  83%  of  the  total  property  rights  of  the 
country. Out of these, 52% are at the stage of public consultation or at a 
later  stage  out  of  which  34%  are  in  operating  cadastre.  Regarding  the 
transition  to  the  new  entity,  43  cadastral  offices  out  of  95  have  opened 

Investment licensing.  

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

Cadastre.  

Greece will fully establish the cadastral agency and complete 45% of 
cadastral  mapping,  with  a  view  to  ratifying  the  complete  cadastral 
mapping and forest maps. 

14 

 
 
Commitment 

State of play and next steps 

and  the  corresponding  mortgage  offices  have  been  closed.  The  rate  of 
new  openings  will  increase  when  the  on-going  recruitment  of  the 
77-strong transition team will be done by the end of the year. The tender 
documentation for the digitalization of the mortgage offices was approved 
by  the  governing  board  of  6 October  2021  and  is  ready  to  launch.  The 
road  map  that  was  agreed  in  July  2018  has  been  practically  completed. 
The  authorities  have  agreed  to  produce  a  quarterly  report  on  the 
completion  rate  of  the  cadastral  mapping  and  the  transition  to  the  new 
entity, divided by region.  

The  ratification  of  the  forest  maps  has  encountered  further 
substantial  delay.  The  forest  maps  that  were  produced  by  the  Hellenic 
Cadastre  need  to  be  ratified  in  order  for  the  cadastre  to  be  complete. 
About  50%  of  the  country  has  ratified  maps;  another  45%  of  the  maps 
were uploaded for public consultation (for the citizens to detect errors and 
raise objections) in  February 2021. The maps were due to be ratified by 
April  2022  after  an  extension  of  the  objection  period.  Nevertheless,  the 
authorities decided to  grant  a  further  general  extension of the period for 
objections by another four months (and twenty day for residents abroad) 
in October 2021. The authorities justified the extension by the impact of 
the fires of summer 2021, which destroyed 130 000 ha of forest land and 
are  stretching  the  capacity  of  the  forest  services.  They  also  noted  that 
delay was partly due to a court case that was eventually dismissed by the 
Council of State and a major reorganisation of the forestry services that is 
currently  underway.  While  these  factors  are  acknowledged,  they  would 
justify  a  targeted  exemption  in  specific  areas  affected  by  the  fires  or  in 
particularly  complex  cases.  The  repeated  horizontal  extensions  put  the 
timely  completion  of  the  cadastre  at  risk.  The  authorities  noted  that  the 
remaining  forest  maps  will  be  ratified  by  mid-2022,  which  is  subject  to 

15 

 
 
Commitment 

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. 

State of play and next steps 

significant implementation risks. 

The  Hellenic  Republic  has  transposed  the  antitrust  remedy  into 
Greek  law.  The  measures  adopted  by  the  authorities  allow  the 
competitors  of  the  Public  Power  Corporation  (PPC),  the  Greek  state-
owned  electricity  incumbent,  to  purchase  more  electricity  on  a  longer-
term basis, which closes this long standing anti-trust case. This completes 
the reform of the energy sector, which was a specific commitment (3).  

its  evolution  and  moves 

The  Corporation  finalised  the  work  on  the  update  of  its  strategic 
plan. The Strategic Plan entails the strategic goals and the strategic levers 
of  the  Corporation.  The  Plan  sets  out  a  structured  emphasis  on  the 
Corporation’s role as an active shareholder, in response to the Ministerial 
Guidance provided to the Corporation by the authorities in early 2021. As 
the  Corporation  continues 
the 
implementation  of  the  new  Plan,  it  remains  critical  for  all  parties  to 
uphold the independence of the Corporation in line with its founding Law 
as this will contribute to the achievement of its mandate and the continued 
positive performance in terms of value creation of the assets of the Greek 
state. The Plan entails the Corporation acting as an investor in the Greek 
economy  and  as  a  reformer  of  the  state-owned  enterprises  under  it  and 
broadly its transformation to a Public Wealth Fund, and sets out various 
overall Key Performance  Indicators by which to track the Corporation’s 
performance. These Key Performance Indicators include overall portfolio 
performance indicators, which is an important step forward in developing 

into 

(3) As reported in the fourth enhanced surveillance report (November 2019), following the cancellation of the NOME (Nouvelle Organisation de Marché de l’Electricité), 
which was a specific commitment for end-2019, the Greek authorities committed to put in place additional structural measures in the context of an alternative remedy for 
the anti-trust case, which have herewith been completed. 

16 

 
 
                                                 
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State of play and next steps 

financial  accountability  for  the  Corporation,  as  well  as  key  social  and 
sustainability indicators. The Plan also includes a set of changes that are 
needed  to  modernise  the  legal  framework  applicable  to  state-owned 
enterprises,  which  in  turn  are  essential  for  the  success  of  the  Strategic 
Plan.  A  further  feature  is  that  the  Plan  includes  benchmarks  for  state-
owned  enterprises  performance,  by  comparing  the  Corporation’s  state-
owned  enterprises  with  similar  companies  elsewhere  in  Europe,  which 
should  assist  in  objectively  evaluating  the  progress  of  state-owned 
enterprises  in  delivering  operational  and  financial  outcomes.  The  Plan 
was  approved  by  the  Board  of  Directors  of  the  Corporation  and  it  is 
expected  to  be  subsequently  approved  by  its  General  Assembly  by 
end-November 2021. 

The  Steering  Committee  set  up  under  the  Coordination  Mechanism 
concluded its work on the preparation of a performance contract for 
the  Athens  Urban  Transport  Organisation  (OASA).  Following  an 
agreement  on  the  methodology  to  estimate  the  amount  of  compensation 
for  the  delivery  of  special  obligations  (that  is,  providing  free  or 
discounted  transfer  for  specific  groups),  the  Athens  Urban  Transport 
Organisation  finalised  the  drafting  of  the  performance  contract,  which 
was discussed and approved by the Steering Committee at the beginning 
of November 2021. The pending actions for its execution are expected to 
be  completed  by  end-November.  The  performance  contract  is  a  further 
important  step  forward  in  clarifying  the  financial  compensation  of  the 
State for costs that accrue to Athens Urban Transport Organisation for the 
delivery  of  public  policy,  and  toward  the  Organisation’s  operational 
improvement,  independence  and  financial  sustainability.  Moreover,  the 
authorities  consider  that  the  performance  contract  for  the  Athens  Urban 
Transport  Organisation  could  become  the  pilot  for  other  performance 
contracts  in  the  public  sector.  As  a  general  reform  effort,  performance 

17 

 
 
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State of play and next steps 

contracts  are intended to  clarify the financial relationship between  state-
owned enterprises and the state, and link financial transfers by the state to 
the  performance  of  specific  policy  goals.  This  should  help  the  public 
understand  whether 
appropriately 
compensated and whether the state receives good value for money. 

state-owned 

enterprises 

are 

The Corporation has, within the framework of the preparation of its 
Strategic Plan and as noted above, identified further changes that are 
needed to address legal and other impediments to the modernization 
and  commercial  operation  of  the  state-owned  enterprises  in  its 
portfolio.  These  changes  include  increasing  the  responsibility  and 
accountability  of  state-owned  enterprises’  boards  and  management  for 
key corporate decisions and corporate performance, as well as a range of 
other  changes  related  to  human  resources,  governance,  synergies  and 
internal audit. These changes are all considered essential for state-owned 
enterprises to transition to high-performing companies delivering quality 
products  and  services,  and  financial  performance.  Addressing  them  is  a 
key  priority  for  the  success  of  the  Corporation  in  its  endeavour  towards 
ensuring  that  state-owned  enterprises  under  the  Corporation  become 
operationally and financially independent, doing business in a customer-
centric way and in line with private sector principles. The Corporation has 
presented  a  set  of  necessary  changes  in  the  Strategic  Plan,  and  the 
authorities  intend  to  prepare  draft  legislation  in  the  coming  months, 
including as noted below.  

The authorities continued with the work on the modernisation of the 
institutional  framework  for  state-owned  enterprises.  Following  the 
mapping  of  the  state-owned  enterprises  and  other  public  entities  into  6 
main categories based on a number of criteria, including the share of the 
fiscal  consideration  and  board  appointment 
state’s  participation, 

18 

 
 
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State of play and next steps 

procedures,  the  authorities  are  working  on  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  authorities expect  a first  draft  of legislation to codify, 
improve  and  modernise  the  current  legal  framework  applicable  to  state-
owned  enterprises  to  be  ready  for  public  consultation  by  end  January 
2022. 

The Public Real  Estate Company (ETAD) will require more time to 
elaborate  a  comprehensive  strategy  to  achieve  an  ambitious  target 
yield  across  its  portfolio.  While  the  Public  Real  Estate  Company  has 
taken steps in relation to specific assets to improve their performance and 
has  seen  success  on  those  projects,  there  is  still  significant  work  to  be 
done  by  the  company  to  achieve  systemic  improvements  across  the 
portfolio as a whole, and progress towards delivering an overall yield for 
its  portfolio  that  is  comparable  to  peers.  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  was  launched  in  September  2021.  Following  this 
exercise,  a  final  list  of  assets  for  transfer  will  be  developed.  The 
authorities clarified the timetable for the process  with  completion of the 
verification process by end-January 2022 and the eventual transfer of the 
eligible assets by end-March 2022.  

19 

 
 
Commitment 

HCAP.  

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

Privatisation.  

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

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

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. 

20 

State of play and next steps 

The authorities continued the work on the development of the master 
plan.  With  the  assistance  of  external  consultants,  the  authorities  are 
preparing  feasibility,  market  and  financial  studies,  which  will  provide 
input  to  the  plan  for  the  future  use  of  the  facility  as  a  civic  park, 
leveraging  its  core  athletics  heritage,  and  adding  various  mixed-uses 
aimed  at  increasing  the  site’s  amenity  to  citizens  and  tourists  and  at 
ensuring the financial sustainability of the facility. This analytical work is 
expected to be completed by the end of the  year. It is important that the 
overall  strategy  for  the  site  ensures  that  the  site  can  generate  enough 
organic  revenue  to  ensure  the  financial  sustainability  of  a  high  quality 
civic  facility  over  the  long  term,  covering  not  just  maintenance,  but 
expected improvements and capital investments.  

The  updated  Asset  Development  Plan,  which  constitutes  the 
privatisation  programme  and  lays  down  the  next  steps  for  the 
transactions included in it, was approved by the Board of the Hellenic 
Republic Asset Development Fund and endorsed by the Government 
Council  for  Economic  Policy  on  12 November  2021.  Progress  with 
specific transactions since the last report has been as follows: 

Egnatia: Good progress was made in the tender process for the long-term 
concession of Egnatia over the past months. The selection of the preferred 
investor  was  made  on  26 August  2021,  as  reported  in  the  11th  enhanced 
surveillance report, for a financial offer comprising of an upfront payment 
of  about  €1.5 billion  and  an  annual  payment  amounting  to  7.5%  of  the 
annual  total  gross revenue of the concessionaire. The  authorities plan to 
proceed with the completion and operation of the toll stations as well as 
with the completion of the works and the licensing of all tunnels. Within 
this  framework  a  specific  timetable  for  the  completion  and  operation  of 
each one of the last toll stations (7 lateral and one frontal) as well as for 

 
 
 
Commitment 

State of play and next steps 

the licencing of each one of the remaining 16 tunnels has been elaborated 
by Egnatia SA in October. Close monitoring will continue. 

Regional  ports of Alexandroupolis  and Kavala: The draft Concession 
Agreement for the port of Alexandroupolis is expected to be uploaded on 
the  virtual  data  room  for  comments  to  the  prequalified  investors  by 
end-November 2021. The draft of the Sub Concession Agreement for the 
port  of  Kavala  has  been  released  to  prequalified  investors  for  their 
comments on 24 September 2021, and their comments were submitted on 
18 October  2021.  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. The hearing before the Court took place on 22 October 
2021 and the decision was issued on 10 November, while next steps in the 
process are to be decided by the competent Ministries. 

Regional port of Igoumenitsa: The Concession Agreement document is 
expected  to  be  finalised  by  the  beginning  of  December  2021  and  to  be 
subsequently  uploaded  on  the  virtual  data  room  to  the  pre-qualified 
investors  for  comments.  The  pending  issue  on  the  determination  of  the 
upland zone of Igoumenitsa port will be fully resolved as it will be clearly 
specified  in  the  concession  agreement,  and  thus  the  tender  process  can 
proceed. 

Regional  port  of  Heraklion:  The  completion  of  the  assessment  of  the 
Investors Expressions of Interest and the short listing of the prequalified 
parties  for  the  binding  offers  phase  is  expected  to  be  completed  by 
end-November 2021. 

21 

 
 
 
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State of play and next steps 

Public Gas Corporation (DEPA) Infrastructure: The tender process is 
proceeding  well.  As  already  reported  in  the  11th  enhanced  surveillance 
report, the selection of the preferred investor took place on 9 September 
2021  for  a  financial  offer  of  €733 million.  This  corresponds  to  about 
€476 million for the 65% stake of the Fund in DEPA Infrastructure. The 
file was submitted to the Court of Audit for approval on 26 October 2021 
and its approval was given on 11 November 2021. 

Public  Gas  Corporation  (DEPA)  Commercial:  The  Fund  decided  to 
extend  the  suspension  of  the  binding  offers  phase  of  the  tender  at  least 
until  end-December  2021,  so  as  to  have  more  clarity  on  the  outcome  of 
pending issues. 

Underground Natural Gas Storage (UGS) South Kavala: Based on the 
envisaged timeline of the tender, submission of binding offers is expected 
in  the  first  quarter  of  2022.  The  first  draft  Concession  Agreement  is 
expected to be shared with prequalified investors by end-December 2021. 
The pending issue on clarity of the tariff setting framework, is expected to 
be resolved via the issue of the decision of the Regulatory Authority for 
Energy by end-November 2021.  

Gournes  Heraklion:  On  15 October  2021  four  interested  parties 
submitted  binding  offers  for  the  exploitation  of  part  of  the  former 
American military base of Gournes in Heraklion, Crete (a beachfront land 
plot of 345 567 square meters located 13 km from the airport and 16 km 
from Heraklion). The development of Gournes is described by many as a 
smaller  Hellinikon  project. The  selection  of  the  preferred  investor  is 
expected by end-November 2021. 

As reported in the previous reports, some transactions had to be delayed 

22 

 
 
 
 
 
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State of play and next steps 

Public administration.  

the 

(digital 
Complete 
organigram  for  all  public  entities  and  link  with  single  payment 
authority). 

integrated  HR  Management  System 

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. 

Justice. 

In  the  context  of  implementing  the  Three-Year  Action  Plan  on 
legal  documents 
the  electronic  filing  of 
Justice, 

implement 

23 

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. 

Job  descriptions  have  been  completed  for  81%  of  all  posts,  which 
constitutes a key element in the establishment of an integrated human 
resources  management  system.  The  authorities  are  expecting  to  have 
job descriptions in place for all posts by January 2022, which would close 
this  commitment.  The  appointment  of  the  Permanent  Secretary  at  the 
Ministry  of  Education  and  Religious  Affairs  remains  pending.  The 
authorities  informed  that  legal  provisions  to  facilitate  the  completion  of 
this appointment would be adopted by end-November 2021. These legal 
provisions  are  expected  to  be  consistent  with  the  principles  of  the 
Executive  State  Law  in  terms  of  delegation  of  signature  powers  to  civil 
servants.  

Work on the codification of labour legislation continues. A high-level 
legal scientific Committee has been set up under the Ministry of Labour 
and  Social  Affairs  to  work  on  the  legal  codification  of  the  Labour  Law 
Code and Code of Labour Regulatory Provisions that is now progressing 
in  close  collaboration  with  the  Central  Codification  Committee.  A  first 
codified  draft  is  expected  to  be  submitted  to  the  Secretariat  General  for 
Legal and Parliamentary Affairs in the first quarter of 2022. The Central 
Codification  Committee  will  proceed  with  the  review  of  the  codified 
legislation as a priority with a view to adopting it as soon as possible. 

Further  progress  has  been  made  with  regard  to  the  specific 
commitment on electronic e-filing. More specifically: 

(i) 
Regarding  the  implementation  of  e-filing  in  civil  courts,  the 
authorities  reported  further  progress  on  the  digitisation  of  court 

 
 
Commitment 

State of play and next steps 

throughout the Courts, having completed the tendering procedure. 

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). 

procedures. In the context of the digitization of judicial procedures, the 
authorities resolved to develop new electronic platforms relating to (a) the 
processing  of  small  claims  disputes,  (b)  the  filing  of  third-party 
statements  in  the  context  of  the  enforcement  proceedings,  (c)  the 
registration  of  consensually  granted  collateral  in  the  context  of  loan 
agreements and (d) the issuance of payment orders. The authorities have 
drafted  working  documents  regarding  all  four  projects  and  formed 
corresponding  working  groups;  upon  receipt  of  feedbacks  by  the  judges 
participating  in  the  working  groups  regarding  implementation  questions 
and the need for the adoption of legislation, a maturity assessment will be 
made  and  further  actions  will  be  planned.  A  Joint  Ministerial  Decision 
allowing  for  the  operationalisation  of  the  e-divorce  platform  will  be 
adopted by end-December 2021.  

(ii)  Regarding  the  implementation  of  mandatory  e-filing  in 
administrative  courts,  the  tendering  procedure  for  the  extension  of 
functionality  and  the  pilot  phase  for  the  interconnection  with  the 
Legal  Council  of  State  database  are  advancing.  Following  the 
completion  of  the  procurement  competition  launched  June  2021,  the 
managing committee of the Council of State awarded the contract to the 
successful candidate on 28 September 2021 and the contract was signed 
on  22 October  2021, 
the 
implementation  of  the  contract  and  a  subsequent  two-month  period  for 
the  completion  of  the  pilot  phase  and  the  full  operationalisation  of  the 
project  (expected  in  April  2022),  whereupon  the  e-filing  of  all  kinds  of 
documents  and  submissions  will  be  available.  Furthermore,  the  pilot 
phase of the project for the interconnection between the IT systems of the 
Legal  Council  of  State  and  the  Council  of  State  is  ongoing  and  is 
expected to be concluded on 20 December 2021, making thus the project 

four-month  period 

initiating  a 

for 

24 

 
 
Commitment 

State of play and next steps 

fully functional and operational. 

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  additional  delay,  making  the  previous 
target  for  awarding  the  project  in  the  first  quarter  of  2022 
unattainable.  The  draft  call  for  proposals  was  submitted  to  public 
consultation  on  1 November  2021;  following  the  expiry  of  the  public 
consultation period on 16 November 2021, the finalised call for proposals 
is  expected  to  be  launched  by  10  January  2022  (as  opposed  to  end-
September  2021  and  end-October  2021  respectively  according  to  the 
previous  enhanced  surveillance  report).  The  European 
institutions 
expressed  concern  about  the  delay  in  the  tender  and  encouraged  the 
authorities to take the necessary actions to ensure the efficient conduct of 
the process going forward. 

The authorities have progressed further with implementing measures 
to  address  the  remaining  recommendations  from  GRECO’s  fourth 
evaluation round.  

1.  Recommendation  on  the  selection  of  senior  positions  of  judges  and 
prosecutors,  and  on  disciplinary  proceedings:  The  new  code  for  the 
organisation  of  justice  and  the  status  of  officers  of  the  courts  aims  at 
enhancing the process within the current constitutional framework and is 
expected to be adopted by end-December 2021. 

2.  Recommendation  on  providing  guarantees  against  delays  and 
improving caseload management: A number of initiatives are under way 
to  address  this recommendation. The adopted mediation law (November 
2019)  provides  for  a  mandatory  mediation  procedure  in  specific 
commercial, civil and family cases, while a similar procedure is foreseen 

Fight against corruption.  

Implement  all  recommendations  addressed  by  the  Group  of  States 
against Corruption (GRECO). 

25 

 
 
Commitment 

State of play and next steps 

under  the  amended  criminal  procedure  code  that  was  published  recently 
for  consultation.  Further,  the  adopted  unified  code  of  procedure  for  the 
Court of Audit (June 2020) contains a number of measures to ensure that 
cases are handled within a reasonable timeframe and to improve caseload 
management.  Similar  provisions  are  expected  to  be  introduced  with  the 
code for the organisation of justice and the status of officers of the courts. 
The above initiatives are complemented by the establishment of e-justice 
systems  and  of  the  JustStat  unit  for  judicial  data  collection.  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 Court of 
Audit  judges  (November  2020).  Moreover,  two  working  groups  are 
developing codes of conduct for administrative judges, as well as for civil 
and  criminal  court  judges  and  prosecutors  (completion  expected  by 
December 2021). 

Amendments  to  the  Criminal  Code  and  the  Code  of  Criminal 
Procedure  that  were  adopted  in  November  2021  aim  at  addressing 
the  recommendations  concerning  the  bribery  of  public  officials, 
the 
included 
amendments to these codes contain the following.  

in  GRECO’s  ad-hoc  report.  More  specifically, 

1. Recommendation on the penalty framework: The article that regulates 
the  offence  of  bribery  of  public  officials  amends  the  penalty  framework 
and rises the relevant sanction to imprisonment.  

2.  Recommendation  on  abstention  of  prosecution:  The  amendments 
intend  to  limit  the  scope  of  corruption  clauses  that  can  be  subject  to 
abstention of prosecution. 

26 

 
 
Commitment 

State of play and next steps 

3. Recommendation on prosecution of foreign officials: The amendments 
extend the concept of a public official as a subject of the crime of bribery 
to foreign officials. 

4.  Recommendation  on  effective  regret:  A  relevant  article  that  provided 
for specific provisions on effective regret is repealed. 

Complementary commitments undertaken by Greek authorities in May 2020  

Complementary commitment 

State of play and next steps 

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. 

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. 

27 

Following  the  Athens  and  Thessaloniki  courts  of  appeal  and  the 
Thessaloniki  court  of  first  instance,  the  decision  amending  the 
internal  regulation  of  the  Athens  court  of  first  instance  has  been 
submitted to the Supreme Court for approval. The operation of special 
chambers has effectively started in Thessaloniki and the Athens Court of 
Appeal,  following  the  lifting  of  the  pandemic-mandated  suspension  of 
judicial  proceedings,  as  of  the  beginning  of  the  ongoing  judicial  year 
(September 2021). The European institutions encouraged the authorities to 
henceforth monitor and report on uptake based on the registration of cases 
on the corresponding dockets of the relevant courts. 

The Code for the Organisation of Justice and the Status of Officers of 
the Courts is expected to be adopted by end-December 2021 and enter 
into force on 1 January 2022. The European institutions encouraged the 
authorities  to  share  the  text  of  the  draft  code  prior  to  the  launch  of  the 
public consultation procedure.  

 
 
 
Complementary commitment 

State of play and next steps 

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  and  introduce  the  relevant 
legislation. 

Public administration.  

Strengthen the hiring control of the public sector through setting  an 
annual ceiling of temporary staff. 

The requisite secondary legislation to operationalise the JustStat unit 
was  signed  and  submitted  to  the  Council  of  State  for  the 
constitutionality  control  and  is  expected  to  be  adopted  by  end-
December 2021, broadly in line with the timeline presented in the 11th 
report.  The  members  of  the  supervisory  committee  will  be  appointed 
within  one  month  from  the  adoption  of  the  secondary  legislation. 
Meanwhile, an electronic platform developed in order to allow the courts 
to upload statistical data is currently operational. 

A Cabinet Act  was adopted that sets a ceiling for temporary staff to 
be  hired  in  2022.  The  ceiling  for  2022  is  set  at  25 344,  which  is  10% 
lower  than  the  temporary  posts  for  2020.  It  is  noted  that  needs  for 
temporary  staff  arisen  due  to  extraordinary  circumstances,  such  as  a 
pandemic  or  natural  disasters,  falls  outside  the  scope  of  the  adopted 
ceiling.  

Due  to  unforeseen  developments  it  was  not  possible  to  reach  the 
expected reduction of temporary teachers following the conversion of 
10 500  teachers  to  permanent  contracts.  The  census  (‘Apografi’)  for 
September  2021  showed  a  reduction  of  temporary  staff  hired  by  the 
Ministry of Education and Religious Affairs that was close to the number 
of  teachers  (10 500)  that  were  hired  ahead  of  the  new  school  year  on  a 
permanent  contract.  However,  the  authorities  informed  that  there  is  an 
exceptional need for 3 000 new temporary teachers for the current school 
year.  This  is  due  to  unexpectedly  high  retirements  of  teachers  and 
increased  demand  for  special  support  to  pupils  coupled  with  specific 
needs  due  to  the  ongoing  pandemic.  The  authorities  committed  to  carry 
out  a  review  of  needs  of  permanent  and  temporary  teachers  in  the 
medium-  to  long-term,  while  the  exceptional  increase  of  temporary 
teachers will be offset for the next school year (2022-2023).] 

28 

 
 
Complementary commitment 

State of play and next steps 

The size of the public administration burdening the state budget has 
seen  an  increase  by  2.6%  since  2018,  which  is  mainly  due  to  the 
increase of temporary staff. This is also consistent with the trajectory of 
the  wage  grid,  which  is  expected  to  increase  by  6%  in  the  period  2018-
2022 (4).  As  shown  in  the  table  below,  the  level  of  permanent  staff  has 
remained stable, while temporary staff and elected officials have  seen an 
increase  of  around  25%.  It  is  noted  that  the  additional  staff  hired  due  to 
the pandemic are not accounted for in this table. 

Table .[x]:  Evolution of public sector staff (2009-2020) 

(1) The figure includes all temporary contracts in general government entities and 
legal entities under private law. For 2018-2020 the figure is a yearly average (Jan-
Dec) while for 2021 is the average of the period January-September 2021. For 2020 
and 2021, the figures do not include the staff involved in the treatment of COVID-
19. 
(2) 2021 figures refer to the September 2021 data except for temporary staff. 
Source: Greek authorities (‘Apografi’ database).  

Efforts continue in addressing unjustified salary deviations, as part of 
the  authorities’  commitment  to  strengthen  central  control  of  hiring 

(4) The calculation caters for ad hoc factors such as the wage refunds paid in 2018, the increase in social security contributions, which is fiscally neutral, and the temporary 

increase in healthcare wages due to the pandemic. 

29 

YearPermanent staffTemporary staff burdening the budget (1)Elected staffOther categoriesTotal2018601 78964 9118 8876 027681 6142019604 56472 03210 2806 320693 1962020602 78974 47310 9946 528694 7842021(2)600 93480 84311 0336 645699 455Change  to 2018-0.1%24.5%24.1%10.3%2.6% 
 
 
  
 
                                                 
Complementary commitment 

State of play and next steps 

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. 

Strategic project pipeline.  

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

and  salary  provisions. A  list  identifying  all  deviations  from  the  unified 
wage  grid  covering  the  period  from  2016  until  today  is  expected  to  be 
completed  by  end-2021  with  relevant  legal  provisions  adopted  by  April 
2022.  Finally,  the  inter-ministerial  committee  mandated  to  prepare  a 
methodology  aiming  to  streamline  the  hazardous  and  arduous  work 
allowance  has  completed  its  work  with  legal  provisions  expected  to  be 
adopted by end-2021. 

The preparatory work on drawing up a holistic and coherent strategy 
is still underway. With the assistance of external consultants, the Hellenic 
Corporation  of  Assets  and  Participations  continues  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  Executive  Committee  and  the  Government  Committee  for 
Contracts  of  Strategic  Importance  became  fully  operational  as  from 
July  2021.  Following  preparatory  work  by  the  Executive  Committee, 
which  included  a  request  for  submission  of  projects  by  Ministries  and 
other public sector entities (including municipalities and SOEs), the first 
Development Programme of Contracts of Strategic Importance is expected 
to be concluded by end-November 2021. With the preparation of the first 
Development  Programme  of  Contracts  of  Strategic  Importance,  the 
commitment will be considered as completed. 

Project preparation facility.  

The  Project  Preparation  Facility  became  fully  operational  as  from 

30 

 
 
Complementary commitment 

State of play and next steps 

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. 

Public procurement.  

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

mid-November.  The  Facility  is  intended  to  mature  and  provide  broader 
support to 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 to the facility was finalised on 8 November 2021, and the first 
contracts  with  the  beneficiaries  are  expected  to  be  signed  in  the  coming 
weeks.  Furthermore,  the  tender  process  for  framework  contracts  for 
consultants is expected to be launched by end-November 2021. Regarding 
projects  funded  under  the  Recovery  and  Resilience  Facility,  the  relevant 
contract   for  the  funding  of  the  Facility’s  related  costs  has  been  signed 
between the Ministry of Finance and the Fund on 12 November 2021; for 
other projects, the discussions between the Fund, the Hellenic Corporation 
of Assets  and Participations  and the authorities  were  concluded  ensuring 
adequate prefunding. 

Public  procurement  reform  steadily  progresses  to  operationalise  the 
new  regulatory  framework,  also  in  the  wider  context  of  the  recently 
adopted  strategy.  Notably,  the  updated  templates  for  procurement 
documents  are  now  in  use  by  contracting  authorities  nationwide,  whilst 
the  authorities  implemented  policy  changes  in  the  area  of  centralised 
procurement  for  general  goods  and  services,  namely  in  the  design  of 
framework contracts. According to the authorities, such changes led to an 
acceleration of contract award procedures and an increase in the quality of 
goods and services purchased. Further, the authorities adopted secondary 
legislation  to  set  up  a  system  of  supervision  and  management  of  public 
works  and related studies by certified private bodies. This  is expected to 
facilitate the effective and timely execution of such contracts. 

The  adoption  of  the  remaining  secondary  legislation  critical  for  the 
implementation  of  newly  introduced  elements  of  the  new  law 

31 

 
 
Complementary commitment 

State of play and next steps 

progresses with a short delay, and is now expected to be completed by 
end-November 2021. These relate to the set up of a registry of certified 
private-sector engineers in order to complement scarce public resources in 
exercising control for certain value contracts for public works and studies, 
and to the transition to an Integrated System for Technical Specifications 
and Costing of Technical Works, including the set up of a new legal entity 
to  develop  and  maintain  this  system.  The  new  system  is  expected  to 
provide in a digitally accessible manner a comprehensive and uniform set 
of  rules,  methods  and  tools  to  support  the  planning,  development  and 
implementation of all technical works.  

The  authorities  are  preparing  a  bill  aiming  at  enhancing  the 
autonomy  of  higher  education  institutions,  strengthen  accountability 
and transparency and promote extroversion, innovation and research 
in the Greek universities. The bill intends to improve study completion 
rates,  reduce  skills  mismatch  and  graduate  unemployment.  Measures 
include  the  transfer  of  responsibilities  from  the Ministry  of  Education  to 
universities,  the  establishment  of  internal  accountability  procedures, 
streamlining  of  institutional  governance  through  a  clear  division  of 
responsibilities  between  the  management  and  the  academic  boards  with 
the introduction of university councils. The bill is expected to be tabled in 
Parliament only in the first trimester of 2022, compared with the end-2021 
timeline indicated in the 11th report. 

The  implementation  of  new  digital  services  and  applications  steadily 
progresses,  underpinned  by  enabling  actions  to  enhance  system 
interoperability and data exchange within the public administration. 
New services to citizens include the digital delivery of certificates such as 
for proof of criminal record and school-leaving certificates, in addition to 
the expansion of the application of ‘MyDeskLive’ platform, most recently 

Education.  

Enhance  the  autonomy  of  higher  education  by  strengthening  the 
accountability  and 
the 
introduction of the University Council. 

framework  and 

transparency 

through 

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 

32 

 
 
Complementary commitment 

State of play and next steps 

infrastructure mid-2021. 

33 

to cover social insurance services. These supplement previously included 
services  of 
tax  administration,  citizens’  service  centres,  public 
employment  services  and  Greek  consulates  worldwide,  with  the  so  far 
total  number of citizens’ transactions serviced through video calls across 
these  services  amounting  to  more  than  13 000  since  the  initial  launch  of 
the  platform.  New  services  are  facilitated 
the  ongoing 
implementation  of  interoperability  initiatives  and  data  exchange  through 
the  central  interoperability  hub.  To  date,  270  public  systems  have  been 
migrated  to  a  g-cloud  environment,  facilitating  efficient  and  secure  data 
exchange. 

through 

The  implementation  of  digital  initiatives  further  contributed  to  a 
number  of  other  policy  objectives,  including  in  health  and  social 
policy.  For  instance,  the  authorities  implemented  the  ‘Freedom  Pass’,  a 
digital  card  for  vaccinated  citizens  aged  18-25,  providing  them  with  a 
lump  sum  contributing  to  specific  expenses,  and  the  ‘Data  Pass’  for 
vaccinated  youth  aged  15-17,  entitling  them  to  a  free  package  of  mobile 
data  for  6  months.  Other  advances  include  the  set  up  of  the  ‘edupass’ 
platform  to  facilitate  health  control  at  university  and  school  premises 
nationwide,  by  providing  live  information  to  these  establishments  about 
the  vaccination  status  and  covid  testing  of  students  physically  attending 
classes. Further, the authorities launched a mobile application for eHealth 
to  enable  citizens  to  access  personal  data  included  in  the  electronic 
prescription system, a proponent for the Electronic Health Record System, 
which will be linked to this application.