COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, May 2022 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance update - Greece, May 2022
Date: 2022-05-23
Institutions: Directorate-General for Economic and Financial Affairs, European Commission
Subjects: Euro Group (euro area), Greece, economic recovery, gross domestic product, macroeconomics, multilateral surveillance, public debt, stability programme, structural adjustment, sustainable development

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 23.5.2022  SWD(2022) 700 final  COMMISSION STAFF WORKING DOCUMENT Enhanced Surveillance Report - Greece, May 2022 Accompanying the document COMMUNICATION FROM THE COMMISSION Enhanced Surveillance update - Greece, May 2022 {COM(2022) 629 final}  
 
 
STAFF WORKING DOCUMENT 

Progress  with  the  implementation  of  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.  

State of play and next steps 

The General Escape Clause remains active in 2022. Greece’s Stability 
Programme,  submitted  on  30 April  2022,  projects  the  primary  deficit  to 
reach 2.0% of GDP in 2022 (1) and a primary surplus of 1.1% of GDP in 
2023. The authorities’ projections are aligned with the Commission 2022 
spring  forecast.  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 
its 
not  endanger  fiscal  sustainability 
Communication of 3 March 2021 (2), the Commission set out its view that 
the  decision  on  the  deactivation  or  continued  application  of  the  general 
escape clause should be taken as an overall assessment of the state of the 
economy,  with  the  level  of  economic  activity  in  the  EU  or  euro  area 
compared  to  pre-crisis  levels  (end-2019)  as  a  key  quantitative  criterion. 
Heightened  uncertainty  and  strong  downside  risks  to  the  economic 
outlook in the context of war in Europe, unprecedented energy price hikes 
and  continued  supply  chain  disturbances  warrant  the  extension  of  the 
general  escape  clause  of  the  Stability  and  Growth  Pact  through  2023. 
Monitoring of fiscal developments will continue on a continuous basis. In 

the  medium 

term. 

In 

in 

(1)  The  primary  deficit  monitored  under  the  enhanced  surveillance  in  2022  is  projected  at  1.9%  of  GDP.  The  adjustments  agreed  under  the  enhanced  surveillance 

framework are applied only until 2022.  

(2) Communication  from the  Commission to the  Council on one  year since the  outbreak of COVID-19: fiscal policy  response, Brussels, 3.3.2021, COM(2021) 105 

final 

1 

 
                                                 
Commitment 

State of play and next steps 

October 2022, Greece – along with other Member States – is expected to 
present  its  2023  Draft  Budgetary  Plan,  which  will  be  assessed  for 
compliance with the Stability and Growth Pact. 

Public financial management.  

Completed. 

Complete  the  chart  of  accounts  for  the  central  administration  by 
implementing  the  fund  and  functional  classifications  in  the  2022 
State budget.  

Public financial management.  

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

The  mid-2022 specific commitment  to implement the second level  of 
functional  classification  has  been  completed.  The  authorities  have 
finalised  the  second  level  of  functional  classification  in  both  the 
investment  and  non-investment  budgets  for  all  general  government 
entities and will be presented in the annual update of the Medium Term 
Fiscal  Strategy  in  May  2022.  The  functional  classification  categorizes 
expenditure according to  the purposes and objectives for which they are 
intended. It was the last part of the chart of accounts reform. This reform 
introduces  a  common  economic,  administrative  and 
functional 
classification for budgetary  and accounting purposes.  The reform  allows 
for  a  deeper  analysis  of  public  expenditure  and  can  be  used  as  a 
performance  budgeting  tool  and  thus  improve  the  design  of  economic 
policy. 

Public financial management.  

Completed. 

Complete  the  cash  monitoring  and  forecasting  for  the  General 
Government Treasury account system. 

2 

 
 
Commitment 

(*) 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  target  to  materially  clear  the  non-pension  arrears  by  February 
2022 has not been met, largely on account of the continued pandemic 
and  the  hikes  in  energy  prices.  The  stock  of  non-pension  arrears  in 
March  2022  increased  to  €528 million  compared  to  €238 million  in 
December  2021  reported  in  the  13th  enhanced  surveillance  report, 
deviating  from  the  target  by  €225 million.  The  underperformance  is 
observed  mainly  in  hospitals  and  extra-budgetary  funds  where  the 
deviation from targets reaches €121 million and €60 million respectively. 
The  impact  of  the  pandemic,  reflected  in  the  high  number  of  cases  and 
hospitalizations,  continues  to  put  pressure  on  hospitals  resulting  in 
increased  workload  and  expenses.  Despite  that  the  legal  amendment 
which  simplifies  and  accelerates  the  payment  of  grants  especially  at  the 
beginning  of  the  year  was  adopted  on  time,  the  first  instalment  of  the 
hospitals’  annual  grant  was  paid  in  March  instead  of  January,  affecting 
negatively hospitals’ liquidity during the first months of 2022. Regarding 
the  extra-budgetary  funds,  the  increase  in  their  arrears  is  mainly  due  to 
increased  energy  costs,  both  fuel  and  electricity.  On  the  other  hand,  the 
application of the mechanism for the prevention of arrears accumulation 
in  local  governments  helped  the  stabilisation  of  their  arrears,  which  are 
now very close to the target. 

Supported by additional targeted actions, the remaining non-pension 
arrears should be materially cleared by August 2022. The authorities 
have  proposed,  and  already  partly  implemented,  additional  actions  to 
support  the  entities  which  continue  to  hold  a  high  stock  of  arrears.  As 
regards the hospitals, a legal provision, which solves the legality issues of 
hospitals’  expenses  and  permits  payments  of  supplies  obtained  through 
direct contract awards instead of an open regular process was adopted in 

3 

 
 
Commitment 

State of play and next steps 

end of March. This provision in combination with the grants received in 
March, should ensure sufficient liquidity to repay overdue obligations in 
the coming months. In response to the high energy costs, the authorities 
plan  to  adopt  a  legal  provision  in  May,  which  will  allow  the  state  to 
transfer an additional grant to public transport companies in order to pay 
their  overdue  obligations  to  electricity  companies.  In  addition,  the 
authorities  issued  in  April,  earlier  than  planned,  a  joint  ministerial 
decision on the conduct of public service obligation, which increases the 
amount  by  €41 million  in  order  to  improve  the  liquidity  of  these 
companies.  The  authorities  expect  that  the  aforementioned  initiatives 
along with the actions undertaken during the previous period will result in 
materially  clearing  the  non-pension  arrears  by  August,  and  possibly 
earlier. 

The clearance of pension arrears has slowed down since December on 
account of delays in implementing the planned IT improvements and 
lower than expected yields of previous measures. The stock of pension 
arrears in March 2022 reached €200 million compared to €267 million in 
December 2021, €105 million above the target set in October 2021. The 
observed deceleration in the clearance pace is mainly a result of delays in 
the delivery of software updates as well as difficulties encountered in the 
implementation of some of measures.  

The authorities  have put forward  additional actions to optimise and 
simplify  the  existing  pension  award  IT  and  procedures,  which  will 
allow  for  a  full  clearance  of  pension  arrears  by  August  2022,  two 
months later than initially envisaged. A law amendment was adopted in 
April,  which  aims  at  significantly  speeding  up  the  process  of  awarding 
pensions  through  improved  verification  of  the  data  available  in  the 

4 

 
 
Commitment 

State of play and next steps 

electronic  system  of  Single  Pension  Fund.  According  to  the  new 
provision,  three  months  after  the  application,  the  pension  award  will  be 
issued  automatically  by  using  not  only  the  data  of  the  insurance  history 
that  are  already  registered  in  the  information  system  but  also  the 
declarations and data submitted by the  applicant for additional insurance 
periods.  The  data  that  have  not  been  verified  before  the  pension  award 
will  be  checked  afterwards  within  three  years  from  the  issuance  of  the 
award. In addition, the authorities designed a number of additional actions 
due in May, which include: (a) changes in the pension application process 
that would allow checking eligibility before finalising the application, (b) 
the introduction of important IT modifications and updates to process the 
old  stock  of  pension  claims  faster,  and  (c)  the  creation  of  an  electronic 
portal  to  facilitate  the  data  exchange  between  Single  Pension  Fund  and 
applicants. These are significant enhancements that should lead to faster 
processing  of  pension  claims  and  full  clearance  of  pension  arrears  by 
August 2022.  

The  commitment  to  implement  reforms  identified  by  the  Hellenic 
Court  of  Auditors  to  prevent  the  accumulation  of  arrears  has  been 
effectively completed. The vast majority of recommendations has either 
been  completed  or  will  be  fulfilled  and  further  broadened  through 
ongoing  wider  structural  reforms  included  in  Greece’s  recovery  and 
resilience  plan.  Since  the  last  report,  the  authorities  completed  some 
important  actions  including  the  improvement  of  statistical  recording  of 
pension claims, the digitalization of the insurance history of private sector 
employees, corrections in  the registration of pension  claims with  part of 
the  insurance  periods  gained  abroad  and  the  introduction  of  controls  in 
the process of generating fiscal reports by the Ministry of Development. 
This effectively finalises the work on the commitment. A small number of 

5 

 
 
Commitment 

State of play and next steps 

(12 out of the 251) recommendations will be completed for the most part 
still  in  2022,  according  to  the  timeline  shared  by  the  authorities.  The 
remaining recommendations, which mostly relate to IT improvements, are 
expected to be completed by the end of 2023. 

The  authorities  have  also  completed  a  broader  reform  to  simplify 
fiscal  procedures  and  accelerate  the  payment  chain.  The  authorities 
have adopted all the law amendments identified by the working group for 
the  simplification  of  the  legislative  framework  governing  the  fiscal 
management of the central administration and public legal entities. These 
include:  (a)  a  simplification  of  the  payment  of  first  instalment  of  the 
annual  regular  grants  to  legal  entities  ensuring  sufficient  liquidity 
especially  at  the  beginning  of  the  year,  (b)  changes  in  the  regulatory 
framework  for  preventing  conflict  of  interest  of  accounting  officers,  (c) 
payment  of  certain  types  of  costs  through  simplified  procedures,  (d) 
amendments  of  the  legal  framework  regarding  multi-annual  obligations. 
These  initiatives  will  eventually  help  streamlining  budget  execution  as 
well as payment processes and are expected to further help the prevention 
of new arrears. 

Tax administration. 

Completed. 

Reach  the  agreed  permanent  staffing  positions  at  the  Independent 
Authority of Public Revenue. 

Tax administration. 

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

The  new  IT  collection  system  for  the  Independent  Authority  for 
Public  Revenue  has  partially  been  put  in  place  with  the  full 
operationalisation of the complete IT system expected to be rolled out 
by  September  2022,  in  line  with  the  agreed  timeline.  The  new  IT 
system  (‘EISPRAKSIS’)  will  contain  seven  sub-systems,  out  of  which 

6 

 
 
Commitment 

State of play and next steps 

four  are  now  in  place,  namely:  (i)  debtor  and  debt  management 
monitoring, including the debtor’s profile, enforcement measures etc.; (ii) 
submission and management of electronic notifications; (iii) risk analysis; 
and (iv) insolvency procedures. These four sub-systems have been rolled 
out to the central tax administration service of the Independent Authority, 
including the directorate for tax collection and tax refunds, the collection 
operations  unit  and  Attica’s  debt  collection  centre.  The  remaining  three 
sub-systems, including automatic offsets of tax obligations, are expected 
to be in place by September 2022. By that time, the complete IT system 
will  be  fully  operational  across  all  parts  of  the  Independent  Authority, 
including all local tax branches with a collection mandate.  

The  foreseen  selection  process  to  appoint  new  members  at  the 
Independent Authority’s management board was launched in March 2022 
and  is  expected  to  be  completed  by  end-May  2022,  whereas  the 
performance  targets  for  2022  set  for  the  Governor  of  the  Independent 
Authority are expected to be adopted in June 2022.  

The authorities have completed a reform of the ENFIA property tax. 
The  reform  applies  new  market-related  property  tax  values,  widens  the 
tax  base  and  improves  the  fairness  and  economic  efficiency  of  the 
property tax. The authorities have issued the  post-reform tax assessment 
bills for 2022 and the payment of the first instalment of the tax is due by 
end-May 2022. 

The  collection  of  the  clawbacks  continues  at  a  regular  pace. 
Clawbacks refer to the spending over and above the legislated ceiling for 
public spending on pharmaceuticals  and other healthcare services that is 
due  to  be  collected  back  from  pharmaceutical  suppliers  and  healthcare 

Tax policy.  

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

(*) Health care.  

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

7 

 
 
Commitment 

State of play and next steps 

providers. The authorities successfully met the target of collecting 45% of 
the pharmaceuticals clawbacks and rebates for 2021 and 60% of the 2021 
clawback  for  healthcare  providers.  The  latter  was  made  possible  by  the 
recently introduced methodology to collect the clawback for providers on 
a  rolling  basis  during  the  year  for  a  70%  of  the  total  (70%  of  clawback 
accrued  in  a  given  year  can  be  collected  during  the  same  year).  The 
authorities have outlined a credible timeline for further progress with the 
collection  of  clawbacks  for  the  second  half  of  2022  (see  Annex)  and 
regular monitoring is expected to continue thereafter. 

The size of the clawback remains large. The pharmaceuticals clawback 
for  2021  is  currently  estimated  at  approximately  €830 million  for 
outpatients  (the  first  semester  of  2021  has  been  quantified  at 
€430 million);  or  some  €1 400 million  when  adding  the  clawback  and 
rebates generated by the closed budget on hospital drugs (i.e. this refers to 
the  amount  above  the  legislated  ceiling  for  hospital  pharmaceuticals 
accounting for both  discounts and the amount that  the industry needs to 
pay  back  net  of  discounts).  Notably,  the  legislated  ceilings  stand  at 
€2 billion 
for  hospital 
pharmaceuticals,  so  actual  spending  currently  exceeds  the  legislated 
ceilings  by  approximately  50%.  The  Recovery  and  Resilience  Plan 
includes relevant measures to address the issue. 

for  outpatients 

€590 million 

and 

at 

Health care.  

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

The  authorities  adopted  the  revised  primary  legislation  for  the 
primary health care reform in early May. Due to ongoing negotiations 
to revise contractual arrangements for general practitioners, the adoption 
of  the  secondary  legislation  has  been  postponed,  but  the  authorities 
committed to adoption by early June ahead of the June 2022 Eurogroup. 
The  implementing  secondary  legislation  will  define  key  elements  of  the 

8 

 
 
Commitment 

State of play and next steps 

functioning  of  the  system  such  as  the  incentives  for  both  patients  and 
providers to join as well as accessibility. 

The  authorities  committed  to  a  revised  timeline  for  the  full 
implementation of the primary health care system. In particular: 

 

the  authorities  envisage 

Implementation  will  start  with  the  enrolment  of  doctors  into  the 
system.  Specifically, 
the 
enrolment of family doctors with the new contract with the Single 
Healthcare  Fund  (EOPYY)  and  to  automatically  enrol  general 
practitioners and internists who work in public primary health care 
by end-May 2022.  

to  start 

IT 

the 

infrastructure 

  Shortly  thereafter,  by  the  end  of  June,  the  authorities  intend  to 
complete 
to  book 
appointments,  and  start  with  the  registration  of  citizens  with  a 
family  doctor.  The  registration  of  self-employed  family  doctors 
into the system will proceed in parallel and will reach a level that 
allows to cover at least 85% of the population by July 2022.  

register  and 

to 

  By  October,  the  authorities  have  also  committed  to  activate  the 
incentive  scheme  for  registration  and  gatekeeping  and  to  have  at 
least 25% of the population registered by the same time, with 50% 
of the population registered by the end of 2022. 

All remaining primary healthcare units will be open by June 2023. 

Health care – PHC.  

Completed. 

Ensure the rollout of the primary health care system, in particular by 
opening at least 120 primary health care centres. 

9 

 
 
Commitment 

State of play and next steps 

Health care – centralised procurement.  

Completed. 

The main body responsible for central procurement (EKAPY) will be 
set up, with a view to achieving a share of centralised procurement in 
total hospital expenditure of 30%. 

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. 

10 

Centralised procurement activity is broadly on track to meet the 40% 
target  of  centralised  procurement  in  total  hospital  expenditure.  The 
40%  of  total  hospital  spending  that  can  be  subject  to  centralised 
procurement corresponds to a target of €320 million. Progress is ongoing 
although  with  minor  delays  accumulated  in  the  phase  of  technical 
specification  of  the  tenders.  Tenders  worth  more  than  €45 million  have 
already  been  completed  and  are  ready  to  be  contracted.  Almost  thirty 
tenders  are  currently  ongoing,  although  at  different  stages  in  the 
procurement  process:  tenders  for  an  approximate  value  of  €200 million 
are  close  to  issuance,  which  is  currently  planned  by  May;  additional 
tenders worth more than €90 million are planned for issuance by June, but 
these  require  further  work  to  finalise  elements  such  as  technical 
specifications and pricing. The remaining tenders to reach the 40% target 
will  likely  be  launched  soon  thereafter.  The  authorities  committed  to 
providing regular updates on the progress with centralised procurement. 

Secondary  legislation  was  adopted  on  24 March  setting  out  a  new 
disability assessment approach based on both medical and functional 
criteria,  thus  completing  the  policy  commitment.  A  Joint  Ministerial 
Decision  by  the  Ministers  of  Labour  and  Social  Affairs  and  Finance  set 
out  the  new  approach,  which  will  be  applied  in  the  next  months  for 
granting personal assistance benefits to person with disabilities on a pilot 
basis.  Disability  assessment  will  be  based  on  both  medical  and 

 
 
Commitment 

State of play and next steps 

functionality-related  criteria  and  made  by  multidisciplinary  assessment 
committees.  Applications  for  potential  beneficiaries  started  on  14 April 
and were completed on 15 May 2022.  

Social welfare.  

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

Social safety nets.  

Complete  the  rollout  of  all  three  pillars  of  the  Social  Solidarity 
Income (SSI) scheme. 

Social safety nets.  

Review the system of subsidies for local public transport. 

Completed. 

Completed. 

Completed. 

(*) 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 

The  platforms  under  the  new  insolvency  framework  start  gradually 
bearing  results,  particularly  with  respect  to  out-of-court  settlements 
and  further  improvements  are  continuously  being  developed.  There 
has been a steady flow of fully submitted applications to the out-of-court 
settlement platform, reaching 3 074 as of 24 March 2022, while for 1 708 
of these, corresponding to a total debt of €373 million, there was already 
a proposed settlement by the platform’s algorithm (3). Quite importantly, 
in  468 cases the  creditors’ settlement  proposal  has been received by the 
debtors  and  in  205  cases  it  has  been  accepted,  with  an  average  debt 

(3)  Out of these 1 708 applications, 967 refer to multilateral restructuring and 666 only refer to bilateral settlements between the debtor and government entities, while 
75 were concluded without a restructuring agreement being reached. In 468 cases the creditors’ settlement proposal has been received by the debtors and in 205 
cases it has been accepted, with an average debt haircut of around 28%.  

11 

 
 
                                                 
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State of play and next steps 

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. 

haircut  of  around  28%.  To  further  facilitate 
the  submission  of 
applications,  the  authorities  have  set  up  since  24 February  2022  a 
helpdesk,  while  similar  initiatives  are  also  undertaken  by  the  systemic 
banks  to  support  their  clients.  The  authorities  are  in  the  process  of 
identifying  and  assessing  areas  of  potential  improvements,  either  of  a 
technical  or  a  legal  nature,  and  are  preparing  an  initial  report  in  May 
2022.  With  regards  to  the  second  chance  platform  (i.e.  the  insolvency 
proceedings platform), there has been a significant (60%) increase in the 
number  of  active  applications,  while  the  applications  validated  by  court 
have  almost  tripled.  Progress  has  been  more  modest  in  the  case  of  the 
rehabilitation and the early warning mechanism platforms. Effectiveness 
of the insolvency framework will be monitored on a continuous basis. 

The  concessionary  process  for  the  setup  of  the  sale-and-lease-back 
entity  is  expected  to be launched in May, after previous delays,  and 
an  interim  support  scheme  is  being  put  in  place  to  ensure  a  smooth 
transition  until  the  new  entity  commences  operations.  Following  the 
appointment  of  an  investment  advisor,  the  authorities  are  expected  to 
launch the call for the expression of interest  in May.  It will be followed 
by a competitive dialogue with pre-selected interested investors, which is 
expected to start by end-September 2022 and will result in the launch of a 
call for binding offers in February 2023 and the issuance of the requisite 
ministerial  decisions  linked  to  the  operation  of  the  sale-and-lease-back 
entity.  The  entire  process,  including  the  award  of  the  contract  and  its 
ratification in Parliament, is expected to be finalised by June 2023 at the 
earliest, which will pave the way for the new entity to be established and 
become  operational.  In  view  of  the  delays  with  the  establishment  of  the 
mechanism,  an  interim  scheme  was  adopted  on  28 March  2022  by  the 
Parliament  and  is  expected  to  be  operational  shortly.  The  scheme  will 

12 

 
 
Commitment 

State of play and next steps 

provide a subsidy on loans secured by collateral on the primary residence 
of  “certified”  vulnerable  debtors  (under  the  new  insolvency  code),  who 
have  been  declared  bankrupt  or  whose  primary  residence  is  about  to  be 
auctioned (4). The scheme is expected to run until the sale-and-leaseback 
entity  is  set  up,  but  no  longer  than  for  15  months.  At  the  end  of  the 
interim  scheme,  the  primary  residence  of  the  vulnerable  debtor  who 
joined the scheme will be obligatorily transferred to the new entity if it is 
set-up  by  that  time,  or  the  enforcement  proceedings  will  continue  from 
the point at which they were at the time of the suspension. 

The  upward  trend  in  the  assignment  of  new  hearing  dates  for 
pending  household  insolvency  cases  has  been  maintained  since  the 
last  report  but  the  number  of  final  court  decisions  is  limited.  The 
validation of household insolvency cases by  court secretariats is  nearing 
completion but  the  pace  of  assignment  of  hearing  dates  for  validated 
cases  has  not  improved,  while  the  number  of  final  court  decisions  is 
limited (5).  In  order  to  accelerate  clearance,  the  authorities  have  taken 
relevant  actions:  In  addition  to  the  secondment  of  14  judges  to  courts 
facing  difficulties  reported  in  the  13th  enhanced  surveillance  report,  the 
authorities have adopted a provision allowing for the hearing of cases also 
by  judges  serving  in  another  court  within  the  same  regional  judicial 

(4)  The subsidy will be equal to the existing housing benefit allowance, i.e. €70 – 210 per month, depending on the family size. The authorities project the cost of the 
subsidy to reach €6.3-10.5 million for the entire period, provided there is no further extension of the scheme. This estimate is based on a forecast of 3 000 to 5 000 
debtors participating in the scheme and assumes an average subsidy of €140 for a 15-month period, on the basis of the average size of Greek households. 

(5)  Ineligible applications are being filtered out in the process, albeit at a smaller volume than initially expected (as of 24 March 2022, 48 305 applications remained 
active, out of a total of 48 715 that had been filed by the mid-July 2021 deadline).  So far, in the limited number of court decisions issued, there is a significant 
percentage  of  rejection  of  petitioners’  applications  (1 127  out  of  2 519  decisions),  entailing  the  termination  of  protection  from  liquidation  and  the  refusal  of  a 
restructuring of the debt under the household insolvency framework.  

13 

 
 
                                                 
Commitment 

State of play and next steps 

division,  thus  overcoming  the  limitations  to  the  maximum  number  of 
cases that can be heard on the same day. Moreover, the provision foresees 
that the 85 successful candidates of the latest competition for the hiring of 
magistrate’s court judges, who will  be appointed in  2022, will serve the 
first two months in the Magistrate’s Court of Athens to support judges in 
the  trial  of  household  insolvency  cases.  These  measures  are  expected  to 
notably enhance the case processing capacity of the magistrate’s courts all 
over Greece and ensure that 95% of validated cases receive a hearing date 
by end-October 2022. Out of these, 70% of cases are expected to be heard 
by the end of 2022, with final court decisions issued for 25% of the cases 
that have been heard until end-October. In addition, the authorities stated 
their  intention  to  introduce  by  end-May  a  targeted  legal  amendment 
introducing a deadline for the mandatory upload, by court secretariats in 
the relevant IT platform, of all necessary details of the court decision for 
each  case  heard,  and,  in  the  case  of  interlocutory  decisions,  the  new 
hearing  date  once  set.  The  authorities  committed  to  progress  with  the 
clearance  according  to  the  timeline  agreed  in  the  action  plan,  which 
envisages  that  95%  of  all  cases  will  be  heard  by  April  2023,  with  final 
court decisions issued for 80% of them. The remaining 5% of cases will 
have a hearing date set  at  the latest  by end-2022 and are expected to  be 
heard by June 2023. The full clearance of the backlog, i.e. the issuance of 
final  court  decisions  for  all  currently  pending  cases,  is  expected  by 
December 2023.  

The  conduct  of  auctions  is  continuously  gaining  traction  since  their 
post-pandemic  resumption  in  September  2021.  The  number  of  e-
auctions scheduled and conducted in the first quarter of 2022 was higher 
than in  the first  quarters of the previous four  years, a clear sign that the 
debt enforcement process is gaining traction. In the period from 1 October 

14 

 
 
Commitment 

State of play and next steps 

2021 to 18 March 2022, more than 70% of the 13 695 scheduled auctions 
were  conducted,  20%  of  which  resulted  in  the  transfer  of  the  property. 
More  than  a  half  of  them  were  acquired  by  third  parties,  a  significant 
increase  in  comparison  to  the  past  when  the  majority  of  auctioned 
properties  ended  up  in  the  banks’  and  servicers’  real  estate  property 
portfolios.  Further  improvements  could  materialise  in  the  future,  given 
that the recently adopted legal enhancements (e.g. automatic reserve price 
adjustment) only entered into force on 1 January 2022. Effectiveness of e-
actions  and  unimpeded  conduct  of  enforcement  will  be  monitored  on  a 
continuous basis. 

The work regarding identification of potential enhancements to the e-
auctions  platform  has  been  completed,  with  one  specific  measure 
adopted  now  and  the  rest  to  be  implemented  in  the  context  of  the 
recovery  and  resilience  plan.  The  working  group  submitted  its 
conclusions to the Ministry of Justice in March 2022. The implementation 
of the majority of their recommendations will take place in parallel to the 
measures outlined in Greece’s recovery and resilience plan. The measure 
that  has  already  been  adopted  was  a  provision  expressly  allowing 
Athenian notaries to conduct auctions in Piraeus.  

Despite  some  improvements,  the  timeline  for  the  clearance  of  the 
backlog  of  called  state  guarantees  has  been  amended  to  reflect  the 
accumulated  shortfalls  and  unexpected  legal  challenges  preventing 
the  payment  of  certain  claims.  The  data  for  the  first  quarter  of  2022 
showed  some  improvement  in  the  clearance  of  natural  persons’  claims, 
while  the  clearance  of  corporate  claims  decelerated.  Moreover,  the 
payments  for  a  significant  number  of  processed  claims  could  not  be 
carried  out,  due  to  five  different  legal  impediments,  according  to  the 

15 

 
 
Commitment 

State of play and next steps 

the  previous  2022 

authorities.  One  of  them,  which  represents  27.4%  of  the  value  for  the 
called guarantees on corporate loans, is the lack of legal clarity regarding 
the treatment of guarantees on loans that were transferred to another legal 
entity  without  prior  approval  by  the  guarantor.  The  authorities  have 
committed  to  assess  potential  solutions  to  accelerate  clarifying  this 
target 
situation.  These  factors  have  rendered 
unattainable.  The  revised  action  plan  of  the  authorities  therefore 
postpones  the  full  examination  of  claims  by  a  quarter,  i.e.  by  the  fourth 
quarter of 2022 for corporate claims and by the third quarter of 2023 for 
natural persons’ claims, while keeping the deadline for the completion of 
all  payments  unchanged,  i.e.  by  the  second  quarter  of  2024.  The 
authorities committed to progress according to the timeline and targets of 
the  revised  clearance  plan  and  agreed  to  continue  providing  monthly 
updates  on  the  pace  of  clearance  and  assess  if  further  corrective  actions 
are  needed.  The  recruitment  of  additional  35  staff  is  expected  to  be 
completed  shortly,  which  strengthens  the  credibility  of  the  revised 
timeline. 

The  authorities  have  agreed  a  reform  of  the  Hellenic  Financial 
Stability Fund with the European institutions. The law is expected to 
be  adopted  shortly.  The  duration  of  the  Fund  will  be  extended  until  the 
end of 2025 to allow the Fund to fulfil its dual objective of contributing to 
the stability of the Greek banking system,  while effectively disposing of 
its  assets.  The  reform  streamlines  the  Fund’s  governance  by  creating  a 
board  of  Directors  as  its  sole  governing  body.  It  will  consist  of  three 
executive and six non-executive members. The managing director, will be 
responsible for preparing and implementing the decisions of the board of 
directors.  In  order  to  incentivise  divestment,  the  law  includes  a  set  of 
principles that will guide the Fund’s divestment strategy and requests the 

16 

 
 
Commitment 

State of play and next steps 

Fund  to  report  regularly  to  the  Ministry  of  Finance  on  the  state  of  its 
implementation. Finally, the Fund’s special rights have been streamlined. 
The  Fund  will  be  represented  by  a  member  in  the  banks’  boards  of 
directors  but  will  exert  a  veto  right  only  with  respect  to  certain  key 
decisions,  namely  the  distribution  of  dividends  and  bonuses  for  those 
banks  with  a  non-performing  loan  ratio  exceeding  10%  and  those 
corporate actions that may significantly affect the Fund’s shareholding. 

Financial stability.  

Completed. 

Related to the above, provide financial training to judges. 

Financial Stability - Hellenic Financial Stability Fund (HFSF).  

Completed. 

The  HFSF  will  develop  an  exit  strategy  for  the  sale  of  its  stakes  in 
the  systemic  banks  and  the  mandate  of  the  Selection  Panel  of  the 
HFSF shall be aligned with the mandate of the HFSF. 

Financial Stability - Hellenic Financial Stability Fund (HFSF).  

Completed. 

Greece will continue the relaxation of capital controls in line with the 
published roadmap. 

Justice. 

Completed. 

In  the  context  of  implementing  the  Three-Year  Action  Plan  on 
Justice, complete phase I of the establishment of the e-justice system 
will be completed. 

Justice 

In  the  context  of  implementing  the  Three-Year  Action  Plan  on 

While  the  implementation  of  e-filing  in  administrative  courts 
is  now 
last-minute  delays,  one  part  of  the  project 
incurred 

17 

 
 
Commitment 

State of play and next steps 

Justice, 
throughout the Courts, having completed the tendering procedure. 

the  electronic  filing  of 

implement 

legal  documents 

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). 

18 

operational  and  the  remaining  part  of  the  project  is  expected  to 
follow by end-June 2022. The operationalization of  the interconnection 
between  the  administrative  courts’  IT  system  and  the  IT  system  of  the 
Legal Council of State, originally due in March 2022, was postponed and 
eventually took  effect  in April 2022. The platform will enable the  filing 
of  initial  submissions,  memoranda  and  procedural  documents  in  the 
context  of  pending  procedures.  Regarding  the  extension  of  functionality 
of  the  e-filing  platform  in  administrative  courts,  the  completion  of  the 
contract  on  21 February  2022  was  expected  to  be  followed  by  a  two-
month  pilot  phase,  leading  to  the  full  operationalisation  by  end-April 
2022.  As  reported  by  the  authorities,  a  two-month  extension  was 
requested  by  the  contractor.  As  a  result,  the  extended  functionality  was 
made available for use by legal professionals, in a pilot environment, only 
in April 2022. Upon completion of the pilot phase and the addressing of 
potential  technical  problems,  the  system  is  expected  to  be  put  into  full 
operation in June 2022. 

The call for proposals for the projects constituting the second phase 
of  the  civil  and  penal  case  management  system  (OSDDY-PP)  was 
launched  on  15 March  2022.  The  tender  process  is  under  way,  the 
deadline  for  the  submission  of  offers  having  expired  on  29 April  2022. 
According to the authorities, the contract awarding and signature phase is 
expected to be completed by end-2022. The implementation of the project 
should  start  in  January  2023  and  will  benefit  from  funds  under  the 
Recovery and Resilience Facility. 

Regarding  the  extension  of  the  functionality  to  all  courts  across 
Greece of the e-docket platform, the project is advancing on schedule. 
The  relevant  contract  was  signed  on  21 March  2022,  with  completion 

 
 
Commitment 

Labour market.  

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

State of play and next steps 

stipulated within 22 months from signature. 

Following  the  2%  increase  in  the  level  of  the  gross  statutory 
minimum  wage  on  1 January  2022,  a  second  increase  of  7.5%  took 
place  on  1 May  2022  in  response  to  the  persistent  commodity  price 
hikes.  The  public  consultation  process  for  the  latter  increase  took  place 
between  January  and  April  2022  and  involved  research,  scientific  and 
social  partners,  and  independent  experts.  On  21 April,  the  Minister 
Labour  and  Social  Affairs  adopted  a  Decision  setting  out  the  new  gross 
statutory  minimum  wage  level  to  apply  on  1May,  in  line  with  amended 
Law  4172/2013.  The  new  level  of  the  gross  statutory  minimum  wage 
brings  the  minimum  wage  up  from  €663  on  1 January  2022  to  €713  on 
1 May  2022  (when  calculated  on  a  14-month  basis)  or  €831.8  (when 
calculated  on  a  12-month  basis).  Implementation  of  the  legislative 
framework will be monitored on a continuous basis. 

Labour market.  

Implement action plan on undeclared work. 

Investment licensing.  

Deploy the relevant ICT. 

Investment licensing.  

Adopt all enabling licensing legislation. 

Investment licensing.  

Revise the nuisance classification. 

Completed. 

Completed. 

Completed. 

Completed. 

19 

 
 
Commitment 

Investment licensing.  

Greece will finalise inspection legislation. 

State of play and next steps 

The  authorities  have  completed  the  commitment  to  finalise  the 
inspection legislation. Secondary legislation for the inspection reform in 
the  last  remaining  area  of  environmental  protection  was  adopted  on 
21 February  2022,  i.e.  shortly  after  the  closure  of  the  13th  enhanced 
surveillance  report  but  ahead  of  the  March  2022  Eurogroup.  The  issued 
legislation allowed the activation of the enforcement management model, 
marking the completion of the environmental inspections reform and the 
broader investment licencing commitment. 

Investment licensing.  

Completed. 

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. 

The  cadastral  mapping  and  the  full  establishment  of  the  Hellenic 
Cadastre continued to progress in the past three months. In April, the 
collection of property rights reached 85% of the total property rights. Out 
of  these,  35%  are  in  operation  and  22.3%  are  in  public  display,  which 
means that 57.3% of the country’s total property rights are at the stage of 
public consultation or at a later stage. Due to the legislative changes in the 
forest maps displayed here below, this figure is expected to reach 65% of 
total  property  rights  by  end-September  2022.  This  is  somewhat  below 
than the 71% under the previous plan. 

A  new  legislative  amendment  affecting  forest  maps  was  adopted  in 
March 2022. With this amendment, afforested fields that were previously 
cultivated and subsequently abandoned are no longer considered as forest 
land. Afforested fields cover 5.2% of the country’s area (6 900 km²) and 
are  usually  areas  between  forests  and  agricultural  land.  This  change 

20 

 
 
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State of play and next steps 

concerns  around  1.3 million  property  rights,  which  will  need  to  be 
updated  in  the  cadastre  after  this  law.  The  cadastral  mapping  contracts 
will  need  to  be  amended  accordingly.  All  this  could  result  in  a  delay  in 
the completion of the cadastre compared to the previous planning. While 
the amendment is solving a long-standing issue that was brought to light 
with the development of the forest maps, it will require a revision of the 
existing contracts for cadastral mapping and expose the cadastre reform to 
a risk of new legal challenges. 

The authorities have granted a further extension to the period where 
citizens  can  raise  objections  to  the  remaining  forest  maps  and  the 
ratification  of  the  50%  of  forest  maps  that  are  still  outstanding  is 
legislative 
to  September  2022.  The  above-mentioned 
delayed 
amendment made it necessary to grant an additional time for the citizens 
to  raise  objections  and  the  ratification  of  the  forest  maps  will  be 
completed with a two-month delay compared to what was reported in the 
13th enhanced surveillance report. About 50% of the country has ratified 
maps; another 45% of the maps were uploaded for public consultation in 
February  2021.  According  to  the  revised  plan,  it  is  expected  that  by 
September  2022,  95%  of  the  forest  maps  would  be  ratified.  The 
ratification  of  the  forest  maps  is  necessary  for  the  completion  of  the 
cadastral  mapping.  In order to  avoid  further delays to  the completion of 
the  ratification  of  forest  maps  and  the  completion  of  the  cadastral 
mapping, the authorities are planning to adopt a legal provision allowing 
for the withdrawal of public ownership in the above mentioned 5% Greek 
land area.  

Regarding the transition to the new entity, 10 cadastral offices (out of 
17) and 46 branches (out of 75) are now open and the corresponding 

21 

 
 
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State of play and next steps 

mortgage  offices  have  been  closed.  This  is  one  cadastral  office  and 
eight branches more compared to what was been reported in the previous 
report.  Opening  of  new  offices  has  now  slowed  down  due  to  lack  of 
managerial staff. Recruitment of 27 specialists for the positions of Heads 
of  Cadastral  offices  through  the  High  Council  for  Selection  of  Staff 
(ASEP)  is  underway,  but  the  time  of  their  recruitment  will  affect  the 
completion  of  the  transition.  The  offers  for  the  digitalization  of  the 
mortgage  offices  are  being  evaluated  and  the  first  lot  is  expected  to  be 
awarded by end-May 2022. 

The authorities are expected to keep the revised timeline with a view 
to  completing  this  reform  including  the  full  operationalisation  of 
property  rights  and  the  full  functioning  of  the  new  Hellenic  Cadastre 
Agency by December 2022. 

Energy.  

Completion of lignite divestiture. 

Energy.  

Launch the Target Model. 

Energy.  

Completed. 

Completed. 

Completed. 

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 

The  implementation  of  the  Strategic  Plan  by  the  Corporation  has 
started. Following the approval of the Strategic Plan of the Corporation 

22 

 
 
Commitment 

basis. 

State of play and next steps 

in January 2022, the projects included in it have begun to be implemented 
as  planned.  However,  uncertainty  as  to  the  Corporation’s  dividend 
revenue  path  has  led  to  an  adjustment  of  the  budget  of  the  Corporation 
and cost containment measures. The planned horizontal asset valuation, a 
key  part  of  the  Strategic  Plan,  which  aims  to  give  a  reliable  market 
valuation  of  the  whole  portfolio,  will  therefore  be  scaled  back.  Rather 
than  the  full  valuation  that  was  scheduled  for  launch  in  July,  the 
Corporation will instead undertake a pilot during the second half of 2022. 
While  the  Corporation  considers  that  this  exercise  will  still  provide 
information  that will assist  it in  establishing a baseline valuation  for the 
portfolio and in prioritising projects for management attention, a thorough 
valuation would be important for robust performance measurement.  

To  track  progress  on  implementation,  the  Plan  contains  three  high-
level  metrics  on  financial,  social  and  environmental  dimensions.  An 
update on financial performance will be available in September 2022. A 
baseline  for  a  “Social  Trust”  metric  is  currently  under  preparation.  An 
environmental metric will be developed under a project to be launched by 
end-May. 

As part of its core mandate, the Corporation continues its work on a 
new cycle of review (and replacement, if needed) of the boards of the 
state-owned enterprises in its portfolio, as their terms of office expire. 
The  Board of the Corporation has proceeded to  the appointment of new 
members  in  the  Board  of  the  Public  Real  Estate  Company  (ETAD)  in 
March 2022 and the appointment of a new chair of the Audit Committee 
in the Hellenic Republic Asset Development Fund (TAIPED) in  January 
2022.  

The  Corporation  and  the  authorities  continue  assessing  the  decision 

23 

 
 
Commitment 

State of play and next steps 

of  the  Council  of  State  decision  relating  to  the  Corporation’s 
ownership of the majority stakes in the water utilities of Athens and 
Thessaloniki  and  the  effect  on  the  Corporation,  with  a  view  to 
resolving the issues raised.  

The  Corporation  is  working  on  the  finalisation  of  the  Technical 
Supplement to its Investment Policy, which is expected to be finalised 
by  end-May.  The  completion  of  the  Technical  Supplement  will  enable 
the Corporation to  begin deploying its investable reserves in  accordance 
with  the  Investment  Policy,  which  is  an  important  complement  to  its 
primary  role  of  creating  value  from  its  portfolio  of  state-owned 
enterprises and real estate assets. 

Following  the  finalisation  and  signing  of  the  performance  contract 
for  the  Athens  Urban  Transport  Organisation  (OASA),  the  joint 
ministerial decision that allows the payment on the agreed public service 
obligation  on  a  monthly  basis  was  issued  on  30 April  2022  (FEK  B’ 
2135/30.04.2022).  The  performance  contract  is  intended  to  set  out  the 
financial  relationship  between  the  Athens  Urban  Transport  Organisation 
and the state in clear terms, and link financial transfers by the state to the 
performance of specific policy objectives. This project is a key element of 
the Corporation’s Coordination Mechanism.  

Also  in  relation  to  the  Coordination  Mechanism,  the  Statements  of 
Commitments  of  each  state-owned  enterprise  in  the  Corporation’s 
portfolio are in the process of being updated, following the approval 
of  the  strategic  plan.  The  Statements  of  Commitments  set  out  key 
financial, operational and other objectives for the state-owned enterprises 
and  reflect  the  strategic  priorities  set  out  in  the  strategic  plan.  They  are 
expected to be finalised by end-May 2022. 

24 

 
 
Commitment 

State of play and next steps 

The  authorities  prepared  the  draft  legislation  for  the  modernisation 
of  the  institutional  framework  for  state-owned  enterprises.  The 
authorities have engaged very  constructively with the institutions on the 
framework.  The  draft  legislation  is  an  ambitious  reform,  which  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  legislation  is  divided  in  two  sections:  (i)  a 
section on public limited companies in which the state holds 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  draft 
legislation aspires to significantly strengthen the corporate governance of 
state-owned enterprises. For instance, all state-owned enterprises covered 
by the draft legislation will be required to have an Audit Committee and 
an internal control unit. The responsibilities between the shareholder and 
the  regulatory  functions  will  also  be  clarified.  With  respect  to  the 
state-owned enterprises in the Corporation’s portfolio, the final legislation 
is  expected  to  incorporate  all  the  changes  identified  by  the  Corporation. 
The  draft  was  submitted  to  the  General  Secretariat  for  Legal  and 
Parliamentary Matters on 6 May 2022 and it is expected to be enacted by 
end-June 2022. 

Efforts  to  improve  the  performance  of  the  real  estate  portfolio 
continue to fall short in terms of achieving an ambitious yield across 
the  whole  portfolio  of  the  Public  Real  Estate  Company.  The  Public 
Real  Estate  Company  has  continued 
the 
performance  of  specific  assets  and  has  seen  some  success  on  those 
projects.  However, progress  in  delivering systemic improvements across 
the  portfolio  as  a  whole  is  not  apparent,  despite  various  attempts  and 
initiatives  over  multiple  years.  An  outline  of  a 
restructuring 

its  efforts 

improve 

to 

25 

 
 
Commitment 

State of play and next steps 

comprehensive  strategy  to  achieve  an  ambitious  yield  across  the 
Company’s total portfolio is expected by end-May 2022.  

With regard to the transfer of the eligible real estate assets included 
in  the  2018  package  to  the  Public  Real  Estate  Company,  there  has 
been  some  progress.  The  verification  process  of  the  real  estate  assets 
belonging to the Ministry of Finance was completed in early May and the 
subsequent  transfer  of  the  eligible  assets  is  expected  by  end-June  2022. 
As  regards  the  real  estate  assets  belonging  to  other  ministries,  the 
verification process was launched at the end of March and it is expected 
to  be  completed  by  end-June.  The  eventual  transfer  of  the  eligible  real 
estate assets under the latter cluster is expected by end-October 2022. 

Implementation  of  the  Strategic  Plan  of  HCAP  will  be  monitored  on  a 
continuous basis. 

The  authorities  have  advanced  with  preparatory  actions  for  the 
development of a detailed feasibility study (including a business plan) 
for the Olympic Athletic Centre, with a relevant tender scheduled to 
be  launched  in  June  2022.  The  feasibility  study  will  be  based  on  the 
guidelines  of  the  consultants’  strategic  action  plan,  which  was  finalised 
on 13 May 2022, and will assess issues such as market depth in order to 
evaluate the financial feasibility of the various uses under consideration. 
The  respective  tender  expected  to  be  launched  in  June  2022  and  the 
detailed feasibility study is expected to be completed in May 2023. A key 
objective of the overall approach for the Olympic Athletic Centre will be 
to  ensure  that  it  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. 

HCAP.  

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

26 

 
 
Commitment 

HCAP. 

State of play and next steps 

Completed. 

Completion of the restructuring of ETAD and review/ replacement of 
all SOE boards. 

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. 

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  5 May  2022.  Progress  with  specific 
transactions since the last report has been as follows: 

Egnatia: The construction works on four additional toll stations (3 lateral 
and  one  frontal)  have  continued  but  at  a  slow  pace.  In  line  with  the 
updated  timetable  submitted  in  the  context  of  the  14th  enhanced 
surveillance  report,  the  authorities  issued  the  required  Joint  Ministerial 
Decision on 13 May 2022, according to which these toll stations will start 
operating within July 2022. The launch of the construction in the last two 
lateral  toll  stations  and  the  finalisation  of  the  construction  works  in 
Chalastra is nevertheless still outstanding, but all of which will need to be 
completed by end-2022 in order to avoid financial sanctions for the state. 
In  total,  17  out  of  18  frontal  toll  stations  and  31  out  of  40  lateral  toll 
stations  are  currently  operational.  With  regard  to  the  licensing  of  the 
remaining  16  tunnels  under  category  E  (i.e.  excluding  the  transport  of 
dangerous cargo), individual studies for each tunnel will be required that 
will identify what is additionally needed to be done. The tender process to 
select  the  technical  advisor  for  those  studies  has  been  launched  by  the 
Fund in early May 2022, with a view to expediting the process and have 
the studies completed the soonest possible. The licensing of the tunnels is 

27 

 
 
Commitment 

State of play and next steps 

also  expected  to  be  completed  by  end-2022,  to  allow  for  the  already 
agreed concession agreement to enter into force. 

Regional port of Alexandroupolis:  The resolution of the pending issue 
on the expropriation process of the private properties in the land zone area 
of  the  port  of  Alexandroupolis  is  in  progress  and  a  “reasonable” 
compensation  for  the  expropriation  has  been  judicially  determined.  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 
June 2022. The selection of the preferred investor is expected by end-July 
and the financial closing by end-December 2022. 

Regional  port  of  Kavala:  One  binding  offer  was  submitted  on 
28 February,  and  the  selection  of  the  preferred  bidder  took  place  on 
6 May 2022. Financial closing is expected by end-December 2022. 

Regional  port  of  Igoumenitsa:  The  updated  documents  (Sale  and 
Purchase  Agreement,  Shareholders’  Agreement  and  Concession 
Agreement)  were  uploaded  on  the  virtual  data  room  on  18 April  2022. 
The pending issue on the determination of the land 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  and  the  selection  of  the  preferred  investor  is  expected  in 
the  third  quarter  of  2022.  Financial  closing  is  expected  by  the  end  of 
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  was  completed  on  7 April,  thus 
launching the binding offers phase for the transaction. The submission of 

28 

 
 
Commitment 

State of play and next steps 

binding offers is scheduled by end-October 2022. 

(DEPA)  Infrastructure:  Public  Gas 
Public  Gas  Corporation 
Corporation  (DEPA)  Infrastructure:  The  Hellenic  Competition 
Commission provided its approval for the preferred investor on 15 March. 
The certification of the preferred investor by the Regulatory Authority for 
Energy is expected by end-May. The financial closing of the transaction 
is  expected  by  mid-June  2022  for  a  financial  offer  of  €733 million  (this 
corresponds to €476 million for the 65% stake held by the Fund). 

Public  Gas  Corporation  (DEPA)  Commercial:  Pending  clarity  on  the 
outcome of a pending legal case, whereby the final decision is expected to 
be issued first in 2-3 years, the current tender cannot proceed. Hence, the 
Fund is considering other transaction structures. 

Underground  Natural  Gas  Storage  (UGS)  South  Kavala:  The  first 
draft  Concession  Agreement  is  expected  to  be  shared  with  Prequalified 
Investors by end-May 2022. The open issue on tariff setting framework is 
expected to be resolved via the issuance of the decision of the Regulatory 
Authority  for  Energy  by  end-May  2022.  The  decision  was  under  public 
consultation till 11 April. The submission of binding offers is expected by 
end-July and the selection of the preferred investor by end-October 2022, 
subject  to  the  timely  issuance  of  the  tariff  setting  framework  by  the 
Regulatory Authority for Energy.  

Gournes Heraklion: The development of Gournes is described by many 
as a smaller Hellinikon project. The transaction concerns the development 
of  part  of  the  former  U.S.  base  in  Gournes,  in  Heraklion  on  Crete, 
Following the nomination of the preferred investor, for a financial offer of 
€42.2 million,  the  file  of  the  tender  process  has  been  submitted  to  the 
Hellenic Court of Auditors on 2 March 2022 for pre-contractual review. 

29 

 
 
Commitment 

State of play and next steps 

The financial closing is expected in the fourth quarter of 2022. 

Attiki Odos: 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 
Fund  is  conducting  an  international  public  tender  for  the  award  of  a 
concession  agreement  for  the  operation  and  maintenance  of  the  Attiki 
Odos  for  a  period  of  25  years.  Eight  interested  parties  submitted  their 
expression of interest on 5 May 2022. 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  allowing  the  launch  of  the  binding 
offers phase for the transaction in July. 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. 

Implementation  of  the  Asset  Development  Plan  will  be  monitored  on  a 
continuous basis (see Annex). 

Privatisation.  

Completed. 

With  a  view  to  swiftly  attracting  investment  to  support  a  sustained 
economic 
the  AIA 
concession, Hellinikon, DESFA, Marina of Alimos. 

recovery,  complete 

transactions  on 

the 

30 

 
 
 
Commitment 

Public administration.  

State of play and next steps 

Completed. 

the 

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

integrated  HR  Management  System 

Public Administration.  

Completed. 

Complete reforms to modernise human resource management in the 
public  sector,  and  in  particular  the  appointment  of  Administrative 
Secretaries and all Directors General according to law 4369/2016.  

Public administration.  

Completed. 

Independent  assessment  of  the  appointment  process  for  senior 
management, including follow up measures 

Public  administration.  Complete  the  3rd  cycle  of  mobility  and 
performance assessments. 

Completed. 

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. 

While  the  codification  process  has  started,  the  adoption  of  the 
consolidated  Labour  Law  Code  and  Code  of  Labour  Regulatory 
Provisions  has  been  postponed  to  October  2022  due  to  a  recent 
significant reform of the Public Employment Service, which will need 
to  be  included  in  the  codification  process.  Work  by  the  Ministry  of 
Labour  and  Social  Affairs  on  the  codification  of  labour  legislation 
continues in close collaboration with the Central Codification Committee. 
However, due to a recently adopted law improving the functioning of the 
labour market  (law 4921/2022 on the public employment service reform 
and on active and passive labour market policies), the previous timetable 

31 

 
 
Commitment 

State of play and next steps 

for  the  completion  of  the  codification  process  has  been  adjusted 
accordingly. The Ministry of Labour and Social Affairs delivered the first 
draft  to  the  Secretariat  General  for  Legal  and  Parliamentary  Affairs  for 
review on 3 May. The draft codified legislation will be presented by June. 
The Central Codification Committee will proceed with the review of the 
codified  legislation  as  a  priority.  The  adoption  of  the  codified  texts  will 
follow by October 2022. 

Legal codification.  

Completed. 

Complete  the  National  Gateway  for  Codification  and  Reform  of 
Greek Legislation. 

Fight against corruption.  

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

The authorities have put in place significant measures to implement 
the remaining recommendations from the fourth evaluation round of 
the  Group  of  States  against  Corruption  (GRECO),  and  the 
commitment can be considered as satisfactorily completed. 

1.  Recommendation  to  enhance  the  selection  of  senior  judges  and 
prosecutors,  and  disciplinary  proceedings:  The  new  Code  on  the 
Organisation  of  Justice  and  the  Status  of  Judges  of  the  courts  that  was 
submitted to the General Secretariat for Legal and Parliamentary Affairs 
on  13 May  2022  and  is  to  be  tabled  to  Parliament  shortly  thereafter, 
tightens  the  rules,  within  the  current  constitutional  framework,  for 
promotion of judges and prosecutors to senior positions. Particularly, the 
new  code  provides  that  certain  senior  positions  of  the  three  supreme 
courts  will  be  fulfilled  from  a  list  including  the  most  senior  judicial 
officers who have the formal qualifications for these positions. 

2.  Recommendation  on  providing  guarantees  against  delays  and 

32 

 
 
Commitment 

State of play and next steps 

improving  caseload  management:  Specific  measures  to  address  this 
recommendation  have  been  implemented  including:  (i)  The  above-
mentioned Code on the Organisation of Justice and the Status of Judges 
contains  provisions  that  aim  at  strengthening  procedural  guarantees 
against delays, and the role of judges and prosecutors as regards caseload 
management.  In  this  respect,  the  code  introduces  provisions  on  the 
evaluation and disciplinary actions against judges, as well as on channels 
for  complaints.  (ii)  The  Mediation  Law  that  entered  into  force  in 
November  2019,  which  facilitated  mandatory  mediation  under  certain 
conditions  in  civil,  commercial  and  family  cases,  before  such  cases  are 
processed  in  court.  A  similar  procedure  is  followed  in  criminal  cases 
according to the Criminal Procedure Code that was adopted in November 
2019,  which  introduces  the  option  for  an  agreement  between  the 
prosecution  and  the  defendant,  to  minimise  the  number  of  cases  that 
require court hearing. (iii) Improvements to the Code of Civil Procedure 
effected  in  January  2022  to  simplify,  digitalise  and  accelerate  trial 
proceedings and to enhance legal certainty. (iv) The implementation of IT 
case  management  systems  and  the  establishment  of  JustStat  unit  for 
judicial  data  collection.  Further,  additional  upcoming  initiatives  are 
expected to assist in accelerating justice, such as the provision of training 
to judges and judicial clerks, the establishment of judicial police, and the 
review of the judicial map. 

3.  Recommendation  on  setting  clear  standards  of  professional  conduct 
and  integrity:  The  Council  of  State  published  in  March  2022  an  ethics 
charter for administrative judges, while an ethics charter for the Court of 
Audit judges has already been adopted since November 2020. In addition, 
a  working  group  will  be  drafting  a  code  of  conduct  for  judges  and 

33 

 
 
Commitment 

State of play and next steps 

prosecutors of the civil and criminal courts. 

remaining  parts  of  certain 
GRECO  will  continue  monitoring 
recommendations,  and  has  asked  the  authorities  to  submit  additional 
relevant information in the course of 2023. 

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. 

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. 

34 

The new Code on the Organization of Justice and the Status of Judges 
is  expected  to  be  tabled  to  Parliament  by  end-May  2022.  The 
authorities have started the adoption process for the code on 13 May 2022 
by  submitting  the  draft  code  to  the  General  Secretariat  for  Legal  and 
Parliamentary  Affairs.  The  adoption  of  the  code  by  the  Parliament  will 
follow shortly, completing the reform. The code is expected to enter into 
force upon publication in the Official Journal, with the notable exception 
of the section on evaluation matters, which is set to enter into force at the 
beginning  of  the  new  judicial  year  in  mid-September  2022  so  as  not  to 
disrupt pending proceedings.  

The  presidential  decree  on  the  establishment,  organization  and 
operation  of  the  Office  for  the  Collection  and  Processing  of  Judicial 
Statistics  (JustStat)  will  be  adopted  with  an  eleven-month  delay  by 
end-May  2022,  which  will  complete  the  reform.  The  authorities  are  in 
the  process  of  appointing  the  members  of  the  supervisory  committee, 
which  is  expected  to  come  to  order  by  end-June  2022.  The  JustStat 
department will operate at the central level as a department of the Ministry 

 
 
 
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. 

35 

of  Justice  and  will  systematically  collect,  aggregate,  process  and  publish 
judicial  data  from  the  courts  and  prosecutor’s  offices  of  Greece;  it  will 
also  safeguard  and  improve  on  a  permanent  basis  the  quality  of  judicial 
statistics. 

A  needs  assessment  of  permanent  and  temporary  teachers  has  been 
prepared by the Ministry of Interior  and is expected to feed into the 
hiring plan for 2022 and beyond. The needs assessment was carried out 
by the Ministry of Interior and is currently under review by the Ministry 
of  Education  and  Religious  Affairs  and  is  expected  to  be  finalised  by 
end-May  2022.  The  needs  assessment  is  expected  to  improve  the 
predictability  of  the  needs  for  permanent  and  temporary  teachers, 
including  special  needs  teachers,  in  the  short  and  medium-term.  The 
findings of this needs assessment is expected to be reflected in the annual 
hiring  plans  for  permanent  staff  going  forward.  Further,  all  temporary 
teachers  will  fall  under  the  overall  ceiling  for  temporary  staff,  which  is 
being  applied  as  of  2022  and  will  see  an  overall  reduction  by,  at  least, 
10% compared to 2021. 

Legal  provisions  to  address  a  number  of  identified  deviations  from 
the unified wage grid have been prepared and a new methodology for 
granting allowances for hazardous and arduous jobs is planned to be 
in  place  by  August  2022.  First,  following  the  preparation  of  a 
comprehensive list of deviations from the unified wage grid, which listed 
160  legal  amendments  adopted  since  2015,  draft  legal  provisions  are 
expected to be adopted by end-May 2022. These draft provisions address 
some  of  the  identified  deviations,  such  as  remuneration  for  management 
posts and travel expenses, and aim to ensure consistent application of the 
unified wage grid across the public administration. Second, following the 

 
 
Complementary commitment 

State of play and next steps 

public  consultation  where  social  partners  provided  comments,  the  new 
methodology  for  hazardous  and  arduous  work  allowance  was  updated. 
Secondary legislation is planned to be in place by June 2022 with the new 
methodology  being  implemented  as  of  August  2022.  The  completion  of 
these  two  work  streams  would  mark  concrete  progress  in  relation  to  the 
authorities’ commitment to strengthen central control of hiring and salary 
provisions. 

A  law  adopted  in  March  2022  on  the  management  for  the  National 
Strategic  Reference  Framework  (2021-2027)  included  temporary 
provisions  on  the  appointment  of  managers,  which  are  not  fully 
consistent  with  the  procedure  that  is  currently  applied  in  the  public 
administration.  The  authorities  clarified  that  any  appointment  made 
using these temporary provisions will only be valid until the completion of 
the regular appointment process, which is expected to be launched in June 
2022 and completed by mid-2023. A Ministerial Decision that will specify 
the temporary provisions has been prepared and is expected to be adopted 
shortly;  it  includes  the  establishment  of  a  selection  committee,  which  is 
chaired  by  a  member  of  the  Supreme  Council  for  Civil  Personnel 
Selection. 

The  appointment  process  to  select  a  Permanent  Secretary  at  the 
Ministry of Education and Religious Affairs has been launched and is 
expected to be completed by July 2022. Following extended discussions, 
a legal amendment was adopted, which was aligned with the principles of 
the  Executive  State  Law  that  established  the  Permanent  Secretary  post. 
This  allowed  the  appointment  process  for  a  Permanent  Secretary  at  the 
Ministry  of  Education  and  Religious  Affairs  to  be  launched  by  the 
Supreme  Council  for  Civil  Personnel  Selection  (ASEP),  which  oversees 

36 

 
 
Complementary commitment 

State of play and next steps 

this appointment process. 

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. 

The  Hellenic  Corporation  of  Assets  and  Participations  proceeded  on 
15 April to selecting the consultant that will work on the study for the 
elaboration  of  a  holistic  and  coherent  real  estate  strategy.  The  work 
started thereafter, with  the draft strategy  expected by  end-June 2022  and 
the final strategy by mid-August 2022. 

Public procurement.  

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

Education.  

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

framework  and 

transparency 

through 

The authorities adopted the final piece of secondary legislation critical 
for  the  implementation  of  the  public  procurement  law,  therefore 
successfully  completing  this  commitment.  The  legislation  concerns  the 
set-up  of  a  new  legal  entity,  the  “Pricing  and  Specifications  of 
Construction  Works  and  Design  Services  Company  (PRI.SPE.CO.)”, 
which  will  develop  and  maintain  a  new  integrated  system  for  technical 
specifications and costing of technical works. The legislation specifies the 
objectives  and  operational  aspects  of  the  new  system,  notably  the  price 
observatory  and  the  common  technical  specifications  system,  as  well  as 
the  organisational  and  managerial  arrangements  for  the  new  entity, 
including its responsibilities, funding, and management bodies. 

The  authorities  have  prepared  and  submitted  to  the  Council  of 
Ministers  a  bill  on  higher  education,  which  enhances 
the 
organizational and educational autonomy, flexibility and efficiency of 
institutions,  delegates  some  decision-making 
higher  education 
authority from  the Ministry to the universities  and  streamlines their 
governance.  The  governance  of  higher  education  institutions  will  be 
overhauled  with  the  introduction  of  university  councils  to  supervise  the 
universities.  This  is  coupled  with  new  instruments  such  as  multi-annual 

37 

 
 
Complementary commitment 

State of play and next steps 

strategic  planning,  programmatic  agreements  with  the  Ministry  of 
Education,  digital  transformation  and  the  link  of  the  operation  of 
universities with the sustainable development goals. The universities will 
be  able  to  found  degrees  without  the  involvement  of  the  Ministry  of 
Education, after certification by the independent certification agency. The 
bill allows universities to grant joint-degrees in cooperation with faculties 
from other local and foreign institutions with the objective to better align 
the  offered  degrees  to  the  needs  of  the  labour  market.  The  creation  of 
master  degrees  is  facilitated  and  executive  master  degrees  conducted  in 
cooperation  with  the  industry  are  introduced.  The  bill  is  expected  to  be 
tabled into Parliament in June 2022. 

38