COMMISSION STAFF WORKING DOCUMENT 2023 Rule of Law Report Country Chapter on the rule of law situation in Greece Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2023 Rule of Law Report The rule of law situation in the European Union
Date: 2023-07-05
Institutions: European Commission, Secretariat-General
Subjects: Greece, administrative transparency, corruption, democracy, independence of the judiciary, infringement of EU law, pluralism in the media, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 5.7.2023  SWD(2023) 808 final  COMMISSION STAFF WORKING DOCUMENT 2023 Rule of Law Report           Country Chapter on the rule of law situation in Greece Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2023 Rule of Law Report                                    The rule of law situation in the European Union {COM(2023) 800 final} - {SWD(2023) 801 final} - {SWD(2023) 802 final} - {SWD(2023) 803 final} - {SWD(2023) 804 final} - {SWD(2023) 805 final} - {SWD(2023) 806 final} - {SWD(2023) 807 final} - {SWD(2023) 809 final} - {SWD(2023) 810 final} - {SWD(2023) 811 final} - {SWD(2023) 812 final} - {SWD(2023) 813 final} - {SWD(2023) 814 final} - {SWD(2023) 815 final} - {SWD(2023) 816 final} - {SWD(2023) 817 final} - {SWD(2023) 818 final} - {SWD(2023) 819 final} - {SWD(2023) 820 final} - {SWD(2023) 821 final} - {SWD(2023) 822 final} - {SWD(2023) 823 final} - {SWD(2023) 824 final} - {SWD(2023) 825 final} - {SWD(2023) 826 final} - {SWD(2023) 827 final}  
 
 
ABSTRACT 

Clear standards of professional conduct and integrity in the judiciary were set with the adoption 
of Codes of Conduct for all jurisdictions. There have been no steps taken with regard to the 
involvement of the judiciary in the appointments of the highest positions of the Greek judiciary, 
in  line  with  European  standards.  Efforts  to  improve  the  quality  of  the  justice  system,  in 
particular as regards digitalisation, continue. The revision of the judicial map for administrative 
justice  aims  at  balancing  the  uneven  distribution  of  cases  and  reducing  delays.  The 
establishment  of  the  Judicial  Police  and  the  recruitment  of  judicial  clerks  is  expected  to 
improve the administration of justice. The system  of legal  aid  is  comprehensive, though its 
effectiveness  could  be  jeopardised  by  delays  in  settling  overdue  lawyer’s  fees.  Serious 
challenges remain regarding the efficiency of justice, in particular the length of proceedings, 
which have further increased. Efforts to address the backlog before the highest administrative 
courts are made, including by adopting an accelerated procedure to deal with specific types of 
cases before the Court of Audit, which is already applied in practice.  

The implementation of the National Anti-Corruption Action Plan for 2022-2025 is under way. 
The activities of the National Transparency Authority are progressing well and its cooperation 
with private and public entities continues. A new law aiming at increasing the verifications of 
asset  declarations  entered  into  force.  Progress  towards  achieving  a  robust  track  record  of 
prosecutions and final judgments in corruption cases has been relatively limited. Measures on 
the integrity of civil servants continue to be taken forward and efforts to improve integrity and 
conflicts of interest within the police force are ongoing. Rules to regulate lobbying are in force, 
while progress  to  implement  an effective transparency  register has  been slow. The rules on 
political party financing were codified and subsequently amended with a reduction of political 
fines.  A  new  law  on  the  protection  of  whistleblowers  who  report  breaches  of  EU  law  was 
adopted. Guidance was issued to ensure that direct awards of public contracts are only used in 
exceptional cases. 

The Government has taken further steps to enhance transparency of media ownership through 
new legislation. Safeguards are in place to ensure the independence of public service media, 
but the fact that board members of the Radio and Television Corporation are appointed by the 
Minister  responsible  for  media  continues  to  raise  concerns  with  regard  to  their  effective 
independence and potential political influence. A new procedure to hire new staff members of 
the audiovisual media regulator has been launched, but challenges persist with regard to the 
adequacy  of  the  regulator’s  resources.  The  creation  of  a  Task  Force  for  the  protection  and 
empowerment  of  journalists  is  an  important  step.  Nevertheless,  concerns  persist  and  more 
concrete  steps  are  needed  to  improve  the  working  environment  of  journalists,  including  as 
regards abusive lawsuits against journalists and their safety.  

Despite efforts improving the quality of the legislative process in practice, challenges remain. 
While draft bills are consistently subject to public consultation and follow-up reports address 
the comments submitted, concerns regarding the lack of effective and timely consultation of 
stakeholders  persists.  Civil  society  organisations  (CSOs)  have  criticised  the  practice  of 
adopting omnibus legislation and last-minute amendments. Independent authorities are playing 
an active role in  the system  of checks  and balances.  An initial  step has been taken towards 
amending the regulatory framework governing the registration requirements for civil society 
organisations.  The  situation  of  civil  society  raises  concerns,  in  particular  in  relation  CSOs 
working in specific areas. 

1 

 
 
RECOMMENDATIONS 

Overall, concerning the recommendations in the 2022 Rule of Law Report, Greece has made: 

  No progress on addressing the need for involvement of the judiciary in the appointment of 
President and Vice-President of the Council of State, the Supreme Court and the Court of 
Audit taking into account European standards on judicial appointments. 

  Significant progress on ensuring the effective and systematic verification of the accuracy 

of asset disclosures filed by all types of public officials. 

  Some progress on increasing efforts to establish a robust track record of prosecutions and 

final judgments in corruption cases. 

  Some progress in establishing safeguards to improve the working conditions and physical 
safety  of  journalists  in  line  with  the  Memorandum  of  Understanding,  but  legislative 
safeguards  are  still  to  be  established,  taking  into  account  European  standards  on  the 
protection of journalists. 

  Some progress on ensuring that registration requirements for civil society organisations are 

proportionate in view of maintaining an open framework for them to operate. 

On this basis, and considering other developments that took place in the period of reference, 
and in addition to recalling the commitments made under the national Recovery and Resilience 
Plan relating to certain aspects of the justice system and the anti-corruption framework, it is 
recommended to Greece to: 

  Take  steps  to  address  the  need  for  involvement  of  the  judiciary  in  the  appointment  of 
President and Vice-President of the Council of State, the Supreme Court and the Court of 
Audit taking into account European standards on judicial appointments.  

  Step up efforts to  establish a robust track record  of prosecutions and final  judgments in 

corruption cases, including high-level corruption. 

  Take forward the process of adopting non-legislative safeguards and start the legislative 
process in relation to the protection of journalists, building on the activities initiated by the 
Task Force, in particular as regards abusive lawsuits against journalists and their safety, in 
line with the adopted Memorandum of Understanding and taking into account European 
standards on the protection of journalists.  

  Ensure the effective and timely consultation in practice of stakeholders on draft legislation, 

including by allowing sufficient time for public consultation. 

  Take further steps to evaluate the current registration system for civil society organisations, 
including by initiating a structured dialogue with CSOs, and assess whether there is a need 
to amend it. 

2 

 
 
 
I. 

JUSTICE SYSTEM  

The Greek judicial system consists of 217 first instance courts (154 magistrate courts and 63 
first-instance courts of general jurisdiction)1. There are 19 second instance courts (courts of 
appeal)  of  general  jurisdiction  and  the  Supreme  Court  as  the  highest  court  of  general 
jurisdiction2. Mixed criminal courts are composed by professional and lay judges3. Within the 
courts of first instance and courts of appeal of large cities, there are special chambers, tasked 
with  adjudicating  in  special  categories  of  law  (e.g.  family  law,  commercial  law,  etc.)4. 
Administrative  courts  are  organised  into  30  administrative  courts  of  first  instance,  9 
administrative courts of appeal  and the Council of State5 which exerts retrospective control 
over  ‘enforceable  acts’  of  administrative  authorities  regarding  their  constitutionality  and 
legality, with the exception of the Acts of Government6. The Court of Audit is the Supreme 
Financial  Court  and  Audit  Institution  auditing  the  use  of  public  funds  in  Greece,  the 
jurisdictional, auditing and advisory competences thereof being grounded on the Constitution7. 
Judges and prosecutors form a consolidated body subject to a system of recruitment, career, 
rights and obligations, which is largely homogeneous for all. Judges are appointed to civil and 
penal  jurisdictions  and  to  administrative  courts.  Promotions,  assignments  to  posts,  transfers 
and  secondments,  are  effected  by  presidential  decree  and  issued  after  prior  decision  by  the 
Supreme  Judicial  Council8.  As  regards  prosecution  authorities9,  they  are  organised  into  63 
prosecution offices at the courts of first instance, 19 prosecution offices at the courts of appeal 
and the General Prosecutor of the Supreme Court. Greece participates in the European Public 
Prosecutor’s Office (EPPO). There are 63 bar associations in Greece, one at the seat of each 
court of first instance.  

Independence  

The level of perceived  judicial independence in Greece continues to be average among 
both the general public and companies. Overall, 46% of the general population and 54% of 

1   Ministry of Justice website, https://ministryofjustice.gr/English/. 
2   CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States, p. 638. 
3   Constitution of Greece,  Art.  97, para. 1: ‘Felonies and political crimes shall be tried by  mixed jury courts 
composed of ordinary judges and jurors, as specified by law. The judgments of these courts shall be subject to 
the legal remedies specified by law’. 

4   As far as other special courts are concerned, special provisions regulate the operation of courts for juveniles, 
military, navy and air force courts. The military, navy and air force courts are under the jurisdiction of the 
Ministry  of  National  Defence.  Juvenile  courts  are  part  of  the  courts  of  first  instance  and  do  not  represent 
separate legal entities. CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States, 
p. 638. 

5   Ibid. 
6   Codification of Law concerning the Council of State, Presidential Decree, 18/1989, Article 45, para 5. Acts of 
Government are classified into three categories: (i) those concerning the relations between the President of the 
Republic  with  Parliament  and  the  Government  (e.g.  decree  dissolving  the  Parliament  and  announcing 
elections, decree accepting the resignation of a minister or the Government, decree proclaiming a referendum, 
etc.); (ii)  acts declaring  the  mobilisation of the  Armed Forces and granting grace; and (iii) acts relating to 
international relations of Greece with third countries. GRECO Fifth Evaluation Round –Evaluation Report, p. 
25. 

7   Constitution of Greece, Article 98. 
8   There are three supreme judicial councils, one for each of the branches of the judiciary, which are composed 
only  by  members  of  the  judiciary.  These  councils  decide  on  appointments,  promotions,  transfers  and 
secondments of judges in the respective branches of the judiciary and prosecutors. Constitution of Greece, 
Article 90, para 1. 2020, 2021, 2022 Rule of Law Reports, Country Chapter on the rule of law situation in 
Greece, p. 2-3, p. 2 and p. 3 respectively. 

9   CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States, p. 641. 

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companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in  202310.  According  to  data  in  the  2023  EU  Justice  Scoreboard,  the  perceived  judicial 
independence among the general public and companies has consistently decreased in the last 
years. Both figures have decreased in comparison with 2022 (53% for the general public and 
59% for companies). In comparison with 2016, the perceived judicial independence among the 
general public has decreased slightly (47%), while the perceived judicial independence among 
companies has increased (37%).  

Clear standards of professional conduct and integrity in the judiciary were set with the 
adoption of Codes of Conduct for all jurisdictions.  In October 2022, the Supreme Court 
published the Code of Conduct for Judges and Prosecutors of the Civil and Criminal Justice11, 
which  follows  the  codes  already  adopted  by  the  Court  of  Audit  and  Council  of  State,  as 
reflected  in  the  2022  Rule  of  Law  Report12.  It  draws  inspiration  from  best  practices  and 
international  texts  in  this  area,  including  the  2002  United  Nations  Judicial  Group  on 
Strengthening Judicial Integrity, the so-called ‘Bangalore Principles of Judicial Conduct’13. It 
aims to provide guidance to judges and prosecutors on ethical issues and strengthen society’s 
confidence in the institution of justice. The Plenary of the Supreme Court has decided in favour 
of the establishment of an ethics committee which would be responsible for the implementation 
of the code14.  

There have been no steps taken  with regard to the involvement of the judiciary in the 
appointments of the highest positions of the Greek judiciary. The 2022 Rule of Law Report 
recommended  to  Greece  to  ‘address  the  need  for  involvement  of  the  judiciary  in  the 
appointment of President and Vice-President of the Council of State, the Supreme Court and 
the Court of Audit taking into account European standards on judicial appointments’15. The 
Government stated that it was not in a position to implement the recommendation, because this 
would require a revision of the Constitution, which cannot take place until a number of years 
has elapsed16. In particular, the Government referred to three opinions delivered by the Council 
of State and the Court of Auditors, between 2010 and 2019, considering that the involvement 
of  any  other  organ  in  the  appointment  procedure  would  run  contrary  to  the  Constitution17, 
which provides that the appointments of the highest positions of the Greek judiciary are done 
by  presidential  decree,  following  a  recommendation  by  the  Council  of  Ministers18. 

10   Figures 49 and 51, 2023 EU Justice Scoreboard. The level of perceived judicial independence is categorised 
as follows: very low (below 30% of respondents perceive judicial independence as fairly good and very good); 
low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%). 

11   Supreme Court, Plenary decision 64/20.10.2022. 
12   2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 6. 
13   The Bangalore Principles of Judicial Conduct are intended to establish standards of ethical conduct for judges. 
They  identify  six  core  values  of  the  judiciary:  independence,  impartiality,  integrity,  propriety,  equality, 
competence and diligence. The United Nations Social and Economic  Council, by resolution 2006/ 23, has 
invited Member States to encourage their judiciaries to take into consideration the Bangalore Principles when 
reviewing  or  developing  rules  with  respect  to  the  professional  and  ethical  conduct  of  the  members  of  the 
judiciary. 

14   Information received from the Office of the Prosecutor to the Supreme Court in the context of the country visit 

to Greece.  

15   2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 2. 
16   No revision of the Constitution shall be permitted before five years have elapsed since the completion of the 
previous one, Constitution of Greece, Article 110 para 6. The last constitutional revision took place in 2019 
(Input from Greece for the 2023 Rule of Law Report). 

17   Council of State, opinions 2/2010 and 7/2019; Court of Audit, 13th General Assembly of 29 June 2015. 
18   Constitution of Greece, Article 90 para 5: ‘Promotion to the post of President or Vice-President of the Council 
of  State,  the  Supreme  Court  and  the  Court  of  Audit  shall  be  effected  by  presidential  decree  issued  on  the 

4 

 
                                                           
Nevertheless,  the  current  system  of  appointments  already  provides,  since  2010,  for  the 
involvement of a parliamentary body in the appointment procedure19 and sets some conditions 
for  candidates  to  the  highest  positions  of  the  judiciary,  notably  a  seniority  criterion,  since 
202220. According to European standards, where the constitutional or other legal provisions 
prescribe  that  the  head  of  state,  the  government  or  the  legislative  power  take  decisions 
concerning the selection and career of judges, an independent and competent authority drawn 
in substantial part from the judiciary should be authorised to make recommendations or express 
opinions  which  the  relevant  appointing  authority  follows  in  practice21.  The  lack  of  reform 
means that there has been no progress on the implementation of the recommendation made in 
the 2022 Rule of Law Report.  

Quality  

Efforts  to  address  shortcomings  in  the  digitalisation  of  all  branches  of  the  judiciary 
continue. There is progress in certain areas as reflected in the 2023 EU Justice Scoreboard, 
including with regard to the availability of secure electronic channels of communication for 
prosecution services and the possibility to carry out specific steps electronically in civil and 
administrative proceedings22. Also in administrative justice, digitalisation is further advancing. 
For instance, the upgraded Legal Information Database and the electronic register of the Court 
of Audit are operational since November 202223. In addition, the installation of an information 
system,  interacting  with  the  information  systems  of  the  audited  bodies  facilitates  the 
interoperability of systems and allows the Court of Audit to collect and exchange audit data 
electronically24. The digital upgrade of the Integrated Administrative Court Case Management 
System is ongoing25. In criminal and civil justice, following the completion of Phase I of the 
project, the Integrated Judicial Case Management System for Civil and Criminal Cases is being 
upgraded  regarding  the  Appeal  Court  Districts  of  Athens,  Thessaloniki,  Piraeus,  and  Evia, 
while the roll-out to all civil and criminal courts and prosecution offices is under way (Phase 

proposal of the Council of Ministers, by selection from among the members of the respective Supreme Court, 
as specified by law’.  

19   Law 3841/2010 on the selection of magistrates for the top posts of Justice and the reinstatement of the self-
governance on courts provided for the involvement of the legislative power in the selection procedure. See 
also 2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 4. The role of the 
Parliament was maintained during the last reform introduced by Law 4938/2022.  

20   Article 59, para 3 of Law 4938/2022 provides that the selection shall be made from among the ten most senior 
judges  who  have the  formal  qualifications,  when the  post  to be filled is one. For each  additional post,  the 
number of candidates to be selected shall be increased by four. According to the Greek authorities, the seniority 
criterion is a limitation to  the discretionary power of the  Council of Ministers and  shall  be perceived as a 
validation of the decisions of the judicial councils on the promotion of judges and the order of seniority formed 
as a result. In its opinion 7/2019, the Council of State had also expressed a positive view on the introduction 
of a seniority criterion. (Input from Greece for the 2023 Rule of Law Report).  

21   Council of Europe: Committee of Ministers (2010), Recommendation CM/Rec(2010)12 of the Committee of 

Ministers to member states on judges: independence, efficiency and responsibilities, paras. 46-48. 

22   2023  EU  Justice  Scoreboard.  There  is  a  significant  improvement  in  (i)  the  adoption  of  procedural  rules 
allowing  the  use  of  digital  technology  in  proceedings  (Figure  41);  (ii)  the  availability  of  secure  electronic 
communication for prosecution services (Figure 44); and (iii) the possibility to carry out specific steps in civil 
and administrative proceedings electronically (Figure 45). 

23   The project ‘Upgrading the digital services of the Court of Audit’ was included in the Operational Program 

Public Sector Reform 2014-2020 of the National Strategic Reference Framework (NSRF) 2014-2020. 
24   The project Support of the internal function of the Court’s audit remit was concluded in October 2022 
25   The project, funded by the Partnership Agreement for the Development Framework (PA) 2014-2020 and 2021 
–  2027,  is  also  part  of  the  Greek  Recovery  and  Resilience  Plan  and  provides  for  the  improvement  of  the 
architecture  of  the  information  system,  the  redesign  of  applications,  the  introduction  of  AI  tools  and  the 
renewal of equipment for all administrative courts.  

5 

 
                                                           
II). The implementation of the reform shall be completed by the end of 202526. Other measures 
to improve the level of digitalisation include the electronic serving of procedural documents27 
and the possibility for parties to submit procedural documents in electronic form throughout 
the procedure, both of which could improve efficiency28. However, some of the shortcomings 
previously  identified  persist29,  notably  as  regards  the  limited  possibilities  for  courts  to 
communicate  electronically  between  themselves  in  a  secure  manner  as  well  as  with  legal 
professionals  and  other  institutions30,  the  lack  of  digital  solutions  to  initiate  and  follow 
proceedings in criminal cases31 and the limited availability of various digital tools, adequate 
infrastructure, and equipment at the disposal of judges, prosecutors, and judicial staff32.  

Delays are observed in the operation of the Office for the Collection and Processing of 
Judicial Statistics, which is not yet fully functioning. As referred in the 2022 Rule of Law 
Report33, the Office for the Collection and Processing of Judicial Statistics was established at 
the  end  of  2020  with  the  objective  of  systematic  collection  of  qualitative  and  quantitative 
statistical data34. However, the Office is still not fully operational. No statistical data have been 
produced yet under the new mechanism and new procedures35. The presidential decree relating 
to its organisation and functioning was adopted in July 2022 and its steering committee was 
established in October 202236. The procurement procedure for its information system is still in 
progress37, while the procedures to fill in the ten posts established to cover the staffing needs 
of the office are not expected to start immediately38. Both the Bar association and CSOs have 
criticised the effective functioning of the office, as there has been no visible improvement in 
the quantity of the statistical data becoming publicly available39. 

26   The  Greek  Recovery  and  Resilience  Plan,  under  the  Digital  Transformation  of  Justice  reform  contains  a 
corresponding milestone which requires Greece to upgrade and provide support services for the “Integrated 
Court Case Management System for the Civil and Criminal Courts (OSDDY-PP A)” and the roll-out of the 
system  to  all  Civil  and  Criminal  Courts  of  the  country  (OSDDY-PP  B).  Following  the  conclusion  of  the 
relevant public tender, the implementation of the OSDDY-PP B is in progress. 

27   Digitalisation  of  procedures  for  service  of  documents  and  relieving  the  Hellenic  Police  from  service  of 

documents in the criminal and civil proceedings, Law 4937/2022, Articles 1-13. 

28   International Trade Arbitration – Arrangements for the functioning of the Court of Auditors and other urgent 

provisions, Law 5016/2023, articles 65-67. 

29   2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 7. 
30   Figure 43, 2023 EU Justice Scoreboard. 
31   Figure 46, 2023 EU Justice Scoreboard. 
32   Figure 42, 2023 EU Justice Scoreboard. 
33   2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 7. 
34   Code  of  Procedure  of  the  Court  of  Audit,  provisions  on  the  effective  administration  of  justice  and  other 
provisions,  Law  4700/2020,  Article  358.  The  Greek  Recovery  and  Resilience  Plan,  under  Component  4.3 
Improve the efficiency of the justice system reform, contains subproject 3 ‘Implementing the provision of Law 
4700/2020 for the establishing of an independent office for the systematic collection and processing of judicial 
statistics. 

35   Written contribution from Greece for the 2023 Rule of Law Report. 
36   The  steering committee coordinates the strategic objectives and priorities in the collection of statistics and 
adopts the Office’s annual work programme. Establishment, organisation and operation of the Office for the 
Collection and Processing of Judicial Statistics at the Central Service of the Ministry of Justice, presidential 
decree 47/2022 and ministerial decision 51867/26-10-2022. 

37   According to the Government, a decision of evaluation of the technical offers of the candidates has already 

been issued. 

38   Information received from the Ministry of Justice and the Council of State in the context of the country visit 

in Greece. 

39   Contribution from the Council of Bars and Law Societies of Europe for the 2023 Rule of Law Report, p. 50; 
Vouliwatch, Greek Council for Refugees, Refugee Support Aegean, HIAS Greece, Generation 2.0 for Rights, 

6 

 
                                                           
The effectiveness of the legal aid scheme could be jeopardised by the long delays in settling 
the  lawyers’  fees.  The  system  of  legal  aid  to  persons  lacking  the  financial  means  is 
comprehensive and well established40. In certain cases, legal aid is also provided irrespective 
of financial criteria41. Each Bar association creates a list of lawyers on duty to provide legal 
aid  services. Compensation is  paid  through the  Ministry of Justice. However, in  November 
2022, the long delays in settling the lawyers’ fees have triggered the Bar associations’ decision 
to abstain from further taking up legal aid cases42. Following the introduction of a simplified 
expedited  procedure  to  settle  the  major  part  of  the  compensations43,  the  Bar  associations 
decided  to  resume  providing  legal  aid  services44.  The  settling  of  pending  claims  is 
progressing45.   

The revision of the judicial map in administrative cases and the introduction of remote 
hearings aim to balance the uneven distribution of cases, improve efficiency, and enhance 
access to justice. In February 2023, the revision of the judicial map in administrative justice 
reached an important milestone with the adoption of Law 5028/202346. The reform contains a 
series of measures for the redistribution of judicial posts and competences  between existing 
courts47  as  well  as  the  implementation  of  new  remote  forms  of  litigation.  The  territorial 
jurisdiction  of  the  Piraeus  Administrative  Court  of  First  Instance  was  extended  to  alleviate 
workload from the Administrative Court of First Instance of Athens. The territorial jurisdiction 
for disputes with the Organisation of Welfare Benefits and Social Solidarity and the National 
Social Security Fund is now determined based on the place of residence of the beneficiaries, 
thereby  ensuring  the  principle  of  proximity  and  enhancing  efficiency48.  Furthermore,  20 
transitional court seats49 will become court offices to be used for remote hearings. The parties 

Equality and Diversity, Reporters United (2023), Rule of Law Backsliding Continues in Greece, Joint Civil 
Society Submission to the European Commission on the Rule of Law Report, p. 11. 

40   Law  3226/2004  on  legal  aid  to  citizens  with  low  income  and  other  provisions  provides  the  main  legal 
framework.  It  has  been  amended  by  Law  4689/2020  to  include  suspects  and  accused  persons  in  criminal 
proceedings. Law 4939/2022 regulates legal aid to asylum seekers. Figure 24, 2023 EU Justice Scoreboard. 
41   For instance, persons charged with an indictable offence; a recent amendment extended legal aid to persons 

with disabilities over 67% regardless of their income (Law 5023/2023, Articles 23 and 24). 

42   Plenary of the presidents of Bar Associations, decisions of 5 November, 11 December 2022 and 28 January 
2023. The decisions provided a number of cases  where lawyers  could be granted leave to appear in court, 
namely in cases subject to statute limitations, pre-trial detention and other urgent cases. 

43   Law 5016/2023, Article 69 Procedure for liquidating and paying legal aid lawyers’ compensation resulting 

from special promissory notes issued between 1.1.2019 and 31.12.2022. 
44   Plenary of the presidents of Bar Associations, decision of 28 March 2023. 
45   According to the Government, on 14 June 2023, the sums due to the lawyers of 33 (out of 64) Bar associations 
were paid. By a press release of 12 June 2023, the Plenary of presidents of Bar Associations informed lawyers 
that the procedure is progressing smoothly and the claims of members of 25 Bar associations have been settled.  
46    Redeployment of districts and decentralisation of competences of ordinary administrative courts, organisation 
of telematics meeting, conversion of transitional seats and establishment of judicial telematics offices, Law 
5028/2023. The Greek Recovery and Resilience Plan contains milestone 226 requiring Greece to enact primary 
legislation for the revision of the judicial map for administrative justice. 

47   The redistribution concerns judicial posts that will become vacant following promotions of the judges who 
served  in  them.  No  transfers  or  relocations  of  judges  are  foreseen  in  the  context  of  this  reform.  Written 
contribution from the Ministry of Justice in the context of the country visit. 

48   The previous criterion of territorial jurisdiction, based on the seat of the authority whose act gave rise to the 
dispute, implied that all the social security cases were brought to the Athens courts. This resulted in significant 
discrepancies  in  the  number  of  pending  cases  between  administrative  courts.  The  changes  regarding  the 
territorial jurisdiction of courts will enter into force on 30 June 2023. Written contribution from the Ministry 
of Justice in the context of the country visit. 

49   Under the current framework, court sessions are held on specific days per month at the transitional seats with 

judges moving to them from neighbouring prefectures and regions.  

7 

 
                                                           
will  be  able  to  participate  in  the  hearings  using  remote  access  technologies:  they  will  be 
physically present at the transitional court office and connect to the court by electronic means50. 
This is intended to facilitate access to justice for citizens in remote areas and on islands. The 
full implementation of the reform is envisaged for January 2027, after a two-year pilot phase 
(2024-2026)51.  The  Bar  associations  expressed  opposition  to  the  reform,  considering  that 
hearings without the physical presence of the parties do not meet the guarantees of a fair trial 
and the principle of oral and public hearings52. 

The  establishment  of  the  Judicial  Police  is  expected  to  improve  the  administration  of 
justice and enhance the assistance to judges. In July 2022, the Judicial Police was established 
with the aim to assist the work of judges and prosecutors, as well as to  assume police tasks 
linked to the judicial services53. The Greek Recovery and Resilience Plan contains a milestone 
which requires Greece to enact further legislation for the full implementation of the law on the 
Judicial Police54. The Judicial Police will have a scientific/civil branch and a police branch. 
The  ‘scientific  personnel’,  including  lawyers,  economists,  IT  specialists,  translators, 
environmental and public health specialists, would conduct preliminary inquiries, investigative 
acts  and  would  provide  scientific  and  technical  assistance  to  judges  and  prosecutors.  The 
‘police branch’ would be responsible for the security of courtrooms, the  execution of court 
decisions and the serving of procedural documents. The number of staff members is envisaged 
at 600 for the police branch and at 150 for the scientific branch55. Both judges and lawyers 
have  welcomed  the  reform  as  a  positive  development  that  would  increase  the  quality  and 
efficiency of the justice system56. 

Additional recruitments of judicial clerks and further investments in court buildings are 
expected  to  positively  impact  the  quality  of  justice.  According  to  the  EU  2023  Justice 
Scoreboard57, Greece’s relative total expenditure on law courts is above the EU average and 
has been steadily increasing in the last four years. Furthermore, procurement procedures for 
the  construction  of  new  and  the  renovation  of  existing  court  buildings  are  ongoing58.  In 
particular, a tender has been launched for the construction of the Athens Courthouse and the 
Courthouse of Piraeus; the renovation of several court buildings is  also foreseen59. Plans to 
recruit  311  judicial  clerks  before  the  end  of  the  year  are  in  progress,  while  200  additional 

50   It is at the discretion of the parties to attend the hearing either from the remote location or in the courtroom 

where the judges are physically present. 

51   A similar reform in civil and criminal justice is ongoing. The Greek Recovery and Resilience Plan contains 
milestone  no. 232  which requires to revise by end 2023 the judicial map  in civil and criminal justice. The 
project also receives technical assistance from the International Bank for Reconstruction and Development. 

52   Plenary of the Presidents of the Greek Bar Associations, decisions of 28 January 2023. 
53   Establishment of the Judicial Police, Law 4963/2022. 
54   The relevant Presidential Decree was adopted in January 2023. Establishment of a Judicial Police Directorate, 
four regional judicial police services, structural judicial police posts and competences of the regional judicial 
police services, Presidential Decree 6/2023.  

55   The pilot phase of the implementation consists in setting up the Central service and four regional services in 

Thessaloniki. 

56   Information received from the judiciary and the Greek Bar associations in the context of the country visit to 

Greece.  

57   Figure 33, 2023 EU Justice Scoreboard.  
58   The Greek Recovery and Resilience Plan included milestones no 227 and 233 requiring the launch of tenders 
for the renovation of buildings of administrative and civil/criminal courts to be completed by end of 2022 and 
end of 2023 respectively. 

59   Namely the buildings of the Council of State, the Court of Audit, the National School of Judges, the Court of 

Appeal, Administrative Court of First Instance and Administrative Court of Appeal of Athens. 

8 

 
                                                           
recruitments  are  planned  for  202460.  The  judicial  clerks  will  be  selected  and  trained  by  the 
National School of Judges61. The high number of envisaged new recruitments forms part of the 
efforts to increase the ratio between judges and judicial clerks62. 

Efficiency 

Serious challenges remain regarding the efficiency of justice, in particular the length of 
proceedings, which has further deteriorated. According to the 2023 EU Justice Scoreboard, 
the disposition time in civil and commercial cases at first instance courts was the highest in the 
EU, as it reached 728 days in 202163. For administrative cases, the disposition time in 2021 at 
first instance courts increased to 595 days (551 days in 2020)64. Furthermore, the disposition 
time for administrative cases in the Council of State reached the very high level of 1 324 days 
in 2021 (1 107 in 2020)65. In 2021, the clearance rate for litigious civil and commercial cases 
decreased to 82%, one of the lowest of the EU)66. On the other side, the clearance rate in 2021 
for administrative cases was 130%67, one of the highest of the EU - this means that more cases 
were resolved than came in - although the number of pending administrative cases at the end 
2021 remained the most substantial in the EU68. Stakeholders have underlined the significant 
delays and backlogs in the administration of justice and identified the length of proceedings as 
the most important challenge for the judicial system69.  

Efforts to address the backlog and reduce the length of proceedings before the highest 
administrative courts are made, including by adopting an accelerated procedure to deal 
with specific types of cases before the Court of Audit, which is already applied in practice. 
The Court of Audit proposed an accelerated procedure to deal with the very high number of 
pending  cases  relating  to  reductions  of  pensions  during  the  period  that  Greece  was  under 
financial supervision,  for which the Court’s Plenary already dealt with  the underlying legal 
issues in pilot judgments70. The proposal led to an amendment to the Statute of the Court of 

60   Written contribution from Greece for the 2023 Rule of Law Report.  
61   Written contribution from the National School of Judges in the context of the country visit in Greece; see also, 

2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 8. 

62   While the number of judges is among the highest in the EU (2023 EU Justice Scoreboard, Figure 35), the ratio 
between judges and non-judge staff decreased substantially in Greece from 2015 (1 judge for 2.53 clerks) to 
2020 (1 judge for 1.09 clerk). CEPEJ (2021), Study on the functioning of judicial systems in the EU Member 
States, p. 640. See also, contribution from the Association of European Administrative Judges for the 2023 
Rule of Law Report, p. 14. 

63   Figure 6, 2023 EU Justice Scoreboard. 
64   Figure 9, 2023 EU Justice Scoreboard, and Figure 10, 2022 EU Justice Scoreboard. 
65   Ibid. 
66   Figure 11, 2023 EU Justice Scoreboard. 
67   Figure 12, 2023 EU Justice Scoreboard. 
68   Figure 15, 2023 EU Justice Scoreboard. 
69   Contribution from the Council of Bars and Law Societies of Europe for the 2023 Rule of Law Report, p. 49; 
Greek  National  Commission  for  Human  Rights,  Impact  of  2022 ENNHRI  rule  of  law  reporting,  p.  10-11; 
Vouliwatch, Greek Council for Refugees, Refugee Support Aegean, HIAS Greece, Generation 2.0 for Rights, 
Equality and Diversity, Reporters United (2023), Rule of Law Backsliding Continues in Greece, Joint Civil 
Society Submission to the European Commission on the Rule of Law Report, p. 11. 

70   The Court of Audit, in its 25th General Assembly of the Plenary of the Court of Audit, of 19 December 2022, 
referred to over 130 000 applicants waiting for a decision on their pension cases, including on claims arising 
from reductions which were held to be unconstitutional. According to the Court of Audit, a legislative initiative 
for the extra-judicial settlement of these claims would be most effective in addressing the backlog; Written 
contribution from the Court of Audit in the context of the country visit in Greece. 

9 

 
                                                           
Audit71.  According  to  the  new  procedure,  which  is  already  in  place  since  March  2023,  the 
President of the Chamber assigns the cases to a single-member panel to deal with them without 
a  public  hearing72,  while  the  time-limits  for  submissions  of  documents  and  delivery  of  the 
decision are also very short.       

II. 

ANTI-CORRUPTION FRAMEWORK  

The National  Transparency Authority  (NTA)73 oversees the implementation  of the National 
Anti-Corruption Action Plan (NACAP) for 2022-2025, conducts investigations on corruption 
cases,  monitors  the  implementation  of  provisions  related  to  asset  declarations  and  lobbying 
activities, takes the necessary actions to ensure the coherence and effectiveness of the national 
strategy, with particular emphasis on coordination of control bodies and the efficiency of their 
operations74, and provides relevant instructions. The Directorate General of the Financial and 
Economic Crime Unit is the law enforcement agency of the Ministry of Finance, whose focus 
is the detection of fraud and corruption cases. The Directorate of Internal Affairs is tasked to 
tackle corruption within the Independent Authority for Public Revenue. The Internal Affairs 
Agency  for  Law  Enforcement  Bodies75  exercises  internal  control  and  investigates  crimes, 
including  corruption,  committed  by  various  entities76.  The  Court  of  Audit  is  the  Supreme 
Financial Court and Audit Institution auditing the use of public funds. 

The perception among experts and the business community is that the level of corruption 
in  the  public  sector  is  relatively  high.  In  the  2022  Corruption  Perceptions  Index  by 
Transparency International, Greece scores 52/100 and ranks 21st in the European Union and 
51st globally77. This perception has significantly decreased over the past five years78.  The 2023 
Special  Eurobarometer  on  Corruption  shows  that  97%  of  respondents  consider  corruption 
widespread in their country (EU average 70%) and 56% of respondents feel personally affected 

71   International Trade Arbitration – Arrangements for the functioning of the Court of Auditors and other urgent 

provisions, Law 5016/2023, Article 52.  

72   The parties have the right to request that the case is heard in court by a three-member panel of judges. 
73   In line with the milestone foreseen under the Greek Recovery and Resilience Plan (RRP), new business 

premises for NTA shall be developed by the end of 2025. NTA is the Greek designated authority responsible 
for coordinating the fight against fraud (AFCOS) in accordance with the Regulation (EE, Euratom) No. 
883/2013 of the European Parliament and the Council of September 11, 2013 (EU L248). The NTA was 
established by Law 4622/2019 and is subject to parliamentary scrutiny. 

74   The  NTA  chairs  the  meetings  of  the  National  Coordinating  Body  for  Audit  and  Accountability  (ESOEL) 
established by Article 103 of Law 4622/2019. ESOEL tasks include the dissemination of good practices and 
developing  common  standards  and  tools  for  the  prevention,  detection  and  control  of  fraud  and  corruption. 
Fifteen public bodies active in the field of law enforcement participate in ESOEL. Input from Greece for the 
2023 Rule of Law Report, p. 12.  

75   The Agency reports to the Ministry of Citizen Protection and is subject to parliamentary scrutiny.  
76   According to the provisions of Presidential Decree 65/2019 these are the Hellenic Police personnel, Hellenic 
Coast Guard personnel, Hellenic Fire Brigade personnel, employees of the wider public sector, and employees 
of the European Union or International Organizations that work on the Greek territory.  

77    Transparency International (2023), Corruption Perceptions Index 2022. The level of perceived corruption is 
categorised as follows: low (the perception among experts and business executives of public sector corruption 
scores above 79); relatively low (scores between 79-60), relatively high (scores between 59-50), high (scores 
below 50). 

78   In 2018 the score was 45 while in 2022 the score is 52. The score significantly increases/decreases when it 
changes more than five points; improves/deteriorates (changes between 4-5 points); is relatively stable 
(changes from 1-3 points) in the last five years. 

10 

 
                                                           
by  corruption  in  their  daily  lives  (EU  average  24%)79.  As  regards  businesses,  95%  of 
companies consider that corruption is widespread (EU average 65%) and 74% consider that 
corruption  is  a  problem  when  doing  business  (EU  average  35%)80.  Furthermore,  25%  of 
respondents find that there are enough successful prosecutions to deter people from  corrupt 
practices  (EU  average  32%)81,  while  16%  of  companies  believe  that  people  and  businesses 
caught for bribing a senior official are appropriately punished (EU average 30%)82. 

The  implementation  of  the  National  Anti-Corruption  Action  Plan  (NACAP)  for  2022-
2025 is underway. The implementation of the NACAP for 2022-2025, approved last year as 
reported in the 2022 Rule of Law Report83, falls under the remit of the NTA. The NACAP is a 
strategic plan that includes a coherent framework of actions, interventions and projects aimed 
at preventing and fighting corruption, strengthening transparency, integrity, and accountability. 
It  also  includes  actions  that  make  up  the  National  Integrity  System  that  focuses  on 
strengthening  public  integrity  and  accountability,  including  the  setting  up  of  Integrity 
Advisors84, in public sector bodies. In 2022, out of 129 actions envisaged under the NACAP, 
23  were  completed85,  84  started  and  are  being  implemented  and  22  have  not  yet  started86. 
Implementation is on track within the specified timeframes87. 

The  activities  by  the  National  Transparency  Authority  are  progressing  well,  and  its 
cooperation with private and public entities continues. In 2022, the NTA already carried 
out several investigations under the new action plan. It received 3 513 complaints on alleged 
corruption,  fraud,  and  maladministration  (3  057  in  2021);  and  it  carried  out  575  audits  and 

79   Special Eurobarometer 534 on Corruption (2023). The Eurobarometer data on citizens’ corruption perception 

and experience is updated every year. The previous data set is the Special Eurobarometer 523 (2022). 

80   Flash Eurobarometer 524 on Businesses’ attitudes towards corruption in the EU (2023). The Eurobarometer 
data  on  business  attitudes  towards  corruption  as  is  updated  every  year.  The  previous  data  set  is  the  Flash 
Eurobarometer 507 (2022). 

81   Special Eurobarometer 534 on Corruption (2023).  
82   Flash Eurobarometer 524 on Businesses’ attitudes towards corruption in the EU (2023).  
83   Approved  by  the  Council  of  Ministers  by  Art.  1  of  Law  4915/2022  in  March  2022. This  was  in  line  with 
Greece’s Recovery and Resilience Plan (RRP). See the 2022 Rule of Law Report, Country Chapter on the rule 
of law situation in Greece, pp. 12-13.  

84   The  National  Integrity  System  (NIS)  2022-2025  was  established  by  Ministerial  Decision  No. 
707/18852/05.12.2022  (GG  6312B’/12.12.2022).  The  main  objectives  are  the  prevention  and  tackling  of 
corruption and the strengthening of transparency, integrity, and accountability in the public administration, as 
well as public information and awareness-raising. Law 4795/2021 includes provisions to institute Integrity 
Advisors in the Greek public sector to provide support, information and advice on ethics and integrity matters 
and to receive reports of integrity breaches at the workplace, which may include whistleblowing reports. Input 
from Greece for the 2023 Rule of Law Report, pp. 14, 16, 18 and 24. Written contribution from the NTA in 
the context of the country visit to Greece.  

85   The completed actions include the development of the Network of Integrity Advisors in Public Administration; 
an e-platform “E-peitharxika” to monitor disciplinary cases in the public sector; a management and control 
system for projects funded under  the Recovery and Resilience Fund; and an update of the Anti-Corruption 
Action Plan 2022-2025 of the Independent Authority for Public Revenue (IAPR). Input from Greece for the 
2023 Rule of Law Report, p. 15.  

86   National  Transparency  Authority  (2023),  NACAP  2022-2025  Implementation  Report,  2nd  Semester  2022. 
Written contribution from the NTA in the context of the country visit to Greece. The actions in progress include 
development of an anti-corruption and anti-fraud strategy  for the implementation of actions  funded by the 
Recovery and Resilience Fund; drafting a new Code of Administrative Procedure for the public sector; and an 
upgrade of the electronic asset declaration system (e-pothen). Actions that have yet to start include a Code of 
Ethics and Conduct for civil servants working in public sector procurement units. 

87   Written  contribution  from  the  NTA  in  the  context  of  the  country  visit  to  Greece.  Experience  with  the 
implementation of NACAP 2018-2021 shows that risks related to a) the procurement cycle and b) delays in 
the adoption of relevant legislation should be taken into consideration.  

11 

 
                                                           
inspections (393 in 2021), of which 13 (21 in 2021) were referred for criminal prosecution to 
the  judicial  authorities.  In  addition,  55  cases  were  referred  to  the  competent  disciplinary 
authorities (42 in 2021) and 41 of these cases (28 in 2021) were referred for both criminal and 
disciplinary prosecution. A total of 186 civil servants and elected officials (137 in 2021) were 
referred to disciplinary boards88.  The NTA is making efforts to ensure an adequate level of 
resources89 and to recruit staff to fill the 103 unoccupied posts (out of a total of 503) through 
both regular recruitment and secondments90. Improving the occupancy of its posts as soon as 
possible is crucial to enable the NTA to carry out its tasks. In 2022, building on efforts reported 
last year91, the NTA signed 15 memoranda of understanding (MoUs) with several agencies92 
and  universities93  aimed  at  developing  integrity  actions94.  This  included  an  MoU  with  the 
European Public Prosecutor’s Office (EPPO) in February 2022 to improve cooperation95. In 
the  same  year,  the  Directorate  of  Internal  Affairs  of  the  Independent  Authority  for  Public 
Revenue conducted 92 audits of its employees’ funds, and found 15 breaches of disciplinary 
rules,  while  suspicious  criminal  offences  were  forwarded  to  the  Court  of  Audit  within  the 
context of the latter’s competence, as well as of its Advocate General competence96.  

Following the recent entry into force of a law on asset declarations, significant progress 
has  been  made  to  increase  the  verifications  of asset  disclosures.  The  2022  Rule  of  Law 
Report  recommended  to  Greece  to  “ensure  the  effective  and  systematic  verification  of  the 
accuracy of asset disclosures filed by all types of public officials”97. The 2022 Report had noted 
that while asset declarations are filed in great numbers, only a limited percentage of them are 
verified on their accuracy98. On 28 February 2023, a new law on asset disclosures entered into 

88   Written contribution and information received from the NTA in the context of the country visit to Greece. 

According to the NTA, the compliance rate is very high (around 80%). 

89   According to relevant international standards, anti-corruption agencies ‘shall be entitled to timely, planned, 
reliable  and  adequate  resources  for  the  gradual  capacity  development  and  improvement  of  the  agency’s 
operations  and  fulfilment  of  its  mandate”.  UNODC  Jakarta  Statement  on  Principles  for  Anti-Corruption 
Agencies (2002), and Colombo commentary (2020). 

90   Out of 503 posts, 103 are currently unoccupied (63 inspector-auditor posts and 40 administrative staff). An 
open call to recruit (via secondment) 15 inspector- auditors should be completed by the end of 2023 while a 
similar call for 20 auditors will be launched in the third quarter of 2023. Other administrative posts are also 
expected to be filled. Input from Greece for the 2023 Rule of Law Report, p. 11 and written contribution from 
the NTA received in the context of the country visit to Greece.  

91   See 2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 11. 
92   Such  as  the  Hellenic  Development  Bank  (HDB),  Hellenic  Public  Electricity  (DEI),  Hellenic Agricultural 
Organization, Naval  Reserve  Fund (NAT), and Hellenic Capital Market Commission (HCMC).  Input from 
Greece  for  the  2023  Rule  of  Law  Report,  p.  13  and  information  received  from  the  National  Transparency 
Authority in the context of the country visit to Greece. 

93   Such  as  the  Aegean  University,  Aristotle  University  of  Thessaloniki,  University  of  Western  Macedonia, 
University of Crete, University of Macedonia and University of Patras. These MOUs aim to strengthen the 
development of academic research, teaching and  knowledge  dissemination on transparency, anti-fraud and 
anti-corruption and internal control systems. Input from Greece for the 2023 Rule of Law Report, p. 13. 
94   In  2022,  the  NTA  organized  a  series  of  workshops  on  transparency  and  integrity  in  cooperation  with  14 
organizations and the participation of 65 public and private sector executives, attended by 7 070 participants. 
Input from Greece for the 2023 Rule of Law Report, pp. 25-26. See also written contribution from the NTA 
in the context of the country visit to Greece. 

95   The MoU with EPPO focuses on establishing channels for information exchange and on the conditions for the 
provision of scientific and technical assistance by the NTA to support investigations regarding the protection 
of the financial interests of the European Union. Ibidem p. 12.  

96   Stipulated  in  Articles  8  para.  2  (b)  and  36  par.  (a)  of  Law  4820/2021  and  in  Articles  118  et  seq.  of  Law 

4700/2020. Input from Greece for the 2023 Rule of Law Report, p. 13. 

97   2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 2.  
98   2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 12. 

12 

 
                                                           
force99. The new law aims to systematise the current rules and streamline the asset declaration 
process through the following tools and processes: digitalisation100; simplification of the list of 
filers101; higher percentage of verifications (to a target of minimum 7% that will be achieved 
over  a  three-year  period  which  is  almost  a  doubling  of  the  current  4%)102;  a  uniform 
methodology for all types of audits, with one central Audit Committee103 (assisted by an audit 
coordinator) to supervise and coordinate the work of the specialised audit bodies104, in order to 
reduce fragmentation105; and uniformity on violations and appropriate sanctions106. The Audit 
Committee is obliged to publish annual activity reports107. The increase in the number of the 
declarations verified should be achieved through better coordination and distribution of tasks 
amongst the audit bodies108. The secondary legislation enabling the full implementation of the 

99   Submission  of  declarations  of  assets  and  financial  interests  -  Arrangements  for  the  strengthening  of  the 
European Public Prosecutor's Office - Other urgent arrangements, Law 5026/2023. The second part of the law 
redefines the status of competences between the domestic prosecutorial authorities and the EPPO. The entry 
into  force  of  a  law  on  asset  disclosure  is  a  milestone  under  Greece’s  recovery  and  resilience  plan  (RRP). 
Milestone no. 209 states: ‘Entry into force of the new legislation regarding: (i) Asset Declarations; (ii) and the 
codification of legislation on political parties.’ The  RRP envisages the revision of the legal framework for 
asset declarations (Law 3213/2003), the simplification of the electronic submission process and an upgrade of 
the IT platform for asset declaration and management by the end of 2023.  

100  This  includes  the  technological  upgrade  of  the  electronic  asset  declaration  system  (e-pothen)  and  its 
interoperability with other databases such as that of the Independent Authority for Public Revenue, banks and 
land registries. The development of the IT platform is part of the NACAP. Input from Greece for the 2023 
Rule of Law Report, p. 22, and information and written contribution received from the NTA in the context of 
the country visit to Greece.  

101  The  new  law  simplifies  the  categories  of  obliged  persons  from  the  current  49  cases  of  obligors  into  13 
categories and defines their relevant obligations more clearly, with spouses, separated spouses and parties to 
a  civil  partnership  now  obliged  to  file  separate  declarations.  Input  from  Greece  for  the  2023  Rule  of  Law 
Report, pp. 9-10 and information received from the Ministry of Justice, the National Transparency Authority 
(including  written  contribution),  and  the  Committee  of  Parliament  for  the  Investigation  of  Declarations  of 
Assets (CIDA) in the context of the country visit to Greece. 

102  According  to  Articles  1  and  29  of  Law  5026/2023,  for  the  first  year  of  application  of  the  new  law,  the 
percentage  of  audits  will  be  set  at  5%  and  at  6%  for  the  second  year.  Information  also  received  from  the 
Ministry  of  Justice,  the  National  Transparency  Authority,  and  the  Committee  of  Parliament  for  the 
Investigation of Declarations of Assets (CIDA) in the context of the country visit to Greece. 

103  The Audit Committee set up under Article 25 of Law 5026/2023 will have independent, administrative, and 
financial autonomy. It will be chaired by the  head of the  Committee of Parliament for the Investigation of 
Declarations  of  Assets  (CIDA),  the  so-called  Committee  3-A  established  under  Law  No.  3213/2003.  The 
CIDA will remain responsible for the oversight and sanctioning of the political financing of both parties and 
persons,  and  on  asset  declarations  of  politicians  and  judicial  officials.  Information  also  received  from  the 
Parliamentary Committee for the Investigation of Declarations of Assets (CIDA) in the context of the country 
visit to Greece.  

104  The three Special Audit Bodies under Article 27 of Law 5026/2023 are essentially the same three out of the 
four authorities responsible for auditing asset declarations under the previous system, namely the ‘C Unit for 
the  Control  of  Asset  Declarations’  of  the  Anti-Money  Laundering  Authority,  the  National  Transparency 
Authority,  and  the  Internal  Affairs  Service  of  the  Security  Forces.  It  appears  that  the  fourth  authority,  the 
CIDA or Article 3 Committee, will be replaced by the Audit Committee, while the special asset declarations 
audit service of the parliament will be maintained. 

105  Input from Greece pp 9-10 and information received from the National Transparency Authority and the CIDA 

in the context of the country visit to Greece.  

106  Input from Greece for the 2023 Rule of Law Report, p. 10. 
107  Article 25 of Law 5026/2023 obliges the  Audit Committee to submit an annual report by 31 March on its 
activities for the previous  year to the Special Standing Committee on Institutions and Transparency of the 
Parliament and to the Ministers for Finance and for Justice. It will incorporate the reports of the special audit 
bodies. It will be posted on the Parliament’s official website and remain posted for three years.  

108  Information received from the Ministry of Justice in the context of the country visit to Greece. A key factor to 
achieve the quantitative target is that the Audit Committee can assign external auditors and experts to facilitate 
the process. Written contribution from the NTA in the context of the country visit to Greece.  

13 

 
                                                           
law  was  adopted  by  May  2023109.  Therefore,  there  has  been  significant  progress  on  the 
implementation of the recommendation made in the 2022 Rule of Law Report.  

Some progress can be noted in relation to establishing a track record of prosecutions and 
final judgments in corruption cases. The 2022 Rule of Law Report recommended to Greece 
to “increase efforts to establish a robust track record of prosecutions and final judgments in 
corruption cases”110. Prosecutions and final judgments related to corruption are still limited, 
including for high-level corruption. In 2022, the Financial Crime Prosecutor opened 650 cases 
(560 in 2021) covering all crimes of financial and economic crimes, including corruption. Of 
these, 229 were closed and 421 are pending preliminary examination111. Until the results of the 
preliminary investigation are ready, it is not possible to extrapolate the number of corruption 
cases112. Available statistics113 on the prosecution of active and passive bribery indicate that in 
2022 there were 80 ongoing criminal investigations (compared to 66 in 2021), 74 investigations 
concluded (53 in 2021) and 30 cases referred to a hearing (compared to 17 in 2021). This shows 
a relatively positive development. There were 32 convictions at appeal and first instance levels 
combined (compared to 24 in 2021) and 15 acquittals (compared to 21 in 2021), which also 
shows  a  positive  development.  However,  of  the  32  convictions,  imposed  sanctions  of 
imprisonment were suspended in 28 cases (compared to 20 in 2021). Overall, the increase in 
the  level  of  prosecutions  and  final  judgments  related  to  bribery  offences  is  offset  by  the 
relatively  high  level  of  acquittals  and  suspended  sanctions  which  raises  concerns  on  the 
deterrent  effect  of  Greece’s  criminal  justice  response  in  relation  to  bribery114.  Cooperation 
between the police and EPPO is considered to be good115. The Financial Crime Prosecutor has 
referred  eleven  cases  to  EPPO  since  it  was  set  up116.  The  Internal  Affairs  Unit  of  Law 
Enforcement Bodies systematically collects statistics, including on corruption cases within the 
Hellenic  Police,  Hellenic  Coast  Guard,  Hellenic  Fire  Brigade  and  employees  of  the  wider 

109  Information received from the Ministry of Justice in the context of the country visit to Greece. Article 45 of 
Law 5026/2023 provides for a series of secondary legislation including ministerial decisions on the content of 
declarations on assets and financial interests and on technical matters to implement the system, a parliamentary 
decision  approving  the  rules  of  procedure  of  the  Audit  Committee  and  of  the  audit  special  service,  and  a 
decision by the Audit Committee on the audit methodology and procedure. The rules of procedure of the audit 
special service and a decision by the Audit Committee on the audit methodology and procedure will be adopted 
upon formation of the Parliament that will emerge from the forthcoming elections. 
110  2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 2. 
111  Written contribution from the Financial Crime Prosecutor in the context of the country visit to Greece. 
112 Written contribution from the Financial Crime Prosecutor in the context of the country visit to Greece. Most 
of the time the cases cannot be classified as ‘corruption cases’ or ‘other’ before the results of the preliminary 
investigation. Usually, the processing and investigating concerns both corruption and other economic crimes.  
113  Written contribution from the Ministry of Justice in the context of the country visit to Greece. The figures 

quoted here have been extrapolated from the statistics provided by the Ministry of Justice. 

114  Concerning foreign bribery, the Financial Crime Prosecutor has one ongoing case (dating from 2014) and four 
(two  each  from  2021  and  2022)  are  pending  the  conclusions  of  a  preliminary  investigation.  Written 
contribution from the Financial Crime Prosecutor in the context of the country visit to Greece. The OECD 
Working Group on Bribery considers that Greece needs to strengthen enforcement and the independence of 
its  criminal  proceedings  on  foreign  bribery  investigations.  OECD  (2022),  Implementing  the  OECD  Anti-
Bribery Convention, Phase 4 Report, Greece, pp. 5 and 66. 

115  Input from EPPO for the 2023 Rule of Law Report.  
116  Information  received  from  the  Financial  Crimes  Prosecutor’s  Office  in  the  context  of  the  country  visit  to 
Greece. According to input from Greece for the 2023 Rule of Law Report, p. 27, in 2022, the Financial and 
Economic Crime Unit (within the Ministry of Finance) investigated 73 cases of corruption and detected 52 
infringements. It conducted 76 investigations regarding the use of EU subsidies and detected 93 irregularities 
and cooperated in 17 joint investigations with OLAF 

14 

 
                                                           
public  sector117.  Therefore,  some  progress  has  been  achieved  in  relation  to  the  2022 
recommendation concerning prosecutions and final judgments in corruption cases. 

Measures on the integrity of civil servants continue to be taken forward, while efforts to 
improve  integrity  and  conflicts  of  interest  within  the  police  force  are  ongoing.  In  the 
second  half  of  2022,  the  NTA  issued  a  Code  of  Conduct  for  Elected  Officials  of  Local 
Government Entities, covering mayors, regional governors and similar118, and a Code of Ethics 
and Professional Conduct for Public Sector Officials119. Following last year’s adoption of Law 
4940/2022120, a Decision of the Ministry of Interior was published in April 2023121 containing 
the details for the establishment of a Code of Conduct for Political Advisors that will be drafted 
by the NTA and is expected to be published by the end of 2023122. The NACAP 2022-2025 
envisages an update of the Code of Conduct for Members of the Government and Members of 
Parliament, although work on this action has not yet started123. In 2022, the Ethics Committee 
of the National Transparency Authority examined and decided on three cases124. Additional 
actions  are  also  envisaged  under  Greece’s  Recovery  and  Resilience  Plan125.  GRECO  has 
recommended addressing integrity in the police force, including by updating the Code of Ethics 
for  the  Police126.  The  current  Code  of  Police  Ethics127  dates  from  2004  and  has  not  been 
amended since. There are plans to amend the current Code and to introduce provisions with 
detailed  guidance  on  issues  of  moral  integrity  (prevention  of  conflicts  of  interest,  non-

117  The Minister of Citizen Protection publishes an annual report of the work and activities of the Internal Affairs 
Agency in the Greek language and presents it to the Standing Committee on Institutions and Transparency of 
the Hellenic Parliament that oversees the work of the Agency. Written contribution from the Internal Affairs 
Unit of Law Enforcement Bodies in the context of the country visit to Greece. The Hellenic Police publishes 
general  statistics  on  crime  and  other  incidents  such  as  road  accidents  (last  report  dates  from  2021).  See: 
Statistics | Hellenic Police (astynomia.gr).  

118  This was announced, also in relation to the relevant RRP milestone, in the 2022 Rule of Law Report, Country 

Chapter on the rule of law situation in Greece, p. 14, footnote 109.  

119  The  Code  of  Ethics  and  Professional  Conduct  for  Public  Sector  Officials  addresses  several  issues  such  as 
conflict of interest, harassment, intimidation, equal treatment, management, and disclosure of information, as 
well as any possible abuse of power by senior members of the public administration. Input from Greece for 
the 2023 Rule of Law Report, p. 18. 

120  Law 4940/2022 aims to ensure integrity and accountability for high-level officials, including political advisors, 
by  the  publication  of  their  data,  and  by  clarifying  their  obligations,  impediments,  and  incompatibilities, 
including post-employment restrictions. Other issues addressed include revolving doors and ethics.  

121  Decision 300/6546/2023 (Government Gazette 2473/Β/13-04-2023).  
122 The Code of Conduct aims to define the conduct of political advisors while exercising their duties and activities 
to prevent conflicts of interest and to ensure transparency, integrity, and accountability in the public policy 
process. It will cover the entire range of persons appointed to posts as political and special advisors. It will 
provide for a competent authority to supervise compliance with the Code, awareness-raising and information 
activities both for political advisors and civil society, examples of moral and ethical dilemmas, and a self-
assessment guide. Written contribution from the NTA in the context of the country visit to Greece. 

123 The Independent Authority for Public Revenue (IAPR) is also working on a Code of Ethics for its employees, 
expected to be ready by May 2023. Input from Greece for the 2023 Rule of Law Report, pp. 20 and 23. 

124  Information obtained from the NTA website.  
125  Actions aimed to review policies and provisions on conflict of interests are expected to be implemented by 

the end of 2024. These include development of a policy framework, guidelines, toolkit for practitioners, and 
the establishment of a national network of Integrity Advisors in the Public Administration. See 2022 Rule of 
Law Report, Country Chapter on the rule of law situation in Greece, p. 15. 

126  Other GRECO actions to address police force integrity include carrying out a comprehensive risk assessment 
of  corruption  in  the  Police,  strengthening  integrity  checks  during  staff  recruitment,  and  providing  for 
independent  and  effective  investigation  into  police  complaints.  GRECO  (2022)  Fifth  Evaluation  Round  – 
Evaluation Report, pp. 42-57. Greece is expected to submit a report on measures taken to implement GRECO’s 
recommendations by 30 June 2023 for GRECO’s subsequent compliance assessment.  

127  Governed by Presidential Decree 254/2004. 

15 

 
                                                           
acceptance of gifts, official confidentiality, and sound management of public resources). The 
competent  service  responsible  for  this  exercise128  has  circulated  an  informative  memo  on 
possible  amendments  to  the  Code  or  other  alternatives  for  consideration  by  the  Police 
hierarchy129. No decision has been taken yet pending possible changes in the civilian leadership 
of the Police following the recent general elections130. There are other efforts underway, such 
as enhancing the electronic complaints monitoring system by the addition, since last year, of 
corruption cases as a special category131. The Police also issued in April 2023 an order to define 
the concept  of  corruption and indicatively mention some criminal  and disciplinary offences 
that  fall  within  that  concept,  to  ensure  impartiality  and  transparency  during  the  conduct  of 
administrative inquiries for corruption cases132.  

Rules to regulate lobbying are in force but progress to implement an effective register has 
been slow. A regulatory framework for lobbying activities entered into force in Greece for the 
first time in 2021133. The law regulates the contact between officials with high executive and 
legislative functions and lobbyists and mandates the setting up of a Transparency Register134. 
The Transparency Register was, however, launched and became operational only in December 
2022135. It contains very few entries so far136, but the numbers are expected to increase by the 
end of the year, including through awareness-raising activities planned by the NTA to clarify 
and improve the implementation and application of the law137. In December 2022, the NTA 
issued a Code of Conduct with practical guidelines to assist lobbyists in their behaviour when 
communicating  with  institutions  and  to  ensure  transparency  and  integrity  in  the  public 
decision-making process and avoid conflicts of interest or any undue influence138. The NTA 

128  The Directorate of Organisation and Legal Support of the Hellenic Police Force.  
129 Written contribution from the Hellenic Police in the context of the country visit to Greece.  
130  Written contribution from the Hellenic Police and information received from the Internal Affairs Unit of Law 

Enforcement Bodies in the context of the country visit to Greece.  

131  This system provides details of police officers being investigated, the complaints against them, criminal and 
administrative  or  disciplinary  actions.  The  cases  are  categorized  by  type  of  complaint,  now  including 
corruption. Written contribution from the Hellenic Police in the context of the country visit to Greece.  

132  Written contribution from the Hellenic Police and information received from the Internal Affairs Unit of Law 

Enforcement Bodies in the context of the country visit to Greece.  

133  ‘Strengthening Transparency and Accountability of State Institutional Bodies’, Law 4829/2021 of 10 

September 2021. See 2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 
14. Five ministerial implementing decisions were issued in 2021 and 2022 by the Minister of Interior and the 
Minister of State with contributions from the NTA. Input from Greece for the 2023 Rule of Law Report, pp. 
20-21 and written contribution from the NTA in the context of the country visit to Greece. 

134  All  interest  representatives  must  register  in  the  Transparency  Register  to  engage  with  members  of  the 
legislature  and  the  executive  branch.  Both  interest  representatives  and  members  of  the  legislature  and 
executive branches are required to submit a publicly available annual activity report to the NTA.  

135  The  Transparency  Register  should  be  interoperable  with  other  databases  such  as  the  Hellenic  Online  Tax 
System (TAXIS), the General Electronic Commercial Registry (GEMI) and the National Criminal Records 
Portal. Input from Greece for the 2023 Rule of Law Report, pp. 20-21. 

136  NGOs  have  voiced  concerns  about  the  late  operationalisation  of  the  Register  and  its  lack  of  registrants. 
Information received from Transparency International in the context of the country visit to Greece. Under Law 
4829/2021, registration of NGOs in the Transparency Register is not mandatory and until now no NGO has 
applied, according to input from Greece for the 2023 Rule of Law Report.  

137  As of the beginning of June 2023, there were 14 registrations and applications pending for approval. Through 
the recent inclusion of the register on the GOV.GR platform and through awareness-raising activities planned 
during the year, the NTA expects approximately 40-50 lobbyists by year end. Written contribution received 
from the NTA in the context of the country visit to Greece. 

138  NTA (2022), Code of Conduct for Interest Representatives – Transparency Register, 30 June 2022. See also 
input from Greece for the 2023 Rule of Law Report, p. 21 and information and written contribution from the 
NTA in the context of the country visit to Greece.  

16 

 
                                                           
has  also  created  a  more  specialised  website  with  all  the  pertinent  information  on  lobbying 
provisions  and  instructions  for  entering  the  lobbying  registry139.  As  the  lobbying  law  also 
regulates gift policy140, the NTA has prepared a draft opinion and Ministerial Decision on the 
technical specifications, content and procedures for an electronic gift registry and rules for the 
management and utilisation of the gifts. The drafts are currently under consultation with the 
Government141. 

The rules on political party financing were codified and subsequently amended with a 
reduction of political fines. In March 2022, the provisions of the legislation on the financing 
by the state of political  parties and the audit of their finances were codified in a single text 
through a Presidential Decree, which was required as part of Greece’s Recovery and Resilience 
Plan142. In July 2022, the Presidential Decree was again amended143 with the stated purpose of 
clarifying  definitions,  updating  the  procedures,  and  amending  the  sanctions  that  could  be 
imposed by the President of the Parliament following a proposal by the Parliamentary Audit 
Committee (the CIDA) in cases of violation by the audited parties144. These changes include a 
reduction of political fines compared to the previous law145 as well as changes to the oversight 
powers of the Audit Committee146.  The choice of audits depends on certain criteria such as 
how active a party is, if it receives state grants147, and on information received about possible 
illegal activities. In 2022, CIDA completed the audits (2020 fiscal year) on 18 political parties, 

139  See also NTA Transparency Register https://lobbying.aead.gr//. Input from Greece for the 2023 Rule of Law 

Report, p. 21. 

140  Part B of Law 4829/2021 introduced rules for the management, recording, disclosure, and utilization of gifts, 
other  benefits,  and  hospitality  offered  to  the  President  of  the  Republic,  members  of  the  Government,  and 
Deputy Ministers, to enhance transparency and accountability. Input from Greece for the 2023 Rule of Law 
Report, p. 22. See also 2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 
14. 

141  Input from Greece for the 2023 Rule of Law Report, p. 22 and information and written contribution received 
from the NTA in the context of the country visit to Greece. The Presidency of the Government will administer 
and manage the gift registry (or electronic book) and the list.  

142  Presidential Decree 15/2022 (A’ 39/1-3-2022). Milestone no. 209 of Greece’s Recovery and Resilience Plan 
states: ‘Entry into force of the new legislation regarding: (i) Asset Declarations; (ii) and the codification of 
legislation on political parties.’ See footnote 95 above.  

143  Law  4954/2022  (A’  136/09.07.2022),  Part  D,  Arrangements  for  the  control  of  revenue  and  expenditure  of 
parties, coalitions and candidates for Members of Parliament and/or elected representatives - amendments P.D. 
15/2022, Articles 19 et seq.  

144  Input from Greece for the 2023 Rule of Law Report, p. 22 (also according to the regulatory impact assessment) 
and information received from the CIDA in the context of the country visit to Greece. Some NGOs have voiced 
criticism that the new law does not really enhance the transparency, accountability and objectivity of the audit 
mechanisms. Joint Civil Society submission for the  2023 Rule of  Law Report,  p. 16. See also Vouliwatch 
(2022), ‘Draft law on political money: a-transparency and a-accountability’. 

145 For instance, the fine for failure to publish the annual balance sheet and the special report on election revenues 
and expenditures of a party or coalition within the deadline has been reduced from 5% to a range from 1% to 
5%. Fines for political parties and coalitions that channel revenues or expenditures in violation of the law have 
been reduced from 50% to 20% of the last regular funding paid to them. For parties that did not receive state 
funding, the fine has been reduced from EUR  150 000 to EUR 50 000. Elected representatives who fail to 
submit a detailed or incomplete statement of election revenues and expenditures within the deadline will now 
be subject to a fine of EUR 1 000 instead of up to 10% of the annual parliamentary allowance.    

146  While  the  Audit  Committee  will  continue  to  assess  financial  statements  of  the  cash  valuation  of  in-kind 
contributions, it will not itself carry out and record the valuation anymore as previously. Rather, the valuation 
will be carried out and recorded by the beneficiaries themselves who may be less impartial than the Audit 
Committee.     

147  There  are  several  political  parties  in  Greece,  but  several  only  exist  on  paper,  so  these  are  not  prioritized. 
Financial audits are performed annually by specialized financial auditors who can also carry out on-the-spot 
checks at party premises. Information received from the CIDA in the context of the country visit to Greece.  

17 

 
                                                           
out of which it proposed penalties148 for four parties and sent letters of compliance to three 
parties149.  

The  new  law  on  the  protection  of  whistleblowers  who  report  breaches  of  EU  law  was 
adopted.  The  law  entered  into  force  in  November  2022150  and  aims  to  transpose  the  EU 
Whistleblowers Directive151. It designates the NTA as the external reporting channel competent 
for receiving, managing, and monitoring reports on violations falling within the scope of the 
law152. Public sector officials and private sector employees will be able to submit, in writing, 
orally, or through an online platform153, eponymous or anonymous reports, covering all types 
of  the  submission  of  complaints154.  The  NTA  is  contributing  to  the  preparation  of  four 
ministerial implementing decisions  (one of which has already entered into force)  as well as 
designing  the  technical  specifications  of  the  electronic  communication  platforms155.  Civil 
Society Organisations (CSOs) consider that the legislator’s decision not to extend the scope of 
the  law  also  to  breaches  of  national  law156  is  a  missed  opportunity  for  encouraging  more 
reporting  of  corruption157.  The  OECD  had  urged  Greece  to  implement  new  legislation  for 
whistleblowers, for cases of foreign bribery158.  

Guidance was issued to ensure that direct awards of public contracts are  only used in 
exceptional cases. To facilitate the work of contracting authorities in the correct application of 
the  negotiated  procedure  without  prior  publication,  the  Hellenic  Single  Public  Procurement 

148  Decisions  on  whether  to  impose  sanctions  are  ultimately  taken  by  the  President  of  the  Parliament.  CIDA 
publishes its audit reports on its  website. The Parliament President’s reasoned decision is published in the 
Official Gazette. Information received from CIDA in the context of the country visit to Greece. 

149  In 2019, CIDA audited 23 parties and proposed penalties for 8 of them. CIDA is currently undergoing checks 
for fiscal year 2021. Greek Parliament Audit Committee (March 2023), Declarations of Assets (Article 3a of 
Law 3213/2003) Annual Report 202, pp. 8-9. 

150  Law 4990/2022 on the ‘Protection of persons who report breaches of Union law’, Government Gazette A’ 
210/11.11.2022. Transposition of Directive (EU) 2019/1937 of the European Parliament and of the Council of 
23 October 2019. 

151  Directive (EU) 2019/1937 on the protection of persons reporting on breaches of Union law. 
152  Article 11 of  Law 4990/2022. In addition, the law provides for Integrity  Advisors (established  under  Law 
4795/2021)  to  receive  and  monitor  whistleblowing  reports  in  public  sector  bodies  and  local  government 
organizations employing up to 49 employees. Input from Greece for the 2023 Rule of Law Report, p. 24. 
153  The existing NTA online complaints platform already supports the submission of anonymous complaints. The 
new  whistleblowing  platform  will  further  enhance  this  function  by  supporting  two-way  communication 
(complainant  and  inspector).  It  will  keep  the  whistleblower’s  anonymity  through  a  secure  online 
communication channel and a management environment for the evaluation and investigation of reports. Input 
from Greece for the 2023 Rule of Law Report, p. 24. 

154  The  Internal Affairs Unit of Law Enforcement Bodies reported that 71% of complaints  were submitted by 
persons via email or by post and only 29% were made anonymously. Written contribution from the Internal 
Affairs Unit of Law Enforcement Bodies in the context of the country visit to Greece.  

155  These implementing acts will specify the qualifications of the persons who receive and monitor whistleblower 
reports; the process of submitting, receiving, and monitoring whistleblower reports; the process of transmitting 
whistleblower  reports  to  the  competent  authorities;  and  the  establishment  and  operation  of  electronic 
platforms. Written contribution and information received  from the National Transparency  Authority in the 
context of the country visit to Greece.  

156  A possibility allowed under the Directive and encouraged by the European Commission. 
157  Information received from Vouliwatch and Transparency International in  the context of the country visit to 

Greece.  

158  See  OECD  (2022),  Implementing  the  OECD  Anti-Bribery  Convention,  Phase  4  Report,  Greece,  p.  5.  See 
GRECO Fifth Evaluation Round – Evaluation Report, pp. 42-57. For its part, GRECO had recommended that 
Greece strengthen the protection of whistleblowers within the Police. 

18 

 
                                                           
Authority issued a communication159 clarifying, amongst other things, the exceptional nature 
of  and  conditions  for  the  use  of  the  negotiated  procedure  without  publication  of  a  contract 
notice, its own advisory competence on requests for consent to use the negotiated procedure, 
and the obligations of the contracting authorities and entities that arise following recourse to 
that procedure160. The Greek recovery and resilience plan adopted in July 2021 contains two 
measures for a total amount of 20 million EUR aiming at the professionalisation of staff for 
better  handling  of  public  contracts,  the  restructuring  of  the  National  Central  Purchasing 
Authority  (N.C.P.A.)  for  goods  and  services  to  promote  centralisation  of  procurement  and 
improvements in the digital tools for public procurement to avoid understaffing in the future 
and modernise the process. Having identified a need for specialized knowledge in this sector, 
the  Financial  Crimes  Prosecutor  is  looking  to  hire  two  experts  to  assist  in  cases  relating  to 
public procurement offences161. The NACAP 2022-2025 includes the development of an ethics 
code for civil servants working on public procurement162. 

III.  MEDIA PLURALISM 

The Greek legal framework concerning media pluralism and media freedom is based on a set 
of constitutional safeguards and legislative measures. The Constitution guarantees freedom of 
expression and press freedom and provides for a right of access to information. Audiovisual 
media is regulated by Law 4779/2021, which also implements the Audiovisual Media Services 
Directive (AVMSD)163. 

There have been no significant changes in the legal framework concerning the regulator 
for audiovisual media services, and the procedure to hire new personnel is ongoing, while 
challenges persist with regard to the  media  regulator’s human resources.  The National 
Council for Radio and Television (NCRTV) supervises and regulates the radio and television 
markets both off-line and on-line. Its independence is enshrined in the Greek Constitution and 
its legal framework set out in the Media Law. As described in the 2022 Rule of Law Report164, 
the  independence  of  NCRTV  has  been  strengthened  in  the  law  transposing  the  revised 
AVMSD165, which contains provisions aimed at reinforcing the independence of the NCRTV 
from the Government and other state bodies166. According to the law, the NCRTV exercises its 
power  with  impartiality  and  transparency,  serving  in  particular  the  objectives  of  pluralism, 
cultural  diversity,  consumer  protection,  accessibility  for  people  with  disabilities,  equal 

159  Hellenic  Single  Public  Procurement  Authority,  Document  No.  3581/1.7/2022,  ‘Reminder  of  obligations  of 
contracting  authorities/entities  related  to  the  use  of  the  exceptional  negotiation  procedure  without  prior 
publication’.  

160  Input from Greece for the 2023 Rule of Law Report, p. 26. 
161  Information obtained from the Financial Crime Prosecutor in the context of the country visit to Greece. They 
are looking specifically for engineers to assist in cases relating to procurement offences in the infrastructure 
sector where they currently lack specialist knowledge. The Flash Eurobarometer 524 on Businesses’ attitudes 
towards corruption in the EU (2023) shows that 53% of companies in Greece (EU average 26%) think that 
corruption has prevented them from winning a public tender or a public procurement contract in practice in 
the last three years. This is 27 percentage points above the EU average. 

162  Input from Greece for the 2023 Rule of Law Report, p. 25. Moreover, the NTA will receive technical assistance 
in the  framework of TSI  2023 in  “Enhancing transparency and integrity in the public procurement system 
through an integrated risk management system”. 

163  Greece ranks 107th in the 2023 Reporters without Borders World Press Freedom Index compared to 108 th in 

the previous year. 

164  2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 16. 
165  Law 4779/2021. 
166  Article33 of Law 4779/2021. 

19 

 
                                                           
treatment,  the  proper  functioning  of  the  internal  market  and  the  promotion  of  healthy 
competition167. Following two ministry cabinet decisions168, a national procedure organised by 
the  National  Council  of  Staff  Selection  to  hire  15  new  staff  members  for  the  NCRTV  is 
ongoing169.  However,  the  NCRTV170  emphasises  that,  while  the  hiring  of  new  personnel is 
welcome, this will not solve the problem of understaffing, as reported in the 2022 Rule of Law 
Report171, and will not be sufficient for the new tasks, assigned to the NCRTV by the AVMSD, 
in particular related to the monitoring activities172. As in the previous year, the Media Pluralism 
Monitor (MPM 2023) considers the independence and effectiveness of the media authority to 
be an area of medium risk173 

A new law aiming to enhance transparency of media ownership has been adopted. Legal 
safeguards  are  in  place  to  ensure  transparency  of  media  ownership.  Law  4779/2021174 
establishes  the  obligation  for  media  service  providers  to  register  in  the  NCRTV  Business 
Register175. The recently adopted Law No. 5005/2022176 aims to strengthen transparency and 
publicity in the field of printed and electronic press. The law set up a Registry for Print Media 
(MET)  as  well  as  a  Registry  for  Electronic  Press  (MHT)  and  reserves  eligibility  for  state 
advertising to  registered companies. Additionally, the recent  Law No.4915/2022 concerning 
press accountability entered into force, aiming at further enhancing transparency in the press177. 
The MPM 2023 has maintained its medium risk score for transparency of media ownership 
since the full impact of recent laws and initiatives is yet to be seen178. Media legislation contains 
specific ownership limitations to prevent horizontal concentration in the media market179New 
conditions for holding a license for the provision of pay radio and television services have been 
introduced by the recent Law No. 5014/2023, which amended Law No. 2644/1998180. 

Safeguards are in place to ensure the independence of public service media, but concerns 
persist with regard to the appointment procedure of the board members of the Hellenic 
Radio and Television Corporation (ERT). As described in the 2022 Rule of Law Report, the 
editorial independence of public service media is guaranteed by the Law on the Hellenic Radio 
and Television181 which provides that ERT is independent of the State, of all public or private 

167 In particular, according to art. 15 of the Constitution, the objectives are: “equal transmission of information 
and news, as well as products of speech and art, ensuring the quality of programs required by the social mission 
of radio and television and the cultural development of the country, as well as respect for the value of the 
human being and the protection of childhood and youth”.  

168  Decisions 50/2021 and 31/2022. 
169  Input from Greece for the 2023 Rule of Law Report, p. 30. 
170  Information received from the NCRTV in the context of the country visit to Greece. 
171  2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 16. 
172  Information received from NCRTV in the context of the country visit to Greece. 
173  2023 Media Pluralism Monitor, Greece, p.13. 
174  Article 37 of Law 4779/2021. 
175  2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 17. 
176  Law  No.  5005/2022  of  21  December  2022  "Strengthening  of  the  publicity  and  transparency  of  print  and 
electronic media - Establishment of electronic registries of print and electronic media and other provisions 
under the competence of the Secretariat General for Communication and Media". 

177  Article 110 Law No 4915/2022. 
178  2023 Media Pluralism Monitor, Greece, p. 9. 
179  Law No. 3592/2007. 
180  Article 60 Law 5014/2023 permits the participation of a pay-tv or radio in a company that holds a license for 
a free-to-air channel, if with its participation: a) the rules of free competition are not violated, b) the dominant 
position it  has acquired in the  market for radio and television services is not abused, and c) the  objective, 
pluralistic and equitable transmission of information and news in the mass media is not prejudiced.  

181  Law 4324/2015 of 29 April 2015. 

20 

 
                                                           
authorities  and  political  parties182.  ERT  is  a  legal  entity  under  private  law  in  the  form  of  a 
limited liability company which belongs to the public sector and is supervised by the State. 
ERT’s board members are appointed by decision of the Minister responsible for the media, 
following the opinion of the Committee on Institutions and Transparency of the Parliament. As 
highlighted in the 2022 Rule of Law Report183, and indicated by the MPM 2023184, while the 
involvement of the Parliamentary Committee seeks to ensure independence and transparency, 
the  fact  that  the  board  members  are  appointed  by  the  Minister  responsible  for  the  media 
continues to raise concerns about the effective independence and potential political influence.  

The  legislative  framework  safeguards  the  right  to  information.  In  Greece  access  to 
information is a Constitutional right. The Greek Constitution guarantees the right of access to 
administrative documents and the right of citizens to obtain information. Restrictions to this 
right may be imposed only insofar as they are absolutely necessary and justified for reasons of 
national security, combating crime or protecting the rights and interests of third parties185.The 
MPM 2023 reports a medium risk with regard to the protection of right to information186. 

Threats and attacks against journalists remain an issue. Since the publication of the 2022 
Rule of Law Report, the Council of Europe’s Platform to promote the protection of journalism 
and  safety  of  journalists  recorded  16  alerts187.  The  registered  incidents  relate  to  physical 
aggressions,  verbal  insults,  arbitrary  detainment  and  use  of  spyware  against  journalists. 
Moreover, journalists continue to face abusive lawsuits188 and to work in precarious working 
conditions189. It was also reported that several journalists have been targeted by the spyware 
Predator190. The surveillance of journalists was highlighted as a matter of concern also by the 
Media Freedom Rapid Response, as a major violation of the journalists’ privacy, journalistic 
source  protection,  and  press  freedom191.  The  Greek  parliament  last  December  passed  a  bill 
banning the sale of spyware: the bill criminalises the sale or possession of spyware and makes 
the  private  use  of  spyware  a  felony  from  a  misdemeanour,  punishable  by  up  to  10  years’ 
imprisonment. The 2023 Media Pluralism Monitor continues to rate the journalistic profession, 
its standards and protection at a high risk192, but registers a decrease compared to last year’s 
assessment, which was connected with the murder of the Greek journalist, Giorgos Karaivaz193.  

182  According to European Parliament’s Flash Eurobarometer: News & Media Survey 2022, 34% of respondents 

in Greece stated that they trust public TV and radio stations, below the EU average of 49%. 

183  2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 18. 
184  2023 Media Pluralism Monitor, Greece, p.19. 
185 Greek Constitution, Article 5A. 
186 2023 Media Pluralism Monitor, country report for Greece, p. 12. 
187  Council of Europe, Platform to promote the protection of journalism and safety of journalists, Greece. 
188  Reporters Without Borders, Abusive lawsuits against journalists amid political tension in Greece, 5 August 

2022. 

189  Information received from Journalists Union ESIEMTH in the context of the country visit to Greece. 
190  Reporters  Without  Borders,  Greek  and  European  authorities  must  take  urgent  action  after  many  more 
journalists said to have been Predator targets, 16 November 2022. See also para in Section IV below on  the 
issue of surveillance. 

191  Media Freedom Rapid Response - Greece, MFRR alarmed by latest revelations of spying on journalists, 20 

December 2022.  

192  2023 Media Pluralism Monitor, Greece, p.13. 
193  In relation to this murder, in April this year two suspects were arrested by the Greek police. European Centre 
for  Press  and  Media  Freedom:  MFRR  partners  welcome  first  arrests  over  2021  assassination  of  journalist 
Giorgos Karaivaz. 

21 

 
                                                           
A new Ethics Committee and a Directorate for Media Oversight, in charge of overseeing 
the compliance of online media with journalistic ethics have been established by the law194 
which set up the new registries for printed and electronic press. The Ethics Committee also 
has the power to  exclude media from  receiving  state advertising funds for up to  two  years. 
While the promotion of media ethics was welcomed also by the journalists’ associations, some 
concerns  were  raised  by  stakeholders  on  the  risk  that  the  new  rules  might  lead  to  effective 
control  of  the  content  published  by  registered  outlets  and  be  misused  to  arbitrarily  exclude 
certain media from receiving state advertising funds195.  

The controversial provision of the Criminal Code on the spread of disinformation was 
amended to address the concerns previously identified. In December 2022, Article 191 of 
the Criminal Code aiming at preventing the spread of disinformation, which, as reported in the 
2022 Rule of Law Report, raised serious concerns about the risks for the right of journalists to 
disseminate information of general interest196, was amended197. According to the Government, 
for  an  offence  to  be  committed,  the  concrete  “effect”  of  “causing  fear  is  required”  and  not 
merely the abstract risk of “causing fear in citizens”, which is a concept difficult to prove and 
not  easy  to  evaluate.  Moreover,  the  amendment  removed  the  aggravating  circumstance  of 
repeated  offence.  The  amendment  has  been  considered  as  a  positive  development  from  the 
journalists’ union198. 

Some progress  has  been made on the 2022 recommendation to establish safeguards to 
improve the working conditions and physical safety of journalists. The 2022 Rule of Law 
Report recommended to Greece to “establish legislative and other safeguards to improve the 
physical  safety  and  working  environment  of  journalists,  in  line  with  the  recently  adopted 
Memorandum of Understanding and taking into account European standards on the protection 
of journalists”199. Following the signing of the Memorandum of Understanding between the 
Secretariat General for Communication and Media of the Presidency of the Government, and 
other competent Ministries200, on 27 July 2022 a Task Force was created for the protection and 
empowerment of journalists201. The members of the Task Force include representatives of the 
journalistic associations, university, ministries, public service media, news agencies and other 
relevant stakeholders. The Task Force convenes once a month and the stakeholders cooperate 
under a mandate that covers a range of topics (such as analysis and reporting on attacks against 
journalists, secure working conditions and security of journalists in conflict situations, digital 
safety,  regional  press,  strategic  lawsuit  against  public  participation  (SLAPPs),  women 
journalists). A progress report on the activities of the Task Force was submitted by the Greek 
authorities to the Commission in March 2023. Among the initiatives taken by the Task Force 
are  the  introduction  of  a  course  on  the  Safety  of  Journalists  at  the  Greek  Universities,  the 
creation  of  an  observatory  to  record  events  and  violations  against  journalists,  and  the 

194  Article 25 of Law No. 5005/2022 of 21 December 2022. 
195  Mapping  Media  Freedom,  Greek  parliament  passes  new  media  law  establishing  controversial  Ethics 

Committee, 22 December 2022. 

196  The previous provision stipulated that whoever, publicly or through the internet, creates or distributes in any 
way, fake news that may provoke anxiety or fear in citizens, or shake citizens’ trust in the national economy, 
or public health, is punishable by a prison sentence of at least three months and a  fine. 2022 Rule of Law 
Report, Country Chapter on the rule of law situation in Greece, p. 19. 

197  Article 41 of Law 5005/2022. 
198  Information received from the Journalists’ Union ESIEMTH in the context of the country visit to Greece. 
199  2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 2. 
200  2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 19. 
201  Input from Greece for the 2023 Rule of Law Report, p. 29. 

22 

 
 
                                                           
establishment  of  an  international  training  centre  for  the  safety  of  journalists  and  media 
professionals202. The establishment of the Task Force is evaluated as a positive step, also by 
the  journalists’  union203.  However  more  concrete  steps  are  needed  to  improve  the  working 
environment of journalists, including as regards abusive lawsuits against journalists and their 
safety204.  Therefore,  there  has  been  some  progress  on  the  implementation  of  the 
recommendation made in the 2022 Rule of Law Report.  

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Greece is a parliamentary democracy with a unicameral Parliament. The separation of powers 
is  enshrined  in  the  Constitution  with  legislative  power  vested  in  the  Parliament  and  the 
President. The right to introduce legislation belongs to the Parliament and the Government205. 
All courts, irrespective of their position in the judicial hierarchy, have the right and the duty to 
review the constitutionality of laws. They are bound not to apply a law whose content they 
deem contrary to the Constitution206. A number of independent authorities and bodies aim to 
protect  and  safeguard  human  rights,  including  the  Greek  Ombudsperson  and  the  Greek 
National  Commission  for  Human  Rights,  which  is  accredited  with  A  status  by  the  Global 
Alliance of Human Rights Institutions207.  

Remaining challenges lessen the efforts improving the quality of the legislative process in 
practice, particularly regarding the consultation of stakeholders.  Law 4622/2019 on the 
Executive State introduced reforms in the law-making procedures, based on better regulation 
principles, and strengthened the institutional framework208. There is progress in the intensive 
programme on codification of legislation209. In 2022, for the first time since 2009, Parliament 
did  not  use  the  expedited  legislative  procedures210.  Omnibus  laws  used  for  the  adoption  of 
disparate  provisions  stemming  from  the  same  Ministry,  including  amendments  to  existing 
provisions, create legal uncertainty to both citizens and businesses as they cannot always detect 

202  In January 2023, the establishment of the training centre in Thessaloniki under the scientific responsibility of 
the Peace Journalism Laboratory of the Department of Journalism and Media of the Aristotle University of 
Thessaloniki  was  decided.  For  this  purpose,  a  Memorandum  of  Cooperation  was  signed  by  all  interested 
parties. The 1st training session took place in April 2023 by ESIEMTH  The 2nd session took place in May 
2023.    (Task  Force  on  Ensuring  the  Protection,  Safety  and  Empowerment  of  Journalists  and  other  Media 
Professionals and Other Initiatives Progress Report, March 2023). 

203  Information received by Journalists’ Union ESIEMTH in the context of the country visit to Greece. 
204 Such as the new adopted Collective Employment Agreement on the working conditions of journalists employed 

in the public sector, put in force from January 1, 2022 until 31 December, 2023. 

205  Constitution of Greece, Article 26. 2021, 2022 Rule Reports, Country Chapter on the rule of law situation in 

Greece, p. 11 and 19 respectively. 

206  Constitution of Greece, Article 93, para. 4. 
207  Chart of the status of national institutions – Accreditation status as of 27 April 2022. 
208  The  General  Secretariat  of  Legal  and  Parliamentary  Affairs  has  an  active  role  in  the  legislative  process, 
including on issuing guidance. An interdisciplinary body, the Committee for the Evaluation of the Quality of 
the Law-making Process carries out quality control of each draft law against the law-making principles as well 
as the constitutionality of draft legislative provisions. A Central Codification Committee has been established 
to coordinate  the legal codification and to develop an annual codification plan (2021 Rule of Law Report, 
Country Chapter on the rule of law situation in Greece, p. 11). 

209  The Central Codification Committee has concluded the codification of fourteen codes. Codes of individual 
and  collective  labor  law;  of  cultural  property;  of  island  policy;  of  maritime  transportation;  of  funding  of 
political parties; of illegal migration; of administrative procedures of Hellenic Police;  ; of police discipline 
regulations; of mental health; of collection of public revenues; of tax procedures; of tourism legislation; of 
military personnel regulations..  

210  2022 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 20. 

23 

 
 
                                                           
the applicable law for a given regulatory subject211. The Government considers the practice to 
be a solution  to  reduce the high number of parliamentary  amendments212. According to the 
Government,  contrary  to  amendments,  such  bills  follow  the  normal  steps  of  the  legislative 
procedures,  in  particular  public  consultation,  and  full  parliamentary  debate,  thus  further 
enhancing the quality of law-making213. Civil society organisations point out that omnibus bills 
are used too  often and frequently cover unrelated issues within the competence of different 
ministries,  reducing  legal  certainty214.  The  Government  considers  that  the  practice  of  last-
minute amendments to draft bills has almost ceased in 2022. This is not, however, the view 
shared by civil society organisations, which consider the figure closer to 50% of all introduced 
amendments215.  According  to  the  OECD,  better  implementation  of  the  legal  requirements, 
including in the area of stakeholder engagement, are advisable216. Draft bills are consistently 
subject to public consultation217 and follow-up reports on the results of consultations address 
the comments submitted218. The National Commission for Human Rights notes that proposals 
by interested parties are often taken into consideration resulting in the amendment or repeal of 
relevant draft provisions219. However, the concerns already expressed by stakeholders in the 
previous Rule of Law Reports as to the insufficient time for public consultation persist220. In 
some  instances,  reduced  time  for  public  consultation  means  less  than  a  week,  including 
weekends and public holidays and may also concern legislation of increased public interest221. 

211  An omnibus bill is a law that seeks to regulate a number of often unrelated matters affecting different areas. 
The  practice  of  omnibus  laws  has  been  often  criticised  as  being  contrary  to  Article  74  para.  5  of  the 
Constitution, which provides that a draft law containing provisions not related to its main subject matter shall 
not be introduced for debate (see Dianeosis, Sotiropoulos, Christopoulos (2017) Polynomia and Kakonomia 
in Greece, p.80; Hellenic Parliament (2017), Conference on Good legislation as a necessary condition for the 
proper and efficient functioning of the State).     

212  According  to  the  Government,  in  2022,  the  total  number  of  amendments  to  draft  bills  approved  by  the 
Government  was  quite  significantly  reduced  to  165  (compared  to  222  in  2020  and  227 in  2022),  partially 
thanks to the introduction of omnibus laws. 

213  Input from Greece for the 2023 Rule of Law Report. 
214  According  to  Vouliwatch,  in  2022,  a  total  of  42  omnibus  bills  (32%  of  the  total  bills)  were  submitted  to 
Parliament. Rule of Law Backsliding Continues in Greece, Joint Civil Society Submission to the European 
Commission on the Rule of Law Report, p. 20-21. 

215  A different interpretation of what constitutes last-minute amendment could explain the discrepancy in these 
estimates.  Article  87  para  of  the  Standing  Orders  of  the  Hellenic  Parliament  provides  that  additions  or 
amendments are introduced at least three days before the start of the debate in the Plenary. However, as the 
Secretariat General of Legal and Parliamentary Affairs explained in the context of the country visit to Greece, 
if the debate in the Plenary starts in less than 3 days after the end of the discussions in the competent standing 
parliamentary  committee,  amendments  submitted  during  that  period  are  not  considered  last-minute 
amendments. 

216  OECD (2023), Indicators of Regulatory Policy and Governance, Europe 2022-Greece.  
217 Law 4622/2019 on the Executive State, Article 61. The ordinary law-making process requires, as a mandatory 
step, that a public consultation has taken place on the provisions of the proposed bill prior to its submission to 
Parliament. The main tool for public consultation is an online platform. 

218  Hellenic Parliament, Standing Orders, Article 85 para 3 (c). 
219  National Commission for Human Rights, Impact of 2022 ENNHRI rule of law reporting, p. 27. 
220  According to data from the opengov.gr, between July 2022 and June 2023, 62 public consultations were carried 
out, out of which 32 were open for the ordinary two weeks’ time limit; 25 for a shorter period (on average 
between 7 to 10 days, while in some cases for even shorter periods); and 5 were open for a longer period of 
time three to four weeks).  Article 61 paras 2 and 3 of Law  4622/2019 on the Executive State stipulate that 
consultation lasts two weeks but can be reduced to one week for duly justified reasons, which are mentioned 
in  the  report  on  the  public  consultation.  The  invitation  to  public  consultations  published  on  the  dedicated 
website does not include information on the reasons for reducing the duration of a given consultation. See 
also, 2021, 2022 Rule of Law Reports, Country Chapter on the rule of law situation in Greece, p. 11 and p. 19. 
221  The consultation on the draft bill on the Code on Migration lasted one week, an issue that was highlighted by 
both CSOs, the Ombudsman and the National Commission for Human Rights during the country visit.  

24 

 
                                                           
Furthermore,  both  the  Ombudsperson  and  the  National  Commission  for  Human  Rights 
expressed their regret that they are not always consulted in respect to draft legislation that falls 
within their area of competences, although the Guide on drafting of impact assessment reports 
foresees their prior opinion222. They often provide comments on their own initiative223. The 
quality  of  law-making  and  frequent  changes  in  legislation  remains  a  significant  reason  for 
concern about the effectiveness of investment protection among companies in Greece (53%, 
same percentage as in 2022)224. 

The Ombudsperson and the National Commission for Human Rights have an active role 
in the system of checks and balances. Despite the high number of complaints received225, the 
Ombudsperson  considers  the  overall  compliance  rate  of  the  administration  with  his 
recommendations satisfactory, notwithstanding an increase in the cases of refusal to comply 
with  recommendations  in  relation  to  previous  years226.  Given  its  broad  mandate227,  the 
Ombudsperson  conducts  investigations  and  publishes  several  special  reports  focusing  on 
specific  areas  of  interest  or  vulnerable  social  groups.  To  achieve  better  accessibility  and 
visibility, the Ombudsperson inaugurated a regional office in Thessaloniki228. Following the 
revision  of  its  regulatory  framework,  the  National  Commission  for  Human  Rights  enjoys 
functional independence, and administrative and financial autonomy229. In 2022, its mandate 
was  strengthened,  and  its  administrative  capacity  was  reinforced  230.  In  January  2023,  the 
National  Commission  for Human Rights  presented the first  interim report  of the Recording 
Mechanism  of  Informal  Forced  Returns231.  The  mechanism’s  existence  is  a  positive 

222  The  Guide  on  drafting  of  impact  assessment  reports  issued  by  the  Secretariat  General  for  Legal  and 
Parliamentary Affairs provides that conducting a comprehensive impact assessment presupposes seeking the 
prior opinion of certain authorities on legislative provisions within their competence; the National Commission 
for Human Rights is expressly mentioned therein. 

223  See, for instance, National Commission for Human Rights, Note on a draft law including provisions relating 
to conscientious objectors, January 2023; Note on the draft law Waiving of communication privacy, cyber 
security and citizens’ data protection, December 2022; Note on the Draft law on the reform of the Penitentiary 
Code, October 2022.  

224  Figure 54, 2023 EU Justice Scoreboard. 
225  In  2022,  the  Ombudsperson  received  17  035  complaints;  75%  of  these  complaints  were  within  the 
Ombudsman’s mandate, out of which 70% led to a finding of maladministration. Greek Ombudsperson (2023), 
Annual report 2022. 

226  Out of the cases, in which the Ombudsman found an instance of maladministration: 62% were resolved by the 
administration (83% in 2021); 14% were resolved thanks to complainants’ initiatives (2% in 2021); in 13% 
the administration refused to comply (7% in 2021); and in 11% compliance was not possible due to legislative 
gaps or organisational malfunctions (8% in 2021). Greek Ombudsperson (2023), Annual report 2022.  

227  The Ombudsperson has the task of mediating between citizens and public services, local authorities and bodies 
governed  by  public  law  to  protect  civil  rights,  combat  maladministration  and  ensure  compliance  with  due 
process. 2020 Rule of Law Report, Country Chapter Greece on the rule of law situation in Greece, p. 11.  
228  The program ‘Good Governance, Institutions and Transparency’, financed by the European Economic Area 
Financial Mechanism, includes measures reinforcing the Ombudsperson’s Office, in cooperation with the EU 
Agency  for  Fundamental  Rights.  See  also  2022  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law 
situation in Greece, p. 21. 

229  The  National  Commission  for Human  Rights  was established in 1998 as an independent advisory body in 
accordance  with  the  UN  Paris  Principles  (UN  General  Assembly  Resolution  48/134,  20.12.1993).  Law 
4780/2021 amended its founding legislation. 

230  The  National  Commission  for  Human  Rights  became  voting  member  of  the  monitoring  committee  on  EU 
Migration Funds. It has also been entrusted with the monitoring of the compliance of EU development funds 
with the provisions of the EU Charter of Fundamental Rights. National Commission for Human Rights, Impact 
of 2022 ENNHRI rule of law reporting, p. 20. 

231  In  September  2021,  the  National  Commission  for  Human  Rights  decided  to  establish  the  Recording 
Mechanism, given: a) the absence of an official and effective data collection mechanism of informal forced 
returns; and b) the need for coordination among organizations who record on their own initiative any alleged 

25 

 
                                                           
development  aiming  to  boost  accountability  for  reported  human  rights  violations  alleged  to 
have occurred during informal forced returns of third country nationals from Greece to other 
countries.  

The  issue  of  surveillance  by  means  of  wiretapping  (i.e.,  through  telecommunication 
providers) and spyware, has been subject to investigations by judicial and independent 
authorities. Following allegations and complaints or applications for information related to 
wiretapping and the use of Pegasus spyware against politicians, journalists, and high-ranking 
army  officers,  both  the  Authority  for  the  protection  of  confidentiality  of  communications 
(ADAE)232 and the Data Protection Authority (DPA)233 initiated investigations. Both ADAE 
and the DPA234 continue their investigations into the matter and have referred their findings to 
the judicial authorities235. The judicial authorities have launched investigations after reports by 
persons allegedly affected. These investigations are still ongoing. A new law amended the rules 
on wiretapping for the fight against crime and the protection of national security, including the 
applicable  procedures  for  lifting  confidentiality  of  communications  and  informing  the 
individuals  subject  to  the  lifting,  modified  the  structure  and  operation  of  the  National 
Intelligence  Service  and  amended  the  criminal  code  to  include  the  development,  selling, 
possession and use of surveillance software within the scope of application of crimes relating 
to the breach of privacy of communications236. The law has been subject to criticism from the 
bar associations, academic circles, and independent authorities, including on the information 
provided  to  the  individuals  subject  to  surveillance  for  national  security  purposes237  and  the 
restriction of the powers of ADAE238. The new law also refers to the use of spyware by public 

incidents of informal forced returns from persons who recourse to their services, National Commission for 
Human Rights, Impact of 2022 ENNHRI rule of law reporting, p. 30. 

232  The Authority for the protection of confidentiality of communications (ADAE) has been established according 
to  article  19  para  2  of  the  Constitution  with  the  purpose  of  protecting  the  free  correspondence  or 
communication in any possible way. Its founding law is Law 3115/2003. 

233  The  Data  Protection  Authority  is  a  constitutionally  established  independent  authority  (Greek  Constitution, 
article 9A), which has as its mission the supervision of the rules concerning the protection of the individual 
from the processing of personal data. 

234  In  January  2023,  the  Opinion  of  the  General  Prosecutor  of  the  Supreme  Court  (Opinion  1/2023  on  the 
interpretation of Law 5002/2022) and the reaction of the President of ADAE (Press release on the Opinion 
1/2023, 10 January 2023) generated an intense debate between law professors, judges and legal practitioners 
regarding  the  role  of  ADAE,  the  competences  of  the  Public  Prosecutor  and  the  constitutionality  of  Law 
5002/2022. See, Association of Greek prosecutors, Press release of 17 January 2023; Athens Bar Association, 
Decision of the Board, 12 January 2023; Thessaloniki Bar Association, Resolution of 14 January 2023; Piraeus 
Bar Association, Decision of the Board, 13 January 2023, Statement of 16 Professors of constitutional law, 
Kathimerini, 12 January 2023. 

235  Information  provided  by  the  presidents  of  ADAE  and  DPA  during  the  public  hearing  of  the  European 
Parliament Committee of inquiry to investigate the use of the Pegasus and equivalent surveillance spyware, 
28 February 2023. 

236  Law 5002/2022 Waiving of communication privacy, cyber security and citizens’ data protection. 
237  Criticism mostly focused on Article 4 para 7 of Law 5002/2022. The provision stipulates that: (i) individuals 
under surveillance for national security purposes are informed upon request after three years from the time the 
measure  has  ceased  to  apply;  and  (ii)  the  decision  to  inform  the  individual  is  taken  by  a  three  members 
committee consisting of the president of ADAE and two prosecutors who previously approved the measure. 
238  Authority  for  the  protection  of  confidentiality  of  communications,  Observations  on  the  Draft  Law  for  the 
communications privacy, cybersecurity and the protection of citizens’ personal data, November 2022; Data 
Protection Authority, Opinion 5/2022 on the Draft Law for the communications privacy, cybersecurity and the 
protection of citizens’ personal data, November 2022; National Commission for Human Rights, Note on the 
Draft  Law  for  the  communications  privacy,  cybersecurity  and  the  protection  of  citizens’  personal  data, 
December 2022; Athens Bar Association, Decision of the Board, 12 January 2023. 

26 

 
                                                           
authorities for the performance of their tasks, it, however, requires a Decree setting out  the 
conditions of use. The Decree has not yet been adopted.  

On 1 January 2023, Greece had 27 leading judgments of the European Court of Human 
Rights pending implementation, a decrease of seven compared to the previous year239. At 
that time, Greece’s rate of leading judgments from the past 10 years that remained pending was 
at 34% (compared to 35% in 2022) and the average time that the judgments had been pending 
implementation  was 6  years 7 months (compared to  6  years and 5 months in  2022)240. The 
oldest leading judgment241, pending implementation for 18 years, concerns the access to and 
the efficient functioning of justice due to the lack and the delayed enforcement of domestic 
judicial  decisions242.  On  15  June  2023,  the  number  of  leading  judgments  pending 
implementation has increased to 28243. 

An initial step has been taken towards amending the regulatory framework governing 
the registration requirements for civil society organisations. The 2022 Rule of Law Report 
recommended to Greece to ‘ensure that registration requirements for civil society organisations 
are proportionate in view of maintaining an open framework for them to operate’244. There are 
currently  nine  different  registries245,  and  their  parallel  existence  remains  an  issue246.  The 
planned  operation  of  a  public  database  and  the  new  central  registry  for  civil  society 
organisations  (CSOs)  under  the  responsibility  of  the  Ministry  of  Interior247  is  a  positive 

239 The  adoption  of  necessary  execution  measures  for  a judgment  by  the  European  Court  of  Human  Rights  is 
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group 
cases against a State requiring similar execution measures, particularly general measures, and examine them 
jointly. The first case in the group is designated as the leading case as regards the supervision of the general 
measures and repetitive cases within the group can be closed when it is assessed that all possible individual 
measures needed to provide redress to the applicant have been taken.  

240 All figures are calculated by the European Implementation Network and are based on the number of cases that 
are considered pending at the annual cut-off date of 1 January 2023. See the Contribution from the European 
Implementation Network for the 2023 Rule of Law Report, p. 4. 

241  Judgment of the European Court of Human Rights of 27 March 2003, Satka and Others v. Greece, 55828/00, 

pending implementation since 2003.  

242  Article 95 para 5 of the Constitution contains a provision on the obligation of the public administration to 
comply with judicial decisions. Greece adopted Law 3068/2002, which provides a special procedure to ensure 
the  execution  of  domestic  judicial  decisions,  following  a  number  of  judgments  of  the  European  Court  of 
Human Rights finding violations of the right to a fair trial (judgment of 19 March 1997, Hornsby v. Greece, 
18357/91; Council of Europe, Committee of Ministers Resolution ResDH(2004)81). 

243  Data according to the online database of the Council of Europe (HUDOC). 
244  2022 Rule of Law Reports, Country Chapter on the rule of law situation in Greece, p. 13. 
245  Written contribution from the Ministry of Interior in the context of the country visit. 
246  The Greek Financial Intelligence Unit identified the parallel existence of multiple registries and the absence 
of  a  common  regulatory  framework  for  CSOs  as  a  weakness  of  the  current  system  that  could  result  in 
facilitating  the  commitment  of  financial  crimes.  Anti-Money  Laundering  Authority,  Unit  A,  Abusive 
Exploitation of Non-Governmental Organisations, May 2023.   

247  Law 4873/2021, Protection of volunteerism, strengthening civil society, tax incentives to strengthen public 
benefit activities and other provisions.  The Registry, which is expected to become fully operational within the 
third quarter of 2023, provides for two main categories based on the amounts of funding. The first category 
concerns funding up to EUR 50 000 and the second category funding over EUR 50 000. For the first category, 
the registration requirements are simpler, whereas in the second additional documents are requested. The CSOs 
registered  in  the  second  category  get  immediate  support  by  targeted  tax  exemptions  and  additional  tax 
incentives. CSOs are not compelled to register, but only registered organisations will be able to request state 
funding  and  benefit  from  tax  exemptions.  The  registration  needs  to  be  renewed  annually  and  is  subject  to 
certain conditions and administrative requirements, including the payment of a registration fee.  The details 
regarding its functioning are set out in secondary legislation, adopted in April 2023 (KYA 6216/2013). Written 
contribution from the Ministry of Interior in the context of the country visit. 

27 

 
                                                           
development  aiming  to  strengthen  transparency  and  protect  public  funds.  In  June  2023,  the 
Government  commissioned  a  study  for  the  simplification  and  digitalisation  of  the 
administrative procedures relating to the functioning of the public database and the new central 
registry  for  CSOs  and  their  interoperability  with  other  existing  public  registries248.  CSOs 
dealing with international protection, migration and social integration are concerned by the fact 
that  they  have  to  register  in  the  Registry  of  Greek  and  Foreign  Non-Governmental 
Organisations  as  well  as  to  register  their  members  in  the  Registry  of  NGO  Members249. 
According  to  the  Government,  all  CSOs  that  are  actively  working  in  the  structures  of  the 
Ministry  of  Migration  and  Asylum,  or  in  the  structures  funded  by  EU  programmes  are 
registered in the Registry250 and can therefore access refugees’ reception facilities and receive 
state funding.  In relation to delays in the process, the time-limit to process applications has 
improved  dropping  from  120  to  60  days  on  average251.  The  Council  of  State  has  not  yet 
delivered its ruling on the pending judicial review of applications challenging some aspects of 
the legality of the legislation252. Concerns have been raised in relation to the implementation 
of  the  regulatory  framework,  including  in  relation  to  the  registration  process253.  While  the 
commissioning of the study on the simplification of the procedures is a positive first step, more 
concrete steps are needed to evaluate the current system, including by initiating a structured 
dialogue with CSOs, and reflect on the need to amend it. There has been thus some progress 
on the implementation of the recommendation made in the 2022 Rule of Law Report.  

248  Contract  55/2023  was  signed  in  the  framework  of  the  National  Program  for  the  Simplification  of 
Administrative Procedures (EPAD). The study is expected to be delivered within 3 months after signature. 
249 Joint Ministerial Decision 10616/2020 (Law 4662/2020, further amended by Law 4686/2020; 2020, 2021 and 
2022 Rule of Law Reports, Country Chapter Greece, pp. 22, 12 and 12, respectively. Registration is necessary 
for all members of CSOs who need to come in contact with refugees and migrants, especially women, children 
and  unaccompanied  minors,  particularly  for  those  who  have  free  access  and  are  active  in  accommodation 
facilities.  

250 According to data from the Ministry of Migration and Asylum, between September 2020 and March 2023, 82 
CSOs have been registered in the Registry of the Ministry of Migration and Asylum and 11 applications have 
been pending for evaluation. 42 CSOs are actually active in the field of migration, their number being close to 
50% of the number of those registered in the Registry, while the rest of  them are either not particularly active 
or they focus on other social groups or they are registered for possible future activities. Written contribution 
from the Ministry of Migration and Asylum in the context of the country visit in Greece.  

251  Information received from Ministry of Migration and Asylum in the context of the country visit to Greece. 
252 On 2 December 2022, the hearing of the three appeals challenging some aspects of the legality of the law on 
the registration of NGOs active in the area of asylum, migration and social inclusion (2022 Rule of Law Report, 
Country  Chapter  Greece,  p.  21)  took  place  before  the  Plenary  of  the  Council  of  State.  The  decisions  are 
pending.   

253  Including in relation to a perceived lack of clarity and foreseeability of the registration process. See, 2022, 
2021  Rule  of  Law  Reports,  Country  Chapter  on  the  rule  of  law  situation  in  Greece,  p.  13  and  pp.  21-22 
respectively; Expert Council on NGO Law of the Conference of INGOs (2020), Opinion on the compatibility 
with European standards of recent and planned amendments to the Greek legislation on NGO  registration; 
Commissioner for Human rights, Council of Europe, Letter to Minister for Citizens’ Protection of Greece, 
Minister of Migration and Asylum of Greece and Minister of Shipping and Island Policy of Greece, urging 
Greek  authorities  to  put  an  end  to  pushback  operations  and  to  ensure  that  independent  and  effective 
investigations are carried out into all allegations of pushbacks, 3 May 2021, CommHR/DM/sf 019-2021; UN 
Special  Rapporteur  on  freedom  of  assembly  and  association,  UN  Special  Rapporteur  on  human  rights 
defenders and UN Special Rapporteur on the  human rights of migrants, OL GRC 1/2021, 31 March 2021. 
Report of the Special UN Rapporteur on the situation of human rights defenders, Mary Lawlor - Visit to Greece 
(A/HRC/52/29/Add.1)  2  March  2023,  point  52.  The  Special  Rapporteur  on  the  situation  of  human  rights 
defenders was first established by the UN Human Rights Commission in 2000. The mandate was most recently 
renewed by the Human Rights Council in 2020 with decision 43/115 and resolution 43/16. 

28 

 
                                                           
The situation of civil society raises concerns, in particular in relation to CSOs working in 
specific  areas.  The  civic  space  has  been  downgraded  from  narrowed  to  obstructed  due  to 
concerns in relation to civil society organisations working with refugees and asylum seekers, 
and failure to tackle the protection of journalists254. According to the Special UN Rapporteur 
on the situation of human rights defenders, while in other areas there is a generally favourable 
environment for civil society, human rights defenders working in the area of migration have 
been subjected to smear campaigns, threats and attacks and the misuse of criminal law against 
them255. Concerns have been reported in relation to the legislation on assembly256, including 
the liability of organisers for any damages incurred during protests257. The Council of Europe 
Commissioner for Human Rights referred to the hostile environment in which human rights 
defenders work in Greece and urged the authorities to ensure that human rights defenders and 
journalists can work safely and freely, by providing an enabling environment for their work 
and publicly recognising their important role in a democratic society258.  

254  Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressed 

and closed. Civicus (2023), Monitor tracking civic space-Greece. 

255  Report of the Special Rapporteur on the situation of human rights defenders, Mary Lawlor - Visit to Greece 

(A/HRC/52/29/Add.1) 2 March 2023. 
256  Public outdoor assemblies, Law 4703/2020. 
257  Organizers of gatherings are required to notify the local law enforcement authorities of the time, place and 
route to be followed prior to the gathering. They must also provide their identification and contact details and 
must cooperate with the authorities in maintaining peace and order. Report of the Special Rapporteur on the 
situation  of  human  rights  defenders,  Mary  Lawlor  -  Visit  to  Greece (A/HRC/52/29/Add.1)  2  March  2023, 
points 54-58; Franet, Centre for European Constitutional Law (2022), Country research - Legal environment 
and space of civil society organisations in supporting fundamental rights – Greece, Vienna, EU Agency for 
Fundamental Rights.  

258 Council of Europe: Commissioner for Human rights, Statement on the need to reverse the trend undermining 
the  work  of  human  rights  defenders  and  journalists  in  Greece,  published  on  12  January  2023.See  also 
contributions from the Border Violence Monitoring Network and Human Rights Watch for the 2023 Rule of 
Law Report, p. 20 and p. 21 respectively. 

29 

 
                                                           
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2023 Rule of Law report 
can 
https://commission.europa.eu/publications/2023-rule-law-report-targeted-
stakeholder-consultation_en. 

found 

be 

at 

Association of European Administrative Judges (2023), Contribution from the Association of European 
Administrative Judges for the 2023 Rule of Law Report. 

Association of Greek prosecutors (2023), Press release of 17 January 2023.  

Athens Bar Association (2023), Decision of the Board of 12 January 2023. 

Authority for the protection of confidentiality of communications (2022),  Observations on the Draft 
Law for the communications privacy, cybersecurity and the protection of citizens’ personal data. 

Authority for the protection of confidentiality of communications (2023), Press release of 10 January 
2023 on the Opinion 1/2023.  

Border  Violence  Monitoring  Network  (2023),  Contribution  from  the  Border  Violence  Monitoring 
Network for the 2023 Rule of Law Report. 

CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States. 

Civicus (2023), Monitor tracking civic space-Greece https://monitor.civicus.org/country/greece/.  

Council of Bars and Law Societies of Europe (CCBE) (2023), Contribution from the Council of Bars 
and Law Societies of Europe for the 2023 Rule of Law Report. 

Council of Europe: Commissioner for Human rights (2021), Letter to Minister for Citizens’ Protection 
of Greece, Minister of Migration and Asylum of Greece and Minister of Shipping and Island Policy of 
Greece of 3 May 2021, CommHR/DM/sf 019-2021. 

Council of Europe: Commissioner for Human rights (2022), Report, Human Rights Defenders in the 
Council of Europe area in times of crises, Roundtable, Dublin 24-25 October 2022. 

Council  of  Europe:  Commissioner  for  Human  rights  (2023),  Statement  of  12  January  2023, 
https://www.coe.int/en/web/commissioner/-/greek-authorities-should-reverse-the-trend-undermining-
the-work-of-human-rights-defenders-and-journalists  

Council  of  Europe:  Committee  of  Ministers  (2010),  Recommendation  CM/Rec(2010)12  of  the 
Committee of Ministers to member states on judges: independence, efficiency and responsibilities. 

Council  of  Europe:  Committee  of  Ministers  (2004),  Resolution  ResDH(2004)81  concerning  the 
judgments  of  the  European  Court  of  Human  Rights  relating  to  non-execution  of  domestic  judicial 
decisions in Greece. 

Council of Europe: Committee of Ministers (2021),  The efficiency and the effectiveness of legal aid 
schemes in the areas of civil and administrative law, Guidelines and explanatory memorandum. 

Council of Europe, Platform to promote the protection of journalism and safety of journalists, Greece, 
https://fom.coe.int/en/pays/detail/11709522. 

Council of State (2023), Written contribution from the Council of State for the 2023 Rule of Law Report 
in the context of the country visit. 

Council of the European Union (2021), Council Implementing Decision of 13 July 2021 on the approval 
for  Greece  with  Annex, 
of 
https://data.consilium.europa.eu/doc/document/ST-10152-2021-ADD-1/en/pdf. 

the  assessment  of 

resilience  plan 

recovery  and 

the 

Court of Audit (2022), 25th General Assembly of the Plenary of the Court of Audit. 

Court of Audit (2023), Written contribution from the Court of Audit for the 2023 Rule of Law Report in 
the context of the country visit. 

30 

 
Data Protection Authority (2022), Opinion 5/2022 on the Draft Law for the communications privacy, 
cybersecurity and the protection of citizens’ personal data. 

Directive (EU) 2019/1973 of the European Parliament and of the Council, of 23 October 2019 on the 
protection of persons reporting on breaches of Union law, OJ L 305. 

Directorate-General for Communication (2023), Special Eurobarometer 534 on Corruption. 

Directorate-General  for  Communication  (2023),  Flash  Eurobarometer  524  on  Businesses’  attitudes 
towards corruption in the EU –.  

European  Centre  for  Press  and  Media  Freedom,  MFRR  partners  welcome  first  arrests  over  2021 
assassination of journalist Giorgos Karaivaz. 

European Civic Forum (2022), Contribution from the European Civic Forum for the 2023 Rule of Law 
Report.  

European Civic Forum (2023), Greece, Civic Space Report 2023. 

European Commission (2023), EU Justice Scoreboard.  

European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation 
in Greece. 

European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation 
in Greece. 

European Commission (2022), 2021 Rule of Law Report, Country Chapter on the rule of law situation 
in Greece. 

European Court of Human Rights, judgment of 19 March 1997, Hornsby v. Greece, 18357/91. 

European Court of Human Rights, judgment of 27 March 2003, Satka and Others v. Greece, 55828/00.  

European Implementation Network (2023), Contribution from the European Implementation Network 
for the 2023 Rule of Law Report. 

European Network of National Human Rights Institutions (2023), Greece, Greek National Commission 
for Human Rights, Impact of 2022 ENNHRI rule of law reporting. 

European Parliament, Policy Department for Citizens’ Rights and Constitutional Affairs (2023),  The 
situation of Article 2 TEU values in Greece. 

European 
https://europa.eu/eurobarometer/surveys/detail/2832. 

Parliament’s 

Flash 

Eurobarometer:  News  &  Media 

Survey 

2022, 

European Public Prosecutor’s Office (2023), Annual Report 2022.  

European Public Prosecutor’s Office (2023), Input to the 2023 Rule of Law Report.  

EU Agency for Fundamental Rights (2023), Country research – An update on developments regarding 
civic  space  in  the  EU  and  an  overview  of  the  possibilities  for  human  rights  defenders  to  enter  EU 
territory– Greece.  

Expert Council on NGO Law of the Conference on INGOs of the Council of Europe (2020), Opinion 
on  the  compatibility  with  European  standards  of  recent  and  planned  amendments  to  the  Greek 
legislation  on  NGO  registration,  https://rm.coe.int/expert-council-conf-exp-2020-4-opinion-ngo-
registration-greece/16809ee91d 

Expert Council on NGO Law, Addendum to the opinion on the compatibility with European standards 
of  recent  and  planned  amendments 
legislation  on  NGO  registration, 
https://rm.coe.int/expert-council-conf-exp-2020-5-addendum-to-the-opinion-on-the-
compatib/1680a076f2 

the  Greek 

to 

Financial Crime Prosecutor (2023), Written contribution from the Financial Crime Prosecutor for the 
2023 Rule of Law Report in the context of the country visit. 

31 

 
First instance court of Athens, decision no. 427/2022. 

Franet, Centre for European Constitutional Law in cooperation with Hellenic League for Human Rights 
and  Antigone-Information  and  Documentation  Centre  on  racism,  ecology,  peace  and  non-violence 
(2023), Country research - Legal environment and space of civil society organisations in supporting 
Fundamental  Rights 
fundamental 
https://fra.europa.eu/en/country-data/2023/civic-space-report-2023 

–  Greece,  Vienna, 

EU  Agency 

rights 

for 

General  Prosecutor  of  the  Supreme  Court  (2023),  Opinion  1/2023  on  the  interpretation  of  Law 
5002/2022. 

Greek Government (2023), Input from Greece for the 2023 Rule of Law Report. 

Greek Ombudsman (2022), Annual report 2022.  

GRECO  (2020),  Fourth  Evaluation  Round  –  Second  Compliance  Report  on  Greece  on  preventing 
corruption in respect of members of parliament, judges and prosecutors. 

GRECO (2022), Fifth Evaluation Round – Evaluation Report on Greece on preventing corruption and 
promoting integrity in central governments (top executive functions) and law enforcement agencies. 

Hellenic  Internal  Affairs  Unit  of  Law  Enforcement  Agencies  (2023),  Written  contribution  from  the 
Hellenic Internal Affairs Unit of Law Enforcement Agencies for the 2023 Rule of Law Report in the 
context of the country visit. 

Hellenic Parliament (2023), Audit Committee, Annual Report 2022.  

Hellenic Police (2023), Written contribution from the Hellenic Police for the 2023 Rule of Law Report 
in the context of the country visit. 

Human Rights Watch (2023), Contribution from the Human Rights Watch for the 2023 Rule of Law 
Report. Ministry of Interior (2023), Written contribution from the Ministry of Interior for the 2023 Rule 
of Law Report in the context of the country visit. 

constitutional 
Kathimerini 
https://www.kathimerini.gr/politics/562224004/dilosi-16-kathigiton-syntagmatikoy-dikaioy/. 

Professors 

Statement 

(2023), 

16 

of 

of 

law, 

. 

Media Pluralism Monitor 2023, country report for Greece. 

Media Freedom Rapid Response, Greece, MFRR alarmed by latest revelations of spying on journalists, 
20 December 2022. 

Ministry of Justice (2023), Written contribution from the Ministry of Justice for the 2023 Rule of Law 
Report in the context of the country visit. 

Ministry of Migration and Asylum (2023), Written contribution from the Ministry of  Migration and 
Asylum for the 2023 Rule of Law Report in the context of the country visit. 

National Commission for Human Rights (2022), Note on a draft law on the reform of the Penitentiary 
Code. 

National  Commission  for  Human  Rights  (2022),  Note  on  a  draft  law  ‘Waiving  of  communication 
privacy, cyber security and citizens’ data protection’. 

National Commission for Human Rights (2023), Note on a draft law including provisions relating to 
conscientious objectors. 

National School of Judges, Written contribution from the National School of Judges for the 2023 Rule 
of Law Report in the context of the country visit. 

National  Transparency  Authority  (2023),  Written  contribution  from  the  National  Transparency 
Authority for the 2023 Rule of Law Report in the context of the country visit.  

32 

 
Thessaloniki Bar Association (2023), Resolution of 14 January 2023. 

Transparency 
International 
https://www.transparency.org/en/cpi/2022/index/grc.  

(2023), 

Corruption 

Perceptions 

Index 

2022, 

OECD (2022), Implementing the OECD Anti-Bribery Convention, Phase 4 Report for Greece.  

OECD (2023), Indicators of Regulatory Policy and Governance, Europe 2022 for Greece.  

Piraeus Bar Association, Decision of the Board of 13 January 2023. 

Plenary of the Presidents of Bar Associations (2022), decision of 5 November 2022. 

Plenary of the Presidents of Bar Associations (2022), decision of 11 December 2022. 

Plenary of the Presidents of Bar Associations (2023), decision of 28 January 2023. 

Plenary of the Presidents of Bar Associations (2023), decisions of 28 March 2023. 

Reporters without Borders – Greece https://rsf.org/en/index?year 

Vouliwatch  (2022),  ‘Draft 
https://vouliwatch.gr/actions/article/nomosxedio-politiko-xrima.  

law  on  political  money:  a-transparency  and  a-accountability’ 

Vouliwatch, Greek Council for Refugees, Refugee Support Aegean, HIAS Greece, Generation 2.0 for 
Rights, Equality and Diversity, Reporters United (2023), Rule of Law Backsliding Continues in Greece, 
Joint Civil Society Submission to the European Commission on the Rule of Law Report. 

United  Nations  Human  Rights  Regional  Office  for  Europe  (2023),  Contribution  from  the  United 
Nations Human Rights Regional Office for Europe for the 2023 Rule of Law Report. 

UN  Special  Rapporteur  on  the  rights  to  freedom  of  peaceful  assembly  and  of  association,  Special 
Rapporteur on the situation of human rights defenders and Special Rapporteur on the human rights of 
migrants (2021), Letter of 31 March 2021, OL GRC 1/2021. 

United Nations Special Rapporteur on the situation of human rights defenders (2023) - Report of the 
Special  Rapporteur  on  the  situation  of  human  rights  defenders,  Mary  Lawlor  -  Visit  to  Greece 
(A/HRC/52/29/Add.1). 

33 

 
 
 
Annex II: Country visit to Greece 

The Commission services held virtual meetings in March 2023 with: 

  Central Codification Committee 
  Committee for the Evaluation of the Quality of the law-making process 
  Committee of Parliament for the Investigation of Declarations of Assets (CIDA, or 

Internal Affairs Unit of Law Enforcement Bodies, Ministry of Citizen Protection 

Committee 3-A) 
  Council of State 
  Court of Audit 
  Generation 2.0 – for Rights, Equality and Diversity 
  Greek Association of Judges and Prosecutors 
  Greek Bar Associations 
  Greek Council for Refugees  
  Greek National Commission for Human Rights 
  Hellenic Broadcasting Corporation (ERT) 
  Hellenic Federation of Enterprises (SEV) 
  HIAS Greece 
 
  Journalists’ Union of Athens Daily Newspaper (ESIEA) 
  Journalists’ Union of Macedonia and Thrace (ESIEMTH) 
  Ministry of Interior  
  Ministry of Justice 
  Ministry of Migration and Asylum 
  National Audiovisual Regulator 
  National School of Judges 
  National Transparency Authority 
  Ombudsman 
  Prosecutor for Financial Crimes  
  Prosecutor's Office to the Supreme Court 
  Refugee Support Aegean 
  Reporters United  
  Supreme Court 
  Secretariat General of Legal and Parliamentary Affairs, 
  Transparency International Greece 
  Vouliwatch 

* The Commission also met the following organisations in a number of horizontal meetings:  

  ALDA (European Association for Local Democracy) 
  Amnesty International  
  Civil Liberties Union for Europe  
  Civil Society Europe 
  Culture Action Europe  
  European Centre for Press and Media Freedom  
  European Civic Forum  

34 

 
 
ILGA Europe  
International Commission of Jurists 
International Federation for Human Rights (FIDH)  
International Planned Parenthood Federation European Network 
International Press Institute  

  European Federation of Journalists  
  European Partnership for Democracy  
  European Youth Forum  
  Free Press Unlimited 
  Front Line Defenders 
 
 
 
 
 
  JEF Europe  
  Osservatorio Balcani e Caucaso Transeuropa 
  Philea  
  Reporters Without Borders  
  SOLIDAR 
  Transparency International EU 

35