EUROPEAN COMMISSION
DIRECTORATE GENERAL
ECONOMIC AND FINANCIAL AFFAIRS

9 JUNE 2016

Compliance Report
The Third Economic Adjustment
Programme for Greece
First Review
June 2016

1. Introduction
In July 2015, after the expiry of the previous programme supported by EFSF financing, Greece requested the
European Stability Mechanism (ESM) financial assistance, to restore fiscal sustainability, address the risks to its
own financial stability and to that of the euro area, promote sustainable growth, create jobs and reduce
inequalities, and modernise the State and public administration. In August 2015, the Hellenic Republic
concluded an agreement for stability support in the form of a loan from the ESM for an availability period of
three years. In accordance with the ESM Treaty, a Memorandum of Understanding (MoU) was signed by the
European Commission, on behalf of the ESM, which details the conditionality attached to the financial
assistance facility covering the period 2015-18. Fulfilment of the conditionality is assessed at regular reviews,
taking account of the progress in reforms.
The policies in the MoU are built around four pillars:





restoring fiscal sustainability;
safeguarding financial stability;
growth, competitiveness and investment;
a modern State and public administration.

This report on compliance with the MoU upon conclusion of the first review of the ESM programme has been
prepared by the Commission staff, in liaison with the ECB staff, based on the findings of the missions to Greece
carried out by the Commission every month between October 2015 and April 2016, together with ECB, ESM
and IMF staff. In addition, Greece completed two sets of milestones in November 2015 and December 2015,
which contained important reforms relevant for the completion of the 1st review of the ESM programme.
The policy package described in the supplemental MoU is final. Ahead and subsequent to the Eurogroup
meetings of 9 and 24 May 2016, the Greek parliament has adopted legislative acts to deliver the actions agreed
in the supplemental MoU prior to the disbursement of the second tranche of the ESM programme. Notably, a
large number of provisions were adopted through law 4387 of 12 May 2016 (FEK A85) and the omnibus law
4389 of 27 May 2016 (FEK A 94) as amended on 3 June 2016 [law not yet published in the OJ]. The
government also adopted a host of secondary legislation in May and June 2016, through Ministerial decisions
and other acts, as agreed with the institutions.
On the basis of this analysis of compliance with the MoU, the ESM programme is broadly on track paving
the way for the next disbursement to Greece of an amount necessary to cover the outstanding debt service
until the expected completion of the next review, and an amount to help clear the sizeable stock of arrears
in line with an agreed clearance plan.
Supported by the launch of the ESM programme in August 2015, the Greek economy demonstrated resilience in
2015 which is forecast to result in a recovery in the second half of 2016. Real GDP in 2015 turned out to be only
slightly negative, falling by 0.2%, but that is over one percentage point better than expected after the imposition
of capital controls (see Table 1). Economic activity was backed by the resilience of private consumption,
positive net exports and by an acceleration of public investment at the end of the year. Mostly due to negative
carry-over from 2015, Greece’s real GDP is forecast to contract by 0.3% in 2016. While fiscal consolidation
should continue to weigh on household disposable income, the fall in public and private consumption is expected
to be partly offset by a positive contribution of net exports backed by another good year for tourism and positive
trends in the export of goods. The economy is expected to start growing again in the second half of 2016 and
should gather strength in 2017 as domestic demand accelerates with the help of EU structural funds, and of
liquidity injected via the clearance of government arrears. Greece’s current account deficit has been improving
since 2011 and it is expected to turn positive in 2016, as past and ongoing structural reforms improve external
competitiveness. Unemployment fell in 2015 and is projected to continue declining over the forecast horizon,

while prices should fall marginally in 2016 and increase moderately in 2017 with the strengthening of domestic
demand.
Table 1. The macroeconomic forecast (2015-18) made in August 2015 and May 2016
August 2015
y-o-y % change

May 2016

Difference

2015

2016

2017

2018

2015

2016

2017

2018

2015

2016

2017

2018

Proj.

Proj.

Proj.

Proj.

Act.

Proj.

Proj.

Proj.

Act.

Proj.

Proj.

Proj.

Nominal GDP

-3.2

-0.7

3.4

4.1

-0.9

-0.5

3.5

4.0

2.3

0.2

0.1

-0.1

Real GDP

-2.3

-1.3

2.7

3.1

-0.2

-0.3

2.7

3.1

2.1

1.0

0.0

0.0

Nominal private consumption

-2.7

-0.5

2.7

2.6

-1.0

-0.7

2.4

2.8

1.7

-0.2

-0.3

0.2

Compensation of employees

-3.2

-0.8

3.4

4.1

1.5

-0.4

3.5

4.4

4.7

0.4

0.1

0.3

Gross operating surplus

-3.2

-0.7

3.5

4.1

-1.9

-0.7

3.5

4.5

1.3

0.0

0.0

0.4

Source: European Commission
Significant implementation risks to the programme remain. Uncertainties around the macroeconomic forecast
remain large. Potential upside risks could come from a faster-than-expected pick-up in business and consumer
confidence, whereas downside risks are related to a failure to fully deliver on the reform programme, a higherthan-expected negative impact of the refugee crisis on trade and tourism, as well as the slowdown in global trade
and the effects of protracted capital controls. A lack of progress by authorities and banks in working out NPLs,
cleaning and strengthening bank balance sheets with the help of private investors and management, and in
improving the payment culture, could severely undermine the ability of banks to supply more credit and support
strong, sustainable economic and employment growth. Sustained and determined reforms in the areas of product
(goods and services) market, public administration, justice and anti-corruption could clearly reduce costs for
businesses and households and underpin a recovery in investment. Progress on the privatisation programme may
be more significant if heightened investor interest results in stronger participation and higher proceeds, and if the
governance of the new Privatisation and Investment Fund protects the Boards of the companies from undue
interference

3

2. Programme Implementation
2.1. PILLAR I. RESTORING FISCAL SUSTAINABILITY
As part of the new ESM programme agreed in August 2015, Greece committed to a revised fiscal path
with a primary balance target of -0.25% of GDP in 2015 rising to a primary surplus of 3.5% of GDP by
2018. To demonstrate their commitment to this path, the Authorities legislated in July and August 2015 fiscal
measures worth 1.7% of GDP in annual terms comprising primarily of a reform of the VAT system and
pensioners' health contribution rate increases and stronger disincentives for early retirement. The resilience of
the economy, the fiscal consolidation in the second half of 2015 and certain positive one-off factors helped
Greece achieve - according to the programme definition - a primary surplus of 0.7% of GDP in 2015,
overachieving the primary balance target of -0.25% of GDP by about 1p.p. of GDP.
Notwithstanding the over-performance relative to targets in 2015, additional parametric measures, which
are expected to yield 3% of GDP by 2018, were adopted by the government to credibly reach the
programme’s primary surplus targets of 0.5% of GDP in 2016, 1.75% of GDP in 2017 and 3.5% of GDP
in 2018. The size and composition of the agreed fiscal package is in line with the MoU adopted in summer 2015
and fully closes the fiscal gap to reach the agreed targets. This package of parametric measures was adopted
through legislative acts as a prior action. As shown in Table 2, the fiscal adjustment by 2018 consists of 1% of
GDP from a major pension reform; 1% of GDP from a structural personal income tax reform; over 0.2% of GDP
from an increase in the standard VAT rate, up to 0.2% of GDP from savings on the public sector wage bill, and
the remaining 0.6% of GDP from other parametric measures mainly in the areas of motor vehicle taxation, excise
and consumption taxes (primarily on energy products, alcoholic beverages, and tobacco) that raise rates and
close existing exemptions and loopholes. In addition to the package of parametric measures, there are a large
number of administrative and structural fiscal reforms in the MoU, especially to improve tax collection and to
fight evasion, and to find savings through spending reviews. These are being supported by technical assistance
through the Structural Reform Support Service (SRSS) of the Commission: properly implemented, they could
generate a substantial yield of up to ¾% of GDP and provide a buffer against slippages.
Table 2. Overview of the parametric fiscal measures to reach the ESM primary surplus targets in 20162018 (net savings)
% of GDP

bn EUR

2016

2017

2018

Primary balance target 1/

0.5

1.75

3.5

Primary balance under baseline scenario 2/

-0.2

-0.5

0.5

Fiscal gap under baseline scenario

0.7

2.3

3.0

I.

Pension reform

0.4

0.8

1.1

II.

Income tax reform

0.1

0.8

III.

Other parametric meaures

0.2

0.8

VAT reform

0.1

Wage bill reform

0.0

2016

2017

2018

0.9

3.2

6.6

-0.4

-1.0

1.0

1.3

4.1

5.7

0.7

1.4

2.0

1.0

0.2

1.4

1.9

0.9

0.4

1.5

1.7

0.2

0.2

0.3

0.4

0.4

0.1

0.2

0.0

0.1

0.3

Other tax measures

0.1

0.5

0.5

0.1

0.9

1.0

Total parametric policy package (I+II+III)

0.7

2.3

3.0

1.3

4.3

5.6

Fiscal gap after total permanent parametric policy package 3/

0.0

-0.1

0.0

Memo items: GDP - bn EUR

0.0

-0.1

0.0

175.1

181.3

189.3

1/ Primary balance as defined under the Economic Adjustment Programme, 2/ Includes measures legislated in July-August 2015
3/ (-) signals over-performance vis-à-vis target; (+) signals fiscal gap vis-à-vis target

Source: European Commission
4

Moreover, the Authorities legislated as a prior action a contingent fiscal mechanism that ensures that
additional measures are automatically implemented to address any divergence from targets. The
Eurogroup on 22 April 2016 concluded that to safeguard the achievement of the fiscal targets of the programme,
a contingency mechanism would need to be adopted by the Greek authorities that would be credible, legislated
upfront, automatic and triggered based on objective factors as soon as there is objective evidence of a failure to
meet the annual primary surplus target in the programme (3.5% of GDP in the medium term). The contingent
fiscal mechanism will be triggered automatically in year (t) in the event of a negative difference between the
target of the ESM programme for the year (t-1) and the actual outcome, as objectively assessed by ELSTAT in
April and validated by Eurostat in the context of the standard procedure of fiscal notification. Exceptions to the
activation of the mechanism will be limited to exceptional events with a major economic impact outside
government control. On this basis, an adjustment will be undertaken equal to the negative deviation from the
target, up to the size of 2 percent of GDP on an annual basis. Structural measures, including revenue measures,
may be taken to replace the measures enacted under the mechanism, and incorporated in the budget of the
following year in consultation with the institutions. The contingent mechanism, in any case, does not prejudice
the standard ex-ante assessment of fiscal gaps and the adoption of adjustment policies aimed at preventing the
emergence of targets’ shortfalls.
The new personal income tax reform completes the process of reform and modernisation of the income tax
system, while generating further revenues of 1% of GDP. The previous reform adopted in 2012 introduced
modern rules for the calculation of business profits, reinforced by the new Accounting Code; eliminated a host of
arbitrary tax allowances and credits, providing a single tax credit, restricted to employment and pension income;
and provided a fully consistent codified framework for the income tax by introducing an Income Tax Code. The
new reform adopted as a prior action for the first review addresses issues which had emerged with the
implementation of the 2012 reform and raises 1% of GDP by making further fundamental changes, as it: (i)
reduces the opportunities for tax avoidance by pooling business and employment income and taxing it on a
single tax schedule; (ii) attenuates the preferential tax regime for farmers by taxing farming income, including
direct subsidies, on the same tax scale as other forms of income while providing a standard tax credit, and by
tightening the definition of professional farmer able to claim the tax credit; (iii) integrates the Solidarity
Surcharge fully into the Income tax system changing from average to marginal tax rates and partly harmonising
the bands with those for personal income tax; (iv) reduces marginal tax rates in particular tackling the problem of
high marginal tax rates for tax payers on middle incomes; (v) broadens the tax base and gives additional
incentives for labour participation and work by reducing tax credit thresholds, which now take account of family
composition.
The semi-autonomous public revenue administration is being transformed into a fully autonomous
agency, while a host of measures are being taken to improve compliance, fight fraud and evasion, and
increase revenue collection. The legislation establishing the new Agency for tax and customs was adopted as a
prior action with its independent Board of Governors, CEO and budget, while reporting to the Government and
Parliament. By June the authorities will operationalize the transfer of IT related functions by signing a Service
level agreement. The Agency is expected to be fully operational by 1st of January 2017.
A series of other strategic plans and measures are to be implemented to increase tax compliance and tax
collection. This will occur inter alia through the promotion and facilitation of the use of electronic payments;
fully-fledged plans on compliance and on collection including a series of measures such strengthening
enforcement, publishing an update of the list of large tax debtors, and ensuring triage of the large debtors, while
the potential of a voluntary disclosure initiative will be explored. The fight against smuggling and custom
services efficiency will be enhanced. Cooperation between Justice and tax administration will be improved and
unnecessary litigations will be reduced. The authorities are reinforcing the tools for social security debt
collection by providing access to indirect bank account registry and to tax administration data and are taking
steps to integrate all social security collection functions - as part of the integration of funds within the pension
reform - with the view to transfer them to the tax administration by end 2017. The results of the reforms of both
the taxation and the revenue administration now being put in place are expected to become more visible in terms
of stronger revenues over the next quarters as implementation progresses.

5

Greece has made further progress in Public Financial Management reforms including by upgrading the
legislation on public procurement. This includes measures to upgrade the Organic Budget Law (OBL) and
finalise the work to transpose the EU directives on public procurement and concessions. These reforms allow
provision of timely and accurate budgetary information, assure strict compliance with the ceilings of the entity’s
budget, ensure the management and optimal utilisation of each entity’s resources, and create the conditions for
budgetary savings from an efficient procurement system. A key requirement of the Organic Budget Law adopted
in October 2015 is the transfer of financial management functions from the Fiscal Audit Offices (FAOs) to the
General Directorates of Financial Services (GDFS) embedded in each line ministry, which is expected to be
completed by January 2017. The authorities will complete the entire OBL reform by end-December 2016,
including termination of the ex-ante audit of payments by the Hellenic Court of Audit in a phased manner. The
members of the Board of the Fiscal Council were appointed, and the Council will be fully staffed by July 2016
and is expected to issue its first opinion by September 2016. The Government has initiated work to design a new
government Budget Classification structure and Chart of Accounts due by December 2016 so that it can be used
for the 2018 Budget. The authorities have taken action in the area of public procurement to increase efficiency
and transparency of the Greek public procurement system, prevent misconduct, and ensure more accountability
and control. Based on the Action Plan on Public Procurement agreed with the European Commission in October
2015, they will adopt in June 2016 a consolidated, comprehensive and simplified legislative framework (primary
and secondary legislation) agreed with the European Commission on public procurement and concessions,
including the transposition of the new EU Directives and the establishment of a Remedies Review Body which
will start operating by 31 December 2016.
The authorities are updating the plan to complete the clearance of arrears by June 2017, also using
designated programme financing. It is expected that clearance of arrears can resume and proceed at an
accelerated pace in 2016 as soon as the ESM disbursement takes place, which would have a positive impact on
the economy and in turn on public revenues. A stronger monitoring mechanism, consisting in monthly reports
from the authorities signed by the finance minister and validated by the Commission, for clearance of net
arrears1 will be established as part of the arrangement related to the disbursement of the sub-tranches of the
release. The Government is also working on a medium-term action plan with the aim to ensure that payments
will be made in compliance with the Late Payment Directive, and on improving the fragmented cash
management system.
The authorities have finalised in close cooperation with the institutions the details of a very comprehensive
and ambitious reform of the pension system. Significant pension measures, which include the curtailment of
early retirement rights, were adopted with the launch of the ESM programme in summer 2015 and are expected
to already generate savings of 0.5% of GDP. The reform adopted as a prior action will produces significant
further fiscal savings by 2018. The reform involves a move to a unified system where the new rules would
immediately apply to all pensions without pro-rating. Existing pensions would be recalibrated according to the
new parameters: current retirees with positive differences continue to be paid the same main pensions in nominal
terms, but these are frozen until any gap between the current and recalibrated pension (known as a 'personal
difference’) is eliminated through the effects of inflation. This reform also addresses the 2015 Council of State
ruling that cancels the pension cuts of 2012 (with a potential impact of 2 pps. of GDP). In gross terms, the
overall fiscal savings from the new reform and that of August 2015 are estimated to be 0.9% of GDP in 2016,
rising to 1.7% in 2018, 2.2% and 3.0% of GDP by 2020 and 2025 respectively, or over 5% of GDP if one
includes the offsetting of the Council of State ruling. The part of savings coming from the expenditure side is
large, reaching 1.0% of GDP by 2018 and growing over time to 2.4% of GDP by 2025. Some elements of the
prior action have been delayed to September 2016, when the harmonisation of social security contributions will
be finalised by: (i) eliminating the lower minimum contribution base for owners of tourist accommodation; (ii)
repealing all exemptions allowing for lower health contributions; (iii) revising downwards the discount for lump
sum payment of notional insurance periods.

1

The clearance of net rather than gross arrears would ensure that the authorities use the funding to clear already existing arrears rather than
new arrears that would accumulate going forward.

6

Table 3. Fiscal impact of proposed pension reform (% of GDP)
2016

2017

2018

2019

Measures legislated in 2015

0.5

0.5

0.5

0.6

Measures legislated in the 1st review

0.5

0.9

1.2

2020

2025

2030

0.6

0.6

0.6

1.4

1.6

2.5

2.5

% of GDP (gross savings)

0.4

0.7

1.0

1.2

1.5

2.4

2.5

Total gross savings

of which: on expenditure

1.0

1.4

1.7

2.0

2.2

3.0

3.1

Measures legislated in 2015

0.4

0.4

0.5

0.5

0.5

0.5

0.5

Measures legislated in the 1st review

0.4

0.8

1.1

1.2

1.4

2.1

2.2

0.3

0.6

0.9

1.1

1.3

2.1

2.2

0.8

1.2

1.5

1.7

1.9

2.7

2.7

Offset of the Council of State ruling

2.0

2.0

2.0

2.0

2.0

2.0

2.0

Total gross savings including offset of Council of State

3.0

3.4

3.7

4.0

4.2

5.0

5.1

% of GDP (net savings) 1/

of which: on expenditure
Total net savings
Memo items:

1/ Taking account of impact on income taxes and social security contributions

Source: European Commission
After backtracking in early 2015, prospects of modernisation for the health care system have improved
although progress is uneven across areas. The Greek authorities have established universal access to health
care, building on legislation introduced under the previous programmes, providing that right for all uninsured
and financially vulnerable Greek citizens, as well as for other vulnerable categories. A number of key
deliverables of the MoU have been achieved, with the clawback on hospital pharmaceutical spending, the
extension of the clawbacks on diagnostics and private clinics to 2018, the cuts in prices of diagnostics and the
gradual elimination of exemptions to price reductions in pharmaceuticals. The authorities have adopted or
planned measures to support cost containment and the use of generic medicines, including the planned reintroduction of centralised public procurement. These are all important steps to preserve both access for citizens
and affordability under a constrained budget and are a key enabler of affordable universal access. Despite
progress, the adoption of structural measures, key to cost-efficient public spending, is lagging behind, often
hindered by vested interests. As a result, expenditure is still above the targets in all the regulated areas. In
addition, there have been episodes of interference which hampers reform efforts, causing delays in policy
implementation and backtracking. This includes the replacement on unclear grounds of the large majority of
hospital administrators that had been previously selected based on meritocratic and transparent criteria, despite
the repeal of a law granting the Minister of Health the faculty to unilaterally appoint hospital CEOs without any
selection process. While this law has been abolished, such episodes raise doubts about the prospects of the health
system to become managed on a professional basis. Regarding health insurance, the issue of persistent arrears in
payments from Social Security Funds to National Organisation for the Provision of Health Services (EOPYY)
continues to be problematic. This is exacerbated by the liquidity crisis in the overall economy.
The programme has a strong focus on social welfare and reducing unemployment. In order to get people
back to work, the authorities, working closely with European partners, have taken measures to boost
employment by providing short-term work opportunities to 52,000 people targeting the long-term unemployed.
In addition, the Government will issue the required Joint Ministerial Decisions and will roll out by September
2016 further active labour market integration schemes which will combine public work and activation
(personalized services, upskilling, re-skilling) measures covering some 43,000 persons.
The Government with the assistance of the World Bank has launched the Social Welfare Review. This
aims at reforming benefits including cash and in-kind benefits, tax expenditures, social security (excluding
pensions) and other social benefits across the general government. The review is planned to be completed by
September 2016. A key part of the Review will be to propose improvements to the system of benefits addressing
specific care needs such as for children and disabilities to reduce fragmentation of welfare and social insurance
benefits and move towards a modern system comparable to that of other EU Member states. The review will
serve as the basis for the rationalization of a redesigned and targeted welfare system, aimed at identifying
7

savings of ½ percent of GDP annually to allow for the introduction of a new guaranteed minimum income
scheme (GMI). After extensive work and pilot tests in the course of the last year, with the assistance of the
World Bank, the authorities have completed preparation and will launch the gradual roll-out of GMI in 30
municipalities by June 2016, with a view to completing it nationwide by end 2016. It will be a key component of
the country’s strategy for social welfare, based on consolidation and better targeting of all existing benefits to
ensure a fiscally sustainable, more efficient and effective allocation reaching those most in need.
2.2. PILLAR II. SAFEGUARDING FINANCIAL STABILITY
The recapitalisation of systemic banks was completed before the end of 2015, and is being followed with
measures to strengthen the governance of banks and the Hellenic Financial Stability Fund (HFSF). The
four systemic banks made a significant capital increase in November/December 2015, and the less systemic
banks also managed to increase their capital. The recapitalisation was necessary following an ECB/SSM
comprehensive assessment of the four systemic banks that revealed a significant capital shortfall . The
recapitalisation through private and public sources brought the average capital adequacy ratio of the four core
banks to approximately 16.2% as of end-2015. They received state aid in the form of a financial backstop
(underwriting) of their capital increase by the HFSF, thereby triggering additional cost cutting requirements as
part of their revised restructuring plans agreed with the Commission. Eventually, only two of them received
capital injections (in the form of common shares and contingent convertible capital) from the HFSF as part of
precautionary recapitalisations, while the other two managed to raise their required capital needs fully on the
market. The two banks that received state aid in the form of a precautionary recapitalization also had to accept
additional divestment commitments as part of their revised restructuring plans.
The governance of the HFSF is being strengthened. To this end, a new procedure for the selection and
appointment of members in the Executive Board and General Council has been adopted and the Selection Panel composed of six independent expert members, of which three appointed by the EU institutions - has been created
to proceed to these appointments and to review annually their performance. This process is now underway and is
expected to be completed at the beginning of the summer. The HFSF has launched the procedure for the review
of the banks' boards, supported by the EBRD in this task, to be finalised by end-June 2016. The HFSF will
become a fully independent sub-entity of the new Privatisation and Investment Fund from the establishment of
the latter, while preserving its current governance arrangements.
Further measures have been put in place to help resolve the high amount of non-performing loans (NPLs).
As part of the milestones package in December 2015, the authorities partially liberalised the market for the
servicing of NPLs by non-bank financial companies and created the possibility for banks to sell certain
categories of NPLs to non-banks. As prior action for the 1st review, the legislation dealing with NPLs was
modified to remove tax and other impediments to the efficient functioning of these markets. The authorities
liberalised the sale of all performing and non-performing loans with the only temporary exception for the sale of
loans secured by primary residences with an objective value of the property up to EUR140,000, for which the
liberalisation will enter into force on 1 January 2018.
Agreement has been reached on other important measures to tackle the NPLs and these will be key
deliverables for subsequent reviews of the ESM programme. The authorities have set up the consultative
committee to fully operationalise the licensing framework of credit servicing firms; and have enacted tax
provisions in order to facilitate debt write-offs and incentivise the borrowers to timely engage in out-of-court
settlements. To optimize the costs and maximize efficiency in collections of the NPL portfolios from banks that
have been put under resolution, the Bank of Greece (BoG) has appointed a single special liquidator to coordinate
the liquidating entities and introduced a performance-based remuneration scheme for liquidators. Banks are
expected to agree with the BoG in cooperation with the SSM on concrete financial and operational targets and
report an extended set of key performance indicators (KPIs) with the objectives to significantly reduce nonperforming exposure and reach sustainable restructuring solutions for borrowers. KPIs will be used to monitor
resolution activities and if needed to further adjust the operational and legal environment to facilitate NPL
resolution. The authorities have committed to amend the legislation on the out-of-court workout framework by
June 2016 to improve its effectiveness, to significantly strengthen by September 2016 the capacity of courts
8

dealing with household insolvency cases, to reform the corporate insolvency law by end-October 2016, and to
fully operationalise the profession of insolvency administrators by end-2016.
2.3. PILLAR III. GROWTH, COMPETITIVENESS AND INVESTMENT
A consultation process has been launched to review existing labour market frameworks, with the aim of
achieving a stable setting that is supportive of job creation, competitiveness and social cohesion. Labour
market reforms implemented during the 1st and 2nd programmes were motivated by the need to support
adjustment in the economy, increasing flexibility to better cushion the burden on employment, favouring gains in
cost competitiveness to correct the large external imbalances, and addressing bottlenecks to attracting
investment, creating jobs and increasing potential growth. The current programme aims to safeguard the progress
already made, while improving the balance between flexibility and fairness, taking into account the still very
high unemployment and the need to pursue sustainable and inclusive growth and social justice. To this aim and
as a prior action, a comprehensive review of the frameworks for collective bargaining, industrial action and
collective dismissals has been launched in April 2016. In line with the terms of reference agreed with the
institutions, the review is led by a group of eight independent experts who are renowned international professors
of labour law, labour economics and industrial relations. The group of independent experts will conduct a
consultation process to gather the views of social partners and key stakeholders (including international
organisation such as the ILO) and produce recommendations for further reforms in these areas. A preliminary
report with recommendations is due by July 2016, and a final report will form the basis upon which the
authorities will align labour market frameworks with best practice in the EU. Any change to labour market
frameworks will be done only after the completion of the review process, in consultation and agreement with the
institutions.
As concerns education and research, efforts to rationalise the Greek education system have been
undertaken in the past years, but some reversal of previous reforms has taken place in the past year and
further measures are needed to improve its quality and efficiency. This will be done in line with the best EU
and OECD practices and will feed the planned wider Growth Strategy. An assessment of the Greek education
system and the reforms of the last years has been launched with the assistance of the OECD. This assessment
covers all levels of education, including linkages between research and education and the collaboration between
universities, research institutions and businesses to enhance innovation and entrepreneurship. A first report will
be produced by June 2016 and together with the results of a national dialogue on education will lead to the
adoption of a three year action plan by September 2016. A series of measures are expected for adoption already
for the academic year 2016-17. Efforts are also undertaken to promote closer linkages between R&D and
businesses to boost the productivity and competitiveness of the economy. A comprehensive national research
and innovation strategy for smart specialisation has been completed and a digital growth strategy is in the
process of being finalised.
An important part of the structural policy package is the reform of product markets. Despite the
substantial progress that has been recorded in key areas such as business environment and competition, there is
still scope for further reforms. According to the OECD, Greece has lowered its general level of product market
regulation in the recent years; however it still ranks among the highest compared to other OECD countries. Since
August 2015, the authorities have adopted a significant package of reforms as part of the new ESM programme.
In August 2015, the authorities adopted OECD recommendations in sectors such as retail trade, food processing
(so-called Toolkit I) and beverages and petroleum products (Toolkit II). The majority of the eighty eight OECD
recommendations under Toolkit II have been already addressed by the end of 2015, while most of the remaining
ones, were addressed as prior action: the remaining five recommendations are to be addressed by September
2016. The ownership of pharmacies was opened to non-pharmacists in compliance with the spirit of the OECD's
2013 recommendation, while the primary legislation on the liberalization of the over-the-counter (OTC)
pharmaceutical products was adopted as a prior action. A new round of an OECD competition assessment
(Toolkit III) in five sectors of the economy (wholesale trade, construction, e-commerce, media and the rest of
manufacturing) was initiated in early 2016 and the first recommendations are due to be addressed by June 2016.
With the support of the World Bank, the reform and simplification of the investment licensing procedures
was initiated in late 2015. In addition, the government adopted the simplification of financial statements and
9

audits for small companies in August 2015 according to OECD recommendations on administrative burden
reductions for business. Moreover, the further liberalisation of key professions took place in August 2015, while
roadmaps for the continuation of such efforts were prepared and submitted as a prior action. A first round of
impact assessments of selected reforms on competition, investment licencing and administrative burden was
launched in October 2015 and the relevant recommendations are due to be addressed by June 2016. Going
forward, the authorities intend to take further steps to open regulated professions, to effectively liberalize the
OTC pharmaceutical products, to simplify the investment licensing procedure and to ensure the effective
implementation of reforms through impact assessments and technical assistance. Strong ownership and swift
implementation of the agreed reform agenda is crucial to further improve the functioning of the product market,
ease doing business and narrow the gap to OECD countries.
Work has continued regarding the policies concerning land use which remain a major impediment to
business activity and investment. The authorities have adopted the Presidential Decree on forest definition, and
as a prior action, the Government finalised provisions for selected improvements of the spatial planning law and
adopted the law on forest maps in agreement with the institutions. The authorities will fully implement the
forestry law by July 2016. On cadastre, the authorities will adopt by September 2016 the new legal framework
for nationwide cadastral offices on the basis of the experience of the two pilot offices and recent technical
assistance advice, in accordance with the roadmap in the agreement between the World Bank and the European
Commission.
On structural funds, an inter-ministerial committee on major projects will continue its work proposing
solutions to blockages on projects. As a prior action the authorities adopted the law establishing the
Information and Communication Technology Secretariat.
Important progress is being made in the reform of the energy sector, with the focus of this review being on
the electricity sector. Agreement on the access – through auctions - by alternative suppliers to the lower-cost
electricity production base of PPC, the incumbent, has been found, and will lead to a reduction of the retail
market share of the quasi-monopolist by 8% in 2016, 20% cumulated by 2017, and 50% cumulated by 2020. In
addition, after this transition phase (by 2020) no undertaking will be able to produce or import, directly or
indirectly, more than 50 percent of total electricity produced and imported in Greece. As a prior action, this
agreement was published and transposed in legislation.
Ownership of the transmission network will be fully separated from supply, on the basis of an agreed
action plan. Thus, PPC will no longer own any share of ADMIE, the electricity transmission system operator,
removing any conflict of interest in the construction and operation of important internal and external
interconnections. To operationalize this, a plan for ownership unbundling was agreed between the institutions
and the Greek authorities and it was endorsed by the KYSOIP (a ministerial body competent on economic
issues) as a prior action; it will lead to the sale by end-2016 of at least 20% of the company to a strategic
investor, having joint control of the company with the State, which will own 51% of it. Legislation to facilitate
the implementation of the plan was also approved by the Parliament. Other important reforms in the electricity
market are ongoing, including the implementation of the EU target model and, as a prior action, the capacity
payments system was reformed, to bring it in line with EU State Aid Guidelines (EEAG) and reduce its cost. The
revision of PPC’s tariffs for industrial (high-voltage) users, to base them on actual costs and consumers’ profiles
was not completed and discussions between PPC and its customers are still ongoing. Completing this action
requires a new mandate to PPC and will be done as part of the milestones due by mid-September.
The liberalisation of the gas market is progressing, with distribution being separated from supply and the
industrial customer segment fully liberalised since August 2015 with complete liberalisation of all customers by
1 January 2018. To this end, the network operator (DESFA) as a prior action submitted a tariff proposal to the
energy regulator (RAE).
Key steps for the reform of the transport and logistics sector are planned and the creation of a stable
regulatory regime in the water sector is progressing. In the Transport and Logistics sector, the Greek
government, in consultation with the European Institutions and in particular with the SRSS, has secured the
required funding and the technical expertise to develop a general transport plan for Greece and thus establish a
clear short-term and long-term strategy for the sector. Other important reforms on logistics are the ongoing
10

implementation of the logistics law, the adoption of the logistics strategy and the related action plan. Further, the
Greek government committed to prepare a comprehensive review of subsidies of the transport sector.
Concerning the water sector, the Special Secretariat for Water (SSW), in consultation with the EC, is working
towards the adoption of pricing principles for water utilities. The Greek government committed to strengthen the
capacity of the SSW with the support of technical assistance.
The privatisation process has made significant advances since the signature of the MOU. The signing of the
agreement to buy 14 regional airports by a consortium, and more recently the signature for the Port of Pireaus,
which constitutes the first major privatisation concluded by the current government, are two important deals
expected to lead to investment and job creation in the country. A similar tender for the port of Thessaloniki has
also been launched; other key tenders are also in final stages including for the train companies. There is investor
interest in these companies and these tenders are expected to be concluded by September 2016. An agreement
was reached to begin discussions about the extension of the terms of the concession agreement for Athens
International Airport. This reaffirms the aim of the government to allow private operators to run the airport and
provide the same, and gradually even better, level of services to domestic and foreign travellers. Overall
proceeds of some EUR 2.5 billion are expected in 2016 compared to some EUR 0.4 billion in 2015. An
agreement was reached with the Greek authorities regarding the core assets to be privatised by TAIPED and an
ambitious but realistic monetary target underpins this list. The Government as a prior action endorsed the Asset
Development Plan approved by TAIPED in April 2016, and carried out a large number of government pending
actions agreed with the institutions to facilitate its implementation and secure the completion of this plan,
including on major projects such as the Hellinkon airport. The GPAs that couldn’t be completed as part of the
related Prior Action will be converted into a milestone for mid-September.
The Greek authorities adopted as prior action legislation to establish a new privatisation and investment
fund (Hellenic Corporation of Assets and Participations S.A., HelCAP). HelCAP would in effect consist of
a holding company with four subsidiaries under its management, namely (i) the privatisation agency (HRADF,
or in Greek: TAIPED), (ii) the Hellenic Financial Stability Fund (HFSF) which holds capital instruments in
systemic banks, (iii) a sub-entity that will monetise the considerable real estate assets of the Greek State (State
Owned Real Estate Corporation S.A, ETAD), and (iv) a sub-entity to manage/monetise State Owned Enterprises
(SOEs) and other shareholdings of the Greek State (State Owned Participations S.A., EDHS). The Fund will
become operational as of day one. Both TAIPED and HFSF are existing operational entities which will be
brought under the new Fund upon its creation, while maintaining their operational independence.
HelCAP has a governance structure ensuring that assets are professionally managed at arm's length from
the Government and undue business interests, in line with the commitments of the Euro summit of July
2015. The Supervisory Board, which will be appointed jointly by the Greek authorities (3 members) and the
European institutions (2 members) by June 2016, will take decisions on the basis of a 4/5 majority and the
chairman will be one of the members appointed by the European institutions. Its role would be to oversee the
proper functioning of the Fund based on its founding law and other key internal documents, to appoint the Board
of Directors (by September 2016) and approve dismissals of senior management of the Fund and the sub-funds.
The Board of Directors will have responsibility for executive tasks including the design and implementation of
the strategic plan for HelCAP. It will be exclusively responsible for its subsidiaries, including appointing their
Boards and management. The Boards of the subsidiaries will be similarly in charge for the companies under their
portfolio ensuring control of these entities and their management, and thus ending the long-standing practise of
direct government control of these companies.
HelCAP will own and manage immediately from its establishment a significant portfolio of assets which
was defined as a prior action in the legislation. The portfolio of assets will gradually expand with the addition
of new assets, a process that will be completed within 2016 for both the real estate and SOEs assets. The
portfolio of assets in HFSF is fixed and the law specified that bank shares should be returned to the private sector
within five years. There is an agreed list of 'core assets' included in the Asset Development Plan of TAIPED.
Regarding real estate assets, the Authorities have agreed to bring immediately under HelCAP the real estate
management entity (ETAD) and to transfer the legal ownership of all the Hellenic-State owned assets under its
management to the new fund (around 70,000) with few exceptions, notably archeological sites, followed by
further transfers of assets held by Ministries. For SOEs and other shareholdings, the transfer will follow a three11

stage process, starting with the immediate transfer of six important companies. The proceeds of HelCAP from
the sale or redemption of bank capital instruments and of the TAIPED assets will be used for debt repayment.
The rest will be earmarked half for decreasing the debt to GDP ratio through debt repayment and the other half
will be used for investments (both for growth-enhancing purposes in Greece and for preparing other assets of the
Fund for monetization). Technical assistance is being provided by the SRSS and the French authorities.
2.4. PILLAR IV. A MODERN STATE AND PUBLIC ADMINISTRATION
Following a substantial scaling down of the public administration, Greece is now implementing key
reforms to improve its quality. A very strong reduction in the number of employees in the core public sector
between 2009 and 2015 (-25.9%) contributed to the stronger reduction in the level of the wage bill (-31.4%),
which is now brought in line with the euro area average in terms of GDP (9% against 9.1%). The third
programme focuses on qualitative reforms and depoliticisation of the administration.
Greece already approved and implemented important reforms, under the milestones package in
December 2015, concerning the HR policies of the public sector. Legislation was adopted to streamline the
structure of the unified wage grid of public servants, to modernise performance assessment, and to establish a
transparent and objective process for the recruitment of managers in the civil service and top civil servants. The
wage grid reform simplifies and rationalises the pay system for more than 400,000 civil servants, with a 20%
decompression in the wage scale, a streamlining of allowances, and a new system of career-based incentives for
the best performers. The performance assessment system itself has been completely overhauled and modernised,
and will also be used in the new system for the recruitment of managers, which is based on merit and
competence. Finally, the system of appointment of top servants in public and private entities has been
depoliticised, and will now be performed through a non-political panel chaired by ASEP, the independent entity
in charge of the recruitment of civil servants. A similar reform for Secretaries General, which are key figures at
the top of all administrations, was completed as a prior action of the first review. Going ahead, key reforms will
include the restructuring of special wage grids, covering around one third of the administration not covered by
the standard wage grid, including uniformed personnel, and the introduction of a modern and transparent
mobility system across the administration to effectively accompany the attrition rule concerning hiring which the
government has extended until 2018.
Key measures have been agreed to enhance the efficiency of the judicial system and improve the
effectiveness of judicial procedures. The implementation of the reform of the Code of Civil Procedure, in line
with international best practice and effective since January 1st 2016 as a key deliverable of the MOU, is expected
to bring very significant improvements to the functioning of the judicial system, by enhancing the efficiency,
credibility and predictability of the civil procedure: this is key to support market activity, thereby benefiting the
economy and the society at large, and contributing to the competitiveness of the Greek economy. The authorities
plan to take two additional steps on auctions, which are essential also to reduce the high levels of NPLs: i) the
value of immovable properties used as first-offer price for auctions will be market-based and not anymore taxbased, and ii) work has been launched to make the conduct of electronic auctions in civil procedures possible.
However, the judicial system is still affected by significant backlogs and the implementation of the new Code
needs to be accelerated. The three year strategic plan targeted at addressing the key weaknesses of the Greek
judicial system, namely at enhancing efficiency, speeding up proceedings and addressing shortcomings in the
functioning of courts, was submitted as a prior action. Other key actions that will be pursued in the area of
justice are related to collecting information on the situation of the courts, computerization, developing alternative
means for dispute resolution, rationalizing the cost of litigation and improving in court functioning and court
management.
The implementation of the National Strategic Plan against Corruption is continuing. Following the
adoption of the framework law for anticorruption and the code of conduct for members of Government in 2014,
the amendment of the legislation on the declaration of assets adopted as a prior action of the first review is
expected to significantly strengthen the framework for the monitoring and controlling of asset declarations of
politically exposed persons in a timely, effective and independent manner, bringing Greece in line with best
practices. Other key reforms in the MoU are the improvement of the law on the financing of the political parties,
12

the insulation from political intervention of financial crime and corruption investigations, and the adoption of a
code of conduct for Members of Parliament.
Greece has committed to strengthen the institutional and operational independence and effectiveness of
key institutions and agencies. Following the commitments at the Eurosummit in July 2015, the authorities have
agreed to publish a report on overall progress towards the modernisation of the public administration and its
depoliticisation. They have also agreed to a process leading to the adoption of a general set of common
fundamental rules applicable to all independent agencies, including the Hellenic Competition Commission and
other regulatory agencies. Reforms will include the relationship between the entities and the Government, as
well as the stakeholders; their organisational and operational autonomy in areas such finances, IT and HR; and
accountability and conflicts of interest. As a prior action, the authorities amended legislation to ensure the
independence and effectiveness of the Hellenic Competition Commission (HCC). The authorities have
reaffirmed their commitment to honour the Commitment on Confidence in Statistics and to support the
independence of ELSTAT. As a prior action, ELSTAT was provided access to administrative data sources and
all the parties have agreed to provide these data on a regular basis, based on an agreed MOU.

13

3. Debt Sustainability Analysis and programme financing
3.1. DEBT SUSTAINABILITY ANALYSIS
There was a substantial improvement in the DSA compared to August 2015 because of better than
expected growth and fiscal outcomes and less than expected bank recapitalisation needs. The economy and
the financial sector were more resilient than expected to last year's policy uncertainty and imposition of bank
holidays, leading to a milder contraction in growth and a lower use of bank recapitalisation funds. Moreover, the
2015 primary surplus (programme definition) of 0.7% of GDP was considerably better than the programme
target of a primary deficit of 0.25%. At the same time, the delay in completing the first programme review led
the authorities to replace external programme funding with internal sources from other general government
entities which are consolidated and reduce the general government debt stock accordingly. The authorities were
also unable to clear arrears (except for EUR 400 mn cleared in August 2015 with the first programme
disbursement) due to lack of funding. As a result of these factors, Greece's debt-to-GDP reached 176.9% in 2015
compared to a projection of 196.3% estimated in August for the baseline scenario.
Going forward, the debt-to-GDP ratio is expected to increase in 2016 as Greece starts receiving
programme funding and clearing arrears, before gradually decreasing from 2017 onwards. The DSA
projections in a baseline scenario (A) assume that Greece will jump-start its arrears clearance programme in the
second part of 2016 such that it would have cleared EUR 4 bn of arrears by the end of the year. The acceleration
of arrears clearance is necessary to return liquidity to the real economy and support growth going forward. The
DSA projections also assume that Greece catches up with the original disbursement schedule by the end of the
year, increasing the debt stock accordingly. The assumptions in the DSA baseline regarding the other main input
parameters are the following:


Short term GDP growth is assumed to register -0.3% in 2016, 2.7% in 2017 and 3.1% in 2018. Longterm GDP growth is expected to level off to 1.5% after 2021, when catching-up effects have become
smaller and the output gap has closed, and decline to 1.25% after 2030 due to ageing effects.



Total privatisation revenues from bank and non-bank assets are estimated at about EUR 18bn, of which
EUR 13bn come from the privatisation of non-bank assets. These long-term projections for privatisation
proceeds are based on already signed sales and concessions and are a conservative estimate of expected
revenue going forward. No further bank recapitalisation is foreseen at this stage and it is assumed that
more than ¾ of the funds used for bank recapitalisation in 2015 can be recovered from the privatisation
of bank assets (EUR 4.5 bn).



In terms of primary surplus, Greece is expected to reach a surplus of 0.5% of GDP in 2016, 1.75% in
2017 and 3.5% in 2018. Afterwards, Greece is expected to maintain the 3.5% primary surplus for a
period of 10 years after which it starts to decrease gradually to 1.5% by 2040.



Market rates, modelled as the expected risk-free rate plus a risk premium, are expected to reach 5.1% in
2019, increase to 5.6% in 2024 because of the increase in the risk free rate and then level off to 4.8% by
2050. The average market re-financing rate after the end of the programme averages 5% in the
projections.

Based on these assumptions, Greece's debt-to-GDP ratio is expected to reach 182.9% in 2016, 181.8% in 2017,
157.3% in 2020, 145.5% in 2022 and 100.7% in 2060. The gross financing needs (GFN)-to-GDP are forecast to
register 16.9% in 2016, 18.2% in 2017, before strongly decreasing to 7.4% in 2020 and 8.4% in 2022. GFN-toGDP will then increase from the 2020s onwards reaching 23.3% by 2060, above the debt sustainability threshold
of 15% to 20%. Given the high debt-to-GDP and GFN-to-GDP, serious concerns remain regarding Greece's debt
sustainability.
Two downside scenarios were also simulated which capture a more unfavourable external economic
environment and a faster decrease in the primary surplus (scenarios B and C). In these scenarios the
assumed growth rate for real GDP is lowered by 0.25 pp per year compared to the baseline between 2019 and
2030. The primary balance is assumed to remain at programme targets until 2018 and start decreasing 5 years
after the end of the programme in scenario B and immediately after the programe in scenario C, leading to an
overall average primary fiscal surplus of 2% and 1.7% respectively in the post programme period. Additionally,
14

in scenarios B and C lower privatization proceeds are assumed and a buffer for possible recapitalization needs is
preserved throughout the horizon.
 Debt-to-GDP stabilizes at a high level in the short to medium term in scenario B and starts increasing
strongly from 2035 onwards reaching nearly 191% in 2060. The debt dynamics in scenario C become
explosive from the mid-2030s onwards and reach 268% of GDP in 2060.
 The picture is similar for GFN-to-GDP: they exceed the 15% sustainability threshold in 2029 and reach
45.2% by 2060 in scenario B; they exceed the 15% sustainability threshold in 2026 and reach over 60%
by 2060 in scenario C.
One upside scenario (scenario D) was also simulated which assumes a more favourable long-term growth
and catching up process and correspondingly better fiscal performance. Growth is assumed to be 0.25 pp
higher compared to the baseline after 2019. Privatisation revenue would total EUR 20 bn over 2015-2022 as it
would include revenue from the privatization of banks of EUR 5.7 bn, reflecting the potential proceeds that
could be generated by the new privatisation and investment fund HelCAP. The fiscal primary balance is based
on programme targets and remains at 3.5% of GDP over an extended period of time. The overall primary surplus
is on average 2.4% of GDP during the post programme period. In this scenario debt-to-GDP is high at 155.8% in
2020, 142.2% in 2022 and 110% in 2030, before decreasing to 62.2% in 2060.
The high debt-to-GDP and gross financing needs resulting from this analysis point to serious concerns regarding
the sustainability of Greece's public debt. The concerns shall be addressed through the implementation of the farreaching and credible reform programme contained in the supplemental MoU, very strong ownership of the
Greek authorities for this programme and debt-mitigating measures granted on full implementation of
conditionality measures agreed in the context of the ESM programme. An appropriate and phased combination
of debt management measures (including locking in of current low levels of interest rates), extension of
maturities and grace periods for principals and interest, plus the use of SMP and ANFA equivalent profits would
allow to bring Greek debt back to a sustainable level in gross financing needs terms without the need for a
nominal haircut.
Table 4. Greece: main DSA results

Debt-to-GDP

GFN-to-GDP

2016

2017

2018

2019

2020

2022

2030

2040

2050

2060

Scenario A

182.9

181.8

172.4

164.8

157.3

145.5

117.1

103.1

100.9

100.7

Scenario B

182.9

181.8

174.3

168.0

161.2

150.9

132.3

134.7

151.7

190.5

Scenario C

182.9

181.8

174.3

168.2

161.8

152.9

143.3

153.0

186.0

268.2

Scenario D

182.4

181.3

171.9

164.2

155.8

142.2

110.0

85.5

74.5

62.2

Scenario A

16.9

18.2

11.3

12.3

7.4

8.4

12.9

19.1

22.0

23.3

Scenario B

16.9

18.2

11.3

12.6

8.0

9.6

16.5

26.2

34.0

45.2

Scenario C

16.9

18.2

11.3

12.8

8.4

10.6

19.2

30.6

42.5

65.4

Scenario D

15.0

17.7

10.7

11.7

6.9

7.9

11.5

15.3

16.0

14.4

Source: European Commission
3.2. PROGRAMME FINANCING
A new ESM programme with an envelope up to EUR 86 bn was agreed with the Greek authorities in
August 2015. As part of the new programme, a first disbursement of EUR 16 bn was approved for fiscal and
debt service needs, split into three tranches. A first tranche of EUR 13 bn was disbursed in August following the
implementation by the authorities of a series of prior actions. Of this amount, EUR 12 bn was disbursed directly
to the segregated account to meet debt service needs, including the early repayment of the EFSM bridge loan that
had been given to Greece in July, and the remaining EUR 1 bn was disbursed to the Treasury Single Account
(TSA) to cover fiscal needs. A further tranche of EUR 2 bn was disbursed in November 2015 following the
completion by the Greek authorities of a first set of milestones. From this second tranche, EUR 1.3 bn was
disbursed directly to the segregated account for debt payments, EUR 400 mn was disbursed to the TSA for fiscal
needs and EUR 300 mn was disbursed to the newly created ring-fenced account for EU structural funds to
replenish what had been used by the authorities in the first part of 2015 to cover their liquidity needs. A final
tranche of EUR 1 bn was disbursed to Greece in December following the completion by the authorities of a
second set of milestones. This last tranche was split into EUR 500 mn for the segregated account, EUR 300 mn
for the TSA and the remaining EUR 200 mn for the ring-fenced account for EU structural funds.
15

In parallel to the disbursement covering fiscal and debt payment needs, a further EUR 10 bn was
approved to cover bank recapitalisation needs. This amount was released on a specific account held at the
ESM to be gradually drawn by the authorities once the ECB/SSM comprehensive assessment was completed and
the actual bank recapitalisation needs became known following efforts to raise capital from private sources. The
ECB/SSM comprehensive assessment identified a capital shortfall of EUR 14.4 bn of the four systemic banks in
the adverse scenario. After the successful completion of book-building processes and liability management
exercises of the four banks, considerably less public funds were needed for bank recapitalisation than envisaged
in the financial sector envelope of the Programme. Eventually, EUR 5.4 bn out of the EUR 10 bn were disbursed
in the form of ESM notes to Greece in December 2015 to meet recapitalisation needs of two banks. The unused
EUR 4.6 bn of this disbursement remain available as part of the programme envelope.
Current projected gross financing needs over the course of the full ESM programme are lower by EUR
19.6 bn compared to the EUR 86 bn in the August 2015 assessment. This is mainly due to substantially lower
public bank recapitalisation needs than originally foreseen (only EUR 5.4 bn out of an estimated total of EUR 25
bn were used in the end), as well as due to lower fiscal needs given a better than expected fiscal outcome in 2015
and slightly lower interest payments. At the same time, the authorities were obliged to increase their use of cash
from other general government entities through repo operations to meet their liquidity needs in the absence of
further disbursements as a result of the delay in completing the first review. In the projected financing needs
until the end of the programme, it is assumed that the authorities will need to unwind an additional EUR 1.6 bn
in repo operations on top of the EUR 3.5 bn that was catered for in August 2015 to get to the same amount of
permanent use of internal cash reserves as in the August 2015 assessment. All of the other gross financing needs
categories remain largely unchanged compared to the assessment made last year. More specifically, compared to
August 2015, the following changes were made in the gross financing needs items:


a reduction in the bank recapitalization needs by 19.6 bn following the comprehensive assessment and
the significant private capital raising of banks in the recapitalization exercise undertaken last year



an improvement in the primary fiscal surplus of EUR 1.4 bn throughout the programme period
following a better fiscal performace last year



a slight reduction in interest payments by EUR 200 mn



an increase in the unwinding of repo operations by EUR 1.6 bn following the increase in repo use in
recent months

Overall, up to EUR 64.6 bn currently remains to be disbursed including the EUR 4.6 bn unused bank
recapitalisation funds. For the remainder of the programme Greece would need to cover EUR 31.5 bn in
amortisation and interest payments, whereas the attainment of cash primary surplus as a result of attaining ESM
programme targets would reduce financing needs by EUR 2.5 bn. The authorities also need to clear arrears of up
to EUR 7 bn. The programme should allow the building of State deposits by EUR 5 bn at end-2016 and to reach
EUR 8 bn by August 2018. The build-up in deposits should also take into account the replenishment of Greece's
SDR holdings to the IMF by around EUR 1 bn. Privatisation receipts are expected to lower financing needs by
around 6 bn over the remainder of the programme. As a result of the above, within the financing envelope there
would be a remaining buffer of EUR 23 bn at the end of the programme.
The long delay in completing the 1st review of the ESM programme exacerbated Greece's tight liquidity
situation. Greece had originally been forecast to receive an additional EUR 11.2 bn between November 2015
and June 2016. In the absence of programme disbursements, Greece met its financing needs over the previous
months partly through the use of internal resources from other general government entities, but also through
further delays in payments and accumulation of arrears.
The absence of funds did not allow the authorities to clear arrears last year on a substantial scale.
According to the disbursement schedule agreed in August 2015, the authorities were supposed to clear EUR 4.9
bn in arrears between August 2015 and June 2016. However, they only cleared EUR 400 nm in arrears last
August, due to lack of funds. The increase in arrears can not only negatively influence growth, but also future tax
collection as private suppliers are not able to make tax payments because their bills are not paid by the State.
This can result in serious financial blockages in the economy.
Going forward, it will be important for the authorities to restore much needed liquidity to the real
economy in order to support growth and thereby ease compliance with the MoU fiscal targets.
16

The size of the disbursement related to the 1st review should allow the authorities to jump-start their
arrears clearance programme and cover financing needs sufficiently into the future so as to avoid further
liquidity shortages. The size of the disbursement should cover financing needs until the next review, which
realistically one could expect to be concluded by end-October – beginning of November, given the high number
of key deliverables.
Based on the factors above, the ESM governing bodies are expected to approve the second tranche of the
programme linked to the completion of the first review amounting to EUR 10.3 bn. This envelope will
cover Greece's financing needs until end-October 2016. Of this disbursement, a total of EUR 3.5 bn will be used
for arrears clearance, while EUR 6.8 bn will cover debt service needs. The EUR 10.3 bn disbursement will be
released to Greece in several tranches. A first tranche of EUR 7.5 bn will be released following the completion
of the prior actions by the Greek authorities. Of this first tranche, EUR 5.7 bn will cover debt service needs until
end-August, while EUR 1.8 bn will be used for domestic arrears clearance. The remaining disbursements will be
made after the summer. The further disbursement for arrears clearance totalling EUR 1.7 bn will be subject to a
positive reporting by the European institutions on the clearance of net arrears. The additional disbursement for
debt servicing needs of EUR 1.1 bn will be released once the Greek authorities complete a number of milestones
related to pension, privatisation (including the operalisation of new privatization and investment fund HelCAP),
bank governance, revenue agency and the energy sector.

17

Table 5. Greece Financing Needs 2016-August 2018 with EUR 10.3 bn disbursement following the completion of the first review

2016

2017

2018

18

Financing requirements
Greece

Q1

May

Jun

Q2

Jul

Aug

Sep

Q3

Oct

Nov

Dec

Q4

2016

Q1

Q2

Q3

Q4

2017

Q1

Q2

Jul

Aug

JanAug
2018

Amortisation and
maturing debt

1.7

0.0

0.9

1.4

2.9

0.1

0.7

3.7

0.0

0.1

0.3

0.5

7.3

0.3

2.2

7.2

0.2

9.9

0.7

0.8

2.4

0.0

3.9

Interest payments

2.3

0.2

0.3

0.9

0.9

0.5

0.0

1.4

0.3

0.2

0.2

0.6

5.2

2.3

0.9

1.7

0.6

5.4

2.3

0.7

0.6

1.1

4.7

State cash primary
balance (‘-‘= surplus)

-1.9

0.3

-1.1

-0.7

-1.1

-0.4

0.3

-1.2

0.2

0.4

3.4

4.0

0.2

-2.2

-1.8

-1.1

3.7

-1.4

-1.1

-1.1

-0.4

-0.4

-3.0

Unwinding of repos

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

3.5

3.5

0.0

0.0

1.6

0.0

1.6

Banking sector needs

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

Arrears clearance

0.0

0.0

0.5

0.5

0.8

0.5

0.8

2.0

0.8

0.8

0.2

1.7

4.3

1.3

1.0

0.0

0.0

2.3

0.0

0.0

0.0

0.0

0.0

A. Financing needs

2.1

0.4

0.6

2.1

3.4

0.7

1.7

5.9

1.2

1.4

4.1

6.8

16.9

1.6

2.3

7.7

8.0

19.7

1.8

0.3

4.2

0.7

7.1

B. Financing sources

0.4

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

1.2

1.2

1.6

1.1

0.8

0.8

0.8

3.5

1.1

0.8

0.0

0.0

1.9

Privatisation revenues

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

1.2

1.2

1.3

0.8

0.8

0.8

0.8

3.2

0.8

0.8

0.0

0.0

1.6

SMP profits

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

ANFA profits

0.3

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.3

0.3

0.0

0.0

0.0

0.3

0.3

0.0

0.0

0.0

0.3

C. Net financing needs
(A-B)

1.7

0.4

0.6

2.1

3.4

0.7

1.7

5.9

1.2

1.4

2.9

5.6

15.3

0.5

1.5

6.9

7.2

16.2

0.7

-0.5

4.2

0.7

5.2

Programme
disbursement

0.0

0.0

7.5

7.5

0.0

0.0

2.8

2.8

0.0

6.1

0.0

6.1

16.4

1.5

9.6

2.0

5.1

18.2

3.0

3.4

0.0

3.5

9.9

IMF tranches

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

State deposit financing

0.7

0.4

-6.9

-6.0

3.4

0.7

-1.1

3.1

1.2

-4.7

2.9

-0.5

-2.8

-1.0

-8.1

4.9

2.1

-2.0

-2.3

-3.9

4.2

-2.8

-4.7

Use of subsector
deposits through repo
operations

1.0

0.0

0.0

0.6

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

1.6

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

D. Financing gap

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

2.7

1.8

8.7

8.7

5.3

4.5

5.6

5.6

4.3

9.0

6.1

6.1

6.1

7.2

15.2

10.3

8.2

8.2

10.4

14.3

10.1

12.9

12.9

Memo items
Total State Deposit
Stock (end-of-month)

4. List of Prior Actions in the Supplemental MoU
Action defined on draft MOU

Status as of 8 June 2016

Fiscal policy (MoU 2.1)
1

Fiscal targets. Adopt supporting legislation generating savings equivalent to ¾, 2¼ and 3 percent of GDP in 2016, 2017 and 2018
respectively through parametric measures

Done

1.1

A series of parametric measures to generate savings of around 1 percent of GDP (VAT, wage bill, car taxation, other)

Done

1.1.1

VAT. Increase in VAT revenues (savings of around ¼ percent of GDP), by raising the standard VAT rate to 24 percent as of 1 June 2016

Done

1.1.2

Wage bill. Control of the wage bill (savings of around 0.2 percent of GDP)

Done

1.1.3

Car taxation. Reform of motor vehicles taxation

Done

1.3.4

Other changes in taxation in the areas of energy, alcoholic beverages, tobacco, e-cigarettes, and coffee, gaming, broadband and cable TV,
investment vehicles, ENFIA, and tourist accommodation

Done

2

Contingency mechanism. Legislation will be adopted to ensure that a package of measures would be automatically implemented as soon as
there is objective evidence of a failure to meet the annual primary surplus targets in the programme

Done

Tax policy reforms (MoU 2.1 and 2.2)
3

Major reform of the personal income tax yielding 1 percent of GDP by fighting tax avoidance, broadening the tax base, integration of the
solidarity surcharge into the income tax law and tightening the definition of professional farmer, providing tax neutrality for investment and
rental income.

3.1

Tax avoidance. Reduction in opportunities for tax avoidance, through the pooling of currently separately-taxed employment and business
income into a single taxable aggregate with an employment tax credit. The top marginal effective tax rate, including both PIT and solidarity
surcharge components, will be capped at 55 percent

Done

3.2

Tax base. A widening of the tax base through a reform in the tax credit for employment and pension income generating additional revenues of
around 0.2 percent of GDP, To improve transparency, the tax credit taper will be substantially reduced.

Done

3.3

Solidarity surcharge. Permanent integration of the solidarity surcharge into the income tax code with schedular marginal rates closely linked
with the income tax brackets.

Done

3.4

Professional farmers. Tightening of the definition of professional farmer for taxable income purposes and the elimination of the preferential
tax regime for tax income including basic payment schemes of the first pillar EU agricultural subsidies through taxation on the same tax
schedule of employment and business income with the same tax credit provided to employees and pensioners.

Done

Action defined on draft MOU

Status as of 8 June 2016

Revenue Agency (MoU 2.3.1)
4

Revenue administration. Establish an autonomous revenue agency. Operationalize the transfer of IT related functions by signing a Service
level agreement.

4.1

Revenue Agency's set up. Pass legislation to establish an autonomous revenue agency that specifies: a) the agency’s legal form, organization,
status, and scope; b) the powers and functions of the CEO and the independent Board of Governors; c) the relationship to the Minister of
Finance and other governmental entities; d) the agency’s human resource flexibility and relationship to the civil service; e) budget autonomy,
with own GDFS and a new funding formula to align incentives with revenue collection and guarantee budget adequacy, predictability and
flexibility and a budget procedure ensuring discussions with the General accounting office of the Ministry of finance allowing for the needs of
the agency to be taken into consideration; f) reporting to the Government and Parliament; e) the deadline of June 2016 for the signature of the
service level agreement to fully operationalise the transfer of all tax and customs administration IT-related functions within the Agency.

Done

Pensions (MoU 2.5.1)
5

Comprehensive reform of the pension system: Adopt a comprehensive reform through primary legislation and ministerial decrees to
strengthen long-term sustainability while targeting savings, and streamline the governance of social security.

5.1

Link between contributions and benefits. establish a closer link between contributions and benefits, through specific design and parametric
changes.

Done

5.2

Recalibrate pension benefits on the basis of the new parameters of the uniform pension rule with the exception of OGA

Done

5.3

Pension freezing. Freeze the current pensions in payment until their value become equivalent to the one calculated under the new uniform
rule

Done

5.4

Eliminate EKAS

Done

5.5

Harmonize contributions

Partially Done

5.6

Harmonise benefits rules

Done

5.7

Address the deficit in auxiliary and dividend funds

Done

5.8

Council of State ruling. Ensure the compliance of the reform with principles in line with the Council of State ruling.

Done

5.9

Governance of social security. Adopt the following measures: legislate to fully harmonize contribution and benefit payment procedures
across all funds; establish a single entity (EFKA) to be fully operational by the end of 2016, legislate that by end 2016 all insured individual
will be transferred into the new single entity, all social security funds - with the exception of the welfare functions of OGA, the guarantee and
credit functions of TSMEDE and the functions of NAT not related to pensions - will be eliminated and all existing governance and
management arrangements of such funds will be abolished after filing the financial statements but no later than March 2017

Done

Resolution of Non-Performing Loans (NPLs) (MoU 3.2)
6

Non-Performing Loans. Amend legislation to allow the sale of performing and non-performing loans; operationalise the licensing
framework of credit servicing firms; exclude debt write-offs from taxable income of the borrower.

Done

Milestones to be completed
by September

Action defined on draft MOU

Status as of 8 June 2016

6.1

Sale of loans. Adopt amendments to Law 4354/2015 (Law on the Management of Non-Performing Loans, pay-setting arrangements and other
emergency provisions in application of the agreement on budgetary targets and structural reforms) in order to allow without a licensing
obligation the sale of all performing and non-performing loans to entities incorporated in any State member of the European economic area
without exclusions or in any other State excluding non-cooperative States and States identified on 1 May 2016 as having a preferential tax
regime(postponed for loans secured by primary residences with an objective value of property below €140,000)

Done

6.2

Licensing framework of credit servicing firms. Adjust related secondary legislation to the amended Law 4354/2015.

Done

6.3

Licensing framework of credit servicing firms. Set up the related consultative committee by the Government to fully operationalise the
licensing framework of credit servicing firms

Done

6.4

Debt write-offs. Amend the income tax law to ensure that for a specified period of time debt write-offs as result of restructuring agreements
are not considered as taxable income of the borrower.

Done

Labour market and human capital (MoU 4.1)
7

Labour market review. Launch a consultation process led by a group of independent experts to review a number of existing labour market
frameworks, including collective dismissals, industrial action and collective bargaining, taking into account best practices internationally and
in Europe

Done

Product markets and business environment (MoU 4.2)
8

Product markets liberalization. Adopt primary legislation for liberalizing the OTC pharmaceutical market, take further liberalization
measures in the beverages and petroleum products. Submit roadmaps to remove restrictions to specific regulated professions.

Done

8.1

OTC. Adopt primary legislation that will provide for a General Sale List sub-category within the OTC pharmaceutical product list with
effectiveness as of June 2016

Done

8.2

OECD Competition Toolkit II. Adopt the remaining recommendations of the OECD Competition Toolkit II - with the exception of 5
recommendations - on beverages and petroleum products.

Done

8.3

Product markets liberalization. Submit to the Institutions draft roadmaps to remove unjustified and disproportionate restrictions for the
activities of engineers; address the external advisor's recommendations on regulated professions including prioritisation

Done

9

Land use. Improve the spatial planning law; adopt the forest maps law.

Done

9.1

Spatial planning law: improve

Done

9.2

Forest maps law: adopt

Done

10

Structural funds. Adopt the Digital Strategy General Secretariat law

Done

Regulated Network Industries (MoU 4.3)
11

Energy. Full ownership unbundling of ADMIE from PPC; Design of the NOME system of auctions; temporary capacity payment scheme.
Cost-based HV tariffs taking into account consumers’ profiles.

Action defined on draft MOU

Status as of 8 June 2016

11.1

ADMIE. Endorse in KYSOIP a detailed action plan, including a timeline, for implementing the full ownership unbundling of ADMIE from
PPC, to be completed by end 2016 in accordance with an integrated procedure analysis produced by independent evaluators

Done

11.2

NOME. Endorse in KYSOIP and publish the design of the NOME system of auctions, with the objective of lowering by 20 percentage points
the retail and wholesale market shares of PPC by 2017, and to bring them below 50 percentage points by 2020

Done

11.3

NOME. Adopt relevant legislation introducing the NOME mechanism in the Greek electricity market, including all relevant powers for
LAGIE and RAE

Done

11.4

Capacity payment scheme. Adopt the temporary capacity payment scheme, as approved by the European Commission in March 2016

Done

11.5

HV tariffs. PPC will conclude the discussions on HV tariffs with all its customers by signing the respective contracts, and the adopted tariffs
shall be cost-based and take into account consumption characteristics (profiles) of customers that affect costs and

11.6

DESFA. DESFA will send a tariff proposal for the next tariff period to RAE.

Partially Done

Milestone to be completed
by September

Done

Privatisation (MoU 4.4)
12

Privatisation. Endorse the Asset Development plan approved by HRADF. Take steps supportive of the privatisation process. Conclude the
remaining Government Pending Actions identified by the Institutions and HRADF.

12.1

Asset Development Plan. Endorse through KYSOIP the Asset Development Plan approved by HRADF on 26/04/2016 which includes 19
assets in line with the agreed December 2015 Action Plan.

Done

12.2

Hellinikon. Sign an MoU with the investor at the end of negotiations on Hellinikon for any revisions in the agreement and to proceed to the
final stage for concluding the deal

Done

12.3

Regional airports. Ratify in Parliament the Concession Agreement for the 14 regional airports and, after signature of the aforementioned
MoU, for Hellinikon the Share Purchase Agreement

Done

12.4

OLTH. Approve through KYSOIP the concession agreement for OLTH in order to proceed with the uploading of the agreement for investors
to place their binding bids

Done

12.5

OLP. Constitute a working group that will formulate a timeline for finalisation of the regional airport and OLP transactions in 2016

Done

12.6

Egnatia Odos. Approve the KYA on Pricing Policy for the Toll Station of Promachonas in Egnatia Odos; launch discussion between Egnatia
Odos SA with Piraeus Bank on the restructuring of the outstanding debt of the Bond Loan

Done

12.7

Port Regulator. Adopt a law strengthening the independence of the Port Regulator (RAL) as provided in Law 4150/2013 and clarifying the
allocation of responsibilities between the port regulator and other port authorities, taking into account the final agreement for Piraeus Port and
any other ports in the future

Done

12.8

Hellenic Civil Aviation Authority. Prepare a report - and draft legislative proposals if needed - on the legal framework of the Hellenic Civil
Aviation Authority’s (HCAA); organize workshop to discuss report on HCAA with the EC’s SRSS.

Partially Done

The implementation of the
reforms is to be completed
subsequently as part of the
Milestones by September

Action defined on draft MOU

12.9

Pending Actions of the HRADF/TAIPED. Conclude the remaining Government Pending Actions identified by the Institutions and HRADF
and which are due by [April 2016] and that are not listed in this section. This includes the transfer of OTE shares to TAIPED, which requires
the renegotiation of a shareholder agreement.

13

Privatisation and Investment Fund. Adopt the law establishing the new Fund in accordance with the Action Plan agreed as part of the
milestones in December 2015

Status as of 8 June 2016

Partially done

Done

Public administration (MoU 5.1)
14

Depoliticisation of Secretaries General. Approve legislation on depoliticisation of Secretaries General, abolishing Secretaries General of
Ministries by December 2016 and replacing them with Administrative Secretaries.

Done

Justice (MoU 5.2)
15

Justice strategic plan. Propose and subsequently implement a three years strategic plan for the improvement of the functioning of the judicial
system

Done

Anti-corruption (MoU 5.3)

16

Declaration of assets legal framework. Adopt legislation modifying the framework for the declaration of assets, to provide for an enhanced
system of declaration, in particular by improving the independence of the committee in charge of controlling the declaration of assets of
politically exposed persons, not only by increasing the number of its independent members but also by assigning the chair of the Committee to
the most senior judge and by appointing plain members of Parliament ensuring at the same time the representation of the opposition in the
Committee.

Done

Independent agencies and regulatory bodies (MoU 5.4)
17

ELSTAT. Ensure that ELSTAT has access to administrative data sources in line with the Art. 17 of Law 4174/2013 amended by 4254/2014
and 4258/2014, and the Memorandum of Understanding signed between ELSTAT, the Ministry of Finance (GSIS), the Secretary General for
Public Revenues and IKA signed on 17/04/2014.

Done

18

Hellenic Competition Commission (HCC). Amend the provisions of the Article 282 of Law 4364/2016 in agreement with the Institutions
relating to i) disciplinary offences; ii) the use of external lawyers so that the cap is not applied until the internal legal office is fully staffed; iii)
the conflict of interest for external lawyers; and iv) the appointment and term of Directors.

Done

OTE: MoU signed between
parties, transfer of share to
take place in July following
signature of new
shareholder agreement.
GPA related to railway
infrastructure network
maintenance will be
completed in June.
Completion to be verified as
part of the milestones in
September

5. List of Milestones for mid-September 2016
I. Pension reforms
By early September, finalise the harmonisation of social security contributions by: (i) eliminating the lower minimum contribution base for
owners of tourist accommodation; (ii) repealing all exemptions allowing for lower health contributions; (iii) revising downwards the discount
for lump sum payment of notional insurance periods.
II. Bank governance
By end-June 2016 (key deliverable), the HFSF with the help of an independent international consultant will finalise the review of the boards
of the banks in which the RFAs apply. This review will be in line with prudent international practices by applying criteria that go beyond
supervisory fit and proper requirements.
III. Energy
By June 2016, to continue the implementation of the gas market reform, (i) RAE (the energy regulator) will adopt gas distribution and
transmission tariffs, (ii) legislation will be amended, further facilitating the unbundling process and (iii) the authorities will complete the
review of the gas release program, improving conditions of access for alternative suppliers and substantially increasing the quantities
available (key deliverable).
In the context of the implementation of the EU target model for the electricity market, pass the required legislation on the transposition of the
high-level market design in June 2016 (key deliverable)
Amend the current legislation on ETMEAR and/or the structure of the RES account while respecting existing contracts in line with European
Union rules, to ensure that the debt in the RES account is eliminated over a 12-months forward looking horizon (not later than June 2017);
the account will be kept annually in balance onwards.
The General Assembly of PPC, of which the Hellenic Republic holds the majority of shares, will authorize the sale of at least 20 percent of
ADMIE to a strategic investor in July 2016, with the respective tender procedure to start in July 2016 (key deliverable).
By June 2016, the Hellenic Republic will propose and vote in a General Assembly of PPC that its management is fully empowered to
negotiate with full flexibility cost- and consumer profile-based tariffs. PPC will conclude the negotiations on HV tariffs with all its customers
by signing the respective contracts, and the adopted tariffs shall be cost-based and take into account consumption characteristics.
IV. Privatisation
The Government will by June 2016 with the Institutions (a) agree nominations of the Supervisory Board which will be responsible for
selecting the Board of Directors.
The Authorities will transfer to the new Fund a second group of SOEs to be mutually agreed with the institutions (list included in the TMU)
The Authorities will ratify in Parliament the Share Purchase Agreement for Hellinikon as soon as possible after signature of the
aforementioned MoU and no later than June 2016
The Authorities take appropriate steps, and adopt legislation if needed by September 2016, on strengthening HCAA in line with the
recommendations of the EC and of other stakeholders and experts involved in the May 2016 workshop and subsequent technical assistance
provided.
HRADF will launch Expressions of interest for the long-term (35 years) concession of Egnatia Motorway S.A. and three Vertical Axes
The authorities will conclude the Government Pending Actions identified by HRADF and which are due by August 2016. OTE shares to be
transferred to TAIPED by end July following new shareholder agreement that is in lie with EU law. Completion of the GPA related to the
railway infrastructure network maintainance.
V. Revenue Agency
The authorities shall by July 2016 (key deliverable) […] adopt, in agreement with the Institutions and in conformity with the agency
legislation, measures (i.e. MDs, budget appropriations) to provide for: a one-off injection of resources to address problems facing the agency
with the initial stock in terms of both personnel and equipment and to ensure a sufficient level of resources to start to operate effectively; an
immediate increase in budget for discretionary operational activities; the adequate appropriation to allow for the recruitments of sufficient
staff in the agency in 2016 and 2017 to reduce the vacant positions to a normal level, consistent with the Attrition Rule.
The authorities shall by July 2016 (key deliverable): appoint the Board of Governors, which from the moment of appointment will assist the
process of establishment of the agency and the work of the implementation committee. It will also assume responsibility for assisting the
revenue administration in the transition period according to the principles of the new agency;

6. List of Key Deliverables in the Supplemental MoU
Action

Key deliverable

MoU

Q2 2016 – June
I. Delivering sustainable public finances
1

Fiscal policy. Legislate the medium term fiscal strategy 2017 – 2020 (end-May 2016)

2.1

2

Improve collection of tax debt. Publish an update of the list of large tax debtors (May 2016)

2.3.3

3

Public financial management. Present a medium term action plan to ensure compliance with the Late Payment
Directive.

2.4.1

4

Social security. Launch the gradual nationwide roll-out of the GMI scheme.

2.5.3

II. Safeguarding financial stability
5

Resolution of Non-Performing Loans. Amend the legal framework for the out-of-court workout with detailed
provisions (end-June 2016).

3.2

6

Bank governance. HFSF finalise the review of the boards of the banks in which the RFAs apply (end-June 2016).

3.4

III. Structural policies to enhance competitiveness and growth

7

Vocational Education and Training. Finalise the integrated implementation plan for VET with quantified targets for
2016/17 and 2017/18; launch two small-scale pilots projects of apprenticeships for 2016/17; develop, adopt the
framework for a series of major VET partnerships to serve as intermediary structures in order to support employers to
offer work-based learning vacancies and ensure a sustainable expansion of apprenticeships for the academic years
2016-17 and 2017-18

4.1

8

Product markets. OECD competition toolkit I recommendation on OTC pharmaceutical products will be made fully
effective

4.2

9

Business environment. Regulated professions: agree with the Institutions a roadmap for the liberalisation of the
reserved activities of engineers (May 2016)

4.2

10

Business environment. Adopt the foreseen legislation according to the investment licensing reform roadmap in three
sectors.

4.2

11

Business environment. Adopt legislation for the one-stop shops for business.

4.2

12

Business environment. Adopt the remaining measures needed to fully implement the selected reforms on
competition, investment licensing and administrative burden identified in the first round of the ex-post impact
assessment.

4.2

13

Energy. Review the gas release program, improving conditions of access for alternative suppliers and substantially
increasing the quantities available.

4.3

14

Energy. In the context of the implementation of the EU target model for the electricity market, transpose into national
legislation the high-level market design of EU target model for the electricity market.

4.3

15

Privatisation. Agree on the Supervisory Board of the Privatisation and Investment Fund and finalise internal
regulations in line with the December 2015's Action Plan.

4.4

16

Privatisation. Ratify in Parliament the Share Purchase Agreement for Hellinikon

4.4

IV. Modern State and Public Administration
17

Public Administration. Issue secondary legislation to implement the reformed performance assessment scheme.

5.1

18

Public Administration. Complete the first phase of the rationalisation of the specialised wage grids.

5.1

19

Public Administration. Adopt legislation to introduce a new permanent mobility scheme.

5.1

20

Justice. On revised Code of Civil Procedure, adopt the key Presidential Decrees required by the transitional
provisions in Law 4335/2015 on the determination of the value of the property seized on the basis of its market value
and first offer price for the auction (May-June 2016).

5.2

21

Anti-corruption. Amend and implement the legal framework of the financing of political parties on key items.

5.3

Action

Key deliverable

MoU

Q3 2016 –July
I. Delivering sustainable public finances
22

Revenue Agency. Adopt measures to provide for adequate resources so as to allow the Agency to operate effectively.

2.3.1

23

Revenue Agency. Appoint the Board of Governors.

2.3.1

III. Structural policies to enhance competitiveness and growth
24

Labour market. Adopt an integrated action plan to fight undeclared and under-declared work.

4.1

25

Energy. PPC launch the tender for the sale of at least 20 per cent of ADMIE to a strategic investor.

4.3

Q3 2016 – September
I. Delivering sustainable public finances
26

Customs. Complete the customs reorganization.

2.3.2

III. Structural policies to enhance competitiveness and growth
27

Labour market. Bring collective dismissal and industrial action frameworks and collective bargaining in line with
EU best practices.

4.1

28

Education. Prepare a three-year Education Action Plan.

4.1

29

Vocational Education and Training. Launch a series of major VET partnerships to serve as intermediary structures
in order to support employers to offer work-based learning vacancies and ensure a sustainable expansion of
apprenticeships for the academic years 2016-17 and 2017-18

4.1

30

Cadastre. Implement the new legal framework for nationwide cadastre offices.

4.2

31

Energy. Launch the first auction under the NOME mechanism in the Greek electricity market.

4.3

32

Water utilities. SSW will finalise, with the support of technical assistance, the charging rules for water services

4.3

33

Transport and logistics. Implement the logistics law

4.3

34

Privatisation. Transfer to the new Privatisation and Investment Fund a second group of SOEs to be mutually agreed
with the institutions, and following the finalisation of an Fund-Government coordination mechanism

4.4

33

Privatisation. Agree with the Institutions on the processes for determining the remaining portfolios of real estate and
SOEs that will be transferred to the Fund

4.4

35

Privatisation. TAIPED will assess its regional airport and port assets and will transfer to the new Fund those it does
not plan to develop

4.4

36

Privatisation. Take appropriate steps and adopt legislation if needed on strengthening HCAA in line with the
recommendations of the EC, stakeholders and experts.

4.4

37

Privatisation. The Port Regulatory Authority prepares its internal regulations and needed laws to ensure its full
functionality.

4.4

38

Privatisation. Complete the selection of the Board of Directors of the Privatisation and Investment Fund, including
the CEO

4.4

39

Privatisation. The Board of Directors of the Privatisation and Investment Fund to be constituted as a body

4.4

40

Privatisation. Agree on the process for determining the exclusions of remaining portfolios of real estate and SOEs
not to be transferred to the Fund.

4.4

Action

Key deliverable

MoU

Deadline

2.5.3

October 2016

3.2

End-October
2016

Q4 2016
I. Delivering sustainable public finances
41

Social security. Legislate reforms to welfare benefits.

II. Safeguarding financial stability
42

Resolution of Non-Performing Loans. Amend the corporate insolvency law in line with an
agreed proposal.

III. Structural policies to enhance competitiveness and growth
43

Product markets. Toolkit III recommendations: the Government will adopt legislation to address
all identified issues for the remaining sectors

4.2

December 2016

44

Transport and logistics. Prepare a comprehensive review of subsidies for all transport modes

4.3

December 2016

45

Privatisation. The Board of Directors of the Privatisation and Investment Fund finalises
outstanding issues of the internal regulation.

4.4

End-October
2016

46

Privatisation. The Board of Directors of the Privatisation and Investment Fund appoints the
Boards of its subsidiaries.

4.4

November
2016

47

Privatisation. Complete asset transfers/allocation for specific classes of assets to be identified by
the technical assistance

4.4

December 2016

IV. Modern State and Public Administration
48

Justice. Adopt Presidential Decree defining the system of e-dockets for electronic auctions.

5.3

December 2016

49

Independent Agencies. Adopt legislation for strengthening the institutional, financial and
functional independence of the Regulatory Authority for Energy.

5.4

December 2016

50

Independent Agencies. Amend any primary and secondary legislation so as to address issues
relating to the conflicts of interest of the HCC's Board members and the staffing of the HCC’s
internal legal office

5.4

December 2016

51

Tax policy reform. Simplify the income tax regime; revise the corporate tax law in ITC; develop
collective investment vehicles; revise the tax legislation in conflict with TCP; revise TCP on
cooperation on audits; review tax certificates extension; reform KEDE; modernise legislation
addressing collection of tax on income generated from offshore portfolio.

2.2

January 2017

52

Revenue administration. Make the autonomous revenue administration fully operational.

2.3.1

January 2017

53

Social security. Full nationwide rollout of the GMI scheme

2.5.3

January 2017

4.1

March 2017

2.2

June 2017

2.3.2

September
2017

Q1 2017
I. Delivering sustainable public finances

III. Structural policies to enhance competitiveness and growth
54

Labour market. Streamline the labour legislation through the codification into a Labour Law
Code.
Q2 2017

I. Delivering sustainable public finances
55

Tax policy reform. Align the property tax assessment values with market prices.
Q3 2017

I. Delivering sustainable public finances
56

Anti-smuggling. Ensure the scanners in the three main international ports are fully operational.

7. Programme implementation: summary tables
Pillar I. Delivering sustainable public finance
Policy area

Prior Actions
July-August 2015

Milestones
November 2015

Fiscal Policy and
Tax Policy Reform

Reform of VAT
system to broaden
base and phased
elimination of island
discounts.

Amend the criminal
law on tax evasion
and fraud.

Gradual abolition of
excise duty on diesel
oil for farmers.
Increase in tonnage
tax.
Elimination of the
cross-border
withholding tax.

Milestones
December 2015

Abolition of the Code
of Books and
Records.
Adopt measures
(wine, insurance) to
compensation for
VAT on private
education.

Transfer of tax and
customs related
capacities from the
Corps for the
prosecution of
financial crimes
(SDOE) and other
entities to the revenue
administration.
Reform of
garnishments rules.

Key deliverables
between June and
December 2016

Adopt parametric
measures of 3% of
GDP by 2018
including reform of
the personal income
tax (to meet 1% of
GDP), pension
reform (1%), VAT
(¼%), public sector
wage bill (¼%) and
other parametric
measures (½%)
including excise on
energy, car taxation
etc…

Adopt the medium
term fiscal strategy
(MTFS) for 20172020.

Tightening the
definition of
professional farmers
with respect to
taxable income.

Increase in
contributions for
health care from
pensions
Revenue
administration
reforms

Prior Actions
1st review 2016

Indirect bank
accounts register
accessible by tax
administration and
investigation bodies.
Adoption of strategy
to promote electronic
payments.
Strengthen revenue
administration by
transfer of SDOE
staff to the revenue
administration
(GSPR).
Improved selection
tax audit cases.

Agree a concept note
on the design of the
independent revenue
Agency.
Actions to combat
VAT carousel fraud
and fuel smuggling.

Adopt legislation to
establish a fully
autonomous revenue
Agency.

Measures to provide
for adequate
resources so as to
allow the Agency to
operate effectively.
Complete the
reorganisation of the
customs service.
Publish updated list
of large tax debtors.
Adoption of
legislation to promote
electronic payments

Establish three
mobile enforcement
teams to combat
smuggling.
Public Financial
Management and
Public Procurement

Create a ring-fence
the account for the
management of EU
structural funds.

Adopt secondary
legislation for the
Fiscal Council.
Amend and upgrade
the Organic Budget
Law (OBL).
Action plan on public
procurement.

Transposition of
directives on Public
procurement and on
Concessions.
Medium term actionplan to ensure
compliance with the
Late Payment
Directive.

Pillar I. Delivering sustainable public finance
Policy area

Prior Actions
July-August 2015

Milestones
November 2015

Sustainable social
welfare: Pensions

First part of a
comprehensive
pension reform
(extended the freeze
of guaranteed
minimum pensions to
the public sector;
gradual elimination
of the grandfathering
to statutory
retirement age and
early retirement).

Unification of all
supplementary
pension funds.
Supplementary
pension funds to be
financed by own
contributions (by
Jan.2015).

Milestones
December 2015

Early retirement law
for public sector.

Re-establish INN
Sustainable social
welfare: Health Care prescriptions based
on active substance.

Extend the claw back Implementation of
ceilings for
hospital claw back.
diagnostics, private
clinics and
Align private
pharmaceuticals.
diagnostics to claw
back ceiling.
Adopt measures to
increase the rate of
generics penetration.

Launch a
Sustainable social
welfare: Social safety comprehensive Social
Welfare Review with
nets and activation
World Bank.

Complete preparatory
work for a gradual
nationwide roll-out of
a Guaranteed
Minimum Income
Scheme, including
the set-up of benefits
registry and social
inclusion strategy.

Prior Actions
1st review 2016

Key deliverables
between June and
December 2016

Comprehensive
pension reform
(unified pension
system with
harmonised
contributions and
entitlements, creation
of a national pension
and contributory
pension with adjusted
accrual rates,
structural reform of
supplementary
pensions, and
recalibration of
existing pensions)

Adopt legislation to
reforms welfare
benefits based on
World bank Review
Launch the gradual
nationwide roll-out of
the GMI scheme.

Pillar II. Safeguarding financial stability
Policy area

Prior Actions
July-August 2015

Milestones
November 2015

Milestones
December 2015

Restoring
liquidity and
capital in the
banking system

Transposition of
the Bank
Recovery and
Resolution
Directive.

Comprehensive
strategy for the
financial system.

(Completion of
the
comprehensive
assessment and
recapitalisation of
the systemic
banks).

Amendments to the
corporate
insolvency law.

Agreement on
Strategy for NPLs.
Amendments to the
Household
insolvency law
(protection of
primary residence).

Resolution of NonPerforming Loans
(NPLs)

Amendments to the
Household
insolvency law.

Amendment of
HFSF law
including bank
recapitalisation
framework.

Enabling legislation
for creation of a
regulated profession
of insolvency
administrator.
Reactivation of the
Governing Council
of Private Debt.
Improving
Governance of the
Hellenic Financial
Stability Fund
(HFSF) and
Governance of
banks

Prior Actions
1st review 2016

(Completion of
the
recapitalisation
process of the less
significant
institutions).

Amendments to the
Household
insolvency law
(financial assistance
for vulnerable
households).

Revision of the NPL
law (removal of
impediments to the
sale and servicing of
performing and nonperforming loans).

Legislation of NPL
market (regulation
for non-bank service
providers, loan
transfers, debt
information
network, bank
liquidators).

Operationalise the
licensing framework
of credit servicing
companies.

Changes of HFSF
law and new
recapitalisation
framework.

Establish a selection
panel to review
governance of the
HFSF.

Bank of Greece's
Code of Conduct on
relationships
between banks and
borrowers.

HFSF to nominate
executive board
member dedicated
to NPL resolution.

Key deliverables
between June and
December 2016

Amend income tax
law related to debt
write-offs.

Amend the legal
framework for the
out-of-court
workout.
Improve the
institutional
framework for NPL
resolution
(insolvency
administrators, etc.).
Amend corporate
insolvency law.

Finalise the review
of the boards of the
banks and of the
HFSF.

Pillar III. Structural policies to enhance competitiveness and growth
Policy area

Prior Actions
July-August 2015

Milestones
November 2015

Milestones
December 2015

Labour market and
human capital

Prior Actions
1st review 2016

Key deliverables
between June and
December 2016

Launch independent
review of the labour
market frameworks
including collective
dismissals, industrial
action and collective
bargaining.

Align labour market
frameworks to best
practice.
Action plan to fight
un- and underdeclared work.
Implementation plan
for VET 2016-2018,
incl. pilot projects.
Adopt a three-year
Education Action
Plan.

Product markets and Recommendations on
OECD toolkit I
business
(bakeries, milk,
environment
promotions, sales
periods, tourist buses,
and truck
licenses) and some
OECD Toolkit II
recommendations
(beverages and
petroleum).
Opening of restricted
profession of
notaries, actuaries
and bailiffs.
Liberalisation of
tourist
rental.

Recommendation of
OECD on pharmacy
ownership.
Adoption of 40
recommendation on
beverages and
petroleum products
(OECD toolkit II).
Issuance of Joint
Ministerial Decision
on determination of
the notaries' fees.
Adoption of road
map for investment
licensing reform.

Launch of impact
assessments of
Establishing the inter- selected reforms on
ministerial
competition,
investment licences
Committee for the
investment licensing and administrative
burden.
reform and lower
administrative burden
on companies as
Reconvene the interidentified by the
Ministerial spatial
OECD.
planning committee.

Address another 18
recommendations on
beverages and
petroleum products
(OECD toolkit II).

Adoption remaining
(apart from 5)
recommendations to
address competition
issues on beverages
and petroleum
products (OECD
toolkit II).

Reinstate the interministerial
Committee for
regulated professions. Adoption of primary
legislation on OTC
pharmaceutical
Proposal for
products (OECD
improvements in
toolkit I).
spatial planning and
Presidential Decree
on forestry
Submit roadmaps to
definitions.
liberalise specific
regulated professions.
Ex-ante
conditionality and
Law on activation of
EU structural funds.

Recommendations on
OTC pharmaceutics
(toolkit I) and on
wholesale trade,
construction, ecommerce, media and
manufacturing
(OECD toolkit III)
Adopt legislation for
the reform of the
investment licensing
in three key sectors.
Recommendations of
the ex-post
assessments of
selected reforms on
competition,
investment licences
and administrative
burden.

Agree improvements
in spatial planning
law, and adopt
legislation on forestry
maps.
One stop shops for
businesses.
Adopt Digital Policy
General Secretariat
Law relevant for the
structural funds.

Legal framework for
the implementation of
nationwide cadastre
offices.

Pillar III. Structural policies to enhance competitiveness and growth
Policy area

Prior Actions
July-August 2015

Milestones
November 2015

Milestones
December 2015

Prior Actions
1st review 2016

Key deliverables
between June and
December 2016

Regulated Network
Industries, notably
energy

Adoption of
legislation to reform
the gas market.

Implementation
measures on the gas
market reform.

Adoption of
legislation to promote
competition in the
electricity market.

Implementation of
measures on the
electricity market
reform.

Agreement of a
framework for the
separation of
transmission
company (ADMIE)
from the incumbent
producer PPC.

Action plan to
implement the full
ownership
unbundling of
ADMIE from PPC.

Review of the gas
release program.
Transposition of the
EU model for
electricity market.

Design of the NOME Privatisation of at
system of auctions.
least 20% of ADMIE.
Adopt the NOME
mechanism into the
Fist auction in the
electricity market.
electricity market
under the NOME
Adopt the temporary mechanism.
capacity payment
scheme. Cost based
(Transport)
HV tariffs.
Implementation of
the Logistics Law
(Transport)Port
Regulatory Authority
to be fully functional.
(Water) Special
Secretariat for Water
to finalise the
charging rules for
water services

Privatisation and the
new Privatisation
and Investment
Fund

Endorsement of the
Asset Development
Plan approved by
Hellenic Republic
Asset Development
Fund (HRADF).
Adopt government
pending actions
GPAs (sales of
regional airports,
launch the bid for
Piraeus and
Thessaloniki ports).

Completion of
Completion of
Government Pending Government Pending
Actions for Q4-2015. Actions (GPAs) for
Q4-2015, including
on OTE (telecom
shares) , TRAINOSE
Restructuring plan for (train) and OASA
the OASA-Transport (metro/bus).
of Athens.

Endorsement of Asset
Development Plan
approved by
HRADF.
Implementation of
Government Pending
Actions (GPAs).

Agreement on a
Adoption of
action plan for the
legislation to
new Privatisation and
establish the new
Investment Fund.
Privatisation and
Investment Fund, and
to transfer assets to
sub-entities.

Appointment of
Supervisory Board
and Management
Board of the Holding
Company TAE and
sub-entities.
Complete asset
transfers on real
estate and SOEs to
the new Privatisation
and Investment Fund.

Pillar IV. A modern State and Public Administration
Policy area

Prior Actions
July-August 2015

Public
administration

Legislation to align
non-wage benefits
(e.g. travel
allowances etc...) to
EU best practices.

Milestones
November 2015

Milestones
December 2015

Prior Actions
1st review 2016

Key deliverables
between June and
December 2016

Adopt legislation to
reform the unified
wage grid.

Adopt legislation on
appointment of
managers and top
managers in the
public sector
(including the
depoliticisation of
Secretaries
General), and on the
new performance
assessment scheme.

Adopt legislation to
achieve
rationalisation of the
specialised wage
grids.

Commitment to
continue the
attrition rule for
recruitments in the
public sector in
2016.

Adopt legislation to
introduce a new
permanent mobility
scheme in the public
sector.
Issue secondary
legislation to
implement the
reformed
performance
assessment scheme
for civil servants.

Justice

Adopt legislation of
significantly amend
the Code of Civil
Procedure.

Anti-corruption

Publish an update
strategic plan
against corruption.

Independent
agencies and
regulatory bodies

Amend legislation
on the independence
of ELSTAT
including the
appointment process
for the ELSTAT
President.

Adopt a roadmap
for the
implementation of
the revised Code of
Civil Procedure,
including on
electronic auctions.

Take measures to
ensure ELSTAT is
granted access to
administrative data.

Adopt a three year
strategic plan to
strengthen the
justice system.

Take steps,
including
Presidential Decrees
to ensure the full
implementation of
the Code of Civil
Procedure

Amend legislation
on the declaration of
assets.

Modify the legal
framework for
financing of
political parties.

Finalise access of
ELSTAT to
administrative data.

Undertake
horizontal review of
autonomy on
independent
agencies and entities
and amend
legislation where
needed including the
HCC.

Amend legislation
to ensure
institutional and
operational
autonomy of the
Hellenic
Competition
Commission (HCC).

Strengthening the
Regulatory
Authority for
Energy.
Address conflicts of
interest in HCC.