COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, February 2022 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance Update - Greece, February 2022
Date: 2022-02-23
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, 23.2.2022  SWD(2022) 50 final  COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, February 2022 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance Update - Greece, February 2022 {COM(2022) 78 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.  

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. 

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

State of play and next steps 

The  2022  budget,  voted  in  December  2021,  expects  the  deficit 
monitored under enhanced surveillance to reach 1.2% of GDP in 2022, 
which  is  aligned  with  Commission  2021  autumn  forecast.  The  fiscal 
policy setting planned for 2022 takes into account the continued application 
of the general escape clause 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. A full 
update of the fiscal forecast will be prepared in spring in the context of the 
assessment of the 2022 Stability Programme. 

The work on developing the 2nd level of functional classification (mid-
2022 specific commitment) is ongoing. It is expected to be finalised by 
end of April and published in the annual update of the Medium Term Fiscal 
Strategy. The development of the 2nd level of functional classification is 
assisted  by  a  working  group  consisted  of  representatives  from  Hellenic 
Statistical  Authority,  Ministry  of  Finance  and  Ministry  of  Development 
and Investment. 

The stock of non-pension arrears has decreased significantly since the 
last report but remained above the target. In December 2021, the stock 
of non-pension arrears amounted to €238 million, down by €316 million 
compared to its September level. The gap to the December target set in the 
March  2021  clearance  plan  narrowed  to  €73  million.  The  decrease  can 
mainly  be  attributed  to  the  actions  undertaken  in  the  previous  period  to 
accelerate  the  clearance  of  arrears.  In  particular,  the  capital  increase  to 
support  public  entities  in  the  defence  sector  and  payments  to  public 
transport companies in relation to the conduct of public sector obligations 

1 

 
 
Commitment 

State of play and next steps 

increased  their  liquidity  and  resulted  in  a  significant  decrease  of  their 
arrears. In addition, the envisaged measures in the sector of public hospitals 
contributed to the clearance of the biggest part of hospitals’ arrears. On the 
other  hand,  the  results  from  the  application  of  the  mechanism  for  the 
prevention  of  arrears  accumulation  in  local  governments  are  yet  to  be 
shown. Some payments already took place in December 2021 but the full 
impact is expected in the coming months in view of the time lag observed 
between  the  activation  of  the  mechanism  and  the  actual  clearance  of 
arrears. The non-pension arrears are expected to be materially cleared by 
end of February 2022.  

The  clearance  of  pension  arrears  also  shows  some  positive 
developments.  The  stock  of  pension  arrears  in  December  amounted  to 
€267 million, down by €93 million compared to the stock in September. 
This translates to a limited deviation from the target set in October 2021 of 
€17 million. The observed improvement is a result of a number of factors, 
including the implementation of the IT system for the processing of pension 
claims (‘Atlas’), the introduction of automated procedures in the pension 
processing workflow, and the use of smart Business Intelligence tools and 
analytics. On the other hand, some other initiatives are behind schedule. 
This concerns in particular the efforts to involve in certified lawyers and 
accountants into the processing of pensions, where delays occurred partly 
due  to  lower-than-expected  rates  of  passing  qualification  tests  and  the 
belated delivery of software automations, which would allow new types of 
pensions claims (i.e. self-employed, public sector, etc.) to be processed by 
the IT system. The authorities reiterated their intention to fully clear the 
pension arrears by mid-2022, as agreed in the twelfth report. 

The  implementation  of  the  recommendations  made  by  the  Hellenic 
Court of Auditors and the simplification of fiscal  procedures are on 
track.  The  vast  majority  of  reforms  identified  by  the  Hellenic  Court  of 

2 

 
 
Commitment 

State of play and next steps 

Tax administration. 

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

Tax policy.  

Auditors have  already been  completed and the  authorities continue their 
efforts  to  finalise  the  remaining  ones.  Notably,  the  authorities  have 
amended the regulatory framework for the fixed expenses, which allows 
for the simplification of payment and control procedures and will help the 
prevention  of  new  arrears.  In  addition,  the  authorities  have  prepared  the 
Ministerial  decision  which  simplifies  the  framework  of  the  multi-annual 
obligations and is expected to be adopted with a delay, by end of February. 

The new IT collection system for the Independent Authority for Public 
Revenue has encountered delays due to the contractor not submitting 
a final version of all parts of the IT system on time, as a result the full 
operationalisation is now expected to take place by  September 2022. 
Some  progress  has  been  made,  as  the  Independent  Authority,  in 
cooperation  with  the  Ministry  of  Digital  Governance,  has  set  up  an  IT 
platform that will host the new IT system (‘EISPRAKSIS’). While its full 
operationalisation  was  planned  by  end-April  2022,  the  Independent 
Authority  still  expects  a  number  of  its  central  and  special  decentralised 
services, including the directorate of collection and refund, the collection 
operation unit and the Attica debt collection centre, to start using its core 
functions (e.g. debtor and debt management, risk analysis and management 
of insolvency procedures) by then. The final submission by the contractor 
of  the  complete  IT  system  is  scheduled  for  end- June  2022.  By 
end-September 2022, the complete IT system will be fully operational and 
utilised  throughout  the  Independent  Authority,  including  its  local  tax 
offices with a collection function, with some 1 100 staff having received 
training and been assigned as users. 

The  authorities  have  reached  the  final  stage  of  preparation  of  the 
ENFIA property tax reform allowing for the 2022 bills to be sent out 
in  April  2022.  The  application  of  the  new  market-related  property  tax 
values  will  widen  the  tax  base  and  improve  the  fairness  and  economic 

3 

 
 
Commitment 

State of play and next steps 

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. 

efficiency  of  the  property  tax.  An  agreement  has  been  reached  on  the 
detailed tax rate structure and fiscal cost of the reform that will be legislated 
in February 2022. Owing to technical factors, the tax assessment will take 
place with a minor delay in April 2022.  

(*) Health care.  

The authorities will complete the full offsetting and collection of the 
clawback by June every year for the previous calendar year. 

Health care.  

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

The  collection  of  the  2020  clawback  is  progressing  according  to 
schedule  for  pharmaceuticals  and  providers.  The  administrative 
procedure for the collection of the 2020 clawback for pharmaceuticals and 
for providers has been completed, fulfilling the milestones for the current 
review. For pharmaceuticals, the authorities have finalised the instalment 
plan for 2020, which has been notified to the companies. For providers, the 
instalment schemes were finalised during January. A total of €35 millions 
is not covered by instalments and will be collected in one single payment.  

There is overall good progress in both categories for 2021 and the new 
collection  methodology  for  providers  is  proving  effective.  The 
calculation of the pharmaceuticals clawback for the first semester of 2021 
was completed timely and the quantification stands at €425 million, rather 
stable compared to the same semester of the previous year (€435 million). 
The  new  methodology  implemented  in  2021  for  the  collection  of  the 
providers clawback is delivering good results, although with some delays. 
The target of 50% of the 2021 to be collected by the time of the current 
review will be fully met only in March. However, considering the delay in 
the  introduction  of  this  new  system,  progress  so  far  can  be  considered 
satisfactory. 

The planned adoption of the revised legislative framework for primary 
health care was postponed to April 2022 and also the openings of the 
additional  primary  healthcare  units  (TOMY)  is  delayed  beyond  the 
current review. The reform envisages patient registration and gatekeeping 
based on a system of financial incentives, whereby  patients  who  are not 

4 

 
 
Commitment 

State of play and next steps 

registered with a family doctor or do not follow the referral pathway would 
bear increased costs. Providers would be reimbursed per registered patient 
based on age-band-specific coefficients reflecting the expected intensity of 
care required. The model may also envisage means-tested entry fees into 
the primary health care  system.  Lastly, new contracts  for family doctors 
contracted by the Single Healthcare Fund (EOPYY) will be implemented 
as  part  of  the  package.  There  are  delays  in  the  planned  opening  of  the 
60 additional  primary  healthcare  units,  which  shifts  beyond  the  current 
review. 

Some  key  parameters  of  the  system  are  still  under  definition.  The 
outcome of the implementation of this model hinges on elements such as 
the size of the financial incentives and on the compulsory registration of 
the whole population, as limited cost differences between self-referring and 
being referred by  a family doctor may not  succeed in  discouraging self-
referrals. There is also an intrinsic risk to equality in access to healthcare, 
linked  to  the  implementation  of  a  system  based  on  financial  incentives. 
Similarly,  the  element  of  entry  fees  may  represent  a  barrier  to  access, 
depending on its final design. Lastly, the stock of public family doctors is 
still  inadequate  and  its  improvement  may  be  affected  by  the  revised 
contracts for family doctors contracted by the Single Healthcare Fund. 

The procurement activity by the centralised health procurement body 
EKAPY  is  on  track  for  the  40%  target  to  be  achieved  by  end-April 
2022.  Following  the  adoption  of  the  revised  legislative  framework  in 
December of last year, the centralised health procurement body EKAPY is 
progressing towards the recruitment of procurement specialists making use 
of the increased flexibility provided by the new law. EKAPY will meet its 
staffing needs through a combination of fixed-term contracts, of permanent 
positions  and  secondments.  According  to  the  existing  timeline  of 
procurements, the objective to reach a value of at least €320 million by end-

5 

Health care.  

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

 
 
Commitment 

State of play and next steps 

Social welfare.  

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

Social welfare.  

Complete the set-up of the single pension fund EFKA. 

April  2022  in  terms  of  completed  tenders  (i.e.  signed  contracts)  appears 
within  reach. This  amount represents  the 40% of total  hospital spending 
that can be subject to centralised procurement, i.e.  €800 million. In fact, 
current  estimates  suggest  that  contracts  of a value between  €350 million 
and  €370 million  could  be  signed  by  mid-2022,  which  may  however 
include some from tenders launched in 2021. 

Secondary  legislation  is  expected  to  be  adopted  by  end-March  2022 
allowing the application of a new disability assessment approach for 
granting  personal  assistance  benefits  based  on  both  medical  and 
functional  criteria.  A  Joint  Ministerial  Decision  by  the  Ministers  of 
Labour  and  Social  Affairs  and  Health  setting  out  the  new  disability 
assessment approach to apply for social assistance benefits in April 2022 
is  underway  and  is  expected  to  be  adopted  by  the  end  of  March.  At 
operation level,  an agreement  has been reached  between the Ministry of 
Labour and Social Affairs and  the Ministry of Digital  Governance’s TA 
framework  contract  ‘Information  Society  S.A.’  that  will  undertake  the 
implementation of the personal assistance scheme.  

The  authorities  completed  the  setup  of  the  Single  Pension  Fund 
(EFKA), fulfilling the commitment under enhanced surveillance. The 
completion of the setup of the Single Pension Fund was a key commitment 
to the Eurogroup monitored under enhanced surveillance. The objective of 
the reform was to improve the efficiency of the pension system and further 
reduce  its  administrative  costs.  To  this  end,  the  Supplementary  Pension 
Fund (ETEAEP) and EFKA were merged into e-EFKA in 2020. In parallel, 
the authorities pursued an ambitious consolidation and digitalisation of all 
pension  system  data  to  speed-up  the  processing  of  pension  applications. 
Important  steps  in  this  consolidation  process  included  the  operational 
integration of the funds into e-EFKA and the setting up of a new structure 
for the local offices of e-EFKA. In June 2021, the authorities provided a 

6 

 
 
Commitment 

State of play and next steps 

(*) 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. 

timeline for the opening of the network of local offices, which would mark 
the completion of the organizational setup, while the finalisation of the IT 
infrastructure  is  progressing  well.  While  originally  planned  for  the  first 
quarter of 2022, the opening of local units was finalized ahead of schedule 
in December 2021. Over and above the efforts envisaged under enhanced 
surveillance, the authorities recently put into public consultation a bill that 
is expected to further support the operation of e-EFKA. The bill envisages 
incentives  for  increasing  productivity  of  staff,  while  strengthening  the 
accountability  of  its  employees  and  providing  more  flexible  recruitment 
and procurement rules. 

The  functioning  of  the  early  warning  platform  completed  the 
electronic  infrastructure  of  the  new  insolvency  framework  and  only 
the set-up of the sale and lease-back mechanism is still pending. All the 
necessary  secondary  legislation  has  been  adopted,  with  the  exception  of 
five ministerial decisions that concern the sale and lease-back mechanism. 
The  early  warning  platform  became  fully  operational  at  the  start  of 
December, complementing the existing 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. The out-of-court workout 
scheme attracted initially strong interest by debtors, which was followed 
by a more moderate but constant flow of new application initiations in the 
platform.  However,  out  of  the  43 795  applications  initiated  as  of  end-
December 2021, only 393 applications or 0.9% of those initiated had been 
submitted and not recalled by that date, while another 28 141 applicants are 
waiting for the collection of data from institutional creditors. As a response 
to this low percentage of applications completed so far, the authorities are 
preparing a new round of workshops, including dedicated in-depth training 
sessions to familiarise users with the workings of the platform. In parallel, 

7 

 
 
Commitment 

State of play and next steps 

the authorities intend to engage in March in a dialogue with stakeholders 
on the initial results from the implementation of the new framework. 

The  concessionary  process  for  the  setup  of  the  sale-and-lease-back 
entity is expected to be launched in February, following past delays. 
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-February 2023, while the full operationalisation of 
the  new  entity  is  not  expected  before  end-March  2023.  The  call  for  the 
expression of interest is expected to be launched in February 2022 and is 
due to be completed, with the preselection of eligible candidates, by mid-
April 2022, to be followed by the conduct of the competitive dialogue and 
the bidding phase.  

An interim scheme is being considered by the authorities to ensure a 
smooth  transition  until  the  sale-and-lease-back  entity  commences 
operations and mitigate litigation risks. The Insolvency Code provides 
for  the  protection  of  vulnerable  debtors  under  the  sale-and-lease-back 
mechanism. In view of the delays with the establishment of the mechanism, 
an  interim  scheme  is  being  designed,  according  to  which  the  state  will 
provide  financial  support  to  vulnerable  debtors  until  the  initiation  of 
operation of the sale-and-lease-back entity or for a maximum period of 15 
months. This financial support will take the form of a partial state subsidy 
on  the  servicing  of  loans,  encumbered  with  the  primary  residence  of 
vulnerable debtors that are certified as such under the conditions of the new 
insolvency  code  and  have  been  declared  bankrupt,  or  whose  primary 
residence is about to be auctioned. Putting in place strong safeguards will 
be instrumental in countering unintended use of the scheme and mitigate 
legal risks.  

8 

 
 
Commitment 

State of play and next steps 

is  advancing,  effectively  filtering  out 

The assignment of new hearing dates for pending household insolvency 
cases  is  picking  up  but  clearance  of  the  backlog  still  falls  short  of 
expectations  and  is  not  envisaged  before  end-2023.  The  authorities 
have taken steps to increase processing capacity. The latest set of data 
received  by  the  authorities  confirm  that  the  processing  of  household 
ineligible 
insolvency  cases 
applications, albeit at a slower pace than initially expected (1). Given that, 
apart  from  pandemic-related  reasons,  the  high  number  of  unprocessed 
applications are mainly a result of the limited case-processing capacity of 
courts, the authorities reported the secondment of 14 judges to courts facing 
difficulties, of whom twelve have taken up their posts, with the remaining 
two  expected  to  follow  suit  in  March  and  April  2022  respectively. 
Moreover,  in  order  to  further  accelerate  the  proceedings  by  appointing 
hearing dates as close to the present as possible, the authorities confirmed 
that  the  adoption  of  amendments  to  the  internal  working  regulations  of 
courts facing the most acute situation is being considered, with a view to 
allowing the inscription of up to 60 household insolvency cases in the daily 
docket instead of the current maximum of 30 cases. 

The recent entry into force of numerous revisions of the Code of Civil 
Procedure is expected to have a positive impact on the case-processing 
capacity  in  general  and  increase  the  efficiency  of  enforcement 
proceedings. Given that the amendments to the Code entered into force on 
1 January 2022, it will not be possible to assess their impact before the end 

(1) Out of the 49 031 submitted applications, 43 104 were validated by 31 December 2021 (representing a 4% increase since November 2021) and 
15 703, or 32% of the total, were assigned a new hearing date (representing a 20% increase since November 2021), while 32 820 cases are yet 
to receive a hearing date. Of all cases that have received a hearing date, 14 562 (92.7%) are scheduled for a hearing within 2022, 1 081 (6.9%) 
within 2023 and 60 (0.4%) up to September 2024. In addition to these cases, the authorities have also reported 1 245 instances where only an 
interlocutory decision (i.e. postponing the issuance of a final decision for need of additional evidence) has been issued by the court and a new 
hearing is still pending, with 945 cases planned to be heard in 2022, 259 in 2023 and 41 in 2024. 

9 

 
 
                                                           
Commitment 

State of play and next steps 

of  the  current  judicial  year  in  mid-June  2022.  Regarding  enforcement 
proceedings,  the  procedure  for  the  automatic  adjustment  of  the  reserve 
price in the context of the conduct of auctions should eliminate significant 
delays  in  the  relevant  proceedings.  The  authorities  committed  to  take 
statistical surveys of the relevant procedural streams and report to the EIs 
in the course of the next enhanced surveillance mission. 

The conduct of auctions continues to increase since its resumption in 
September 2021. According to the aggregated data for 2021 provided by 
the  authorities,  out  of  the  23 073  auctions  planned,  11 318  (49%)  were 
concluded, while 11 658 (50.5%) were suspended. A very small number of 
auctions was cancelled. 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 advancing regarding the introduction of enhancements to the 
e-auctions  platform  and  the  adoption  of  legislation  is  planned  to 
remove perceived legal impediments. The two working groups referred 
to in the previous two enhanced surveillance reports were merged and the 
relevant proposals will be submitted to the Ministry of Justice on a date yet 
to be defined by the authorities. Finally, the authorities reported being in 
the process of adopting legislation to expressly expand the territorial scope 
for the conduct of auctions by Athens notaries in the neighbouring area of 
Piraeus, thus removing a perceived impediment to such schedulings; the 
relevant provision is expected to be adopted by end-March 2022. 

The  authorities  remain  committed  to  meet  the  agreed  targets 
concerning the processing and clearance of the backlog of called state 
guarantees by mid-2023 and mid-2024, respectively. The revised action 
plan of the authorities envisages the full examination of accumulated called 
loan  guarantees  by  the  third  quarter  of  2022  for  corporate  claims  and 

10 

 
 
Commitment 

State of play and next steps 

second  quarter  2023  for  natural  persons’  claims,  followed  by  the 
completion  of  all  payments  by  the  second  quarter  2024.  There  was  a 
material  increase  in  the  number  of  claims  examined  and  the  value  of 
expected  payments  in  fourth  quarters  2021,  but  the  rate  of  increase  was 
lower  than  expected.  Moreover,  while  the  processing  of  claims  has 
accelerated, this is only partially reflected in actual payments, resulting in 
regular  revisions  to  the  intermediate  quarterly  targets.  Meeting  the  set 
targets  for  2022  will  require  almost  a  threefold  increase  in  the  claims 
examined per quarter compared to what was achieved in the fourth quarter 
2021 and a more than commensurate increase in payments. This increase 
will depend on the smooth execution of planned recruitment and training 
of  the  additional  35  employees,  which  is  not  expected  to  be  completed 
before the end of the first quarter of 2022. The authorities have committed 
to  provide  monthly  updates  on  the  pace  of  clearance  and  will  assess  if 
further corrective actions would be required.  

Discussions  progressed  well  on  the  future  of  the  Hellenic  Financial 
Stability Fund. 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 in the coming months and will be reported on in the 14th report.  

Following the 2% increase in the gross statutory minimum wage that 
came  into  effect  on  1  January  2022,  discussions  are  underway  for  a 
possible second adjustment of its level in May 2022 in light of the recent 
price  hikes.  Secondary  legislation  setting  out  the  new  gross  statutory 
minimum wage level from 1 January 2022 was adopted on 27 December. 
The  new  level  brings  about  a  2%  increase  compared  to  its  level  on 
1 January 2019 when it was last changed (e.g. from €650 to €663 per month 
on a 14-month basis or €773.5 per month on a 12-month basis for workers 

11 

(*) Labour market. 

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

 
 
Commitment 

State of play and next steps 

Investment licensing.  

Greece will finalise inspection legislation. 

Investment licensing.  

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

of up to three years of work experience). A possible second increase in the 
gross  statutory  minimum  wage  is  expected  to  take  place  in  May  2022 
following  an  amendment  of  Law  4172/2013  that  sets  out  the  relevant 
revision  process.  The  legal  amendment  shortens  the  timeline  of  the 
consultation process that will apply in 2022 only (from February-July to 
January-April) allowing for any change in the minimum wage to take place 
already on 1 May 2022. The process itself and its various steps, including 
the established consultations with  research, scientific and social partners 
and  the  involvement  of  an  independent  Committee  of  economic  experts 
the  section  on  macroeconomic 
have 
developments for further assessment.  

remained  unchanged.  See 

Secondary legislation for the inspection reform in the last remaining 
area of environmental protection has not been finalised in time for this 
review  but  is  expected  to  be  adopted  shortly.  The  authorities  are 
finalising secondary legislation to enable the activation of the enforcement 
management model, which is necessary to facilitate a harmonised approach 
in the application of enforcement. Adoption of this last piece of legislation, 
which  has  been  delayed  due  to  the  necessary  consultations  to  ensure 
constitutional  conformity  of  the  reform,  is  now  expected  shortly,  as  the 
consultations have recently been completed. This will mark the completion 
of the environmental inspections reform and the commitment.  

The authorities successfully completed the commitment to finalise the 
simplification  of  investment  licensing  in  the  agreed  sectors.  The 
authorities completed the last step through the adoption of the secondary 
legislation  for  the  simplification  of  licensing  procedures  for  education 
activities,  i.e.  private  institutes  for  vocational  training,  colleges,  private 
tutoring centres and language  centres. Completing the technical setup of 
the  new  simplified  processes  for  all  recently  reformed  activities  would 
allow for a swift implementation of the simplified procedures. This reform 

12 

 
 
 
Commitment 

State of play and next steps 

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. 

has led to streamlined licensing requirements and has reduced the extent of 
ex-ante  control  currently  imposed  for  several  economic  activities  on  the 
basis  of  a  risk-assessment  approach. In  addition  to  the  abovementioned 
activities related to education, the reform covered the areas of transport and 
transport-related  services,  social  welfare, tourism, physical  well-being, 
personal  and  health  services,  leasing  of  maritime  leisure  equipment, 
lifeguard  training,  livestock  installations,  aquaculture,  veterinary  clinics 
and pet breeding and trading. With support from the EU’s Recovery and 
Resilience Facility, the reform will be further extended to new economic 
activities, including canteens, internet rooms, organization of conventions 
and trade shows, child day-care activities, social care housing facilities for 
the  elderly  and  disabled,  tourist  ports  and  ski  resorts.  A  new  licensing 
framework will also be developed in line with the principles of the reform 
for non-therapeutic spas and massage centres, artificial tanning units, and 
storage of boats in land areas.  

The cadastral mapping and the transition to the full establishment of 
the Hellenic Cadastre continued to progress in the past three months. 
The tender for the digitalization of the mortgage offices has been launched 
and offers were received on 11 January 2022. The collection of property 
rights has reached 84% of the total property rights of the country. Out of 
these,  35%  are  in  operating  cadastre  and  19%  in  public  display,  which 
means that  54% of the country’s total  property rights  are  at  the stage of 
public  consultation  or  at  a  later  stage.  It  is  expected  that  60%  of  total 
property  rights  will  be  in  operation  or  publicly  displayed  (uploaded)  by 
end-April 2022. This figure will reach 71% in October 2022. 

The ratification of the last 50% of forest maps will start in May 2022 
and  will  be  completed  by  July  2022.  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 

13 

 
 
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State of play and next steps 

February  2021.  These  maps  were  due  to  be  ratified  by  April  2022.  The 
authorities  have  granted  an  extension  of  the  objections  period  of  four 
additional  months  in  October  2021.  The  extension  was  justified  by  the 
impact of the wild fires of summer 2021 which destroyed 130 000 ha of 
forest  land  and  stretched  the  capacity  of  the  forest  services  which 
additionally triggered a major reorganisation of the services. According to 
the revised plan, it is expected that by July 2022, 95% of the forest maps 
would  be  ratified  and  96%  would  be  achieved  by  October  2022.  The 
ratification  of  the  forest  maps  is  necessary  for  the  completion  of  the 
cadastral mapping. 

Regarding the transition to the new entity, 9 cadastral offices (out of 
17) and 38  branches (out of 75) have opened and the corresponding 
mortgage offices have been closed. Opening of new offices continues at 
a  rate  of  two  per  month  and  it  is  estimated  that  by  April  2022,  55-57 
cadastral offices and branches will be in operation. However, the rate of 
further openings may be affected by a lack of managerial staff. Recruitment 
of  28  specialists  for  the  positions  of  Heads  of  Cadastral  offices  was 
launched in January 2022 through the High Council for Selection of Staff 
(ASEP). The recruitment process is expected to last about a  year, which 
could affect the timely completion of the transition.  

The  strategic  plan  was  approved  by  the  General  Assembly  on 
31 January 2022 and started to be implemented by the Corporation. 
The Plan sets out the top-level key performance indicators by which the 
Corporation will track its performance, as well as detailed actions for the 
Corporation  to  act  as  an  investor  and  a  reformer  in  the  state-owned 
enterprises  in  its  portfolio.  Within  the  framework  of  the  enhanced 
engagement of the Corporation in its subsidiaries, it is planning to monitor 
closely  the  alignment  of  the  business  plans  of  the  subsidiaries  to  the 
Strategic  Plan,  including  the  close  monitoring  of  the  set  for  each 

14 

(*) Hellenic Corporation of Assets and Participations (HCAP). 

The  Strategic  Plan  of  HCAP  will  be  implemented  on  a  continuous 
basis. 

 
 
Commitment 

State of play and next steps 

state-owned enterprise key performance indicators. Key for improving the 
performance  of  the  state-owned  enterprises  under  the  Corporation  is  the 
adoption  of  a  set  of  changes  that  are  needed  to  modernise  the  legal 
framework applicable to state-owned enterprises. The necessary changes 
are  set  out  in  the  Strategic  Plan.  They  include  enabling  state-owned 
enterprises’ boards to exercise the typical responsibilities of public limited 
companies  (sociétés  anonymes),  including  in  relation  to  staffing  and 
internal  organisation,  as  well  as  strengthening  internal  controls  and 
utilising  synergies.  The  changes  are  expected  to  be  reflected  in  the 
forthcoming  legislation  setting  out  broader  modernisation  of  the  legal 
framework applicable to state-owned enterprises (see dedicated paragraph 
below). 

Shortly before the closure of this report, the Council of State provided 
its  decision  relating  to  the  Corporation’s  ownership  of  the  majority 
stakes in the water utilities of Athens and Thessaloniki. The Council of 
State ruled in February 2022 the transfer of these stakes to the Corporation 
in  2018  unconstitutional.  The  decision  and  its  implications  for  the 
Corporation’s portfolio is currently under assessment. 

The Corporation has begun implementing the updated strategic plan, 
in particular in relation to asset valuations. It has begun the process of 
tendering  advisors  to  provide  valuations  of  all  assets  to  give  a  reliable 
valuation of the whole portfolio. For state-owned enterprises this valuation 
is expected to be completed by the end of 2022. For the Public Real Estate 
Company (ETAD), which comprises the main part of the valuation given 
its extensive real estate portfolio, the valuation is scheduled for completion 
by the end 2023 – though the process will be structured to provide initial 
actionable information soon after the process begins. 

The Corporation finalised updates to the Investment Policy and this 
was approved by the shareholder on 31 January 2022. The Investment 

15 

 
 
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State of play and next steps 

Policy will be supplemented by a Technical Supplement covering technical 
matters, which is expected to be finalised by end-February. 

Following the conclusion of the work of the Steering Committee set up 
under  the  Coordination  Mechanism  on  the  preparation  of  a 
performance contract for the Athens Urban Transport Organisation 
(OASA),  the  competent  Government  Committee  approved  the 
performance contract, which was subsequently signed by the Athens 
Urban  Transport  Organisation  and  the  competent  ministries  on  2 
December  2021.  The  performance  contract  is  intended  to  clarify  the 
financial  relationship  between  the  Athens  Urban  Transport  Organisation 
and the state and link financial transfers by the state to the performance of 
specific  policy  objectives.  Budgetary  appropriations  have  been  made  by 
the Ministry of Infrastructure and Transport for the implementation of the 
contract in 2022. The next step for the full implementation of the contract 
is the issuance of a joint ministerial decision that would make possible the 
payment on a monthly basis, in 12 instalments of the budgeted amount. The 
joint ministerial decision is expected to be issued by end-February. 

Also  in  relation  to  the  Coordination  Mechanism,  the  Statements  of 
Commitments  of  each  state-owned  enterprise  will  now  need  to  be 
updated following the approval of the strategic plan. This is expected 
during the first quarter of 2022. The Statements of Commitments set out 
key  objectives  for  state-owned  enterprises  as  agreed  between  the 
state-owned enterprise and the Corporation, and will need to be updated to 
reflect the strategic priorities set out in the strategic plan. 

The authorities prepared components of a first draft of the legislation 
for the modernisation of the institutional framework for state-owned 
enterprises.  The  draft  legislation  aims  at  the  codification,  improvement 
and  modernisation  of  the  current  legal  framework  applicable  to  the 
state-owned  enterprises  inside  and  outside  the  Corporation.  The  draft 

16 

 
 
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State of play and next steps 

legislation  is  divided  in  two  sections  (i)  a  section  on  public  limited 
companies in which the state has at least 50% of the share capital but which 
are not held by the Corporation and (ii) a section on the indirect subsidiaries 
of  the  Corporation.  The  institutions  look  forward  to  a  constructive 
engagement  with  the  authorities  in  the  final  elaboration  of  the  specific 
legislation,  following  the  sharing  of  the  draft  legislation  with  the 
institutions.  The  Corporation  has  specified  a  set  of  reforms  to  the 
framework  in  its  Strategic  Plan  that  are  all  necessary  for  the  effective 
functioning of the enterprises in the Corporation's portfolio. 

There has not been material progress in improving the management of 
the real estate portfolio. The holistic strategy from the Public Real Estate 
Company  (ETAD)  aimed  at  accelerating  the  development  of  the 
company’s assets remains pending. The Public Real Estate Company has 
continued its efforts to improve the performance of specific assets and has 
seen  some  success  on  those  projects.  However,  systemic  improvements 
across the portfolio as a whole, with a view to delivering an overall yield 
for its portfolio that is comparable to peers, are not evident. Turning this 
situation around, and delivering value from the real estate portfolio, is a 
critical  responsibility of  the  Public Real  Estate Company  and key to  the 
success of the Corporation. To achieve this turnaround, it is fundamental 
for the Public Real  Estate Company to  be viewed as, and operate like a 
private sector real estate manager. The valuation exercise that will unfold 
over  the  coming  18  months  is  also  intended  to  create  a  clear  basis  for 
performance measurement and improvement. 

With regard to the transfer of the eligible real estate assets included in 
the 2018 package to the Public Real Estate Company, a working group 
has  been  set  up  to  accelerate  the  process  of  final  verification  of  the 
eligible  for  transfer  assets  and  resolve  potential  issues. The  working 
group is composed of representatives from the General Secretariat for Tax 

17 

 
 
 
Commitment 

State of play and next steps 

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, 

Policy and Public Property, the General Secretariat for Coordination, the 
Hellenic Corporation of Assets and Participations and the Public Property 
Company  (ETAD).  The  final  verification  process  is  expected  to  be 
concluded by end-May 2022 and the eventual transfer of the eligible assets 
by end-June 2022. 

The authorities continued the work on the development of the master 
plan. A study setting the guidelines for the financial sustainability of the 
facility, that 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, is expected to be 
finalised by end-February. Separately, the authorities are preparing a tender 
for a detailed feasibility study (including a relevant business plan) based 
on  the  guidelines  and  strategy  depicted  in  the  consultants’  preliminary 
study under finalisation, looking at issues such as market depth in order to 
evaluate the financial feasibility of the various uses under consideration. 
This  feasibility  study/business  plan  is  expected  in  March  2023. It  is 
reiterated that it is crucial that the overall strategy for the site ensures that 
the site can generate enough 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  Government  Pending  Actions  List  was  updated  by  the  Fund  in 
January 2022. Progress with specific transactions since the last report has 
been as follows: 

Egnatia: The authorities reiterated their commitment 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.  In  line  with  the  submitted 
during the last review timetable, the authorities launched the construction 

18 

 
 
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State of play and next steps 

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. 

works for two lateral toll stations (Chalastra) in mid-February 2022, and 
the construction works on four additional toll stations (three lateral and one 
frontal) continued. Pending is the launching of the construction in the last 
two lateral toll stations, whereby the technical resolution of an open issue 
needs to be decided. In total, 17 out of 18 frontal toll stations and 31 out of 
40  lateral  toll  stations  are  currently  in  operation.  With  regard  to  the 
licensing of the remaining 16 tunnels under category E (i.e. excluding the 
transport of dangerous cargo), a study has been finalised in January 2022, 
providing clarity as to what additional works will be needed. By end-April 
2022, it is expected that there will be the completion and operation of one 
frontal  and  three  lateral  toll  stations,  the  licensing  under  category  E  of 
seven  tunnels  and  the  submission  of  the  file  to  the  Court  of  Audit.  By 
end-October 2022, the two lateral toll stations in Chalastra are expected to 
be put into operation, and the remaining tunnels licensed under category E. 
The financial closing is planned for the end of 2022. 

Regional  ports of Alexandroupolis  and Kavala: The draft Concession 
Agreement  for  the  port  of  Alexandroupolis  was  uploaded  on  the  virtual 
data  room  for  comments  to  the  prequalified  investors  on  15  December 
2021. The expropriation process of the private properties in the upland zone 
area  of  the  port  of  Alexandroupolis  is  in  progress.  The  competent 
Ministries  of  Finance  and  Shipping  have  decided  on  the  next  steps  as 
regards  the  necessary  budgetary  resources  to  be  made  available  for  the 
expropriation. The submission of binding offers is scheduled for end-April 
2022. The selection of the preferred investor is expected by end-July and 
the  financial  closing  by  end-December  2022.  For  the  port  of  Kavala, 
binding offers are expected by end-February 2022, whereas the selection 
of  the  preferred  investor  is  expected  by  end-April.  Financial  closing  is 
expected by end-December 2022. 

19 

 
 
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State of play and next steps 

Regional port of Igoumenitsa: The Concession Agreement document was 
finalised  in  December  2021  and  sent  to  the  competent  Ministries  for 
comments.  It  was subsequently uploaded on the  virtual  data room to the 
pre-qualified  investors  for  comments  on  9 February  2022.  The  pending 
issue on the determination of the upland zone of Igoumenitsa port has been 
fully resolved as it is  clearly specified in  the concession agreement, and 
thus the tender process can proceed. The submission of binding offers is 
scheduled  for  end-June  2022.  The  selection  of  the  preferred  investor  is 
expected by September 2022.  

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 by end-February 2022, thus 
launching the binding offers phase for the transaction. The submission of 
binding offers is scheduled by end-September 2022. 

Public  Gas  Corporation  (DEPA)  Infrastructure:  Following  the 
approval of the file by the Court of Audit on 11 November 2021, the Share 
Purchase  Agreement  between  the  preferred  investor,  and  the  current 
shareholders of DEPA Infrastructure (the Fund having a stake of 65% and 
Hellenic Petroleum with a stake of 35%) was signed on 10 December 2021. 
The next steps are the approval of the preferred investor by the Hellenic 
Competition Commission and its certification by the Regulatory Authority 
for  Energy.  The  financial  closing  of  the  transaction  is  expected  by 
end-April 2022 for a financial offer of €733 million (for the 65% stake of 
the Fund, this corresponds to €476 million).  

Public  Gas  Corporation  (DEPA)  Commercial:  The  Fund  decided  to 
extend the suspension of the Binding Offers Phase of the tender further, so 
as to have more clarity on the outcome of pending issues. 

20 

 
 
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State of play and next steps 

Underground Natural Gas Storage (UGS) South Kavala: Following the 
completion of all technical studies and their uploading on the virtual data 
room, prequalified investors were granted access to the Virtual Data Room 
in December 2021. The first draft Concession Agreement is expected to be 
shared  with  prequalified  investors  by  end-February  2022.  The  pending 
issue on clarity of the tariff setting framework is expected to be resolved 
via  a  decision  of  the  Regulatory  Authority  for  Energy  expected  by 
end-February  2022.  Based  on  the  envisaged  timeline  of  the  tender, 
submission of binding offers is expected by end-May 2022. The selection 
of the preferred investor is expected by end-July 2022 and the signing of 
the concession agreement by end-December 2022. 

Gournes  Heraklion:  Following  the  submission  of  binding  offers  on  15 
October 2021, an electronic auction was conducted with the participation 
of  the  prequalified  for  improved  financial  offer  investors  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.  On  9 
December, the Board of Directors of the Fund approved the result of the 
electronic auction of improved financial offers for Gournes and nominated 
as preferred investor the highest bidder of the electronic auction process, 
with a total consideration of €42.2 million in nominal prices. The file of 
the  tender  process  is  expected  to  be  sent  to  the  Court  of  Audit  by 
end-February for pre-contractual review. The financial closing is expected 
by end-July 2022. 

Attiki  Odos:  The  Attiki  Odos  is  a  modern  motorway  extending  along 
70 km.  It  constitutes  the  ring  road  of  the  greater  metropolitan  area  of 
Athens  and  the  backbone  of  the  road  network  of  the  whole  Attica 
prefecture.  The  tender  for  the  award  of  a  concession  agreement  for  the 

21 

 
 
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State of play and next steps 

operation and maintenance of the Attiki Odos for a period of 25 years will 
be conducted in two phases: Phase A (submission of expression of interest 
and  pre-qualification  of  investors)  and  Phase  B  (submission  of  binding 
offers and selection of the concessionaire). The tender for the submission 
of the expression of interest was launched on 20 January and the deadline 
for submission of expressions of interest is 20 April. 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 
concluded by end-June 2022, thus launching the binding offers phase for 
the transaction. The submission of binding offers is scheduled for the end 
of 2022.  

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. 

Job  descriptions  have  been  completed  for  95%  to  all  posts,  thus 
completing  this  specific  commitment.  In  total,  more  than  346 500  job 
descriptions  have  been  prepared.  Together  with  the  digital  organisation 
charts that are in place since January 2021 2 the job descriptions constitutes 
key  elements  in  the  establishment  of  an  integrated  human  resources 
management system for the Greek public administration.  

Legal provisions paving the way for the appointment of a Permanent 
Secretary at the Ministry of Education and Religious Affairs have been 
agreed  and  are  expected  to  be  adopted  by  end-February  2022.  The 
agreed  legal  provisions  reflect  the  specificities  of  this  Ministry,  in 
particular  relating  to  religious  affairs,  but  overall  these  provisions  are 

Public administration.  

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

2 9th Enhanced surveillance report, European Commission, February 2021. 

22 

 
 
                                                           
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State of play and next steps 

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 Justice, 
implement  the  electronic  filing  of  legal  documents  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). 

considered 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 with a view to 
adopting  the  Labour  Law  Code  and  Code  of  Labour  Regulatory 
Provisions  in  May  2022.  A  cooperation  agreement  has  been  reached 
between  the  Ministry  of  Labour  and  Social  Affairs  and  the  Secretariat 
General for Legal and Parliamentary Affairs on the way forward. A first 
codified  draft  of  the  Labour  Law  Code  and  Code  of  Labour  Regulatory 
Provisions is expected to be submitted by the Ministry to the Secretariat 
General  for  Legal  and Parliamentary  Affairs by the end of March 2022. 
The Central Codification Committee will proceed with the review of the 
codified legislation as a priority. Adoption of the Labour Law Code and 
Code of  Labour Regulatory Provisions is  expected to  take place in  May 
2022.  

Implementation  of  mandatory  e-filing  in  administrative  courts  is 
advancing and both parts of the project are expected to be concluded 
by  April  end  of  the  first  quarter  of  2022.  The  pilot  phase  for  the 
interconnection with the Legal Council of State database was completed on 
20  January  2022  and  the  authorities  confirmed  that  the  competent 
committee accepted delivery of the work on condition of correction of bugs 
within  February,  with  the  productive  functioning  of  the  interconnection 
being expected by the first week of March 2022; as for the extension of the 
functionality of the administrative courts’ platform, the implementation of 
the  contract  was  completed  on  21  February  2022;  the  currently  ongoing 
two-month pilot phase is due to lead to the full operationalisation of the 
project  by  end-April  2022,  whereupon  the  e-filing  of  all  kinds  of 
documents and submissions is expected to become available, bringing the 
project to its conclusion. 

23 

 
 
 
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State of play and next steps 

The  launch  of  the  call  for  bids  for  the  integrated  case  management 
system  for  civil  and  criminal  cases  (‘OSDDY-PP’)  has  been  further 
delayed and is due to be launched in March 2022. Following the expiry 
of the public consultation period on 16 November 2021, the finalised call 
for proposals was amended to incorporate selected feedback and is being 
finalized by the managing authority; the authorities committed that the call 
will be launched in the first week of March 2022, with a six-month delay. 
The European institutions reiterated their concern about  the delay in  the 
launch of the call for proposals tender and encouraged  the authorities to 
ensure the efficient and unhindered conduct of the process going forward, 
so that the award of the contract will be effected as projected by the call of 
proposals. 

launched 

in  Athens  and 

its 
An  e-docket  platform  has  been 
functionality  will  gradually  extend  across  the  territory  of  Greece. 
Regarding  the  digitisation  of  court  dockets,  for  enabling  stakeholders  to 
register  and  monitor  the  progress  of  cases  through  the  courts,  an  online 
platform was operationalized on 1 December 2021, covering the Athens 
first  instance court; citizens and legal  stakeholders can henceforth  query 
the  platform,  using  a  different  search  criteria,  on  the  exact  location  of 
hearings and on the status of the civil or penal procedure of interest (heard, 
adjourned, cancelled etc.). The authorities intend to gradually extend the 
functionality of the platform to all courts across Greece, starting with the 
three remaining ‘OSDDY-PP (first phase)’ first  instance courts (Piraeus, 
Thessaloniki and Chalkis). The relevant  draft contract  is  currently being 
reviewed by the Court of Audits and is expected to be finalized by the end 
of  the  first  quarter  2022,  enabling  the  gradual  territorial  roll-out  of  the 
platform  functionality,  starting  in  late  May  2022,  with  a  projected 
completion date by end August 2023. 

24 

 
 
Commitment 

State of play and next steps 

Fight against corruption.  

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

The e-divorce procedure is now fully functional. Following the adoption 
of the Joint Ministerial Decision allowing for the operationalisation of the 
e-divorce platform on 31 December 2021 (3), the procedure entered its fully 
operational stage for the general public on 3 February 2022. 

Further selected improvements of court procedures have been planned 
and  are  to  be  implemented  in  the  context  of  the  Recovery  and 
Resilience Facility. The authorities intend to develop and put into use e-
platforms  for  selected  judicial  procedures  (small  claims  disputes,  third-
party  statements  in  enforcement  proceedings,  the  consensual  grant  of 
collateral in the context of loan agreements and payment orders). In this 
context,  they  have  solicited  and  received  feedback  by  judges  and 
contemplate implementing the relevant projects in the context of the second 
phase of the OSDDY-PP project, as part of the justice-related actions of the 
Recovery and Resilience Plan. 

The  authorities  continued  working  towards  implementation  of  the 
remaining  recommendations  from  fourth  evaluation  round  of  the 
Group of States against Corruption (GRECO). 

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.  Its 
adoption has been delayed and it is now expected to be tabled to Parliament 
by the end of April 2022 (see also a specific section on Justice below). 

2. Recommendation on providing guarantees against delays and improving 
caseload management: Work continues with additional measures to address 

(3)   Ministerial Decision of the Ministers of Justice and the State No. 70057 OJ B 6390/31 December 2021. 

25 

 
 
                                                           
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State of play and next steps 

this recommendation including: (i) implementation of IT case management 
systems; (ii) establishment of JustStat unit for judicial data collection; (iii) 
qualitative elements for guiding and assessing the work of the courts to be 
introduced in the new Code for the Organisation of Justice and the Status 
of Officers of the Courts; (iv) improvements to the Code of Civil Procedure 
to simplify, digitalise and accelerate trial proceedings and to enhance legal 
certainty; (v) inclusion in the new Code of Criminal Procedure of tools such 
as criminal mediation and conciliation. The recommendation is expected 
to be implemented by April 2022. 

3. Recommendation on setting clear standards of professional conduct and 
integrity: The Charter of Judicial Ethics was adopted by the administrative 
full plenary of the Council of State in December 2021. 

In its latest plenary meeting, the Group of States against Corruption 
terminated  the  Rule  34  procedure  on  Greece  concerning  bribery  of 
public  officials.  More  specifically,  the  relevant  recommendations  were 
implemented through amendments to the Criminal Code and the Code of 
Criminal  Procedure  adopted  in  November  2021  that  included  the 
following:  (1)  rising 
to 
imprisonment;  (2)  limiting  the  scope  of  corruption  clauses  that  can  be 
subject to abstention of prosecution; (3) extending the concept of a public 
official as a subject of the crime of bribery to foreign officials; (4) repealing 
provisions on effective regret. 

the  bribery  of  public  officials  sanction 

26 

 
 
 
Complementary commitments undertaken by Greek authorities in May 2020  

Complementary commitment 

State of play and next steps 

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. 

The Code for the Organisation of Justice and the Status of Officers of 
the Courts is expected to be tabled to Parliament by the end of April 
2022,  and  enter  into  force  upon  publication  in  the  Official  Journal 
shortly thereafter. The authorities assured the European institutions that 
the  new  code  will  contain  the  newly  elaborated  chapters  on  disciplinary 
proceedings,  evaluation  and  professional  advancement  of  magistrates  in 
their full and final form. The revised sections are expected to contribute to 
increasing the efficiency and effectiveness of courts by revising evaluation 
standards  and  mechanisms  and  by  putting  in  place  a  fair  and  effective 
disciplinary  framework.  Among  other  things,  the  Code  is  expected  to 
contribute  to  alleviating  the  challenges  faced  by  courts  in  dealing  with 
personal  insolvency  backlogs  monitored  under  the  financial  policy 
commitment, in the sense that its revised disciplinary and promotion rules 
will  foster  a  culture  of  stricter  adherence  to  high  professional  standards 
amongst  the  members  of  the  judiciary.  A  quick  progress  with  the  key 
legislation is critical for a successful completion of the specific commitment 
on  the  fight  against  corruption.  The  authorities  committed  to  sharing  the 
text of the draft code in early March 2022, prior to the launch of the public 
consultation procedure. 

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. 

legislation 

The  adoption  of 
the 
the  requisite  secondary 
operationalisation  of  the  JustStat  unit  of  the  Ministry  of  Justice  is 
expected to be adopted with a nine-month delay, by end-March 2022. 
The  draft  presidential  decree  to  operationalise  the  JustStat  unit  was 
examined by the Council of State for conformity with the constitution and 
its remarks will shortly be addressed to the Ministry of Justice; following 
the completion of the appropriate amendments to the text, it is expected to 
be adopted by end-March 2022. The authorities confirmed that the members 

for 

27 

 
 
Complementary commitment 

State of play and next steps 

Public administration.  

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

Management of public real estate.  

Draw  up  a  holistic  and  coherent  strategy  aiming  to  optimize  the 
protection,  management  and  investment-oriented  exploitation  of 

of the supervisory committee will be appointed within two months from the 
adoption of the presidential decree. 

A  needs  assessment  of  permanent  and  temporary  teachers  in  the 
medium- to long-term will be completed by April 2022. The authorities 
have  assigned  the  Ministry  of  Interior  to  carry  out  this  study  with  the 
support of an independent human resources auditor. The study is expected 
to include considerations regarding the 3 000 exceptional temporary staff 
hired for the 2022-23 school year that have not been fully offset so far by 
reductions in permanent teaching positions. The authorities have confirmed 
that a timeline and overall scope for the needs assessment has been set and 
an independent human resources auditor has been assigned. 

As part of the authorities’ commitment to strengthen central control of 
hiring  and  salary  provisions,  a  list  identifying  deviations  from  the 
unified wage grid has been finalised with relevant legal provisions to be 
adopted  by  April  2022.  The  list  setting  out  deviations  from  the  unified 
wage  grid  covers  the  period  from  2016  until  September  2021  will  be 
presented to the Council of Ministers in February 2022. Legal provisions to 
address any deviation not considered justified are expected to be adopted 
by April 2022. Finally, a detailed report setting out the revised methodology 
for  the  allowance  for  hazardous  and  arduous  has  been  made  publicly 
available.  The  revised  framework,  which  allows  for  greater  transparency 
and predictability with the overall cost remaining unchanged, is expected to 
be adopted by all ministries by February 2022. 

The preparatory work on drawing up a holistic and coherent strategy 
is  progressing.  The  collection  of  all  the  required  information  and  the 
drafting of the request for proposal for the consultant that will work on the 
study for the elaboration of the real  estate strategy is underway  and it is 
expected to be finalised by end-February 2022. The process for the selection 

28 

 
 
Complementary commitment 

State of play and next steps 

public real estate, including all organizations involved with public real 
estate management, without prejudice to their mandates. 

Public procurement.  

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

Education.  

of the consultant, who will undertake the study is expected to be concluded 
by mid-April 2022, so that the work can start immediately thereafter and be 
completed by end-June 2022 with the finalisation of the strategy. As already 
reported in the 12th enhanced surveillance report, 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 authorities adopted two pieces of secondary legislation critical for 
the implementation of newly introduced elements of the new law, while 
the final one remains pending. The two adopted joint ministerial decisions 
concern  the  establishment  of  a  certification  framework  to  allow  the 
deployment  of  private-sector  engineers  in  the  audit  of  certain  value 
contracts for public works and studies. However, the adoption of the third 
pending joint ministerial decision to fulfil this commitment, which concerns 
the set-up of a new legal entity to develop and maintain a new integrated 
system for technical specifications and costing of technical works, has been 
delayed  and  is  now  expected  shortly.  The  latter  constitutes  an  important 
first  step to  introducing a unified approach in  the technical  and  financial 
management of all public works, in order to overcome distortions that lead 
to  large  variations  in  the  technical  specifications  and  pricing  of  similar 
projects.  The  actual  transition  to  the  new  system  itself  will  take  place 
following the achievement of the system’s full productive operation, which 
is expected by September 2022. 

The draft law on higher education is advanced, but not at a pace that 
would  allow  a  closer  assessment.  This  means  a  further  delay  of  this 
additional  commitment  compared  with  the  agreement  reached  in  the 
previous report,  which  was  to  have the draft law  ready  by  end-2021 and 
vote it in Parliament in the first quarter of 2022. The delay is partly due to 

29 

 
 
Complementary commitment 

State of play and next steps 

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

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 
infrastructure mid-2021. 

the substantial effort that was needed to keep universities open during the 
latest outbreak of the fourth COVID wave. The revised timetable is to put 
the bill in public consultation in March 2022 and adopt it in May 2022.  

The upcoming law foresees the establishment of a university council for 
each  institution  to  further  strengthen  the  autonomy  of  the  higher 
education  institutions.  Apart  from  the  reform  of  the  governance, 
upcoming reforms will include the continuous education of teachings staff, 
graduate  tracking  to  follow-up  on  the  graduates’  employability  and  the 
initial training of graduates for teaching in secondary education. 

The new Higher Education Act is also expected to cover technological 
education, which was practically abolished in 2018-19. Reinforcement 
of the technological sector of higher education institutions is important to 
improve links between higher education and the labour market and to create 
credible prospects for the professional integration of their graduates.  The 
new legislation will increase diversification within the university sector to 
ensure that the orientation of studies in applied sciences and technology is 
provided and strengthened.  

The authorities successfully completed the set-up of the single digital 
(gov.gr)  portal  backed  by  relevant  initiatives  to  ensure  system 
interoperability  and  robustness,  in  line  with  the  guidelines  and 
priorities set out in the National Digital Transformation Strategy and 
the urgent needs arising from the evolution of the pandemic. The portal, 
which brings to date more than 1 300 services, constitutes a key first step 
towards creating a digital public administration and improving the quality 
of services offered. At the same time, it paves the way for the creation of an 
extended innovation ecosystem with gov.gr acting as an open technology 
enabler  for  third  parties.  Recently  added  functionalities  and  applications 
include business intelligence to generate analysis on the use of services and 

30 

 
 
Complementary commitment 

State of play and next steps 

user  traffic  flows,  a  helpdesk  platform  for  services  hosted,  and  a  digital 
repository  for  all  Greek  legislation  since  the  establishment  of  the  Greek 
state. Moreover, the authorities continue to implement initiatives to ensure 
interoperability and secure data  exchange,  which enable the provision  of 
new  services  and  ease  the  administrative  for  businesses  and  citizens.  A 
recent initiative concerns the redesign and digitalisation of the procedure to 
enable the start-up of a private business without the need to visit any public 
service. Going forward, an ambitious set of interventions aimed at further 
enhancing the provision of customer-oriented digital services is envisaged 
under Greece’s recovery and resilience plan. 

31