Digitalisation and digital transformation in Greece : implications for persons with disabilities.
Date: 2023-07-27
Institutions: Directorate-General for Employment, Social Affairs and Inclusion
Subjects: Greece, Internet, digital literacy, digital transformation, digitisation, electronic government, facilities for people with disabilities, harmonisation of standards, integration of people with disabilities, mobile phone, public institution, public service, vocational training

Digitalisation and digital 
transformation in Greece 

Implications for persons with disabilities 

June 2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
Directorate-General for Employment, Social Affairs and Inclusion 
Directorate D — Social Rights and Inclusion 
Unit D3 — Disability and Inclusion 

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Digitalisation and digital 
transformation in Greece 

Implications for persons with disabilities 

Eleni Strati 

This report has been developed under Contract VC/2020/0273 with the European 
Commission. 

Directorate-General for Employment, Social Affairs and Inclusion  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
LEGAL NOTICE 

Manuscript completed in June 2021 

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PDF 

ISBN 978-92-76-42561-8 

DOI: 10.2767/634846 

KE-09-21-462-EN-N 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Digitalisation and digital transformation - Greece 

Table of contents 

1 
2 

3 

4 

5 

6 

Executive summary ............................................................................................ 6 
Are government strategies and plans on digitalisation and digital transformation 
disability-inclusive? ............................................................................................ 8 
2.1  Disability inclusion in generic strategies on digitalisation and digital 

transformation ............................................................................................ 8 
2.2  Disability inclusion in focused or sector-specific strategies on digitalisation 
and digital transformation ........................................................................ 10 

Do disability strategies address the potential of and challenges pertaining to 
digitalisation and digital transformation? .......................................................... 12 
3.1  How digitalisation and digital transformation are addressed in the national 
disability strategy ..................................................................................... 12 

3.2  How digitalisation and digital transformation are addressed in specific 

disability-related strategies ...................................................................... 12 
Promoting disability inclusion through funding, education and training ............ 14 
4.1  How funding promotes disability-inclusive digitalisation and digital 

transformation .......................................................................................... 14 

4.2  How disability inclusion is promoted through the education and training of 

digital professionals ................................................................................. 14 

4.3  How digital inclusion and accessibility is addressed in the education and 

training of accessibility and inclusion professionals ................................. 15 

4.4  How digital inclusion is addressed via the training of people with 

disabilities ................................................................................................ 15 

The opportunities and challenges presented by digitalisation and digital 
transformation to the rights of persons with disabilities .................................... 17 
5.1  The most significant opportunities presented by digitalisation and digital 

transformation for persons with disabilities .............................................. 17 

5.2  The most significant challenges faced by persons with disabilities in 

relation to digitalisation and digital transformation ................................... 17 
Conclusions and recommendations ................................................................. 19 
6.1  Conclusions ............................................................................................. 19 
6.2  Recommendations ................................................................................... 19 

5 

 
 
 
 
 
 
 
 
Digitalisation and digital transformation - Greece 

1 

Executive summary 

The Ministry of Digital Governance (2020) reset the agenda for digitalisation and digital 
transformation  of  public  and  private  services,  maintaining  centralized  strategic  and 
operational management of government information and communication systems and 
ICT projects across sectors. The so-called Bible for Digital Transformation 2020-2025 
outlines  numerous  projects  to  be  implemented  in  the  short-term  and  long-term, 
focusing on infrastructure, e-government as well as sectoral development, making use 
of  various  funding  sources  such  as  European  Structural  Funds,  European  research 
funds,  Public  Investment  Funds,  the  Recovery  Fund  as  well  as  loans  and  private 
capital. Some important legislative actions include the recent transposition of the EU 
Directive  2016/2102  on  Digital  Governance  and  2019/1024  on  Electronic 
Communications  in  Greek  legislation,  as  well  as  the  establishment  of  the  National 
Accessibility Authority for monitoring compliance of implemented projects with relevant 
regulatory frameworks.  

Electronic  accessibility  and  digital  inclusion  form  a  distinct  guiding  principle  in  the 
national  strategy  for  digitalisation  and  digital  transformation,  directly  linked  with 
selection and evaluation criteria for funding new projects, as well as informing a strand 
of  horizontal  interventions,  with  emphasis  on  web  accessibility  compliance  of  public 
services,  digital  skills  training  and  disability  related  digital  platforms.  The  Digital 
Strategy  outlines  possible  funding  sources,  including  European  Structural  Funds, 
however at the time of writing this report there was not any information about allocated 
budget across funding streams. Sector specific strategies are embedded and aligned 
with  the  objectives  of  the  Bible  for  Digital  Transformation  of  the  Ministry  of  Digital 
Governance. Strategic priorities under the Ministry of Labour and Social Affairs directly 
address  disability  related  services,  such  as  disability  assessment  and  benefits 
allocation,  connected  social  protection  related  information  systems  and  registries  of 
persons with disabilities. Disability inclusion is not however adequately addressed in 
other sector specific government strategies, such as education, where commitments 
to accessibility and universal design do not instantly materialise in recent legislation 
introducing  science  and  technology  skills  workshops  in  primary  and  secondary 
schools.    

The National Disability Action Plan (2020) reflects actions included in generic national 
digital  strategies  related  to  electronic  accessibility,  in  particularly  those  related  to 
accessible  digital  services  and  digital  transformation  of  social  protection  information 
systems, with emphasis on strengthening disability related data collection systems to 
inform  policymaking.  The  creation  of  accessible  learning  content  addressing  digital 
skills is also prominently linked with education and lifelong learning objectives. There 
are  no  sector  specific  strategies  addressing  disability,  while  there  is  overall  lack  of 
analysis  on  opportunities  and  challenges  informing  the  selected  actions  in  disability 
related  strategic  planning.  It  should  also  be  noted  that  there  is  no  specific  funding 
earmarked for actions outlined in the National Disability Action Plan.  

Up  to  date  evidence  on  the  experiences  of  persons  with  disabilities  with  respect  to 
digitalisation and digital transformation is not available. To an extent this is indicative 
of  low  digital  maturity  in  Greece  is  overall,  and  is  potentially  linked  to  low  levels  of 
internet use and digital skills for persons with disabilities. The Concluding Observations 
of the UN Committee on the Rights of Persons with Disabilities to the initial report of 
Greece (2019) importantly emphasizes the potential of information and communication 

6 

 
 
 
 
 
Digitalisation and digital transformation - Greece 

technology in ensuring accessible and inclusive educational environments, which are 
currently lacking.     

Good practices  

The establishment of the National Accessibility Authority with the active involvement of 
representative  bodies  of  persons  with  disabilities  stands  out  as  good  practice  in 
ensuring independent monitoring and compliance with relevant regulatory frameworks. 
This  may  include  for  instance  ensuring  that  accessibility  standards  are  fulfilled  in 
relevant  funded projects,  but also  in  the provision  of mainstream  ICT  related  goods 
and services. The legislative act that establishes the National Accessibility Authority 
does not make any reference to specific EU legislation, even though its primary role is 
to ‘monitor international, EU and national frameworks for accessibility’. Its role is rather 
detailed in relation to national legislation, including ratification of the UN CRPD.      

Recommendations  

It  is  important  to address  the general  lack  of  evidence  concerning  digitalisation  and 
digital transformation from a disability perspective. It would be important to conduct for 
instance  situation  analysis  and  sector  specific  baseline  assessments  to  gain 
understanding of the experiences of persons with disabilities (and other stakeholders) 
using  digital  technology  and  services  currently,  to  identify  opportunities  and 
challenges, and  to  inform  targeted  project  design and  implementation. Programmes 
aiming to address digital inequalities, such as digital skills training, must ensure both 
accessible  content  and  delivery  when  addressing  the  general  population  as  well  as 
disability focused projects that address specific support needs and barriers. Building 
evidence and learning on this topic could further contribute to increased engagement 
of public and private actors not only in terms of complying with accessibility standards, 
but also actively using new digital technologies to transform disability support service 
provision across sectors in ways that not only increase efficiency, but also empower 
persons with disabilities. This potential is not adequately addressed in current national 
disability related and/or digital strategies.  

7 

 
 
 
 
 
 
 
Digitalisation and digital transformation - Greece 

2 

Are  government  strategies  and  plans  on  digitalisation  and  digital 
transformation disability-inclusive?  

2.1  Disability  inclusion  in  generic  strategies  on  digitalisation  and  digital 

transformation 

The National Digital Strategy 2016-2021 first addressed the need for a new model of 
governance and management of ICT projects at high-level. The responsibilities for the 
design, coordination, and monitoring of actions aimed towards digital transformation in 
the country were centralized under the newly established Ministry of Digital Policy, later 
renamed  as  Ministry  of  Digital  Governance.1  The  Ministry  is  exclusively  tasked  with 
setting  strategic  priorities  and  ensuring alignment  of  sector  specific  action plans,  as 
well as managing central government information and telecommunication systems.2  

Using digital technology to ‘combat social exclusion’ and ‘diffusing the benefits of digital 
economy’ formed a specific priority under the National Strategy 2016-2021 (Priority 6), 
acknowledging  potential  digital  inequalities  owing  to  geographical  and/or  social 
barriers,  including  lack  of  digital  skills,  and  promoting  ‘accessibility  for  all,  without 
discrimination’.3  Disability  was  explicitly  mentioned  in  relation  to  monitoring  and 
evaluation of web accessibility ‘in compliance with UN CRPD Article 9’, which further 
foresaw the involvement of representative disability organizations in the process.4 

Rather than a set of priorities, the Bible for Digital Transformation 2020-2025 provides 
guidance on cross-cutting strategic interventions, such as interoperability, digital skills 
and digital innovation, horizontal actions, such as digital public sector transformation, 
open government and data protection, as well as sector specific action plans (please 
see  section  2.2).  ‘Combating  exclusion  and  universal  accessibility’,  with  explicit 
reference to the ‘needs of persons with disabilities’, forms a guiding principle as well 
as horizontal action, although there lacks any planning as to how this will be enforced.5 
Specific projects at short and long term under the latter strand include:6 

• 

• 

• 

Strengthening and ensuring compliance of public digital services with web 
accessibility standards. 
Awareness raising activities across the public sector, including accessibility self-
assessment tools and lifelong learning courses, digital skills training and training 
on design of accessible webpages and digital applications (please see Section 
4). 
Development of web platform for registering persons with disabilities, including 
pupils in special education, persons with dementia and their caregivers, users of 
psychiatric services connected to public hospitals, interactive map of public and 
private mental health services, as well as of community- based services.   

1   Hellenic Republic, Ministry of Digital Policy, Telecommunications and Information, General 

Secretariat of Digital Policy (December 2016) National Digital Strategy 2016-2021 
https://www.eydamth.gr/images/site_2017/ArticleID_283/GR_Digital_Strategy_2016_2021.pdf. 
2   Hellenic Republic, Ministry of Digital Governance (December 2020) Bible for Digital Transformation 

2020-2025 http://www.opengov.gr/digitalandbrief/wp-
content/uploads/downloads/2020/12/digitalstrategy.pdf. 
3   Hellenic Republic, Ministry of Digital Policy (2016) p. 35. 
4   Hellenic Republic, Ministry of Digital Policy (2016) p. 22.  
5   Hellenic Republic, Ministry of Digital Governance (2020) p. 23. 
6   Hellenic Republic, Ministry of Digital Governance (2020) p. 154-155. 

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Digitalisation and digital transformation - Greece 

Overall, the projects outlined in the Bible for Digital Transformation 2020-2025 will be 
funded through Operational Development Programmes (European Structural Funds), 
the  National  Development  Plan  (Public  Investment  Programme),  national  and 
European  research  projects,  as  well  as  through  loans  for  enhancing  digital 
transformation of businesses, the Recovery Fund, and private capital through private-
public sector partnerships.7 

It  is  worth  mentioning  that  Law  4727/20208  recently  transposed  the  EU  Directive 
2016/2102  on  Digital  Governance  and  2019/1024  on  Electronic  Communications  in 
Greek legislation, which importantly adopts: 

• 
• 

• 

• 

common definition of assistive technology ICT (Article 2 paragraph 57);  
explicit obligation to ensure ‘equal access’ to digital public services and ‘take 
into consideration specific access needs of certain groups or individuals, 
especially persons with disabilities’ (Article 3 paragraph 4 General principles) 
e-accessibility standards (Article 39), and exceptions based on disproportionate 
burden (Article 40) 
consultative approach concerning the exercise of rights of end users of network 
providers and electronic communications, including equal access of persons 
with disabilities (Article 132 paragraph 1). 

It is further stipulated that the Minister of Digital Governance in collaboration with other 
ministries  may  take  measures  (after  recommendation  by  the  National  Committee  of 
Telecommunication  and  Postal  services)  as  necessary  to  ensure  that  assistive 
equipment  and  services  to  access  digital  services  are  available  and  economically 
accessible (Article 198).  

Finally, the establishment of the National Authority for Accessibility9 is anticipated to 
be  instrumental  to  monitoring  the  implementation  of  digital  governance  and  other 
projects aligned with the national digital strategy, with respect to compliance with e-
accessibility standards. It is worth mentioning that government officials, including the 
General  Secretary  of  Digital  Governance,  as  well  as  technical  experts,  and 
representatives  appointed  by  disabled  people’s  organizations,  participate  in  the 
National Authority for Accessibility. Additionally, the National Co-federation of Disabled 
People has been actively involved in government plans for establishing a certification 
process of  accessibility  standards  based on the  National Standard  (ELOT  1429)  for 
both public and private sectors.10  

7   Hellenic Republic, Ministry of Digital Governance (2020) p. 31. 
8   Law 4727/2020 Digital Governance, Electronic Communications, and other Regulations Law 

4727/2020 http://www.opengov.gr/digitalandbrief/wp-content/uploads/downloads/2020/12/fek-184-
2020.pdf. 

9   Draft legislation voted on 23 February 2021 https://www.hellenicparliament.gr/UserFiles/18a4e643-

1429-4e6b-a317-d7c6a29adabf/11578912.pdf. 

10   ‘Greek Accessibility Sign, powerful tool for creating accessible environments’ National Co-

federation of Disabled People Press Release 11 March 2021 
https://www.esamea.gr/pressoffice/press-releases/5180-elliniko-sima-prosbasimotitas-isxyro-
ergaleio-gia-ti-dimioyrgia-prosbasimon-periballonton. 

9 

 
 
  
 
 
 
 
 
 
Digitalisation and digital transformation - Greece 

2.2  Disability 

inclusion 

in 

focused  or  sector-specific  strategies  on 

digitalisation and digital transformation 

The  following  sector-specific  strategies  are  embedded  in  the  Bible  for  Digital 
Transformation  2020-2025.  A  general  observation  is  that  there  are  no  stand-alone 
sector-specific strategies on digitalisation and digital transformation. The following two 
sectors were selected based on their direct relevance of proposed actions for persons 
with disabilities and/or available commentaries from a disability perspective.  

Employment and Social Affairs11 

Strategic  priorities  and  actions  planned  in  this  sector  directly  affect  persons  with 
disabilities,  touching  upon  digitalization  of  disability  assessment  and  certification 
procedures, access to welfare benefits and social protection services. Most actions are 
concerned  with  increasing  efficiency,  by  reducing  the  need  for  repeated  physical 
presence  (e.g.  application,  re-assessment,  notification,  and  appeal),  which  has  also 
been  viewed  as  excessive  from  the  user  perspective,  resulting  in  long  delays  and 
disruption of disability provisions.12  

The national strategy makes specific reference to the scale up of the pilot of electronic 
application and allocation of disability welfare benefits, managed by the Organisation 
of Welfare Benefits and Social Solidarity (OPEKA),13 as well as digital transformation 
of  the  Disability  Assessment  and  Certification  Centres  (KEPA),  which  additionally 
foresees interoperability among public agencies requiring access to case files, links to 
electronic prescription and disability benefits information systems, which are currently 
fragmented.14 A digital platform for social protection is similarly envisaged to provide 
seamless information and thus enhanced access to different social protection benefits 
as  well  as  public  and  private  support  services,  such  as  municipal  social  services, 
residential care, homeless shelters, etc.  

Apart  from  enhanced  efficiency  and  transparency,  and  data  protection,  connected 
information systems will offer the possibility for data analytics to support policy making 
taking into consideration disability support needs, social and geographical traits.15 

Finally, the digital strategy for social protection also mentions the need for building the 
digital skills of welfare service providers. It acknowledges that particularly during the 
first wave of the COVID-19 pandemic, which disrupted face to face service provision, 
there was limited capacity overall to transfer services online in terms of infrastructure 
as much as of digital skills, e.g. provide remote counselling, and recreation of children 
with  disabilities.  The  strategy  however  is  limited  to  digital  skills  training,  rather  than 
digital transformation of support services.     

11   Hellenic Republic, Ministry of Digital Governance (2020) p. 199-219. 
12   See for instance The Greek Ombudsman (2013) Special Report on KEPA (Centralized Certification 
Centre for Disability) http://www.synigoros.gr/resources/docs/130404-special-report.pdf; Please 
see also the ANED Disability assessment – country report (2018) for more detailed discussion of 
disability assessment procedures and related challenges. 

13   Law 4512/2018 (FEK Α 105) Disability welfare benefits provision Pilot Article (17). The pilot was 
initially implemented in the region of Attika http://opeka.gr/wp-content/uploads/2018/02/pilotiko-
pronomiakon-paroxon-atoma-me-anapiria-215_n4512-2018.pdf. 
14   Hellenic Republic, Ministry of Digital Governance (2020) p. 202; 212. 
15   Hellenic Republic, Ministry of Digital Governance (2020) p. 213. 

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Digitalisation and digital transformation - Greece 

Education16  

Although not directly addressing disability, this sector specific strategy aims to upgrade 
the digital skills of 165 000 primary and secondary education staff, the digital school 
services for 1,5 million pupils but also promote a digital learning culture more broadly, 
while ‘equal access’ to digital educational and related administrative services forms a 
specific  objective.17  Most  of  the  projects  outlined  concern  improvement  of  the 
infrastructure of the existing educational platform (MySchool), including use of open 
data (data centric, rather than document-centric, registries of individuals participating 
in the educational process) and enriched digital content and tools for remote learning, 
as well as digital skills training of teaching staff. 

A  first  legislative  step  in  the  strategic  direction  of  ‘upgrading  schooling’  through 
digitalisation,  concerns  the  inclusion  of technology and  science  ‘skills  workshops’  in 
primary and secondary education,18 which nevertheless makes no explicit provisions 
for pupils with disabilities, who already face barriers in accessing educational material, 
including digital tools and content.19 As the National Co-federation of Disabled People 
(NCDP) suggests, this piece of legislation is far from promoting inclusive education’.20 
It points out that: 

‘The  “Skills  Workshops”  is  an  exceptionally  important  action  for  all  pupils  and 
particularly  for  pupils with  disability  and/or  special educational needs, because 
they train them from an early age on basic skills which are very useful for their 
socialisation  and  communication  […]  while  they  can  contribute  to  raising 
awareness about accessibility and the needs of pupils with disabilities. However, 
there  is  no  reference  about  teaching  modes  for  pupils  with  disabilities  and/or 
special  educational  needs,  nor  the  integration  of  those  workshops  in  special 
education  units.  In  view  of  Article  24  of  the  UN  Convention  on  the  Rights  of 
Persons with Disabilities, it is necessary to establish workshops which will benefit 
pupils with disabilities, in terms of developing mobility skills, orientation and daily 
living, which are also beneficial for pupils without disabilities’.21 

16   Hellenic Republic, Ministry of Digital Governance (2020) p. 166-186. 
17   Hellenic Republic, Ministry of Digital Governance (2020) p. 166. 
18   Law 4692/2020 Schools upgrading and other regulations, 

https://www.minedu.gov.gr/publications/docs2020/nomos_yp_arithm._46922020.pdf. 

19   National Co-federation for Disabled People (2020) Study for the Transition from Special Education 

to Education without exclusions, Athens available at: 
https://paratiritirioanapirias.gr/el/news/publications/69/meleth-gia-th-metabash-apo-thn-eidikh-
agwgh-kai-ekpaideysh-sthn-ekpaideysh-xwris-apokleismoys.  

20   ‘The system the Ministry of Education promotes is far from any concept of inclusive education’ 
NCDP Press Release 1 June 2020  https://www.esamea.gr/press-office/press-releases/4824-
makria-apo-kathe-ennoia-symperiliptikis-ekpaideysis-to-systima-poy-proothei-to-yp-paideias. 
21   ‘Letter to Parliament Committee on Educational Affairs Observations and Recommendations on 

draft legislation “Schools Upgrading and other regulations”’ NCDP Protocol Number 
736/01.06.2020 1 June 2020 https://www.esamea.gr/our-actions/ypdbmth/4823-i-e-s-a-mea-
katathetei-sti-boyli-tis-protaseis-paratiriseis-tis-sto-sxedio-nomoy-me-thema-anabathmisi-toy-
sxoleioy-kai-alles-diataxeis. 

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3 

Do disability strategies address the potential of and challenges pertaining 
to digitalisation and digital transformation? 

3.1  How digitalisation and digital transformation are addressed in the national 

disability strategy 

Overall, the National Disability Action Plan is aligned with the actions proposed in the 
Bible  for  Digital  Transformation  in  the  short-term  (2020-2023)  primarily  those 
concerning  the  accessibility  of  digital  public  services,  including  public  websites  and 
mobile  applications,  and  procedures  related  to  the  provision  of  disability  benefits 
(please  see  Section  2.2).  The  benefits  of  digital  transformation  in  those  sectors  are 
viewed mainly in terms of simplification of administrative procedures and reduction of 
bureaucratic obstacles.   

Data collection and use of data for policymaking in the field of disability (Objective 7) 
is also envisaged to be served well by digital transformation, by ‘mapping disability in 
the current information systems” (paragraph 7.4), although this is not elaborated any 
further  in  the  National  Disability  Action  Plan.22  The  creation  of  ‘accessible  digital 
content”23 for education is also very briefly mentioned, as well as for wide scale ICT 
training of persons with disabilities, which is foreseen to be embedded in the National 
Digital  Academy  and  digital  centres24  (please  see  also  section  4).  Finally,  the 
involvement  of  the  Ministry  of  Digital  Transformation  is  also  referenced  in  actions 
related to enhanced access to justice and civil protection.25 

An overall remark is that although the National Disability Action Plan outlines specific 
objectives, and indicative actions, timelines and authorities involved, across thematic 
areas such as education, employment, independent living, health, accessibility, social 
participation, and so on, it lacks analysis informing the proposed actions. There is a 
lack of evidence about opportunities and challenges related to digitalisation and digital 
transformation  from  a  disability  perspective  (please  see  also  section  5  for  similar 
observations). There is no clear prioritization of selected actions and it lacks specific 
targets and expected outcomes. At the same time, the actions outlined tend to be broad 
in  scope,  while  there  are  no  explicit  links  to  sector  specific  strategies  and  possible 
funding  mechanisms.  Although  it  seems  that  the  National  Disability  Action  Plan 
primarily intends to list a series of actions, it fails overall to provide details related to 
selection criteria of relevant projects, implementation, monitoring and evaluation.        

3.2  How  digitalisation  and  digital  transformation  are  addressed  in  specific 

disability-related strategies  

Apart from the National Disability Action plan, no other disability-related strategies or 
up to date sector focused strategies relevant to the rights of persons with disabilities 
were identified.  

The National Strategy for Development 2030 was reviewed for relevant insights, and 
the following two references to disability and/or digital transformation are indicative of 

22   Hellenic Republic Minister of Interior (acting as National Coordination Mechanism for the 

implementation of UN CRPD (Law 4488/2017, art. 69) (2020) National Disability Action Plan p.14. 

23   Hellenic Republic Minister of Interior (2020) p.25. 
24   Hellenic Republic Minister of Interior (2020) p.29. 
25   Hellenic Republic Minister of Interior (2020) pp.36, 37. 

12 

 
 
 
 
 
  
 
 
 
Digitalisation and digital transformation - Greece 

the limited sector specific strategic planning as such, as well as limited links to disability 
rights. 

A first related remark is that the last action plan in the field of education concerned the 
period 2017-2020, which included reforms in special education school grading as well 
as  educational  support  structures.26  The  development  plan  for  2030  is  limited  to 
suggesting that ‘those structures need further support’.27  

A second reference is made in relation to ‘a digital mechanism supporting actions for 
de-institutionalization,  which  will  connect  to  the  foster/adoption  system’.28  This  is 
reflected in plans for the digital transformation of social protection services (please see 
section  2.2),  but  not  clearly  articulated  as  such  in  actions  for  de-institutionalization 
embedded in the National Disability Action plan.  

26   DOTCOM - The Academic Network of European Disability experts (ANED) Greece E1- Special 

schools, https://www.disability-europe.net/dotcom/text/greece/e1-special-schools. 

27   The National Strategy for Development 2030 (May 2019) p. 102, 

https://www.espa.gr/el/Documents/2127/Strategy_for_Development_2030_May2019.pdf. 

28   The National Strategy for Development 2030 (May 2019) p. 111. 

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Digitalisation and digital transformation - Greece 

4 

Promoting disability inclusion through funding, education and training  

4.1  How  funding  promotes  disability-inclusive  digitalisation  and  digital 

transformation 

Any  ICT  project,  regardless  of  funding  source  is  reviewed  and  pre-approved  by  the 
Ministry  of  Digital  Governance  to  ensure  alignment  with  the  Bible  for  Digital 
Transformation, including that is e-accessibility which is an explicit strategic goal. In 
addition, ‘universal design for ensuring accessibility of electronic services, webpages 
and  applications  from  any  device,  for  persons  with  disabilities’  is  a  key  criterion  for 
evaluating and selecting new project proposals for funding.29  

Furthermore,  the  government  has  committed  to  updating  national  procurement 
legislation  to  ensure  compliance  with  the  EU  Directive  2019/88230  -  Accessibility 
requirements for products and services and the national accessibility standard (ELOT 
1439:2013).31 As described above (please see section 2.1) the National Accessibility 
Authority,  with  the  active  involvement  of  representatives  of  disabled  people’s 
organizations, will be a key independent body responsible for monitoring compliance.  

4.2  How disability inclusion is promoted through the education and training of 

digital professionals 

With regard to engineers’ training in disability issues it is worth noting that the revised 
disability rights framework (Law 4488/2017) specifies that universities are responsible 
for including in their study programmes and seminars, training modules which relate to 
the  rights  of  persons  with  disability  according  to  the  UN  CRPD.  The  content  and 
technical  specifications  of  such  programmes  shall  be  defined  by  the  respective 
Ministries in cooperation with the national Coordination Mechanism and Focal Point for 
the implementation of the UN CRPD (Law 4488/2017 Article 66, paragraph 2).32 There 
was no evidence identified suggesting such actions have taken place to date. 

It  is  interesting  that  the  Bible  for  Digital  Transformation  makes  explicit  reference  to 
plans  for  promoting  inclusion  of  accessibility  in  higher  education  training  related  to 
design  and  programming  of  webpages  and  digital  applications,  however  this  is  not 
elaborated any further.33 

It was not possible to identify any examples of courses integrating accessibility issues 
in the education and training of digital professionals.34 It is worth noting nevertheless 
that  the  Hellenic  Association  of  Assistive  Technologies,35  which  includes  a  working 

29   Bible for Digital Transformation 2020-2025 p. 29. 
30   EU Public Procurement Directives have applied since 2016 (L.4412/2016). The latest modification 

of national procurement legislation (March 2021) (Article 54, Law 4782/2021) reinstates that 
technical standards must consider accessibility criteria for persons with disabilities or universal 
design and that where EU Directives apply, technical standards are defined accordingly. 

31   Hellenic Republic Minister of Interior (2020) p. 48. 
32   ANED DOTCOM database Greece H.5 https://www.disability-europe.net/dotcom. 
33   Hellenic Republic, Ministry of Digital Governance (2020) pp. 154-155. 
34   It should be noted that this kind of information is very fragmented; there isn’t for instance existing 

research of good practices, and one would need to research the course curriculum of each 
university. It is understood that to make the case that accessibility is well integrated in the 
academic training of digital professionals there should be a distinct module or similar knowledge 
base. 

35   http://www.eeeyt.gr/index.php/el/e-prosvasimotita. 

14 

 
 
 
 
 
 
 
 
 
Digitalisation and digital transformation - Greece 

group on e-accessibility, aims to contribute to the training of its members and produce 
relevant  learning  material,  as  well  as  participating  in  research  projects  and 
disseminating related knowledge through events.   

4.3  How digital inclusion and accessibility is addressed in the education and 

training of accessibility and inclusion professionals 

The  theme  of  special  education  and  new  technologies  stands  out  for  being  well 
integrated in undergraduate and postgraduate academic courses in the country. The 
field is served in different ways such as a module in mainstream pedagogic studies,36 
research  departments,37  and  ongoing  professional  development  courses  offered  by 
higher education institutes.38 There are in addition a number of accredited courses in 
special  education  and  new  technologies  provided  by  private  Lifelong  Learning 
Centres.39 

4.4  How  digital  inclusion  is  addressed  via  the  training  of  people  with 

disabilities 

The most recent calls for tender and projects related to digital skills training, typically 
funded through European Structural Funds, address the general population. There is 
no evidence of the extent to which persons with disabilities are able to access those. 

A  notable  example  is  the  Call  for  proposals  (April  2021)  addressed  to  Youth  and 
Lifelong Learning Foundations to develop training programs on telework skills, with a 
total  budget of EUR 15 600 000,  with  over  half  of  funds  allocated  to  less  developed 
regions  in  the  country.40  In  addition,  there  is  currently  a  program  for  gaining  work 
experience in digital marketing (over 5 000 placements) targeting young people aged 
18-29, who have already completed relevant training.41  

Furthermore, the National Digital Academy (nationaldigitalacademy.gov.gr) run by the 
Ministry of Digital Governance to date provides free access to 279 basic and advanced 
modules  in  31  thematic  sectors  offered by 37  certified organizations.42  The national 
digital strategy also foresees the creation of 15 digital centres across the country to 
enhance  the  digital  skills  of  the  general  population,  including  specialized  training 
programs for specific social groups such as persons with disabilities.43  

Current specialised vocational training programmes on ICT and related skills for people 
with disabilities, are typically provided by the Public Employment Organisation (OAED), 

36   See for instance curriculum of undergraduate studies in Philosophy and Pedagogy at the Aristotle 

University of Thessaloniki https://qa.auth.gr/el/x/class/1/600119241. 

37   See for instance University of Thessalia Workshop of ICT applications in Education and Special 

Education https://www.sed.uth.gr/index.php/gr/research-activities/labs/103-sedict-lab. 

38   See for instance University of Macedonia Centre for Training and Lifelong Learning Education and 

Special Education courses https://kedivim.uom.gr/education/. 

39   See for instance https://www.easy-education.gr and https://ianap.gr/. 
40   ‘Training program for gaining telework skills for the general population’ 
https://www.espa.gr/el/pages/ProclamationsFS.aspx?item=5208. 

41   ‘Program for gaining work experience in digital marketing for 5,000 unemployed youth up to 29’ 

https://www.espa.gr/el/pages/ProclamationsFS.aspx?item=5171. 

42   Ministry of Digital Governance Press Release 2 April 2021 Enrichment of the National Digital 

Academy with new lessons https://mindigital.gr/archives/2241. 
43   Hellenic Republic, Ministry of Digital Governance (2020) p. 86. 

15 

 
 
 
 
 
 
 
 
 
Digitalisation and digital transformation - Greece 

available  only  in  the  two  largest  urban  centres,44  or  non-profit  organisations/ 
associations  of  parents  of  persons  with  disabilities,  supervised  by  the  Ministry  of 
Labour.45 

44   National Manpower Organization Vocational Training Programs for persons with disabilities 

https://www.oaed.gr/idikes-koinonikes-omades?tab=epaghghelmatiki-katartisi-
amea&tab2=skholes-epaghghelmatikis-katartisis-amea&tab3=. 

45   Please see for instance https://www.kea-amea.gr/index.php/gr/ergasthria/tmima-pliroforikis. 

16 

 
 
 
 
 
Digitalisation and digital transformation - Greece 

5 

The  opportunities  and  challenges  presented  by  digitalisation  and  digital 
transformation to the rights of persons with disabilities 

5.1  The  most significant  opportunities  presented  by  digitalisation  and  digital 

transformation for persons with disabilities 

There are few national studies on new technologies and disability and where they do 
exist,  they  are  quite  outdated.  More  specifically,  the  last  available  studies  were 
conducted in the ESF period 2007-2014 where Information Society formed a distinct 
strand of actions.46 The conclusions of those studies pointed to challenges, rather than 
opportunities,  related  overall  to  very  low  demand  and  supply  of  accessible  new 
technologies for people with disabilities (please see also section 5.2). Apart from efforts 
to  put  e-accessibility  in  the  political  agenda,  i.e.  National  Digital  Strategy,  National 
Disability  Action  Plan,  there  are  no  standalone  thematic  reports  and/or  information 
campaigns by the civil society, disabled people’s organizations or independent equality 
bodies  on  the  topic  of  new  technologies  and/or  digitalisation  from  a  disability 
perspective.  This  is  arguably  reflecting the ‘low  digital maturity  of Greece  and  small 
contribution of digital economy’ overall (please see also section 5.2 below).47    

5.2  The  most  significant  challenges  faced  by  persons  with  disabilities  in 

relation to digitalisation and digital transformation 

Despite progress in terms of connectivity in more recent years,48 Greece ranks 27th out 
of 28 Members States in the Digital Economy and Society Index 2020.49 Internet usage 
is below 50 % with 22 % of population having never used the internet.50 On EU level, 
access barriers such as insufficient skills (44 %), equipment costs (26 %) and high cost 
barriers (24 %) prevent people from using the internet at home.51 These barriers seem 
to  be particularly  relevant  for  Greece from a  disability  perspective,  given  the  limited 
scope of health and social policy provisions for assistive technology and/or accessible 
digital solutions.52 Just over 20 % of the population in Greece have internet user skills 
and given the limited investment in accessible digital skills training so far (please see 

46   Athens Network of Collaborating Experts (2014) New technologies and Disability: Equal 

opportunities or new forms of exclusion? Athens, National Co-federation of Disabled People p. 118-
119 provides an overview of studies conducted from 2004 to 2008. The study itself provides a 
rather conceptual framework for assessing the wider theme of new technology and disability, 
holding the position that “new technologies create both opportunities and risks for social inclusion 
of persons with disabilities. However, their role in either direction should not be overestimated, 
given that the roots of social exclusion are linked to deeper causes of social organization and 
functioning” (p.15). Empirical findings included in the report are considered outdated, especially 
where it concerns policy review, or evidence of digital divide (2007 data).  

47   Hellenic Federation of Enterprises (SEV) 2017 Digital Greece Roadmap to Development 

https://www.sev.org.gr/vivliothiki-tekmiriosi/erevnes-meletes-2/meleti-me-thema-psifiaki-stratigiki-
gia-tin-ellada/. 

48   Hellenic Republic, Ministry of Digital Governance (2020) p. 15-16 offers focused analysis of data 
from the Digital Economic and Social Index (DESI) 2020; it is noted that in 2019 Greece marked 
progress of 15 percentage points in Next Generation Access high speed broadband 
communications, placing it 5 percentage points below EU average.  

49   European Commission (2020) Digital Economy and Society Index (2019 data) https://digital-

strategy.ec.europa.eu/en/policies/desi. 

50   European Commission (2020) p. 52. 
51   European Commission (2020) p. 59. 
52   Accessible Limitless Living (2020) SUITCEYES Scoping Report on Law and Policy on Deaf 

blindness, Disability and New Technologies Working Paper-Greece https://suitceyes.eu/policy-
reports/. 

17 

 
 
 
 
 
 
Digitalisation and digital transformation - Greece 

section 4.4) this is likely to disproportionally affect persons with disabilities. Just over 
half  of  people  with  moderate  or  severe  disabilities  in  Greece  have  access  to  the 
internet, in contrast with the large majority of non-disabled population (88.1 %), with 
affordability mentioned  as a main  reason  in a  minority  of  cases only,  indicating  that 
lack of skills and/or accessible solutions may be more important factors shaping access 
to the internet for persons with disabilities.53 

As  pointed  out  in  Section  5.1,  there  is  limited  engagement  from  non-governmental 
organisations with the topic of digitalisation and digital transformation and harnessing 
their potential, as much as addressing challenges, for advancing the rights of persons. 
There  is  however  notable  reference  to  the  limited  use  of  new  technologies  for 
enhancing  accessible  and  inclusive  education  in  the  UN  CRPD  Concluding 
Observations and Recommendations for Greece.54   

53  Disability Observatory of the National Co-federation of Disabled People (2021) National Disability 
Report 2020 p. 45 available at: https://paratiritirioanapirias.gr/el/news/publications/63/e8nikh-
ek8esh-gia-thn-anaphria-etoys-2020. 

54   UN Committee on the Rights of Persons with Disabilities (2019) ‘Concluding Observations on the 

initial report of Greece’ CRPD/C/GRC/CO/1, 
http://docstore.ohchr.org/SelfServices/FilesHandler.ashx?enc=6QkG1d%2fPPRiCAqhKb7yhskOcZ
9cO6iPa1r3wEJzoMtZPRlsn2F8be6qzYChDHrmBTMH%2bqHKEyy9lkIKsnfl7vYm%2b%2fX3mXiO
TCPBgssnHiOpTdzNgr31DcGr9iV91p4N2. 

18 

 
 
 
 
 
 
Digitalisation and digital transformation - Greece 

6 

Conclusions and recommendations 

6.1  Conclusions 

Greece is characterized by low digital performance, including low levels of digital skills/ 
use  of  internet,  digital  economy,  and  digitalisation  of  public  services.  This  is 
acknowledged in current national digital strategies, which seek to maintain alignment 
of sector specific digital transformation strategies and governance over ICT projects 
implemented  across  the  board,  to  accelerate  efforts  and  ensure  effectiveness. 
Electronic  accessibility  is  adequately mainstreamed  in  guiding principles,  evaluation 
criteria  and  cross  cutting  interventions,  however  it  does  not  materialise  in  concrete 
actions in sector-specific strategies such as education, while allocation of resources is 
not explicit at this stage.  

At  the  same  time,  the  National  Disability  Action  Plan  (2020)  is  the  first  coordinated 
attempt  to  mainstream  disability  across  policy  sectors  at  national  level.  Priorities 
addressing digitalisation are well aligned with disability related actions in the national 
digital  strategy,  including  timelines  and  authorities  involved.  However,  there  lacks 
evidence  and  analysis  supporting  decision-making  in  terms  of  prioritization  and/or 
resource allocation, as well as design and monitoring of programmatic interventions. It 
is  similarly  not  clear  whether  actions  such  as  creating  accessible  digital  learning 
content for education and/or digital skills training will be part of mainstream projects 
targeting  the  general  population,  or  specialised  projects  through  separate  funding 
streams. 

Finally,  the  low  levels  of  digital  maturity  mean  that  most  actions  directly  addressing 
disability are concerned with establishing efficient information systems and expanding 
digital  public  services  at  short  term,  such  as  disability  assessment  procedures  and 
allocation  of  disability  benefits,  rather  than  harnessing  potential  for  enhancing 
accessibility and inclusiveness of services in the long-term, for instance in education 
or social protection sectors.    

6.2  Recommendations 

1.  Recommendation targeting the Ministry of Digital Governance and the National 
Co-federation  of  Disabled  People  as  actors  involved  in  managing  funding 
streams and programs at the intersection of disability and digitalisation:  

Allocate  resources 
for  situation  analysis  and  sector  specific  baseline 
assessments to gain understanding of the experiences of persons with disabilities 
(and other stakeholders) using digital technology and services currently, identify 
opportunities  and  challenges,  in  order  to  inform  targeted  project  design, 
implementation, monitoring and evaluation. 

2.  Recommendation 

in  designing  operational 
development programs for addressing digital inequalities, including gaining digital 
skills, the National Accessibility Authority as independent monitoring body: 

targeting  Ministries 

involved 

Ensure a comprehensive approach to disability inclusion in related programming: 
ensure  programs  targeting  the  general  population  comply  with  electronic  and 
physical accessibility standards, as well as design and deploy programs that meet 

19 

 
 
 
   
 
 
 
 
 
 
Digitalisation and digital transformation - Greece 

additional  support  needs  of  persons  with  disabilities  to  access  and  use  digital 
technology,  including  information  sharing/  provisions  for  specialised  ICT 
equipment and assistive technology.     

3.  Recommendation  targeting  the  Minister  of  Interior,  as  National  Coordination 
Mechanism as per the UN CRPD informed national disability legal framework, the 
National Co-federation of Disabled People as representative disabled persons’ 
organisation and state partner in disability policymaking: 

Use  evidence  and  learning  from  the  implementation  of  projects  addressing 
digitalisation and disability to update, refine and elaborate the National Disability 
Action  Plan  in  ways  that  further  harness  the  transformative  potential  of  digital 
technologies, not only in ensuring access to mainstream goods and services, but 
in instigating innovative quality service provision across sectors.  

20 

 
 
 
  
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