COMMISSION STAFF WORKING DOCUMENT 2024 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 2024 Rule of Law Report The rule of law situation in the European Union
Date: 2024-07-24
Institutions: European Commission, Secretariat-General
Subjects: Greece, administrative transparency, corruption, democracy, freedom of the press, independence of the judiciary, infringement of EU law, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.7.2024  SWD(2024) 808 final  COMMISSION STAFF WORKING DOCUMENT 2024 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 2024 Rule of Law Report                      The rule of law situation in the European Union {COM(2024) 800 final} - {SWD(2024) 801-831 final}  
 
 
ABSTRACT 

The evaluation of judges is taking place under a new legal framework. A legislative proposal 
was adopted involving the judiciary in appointments to the highest positions in the judiciary. 
Efforts  to  increase  the  level  of  digitalisation  continue,  and  the  implementation  of  several 
reforms  financed  by  the  Recovery  and  Resilience  Facility  aiming  to  improve  the  quality  of 
justice are well on track. The new judicial map in civil and criminal justice is a major reform 
which  aims  at  a  balanced  distribution  of  cases  among  first  instance  judges  and  a  speedier 
administration  of  justice.  Serious  challenges  remain  regarding  the  length  of  proceedings 
before  civil  courts  and  the  Council  of  State  with  some  improvements  in  ordinary 
administrative  courts.  Efforts  to  reduce  the  length  of  proceedings  include  the  transfer  of 
categories  of  non-litigious  cases  from  courts  to  lawyers  and  the  planned  reform  of  the 
preliminary procedure of the Council of State.   

The 2022-2025 National Anti-Corruption Action Plan was updated and implementation is on 
track.  Efforts  to  establish  a  track  record  of  prosecutions  and  final  judgments,  in  corruption 
cases,  including  in  high-level  corruption  cases  were  made.  The  legal  framework  for 
combatting  corruption  and  foreign  bribery  was  strengthened.  The  National  Transparency 
Authority maintained its level of activities. The implementation of rules on lobbying and gifts 
is ongoing with the number of entries in the lobby register increasing and information from 
the gifts’ registry is now public. Implementation  of the new law on asset  declarations is on 
track with a significant percentage of verifications completed. Work on developing codes of 
conduct for ministers and parliamentarians and guidelines for the police continued. Audits of 
political  parties  indicated  a  better  level  of  compliance  with  the  new  rules.  Whistleblower 
protection  was  extended  to  corruption  offences  and  the  external  reporting  channel  became 
operational. The government is developing an integrated risk management system to increase 
transparency and integrity in public procurement, still considered to be a high-risk sector.  

A  new  system  for  the  selection  and  appointment  of  administrators  of  public  sector  entities 
entered  into  force,  covering  also  public  service  media.  Selection  procedures  to  address 
challenges regarding the resources of the media regulator are ongoing, while concerns have 
been  raised  regarding  its  independence.  Some  further  progress  has  been  made  in  adopting 
non-legislative  safeguards  to  improve  the  protection  of  journalists  and  significant  progress 
has been made in the legislative process, including with the decriminalisation of the offence 
of simple defamation.  

Some progress was made to improve the consultation of stakeholders, while its effectiveness 
and timeliness in practice still need to be better addressed. Efforts are under way to improve 
access  to  legislation,  while  challenges  regarding  the  quality  of  the  law-making  process 
persist. Independent authorities established by virtue of the Constitution face challenges that 
could  undermine  their  status  and  ability  to  carry  out  their  tasks  effectively.  The 
Ombudsperson  is  investigating  incidents  of  alleged  misconduct  involving  law  enforcement 
officers.  Judicial  investigations  into  the  use  of  spyware  are  ongoing.  The  ongoing 
implementation  of  the 
the  existing  registries  for  Civil  Society 
Organisations  is  a  positive  development.  The  registration  framework  still  needs  to  be 
evaluated, in particular in relation to the Special Registries of the Ministry of Migration and 
Asylum. Concerns regarding the space for civil society remain.  

interoperability  of 

1 

 
 
RECOMMENDATIONS 

Overall,  concerning  the  recommendations  in  the  2023  Rule  of  Law  Report,  Greece  has 
(made): 

•  Fully  implemented  the  recommendation  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. 

•  Some  further  progress  on  stepping  up  efforts  to  establish  a  robust  track  record  of 
prosecutions and final judgments in corruption cases, including high-level corruption. 
•  Some  further  progress  on  taking  forward  the  process  of  adopting  non-legislative 
safeguards  and  significant  progress  on  starting  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.  

•  Some  progress  on  ensuring  the  effective  and  timely  consultation  in  practice  of 
stakeholders  on  draft  legislation,  including  by  allowing  sufficient  time  for  public 
consultation. 

•  Some further progress on taking 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.  

On this basis, and considering other developments that took place in the period of reference, 
and  in  addition  to  recalling  the  relevant  commitments  made  under  the  Recovery  and 
Resilience Plan, it is recommended to Greece to: 

•  Continue efforts to establish a robust track record of prosecutions and final judgments in 

corruption cases, including high-level corruption. 

•  Further advance with the process of adopting legislative and non-legislative safeguards to 
improve  the  protection  of  journalists,  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. 

•  Step  up  the  efforts  to  ensure  the  effective  and  timely  consultation  in  practice  of 
stakeholders  on  draft  legislation,  including  by  observing  the  statutory  timeframe  for 
public consultation. 

•  Strengthen efforts to evaluate the current legal framework for the registration system for 
civil society organisations and assess whether there is a need to amend it, while moving 
forward with a structured dialogue with CSOs. 

2 

 
 
 
I. 

JUSTICE SYSTEM  

The Greek judicial system consists of two autonomous branches: courts with jurisdiction in 
civil  and  criminal  matters  and  administrative  courts.  Both  branches  are  organized  in  three 
instances,  with  first  instance  courts,  courts  of  appeal1  and  a  court  of  last  instance.  The 
Supreme  Court  is  the  highest  court  of  general  jurisdiction,  and  the  Council  of  State  is  the 
Supreme Administrative Court2. The Court of Audit is the Supreme Financial Court and has 
jurisdiction on the audit of the expenditures of the State, local government agencies and other 
legal  entities3.  Judges  and  prosecutors  are  appointed  by  presidential  decree  after  their 
successful  training  in  the  National  School  of  Judiciary4.  Promotions,  assignments  to  posts, 
transfers  and  secondments,  are  decided  by  the  competent  Supreme  Judicial  Council5.  As 
regards  prosecution  authorities,  they  are  organised  into  prosecution  offices  at  the  courts  of 
first instance, 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, 40% of the general population and 48% of 
companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in  20246.  The  perceived  judicial  independence  among  the  general  public  has  significantly 
decreased in comparison with 2023 (46%)7, as well as in comparison with 2020 (53%). The 
perceived  judicial  independence  among  companies  has  decreased  in  comparison  with  2023 
(54%), as well as in comparison with 2020 (51%)8. 

A legislative provision was adopted, fully implementing the recommendation to address 
the need for involvement of the judiciary in appointments to the highest positions in the 
judiciary. The 2023 Rule of Law Report recommended to  Greece to  ‘take steps to  address 

1   Special provisions regulate the operation of courts for juveniles, military, navy and air  force courts. CEPEJ 

(2021), Study on the functioning of judicial systems in the EU Member States, p. 638. 

2   In  certain  categories  of  cases,  the  Council  of  State  has  competence  to  decide  in  first  and  last  instance  by 
exercising full jurisdiction. The elaboration of all decrees of regulatory nature falls under the jurisdiction of 
the Council of State which has competence to give an opinion concerning the legality thereof. Codification 
of Law concerning the Council of State, Presidential Decree, 18/1989. 

3   The Court of Audit is also  an Audit Institution auditing the  use  of public funds in Greece. Constitution of 

Greece, Article 98. 
4   Constitution, Article 88. 
5     There  are  three  supreme  judicial  councils,  which  are  composed  of  the president of  the  respective  supreme 
court and of members of the same court chosen by lot from among those having served in it for at least two 
years. Constitution of Greece, Article 90, para 1; Law 4938/2022; 2024 EU Justice Scoreboard, Figure 57.  
6   Figures 51 and 53, 2024 EU  Justice Scoreboard and  Figures 50 and 52, 2022 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%). 

7   56% of the respondents consider that there is interference or pressure from government and politicians and 

53% pressure from economic or other specific interests. 2024 EU Justice Scoreboard, Figure 52.  

8   28% of the companies in Greece are either fairly or very confident that their investments are protected by the 
law  and  courts  in  the  Member  State.  47%  of  the  surveyed  companies  see  the  quality,  efficiency  or 
independence of justice as one of the main reasons for concern about investment protection in the country. 
Figures 55 and 56, 2024 EU Justice Scoreboard. 

3 

 
 
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’9. In July  2024,  Parliament  voted a  legislative 
proposal to involve the administrative Plenaries of the three highest courts in the procedure 
leading  to  the  appointment  of  their  Presidents  and  Vice-Presidents10.  According  to  the 
adopted provision, the Minister of Justice requests the opinion of the plenary of the relevant 
highest  court11.  Members  of  that  court  vote  by  secret  ballot  up  to  five  candidates  for  the 
position  of  the  President12.  The  opinion  is  not  binding.  The  Council  of  Ministers,  after 
consulting the Conference of Presidents of Parliament and upon a proposal from the Minister 
for  Justice,  selects  the  candidates.  The  appointments  are  done  by  presidential  decree, 
following  the recommendation by  the Council of Ministers13. The  new provision takes into 
account European standards14. Judges from the three highest courts had spoken in favour of a 
reform and had expressed the view that the Plenaries of these Courts should be consulted on 
any  relevant  legislative  proposal15.  Such  prior  consultation  did  not  take  place.  Judges 
associations and the Bar association were, however, heard before Parliament. They all noted 
that the reform is a first positive step towards the right direction, which needs to be followed 
up  and  discussed  in  depth  during  the  upcoming  constitutional  revision.16.  In  view  of  the 
foregoing, the implementation of the recommendations made in the previous years have been 
fully implemented. 

The  evaluation  of  judges  is  taking  place  under  a  new  legal  framework.  Following  the 
revision of the Code on the organisation of the courts and the status of judges in 202217, the 
evaluation  of  both  judges  and  courts  is  now  performed  every  two  years  by  judges  of  the 
highest courts18. In September 2023, the Supreme Court appointed 12 judges-evaluators and 9 

9   In the 2023 Rule of Law Report, the Commission concluded that no progress was made on the  similar 2022 
recommendation. 2022, 2023 Rule of Law Reports, Country Chapter on the rule of law situation in Greece, 
p.  2.  GRECO  also  addressed  a  recommendation  to  Greece  to  revise  the  method  of  selection  of  the  most 
senior  positions  of  judges  and  prosecutors  so  as  to  involve  the  peers  in  the  process,  which  remains  non-
implemented.  GRECO  (2023),  Fourth  Evaluation  Round,  Second  Addendum  to  the  Second  Compliance 
Report Greece, paras 16-20.  

10   Law 5123/2024 on the modernisation of the institutional framework for pledges and the establishment of a 
unified  Electronic  Register  of  Pledges  on  movable  property,  claims  and  other  rights  and  other  provisions, 
Article 27 amending Article 59, para 3 of Law 4938/2022. 

11   The General Prosecutor and the deputy prosecutors participate in the plenary session of the Supreme Court.  
12   For the positions of vice-presidents, judges can vote up to fifty per cent of the number of judges having the 

required qualifications.  

13   2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, pp. 4-5.  
14   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 practice. 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. 

15   Information received from the Council of State, the Court of Audit and the Supreme Court in the context of 

the country visit.   

16   The proposed amendment  was not submitted to public consultation.  Stakeholders (association of judges of 
the Council of State, association of judges of the Court of Audit,  association of prosecutors, the Plenary of 
the Bar Associations) were heard before the relevant standing parliamentary committee. 

17   Law 4938/2022. 
18   The Law provides different systems for civil courts, administrative courts, the Council of State and the Court 
of Audit,  which are  nevertheless based on the same general principles. European Network of Councils for 
the Judiciary (ENCJ) (2024), Contribution for the 2024 European Commission Rule of Law report, p. 7. 

4 

 
 
substitutes  for  a  two-year  term19.  It  expects  the  evaluation  process  to  provide  a 
comprehensive  image  of  the  performance  and  the  functioning  of  civil  justice20.  In  October 
2023,  the  Court  of  Audit  revised  its  Rules  of  Procedure  to  clarify  the  evaluation  of 
performance of judges and the allocation of cases based on preestablished objective criteria21. 
The Council of State adopted guidelines for the inspection of ordinary administrative courts 
and their judges in June 2023 as well as of the judges of the Council of State22.  

The Supreme Court formally reacted to a resolution of the European Parliament on the 
rule of law and media freedom in Greece. In February 2024, the administrative plenary of 
the  Supreme  Court  issued  a  decision  on  the  resolution  of  the  European  Parliament  of  7 
February 2024 on the rule of law and media freedom in Greece23. It reacted to several points 
in  the  resolution  relating  to  the  judiciary  and  considered  that  public  opinions  expressed  by 
national  or  EU  institutions  in  relation  to  cases  pending  before  national  courts  constitute 
impermissible interventions in breach of judicial independence24, while a minority of thirteen 
judges  considered  that  the  discussion  on  the  resolution  fell  outside  the  competence  of  the 
Court25. The Athens Bar Association criticised the decision of the Supreme Court, stating that 
the judiciary cannot be beyond criticism26. 

Quality  

Efforts to increase the level of digitalisation continue. As reflected in the 2024 EU Justice 
Scoreboard, there is some progress in certain areas, including in criminal proceedings, where 
digitalisation has been particularly slow27. Defendants can communicate confidentially with 
their  lawyers  during  remote  hearings  and  defendants  in  detention  can  use  ICT  facilities  to 
prepare  for  hearings,  while  secure  electronic  channels  of  communication  for  prosecution 
services  were  also  introduced28.  In  administrative  justice,  a  unified  database  allows  for  the 
electronic filing of cases and documents and the necessary legal provisions were adopted to 
include  the  Supreme  Special  Court  in  the  electronic  Integrated  Judicial  Case  Management 
Information  System29.  There  has  been  some  progress  in  adopting  procedural  rules  allowing 
digital  technologies  in  civil  cases,  but  such  rules  are  lacking  in  administrative  justice,  a 
shortcoming  that  has  been  also  highlighted  by  judges30.  Some  previously  identified 
shortcomings  remain,  notably  as  regards  the  limited  availability  of  digital  tools,  adequate 

19   Input from Greece for the 2024 Rule of Law Report, p. 4. 
20   Information received from the Supreme Court in the context of the country visit to Greece.  
21   Information received from the Court of Audit in the context of the country visit to Greece. 
22   Decision  of  Council  of  State  in  Council  26/2023.  Written  contribution  from  Greece  in  the  context  of  the 

country visit.  

23   European Parliament resolution of 7 February 2024 on the rule of law and media freedom in Greece. 
24   Supreme Court, Administrative Plenary Decision 2/2024, 15 February 2024. 
25   They  considered  that  the  decision  of  the  Supreme  Court  did  not  concern  a  legal  issue  relating  to  its 
functioning  or  the  administration  of  justice  and  risked  tangling  the  Court  into  the  political  debate  and 
undermine its status. 

26   Athens Bar Association (2023), Judicial Independence – The limits of criticism to justice, press release, 23 

February 2024. 

27   2022,  2023  Rule  of  Law  Reports,  Country  Chapter  on  the  rule  of  law  situation  in  Greece,  p.  7  and  p.  6 

respectively. 

28   Figures 48 and 46, 2024 EU Justice Scoreboard. 
29   Article 25 of the Law 5067/2023; Input from Greece for the 2024 Rule of Law Report, pp. 9-11. 
30   Figure 43, 2024 EU Justice Scoreboard. Judges of the Council of Stated noted that there is a pressing need to 
adopt rules in relation to legal deadlines and electronic serving of documents. Information received from the 
Council of State in the context of the country visit. 

5 

 
 
infrastructure  and  equipment  and  the  limited  possibilities  for  courts  to  communicate 
electronically in a secure manner31. Several projects, including those under the Recovery and 
Resilience Plan, are expected to increase the level of digitalisation32, which stakeholders see 
as a precondition to improve working conditions for the judiciary33. 

The  Office  for  the  Collection  and  Processing  of  Judicial  Statistics  continues  to  face 
challenges  but  a  project  to  support  its  functioning  has  been  included  in  the  revised 
Recovery and Resilience Plan. The 2023 Rule of Law Report noted delays in the effective 
functioning of the Office for the Collection and Processing of Judicial Statistics linked to the 
lack  of  human  resources  and  IT  infrastructure34.  The  Office  is  not  fully  functional  yet  and 
lacks the necessary tools to produce better qualitative and quantitative statistics. Stakeholders 
consider the data available to the public to be insufficient35. In December 2023, a project to 
support  the  functioning  of  the  Office  was  included  in  the  revised  Recovery  and  Resilience 
Plan  and  is  expected  to  be  completed  at  the  end  of  202536.  Plans  to  recruit  specialised 
scientific staff are ongoing.  

The implementation of several reforms financed by the Recovery and Resilience Facility 
aiming  to  improve  the  quality  of  justice  are  well  on  track.  The  implementation  of  the 
revised  judicial  map  in  administrative  justice  is  progressing  well37.  A  three-member 
monitoring committee was established in October 2023 to follow-up on the reform, while the 
information  systems  and  video  conferencing  services  have  been  tested  during  a  five-month 
pilot  phase that ended in April 202438. Regarding the establishment of the judicial  police39, 
the recruitments of officers for both the scientific/civil and police branches are ongoing. The 
first officers are expected to take up their duties in August 202440. The secondary legislation 
for  the  establishment  of  the  Judicial  Clerks  Performance  Tool  was  adopted  in  December 
202341  and  the  system  is  now  operational.  The  objective  of  this  performance-based 
compensation  scheme  is  to  diminish  the  time  required  for  the  different  tasks  assigned  to 

31   Figures 44 and 45, 2024 EU Justice Scoreboard. 
32   Indicatively, projects include the upgrading of the court records management system; the digitisation of court 
records and data forms; the video conferencing services in courts and penitentiaries and information services 
of courts’ e-dockets and exhibits. Input from Greece for the 2024 Rule of Law Report, pp. 9-11. 

33   Information received from Prosecutors, the Association of Judges and Prosecutors, the Supreme Court and 

the Athens Bar Association in the context of the country visit.  

34   2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 6. 
35   Vouliwatch,  Greek  Council  for  Refugees,  Refugee  Support  Aegean,  HIAS  Greece,  Generation  2.0  for 
Rights,  Equality  and  Diversity,  Reporters  United  (2024),  Rule  of  Law  Backsliding  Continues  in  Greece, 
Joint  Civil  Society  Submission  to  the  European  Commission  on  the  2024  Rule  of  Law  Report,  para  45; 
Contribution from Civil Liberties Union for Europe  for the 2024 Rule of Law  Report, pp.  10-11. GRECO 
also recommended to Greece to make publicly available data concerning the management of the workload as 
well  as  the  content  and  outcome  of  disciplinary  cases  against  judges  and  prosecutors.  GRECO  (2023), 
Fourth Evaluation Round, Second Addendum to the Second Compliance Report Greece, paras 34-37. 

36   Revised Annex to the Council Implementing Decision Amending Implementing Decision of 13 July 2021 on 

the approval of the assessment of the recovery and resilience plan for Greece.  

37   2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, pp. 7-8. 
38   Input from Greece for the 2024 Rule of Law Report, p.12; Information received from the Ministry of Justice 

in the context of the country visit.  

39   2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 8. 
40   Input from Greece for the 2024 Rule of Law Report, p. 6; Information received from the Ministry of Justice 

in the context of the country visit.  

41   Joint Ministerial Decision GG A’ 7462/29.12.2023. 

6 

 
 
judicial  clerks42.  In  parallel,  the  planned  recruitment  of  additional  judicial  clerks  is  also 
progressing43. 

The  new  judicial  map  in  civil  and  criminal  justice  is  a  major  reform  which  aims  at  a 
balanced distribution of cases among first instance judges and a speedier administration 
of justice in civil and criminal justice. In May 2024, Parliament adopted the law reforming 
the judicial map in civil and criminal justice44, despite lawyers and judicial clerks reacting to 
the  reform45.  Central  elements  of  the  reform  are  the  consolidation  of  the  first  degree  of 
jurisdiction  with  the  merging  of  the  magistrate’s  courts  and  the  courts  of  first  instance46  as 
well as the rationalisation of the number of courts47. The new judicial map intends to reduce 
workload  inequalities  and  alleviate  excessive  workload  at  the  first  instance  level48.  Τhe 
changes regarding the career track and salaries of magistrates and first instance judges take 
into consideration constitutional  constraints49. The adoption and implementation of the new 
judicial  map  will  entail  the  need  for  further  changes,  including  in  legislation  and 
infrastructure50.  The  judiciary  considers  the  reform  a  necessary  step  to  improve  the  quality 
and the efficiency of the justice system.  

Delays in settling outstanding lawyers’ fees in legal aid cases have been addressed. The 
Government took a series of legislative measures to facilitate the settling of unpaid lawyers’ 

42   The  criteria  for  potential  beneficiaries  include  a  commitment  to  expeditious  and  efficient  task  processing, 
proficiency  in  handling  multiple  tasks,  adaptability  to  new  technologies  and  processes  and  effective 
communication skills. Input from Greece for the 2024 Rule of Law Report, pp. 6-7. 

43   2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, pp. 8-9; Judges reported 
that  the  lack  of  judicial  clerks  impacts  on  their  working  conditions.  Information  received  from  the 
association of judges and prosecutors in the context of the country visit.  

44   Law 5108/2024. The law was the outcome of a long consultation with relevant stakeholders, which started in 
September 2023. Written contribution from Greece. The reform is included in the Recovery and Resilience 
Plan  (measure  ID  16575)  and  is  set  to  be  fully  implemented  by  the  end  of  2025.  Revised  Annex  to  the 
Council Implementing Decision Amending Implementing Decision of 13 July 2021 on the approval of the 
assessment of the recovery and resilience plan for Greece. 

45   Association of Judicial Clerks (2023), Decision of the Conference of the Association of Judicial Clerks, 29 
November – 2 December 2023. The Plenary of the Bar Associations stated that the reform does not lead to 
accelerating  the  administration  of  justice,  as  the  necessary  conditions  for  this  are  better  digitalisation, 
appropriate training for magistrates and necessary infrastructure. Statement of the Plenary of 20 April 2024. 
Both  associations  abstained  from  their  duties  for  several  weeks,  reacting  notably  to  the  possibility  of 
abolishing or merging courts in certain areas.  

46   Magistrates’ courts represent the small claims justice in Greece, while courts of first instance handle the bulk 

of civil and criminal litigations.  

47   In principle, the distribution of courts will respect the administrative division of the country; hence there will 
be a court of first instance in every regional unit, while a limited number of transitional and parallel seats is 
also foreseen. Written contribution from the Ministry of Justice in the context of the country visit, pp. 22-23.  
48   Until recently 916 magistrates were dealing with only 20% of the judicial caseload, while the remaining 80% 
was  assigned  to  1  200  first  instance  judges.  Once  the  new  structures  become  operational,  cases  should  be 
adjudicated within less than two years. Written contribution from the Ministry of Justice in the context of the 
country visit, p. 21. 

49   There  will  be  two  different  career  tracks  for  serving  magistrates  and  judges:  a  special  yearbook  for 
magistrates  and  a  general  yearbook  for  first  instance  judges.  Magistrates  will  be  given  the  possibility  to 
reclassify to the general yearbook after evaluation by the Supreme Judicial Council and targeted training in 
the National School of Judges. Written contribution from the Ministry of Justice in the context of the country 
visit, p. 23. See also, N.K. Alivizatos, Opinion on the new judicial map, 26 February 2024. 

50   Including the revision of the Code of Civil Procedure and the Code on the organisation of the courts and the 

status of judges. Information received from the Ministry of Justice in the context of the country visit.  

7 

 
 
fees for the provision of legal aid services51 and is now examining means to accelerate and 
digitalise  the  compensation  procedure  for  lawyers52.  Lawyers  welcomed  the  settling  of  all 
pending  claims,  while  they  highlighted  the  need  for  a  structural  solution,  as  the  current 
measures  cannot  prevent  similar  issues  from  reoccurring53.  The  Ministry  of  Justice 
established  a  working  group  to  revise  the  Code  of  Lawyers,  aiming  to  amend,  amongst 
others, the provisions on lawyer’s fees54. 

Efficiency 

Serious  challenges  remain  regarding  the  length  of  proceedings  before  civil  courts  and 
the  Council  of  State,  with  some  improvements  in  ordinary  administrative  courts. 
According  to  data  in  the  2024  EU  Justice  Scoreboard,  the  disposition  time  in  civil  and 
commercial cases at first instance courts has further deteriorated, reaching 746 days in 2022 
(compared  to  728  days  in  2021)  and  remaining  among  the  longest  in  the  EU55.  For 
administrative cases, the disposition time at first instance courts has significantly improved to 
464 days in 2022 from 595 days in 2021 (551 days in 2020)56. On the contrary, it remained at 
a very high level in the Council of State, namely 1 239 days (1 324 days in 2021)57. In 2022, 
the  clearance  rate  for  litigious  civil  and  commercial  cases  increased  significantly  to  93% 
(82% in 2021) but remains still clearly below 100% and among the lowest of the EU58. On 
the  other  side,  the  clearance  rate  in  2022  for  administrative  cases  was  127%59,  one  of  the 
highest  of  the  EU,  meaning  that  more  cases  were  resolved  than  came  in.  The  number  of 
pending administrative cases has been steadily dropping, though at the end of 2022, they still 
remained  among  the highest  in  the EU60. Stakeholders consider the  persisting  delays in  the 
administration of justice to constitute a systemic challenge for the judicial system61.  

Ongoing efforts to reduce the length of proceedings include the transfer of categories of 
non-litigious cases from courts to lawyers. From June 2024 onwards, several types of non-
contentious  cases,  including  mortgage  pre-notations,  the  provision  of  sworn  statements  and 
acts relating to inheritance, are performed by lawyers62. Both lawyers and judges welcomed 
the measure, which is expected to contribute to decongesting civil courts from a significant 
number  of  time-consuming  cases  and  improve  efficiency63.  The  reform  of  the  Code  of 

51   Laws  5016/2023,  5049/2023 and  5095/2024.  See  also,  2023  Rule  of  Law  Report,  Country  Chapter  on  the 

rule of law situation in Greece, p. 7. 

52   Input from Greece for the 2024 Rule of Law Report, p. 6. 
53   Information received from the Athens Bar Association in the context of the country visit.  
54   The  working  group,  which  includes  Bar  Associations,  will  also  examine  the  admission  into  the  legal 
profession, disciplinary rules and professional incompatibilities. Information received from the Ministry of 
Justice and the Athens Bar Association in the context of the country visit.  

55   Figure 6, 2024 EU Justice Scoreboard. 
56   Figure  9,  2024  EU  Justice  Scoreboard,  Figure  9,  2023  EU  Justice  Scoreboard,  and  Figure  10,  2022  EU 

Justice Scoreboard. 

57   Ibidem. 
58   Figure 11, 2024 EU Justice Scoreboard. 
59   Figure 12, 2024 EU Justice Scoreboard. 
60   Figure 15, 2024 EU Justice Scoreboard. 
61   Information received from Athens Bar Association, Supreme Court and Council of State in the context of the 
country visit; Contribution from Civil Liberties Union for Europe for the 2024 Rule of Law Report, pp. 12-
13; Joint Civil Society Submission to the European Commission on the Rule of Law Report, paras 46-52. 

62   Law 5095/2024.  
63   Indicatively,  in  2023,  the  Court  of  First  Instance  of  Athens  dealt  with  12  000  mortgage  cancellation 
procedures, while the Magistrates Court of Athens issued 7 190 sworn statements. Information received from 

8 

 
 
 
Criminal  Procedure  also  seeks  to  accelerate  criminal  proceedings,  particularly  with  the 
abolition of the pre-trial judicial council procedure for certain categories of offences and the 
restriction  of  the  number  of  adjournments64.  However,  judges  and  lawyers  fear  that  the 
elimination of the pre-trial procedure may increase the number of cases brought to trial and, 
subsequently,  also  the  length  of  proceedings65.  In  administrative  justice,  in  July  2024,  the 
preliminary procedure before the Council of State was reformed to accelerate the adjudication 
of cases66. The implementation of a similar accelerated procedure by the Court of Audit for 
specific cases relating to reductions of pensions has significantly reduced the backlog of the 
Court67, which has indicated its preference for a legislative initiative allowing for the extra-
judicial  settlement  of  these  cases68.  Technical  support  has  been  mobilised  for  reducing  the 
backlog and the disposition time of the Courts of First Instance of Athens and Thessaloniki69. 

II. 

ANTI-CORRUPTION FRAMEWORK  

The National  Transparency Authority (NTA)70 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 emphasis on coordination of control bodies and the efficiency of their 
operations71, and provides relevant instructions. The Directorate General of the Financial and 

the  Ministry  of  Justice  in  the  context  of  the  country  visit.  The  President  of  the  Athens  Bar  Association 
welcomed  the  new  law  considering  that  it  confirms  the  important  role  of  lawyers  in  the  administration  of 
justice, upgrades their status  and expands their professional activity. Athens Bar Association (2024), Press 
release of the President, 14 March 2024.  

64   Law 5090/2024. 
65   Information  received  from  the  Athens  Bar  Association  and  Association  of  judges  and  prosecutors  in  the 

context of the country visit. 

66   Law 5119/2024. According to the reform, cases will be assigned to a single judge and will be decided by a 
three-member  panel  unless  the  legal  issues  raised  require  a  hearing.  The  law  also  provides  for  stricter 
deadlines for the notification of pleadings, the submission of public authorities’ input and the gathering of 
evidence. Written  contribution  from  Greece.  Judges  consider  that  the  proposed procedure  could  accelerate 
the  adjudication  of  appeals  on  points  of  law  but  may  have  an  adverse  effect  for  requests  for  annulment. 
Information received from the Council of State in the context of the country visit. The plenary of the Bar 
Associations issued a statement opposing the reform, on the grounds that it restricts the right to be heard and 
to  effective  judicial  protection.  They  also  criticised  that  there  was  no  prior  consultation  with  lawyers. 
Plenary of the Bar Associations (2024), Decision of 15 June 2024.   

67   See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 9-10. Based on this 
procedure, 1 341 judgments have been delivered, corresponding to 70 819 claims. Input from Greece for the 
2024 Rule of Law Report, p. 13.  

68   Information received from the Court of Audit in the context of the country visit.  
69   Project 24EL13, ‘Supporting the reduction of backlog in the first instance courts of Athens and Thessaloniki 

(pilot courts)’, is funded by the Technical Support Instrument of the European Commission. 

70   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. 

71   The  NTA  chairs  the  meetings  of  the  National  Coordinating  Body  for Audit  and Accountability  (ESOEL) 
established  by Article  103  of  Law  4622/2019.  ESOEL’s  tasks  include  the  dissemination  of  good  practices 
and  development  of  common  standards  and  tools  for  the  prevention,  detection  and  control  of  fraud  and 
corruption. Seventeen public bodies active in the field of law enforcement participate. In 2023, the Internal 
Audit  Unit  of  the  Ministry  of  Economy  and  Finance  and  the  Hellenic  Labour  Inspectorate  were  added  to 
ESOEL. See input from Greece for the 2024 Rule of Law Report, p. 17. 

9 

 
 
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  Bodies72  exercises  internal  control  and  investigates  crimes, 
including  corruption,  committed  by  various  entities73.  The  Court  of  Audit  is  the  Supreme 
Financial Court and Audit Institution auditing the use of public funds.  

The perception among experts and business executives is that the level of corruption in 
the  public  sector  is  high.  In  the  2023  Corruption  Perceptions  Index  by  Transparency 
International, Greece scores 49/100 and ranks 24th in the European Union and 59th globally74. 
This  perception  has  been  relatively  stable  over  the  past  five  years75.  The  2024  Special 
Eurobarometer on Corruption shows that 98% of respondents consider corruption widespread 
in  their  country  (EU  average  68%)  and  63%  of  respondents  feel  personally  affected  by 
corruption in their daily lives (EU average 27%)76. As regards businesses, 95% of companies 
consider that corruption is widespread (EU average 65%) and 70% consider that corruption is 
a problem when doing business (EU average 36%)77. Furthermore, 24% of respondents find 
that  there  are  enough  successful  prosecutions  to  deter  people  from  corrupt  practices  (EU 
average  32%)78,  while  13%  of  companies  believe  that  people  and  businesses  caught  for 
bribing a senior official are appropriately punished (EU average 31%)79.  

The National Anti-Corruption Action Plan (NACAP) for 2022-2025 was updated and its 
implementation is on track. The NACAP was updated at the end of 2023 to take account of 
developments since its initial adoption in 2022, incorporating sixteen actions of the National 
Integrity  System80  and  new  actions  such  as  the  update  of  the  Code  of  Conduct  for  Police 
Officers81.  The  inter-institutional  Central  Coordination  Committee  approved  the  updated 
NACAP on 21 March 2024 and is it now pending final approval by the Council of Ministers. 
In 2023, out of 129 actions envisaged under the NACAP, 47 (36%) were completed (23 or 

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

74   Transparency International (2024), Corruption Perceptions Index 2023. 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). 

75   In 2019 the score was 48 while in 2023 the score is 49. 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. 

76   Special Eurobarometer 548 on Citizens’ attitudes towards corruption in the EU (2024). The Eurobarometer 
data  on  citizens’  corruption  perception  and  experience  is  updated  every  year.  The  previous  data  set  is  the 
Special Eurobarometer 534 (2023). 

77   Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024). The Eurobarometer 
data  on  business  attitudes  towards  corruption  as  is  updated  every  year. The  previous  data  set  is  the  Flash 
Eurobarometer 524 (2023). 

78   Special Eurobarometer 548 on Citizens’ attitudes towards corruption in the EU (2024).  
79   Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024).  
80   The main objectives of the National Integrity System (NIS) 2022-2025, established by Ministerial Decision 
No.  707/18852/05.12.2022,  are  the  prevention  and  tackling  of  corruption,  strengthening  transparency, 
integrity, and accountability in the public administration, and public information and awareness-raising. See 
2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 11.  

81   Written input from NTA for the 2024 Rule of Law Report, p. 1. 

10 

 
 
18%) in 2022), 68 (53%) are being implemented (84 (65%) in 2022) and 14 (11%) have not 
yet started (22 or 17% in 2022), which shows a steady increase in implementation over the 
past year. Completed actions include development of a special anti-corruption and anti-fraud 
strategy  in  the  context  of  the  management  of  Recovery  and  Resilience  Funds,  and  the 
digitisation of more  than 150 administrative procedures in  2023,  further reducing  in-person 
interaction  between  citizens  and  state  employees  and  thus  eliminating  corruption  risks82.  In 
January  2024,  the  e-Peitharxika  application,  an  electronic  database  for  registration  and 
follow-up of disciplinary cases in the public sector, became fully operational. The aim is to 
enhance  citizens’  trust  in  public  institutions,  improve  the  administration  of  disciplinary 
justice, and reinforce transparency and accountability efforts by the Ministry of Interior and 
NTA83. 

Some  further  progress  has  been  made  to  establish  a  track  record  of  prosecutions  and 
final judgments in corruption cases, including in high-level corruption cases. The 2023 
Rule  of  Law  Report  recommended  to  Greece  to  ‘step  up  efforts  to  establish  a  robust  track 
record  of  prosecutions  and  final  judgments  in  corruption  cases,  including  high-level 
corruption’84. Prosecutions and final judgments related to corruption, including for high level 
corruption85, have been taken forward though are still limited. In 2023, there were 44 ongoing 
criminal investigations for bribery and corruption offences at first instance (compared to 80 
in  2022),  224  investigations  concluded  (74  in  2022)  and  21  cases  referred  to  a  hearing 
(compared  to  17  in  2022).  There  were  34  convictions  at  appeal  and  first  instance  levels 
combined  (compared  to  32  in  2022)  and  16  acquittals  (compared  to  15  in  2022)86.  The 
prosecution  services  identified  a  number  of  challenges  to  investigate  corruption  and 
economic  crime  such  as  difficulties  to  obtain  evidence  through  judicial  or  administrative 
assistance, the management of time limits to carry out preliminary examinations in complex 
cases,  and  risks  of  leaks  of  confidential  information  to  the  media87.  To  address  challenges 

82   NTA (2024), NACAP 2022-2025 Implementation Report 2nd Semester 2023; Input from Greece for the 2024 
Rule of Law Report, pp. 22-23; Written contribution from NTA in the context of the country visit to Greece, 
pp. 1-2.  

83   National  Transparency  Authority  (2024),  Press  release  ‘E-peitharxika  Application’.  See  also  Input  from 

Greece for the 2024 Rule of law Report, p. 25. 

84   2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 2, which reported that 
some  progress  had  been  achieved  on  implementing  the  similar  recommendation  in  the  2022  Rule  of  Law 
Report, p. 2.’ 

85   According to data on high level corruption cases provided in July 2024, one case for bribery of judges and 
two for bribery of employees of international organisations were concluded. Ongoing  prosecutions include 
one  case  for  bribery  of  politicians,  two  for  bribery  of  judges  and  four  for  bribery  of  employees  of 
international organisations. At appeals court level, there was one conviction (imprisonment combined with 
fines)  for  bribery  of  national  public  officials  and  three  for  passive  bribery  (imprisonment).  Written 
contribution from Greece in the context of the country visit. However, it is not specified whether these cases 
pertain  to  high-level  officials,  for  instance  in  the  case  of  the  employees  working  in  international 
organisations.  There  are  more  cases  concluded,  ongoing  or  brought  to  trial  for  fraud  (15,  2  and  12 
respectively) and money laundering (9, 25 and 7 respectively) than for bribery. 

86   Written  contribution  from  the  Ministry  of  Justice  in  the  context  of  the  country  visit  to  Greece,  p.  32  and 

input from Greece for the 2024 Rule of Law Report, pp. 43-44. 

87   They  also  point  to  the  fact  that  the  effectiveness  of  investigations  and  prosecutions  cannot  be  determined 
solely on the basis of statistical and quantitative criteria, e.g., the way statistics of case files at local level are 
consolidated at central level could reduce the numerical assessment as individual case files are linked to the 
central case files. Training of financial crime  prosecutors continued and for the first time, a  representative 
was appointed as a national expert to take part in the country evaluations of the United Nations Convention 
against  Corruption.    Written contribution  from  the  Financial  Crime  Department  of  the  Public  Prosecutor’s 
Office, in the context of the country visit to Greece, pp. 3-4 and 11. 

11 

 
 
identified  in  collecting  corruption  statistics,  the  Ministry  of  Justice  created  a  dedicated 
working group to monitor the track record of prosecutions and final judgments in corruption 
cases, including high level corruption88. The group is operational and held its first meeting on 
14  April  2024  during  which  it  launched  the  online  platform  and  proposed  the  collection  of 
additional data categories89. Cooperation between the EPPO and the police and the  national 
prosecution  offices  is  overall  satisfactory90.  The  OECD  reported  concerns  about  Greece’s 
poor  track  record  of  the  enforcement  of  the  Anti-Bribery  Convention  and  the  lack  of  any 
convictions  with  sanctions  for  foreign  bribery91.  In  light  of  these  developments,  including 
efforts to improve the quality of statistics, including for high-level corruption cases, there has 
been some further progress in the implementation of the recommendation made in the 2023 
Rule of Law Report. 

The legal framework for combatting corruption and foreign bribery was strengthened. 
A  series  of  important  and  substantive  amendments  to  enhance  the  fight  against  corruption 
were  made  to  the  Criminal  Code  and  Criminal  Procedure  Code  that  entered  into  force  in 
January 202492. The OECD welcomed Greece’s efforts to implement several of its previous 
recommendations, including on reforming its corporate liability regime for (foreign) bribery 
offences93. The changes to the Criminal Code introduce for the first time in the Greek legal 
order  the  criminal  liability  of  legal  persons  and  entities  for  corruption  and  bribery  offences 
regardless of any liability of natural persons involved94. In addition, the financial penalties for 
bribery of political persons were significantly increased while the financial penalties for the 

88   Decision  No  20459  of  29.03.2024  of  the  Minister  for  Justice,  The  Working  Group  is  composed  of 
prosecutors  from  different  Court  levels  and  one  official  from  the  Statistics  Department  of  the  Ministry  of 
Justice.  Its  tasks  involve  monitoring,  evaluating  and  categorising  corruption  statistics  in  order  to  collect 
statistics  in  a  timely  manner  and  include  more  qualitative  characteristics  depending  on  the  gravity  of  the 
corruption crimes involved. Written contribution from the Ministry of Justice in the context of the country 
visit to Greece, p. 30. In addition, the Office for the Collection and Processing of Judicial Statistics (JustStat) 
reported  that  a  new  information  system  is  being  created  that  will  be  interconnected  with  the  various 
Integrated Judicial Systems to allow for a faster and better-quality collection of judicial statistics. Input from 
Greece for the 2024 Rule of Law Report, pp. 14-15. 

89  These include pending and closed cases, cases with prosecution, cases forwarded to the court of first instance, 
asset freezes, and follow-up of cases at trial stage. Written contribution from the Ministry of Justice in the 
context of the country visit to Greece, p. 30.  

90  To improve the support to the European Delegated Prosecutors, Greek authorities will second 10 specialised 
financial investigators to the Athens local EPPO office in 2024. Input from EPPO for the 2024 Rule of Law 
Report p. 20. In 2023, EPPO investigated 9 corruption cases in Greece that amount to 9% of EPPO cases in 
Greece.  EPPO  (2024),  Annual  Report  2023,  p.  35.  The  EPPO  also  expressed  concerns  about  certain 
limitations related to the lifting of immunities. EPPO’s input to the 2024 Rule of law Report, p. 21.  

91   OECD (2024), Phase 4 Two-Year Written Follow-Up Report, pp. 5, 8 and 9. The OECD did note that Greece 
launched three new foreign bribery investigations since 2022 of which one has been terminated and two are 
at the preliminary investigation phase. 

92   Law 5090/2024, Government Gazette, Series I, No 30/23.2.2024 and Law 5095/2023, Government Gazette, 

Series I, No 40/15.3.2024.  

93   In  its  latest  report  on  Greece’s  implementation  of  the  Anti-Bribery  Convention,  the  OECD  welcomed 
Greece’s efforts to implement several of its previous recommendations, including on reforming its corporate 
liability regime for (foreign) bribery offences, extending whistleblower protection to include foreign bribery, 
and ensuring that the Economic Crime Prosecutor possesses the authority to both investigate and prosecute 
foreign bribery cases. OECD (2024), Phase 4 Two-Year Written Follow-Up Report (see e.g., pp. 4-5, 7-9 and 
14).  See  also  2023  Rule  of  Law  Report,  Country  Chapter  on  the  Rule  of  Law  Situation  in  Greece,  p.  14 
(footnote 114). 

94   Input  from  Greece  to  the  2024  Rule  of  Law  Report,  p.  41  and  information  received  from  the  Ministry  of 

Justice and Prosecution Services in the context of the country visit to Greece.  

12 

 
 
corruption  and  bribery  of  judicial  officials,  including  judges  seconded  to  international 
organisations, regardless of whether or not they exercise judicial functions, were redefined95. 
Furthermore, the Code of Criminal Procedure now specifically provides the Public Prosecutor 
of Economic Crime with the competence to initiate criminal proceedings directly instead of 
first  assigning  the  case  to  local  prosecutors  as  was  previously  the  case.  This  change  is 
designed to avoid unnecessary procedural delays in the investigation of corruption as well as 
foreign bribery cases96. The law now also requires prosecutors to  report all convictions and 
sanctioning decisions against legal persons in bribery cases to the Independent Authority for 
Public Revenue and to the Hellenic Single Public Procurement Authority97. 

The  National  Transparency  Authority  maintained  its  level  of  activities.  The  NTA 
continued  its  efforts  to  ensure  an  adequate  level  of  resources  and  to  recruit  staff  to  fill  a 
significant  number  of  vacant  posts  (122  in  early  March  2024  compared  to  103  in  2022)98. 
Lengthy recruitment processes and the lack of extra remuneration incentives are mentioned as 
challenges  to  attract  administrative  and  audit  staff99.  In  November  2023,  three  members  of 
the  Management  Board  of  the  NTA,  including  its  President,  resigned  and  the  process  of 
filling the vacancies is expected to be completed in the third quarter of 2024100. The NTA has 
been run by an interim Governor for the past two years. The recruitment procedure for a new 
Governor will be launched after the new members of the Management Board are appointed. 
The  delays  in  recruitment  of  top  positions  have  been  criticised  by  stakeholders101. 
Nevertheless, the NTA managed to maintain its level of activity in 2023. The NTA in 2023 
received  3 565  complaints  on  alleged  corruption,  fraud,  and  maladministration  (3 513  in 

95   The penalties for passive bribery of politicians were increased from two hundred thousand (200 000) to four 
million (4 000 000) euros while those for active bribery of politicians increased from one hundred thousand 
(100 000) to five hundred thousand (500 000) euros. Law No 5090/2024 also provides for an increase in the 
maximum prison limit for all felonies, including corruption crimes, from 15 to 20 years. Moreover, Greek 
criminal laws now apply to nationals and foreigners, irrespective of the laws of the place where the offence 
was committed. Written contribution from the Ministry of Justice received in the context of the country visit 
to  Greece,  pp.  2–  7.  In  Greece’s  next  evaluation  phase,  the  OECD  will  continue  to  monitor  whether  the 
(increased) sanctions against natural and legal persons are effective, proportionate and dissuasive in practice, 
which so far has been difficult to assess  especially given Greece’s lack of enforcement of the Convention.  
OECD (2024), Phase 4 Two-Year Written Follow-Up Report (pp. 4-5 and 7-8). 

96   Prosecutors must close their preliminary investigation within six months after a case has been brought before 
them, unless the Head of the Economic Crime Department determines that the  nature of the case or of the 
acts  to  be  investigated  justifies  an  extension  of  the  time  limit.  Written  contribution  from  the  Ministry  of 
Justice  in  the  context  of  the  country  visit  to  Greece.  See  also  OECD  (2024),  Phase  4  Two-Year  Written 
Follow-Up Report, pp. 4 and 9. 

97   Information received from Greece in the context of the country visit. See also OECD (2024), Phase 4 Two-

Year Written Follow-Up Report, p. 13. 

98   15 Inspectors-Auditors (are expected to take up duties within the first semester of 2024. In addition, a call to 
recruit  an  extra  10-15  Inspectors-Auditors  for  the  NTA’s  Regional  Units  will  be  published  in  2024.  The 
number  of  vacancies  increased  in  2023  compared  to  2022  due  to  retirements  and  termination  of  previous 
secondments. Input from Greece for the 2024 Rule of Law Report, p. 16 and NTA written contribution in the 
context of the country visit to Greece (pp. 2-4).  

99   Information received from the NTA in the context of the country visit to Greece.  
100  Written contribution from the NTA in the context of the country visit to Greece, pp. 9-10.  
101  Information received from Vouliwatch  and Transparency International in the context of the country visit to 
Greece. The Civil Liberties Union for Europe has also  expressed concern about the selection procedure of 
the  director  and  management  board  members  in  that  it  does  not  provide  for  the  super-majority  vote 
guarantees of Article 101A(2) of the Constitution, which apply to other independent authorities. Contribution 
from Civil Liberties Union for Europe for the 2024 Rule of Law Report, p. 15.  

13 

 
 
2022)  and  carried  out  700  audits  and  inspections  (575  in  2022)102.  The  NTA’s  cooperation 
with other independent entities continued to be good and several trainings were organised103. 

Implementation  of  the  new  law  on  asset  declarations  is  on  track,  with  a  significant 
percentage  of  verifications  completed.  Law  5026/2023  on  asset  declarations  adopted  in 
February  2023  extensively  revamped  the  previous  system  of  asset  disclosures104.  The  2023 
Rule of Law Report highlighted significant progress on the 2022 recommendation to ensure 
the effective and systematic verification of the accuracy of asset disclosures filed by all types 
of public officials105. The total number of audits carried out by the Audit Committee in 2023 
with reference to a five-year period was 16 818. The audit target of 5% for the first year as 
provided  for  by  the  law106  was  therefore  reached  and  surpassed  to  reach  6%107.  As  regards 
post-audit activities, 28 natural persons were reported to public prosecutors in 2023 because 
they  repeatedly  failed  to  fulfil  their  obligations  during  the  last  five  years108.  In  terms  of 
enhancing transparency, a noteworthy development is represented by Law 5104/2024 which 
aims  to  streamline  and  improve  the  administrative  processes  for  citizens  and  tax 
administration109. The electronic platform e-pothen has been upgraded to allow for the higher 
number110 of declarations and files to be registered more efficiently and transparently as the 
necessary  financial  data  will  be  retrieved  electronically  from  banks  directly  through  the 
interconnection with the e-pothen platform111. Overall, the implementation of the law is going 

102  Of these cases 17 were referred for criminal prosecution to the judicial authorities (13 in 2022). In addition, 
83  cases  were  referred  to  the  competent  disciplinary  authorities  (55  in  2022)  and  33  (41  in  2022)  were 
referred for both criminal and disciplinary prosecution. A total of 315 civil servants and elected officials (186 
in  2022)  were  referred  to  disciplinary  boards.  Written  contribution  from  the  NTA  in  the  context  of  the 
country visit to Greece, p. 9. 

103  For  instance,  the  NTA  signed  Memorandum  of  Understanding  with  the  Independent Authority  for  Public 
Revenues  (IAPR),  the  Data  Protection  Authority,  the  Institute  of  Education  Policy  and  other  institution. 
Under the Memorandum, a digital platform will be launched enabling IAPR’s employees or persons working 
with  the  authority  to  report  corruption  or  integrity  incidents  as  well  as  EU  law  infringements.  The  NTA 
organised  several  awareness-raising  as  well  as  a  training  programme  on  internal  audit  with  the  Public 
Employment  Service  (DYPA)  aimed  at  developing  internal  audit  performance.  Input  from  Greece  to  the 
2024 Rule of Law Report, pp. 19-20, 24 and 38-40. 

104  Changes involving the functioning of assets control system involved the preparation, submission, and control 

of declarations and penalties.   

105  See 2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, pp. 12-13.  
106  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.  

107  The scheduled target of 5% set by the Law was outstripped by 20%, leading to a 6% of audits for the first 
year. Information and written contribution received from the Parliamentary Committee on asset declarations 
(CIDA) in the context of the country visit to Greece.  

108  According to information received from the CIDA, the number of prosecutions in relation to the year 2023 is 

expected to increase over the course of 2024 as the new system ‘catches up’.  

109 Some of the improvements: simplification of bureaucracy to assist taxpayers, enabling digital communication 
with the Hellenic Authority for Communication Security and Privacy; Transition from paper-based to digital 
correspondence  between  the  tax  administration  and  taxpayers;  specific  timeframe  for  tax  audits,  typically 
one year from the order notification, with the option for a six-month extension; expansion of the issuance of 
tax information. 

110  Number of persons obliged to submit an asset declaration has increased by 50%. Total number of persons 
with obligation for submission of the year 2023 were 290 856. Written contribution from the CIDA in the 
context of the country visit to Greece.  

111  The  new  law  on  asset  declaration  incorporates  the  data  protection  safeguards  of  the  EU  General  Data 
Protection Regulation in relation to the obligated persons and bodies in the public and private sectors and the 
e-pothen system.  Written contribution from the CIDA in the context of the country visit to Greece, p. 1. The 
law indeed aims to avoid unnecessary inconvenience to collect the required information for the declaration 

14 

 
 
 
well although the limited number of staff  and financial resources  risk making it difficult  to 
sustain  the  implementation  rate  at  the  same  level112.  Civil  society  organisations,  however, 
continued  to  express  concerns  as  to  the  transparency  and  effectiveness  of  the  Audit 
Committee’s scrutiny113. 

Work  on  developing  codes  of  conduct  for  political  advisers,  ministers  and 
parliamentarians  and  guidelines  for  the  police  continued.  Following  last  year’s  Rule  of 
Law  Report114,  various  planned  codes  of  conduct,  including  for  high-level  officials,  have 
been taken forward. In the second half of 2023, the NTA finalized a draft Code of Conduct 
for  Political  Appointees  and  Special  Advisors  that  is  undergoing  an  internal  round  of 
consultation within the Government prior to its publication expected in the second quarter of 
2024.115 The update to the Codes of Conduct for Members of Government and Members of 
Parliament  envisaged    in  the  NACAP,  was  finalised  following  the  opinion  of  the  NTA’s 
Ethics Committee in April 2024, and should be published by May 2024116. The Independent 
Authority  for  Public  Revenue  (IAPR)  published  a  Code  of  Ethics  for  its  employees  in 
November  2023117.  Following  last  year’s  reported  plans  to  improve  integrity  in  the  police 
force, the 2004 Code of Police Ethics will be complemented by a new Guide118. The Guide 
will  introduce  provisions  with  detailed  guidance119  on  issues  of  integrity  and  transparency 
and on handling corruption incidents and integrity issues within the police120.  

(e.g., certificates from each bank for the balance of accounts, credit cards etc.). This contributes to increasing 
the number of declarations checked each year by introducing an annual audit target by the Audit Committee, 
while  avoiding  the  fragmentation  of  the  audit  work.  However,  difficulties  emerged  in  relation  to 
interoperability issues (interconnection of banks) and data collection) which is why the period for submitting 
asset declarations for 2023 was extended until the end of June 2024. Written contribution from the Ministry 
of Justice in the context of the country visit to Greece, p. 36.  This delay was criticised by some CSOs such 
as Vouliwatch. Information received from Vouliwatch in the context of the country visit to Greece. 

112  CIDA has asked for more resources considering the positive results of their work. Information received from 

CIDA in the context of the country visit to Greece. 

113  Concerns  related  to  the  unjustified  reduction  of  the  availability  period  of  the  report  of  the  Parliamentary 
Committee (from 7 to 3 years); the reduction of the availability of the information online reduced to three 
years; the repeal of the obligation to declare cash exceeding EUR 30 000; the attribution of audit tasks to 
only  one  single  body  –  CIDA-  considering  the  high  numbers  of  declarations;  the  lifting  of  confidentiality 
remaining optional. CSOs Joint submission for the 2024 Rule of Law Report pp. 21-22. 
114  2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 15. 
115  Written contribution from  the  NTA in the context of the country visit to Greece, p. 6. See also input from 

Greece for the 2024 Rule of Law Report, p. 28. 

116  The proposed code of conduct covers ministerial cabinets and their advisors. This will be signed off by the 
Prime  Minister.  The  President  of  Parliament  must  also  review  the  text  to  see  whether  changes  to  the 
Parliament’s 2016 Code of Conduct and Rules of Procedure need amending to cover those members who are 
also  government  ministers.  The  NTA  intends  to  carry  out  awareness-raising  activities  about  these  Codes. 
Written contribution (p.6) and information received from the General Secretariat of Legal and Parliamentary 
Affairs, and the NTA in the context of the country visit to Greece.  

117  Input from Greece for the 2024 Rule of Law Report, p. 28.  
118  2023 Rule of Law Report, pp. 15-16. See also GRECO (2022) Fifth Evaluation Round – Evaluation Report 

for Greece, pp. 43-47. 

119  The  Guide  will  serve  as  a  syllabus  of  the  police  ethics  courses  that  are  included  in  various  police 
trainings/seminars. The corresponding draft Ministerial Guidelines are being finalised and elaborated by the 
competent independent authorities, including the NTA and the Ombudsman. Input from for the 2024 Rule of 
Law Report, p. 29. 

120  Ibid. Information also received from the Ministry of Citizen Protection and the Internal Affairs Unit of law 
enforcement bodies in the context of the country visit to Greece. Guidelines are also being developed for all 
police personnel when dealing with incidents of violence and harassment.  

15 

 
 
The implementation of rules on lobbying and gifts is ongoing with the number of entries 
in the lobby register  increasing slightly  and information  from the gifts registry is  now 
publicly  available.  Lobbying  legislation,  in  force  since  2021,  obliges  high-level  officials 
with  executive  and  legislative  functions  to  declare  their  contacts  with  lobbyists121.  It  also 
mandated  the  setting  up  of  a  lobby  register,  which  has  been  operational  since  December 
2022122. As of July 2024, the publicly accessible lobby register only had 20 registrations, a 
slight increase from the 17 recorded in December 2023123. Civil society organisations noted 
that no statistics have yet been released on the functioning of the lobby register124. However, 
the NTA will draft a report with statistical data concerning the operation of the Registry for 
the  calendar  year  2023  by  the  end  of  2024125.  There  are  also  two  publicly  available  gift 
registries,  one  for  the  President  of  the  Republic  and  another  for  the  Prime  Minister  and 
Members  of  Government.  According  to  a  Ministerial  Decision  adopted  in  November  2023, 
items  offered  as  gifts  will  become  State  property126.  The  received  gifts  are  recorded  in  a 
Special  Electronic  Book  administered  and  managed  by  the  Prime  Minister’s  Office127.  An 
extract  from  the Electronic Register showing the gifts  offered in  2022-2023 to  Members of 
Government and the Prime Minister was published on the Prime Minister’s  website128. The 
slow  implementation  of  the  rules  on  lobbying  has  been  raised  by  some  civil  society 
organisations that have asked for more transparency on the functioning of both the lobby and 

121  Law  4829/2021  stipulates  that  all  interest  representatives  should  register  in  the  Transparency  Register 
(operational  since  2022)  and  they  should  submit  their  annual  declarations  in  the  month  of  January  of  the 
same  year;  for  the  legislature  and  the  executive  they  have  to  submit  declaration  in  the  month  of  May  for 
lobbying activities exercised during previous year. 

122  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.  The 
Transparency  Register  is  meant  to  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. See 2023 Rule of Law Report Country Chapter on the rule of law situation in Greece, p. 16.  

123  In the context of the country visit to Greece, the NTA explained that there is a lack of familiarity in Greece 
about  the  need  for  formal  lobbying  rules  since  such  practices  have  been  always  informal.  NTA  has  been 
engaged in raising awareness activities in close cooperation with the Ministry of the Interior with officials 
and competent bodies required to submit declarations when they meet lobbyists. Following this awareness 
campaign an increase on lobbying registrations is expected in 2024. 

124 Joint Civil Society Submission on the 2024 Rule of Law Report, p. 19. The Greek authorities explained that 
the statutory deadlines for  the submission of annual activities for both lobbyists and public officials  (were 
extended  to  enable  the  obliged  persons  to  comply  with  the  new  regulatory  framework  and  familiarize 
themselves with the process of submitting an annual declaration through the lobby register. 

125  The  NTA will submit the 2022 Report to the Parliamentary Committee and  upload  it to the  lobby register 
website by the end of July 2024. However, it will not contain any statistical data as the register was not yet 
fully operational at the time. 

126  Ministerial Decision 18552/08.11.2023 (Government Gazette, Series II, No. 6427) and Articles 14 to 19 of 
Law 4829/2021 (Government Gazette, Series I, No 166) govern the rules on gifts. The Ministerial Decision 
lays down the conditions, procedures, and technical specification for the registration and publication of gifts. 
Written  contribution  from  the  Ministry  of  Justice  in  the  context  of  the  country  visit  to  Greece,  p.  39  and 
input from Greece for the 2024 Rule of Law Report, p. 33. 

127  Gifts  must  be  recorded  and  information  about  them  made  public  when  their  estimated  value  exceeds  two 
hundred euros or when they are of a particular national, historical, cultural or  artistic value, irrespective of 
their value. Written contribution from the Ministry of Justice in the context of the country visit to Greece, p. 
39. 

128 There is, however, no information on the approximate value of the gift itself recorded in the public registry. 
The  publication  follows  Decision  No  4753/08.05.2024  of  the  Secretary-General  of  the  Prime  Minster. 
Written contribution from the Ministry of Justice in the context of the country visit to Greece, p. 39.  

16 

 
 
gift registries129. The NTA has also been raising public awareness on the lobbying legislation, 
including with public officials130. 

Audits of political  parties carried  out under the new rules on political  party financing 
indicated  a  better  level  of  compliance.  In  2023,  the  Committee  of  Parliament  for  the 
Investigation of Declarations of Assets (CIDA) carried out the audits (referring to 2021 fiscal 
year)  on  18  political  parties,  out  of  which  it  proposed  penalties  for  seven  parties  and  sent 
letters of compliance to one party. The President of the Hellenic Parliament adopted CIDA’s 
proposal  and  imposed  sanctions131.  The  CIDA  concluded  the  audit  of  17  political  parties’ 
financial statements for 2022 and proposed sanctions for 5 of them and letters of compliance 
for 2 parties132.  The CIDA is assessing the findings and conclusions related to the financial 
data of parties for the two 2023 elections and will begin its audit of the financial statements 
of  the  political  parties  once  they  are  submitted  by  the  end  of  May  2024133.  The  CIDA  has 
noted a significant  level  of compliance with  the  new legal  framework from  all the political 
parties  based  on  the  data  the  parties  submitted  to  it134.  Some  civil  society  organisations 
continue to consider that the audit mechanisms could be more transparent and regret that the 
deadline for submitting financial statements is often extended and delayed135.  

The  material  scope  of  the  law  on  the  protection  of  whistleblowers  was  extended  to 
corruption  offences  and  the  external  reporting  channel  became  operational.  In  2023, 
several Ministerial Decisions were adopted to implement the 2022 Whistleblower Protection 
Act  to  clarify  the  scope  of  application,  the  procedure  for  submission,  duties  and 

129  They claim, for instance, that it should be made clearer what obligations are imposed on lobbyists and that 
the functioning of the system should be made more transparent.  Doubts remain as to the compliance with 
legally required gift lists, particularly in the case of members of Parliament. Article 4(2) of the Parliament’s 
Code of Conduct provides for a list of gifts and benefits offered to Members of Parliament. Vouliwatch had 
submitted  requests  to  access  the  lists  of  gifts  offered  to  Cabinet  Members  and  Deputy  Minister  and  to 
Members  of  Parliament.  Joint  Civil  Society  Submission  on  the  2024  Rule  of  Law  Report,  pp.  19-20. 
GRECO  had  issued  a  recommendation  that  Greece  adopt  a  comprehensive  code  of  conduct  for  persons 
entrusted with top executive functions on issues such as contacts with lobbyists and other third parties, gifts 
and  other  advantages,  among  others,  and  made  easily  accessible  to  the  public,  which  has  not  been 
implemented yet. GRECO (2022, 2024), Fifth Evaluation Round, Evaluation Report and Compliance Report 
for Greece, pp. 18 (para. 58), 60 and 4-6 respectively. 

130  The NTA noted that the phenomenon of lobbying is not very common to the public discourse in Greece. It 
has  therefore  carried  out  awareness-raising  activities  on  the  law  4829/2021,  which  will  be  complemented 
within  2024  by  a  more  targeted  awareness  raising  plans  for  interest  representatives  and  public  officials. 
Information from NTA in the context of the country visit to Greece. 

131  Input from Greece for the 2024 Rule of Law Report, p. 33. 
132  Written contribution from the CIDA in the context of the country visit to Greece, p. 7. 
133  Written  contribution  from  the  CIDA  in  the  context  of  the country  visit  to  Greece,  p.  7. Collection  of  data 
from political parties, candidates, marketing, media and polling companies for the pre-election periods of the 
two national elections of 2023 was extended and will be checked by CIDA in 2024. Input from Greece for 
the 2024 Rule of Law Report, p. 33. 

134  The codification of the law provides a clearer insight of the political parties’ obligations and acts that they 
can or cannot do throughout a year regardless of whether it is an election year or not. Written contribution 
from the CIDA in the context of the country visit to Greece, p. 5. 

135 Joint Civil Society Submission on the 2024 Rule of Law Report, p. 23. As measured against OECD standards 
on political finance, Greece fulfils 60% of criteria on regulations and 71% of criteria on practice, compared 
to  the  OECD  average  of  73%  and  58%,  respectively.  All  financial  reports  are  available  from  one  single 
online platform in a user-friendly format. However, there is no published information on the number of cases 
related to breaches of political finance regulations, the number of investigations conducted, and a breakdown 
of  the  different  types  of  sanctions  issued.  OECD  (2024)  ‘Anti-corruption  and  Integrity  Outlook,  Country 
Fact Sheet for Greece’, p. 8.  

17 

 
 
responsibilities  of  the  officers  receiving  the  reports  and  other  administrative  issues136.  The 
NTA has been operating an external channel to receive and manage reports from the private 
and public sectors on violations of EU law since August 2023137. Law 5095/2024 extended 
the  material  scope  of  the  2022  Whistleblower  Protection  Act  to  persons  who  report  or 
disclose  breaches  of  national  law  regarding  the  offences  of  bribery  and  trading  in 
influence138.  In  2023,  a  total  of  79  reports  were  submitted  to  the  NTA,  of  which  65  were 
unfounded,  6  were  not  within  the  framework  of  the  2022  Act,  3  were  forwarded  to  other 
competent bodies and 5 were under examination by the competent inspectors139.  

The  government  is  developing  an  integrated  risk  management  system  to  increase 
transparency  and  integrity  in  public  procurement,  which  is  still  considered  as  a  high-
risk  area.  The  Flash  Eurobarometer  on  Businesses’  attitudes  towards  corruption  in  the  EU 
shows  that  54%  of  companies  in  Greece  (EU  average  27%)  think  that  corruption  has 
prevented them from winning a public tender or a public procurement contract in practice in 
the last three years140. Based on the number of complaints received, the NTA considered that 
the  sectors  characterized  as  high-risk  are  local  government  concentrating  26%  of  the  total 
complaints, as well as public procurement and the health sector amounting to 16% and 15% 
respectively  of  the  total  complaints141.  Based  on  the  complaints  received  by  the  Hellenic 
Single Public Procurement Authority (HSPPA), the sectors of public procurement that seem 
to  have  a  high  risk  of  infringement  of  national  or  EU  law  on  public  procurement  possibly 
linked  to  corruption  are  health,  education  and  civil  protection142.  The  NTA  carried  out  two 
significant projects to identify and outline areas of corruption risk within public hospitals in 
the national health system.143 A new project to develop an integrated risk management system 
aims  to  enhance  the  transparency  and  integrity  in  the  public  procurement  sector  and 
contribute to the strategic priorities of Greece’s National Public Procurement Strategy 2021-
2025144.  In  this  context,  a  code  of  conduct  for  civil  servants  working  in  procurement  units 

136  Input from Greece to the 2024 Rule of Law Report, p. 34. 
137  The established platform allows secured and anonymized communication between NTA and whistleblowers. 
Written  contribution  from  the  NTA  in  the  context  of  the  country  visit  to  Greece,  pp.  5-6  and  Input  from 
Greece for the 2024 Rule of Law Report, pp. 22 and 35. 

138  Article  20  of  Law  5095/2024  ‘Inclusion  of  bribery  offences  in  the  material  scope  of  Law  4990/2022, 
Amendment  of  Article  4  of  Law  4990/2022’.  The  following  breaches  are  now  also  included:  active  and 
passive bribery of political persons,  active and passive bribery of an official,  active and passive bribery of 
judicial officers, trading in influence by intermediaries and active and passive bribery in the private sector 
and  liability  of  legal  persons  and  entities  for  bribery  offences.  Written  contribution  from  the  NTA  in  the 
context of the country visit to Greece, written contribution p. 6. These changes fully implement the OECD’s 
recommendation  to  extend  whistleblower  protection  to  bribery  offences,  including  foreign  bribery.  The 
OECD will assess the law against the standards of the Anti-Bribery Recommendation XXII in Greece’s next 
evaluation phase. OECD (2024), Phase 4 Two-Year Written Follow-Up Report, pp. 4 and 6.  

139  Written contribution from the NTA in the context of the country visit to Greece, p. 6.  
140  Flash  Eurobarometer  543  on  Businesses’  attitudes  towards  corruption  in  the  EU  (2024).  This  is  27 

percentage points above the EU average. 

141  Written input from the NTA in the context of the country visit to Greece, p. 9. 
142  Written contribution  from  the  HSPPA  in the  context of the country visit to Greece, p.11. The HSPPA also 

referred to direct awards of regional student transportation services. 

143  Some  actions  have  been  put  in  place  in  relation  to  the  Recovery  and  Resilience  Funds,  such  as  the 
appointment of a Fraud/Corruption and Conflict of Interest Officer by the IAPR. Input from Greece for the 
2024 Rule of Law Report, pp. 36-37. 

144  The project brings together the NTA, OECD and the European Commission and is financed under the EU’s 
Technical  Support  Instrument  (TSI).  Specifically,  the  project  aims  to  introduce  a  Risk  Registry,  which 
contains  integrity  risks  as  well  as  mitigation  measures  and  a  training  program  for  contracting  authorities. 
Written contributions from the HSPPA and NTA in the context of the country visit to Greece, pp. 8 and 6-7. 

18 

 
 
within the public sector will be drafted by the OECD in collaboration with the NTA and is 
expected  to  be  delivered  by  the  end  of  2024145.  The  Court  of  Audit  intends  to  carry  out  a 
thematic  audit  on  the  effectiveness  of  measures  and  practices  to  prevent  corruption  and 
ensure integrity in the public sector in high-risk areas in the course of 2024146.  

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

The Greek legal framework regulating media pluralism and media freedom is established by 
the Constitution and specific sectorial legislation. The Greek Constitution enshrines the rights 
to  freedom  of  expression  and  press  freedom.  It  also  provides  for  a  right  of  access  to 
information.  Law  No.  4779/2021,  which  transposed  the  Audiovisual  Media  Services 
Directive (AVMSD) into the Greek legal order, regulates audiovisual media147. 

Selection  procedures  to  address  challenges  regarding  the  resources  of  the  media 
regulator are ongoing, while concerns have been raised regarding its independence. The 
selection procedure organised by the Supreme Council for Civil Personnel Selection to hire 
17  new  staff  members  for  the  National  Council  for  Radio  and  Television  (NCRTV)  is 
ongoing. The first stage of appointment of 11 new employees is expected to be completed by 
summer  2024148.  While  the  impending  appointment  of  new  staff  members  is  a  welcome 
development,  previously  identified  challenges  persist  in  relation  to  the  adequacy  of  the 
resources with respect to the functions that the NCRTV needs to carry out under the existing 
regulatory  framework149.  Under  the  legal  framework150,  the  NCRTV  is  only  subject  to 
parliamentary  scrutiny.  However,  the  procedure  followed  for  the  appointment  of  the  new 
members  of  the  NCRTV  in  September  2023151  has  raised  concerns  among  civil  society, 
journalists,  and  legal  experts  and  was  perceived  as  an  attempt  to  interfere  with  its 
independence152. In July 2024, the hearing of the related petitions of annulment submitted by 
the Athens Bar Association took place in the Plenary Session of the Council of State and the 
judgement  is  expected153.  The  2024  Media  Pluralism  Monitor  (MPM)  has  changed  its 
previous  assessment  of  the  independence  and  effectiveness  of  the  Media  Authority  from 
medium to high risk154.  

The  new  registries  are  regarded  as  a  positive  development  for  transparency  of  media 
ownership. The legal framework in place ensures a certain degree of transparency of media 

145  The code of conduct is meant to be brief, user-friendly and practical and will have a section on fundamental 
principles and values and one will be a guidance on expected behaviour. Written contributions from HSPPA 
the NTA in the context of the country visit to Greece, pp. 7 and 10. 

146  Written contribution from the Court of Audit in the context of the country visit to Greece, pp. 5-6. 
147 Greece ranks 88th in the 2024 Reporters without Borders World Press Freedom Index compared to 107th in 

the previous year. 

148 Input from Greece for the 2024 Rule of Law Report, p. 46. 
149  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Greece,  p.  19;  Information 

received from NCRTV in the context of the country visit to Greece. 

150 Articles 2 and 2A of Law 3051/2002. 
151  See details below in Pillar IV.  
152 Information received from NCRTV, ADAE, NCHR, Ombudsman, Athens Bar Association, Vouliwatch and 
Transparency  International  in  the  context  of  the  country  visit  to  Greece.  The  annulment  application 
submitted  by  the Athens  Bar Association  against  the  appointment  decision  were  heard  by  the  Council  of 
State in May 2024. A decision on the matter is pending. See details and contributions below in Pillar IV, pp. 
27-28. 

153 See details and contributions below in Pillar IV, pp. 27-28. 
154 2024 Media Pluralism Monitor, Greece, p. 12. 

19 

 
 
ownership  and  all  media  service  providers  are  required  to  register  in  the  NCRTV  Business 
Register155. As referred in the 2023 Rule of Law Report, Law 5005/2022156 set up a Registry 
for  Print  Media  (MET)  as  well  as  a  Registry  for  Electronic  Press  (MHT)  with  the  aim  to 
improve  the  transparency  of  media  ownership,  including  beneficial  ownership157.  Both 
registers started to operate in May 2023 and are accessible through the Digital Portal of the 
Public Administration158. Only media  appearing in the registers  are eligible to  benefit  from 
state advertising. The creation of the new registries, as well as the new Ethics Committee in 
charge of overseeing the compliance of online media with journalistic ethics, are regarded as 
positive developments. Media legislation159 contains specific ownership limitations to prevent 
horizontal concentration in the media market. The 2024 MPM has this year adjusted its risk 
score from medium to low risk with regard to transparency of media ownership160, due to the 
implementation of Law 5005/2002 which established the above-mentioned registries.  

A  new  system  for  the  selection  and  appointment  of  administrators  of  public  sector 
entities entered into force, covering also  public service media.  The Law on the Hellenic 
Radio  and  Public  Service  Television  guarantees  the  editorial  independence  of  the  public 
service media  - Hellenic Radio  and Television Corporation (ERT)161. In November 2023, a 
new Law 5062/2023,  which sets  out  new conditions  and procedures for  the appointment of 
directors and other managers of public administration bodies, entered into force162. The new 
law  defines  more  transparent  criteria  related  to  the  selection  process.  It  also  introduces  an 
additional framework for the annual evaluation of the performance of administrative bodies 
based  on  the  performance  contract  signed  between  them  and  the  supervising  Minister163. 
These  changes  in  the  selection  process  are  a  welcome  improvement  by  media  experts  and 
media  representatives,  as  also  reported  in  the  Media  Freedom  Rapid  Response  mission 
report164. On this basis, in June 2024, the procedure for the selection of the CEO of ERT was 
launched165.  Under  the  applicable  legal  framework,  ERT  has  administrative  and  financial 
autonomy166  and  operates  independently.  ERT  is  subject  to  administrative  oversight  by  the 

155 Article 37 of Law No. 4779/2021; See also, 2022 Rule of Law Report, Country Chapter on the rule of law 

situation in Greece, p. 17. 

156  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". 

157  Access  to  the  following  information  is  provided  through  the  Portal:  a)  name,  b)  title,  c)  legal  form,  d) 
registered office, e) address of organized office, f) VAT identification number and competent TAX Offices g) 
name and surname of publisher and/or website manager, manager, editorial director, h) details of ownership, 
i) periodicity, j) title of media and website name, k) circulation data, measurement or tracking of networking 
sites l) thematic units, m) public targeting to which they are addressed, n) geographical and circulation areas 
for the printed press and geographical targeting for the electronic press. 

158 As of January 2024, i.e. less than a year from the launch of the registries, Media Freedom Rapid Response 
mission  report  assessed  access  to  them  as  still  challenging.  Media  Freedom  Rapid  Response  –  Mission 
Report:  Stemming  the  tide  of  Greek  media  freedom  decline,  30  January  2024,  p.  23;  and  2024  Media 
Pluralism Monitor, Greece p. 14. 

159 Law No. 3592/2007 and Law No. 2328/1995. 
160 2024 Media Pluralism Monitor, Greece, p. 14. 
161 Law No. 4324/2015. 
162 Law No. 5062/2023. 
163 Input from Greece for the 2024 Rule of Law Report, p. 50.  
164 Media Freedom Rapid Response – Mission Report: Stemming the tide of Greek media freedom decline, 30 

January 2024 and information received from NCRTV in the context of the country visit to Greece. 

165 Written contribution from Greece. 
166  Law 4173/13 (Α΄ 169). 

20 

 
 
General Secretariat for Communication and Media, which some stakeholders criticise as the 
latter is placed under the responsibility of the office of the Prime Minister167. The 2024 MPM 
considers the independence of public service media to be an area of medium risk168. 

The  right  of  access  to  documents  is  recognised  in  the  Constitution.  According  to  the 
Constitution,  restrictions  can  only  be  imposed  by  law,  provided  they  are  necessary  and 
justified  by  reasons  of  national  security,  combating  crime,  or  protecting  the  rights  and 
interests of others169. In this respect, the Code of Administrative Procedure regulates the right 
of interested parties to have access to administrative documents created by public services170 
GRECO  issued  a  recommendation  to  Greece  to  undertake  an  independent  assessment  on 
access  to  information  requirements  in  order  to  adopt  regulation,  which  has  not  been 
implemented  yet171.  Challenges  have  been  highlighted  by  journalists  and  civil  society  with 
regard  to  the  effectiveness  of  the  public  authorities’  responses  to  requests  for  information, 
since  requests  for  access  to  documents  are  often  addressed  with  a  long  delay  or  remain 
unanswered172. The 2024 MPM has maintained its medium risk score for this area173.  

Some further progress has been made in adopting non-legislative safeguards to improve 
the  protection  of  journalists  and  significant  progress  has  been  made  in  the  legislative 
process,  including  with  the  decriminalisation  of  the  offence  of  simple  defamation.  The 
2023 Rule of Law Report recommended to Greece to ‘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 
the  protection  of 
journalists’174.  In  February  2024,  the  amended  Criminal  Code175  abolished  the  criminal 
offence  of  simple  defamation  (απλή  δυσφήμιση)176,  only  retaining  the  one  of  slanderous 
defamation  (συκοφαντική  δυσφήμιση).  The  objective  pursued  with  this  reform  is  to  protect 

into  account  European  standards  on 

taking 

167  Contribution  from  2024  Civil  Liberties  Union  for  Europe  for  the  2024  Rule  of  Law  Report;  and  Media 
Freedom Rapid Response – Mission Report: Stemming the tide of Greek media freedom decline, 30 January 
2024. 

168 2024 Media Pluralism Monitor, Greece, p. 18.  
169 Greek Constitution, Articles 5A and 10 para. 3.  
170 Article 5 of Law 2690/1999. Law 3861/2010, provides an obligation for all government institutions to upload 

certain acts and decisions on the dedicated portal, the Transparency portal (diavgeia). 

171  GRECO  (2022),  Fifth  Evaluation  Round,  Evaluation  Report  and  Compliance  Report  on  Greece  (2024), 

paras. 59-66 and 24-27 respectively.  

172 Joint Civil Society Submission to the European Commission on the 2024 Rule of Law Report, paras. 78.  
173 2024 Media Pluralism Monitor, Greece, p. 11. 
174 In the 2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p.2, the Commission 
concluded  that  ‘some  progress’  was  made  on  the  implementation  of  the  recommendation  addressed  in  the 
2022  Rule  of  Law  Report  to  Greece  to  establish  safeguards  to  improve  the  physical  safety  and  working 
environment of journalists, in line with the recently adopted Memorandum of Understanding, but legislative 
safeguards  are  still  to  be  established,  t  taking  into  account  European  standards  on  the  protection  of 
journalists.  
175  Law 5090/2024.  
176  The two offences were foreseen in Article 362 of the Criminal Code. In the case of the simple defamation, 
only the dissemination of a fact is required, while in the slanderous defamation, the offender knows that the 
facts disseminated are false.  

21 

 
 
freedom  of  expression  and  protect  journalists  from  abusive  lawsuits177.  Journalists’ 
organisations and civil society have long been calling for the decriminalisation of defamation. 
At  the  same  time,  journalists’  associations  have  criticised  the  amended  provisions  of  the 
Criminal Code and the Code of Criminal Procedure which increased the minimum sentence 
for slanderous defamation  and reduced significantly the possibility of suspending  sentences 
imposed  at  first  instance  when  they  are  appealed178.  However,  the  Greek  government 
submitted that, to date, courts have not imposed a prison sentence of more than two years on 
a  journalist  for  the  offence  of  slanderous  defamation179.  A  new  law  aiming  to  combat 
violence  in  the  context  of  sport  events  includes  specific  provisions  for  the  protection  of 
journalists  covering  or  commenting  on  sporting  events180.  The  Task  Force  on  Ensuring  the 
Protection,  Safety  and  Empowerment  of  Journalists  and  other  Media  Professionals181  is 
continuing its work, mainly focusing on organising trainings, academic courses on safety  of 
journalists  and  awareness-raising  events.  The  office  term  of  the  current  members  was 
renewed in September 2023. Among the initiatives in the context of the Task Force is also the 
establishment  of  an  observatory  on  SLAPPs  by  the  Panhellenic  Federation  of  Journalists 
Associations  (POESY)  in  July  2023.  According  to  the  journalists’  unions,  the  SLAPPs 
Observatory represents a positive step182. Notwithstanding statistics by the Greek government 
that point at a relatively low number of lawsuits against journalists and the media183, SLAPPs 
remain  a  concern  for  journalists184,  the  Media  Freedom  Rapid  Response  Mission  Report185 
and the National Commission for Human Rights (NCHR)186. In light of the above, there has 

177 Input from Greece for the Rule of Law Report, p. 54. The Government notes that, thanks to the abolition of 
simple  defamation  at  the  level  of  criminal  law,  it  becomes  difficult  to  bring  a  civil  action  for  damages. 
Written contribution from Greece.  

178 Journalists’ associations indicated that in past cases involving the convictions of journalists for defamation, 
first  instance  rulings  were  overturned  on  appeal.  Information  received  from  journalists’  associations  and 
Reporters United in the context of the country visit to Greece. According to the revised provisions, in case of 
a first-instance conviction for slanderous defamation, the sentence  has to be served, only if it exceeds two 
years.  

179 Written contribution from the Ministry of Justice in the context of the country visit, pp. 9-12. 
180  Law 5085/2024 on "Urgent Measures for the Prevention of Violence at Sporting Events". 
181 2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 22; The Task Force was 
formed under the decision of the Secretary General for Communication and Media No. 4957/27.07.2022. 

182  Information received from journalists’ associations in the context of the country visit to Greece. 
183 Based on statistical data  already collected by the six  largest courts in the country (namely Athens, Piraeus 
and Thessaloniki Courts of First Instance and Appeals) submitted by the Greek Government,  for the years 
2022 and 2023, overall 75 cases out of 603 actions brought concerned offences committed through the press, 
whilst the Government notes further that the number of the lawsuits that are accepted by the court is even 
lower  and  that,  even  in  the  case  of  claims  that  are  upheld  as  well-founded,  the  amounts  awarded  by  the 
courts are significantly lower than those requested in the lawsuits, with most of them being less than € 5,000. 
Written contribution from Greece. 

184  In January 2024, the defamation lawsuit brought against media  outlets and journalists that reported on the 
spyware case was heard before the Court of First Instance of Athens. The International Press Institute (IPI) 
and  other  organisations  called  the  legal  action  a  startling  example  of  a  SLAPP  and  an  attempt  to  muzzle 
investigative  reporting  on  a matter  of  significant  public  interest;  IPI  et  al.  (2024),  Greece: Ahead  of  court 
hearing, SLAPP lawsuit against media and journalists must be dropped, 18 January 2024; Media Freedom 
Rapid Response, “Murdered, surveilled and sued: decisive action needed to protect journalists and salvage 
press  freedom  in  Greece”,  27  September  2023;  Centre  for  European  Constitutional  Law  (2024),  Country 
research,  Legal  environment  and  space  of  civil  society  organisations  in  supporting  fundamental  rights 
[Greece], EU Agency for Fundamental Rights, pp. 34-35. 

185 Media Freedom Rapid Response – Mission Report: Stemming the tide of Greek media freedom decline, 30 

January 2024. 

186 According to the NCHR, the level of protection of journalists in Greece is below European standards, as on 
the  specific  issue  of  protection  against  abusive  lawsuits  (SLAPPs),  no  legislative  measures  have  been 

22 

 
 
 
been some further progress on the implementation of the recommendation made in the 2023 
Rule of Law Report.  

The safety of journalists remains an issue, while some measures have been taken. There 
have been several cases of attacks or threats to safety of journalists since the publication of 
the  2023  Rule  of  Law  Report.  Journalist  associations  reported  threats,  verbal  and  physical 
aggression during demonstrations and, particular issues when reporting on migration187. The 
Council  of  Europe’s  Platform  to  promote  the  protection  of  journalism  and  safety  of 
journalists  registered  seven  alerts188  relating  to  attacks  on  physical  safety  of  journalists, 
verbal insults, arbitrary detainment and harassment and intimidation, including by politicians, 
which is a considerable decrease compared to the previous reporting period189. The Mapping 
Media Freedom platform registered five new alerts190 since the publication of the 2023 Rule 
of Law Report. In June 2024, the trial of two suspects for the murder of the journalist Giorgos 
Karaivaz  (in  April  2021)  began191.  The  spyware  case192  is  under  judicial  investigation 
conducted  by  the  Deputy  Public  Prosecutor  of  the  Supreme  Court193,  although  journalists’ 
associations criticise the progress made194. Furthermore, whilst journalists associations have 
raised concerns about the precarious working conditions195, on 23 May 2024 a new collective 
labour  agreement  was  signed  between  the  Greek  State  and  the  unions  concerning  public 
sector journalists196, which was welcomed by trade unions197. The OECD also acknowledges 
Greece’s efforts towards securing a safe environment for journalists, while noting that some 
concerns  remain198.  The  2024  MPM  considers  ‘journalistic  profession,  its  standard  and 
protection’ to be an area presenting medium risk, pointing out that ‘journalism continues to 
be  a  precarious  and  dangerous  profession  in  Greece’  and  highlighting  the  ‘prevalence  of 
SLAPPs  particularly  targeting  smaller  independent  outlets,  posing  an  existential  threat  to 
investigative journalism in the country’199. 

adopted. The NCHR considers that the binding out-of-court procedure, which imposes an obligation to ask 
for  the  correction  of  an  offensive  publication  within  10  days  for  the  lawsuit  to  be  admissible,  is  not  a 
sufficient  safeguard  against  misuse.  It  points  out  that  this  procedure  applies  only  to  civil  lawsuits  and  not 
criminal  complaints  and  is  subject  to  exceptions.  ENNHRI  (2024),  The  state  of  the  rule  of  law  in  the 
European Union, Reports from National Human Rights Institutions, Greece, Greek NCHR, pp. 252-254. 
187  Information received by journalists’ associations, (ESIEA, POESY, FPA, Reporters United), Vouliwatch and 

Transparency International in the context of the country visit to Greece.  

188 Council of Europe, Platform to promote the protection of journalism and safety of journalists, Greece. 
189 The 2023 Rule of Law Report referred to 16 recorded alerts; 2023 Rule of Law Report, Country Chapter on 

the rule of law situation in Greece, p. 21. 

190 European Centre for Press and Media Freedom, Mapping Media Freedom, Greece country profile. 
191 Written contribution from Greece. 
192 2023 Rule of law Report, Country Chapter on the rule of law situation in Greece, p. 21. 
193 Written contribution from Greece. 
194  See below, Pillar IV.  
196 Written contribution from Greece. 
196 Written contribution from Greece. 
197  IFJ press release of 29 May 2024 “New collective agreement to boost gender equality in State and  public 

media”. 

198 According to the report, Recommendation 3(b), to ensure that laws relating to freedom of the press are fully 
applied in practice and that allegations of foreign bribery can be reported,  is partially implemented. OECD 
(2024), Phase 4 Two-Year Written Follow-Up Report, pp.6-7. 

199  2024 Media Pluralism Monitor, Greece, p. 12. 

23 

 
 
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 Government200. 
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  if  they  deem  its 
content  to  be  contrary  to  the  Constitution  201.  A  number  of  independent  authorities202  and 
bodies aim to protect and safeguard human rights, including the Greek Ombudsperson203 and 
the National Commission for Human Rights, which is accredited with A status by the Global 
Alliance of Human Rights Institutions204. 

Some  progress  was  made  to  improve  the  consultation  of  stakeholders,  while  its 
effectiveness and timeliness in practice still need to be better addressed. The 2023 Rule 
of  Law  Report  recommended  to  Greece  to  ‘ensure  the  effective  and  timely  consultation  in 
practice of stakeholders on draft legislation, including by allowing sufficient time for public 
consultation’205. Draft bills continue to be systematically submitted to public consultation and 
in 2023, there was a significant decrease in the number of provisions added in the final text of 
the  law  without  having  been  submitted  to  public  consultation206.  The  statutory  period  for 
public consultation is two weeks, with the average time in practice being 12.4 days during the 
reporting  period207,  and  it  can  be  subject  to  derogation  without  a  justification  for  the 
shortening208.  Stakeholders  pointed  at  the  fact  that  draft  bills  are  frequently  submitted  to 
Parliament almost immediately after the end of the public consultation209, making it difficult 
to  take  account  of  comments  submitted  during  the  public  consultation210.  Independent 
authorities  highlighted  that  they  are  rarely  consulted  by  the  executive  on  draft  bills  despite 

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

Greece, p. 11 and 19 respectively. 

201  Constitution of Greece, Article 93, para. 4. 
202  The  Constitution  establishes  five  independent  authorities,  the  Data  Protection  Authority;  the  National 
Council  for  Radio  and  Television  (NCRTV);  the  Hellenic  Authority  for  Communication  Security  and 
Privacy (ADAE); the Supreme Council for Civil Personnel Selection; and the Ombudsperson.  

203 The Ombudsperson is also the national equality body with a mandate to combat discrimination and promote 

the principle of equal treatment. 

204  Chart of the status of national institutions – Accreditation status as of 27 April 2022. 
205  2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 2. 
206  In 2023 15,3% of the articles included in the published law were not submitted for public consultation (34% 
for  the period  2020-2022).  Information  received from  the General  Secretariat  for  Legal  and  Parliamentary 
Affairs  in  the  context  of  the  country  visit.  See  also,  European  Semester,  2024  Country  Report  –  Greece, 
SWD (2024) 608 final, p. 64.  

207  According to data from the opengov.gr, between July 2023 and June 2024, 17 out of 53 public consultations 
observed strictly the two weeks rule. According to the Quality of Law-Making Index 2023, the average time 
for  the  first half of  2023  was  also  12.4  days.  Centre  of  Liberal  Studies  (KEFIM)  (2023),  Quality  of  Law-
Making  Index  2023,  pp.  16. According  to  the  Government,  during  the reporting period  80%  of  the  public 
consultations  were  open  for  public  consultation  for  two  weeks  or  more.  Written  contribution  from  the 
General Secretariat for Legal and Parliamentary Affairs, p. 2.  

208  According to GRECO, it would have been preferable that the statutory timeframe for consultation was not 
subject to derogation and that the law itself had some indication as to the reasons which would justify the 
derogation. GRECO (2022), Fifth Evaluation Round, Evaluation Report on Greece, para 68.  

209  During the reporting period 28 draft bills (out of 44) were submitted to Parliament the same or the following 

day after the public consultation ended.  

210  Information received by Vouliwatch and Transparency International in the context of the country visit.  

24 

 
 
their areas of expertise211; in most cases, they are invited to present their views at a later stage 
before  Parliament212.  GRECO  also  issued  two  recommendations  for  appropriate  timelines 
to  be  effective213,  and  early  and  relevant  stakeholder 
allowing  for  consultations 
engagement214.  In  view  of  the  foregoing,  there  has  thus  been  some  progress  on  the 
implementation of the recommendation made in the 2023 Rule of Law Report.  

Efforts  are  underway  to  improve  access  to  legislation,  while  challenges  regarding  the 
quality of the law-making process persist. The National Codification Portal, an electronic 
system  that  aims  to  gradually  standardise  the  law-making  process  and  to  facilitate  the 
administrative  codification  of  legislation,  was  completed  in  November  2023215.  This  will 
grant  individuals  and legal  entities free and immediate access  to  consolidated legislation216. 
During the reporting period, the total number of parliamentary amendments and the number 
of provisions included in these amendments decreased217. According to stakeholders, most of 
these  amendments  regulate  issues  which  are  not  linked  to  the  main  subject-matter  of  the 
law218.  Last-minute  amendments  remain  a  point  of  controversy219.  The  Constitution  and 
Rules of Parliament provide that amendments should be submitted at least three days before 
the  start  of  the  debate  in  the  Plenary220.  However,  the  Government  reports  that  under  the 
prevailing  practice  the  timely  submission  of  amendments  is  assessed  with  reference  to  the 
adoption of the agenda of the Plenary. It hence states that not a single last-minute amendment 

211  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.  Information received 
from  the  Ombudsperson,  the  NCHR,  Data  Protection Authority  and ADAE  in  the  context  of  the  country 
visit. See also 2023 Rule of law Report, Country Chapter on the rule of law situation in Greece, p. 25.  

212 Information received from the Ombudsperson and the National Commission for Human Rights.  During the 
reporting  period,  the  Parliament  has  held  31  hearings  of  representatives  of  independent  authorities  before 
various parliamentary committees. Written contribution from Parliament.   

213 GRECO (2024), Fourth Evaluation Round Second Addendum to the Second Compliance Report on Greece, 
paras 6-10. GRECO noted that, while draft bills are consistently subject to public consultation, the concerns 
about  the  insufficient  time  for  public  consultation  remain  and  concluded  that  GRECO  concludes  that  the 
recommendation remained partly implemented. 

214 GRECO (2022, 2024), Fifth Evaluation Round, Evaluation Report and Compliance Report on Greece, paras 
72  and  28-31  respectively.  GRECO  noted  the  need  for  additional  targeted  steps  to  better  provide  for 
meaningful stakeholder engagement at earlier stages and concluded that  the  recommendation has not been 
implemented. 

215  Input from Greece for the 2024 Rule of Law Report, p. 61. 
216  The  target  date  for  the  functioning  of  the  portal  is  set  at  the  end  of  2024/beginning  of 2025.  Citizens  and 
legal  professional  have  currently  access  to  consolidated  legislation  mainly  through  paid  databases.  Other 
projects funded under the Technical Support Instrument also aim to improve the law-making process.  

217  Between July 2023 and June 2024, 292 provisions were included in 69 amendments, an average of 4 articles 
per amendment, which is a decrease in comparison to the first half of 2023 (7 articles per amendment) and to 
2022  (6).  Written  contribution  from  the  General  Secretariat  for  Legal  and  Parliamentary  Affairs.  A  single 
tabled amendment often groups several disperse, unrelated provisions, proposed by different ministries, in an 
effort  to  reduce  the  total  number  of  amendments.  Centre  of  Liberal  Studies  (KEFIM)  (2023),  Quality  of 
Law-Making Index 2023, pp. 18-19.  

218  Amendments unrelated to the main subject of the law amount to  82%, Centre of Liberal Studies (KEFIM) 
(2023), Quality of Law-Making Index 2023, pp. 19-20; Information received from the Ombudsperson, the 
NCHR and Transparency International in the context of the country visit; Contribution from Civil Liberties 
Union for Europe for the 2024 Rule of Law Report, pp. 31-32. 

219  2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 24. 
220  Articles 74 para. 5 d) of the Constitution and 87 para 2 of the Rules of Parliament.  

25 

 
 
was submitted to Parliament in 2023221. However, stakeholders report that often amendments 
don’t  respect  the  three-day  rule  and,  while  in  essence  overdue,  are  not  recorded  as  such222. 
Also,  the  quality  of  law-making  and  frequent  changes  in  legislation223  remain  a  significant 
reason  for  concern  among  companies  about  the  effectiveness  of  investment  protection  in 
Greece (59% among the respondents, one of the highest in the EU)224. 

Independent authorities, established by virtue of the Constitution, face challenges that 
could undermine their status and ability to carry out their tasks effectively. In September 
2023,  the  Conference  of  Presidents  of  Parliament225  replaced  members  of  the  National 
Council for Radio and Television (NCRTV) and the Authority for Communication Security 
and  Privacy  (ADAE),  whose  mandate  had  expired226.  These  appointments  have,  however, 
been subject to discussion among political and legal experts questioning whether there was an 
attempt  of  undue  interference  with  the  functioning  of  these  independent  authorities227. 
According  to  the  Government,  the  appointments  were  in  line  with  the  Constitution  and  the 
new  members  are  widely  recognised  experts228.  In  November  2023,  the  Athens  Bar 
Association  filed  two  annulment  applications  before  the  Council  of  State  against  the 
appointment  decisions,  claiming  that  they  were  in  violation  of  the  Constitution229. 

221  The agenda of the Plenary is adopted from one to three days before the debate in Plenary starts. According to 
Parliament, even amendments submitted on the day before the opening of the debate in the Plenary  can be 
sufficient discussed. Written contribution from the Parliament in the context of the country visit.   

222  According to Vouliwatch, 49 out of 75 amendments were filed either on the day or the eve of adoption of the 
law.  Joint  Civil  Society  Submission  to  the  European  Commission  on  the  2024  Rule  of  Law,  para. 92.  See 
also,  Centre  of  Liberal  Studies  (KEFIM)  (2023),  Quality  of  Law-Making  Index  2023,  pp.  25;  and 
SyntagmaWatch  (2024),  Constitution:  Interpretation  by  article, Article  74, Amendments  to  draft  bills  and 
proposals for law, N. Papaspyrou, p.6. ENNHRI (2024), The state of the rule of law in the European Union, 
Reports from National Human Rights Institutions, Greece, Greek NCHR, p. 258. 

223  Stakeholders referred by way of an example to the Criminal Code that has been modified seven times in the 
last  four  years.  Information  received  by  the  Athens  Bar  Association,  Vouliwatch,  Transparency 
International, Journalists Unions, Hellenic Ligue for Human Rights in the context of the country visit.  

224  53%  in  2023.  28%  of  companies  perceive  the  effectiveness  of  investment  protection  by  law  and  courts  as 
very or fairly confident, the lowest in the EU (32% in 2022 and 38% in 2021).  Figure 55 and 56, 2024 EU 
Justice Scoreboard. 

225  Rules  of  Parliament,  Articles  13-14;  the  Conference  of  Presidents  is  a  collective  body  organising 
parliamentary  work.  In  early  September  2023,  Parliament  modified  the  composition  of  the  Conference  of 
Presidents to add an extra member.  

226  Prolonged  delays  in  selecting  new  members  of  the  Independent  Authorities  are  a  recurrent  issue.  The 
mandates  of  the  Ombudsperson  as  well  as of  several  members  of  the  Data  Protection  Authority  have  also 
long  expired.  NCHR  (2023),  Statement  on  Independent  authorities,  Issues  of  ensuring  the  institutional 
integrity  of  the  constitutionally  enshrined  Independent  Authorities  and  respecting  the  regime  of  increased 
guarantees of their members, 30 November 2023. 

227  NCHR  (2023),  Statement  on  Independent  authorities,  Issues  of  ensuring  the  institutional  integrity  of  the 
constitutionally enshrined Independent Authorities and respecting the regime of increased guarantees of their 
members,  30  November  2023;  Minutes  of  the  Conference  Constitutionally  Enshrined  Independent 
Authorities:  Their  contribution  to  a  European  democratic  rule  of  law,  1-2  November  2023;  Centre  for 
European  Constitutional  Law  (with  Hellenic  League  for  Human  Rights  and  Antigone-Information  and 
Documentation Centre on racism, ecology, peace and non-violence) (2024), Country 
-  Legal 
environment and space of civil society organisations in supporting fundamental rights [Greece], EU Agency 
for  Fundamental  Rights,  pp.  34-35;  Contributions  from  Civil  Liberties  Union  for  Europe  and  Joint  Civil 
Society Submission for the 2024 Rule of Law Report, pp. 32-34 and paras. 13-17.  

research 

228  Input from Greece for the 2024 Rule of Law Report, pp. 46-47. 
229  Athens Bar Association (2023), Appeal before the Council of State, 30 November 2023.  The main issue is 
whether the required 3/5 majority required by the Constitution (Article 101A) was respected. The contested 
decisions were taken with a majority of 16 out of 27 votes. For the Government, the majority required was 

26 

 
 
 
Independent authorities consider that their status is severely affected by the mere impression 
that they operate under pressure230. They also  argue that the current  appointment procedure 
gives  the  power  to  decide  to  a  body  that  does  not  have  a  fixed  composition,  exposes  the 
authorities  to  undue  political  influence  and  should  be  reviewed231.  The  Data  Protection 
Authority, the NCRTV and ADAE reported problems of understaffing and limited resources 
to  effectively  perform  their  tasks232.  They  pointed  to  the  need  for  the  establishment  of  a 
procedure  for  the  selection  of  their  own  staff  members,  which  would  reduce  delays  in 
recruitments233. In December 2023, legislative measures were adopted to improve the salary 
regime for all members of the constitutional authorities234. Independent authorities and other 
stakeholders  also  pointed  to  the  barriers  faced  by  ADAE  in  the  performance  of  its  tasks, 
including  the  summons  of  its  members  to  justice  for  acts  related  to  their  duties235  and 
personal attacks on its president236. 

The  Ombudsperson 
investigates  incidents  of  alleged  misconduct  involving  law 
enforcement  officers.  The  Ombudsperson  investigates  cases  of  alleged  misconduct  by  law 
enforcement  officers  under  its  mandate  of  National  Mechanism  for  the  Investigation  of 
Arbitrary Incidents237. According to its 2022 Special Report, published in October 2023, the 
systematic  lack  of  effective  investigation  into  disciplinary  misconduct  of  law  enforcement 
officers,  despite  its  repeated  recommendations  led  the  Ombudsperson  to  conclude  that 
documented problems not only persist but have been exacerbated238. In November 2023, the 
Ombudsperson launched its own investigation239 into the conduct of the Coast Guard in the 

reached in line with the Rules of Procedure of Parliament. The Bar argues that the majority required is 17.  
The hearing of the case before the Council of State took place on 17 May 2024.  

230  Press  release  of  the  constitutionally  enshrined  Independent  Authorities  on  the  joint  Conference 
“Constitutionally  Enshrined  Independent Authorities:  Their  contribution  to  a  European  democratic  rule  of 
law”, 7 November 2023 

231 Idem; Information received from the Ombudsman, NCHR, NCRTV, ADAE, DPA, Athens Bar Association, 

Vouliwatch and Transparency International in the context of the country visit to Greece. 

232  Information received from the DPA, ADAE and NCRTV in the context of the country visit. The DPA pointed 
that  it  experienced  a  15%  decrease  of  its  budget  in  the  last  four  years  while  the  other  data  protection 
authorities have an increase. In relation to NCRTV, see Pillar III, p. 20.  

233  Independent  Authorities  recruit  their  staff  through  long  selection  procedures  organized  by  the  Supreme 
Council  for  Civil  Personnel  Selection.  For  the  Ombudsperson,  the  establishment  of  its  own  staff  selection 
process is the only remaining arrangement in order for the authority to be fully compliant with the Principles 
on  the  Protection  and  Promotion  of  the  Ombudsman  Institution  of  the  Venice  Commission  (CDL-
AD(2019)005-e). Information received from the Ombudsperson in the context of the country visit.  

234  Article 95 of Law 5079/2023. 
235  In  October  2023,  members  of  ADAE  were  summoned  as  suspects  for  leaking  classified  information. 

Charges were dropped in February 2024. 

236  NCHR  (2023),  Statement  on  Independent  authorities,  Issues  of  ensuring  the  institutional  integrity  of  the 
constitutionally enshrined Independent Authorities and respecting the regime of increased guarantees of their 
members,  30  November2023;  Information  received  from  ADAE  in  the  context  of  the  country  visit; 
Contributions from Civil Liberties Union for Europe  and Joint Civil Society Submission for the 2024 Rule 
of Law Report, pp. 32-34 and paras. 13-17 respectively. 

237 Law  4443/2016. Law  4960/2022 also established  a Fundamental Rights Monitoring Mechanism,  including 
Fundamental  Rights  Officers  in  the  Ministry  of  Migration  and Asylum,  the  Police  and  the  Coast  Guard. 
Written contribution from Greece. 

238  Ombudsman (2023), 2022 Special Report, National Mechanism for the Investigation of Arbitrary Incidents, 

p. 23. 

239  Ombudsman (2023), Press release 9 November 2023.  In parallel, the European Ombudsman also launched 
an own-initiative inquiry on how the European Border and Coast Guard Agency (Frontex) complies with its 
fundamental rights obligations with regard to search and rescue  in the context of its maritime surveillance 
activities,  in  particular  the  Adriana  shipwreck,  which  was  concluded  in  February  2024  (OI/3/2023).  The 

27 

 
 
 
context  of  the  shipwreck  of  Pylos.  The  Commissioner  for  Human  Rights  of  the  Council  of 
Europe  commended  the  launch  of  the  Ombudsperson’s  investigation  and  urged  the  Greek 
authorities to fully cooperate with the Ombudsperson240. He also recognised the importance 
of the criminal investigations led in parallel, which should be conducted in compliance with 
the  requirements  set  out  by  the  European  Court  of  Human  Rights241.  Two  independent 
criminal  procedures  were  launched  in  June  2023:  one  by  the  Criminal  Court  of  Kalamata 
which is concluded242 , and the other, by the Naval Court of Piraeus, which is still ongoing 
and  focuses  specifically  on  the  conduct  of  the  Coast  Guard243.  The  European  Commission 
considers  that  effective  and  timely  investigations244  of  such  incidents  are  an  important 
demonstration of the ability of competent authorities to deliver an adequate response245. More 
generally, in December 2023, the Committee of Ministers of the Council of Europe strongly 
invited  Greece  to  reinforce  the  Ombudsperson  with  sufficient  staff,  to  give  effect  to  its 
recommendations and to enhance disciplinary investigations246.  

Judicial investigations into allegations of wiretapping and the use of spyware started in 
2022  and  are  ongoing247.  In  July  2023,  the  Data  Protection  Authority  (DPA)  released  the 
findings  of  its  investigation  and  forwarded  them  to  the  judicial  authorities  248.  In  October 
2023, ADAE rejected the prosecutors’ request to verify whether the individuals targeted with 
spyware were also subject to wiretapping activities by the National Intelligence Service249. In 

inquiry found that Frontex had complied with its obligations stemming from Regulation (EU) 2019/1896 of 
the European Parliament and of the Council of 13 November 2019 on the European Border and Coast Guard.  
240  Council of Europe: Commissioner for Human Rights (2023), Statement Greece: The Ombudsman institution 

opening an independent investigation into the Pylos shipwreck is a welcome step, 9 November 2023. 

241  Ibidem. 
242 The  case  concerned  allegations  of  smuggling  and  was  closed  by  the  Court of Appeal of  Kalamata  in  May 

2024 due to lack of jurisdiction.  

243 In September 2023, forty survivors also filed a criminal complaint before the Naval Court of Piraeus against 

the Greek authorities. The criminal investigation is also pending. 

244  In December 2023, the Committee of Ministers of the Council of Europe strongly invited Greece to notably 
ensure  that  criminal  investigations  are  sufficiently  thorough.  Greece  has  been  under  enhanced  supervision 
for the group of cases Sidiropoulos and Papakostas v. Greece concerning ill-treatment by law enforcement 
agents as well as the lack of effective investigations.  Council of Europe, Committee of Ministers Decision 
CM/Del/Dec(2023)1483/H46-16.  See  also  the  judgment  of  the  European  Court  of  Human  Rights  of  16 
January 2024, Alkhatib and Others v. Greece, 3566/16. Moreover, CSOs voice criticism that despite credible 
evidence, official investigations into reported incidents have not made meaningful progress, raising concerns 
about  the  investigation  procedures  and  the  prospect  of  accountability.  Contributions  from  the  European 
Civic  Forum,  the  Border  Violence  Monitoring  Network,  Civil  Liberties  Union  for  Europe  and  Joint  Civil 
Society Submission for the 2024 Rule of Law Report. 

245  The  European  Commission  has  underlined  the  need  to  conclude  pending  investigations  in  a  transparent, 
thorough  and  swift  manner.  Commissioner  Ylva  Johansson  (2023),  Opening  Statement  -  European 
Parliament Plenary Debate on Search and Rescue in the Mediterranean, 12 July 2023; Commissioner Ylva 
Johansson  (2023),  Intervention  in  the  Committee  on  Civil  Liberties,  Justice  and  Home Affairs,  European 
Parliament, 6 June 2023. A dedicated Fundamental Rights Monitoring Mechanism is set up, which includes 
an inter-ministerial high level task force and Fundamental Rights Officers in the Ministry of Migration and 
Asylum, the Police and the Coastguards. Law 4960/2022.  

246  Council  of  Europe,  Committee  of  Ministers  Decision  CM/Del/Dec(2023)1483/H46-16.  According  to  the 
Government, the Ombudsperson has been reinforced with five additional Special Scientific Staff, while two 
more will join his office in 2024.Written contribution from Greece. 

247 2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, pp. 26-27. 
248  The DPA stated that over the past years 92 users of Greek phone numbers had been targeted with malicious 
Predator  spyware.  DPA  (2023),  DPA  actions  in  relation  to  activities  of  installing  and  using  spyware  in 
Greece, Press Release 20 July 2023; Information received from the DPA in the context of the country visit.  

249  Kathimerini, Surveillance, the request of the two judges to ADAE, 24 October 2023. 

28 

 
 
October 2023, the Prosecutor of the Supreme Court ordered the transfer of the investigation 
file from the first-instance prosecutor’s office to the Supreme Court.  This decision was met 
with  criticism, including  by  press freedom  organisations,  as  it  was viewed as an attempt to 
interfere with the ongoing investigation and further delayed its progress250. According to the 
Council of Europe Platform for the safety of journalists, the criminal investigations into the 
use of spyware lacked clarity251. The Parliamentary Assembly of the Council of Europe urged 
Greece to conduct effective, independent and prompt investigations on all cases of abuse of 
spyware  and  provide  sufficient  redress  to  victims252.  In  March  2024,  the  Government 
submitted  its  reply  to  the  Parliamentary  Assembly  in  relation  to  the  Resolution  providing 
information  on  investigations  of  reported  individual  incidents  conducted  in  courts,  by  the 
National Transparency Authority and by the Parliament253, as well as on improvements of the 
applicable  legal  framework254.  In  April  2024,  the  Council  of  State  ruled  that  the  provision 
applicable  at  the  time  stipulating  that  an  individual  under  surveillance  for  national  security 
reasons could not be informed about this, is unconstitutional255. 

The  immunity  regime  for  members  of  Government  has  given  rise  to  a  public  debate. 
The  Constitution  provides  that  Parliament  has  the  exclusive  power  to  investigate  and 
prosecute  serving  and  former  members  of  the  Government  for  offences  committed  in  the 
discharge  of  their  duties256.  A  public  debate  started  following  Parliament’s  decision  not  to 
start  a  preliminary  investigation  into  allegations  against  former  members  of  Government. 
Stakeholders also  expressed concern over the immunity  regime257. A petition to  modify the 
legal  framework  on  immunities  gathered  1.5  million  signatures258  in  relation  to  a  separate 
case.  The  Plenary  of  Bar  Associations  announced  plans  to  set  up  a  working  group,  which 
would work on a corresponding legislative proposal and send it to the Speaker and the parties 

250  Reporters  Without  Borders,  Predatorgate  scandal  in  Greece:  RSF  denounces  the  political  sabotage  of  the 
investigation, 2 November 2023. Civil society also criticised that the transfer of the case was ordered while 
the first instance prosecutors were investigating if the targets of the illegal spyware were also targeted by the 
National Intelligence Service.  Joint Civil Society Submission to the  European Commission on the Rule of 
Law Report, para 11. Contribution from the European Civic Forum for the 2024 Rule of Law, pp. 12-13. 
251  Annual Report, Annual assessment of press freedom in Europe by the partner organisations of the Safety of 

Journalists Platform, pp. 71-72.  

252  Council  of  Europe:  Parliamentary  Assembly  (2023),  Resolution  2513,  Pegasus  and  similar  spyware  and 
secret State surveillance para 11.3. In March 2024, the Government submitted its reply to the Parliamentary 
Assembly in relation to the Resolution. Written contribution by Greece.  

253  Greece’s  Submission  to  PACE’s  Committee  on  Legal Affairs  and  Human  Rights  Request  for  Information, 

following Council of Europe’s Parliamentary Assembly Resolution 2513 and Report, March 2024 

254  Law  5002/2022, 5086/2024 and  strengthening  of Independent Authorities  charged  with  privacy protection. 
According  to  the  Greek  authorities,  new  cybersecurity  authority  will  closely  cooperate  with  intelligence 
services  and  independent  data  protection  authorities,  to  raise  the  level  of  awareness  and  protection  of 
citizens. 

255 Council of State (Plenary), 465/2024, 5 April 2024. 
256  Constitution, Article 86 paras 1 and 2, Rules of Procedure of Parliament, Article 153 and Law 3126/2003 on 
the criminal liability of Ministers and other provisions. Following a proposal submitted by thirty Members of 
Parliament,  Parliament  decides  by  absolute  majority  to  set  up  a  Parliamentary  Committee  to  conduct  a 
preliminary  examination  of  the  case.  The  findings  of  the  committee  are  introduced  to  the  Plenary,  which 
decides by absolute majority whether to prosecute.  

257  Information  received  from  the Athens  Bar Association,  the  Ombudsperson,  the  National  Commission  for 
Human Rights, Transparency International and Vouliwatch in the context of the country visit in Greece. 
258 The petition was launched by the families of victims of the train collision in the Tempi area on 28  February 
2023 in which 57 people died. Article 73 para. 6 of the Constitution foresees the right of 500 000 citizens to 
introduce  draft  bills  (citizens’  legislative  initiative).  However,  the  necessary  legislation  to  implement  this 
provision has not been adopted yet. 

29 

 
 
of the Parliament259. According to the association of judges and prosecutors, the justification 
for the current system is that members of Government would otherwise refrain from taking 
decisions under the threat of a lawsuit260. 

An  established  mechanism  is  in  place  to  ensure  the  administration’s  compliance  with 
judicial  decisions.  The  Constitution  contains  a  provision  on  the  obligation  of  the  public 
administration  to  comply  with  judicial  decisions261.  A  special  procedure  to  ensure  the 
execution  of  domestic  judicial  decisions  is  foreseen  by  law262.  The  judiciary  considers  that 
the mechanism works overall well except in some cases related to pension rights263.   

On 1 January 2024, Greece had 28 leading judgments of the European Court of Human 
Rights pending implementation, an increase of one compared to the previous year264. At 
that time, Greece’s rate of leading judgments from the past 10 years that remained pending 
was  at  30%  (compared  to  34%  in  2023)  and  the  average  time  that  the  judgments  had  been 
pending implementation was 6 years 7 months (same as in 2023)265. One of the oldest group 
of cases, pending implementation for more than 15 years, concerns violations of the right to 
freedom  of  association  due  to  the  domestic  courts’  rulings  not  to  register  or  to  dissolute 
associations  on  the  grounds  that  their  aim  was  to  promote  the  idea  that  an  ethnic  minority 
existed  in  Greece266.  As  regards  the  respect  of  payment  deadlines,  on  31  December  2023 
there were 7 cases in total awaiting confirmation of payments (compared to 13 in 2022)267. 

259 Athens Bar Association, Press Release, 5 June 2024. 
260  Information received from the Association of judges and prosecutors in the context of the country visit.  
261  Constitution, Article 95, paragraph 5. The Constitution also provides the compulsory execution of judgments 

against the state, local authorities and legal entities of public law (article 94 paragraph 4). 

262  Law  3068/2002.  A  three-member  council  within  the  jurisdiction  that  issued  the  relevant  judicial  decision 
examines,  at  the  request  of  the  private  party  concerned,  if  the  administration  has  not  complied  or  has  not 
correctly complied with the decision and, if so, it invites the  administration to comply within a prescribed 
time. The same panel can impose a penalty. 

263  The Court of Audit reported that in such cases, due to their impact on the State budget, the administration 
often refuses to comply even after the special procedure foreseen has been concluded. Information received 
from the Court of Audit in the context of the country visit.  

264 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. 

265  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  2024.  See  the  Contribution  from  the 
European Implementation Network for the 2024 Rule of Law Report, p. 4. 

266  In  December  2023,  the  Committee  of  Ministers  expressed  its deep  concern  that,  despite  the  legislative 
amendment  adopted  by  Greece  in  2017  which  allowed  the  reopening  of  the  impugned  proceedings,  the 
applicants have still not been provided with restitutio in integrum, despite having exhausted the possibilities 
available  to  them  within  the  domestic  legal  system; CM/Del/Dec(2023)1483/H46-15/  06  December  2023- 
H46-15 Bekir-Ousta and Others group v. Greece (Application No. 35151/05).  

267  Council  of  Europe  (2024),  Supervision  of  the  execution  of  judgments  decisions  of  the  European  Court  of 
Human Rights – 17th Annual Report of the Committee of Ministers – 2023, p. 137. The NCHR reports that 
Greece continues to maintain a satisfactory track record regarding the payment of just satisfaction ordered by 
the  Court.  ENNHRI  (2024),  The  state  of  the  rule  of  law  in  the  European  Union,  Reports  from  National 
Human Rights Institutions, Greece, Greek NCHR, p. 276. 

30 

 
 
On 1 July 2024, the number of leading judgments pending implementation had increased to 
29268. 

Some  further  progress  was  made  with  the  ongoing 
implementation  of  the 
interoperability  of  the  existing  registries  for  Civil  Society  Organisations,  while  the 
registration framework still needs to be evaluated in particular in relation to the Special 
Registries  of  the  Ministry  of  Migration  and  Asylum.  The  2023  Rule  of  Law  Report 
recommended to Greece to ‘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’269. In October 2023, the Public Database and the 
Special  Registry  for  CSOs  became  operational270  and  their  functioning  has  been  overall 
smooth271. The nine Special Registries managed by different ministries continue to operate, 
including  the  two  Special  Registries  of  the  Ministry  of  Migration  and  Asylum  (MoMA)272. 
There are ongoing efforts to make the different registries interoperable, thus minimising the 
number  of  documents  to  be  resubmitted  and  avoiding  duplication273.  In  May  2024,  the 
MoMA  abolished  the  obligation  for  registered  CSOs  to  renew  every  three  years  the 
registration  in  its  Special  Registries274.  These  are  positive  steps  aiming  to  reduce  costs  and 
administrative  burden,  while  the  need  to  evaluate  the  substance  of  the  current  legal 
framework  and  its  impact  on  the  CSOs’  ability  to  operate  remains,  in  particular  of  those 
CSOs  dealing  with  international  protection,  migration  and  social  integration275.  In  October 
2023,  in  a  targeted  meeting  with  CSOs,  the  MoMA  announced  its  intention  to  review  the 
legal  framework  governing  its  Special  Registries  and  requested  feedback.  Several  CSOs 
referred  to  specific  concerns  and  put  forward  concrete  proposals276.  The  MoMA  has  been 

268  Data according to the online database of the Council of Europe (HUDOC). 
269  In  the  2023  Rule  of  Law  Report,  the  Commission  concluded  that  some  progress  was  made  on  the 
recommendation to ensure that registration requirements for civil society organisations are proportionate in 
view of maintaining an open framework for them to operate. 2022 and 2023 Rule of Law Reports, Country 
Chapter on the rule of law situation in Greece, p. 2. 

270  2023  Rule  of Law  Report,  Country  Chapter  Greece,  p.  27;  Law  4873/2021.  CSOs  need  to  register  if  they 
wish  to  apply  for  state  funding  and  other  benefits.  Registration  requirements  for  the  Public  Database  are 
simpler  and  the  funding  is  up  to  EUR  50  000.  For  the  Central  Registry,  CSOs  need  to  submit  additional 
documents  and  can  receive  funding  over  EUR  50  000  as  well  as  support  by  targeted  tax  exemptions  and 
additional tax incentives.  

271  In the first eight months, 703 CSOs registered in the Public Database and 628 in the Special Registry. The 
average time to process applications was short and well below the time-limits prescribed in the law. Written 
contribution from the Ministry of Interior in the context of the country visit.  

272  Registry of Greek and Foreign Non-Governmental Organisations and Registry of NGO Members; 87 CSOs 
are  currently  registered  with  approximately  2,200  CSO  members  included  in  the  Registry  for  NGO 
Members,  8  applications  are  pending,  while  116  CSOs  were  denied  registration  at  least  once.  Written 
contribution from the Ministry of Migration and Asylum in the context of the country visit.  

273  The Ministries of Interior and Migration and Asylum have been working to establish an electronic validation 
process, through which the registration of a CSO in one of their Registries will be verified and status updates 
will  automatically  be  incorporated  in  the  other  ones.  The plans  shall  progressively  include  all  the  existing 
Registries,  while  interoperability  shall  be  implemented  by  early  2025.  Written  contribution  from  the 
Ministry of Interior in the context of the country visit; 2024 Annual Action Plan of the Ministry of Interior.  
274  Registered CSOs remain thus registered until a revocation decision. Ministerial decision 148104/19-5-2024.  
275  2021, 2022, 2023 Rule of Law Reports, Country Chapter on the rule of law situation in Greece, p. 13, pp. 

21-22 and p. 27 respectively. 

276  CSOs refer to (i) the excessive discretion of the administration in refusing or suspending registration based 
on  grounds  which  are  not  expressly  provided  by  the  law;  (ii)  the  administration’s  insistence  on  imposing 
registration requirements to lawyers; (iii) the compatibility of the legal framework with EU data protection 
legislation. Joint Civil Society Submission to the European Commission on the Rule of Law Report,  paras 

31 

 
 
 
engaging  with  CSOs,  which  could  pave  the  way  for  setting  up  a  structured  dialogue 
scheme277,  and  intends  to  submit  a  concrete  proposal278.  The  Council  of  State  has  not  yet 
delivered its judgment on the case challenging some aspects of the legality of the legislation, 
which  is  pending  for  more  than  three  years279.  Several  CSOs  offering  critical  services  to 
refugees  and  migrants  have  reported  difficulties  to  the  Commission’s  Task  Force  on 
Migration  Management  in  complying  with  registration  requirements.  In  some  cases,  CSOs 
reported that the difficulties to register resulted in the temporary suspension of their activities 
or  in  their  complete  inability  to  operate  due  to  the  freezing  of  their  assets  by  banks280. 
According  to  the  NCHR,  the  inconsistent  and  non-transparent  application  of  the  legal 
requirements for registration and the increased formalities has led many CSOs either to leave 
Greece  or  reduce  their  presence  in  the  field281.  The  Council  of  Europe  Commissioner  for 
Human Rights referred to the Greek registration system as raising concerns282. In light of the 
above, there has been some further progress on the implementation of the recommendations 
made in the 2023 Rule of Law Report.  

Concerns regarding the space for civil society remain. The civic space in Greece remains 
“obstructed” due to concerns in relation to civil society organisations working with refugees 
and asylum seekers283. In July 2023, the Commissioner for Human Rights of the Council of 
Europe called on Greece to actively create and maintain an enabling legal framework and a 
political  and public environment  conducive to  the existence  and functioning  of CSOs284. In 
September  2023,  in  response  to  a  request  submitted  by  115  lawyers,  the  Athens  Bar 
Association  expressed  the  opinion  that  lawyers  providing  legal  advice  and  assistance  to 
persons arriving in Greece and wishing to apply for international protection can in no way be 

112-123; Contribution from Civil Liberties Union for Europe  for the 2024 Rule of Law Report, pp.  19-20; 
Contribution from the Border Violence Monitoring Network for the 2024 Rule of Law  Report, pp. 25-26; 
Contribution from the European Civic Forum for the 2024 Rule of Law, pp. 7-8. 

277 The scheme will establish an annual high-level meeting between MoMA’s political leadership and CSOs and 
will be complemented by regular operational meetings with all relevant MoMA services. A key element of 
the  structured  dialogue  scheme  will  be  targeted  consultations  on  future  MoMA  initiatives.  Written 
contribution from the Ministry of Migration and Asylum in the context of the country visit.  

278  The  2024  Action  Plan  of  the  Ministry  of  Migration,  under  the  Action  relating  to  control  of  requests  and 
registration of CSOs, includes a milestone foreseeing a tri-monthly meeting with CSOs for information and 
better  coordination.    The  Government  has  submitted  an  updated  Action  Plan  including  a  new  action  with 
milestones to improve and update the current legal framework. Written contribution from Greece.  

279  2023 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 28.  
280  For  instance,  Boat  Refugee  Foundation,  active  in  reception  and  provision  of  medical  services  and  mental 
health  support  had  to  temporary  suspend  its  activities  on  the  ground.  HIAS  Greece  considers  that  the 
rejection  of  its  application  led  to  the  deactivation  of  its  bank  accounts  and  its  inability  to  perform  any 
financial transactions, including paying salaries, telecommunication bills and court fees. Written contribution 
from HIAS Greece in the context of the country visit. 

281  The NCHR referred to a field visit in the island of Samos and recommended to national authorities to review 
the  legal  framework  governing  the  Special  Registries  and  establish  transparent  and  uniform  criteria. 
ENNHRI (2024), The state of the rule of law in the European Union, Reports from National Human Rights 
Institutions, Greece, Greek NCHR, p. 258-260. 

282 Council of Europe, Commissioner for Human Rights (2024), Protecting the Defenders Ending repression of 
human  rights  defenders  assisting  refugees,  asylum  seekers  and  migrants  in  Europe,  Recommendation,  pp. 
16-17.  

283 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);  2023  Rule  of  Law  Report,  Country 
Chapter on the rule of law situation in Greece, p. 29. 

284 Council of Europe: Commissioner for Human Rights, Letter to Prime Minister of Greece, 19 July 2023. 

32 

 
 
considered as facilitating irregular entry  or stay285. In April 2024, the NCHR noted that the 
situation  of  human  rights  defenders  working  with  migrants  and  asylum  seekers  has 
deteriorated  and  made  an  urgent  appeal  to  the  government  to  act,  proposing  concrete 
measures286. A study by the Expert Council of NGO Law also refers to the stigmatisation and 
criminalisation  of  certain  activities  of  CSOs  in  Greece287.  The  adoption  of  a  law  legalizing 
same-sex marriages288 is expected to have a positive impact on the working environment for 
CSOs advocating for LGBTIQ+ rights289. The MoMA is in the process of instituting regular 
meetings with CSO representatives along specific thematic axes290 and has designated focal 
points in its services dealing with CSOs to better liaise with them291. It also plans to map the 
specific areas of expertise of the CSOs active in  the areas of migration and asylum, for the 
purposes  of  targeted  consultations292.  These  plans  are  positive  steps  that  remain  to  be 
implemented.  

285 Athens Bar Association (2023), 143/ 11-09/2023. 
286 NCHR, Statement of 22 April 2024 on human rights defenders working with migrants and asylum seekers.  
NCHR, Statement of 22 April 2024 on human rights defenders working with migrants and asylum seekers.  
NCHR, Statement of 22 April 2024 on human rights defenders working with migrants and asylum seekers.  
287 Conference of INGOs of the Council of Europe, Expert Council on NGO Law, Study on Stigmatisation of 

Non-Governmental Organisations in Europe, pp. 23, 32-33. 

288  Law 5089/2024. 
289  Joint  Civil  Society  Submission  to  the  European  Commission  on  the  Rule  of  Law  Report,  para  203. 
LGBTQI+  individuals  as  well  as  their  advocates  are  reported  as  targets  of  incidents  of  racist  violence. 
Network Racist Violence Recording (2024), Annual Report 2022.   

290 A first meeting to discuss issues arising from CSOs activities in the fields of migration and asylum initially 

scheduled for June 2024 was postponed to a later date. Written contribution from Greece.  

291 Written contribution from Greece.  
292 Idem. 

33 

 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2024 Rule of Law report 
can 
https://commission.europa.eu/publications/2024-rule-law-report-targeted-
stakeholder-consultation_en. 

found 

be 

at 

Athens Bar Association (2023), Appeal before the Council of State, 30 November 2023.  

Athens  Bar  Association  (2024),  Judicial  Independence  –  The  limits  of  criticism  to  justice,  press 
release, 23 February 2024. 

Athens Bar Association (2024), Press release of the President, 14 March 2024. 

Border  Violence  Monitoring  Network  (2024),  Contribution  from  the  Border  Violence  Monitoring 
Network for the 2024 Rule of Law Report. 

Centre of Liberal Studies (KEFIM) (2023), Quality of Law-Making Index 2023. 

Centre for Media Pluralism and Media Freedom,  Monitoring Media Pluralism in the Digital Era in 
the year 2022 (2023) Country report: Greece. 

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/. 

Civil Liberties Union for Europe (2024), Contribution from Civil Liberties Union for Europe for the 
2024 Rule of Law Report. 

Council of Bars and Law Societies of Europe (CCBE) (2024), Contribution from the Council of Bars 
and Law Societies of Europe for the 2024 Rule of Law Report. 

Council  of  Europe:  Commissioner  for  Human  Rights,  Letter  to  Prime  Minister  of  Greece,  19  July 
2023 

Council  of  Europe:  Commissioner  for  Human  rights  (2023),  Statement  Greece:  The  Ombudsman 
institution  opening  an  independent  investigation  into  the  Pylos  shipwreck  is  a  welcome  step,  9 
November 2023. 

Council  of  Europe:  Commissioner  for  Human  Rights  (2024),  Protecting  the  Defenders  Ending 
repression  of  human  rights  defenders  assisting  refugees,  asylum  seekers  and  migrants  in  Europe, 
Recommendation. 

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 (2023), Decision CM/Del/Dec(2023)1483/H46-16. 

Council of Europe: Parliamentary Assembly (2023), Resolution 2513, Pegasus and similar spyware 
and secret State surveillance. 

Council of Europe, Platform to promote the protection of journalism and safety of journalists. 

Council  of  Europe:  Venice  Commission  (2019),  Principles  on  the  Protection  and  Promotion  of  the 
Ombudsman Institution of the Venice Commission (CDL-AD(2019)005-e). 

Council of the European Union (2023), Council Implementing Decision amending the Implementing 
Decision of 13 July 2021 on the approval of the assessment of the Recovery and Resilience Plan for 
Greece with Annex. 

Court of Audit (2024), Written contribution from the Court of Audit for the 2024 Rule of Law Report 
in the context of the country visit. 

European  Civic  Forum  (2024),  Contribution  from  the  European  Civic  Forum  for  the  2024  Rule  of 
Law 

34 

 
Directorate-General  for  Communication  (2024),  Flash  Eurobarometer  543  on  Businesses’  attitudes 
towards corruption in the EU. 

Directorate-General  for  Communication  (2024),  Special  Eurobarometer  548  on  Citizens’  attitudes 
towards corruption in the EU. 

European  Centre  for  Press  and  Media  Freedom  (2024),  Mapping  Media  Freedom,  Greece  country 
profile. 

European Commission (2024), 2024 Country Report – Greece, SWD (2024) 608 final.  

European Commission (2024), EU Justice Scoreboard. 

European Commission (2023), EU Justice Scoreboard. 

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

European Commission (2023), 2023 Rule of Law Report, Country Chapter on the rule of law situation 
in Greece. 

European  Court  of  Human  Rights,  judgment  of  16  January  2024,  Alkhatib  and  Others  v.  Greece, 
3566/16. 

European Implementation Network (2024), Contribution from the European Implementation Network 
for the 2024 Rule of Law Report. 

European  Network  of  Councils  for  the  Judiciary  (ENCJ)  (2024),  Contribution  from  the  European 
Network of Councils for the Judiciary for the 2024 Rule of Law report. 

European Network of National Human Rights Institutions (2024), The state of the rule of law in the 
European  Union,  Reports  from  National  Human  Rights  Institutions,  Greece,  Greek  National 
Commission for Human Rights. 

European Parliament: Flash Eurobarometer: News & Media Survey 2023.  

European Parliament, Resolution of 7 February 2024 on the rule of law and media freedom in Greece. 

European 
Office 
https://www.eppo.europa.eu/sites/default/files/2024-03/EPPO_Annual_Report_2023.pdf.  

Prosecutor’s 

(2024), 

Annual 

Public 

EPPO 

Report 

2023, 

European  Public  Prosecutor’s  Office  (2023),  Greece:  EPPO  charges  23  suspects  with  crimes 
involving railway signalling systems, Press release, 12 December 2023. 

European 
Office 
https://www.eppo.europa.eu/sites/default/files/2024-03/EPPO_Annual_Report_2023.pdf. 

Prosecutor’s 

(2024), 

Annual 

Public 

EPPO 

Report 

2023, 

Franet, [Centre for European Constitutional Law (in collaboration with Hellenic League for Human 
Rights  and  Antigone-Information  and  Documentation  Centre  on  racism,  ecology,  peace  and  non-
violence)] (2024), 
Country  research  –  Legal  environment  and  space  of  civil  society 
organisations  in  supporting  fundamental  rights  –  Greece,  EU  Agency  for  Fundamental  Rights, 
https://fra.europa.eu/en/publication/2024/fundamental-rights-report-2024.  

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

35 

 
GRECO  (2023),  Fourth  Evaluation  Round,  Preventing  corruption  in  respect  of  members  of 
parliament, judges and prosecutors – Second Addendum to the Second Compliance Report on Greece. 

GRECO  (2024),  Fifth  Evaluation  Round,  Preventing  corruption  and  promoting  integrity  in  central 
governments (top executive functions) and law enforcement agencies – Compliance Report on Greece. 

Greek Association of Judicial Clerks (2023), Decision of the Conference of the Association of Judicial 
Clerks, 29 November – 2 December 2023. 

Greek Data Protection Authority (2023), DPA actions in relation to activities of installing and using 
spyware in Greece, Press Release of 20 July 2023. 

Greek Council of State (2024), Judgment (plenary) 465/2024 of 5 April 2024.  

Greek Government (2024), Input from Greece for the 2024 Rule of Law Report. 

Greek National Commission for Human Rights (2023), Statement on Independent authorities, Issues 
of  ensuring  the  institutional  integrity  of  the  constitutionally  enshrined  Independent  Authorities  and 
respecting the regime of increased guarantees of their members, 30 November 2023. 

Greek  Ombudsman  (2023),  2022  Special  Report,  National  Mechanism  for  the  Investigation  of 
Arbitrary Incidents. 

Greek  Ombudsman  (2023),  Press  release  9  November  2023,  The  Ombudsperson  investigates  the 
Pylos shipwreck. 

HIAS Greece (2024), Written contribution from HIAS Greece in the context of the country visit. 

Hellenic  Parliament  Committee  on  asset  declarations  (2024),  Written  contribution  from  the 
Parliamentary Committee on asset declarations for the 2024 Rule of Law Report in the context of the 
country visit. 

Hellenic Police (2024), Written contribution the Hellenic Police in the context of the country visit to 
Greece. 

Hellenic  Single  Public  Porcurement  Authority  (HSPPA),  Written  contribution  the  Hellenic  Single 
Public Porcurement Authority in the context of the country visit to Greece. 

Human Rights Watch (2024), Contribution from the Human Rights Watch for the 2024 Rule of Law 
Report. 

International  Press  Institute  (IPI)  et  al.  (2024),  Greece:  Ahead  of  court  hearing,  SLAPP  lawsuit 
against media and journalists must be dropped, 18 January 2024. 

Kathimerini (2023), Surveillance, the request of the two judges to ADAE, 24 October 2023. 

Médecins  Sans  Frontières  and  11  other  CSOs  (2024),  Letter  of  20  March  2024  addressed  to  the 
Secretary General for Reception of Asylum Seekers. 

Media  Freedom  Rapid  Response,  Murdered,  surveilled  and  sued:  decisive  action  needed  to  protect 
journalists and salvage press freedom in Greece, 27 September 2023. 

Media  Freedom  Rapid  Response  –  Mission  Report:  Stemming  the  tide  of  Greek  media  freedom 
decline, 30 January 2024. 

Ministry of Citizen Protection (2024), Written contribution from the Ministry of Citizen Protection in 
the context of the country visit to Greece. 

Ministry  of  Interior  (2024),  Written  contribution  from  the  Ministry  of  Interior  for  the  2024  Rule  of 
Law Report in the context of the country visit. 

List  of  items  offered  as  gifts  to  members  of  the  Government  and  Deputy  Ministers  in  2022-2023, 
https://www.primeminister.gr/wp-content/uploads/2024/05/katalogos_2022-2023.pdf. 

Ministry of Justice (2023), Annual Action Plan 2024. 

36 

 
Ministry of Justice (2024), Written contribution from the Ministry of Justice for the 2024 Rule of Law 
Report in the context of the country visit. 

Ministry of Migration and Asylum (2023), Annual Action Plan 2024. 

Ministry of Migration and Asylum (2024),  Written contribution from the Ministry of Migration and 
Asylum for the 2024 Rule of Law Report in the context of the country visit. 

National  Council  for  Radio  and  Television,  Supreme  Council  for  Civil  Personnel  Selection,  Data 
Protection Authority, Ombudsperson and Hellenic Authority for Communication Security and Privacy 
(2023),  Press  release  of  the  constitutionally  enshrined  Independent  Authorities  on  the  joint 
Conference  Constitutionally  Enshrined  Independent  Authorities:  Their  contribution  to  a  European 
democratic rule of law, 7 November 2023. 

National  Transparency  Authority  (2024),  Written  contribution  from  the  National  Transparency 
Authority for the 2024 Rule of Law Report in the context of the country visit. 

National  Transparency  Authority  (2024),  NACAP  2022-2025  Implementation  Report  2nd  Semester 
2023. 

National  Transparency  Authority  (2024),  Press  release  ‘E-peitharxika  Application’,  National 
Transparency Authority - E-peitharxika Application (aead.gr).  

Network Racist Violence Recording (2024), Annual Report 2022. 

Network  Racist  Violence  Recording  (2024),  Press  release  on  the  violent  incident  against  two 
LGBTQI+ individuals in Thessaloniki, 15 March 2024. 

N.K. Alivizatos, Opinion on the new judicial map, 26 February 2024. 

OECD (2023), Implementing the OECD Anti-Bribery Convention, Phase 4 Report for Greece.  

OECD (2024), Implementing the OECD Anti-Bribery Convention, Phase 4 Report for Greece 

OECD  (2024),  Anti-corruption  and  Integrity  Outlook,  Country  Fact  Sheet 
https://www.oecd.org/publication/anti-corruption-and-integrityoutlook/2024/webbooks/dynamic/anti-
corruption-integrity-outlook-country-notes/d0a9beef/pdf/greece.pdf. 

for  Greece, 

Prosecutors  for  Financial  Crimes  (2024),  Written  contribution  from  the  Prosecutors  for  Financial 
Crimes in the context of the country visit to Greece. 

Reporters  Without  Borders  (2023),  Predatorgate  scandal  in  Greece:  RSF  denounces  the  political 
sabotage of the investigation, Statement of 2 November 2023. 

Reporters without Borders (2024), 2024 World Press Freedom Index.  

Supreme Court, Administrative Plenary Decision 2/2024, 15 February 2024. 

SyntagmaWatch  (2024),  N.  Papaspyrou,  Constitution:  Interpretation  by  article,  Article  74, 
Amendments to draft bills and proposals for law. 

Transparency 
https://www.transparency.org/en/cpi/2023. 

International 

(2024), 

Corruption 

Perceptions 

Index 

2023, 

Vouliwatch,  Greek  Council  for  Refugees  (GCR),  HIAS  Greece,  Refugee  Support  Aegean  (RSA), 
Hellenic  League for  Human  Rights,  Reporters  United  (2024),  Greece  in  Institutional  Decline,  Joint 
Civil Society Submission to the European Commission on the 2024 Rule of Law, January 2024.  

Vouliwatch,  Greek  Council  for  Refugees  (GCR),  HIAS  Greece,  Refugee  Support  Aegean  (RSA), 
Hellenic League for Human Rights, Reporters United (2024), Greece in Institutional Decline, 60-day 
update,  Addendum  to  the  Joint  Civil  Society  Submission  to  the  European  Commission  on  the  2024 
Rule of Law, March 2024. 

37 

 
Annex II: Country visit to Greece 

The Commission services held virtual meetings in March 2024 with: 

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

•  Authority for Communication Security and Privacy (ADAE) 
•  Committee of Parliament for the Investigation of Declarations of Assets (CIDA) 
•  Council of State 
•  Court of Audit 
•  Foreign Press Association Greece 
•  Greek Association of Judges and Prosecutors 
•  Greek Bar Associations 
•  Greek Council for Refugees 
•  Greek Data Protection Authority(DPA) 
•  Greek National Commission for Human Rights 
•  Greek Ombudsman 
•  Hellenic Broadcasting Corporation (ERT)  
•  Hellenic Federation of Enterprises (SEV) 
•  Hellenic League for Human Rights 
•  Hellenic Single Public Procurement Authority (HSPPA) 
•  HIAS Greece 
• 
•  Journalists' Union of Athens Daily Newspaper (ESIEA) 
•  Ministry of Citizen Protection 
•  Ministry of Interior 
•  Ministry of Justice 
•  Ministry of Migration and Asylum  
•  National Audiovisual Regulator 
•  National Commission for Human Rights 
•  National Transparency Authority 
•  Panhellenic Federation of Journalists' Unions 
•  Professor Nikos K. Alivizatos, member of the Venice Commission  
•  Prosecutor for Financial Crimes and the Financial Police Division 
•  Prosecutor's Office to the Supreme Court 
•  Refugee Support Aegean 
•  Reporters United 
•  Secretariat General for Communication and Media 
•  Secretariat General of Legal and Parliamentary Affairs 
•  Special Secretary to the President of Parliament 
•  Supreme Court 
•  Transparency International Greece 
•  Vouliwatch 

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

38 

 
 
•  Amnesty International EU 
•  Centre for Democracy and Technology Europe 
•  Centre for European Volunteering 
•  Civil Liberties Union for Europe 
•  Civil Rights Defenders 
•  Civil Society Europe 
•  Culture Action Europe 
•  Democracy Reporting International 
•  European Centre for Non-Profit Law 
•  European Civic Forum 
•  European Federation of Journalists 
•  European Partnership for Democracy 
•  European Youth Forum 
•  Free Press Unlimited 
• 
• 
• 
• 
•  JEF Europe 
•  Open Society Foundations 
•  Philanthropy Europe Association 
•  PICUM 
•  Reporters Without Borders 
•  SOLIDAR 
•  Transparency International EU 

International Federation for Human Rights 
International Planned Parenthood Federation 
International Press Institute 
Irish Council for Civil Liberties 

39