Όπως, συνεχώς, γράφουμε, σε αυτό εδώ το μπλογκ, παρά τα παχιά λόγια των υπουργών, των βουλευτών και των στελεχών του ΣΥΡΙΖΑ, όπως και ίδιου του Αλέξη Τσίπρα, περί του τέλους της μνημονιακής εποχής, που - υποτίθεται ότι - θα έλθει τον ερχόμενο Αύγουστο, με την λήξη του 3ου Μνημονίου, η πραγματικότητα είναι πολύ σκληρή. Μα, πάρα πολύ σκληρή. Είναι, κυριολεκτικά, βάρβαρη. Και φυσικά, ο θανάσιμος εγκλωβισμός της ελληνικής κυβέρνησης είναι πλήρης και ολοσχερής.
Οι μάσκες πέφτουν, λοιπόν.
Το 4ο Μνημόνιο είναι, ήδη, εδώ, αφού η Ευρωπαϊκή Επιτροπή δημοσίευσε, χθές, στηην ιστοσελίδα της, το κείμενο του προσχεδίου του νέου Μνημονίου το οποίο καλείται να υπογράψει η ελληνική κυβέρνηση, η οποία και προφανώς θα το υπογράψει και θα το ψηφίσει, μαζύ με ένα λεγόμενο Μεσοπρόθεσμο Πρόγραμμα, όπως και ένα ολοκληρωμένο κείμενο αυτού του 4ου Μνημονίου, το οποίο θα συμπεριλαμβάνει, εντός αυτού - ή και χωριστά -, την συμφωνία για την ρύθμιση του ελληνικού δημόσιου χρέους, η οποία θα παρακολουθείται και θα ενεργοποιείται, κατά το δοκούν, σύμφωνα με τις επιθυμίες του Βερολίνου, από τους ξένους δανειστές, για το εάν και εφόσον τηρούνται οι δεσμεύσεις, που θα αναλάβει το ελληνικό κράτος, με τις υπογραφές, που θα πέσουν, στα κείμενα αυτών των συμφωνιών και μετά την ψήφισή τους.
Η δημοσίευση του προσχεδίου του ονομαζόμενου, ως 4ου συμπληρωματικού Μνημονίου, ανάμεσα, στην ελληνική κυβέρνηση και τους ξένους δανειστές, είτε συμμετάσχει, είτε δεν συμμετάσχει, με χρήματα, του Δ.Ν.Τ., το οποίο, πιθανότατα, θα συμμετάσχει και σε αυτό το Μνημόνιο, σαν τεχνικός σύμβουλος και όχι σαν χρηματοδότης, καταρρακώνει και ευτελίζει όλη την επιχειρηματολογία των συριζαίων, για την λεγόμενη "καθαρή έξοδο", από το 3ο Μνημόνιο, οι οποίοι, κυριολεκτικά, αδειάστηκαν, για μία ακόμη φορά, από τους ευρωθεσμούς, οι οποίοι οδηγούν τον ΣΥΡΙΖΑ, σε μια μεγάλη και καταστροφική ήττα, εάν καθίσουν, στους κυβερνητικούς θώκους, μαζύ με τον Πάνο Καμμένο και τους ΑΝΕΛ - ή και με οποιονδήποτε άλλον κυβερνητικό εταίρο.
Παρά τα όσα λέγονται, προς άγραν ψήφων και για την αποπροσανατόλιση του πληθυσμού της χώρας, στην πραγματικότητα, το προσχέδιο, που αφορά το συμπληρωματικό (το επικαιροποιημένο) 4ο Μνημόνιο, που δημοσιεύτηκε χθες, στην ιστοσελίδα της Commission, με ημερομηνία 23/5/2018, κλειδώνει τις βαριές περικοπές των συντάξεων, με την ουσιαστική εξάλειψη της λεγόμενης "προσωπικής διαφοράς" των συντάξεων, του Ν. 4387/2016, που ψηφίστηκε, επί υπουργείας του Γιώργου Κατρούγκαλου και οι οποίες περικοπές αυτής της "προσωπικής διαφοράς" των συντάξεων έχουν προψηφισθεί, με τον Ν. 4472/2017, ενώ καθιστά, άκρως, πιθανό και οι μειώσεις του αφορολογήτου ορίου των εισοδημάτων, που έχουν δηλώσει, στην Εφορία, οι φορολογούμενοι και οι οποίες είχε ψηφισθεί να αρχίσουν το 2020, να μετατεθούν και να υλοποιηθούν, εμπροσθοβαρώς, το 2019.
Στο προσχέδιο του κειμένου του 4ου Μνημονίου, προβλέπεται ότι και τα 62 υπολειπόμενα προαπαιτούμενα, που έμμειναν χωρίς να υλοποιηθούν, μέχρι την - όπως, όπως -, συμφωνία, του αποκαλούμενου Stuff Level Agreement, με τα τεχνικά κλιμάκια του κουαρτέτου των ξένων δανειστών, λόγω των κινδύνων, που πηγάζουν, από την νέα ιταλική κυβέρνηση των ευρωσκεπτικιστών, του Luigi Di Maio του Κινήματος των 5 Αστέρων και της Λέγκας του Βορρά του Matteo Salvini, που πονοκεφαλιάζει τις Βρυξέλλες, το Βερολίνο, το Παρίσι και την Φραγκφούρτη, θα υλοποιηθούν, με το νέο Μνημόνιο, ενώ "η επιτυχία της ανάκαμψης θα απαιτήσει την διατηρήσιμη, εφαρμογή των συμφωνημένων πολιτικών, για αρκετά χρόνια". Στον κατάλογο περιλαμβάνεται και η απαίτηση, που οι ελληνικές αρχές είναι υποχρεωμένες να εφαρμόσουν και να καταργήσουν, όσες εκπτώσεις στον ΦΠΑ, έχουν μείνει, στα νησιά και οι αυτοματοποίηση των κατασχέσεων, για τις οφειλές, προς το ελληνικό δημόσιο.
Με αυτά τα δεδομένα, που προκύπτουν, από το κείμενο του 4ου Μνημονίου, το οποίο, όπως είπαμε, είναι, μόνον, ένα πρόχειρο προσχέδιο, η τελική κατάληξη του οποίου, με το αναμενόμενο Μεσοπρόθεσμο Πρόγραμμα, μέχρι το 2022 και τα μέτρα και οι δεσμεύσεις, που θα συμφωνηθούν, για την "ελάφρυνση" του ελληνικού δημόσιο χρέος, αφαιρώντας κάθε φύλλο συκής, από την κυβέρνηση της αριστεροδεξιάς, ανοίγει την πόρτα για την προσφυγή, μέσα στο τρέχον έτος, σε κάλπες, για πρόωρες βουλευτικές εκλογές, μετά τον Αύγουστο, ή και νωρίτερα, με πιθανή ημερονηνία την 25η Νοεμβρίου, αφού ο Αλέξης Τσίπρας δεν μπορεί να βρει συμμάχους, στον κοινοβουλετικό μνημονιακό χώρο των κομμάτων και φυσικά, είναι πολύ δυσχερές να αφήσει τον χρόνο να κυλίσει και να περάσει τον Ιανουάριο του 2019, οπότε θα εφαρμοστούν οι μαζικές μειώσεις των συντάξεων, ενώ είναι πολύ πιθανό να έλθει, εμπροσθοβαρώς και η μαζική μείωση του
Έτσι, όλα τα "καλά" είναι μπροστά μας.
Και για όσους είναι δύπιστοι, όπως και για όσους θέλουν να δούν το αυθεντικό κείμενο του πρόχειρου προσχεδίου, που δημοσίευσε, χθες, η Ευρωπαϊκή Επιτροπή, παραθέτω, παρακάτω, το πλήρες κείμενο, στην αγγλική γλώσσα, έτσι, όπως έχει αναρτηθεί, στην ιστοσελίδα της Commission, προκειμένου όλοι οι ενδιαφερόμενοι να λάβουν γνώση.
Και αυτό, διότι η άθλια "ευρωπαϊστική" ελίτ του τόπου μας τρέφει, με κουτόχορτο, σύμπαντα τον ελληνικό πληθυσμό...
Ας δούμε, λοιπόν, το κείμενο του προσχεδίου του 4ου Μνημονίου, για να καταλάβουμε, περί τίνος πρόκειται, καθώς και το τί πρόκειται να έλθει, όταν πέσουν οι τελικές υπογραφές και ψηφισθούν τα έτοιμα τελικά και επισήμα κείμενα, και στο 4ο Μνημόνιο και στο Μεσοπρόθεσμο Πρόγραμμα, αλλά και στην συμφωνία, για το ελληνικό δημόσιο χρέος :
1 Supplemental Memorandum of Understanding
Fourth Review of the ESM Programme
DRAFT – 23 May 2018
Outlook and strategy
In July 2015, Greece requested support from its European partners to restore
sustainable growth, create jobs, reduce inequalities, and address the risks to its own
financial stability and to that of the euro area. In August 2015, the Hellenic Republic
concluded an agreement for stability support in the form of a loan from the European
Stability Mechanism for an availability period of three years. In accordance with Article 13(3)
of the ESM Treaty, a Memorandum of Understanding was signed which details the
conditionality attached to the financial assistance facility covering the period 2015-18. The
conditionality is updated regularly, taking into account the progress in reforms achieved over
the previous months. In each review the specific policy measures and other instruments to
achieve these broad objectives outlined here are fully specified in detail and timeline. This
update reflects the agreement among the ESM, the European Commission acting on its
behalf, and the authorities upon conclusion of the fourth review of the ESM programme.
Success requires ownership of the reform agenda by the Greek authorities. The
government therefore stands ready to take any measures that may become appropriate for
this purpose as circumstances change. The government commits to consult and agree with
the European Commission, the European Central Bank and the International Monetary
Fund on all actions relevant for the achievement of the objectives of the Memorandum of
Understanding before these are finalized and legally adopted.
The recovery strategy takes into account the need for social justice and fairness,
both across and within generations. Fiscal constraints have imposed hard choices, and it
is therefore important that the burden of adjustment is borne by all parts of society and
taking into account the ability to pay. Priority has been placed on actions to tackle tax
evasion, fraud and strategic defaults, as these impose a burden on the honest citizens and
companies who pay their taxes and loans on time. Product market reforms seek to eliminate
the rents accruing to vested interest groups as the associated higher prices undermine the
disposable income of consumers and the competitiveness of companies. The pension
reform takes into account that existing pensioners find it more difficult to compensate for
income losses and it has applied cuts progressively, based on the level of pensions. To get
people back to work and prevent the entrenching of long-term unemployment, the
authorities have accelerated the absorption of ESIF funds and are working to ensure an
effective impact on the economy, both in the short and the long run. A fairer society requires
that Greece continues to improve the design of its welfare system, so that there is a genuine
social safety net which targets scarce resources at those who need them most. In this
context, the authorities have taken measures to provide access to health care for all
(including the uninsured) and rolled out nationally a basic social safety net in the form of a
Social Solidarity Income (SSI) in early 2017.
Implementation of the reform agenda provides the basis for a sustainable recovery,
and the policies are built around four pillars:
• Restoring fiscal sustainability (section 2): Greece will target a medium-term primary
surplus of 3.5 percent of GDP. This is supported by an ambitious programme to
strengthen tax compliance and public financial management, and fight tax evasion,
while ensuring adequate protection of vulnerable groups, including through the
Independent Agency for Public Revenues (IAPR).
• Safeguarding financial stability (section 3): Further efforts are needed to tackle the
large stock of Non-Performing Loans (NPLs). This requires in particular the effective
impementation of the strengthened framework to support NPL resolution (market for
NPLs, out-of-court workout (OCW), e-auctions, insolvency framework). Banks and the
public sector need to speed up the restructuring of debts and the liquidation of non-
viable businesses to support the recovery of the economy along with the gradual
phasing out of capital controls.
• Growth, competitiveness and investment (section 4): Greece will continue to design
and implement a wide range of structural reforms that not only ensure full compliance
with EU requirements, but which also aim at achieving European best practices. The
authorities will continue to implement an ambitious privatisation programme, and the
independent Privatisation and Investment Fund (HCAP) has been established
supporting a more efficient monetisation of valuable State assets..
• A modern State and public administration (section 5): Particular attention is being paid
to the implementation of reforms to increase the quality and efficiency of the public
sector in the delivery of essential public goods and services. Measures will be carried
forward to enhance the efficiency and improve the capacity of the judicial system and
to upgrade the fight against corruption. Reforms include strengthening the institutional
and operational independence and effectiveness of key institutions and agencies such
as the statistics institute (ELSTAT), the Hellenic Competition Commission and other
The success of recovery will require the sustained implementation of agreed policies
over many years - which necessitates the political commitment, but also the technical
capacity of the Greek administration to deliver - and to this end the authorities have
committed to make full use of the available technical support. Technical support on the
European side is coordinated by the Structural Reform Support Service (SRSS) of the
European Commission. Technical support is already in place for some key reform
commitments, including on tax policy and Public Financial Management (PFM), the reform
of the custom and tax administrations, the review of regulatory barriers to competition,
licensing simplification and doing business reforms, the social welfare review, the national
roll-out of the Guaranteed Minimun Income (GMI), the consolidation of pension funds into
one single fund, the fight against corruption, the implementation of the Greek energy policy
objectives, the reform of the Greek health programme, the modernisation of the judicial
system and the administrative reform. In October 2015, the Greek authorities and the
European Commission finalised a medium-term tecxhnical support plan in line with the MoU
signed in August 2015. In December 2015, the Greek authorities informed the Commission
that they would allocate EUR 30 million to technical support projects in the areas of PFM
and privatization; economic development and procurement; justice and anti-corruption;
public administration reform at both central and local level; labour, employment and social
protection (including health and education). The transport sector and other sectors such as
tourism, energy, waste and water are also addressed. In July 2017, the Commission agreed
with the Greek authorities on a complementary plan aligning the framework to the newly
established Structural Reform Support Programme (SRSP) for the period 2017-2020. This
complementary plan defined technical support projects with a value of EUR 2.9 million for
SRSP 2017 and EUR 2 million for SRSP2 2018. The support projects funded are aligned
with previous technical support requests (that they deepen and / or complement) and with
the MoU, including this update. Moreover, the Greek authorities have activated Article 11 of
the SRSP on January 30 for EUR 20 million to continue in the coming years technical
support for ongoing projects where the reform has still not yet been completed and for new
technical support needs that may arise from the Growth Strategy.
Greece needs to build upon the agreed recovery strategy and pursue a genuine
growth agenda which is Greek-owned and Greek-led and fully uses available
resources, including those provided by the EU. This should take into account the
reforms included in this SMoU, relevant European Union initiatives, the Partnership
Agreement of the implementation of the National Strategic Reference Framework (NSRF)
and other best practices. Greece must benefit fully from the substantial means available
from the EU budget and the European Investment Bank (EIB) to support investment and
reform efforts. For the period 2007-2013, Greece was eligible for EUR 38 billion in grants
from EU policies, and should ensure that all projects funded under that financing envelope
are completed as planned according to the EU regulations. For the 2014-2020 period, more
than EUR 35 billion is available to Greece through EU funds and Greece should continue in
its effort to maximise and speed up absorption of this envelope. The European
Commission’s Investment Plan for Europe and the EBRD will provide additional sources of
investment, as well as technical help for public and private investors to identify, promote and
develop high-quality and feasible projects to fund, and the Greek authorities and operators
should make full use of this opportunity.
The Greek authorities have presented a draft Growth Strategy to the Eurogroup on 27
April 2018, which sets out key priorities in the areas of ensuring fiscal sustainability,
strengthening the business environment, wage setting framework, ensuring effective
functioning of network industries and management of state assets, fostering fair and
inclusive growth, and strengthening the financing of growth (financial instruments,
development bank, reduction of non-performing loans). It it also aims at designing sectorial
priorities in areas such as transport and logistics, energy, circular economy, agri-food,
manufacturing, shipping, pharmaceutical sector, health and environment, tourism and
culture. The Growth Strategy builds upon reforms agreed under the programme as well as
existing medium-term action plans in key areas. The authorities will consult social partners
and other stakeholders in finalising the growth strategy. Where the draft growth strategy
remains general in scope, the authorities will use it as a basis for further elaborating and
operationalising concrete policy measures, so as to enhance its traction and credibility. The
authorities will implement the Strategy with the assistance of a Scientific Development
Council including social partners and sectoral business organisations as well as an Advisory
Panel of foreign investors.
End-November 2017, the authorities presented a concept paper aimed at establishing a
National Development Bank that will coordinate the implementation of development and
promotional activities, in line with the Eurogroup statement of 15 June 2017. The new entity
will not accept deposits from the public nor engage in direct lending. The new entity’s
functions, final structure and by-laws will reflect in-depth consultation and agreement with
the institutions and will be designed to ensure no risks to public finances and financial
stability; its objectives, instruments and governance will be established in line with
international best practice and with the benefit of technical support.
2. Delivering sustainable public finances that support growth and jobs
2.1 Fiscal policy
The general government primary balance in programme terms reached 4.2% of GDP in
2017, significantly outperforming the programme target for three consecutive years. The
outturn of 2017 was supported by a large amount of measures, in particular the 2016 pension
reform and the reform of indirect taxation, while the yield from the PIT reform was below
expectations. An additional boost was provided by sizeable payments of tax arrears through
the Voluntary Disclosure Initiative and through social contributions, while most of the over-
performance was however accounted for by lower-than-expected spending, in particular on
The Greek authorities commit to ensuring sustainable public finances by pursuing the fiscal
path agreed in August 2015 that is based on a primary surplus target of 3.5 percent of
GDP in 2018. The primary surplus target of 3.5% of GDP will be maintained over the medium
term until 2022.
The government as a prior action will adopt the Medium-Term Fiscal Strategy (MTFS)
2019-22 that will set spending ceilings consistent with ESM programme targets and a
primary surplus of 3.5% of GDP for 2019-2022.
The Greek government will monitor fiscal risks, including existing and future court rulings,
and will take offsetting measures as needed to meet the medium-term fiscal targets in the
context of the Medium-term Fiscal Strategy and in its annual updates.
The authorities have pre-legislated a fiscal package in June 2017 in support of rebalancing
the budget toward more growth-friendly and distributionally just policies. Specifically, the
package contains the following elements:
• a pension reform, to be implemented in 2019, delivering net savings of 1% of GDP in
2019-2022 and a personal income tax reform to be implemented in 2020 and delivering
net savings of 1% of GDP in 2020, 2021 and 2022 (see TMU Section L);
• a growth-enhancing tax package matching in net terms the yield from the personal
income tax reform encompassing (i) a reduction in PIT rates and the solidarity surcharge
with a medium-term fiscal impact of 0.8% of GDP; (ii) a reduction in CIT rates with a
medium-term fiscal impact of 0.1% of GDP, and (iii) a reduction in property tax (ENFIA)
with an impact of 0.1% of GDP (see TMU Section L);
• a targeted spending package matching in net terms the yield from the pension reform
composed of an increase in (i) spending on targeted welfare benefits (housing allowance;
child benefits; school meals; nursery/pre-school education; means-tested reduction in
health co-payments) by 0.7% of GDP, (ii) high-quality public infrastructure investment by
0.15% of GDP, and (iii) active labour market policies by 0.15% of GDP (see TMU Section
L). To the extent that elements of the social welfare package have been advanced to
2018, the use of available fiscal space will be specified in agreement with the institutions.
5 The authorities, as a prior action, will bring forward the implementation of the personal
income tax measures to 2019 if the IMF, in cooperation with the European institutions and
the Greek authorities, in the context of the final programme review, considers that, based on
a transparent forward looking assessment, a frontloaded implementation is needed in order
to reach the agreed 3.5% primary surplus fiscal target in 2019, which should be reached
without growth-detrimental measures, and if needed will adopt legislation, in agreement with
the institutions, to ensure the exact achievement of the fiscal target, in a manner that is
positive for growth. In addition and based on an assessment and agreement by all institutions
and in consultation with the Greek authorities, following a transparent process, the authorities
will adopt the necessary secondary legislation for the implementation of the expansionary
package starting in 2019. The amount to be implemented will be in line with the institutions’
projected over-performance relative to the agreed medium-term targets – on the assumption
that the contractionary measures will have already been built into the baseline scenario – in
order to ensure the achievement of the targets.
2.2 Tax policy reforms
The authorities will as a prior action: (a) review preferential tax treatments for the shipping
industry in the light of the indications of the European Commission; (b) undertake a technical
review of the ITC provisions after its 3-year application, identifying problems and loopholes
and proposing amendments with the objective of clarifying and ameliorating its application
and eliminating conflicting provisions, (c) reform the business tax incentives for employment,
environmental protection, and the production of audio-visual work in agreement with the
institutions; (d) codify and simplify the VAT legislation, aligning it with the TPC and
eliminating outstanding loopholes and (e) review the TPC interest regime and (f) the
authorities have amended the Code of Public Revenue Collection to provide for the extension
of the e-auctions mechanism to auctions conducted by the revenue authorities under the
Code of Public Revenue Collection under its provisions.
By June 2018, the authorities will (a) review the Stamp duty code with the aim of modernising
and simplifying the Stamp duty regime by taking into account the modern business
environment; (b) review of the imputed income system of ITC and legislate if change needed.
In parallel with the review by the Ministry of Justice, the IAPR will review the effectiveness of
the application of the KEDE for auctions and e-auctions; and, if needed, adopt legal or
procedural amendments (prior action).
As a prior action, (i) the authorities with the aid of technical support will align property tax
assessment zonal values with market prices, through legislation if needed and will issue
legislation for a permanent unit dedicated to property revaluation; (ii) the authorities will
legislate to adjust tax rates and broaden the property tax base if necessary in a revenue
neutral way in order to issue ENFIA bills by August 2018. By July 2018, the authorities with
technical support will (i) develop plans for the permanent IT system for property revaluation
and will identify the required budget and (ii) establish the property evaluation unit within the
Ministry of Finance organigramme.
The authorities will review the implementation of the capital gains tax on real estate and
adopt legislation if needed by May 2018.
The authorities will ensure that the VAT discount on the remaining islands is eliminated by
end-June 2018 (prior action).
2.3. Public revenue reforms
Revenue collection has been hampered by complicated legislation, poor administration
reflected by chronically weak enforcement, political interference and generous amnesties. To
break from this practice and build a responsible tax and social security payment culture, the
government firmly commits to take strong actions to ensure the independence of the revenue
services and improve compliance and collection.
The authorities will continue to improve operations as measured by key performance
indicators (KPIs) (see TMU H). The authorities will continue the reforms improving public
revenue administration in agreement with the institutions, and taking into account
recommendations of technical support.
The Independent Authority of Public Revenue
The authorities will take the necessary measures to ensure an effective functioning of the
Independent Authority of Public Revenue (IAPR) (see TMU R). In this respect, the authorities
will, taking into account the experience gained since the January 2017 inception of the
Management board, take any necessary measures for improvement by June 2018 taking
into account as necessary technical assistance suggestions..
The authorities will undertake an assessment of the experience with the 2017 performance
contract of the Head of the Agency together with the institutions in May 2018 (see TMU
With the help of technical support, the IAPR has produced the Human Resources policy
paper for the agency staff, in terms of grading, assessment, promotion and remuneration.
The authorities will pass primary and/or secondary legislation as appropriate on the grading
of staff and will initially allocate staff to appropriate grades by June 2018. The authorities will
pass primary and/or secondary legislation as appropriate for remuneration and on the
individual assessment of staff by July 2018. A specific appropriation will be agreed in May
2018 for the implementation of the new remuneration system.
The IAPR will be given a specific budget envelope, within General Secretariat of Information
Systems(GSIS) budget line, for central IT hardware and systemic software. The IAPR will
define the priorities within this envelope. The GSIS will provide the hardware and systemic
software as service provider on the basis of agreed costs. The framework and level of budget
envelope within GSIS budget line will be agreed by May 2018.
The authorities will ensure that the tax and customs academy is fully in place by June 2018.
The authorities will (prior action) proceed with the following hiring plan for 2017 – 2018, as
agreed with the one-off injection of resources through the Supreme Council for Civil
Personnel Selection (ASEP):
• starting the process for hiring through ASEP 728 staff, including 28 IT staff
• implementing an attrition rule 1:1 (i.e. one entry for one exit) for 2018 and going
• applicants through the mobility schemes: IAPR has the capacity to screen staff
coming from the 1997 ASEP recruitment and from the mobility scheme if they do not
meet the qualification requirements corresponding to the IAPR needs and decided by
• After IAPR concludes the screening of applicants through the mobility scheme, 60%
of the remaining vacant positions will be covered by recruitments in 2018 and 40% in
early 2019, with a maximum threshold of 900 people. The decisions on the 2018 and
2019 recruitments will be taken and the hiring process will be launched.
IAPR makes the final decision on staff to be transferred to it. For the ASEP recruitments, in
order to limit delays, a reserve list system will be created by May 2018 and ASEP will
schedule its recruitment process to ensure that the reserve list contains sufficient candidates
for a year of future recruitment.
With a view to reinforce fight against corruption, the authorities will proceed with a yearly
publication of disciplinary proceedings and infringements.
Finally, the authorities will provide the institutions with regular updates on the activities of the
IAPR including :
• monthly updates on the budget execution, and on the situation of staffing and actual
hiring of the Authority;
• the semi-annual updates of the service-level agreement implementing corrective actions
To further improve compliance, the government will pursue, and will quarterly report to the
institutions on the progress of the implementation of the action plan for the promotion and
facilitation of the use of electronic payments (through both transfers and cards) and the
reduction in the use of cash and cheques: in 2018 this should take place in April and July.
The authorities will update regularly the action plan, and in 2018 do so by the month of May.
The authorities will fully implement the operational roadmap to improve compliance,
according to its timeline.
The authorities will procure or lease the risk-assessment software allowing substantially
increased detection of carousel fraud to be used as from May 2018.
The authorities will commit not to provide any filing extension and to put in place in time the
necessary information campaign to encourage taxpayers to fulfil their declarative obligations
by due date (continuous action).
Improving the fight against tax evasion
The authorities will implement the new system of organisation of fight against financial crime
between Justice and IAPR. The previously received pending orders not in their final stage of
audit will be transferred back to the prosecutors as a prior action (see TMU Section xx).
The authorities will adopt legislation establishing a central registry of beneficial ownership
information of legal persons to ensure public authorities access to adequate, accurate and
current information in line with the Financial Action Task Force standard by May 2018.
The authorities will address the problem of base erosion, and propose by May 2018 an action
plan which will use risk assessment measures to identify for priority audit Greek taxpayers
engaged in profit shifting through manipulation of transfer pricing or avoidance of Permanent
In order to reduce unnecessary litigations the authorities will reinforce the dispute resolution
unit by providing it by May 2018 with a case management system.
Improving public revenue collection and debt management
To improve the collection of tax debt the authorities will fully implement the agreed national
collection strategy. This will include:
i. following the completion as prior action of a key procedural step as specified in the
TMU (Section V), the pursuit of the procurement of the software allowing for further
automation of the debt collection, embracing notably fully automatized garnishment
ii. if needed, the possible amendment of the legislation establishing clear criteria of non-
collectability to enable the write-off of tax claims, to be implemented by May 2018,
iii. review and amend, if necessary, of the statute of limitation for collection to ensure an
adequate ceiling on the total number of years that collection of a tax claim can be
enforced, by May 2018,
iv. a study on the possibility to introduce a system of regular monthly payment by
automated electronic means for the taxes paid by individual taxpayers, to be
completed by May 2018,
v. publication of the yearly update of the list of large tax debtors with the next
publication due in March 2019 (see TMU Section X),
vi. commitments to review and amend if necessary the TPC framework relative to
actions to regularly revert against persons who are jointly and severally liable for the
liabilities of legal persons by May 2018,
vii. the commitment, necessary to improve payment compliance, not to introduce new
instalment or other amnesty or settlement schemes nor extend existing schemes and
to take immediate enforcement action regarding debtors who fail to pay their
instalments or current obligations on time (continuous action).
After the first phase of the triage of the large debtors on the basis of the analysis of economic
and financial data determining their viability (see TMU Section W), starting by the debtors of
the Large Debtor Unit (LDU) and of the Single Collection Centre for Social Security
Contribution Debt (KEAO), and in the framework of the second phase of the triage the LDU
and the KEAO will finalize a report classifying large debtors and proposing solutions by May
2018. The report will also include timelines and specific KPIs.
The authorities will produce, by May 2018, a policy paper on the ways and means to curb the
regular increase in public tax debt.
Fight smuggling and improve customs efficiency
The authorities will implement the anti-smuggling strategy for excisable products according to
its timeline. They will report progress on a quarterly basis (see TMU Section Y). The anti-
smuggling strategy implementation will include the fight against fuel smuggling and the full
and timely implementation of the joint ministerial decision taken to combat fuel smuggling and
its measures for locating storage tanks (fixed or mobile) and for installing the inflow-outflow
system. The authorities will install and operationalize the Operational Coordination Centre
against Excisable Product Smuggling. It has access to IT systems and a detailed business
plan has been agreed. The interoperable IT system will be up and running by May 2018. The
centre will be fully staffed by October 2018. The authorities will also register equipment and
licence warehousing, companies and individuals by December 2018. The authorities will
implement the action plan for the procurement of an effective fuel marker system to be put in
place for full scale application expected in May 2019.
The authorities will pass, if necessary, legislation as a prior action to reinforce domestic
tobacco manufacturers' responsibility of their distributors by supply chain agreements (see
TMU Section AA). The authorities will fully implement the customs reorganisation, with the
mobile control units and regional centres fully financed and equipped, and to be fully staffed
by December 2018. To improve customs efficiency the authorities, with the participation of
public and private stakeholders, will implement in a timely manner the trade facilitation
roadmap for the national single window including the streamlining of pre-customs procedures
and will report quarterly on the implementation.
Centralise the collection of social security contributions into a single social security
With the scope of merging all contributions and debt collection into EFKA and KEAO, and in
order to ensure full completion of the registration of all social-security-contribution debts in
the single social-security-contribution debt database managed by KEAO, the authorities have
set up a dedicated team to start clearing the paper cases and introduce the relevant
information into KEAO database. As a prior action (see TMU Section CC),
• The dedicated team will produce a report about the cases that have been dealt with
and, based on the number of the remaining cases to be checked, will propose a
timeplan for completion of the integration into the KEAO debt database; and
• All social security contributors debt in all instalments schemes will be entirely
transferred to KEAO (TMU Section CC).
To improve social security debt collection, the authorities will publish regularly the list of large
debtors for social security debt at the same time as they publish the list of large tax debtors
(see TMU Section X). The authorities will further improve the rules for quarantining and
writing off debt in order to align them with rules applicable to tax debt, one month after the
publication of the relevant rules for tax debt. They will also improve, if necessary, the
framework in order to allow restructuring of public debt for viable businesses in distress.
KEAO's business process will be reviewed and adapted by May 2018 (see TMU Section DD).
2.4 Public Financial Management and Public Procurement
2.4.1 Public financial management
The authorities commit to continuing reforms that aim at streamlining and improving the
budget process and expenditure controls, clearing arrears, strengthening budget reporting
and making cash management more effective.
The government is implementing a new Government Budget Classification structure and
Chart of Accounts. The authorities commit to: (i) implement the Chart of Accounts for the
economic and administrative classifications in the 2019 State budget and to (ii) complete the
Chart of Accounts for central administration concerning the remaining segments. In detail,
the fund classification will be adopted for its implementation in the 2020 State budget and the
functional classification in the 2021 State budget. The programme and project classifications
will be introduced in line with the performance budgeting framework to be agreed with the
technical support. The implementation of the new classifications will be also in view of
supporting the cash management functions. The authorities will modify the presentation of
the State Budget bulletin, t-report and MTFS to align with international statistical standards
and the General Government monthly bulletin. The finalization of the Chart of Accounts for
the general government will be done in consultation with the relevant stakeholders of the
reform. Furthermore, the authorities commit to: (iii) set up an action plan for the
implementation of the Chart of Accounts in the general government. These actions require
adequate staff resources allocated to the reform in GAO. A pilot phase will be conducted
ahead of the implementation of the Chart of Accounts in the 2019 State budget. The pilot
phase will conduct a test exercise, the mapping of the Chart of Accounts to fiscal reporting in
line with international standards and a parallel run of the old and new FMIS in at least one
ministry. Moreover, the authorities commit to: (iv) amend the conflicting provision with
reference to the sectoral Chart of Accounts (Article 40 of Law 4483/2017) to specify it is
meant to be transitional pending the full implementation of the single Chart of Accounts for
general government; (v) finalize the design of the integration of the Financial Management
Information System (FMIS) and the new Chart of Accounts (prior action) so as to ensure the
full use of the FMIS to support the implementation of the new Chart of Accounts in the 2019
State budget; and (vi) develop a programme of communication and training covering all the
The authorities will make sufficient progress in clearing arrears to the private sector by June
2018 (see TMU Section xx). With a view to fully clear the outstanding stock by the end of the
programme, and the authorities will implement their arrears clearance plan taking also
account of the disbursement plan under the ESM programme. The authorities will clear the
outstanding stock of arrears, including overdue but unprocessed tax refund and pension
claims by using own resources and designated programme financing. The authorities will
continue producing detailed monthly reports on the arrears cleared and on outstanding gross
and net arrears. In parallel to the arrears clearance programme, and without hampering or
delaying it, the authorities will ensure that the assessment by the independent auditor will be
completed by May 2018, covering the government accounts payable and the use of ESM
programme funds from end-June 2016 up to end-December 2016. The assessment will
check the accounts to verify proper use of the funds, identify the extent of structural problems
and assess the optimality of the arrears clearance plan sequencing. Based on the
recommendations of the final report presented to the authorities and the institutions, the
authorities will take corrective actions to address structural shortcomings leading to the
accumulation of new arrears (see TMU Section XXX) (prior action). The supervising
Ministries will ensure the implementation of these actions by the concerned entities. The
implementation will be assessed through the Hellenic Court of Auditors follow-up compliance
audit in 2019 and monitored by GAO on an ongoing basis. The government will ensure that
budgeted social security contributions are transferred from social security funds to health
funds and hospitals evenly throughout the year so as to clear the stock of health sector-
related arrears, in line with the KPI targets..
The authorities will provide all relevant information for the institutions to assess progress in
the implementation of the Late Payment Directive and will continue to improve operations as
measured by KPIs. In order to facilitate the clearance of hospitals' late payments the
government will submit by May 2018 a roadmap on: i) the implementation of measures to
make allocation of staff in financial departments more efficient, as well as improving their
technical capability, ii) the roll out of the business intelligence system to improve the quality
and quantity of data and for calculating average payment terms, and late payment amounts
(interests) on a monthly basis. The government will take appropriate measures to ensure
that payments to suppliers of public and military hospitals arising from contracts signed after
15 February 2016 comply fully with Law 4152/2013, and will avoid taking legal or
administrative measures or implementing practices that are not in conformity with it.
The government will continue the work on improving the fragmented cash management
system transfering general government surplus reserves to the Bank of Greece accounts.
The transfer is to be conducted in cooperation with the Bank of Greece and taking into
account financial stability implications and operational needs of general government entities.
The amounts to be transferred are to be determined in agreement with the institutions.
Following the implementation of the cash management reform the authorities will close
accordingly unused central government accounts in commercial banks and consolidate them
in the Treasury Single Account (TSA). By May 2018, the authorities will prepare the new
legislative framework defining the TSA and the timeline for the full integration of the general
government accounts into it.
The authorities will fully implement the action plan to improve the management of state
guarantees granted to individuals and enterprises for proven damages as a result of natural
disasters or to private enterprises operating in geographical areas characterized by
exceptionally low economic activity.
The Ministry of Finance will continue using the established ring-fenced account for the
management of the EU Home Affairs Funds (AMIF/ISF). A bi-monthly detailed reporting of
the activities of this account will be provided to DG Home of the European Commission.
The Greek government is committed to making the Fiscal Council fully operational by
ensuring better coordination of information flows with relevant entities (e.g. ELSTAT and
IAPR) through a memorandum of understanding or amending the relevant legislation if
2.4.2 Public procurement
Greece has made significant progress 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. Further action is needed to complete the reforms
in the area of public procurement.
In particular, the authorities will, as a prior action, appoint the remaining members of the
Remedies Review Body and will complete the selection procedure and appoint its scientific
and administrative personnel (as provided for in Article 357 of Law 4412/2016).
2.5 Sustainable social welfare
The authorities have adopted a comprehensive reform of the pension system, to strengthen
long-term sustainability while targeting savings of around 1 percent of GDP by 2018, mostly
from the expenditure side, on top of the full absorption of the impact of the Council of State
ruling on the pension measures of 2012, around 2 percent of GDP. To fully implement the
new legislative provisions, the authorities:
i. Recalibrate pension benefits. In order to achieve intra- and inter-generational equity
and fully absorb the Council of State ruling, recalibrated all the existing pensions on
the basis of the new parameters of the uniform pension rule applied to the
pensionable earnings in current value, with the exception of OGA. For ETEA insured
persons, accrued rights up to 2014 were recalculated with an accrual rate of 0.45, to
align them to the current NDC system and taking into account higher contribution
rates than those specified with the harmonised contribution rules. Lump-sum
calculation will be revised to guarantee actuarial fairness.
ii. The cross-check between digital records and paper documents for the individual
recalculation of the pension benefit under the new uniform rules will be completed as
a prior action.
iii. As a prior action, the authorities will calculate and process all main pension
applications of 2016 and 30% of main pensions applications submitted in 2017 and
at least 13.800 of supplementary pension applications submitted from 1.1.2015 and
iv. Eliminate EKAS. Phase out the solidarity grant (EKAS) for all pensioners by end-
December 2019, reducing it by EUR 570 million by 2017; EUR 808 million by 2018;
and EUR 853 million by 2019. The authorities will adopt as a prior action the
Ministerial Decision setting all the details for the awarding of EKAS in 2019.
v. Benefits for past higher contributions. Benefits should be provided in a fiscally neutral
manner based only on accrual rates as defined in the primary law.
vi. For the full implementation of the pension reform, the authorities have issued the
Ministerial decisions of art. 70.2 of Law 4387/2016 and the Presidential Decree of art.
52 of the same law. The authorities will finalise and implement this Presidential
Decree within one month after the opinion of the Council of State.
To complete the full merge of all insured persons and related data into the single pension
i. As a prior action, the incorporation of the public-sector pension scheme in EFKA,
including transfers of relevant staff from the General Accounting Office, and any legal
or administrative step required for the actual transfer of databases, software and IT
infrastructure will be fully completed;
ii. On 2 May 2018, Eurostat has published its official opinion on the classification of the
journalists pension fund (EDOEAP) within the general government periphery. In light
of this opinion, as a prior action, the authorities, within one month following the
publication, will adopt the necessary measures (see TMU Section O) in consultation
with the institutions and in compliance with the supreme court ruling (5/2002),
including measures to ensure the full alignment to ETEAEP rules as defined in
Articles 96 and 97 of law 4387/2016 and any other measure necessary to guarantee
that no public funding of EDOEAP's deficit can occur. Additional revenues (if any)
can only fund health care services offered by EDOEAP.
iii. Automatic electronic records shall be created in EFKA also for insured persons. The
authorities will record data on insured persons targeting those over 55-years old
ensuring that 90% of the relevant data are entered in the system by June 2018 ; and
the process will be fully completed by the end of the programme.
The merging of the social security funds into EFKA will lead to efficiency gains including
through a reduction of overall staff. The authorities will implement the action plan adopted as
part of the second review. As a matter of priority, qualified personnel will be directed to
clearing unprocessed pension claims and creating electronic registries for the insured and
retirees (see ¶2.3) or transferred to other administrations. Staff who are not retained should
be transferred to other entities – including KEAO, the National Actuarial Authorities and
EOPYY (the National Organisation for the Provision of Health Services), in order to
strengthen their operational capacity (TMU Section O) – taking into account their hiring
needs, and making use, to the extent possible, of the new mobility system introduced with
As a prior action, EFKA will take concrete steps for the diversification of its investment
portfolio in line with best practices, to ensure that it holds no controlling stakes in any private
The authorities will continue the regular publication of the Helios report whose structure and
content will be defined in agreement with the institutions (continuous action).
2.5.2 Health care
The authorities have committed to further reforming the health care sector, with the aim of
universal, equal and effective care, controlling public expenditure, managing prices of
pharmaceuticals, improving hospital management, increasing centralized procurement of
hospital supplies, managing demand for pharmaceuticals and health care through
evidence-based e-prescription protocols, commissioning private sector health care
providers in a cost effective manner, modernizing IT systems, developing a new electronic
referral system for primary and secondary care that allows to formulate care pathways for
patients. As the full implementation of these objectives requires time, the authorities are
committed to implement necessary additional necessary measures also beyond the
deadlines referred to this document.
22.214.171.124 Rationalisation of health expenditure
The authorities will, in line with detailed targets and deadlines set out in the TMU (Section P),
a. in order to address the remaining part of the recent overspending on "other items" in
the EOPYY budget for "Other Illness Benefits" (125 million in 2017) EOPYY will
extend the clawback to include optometrist services and special education services
b. as a prior action, the authorities will implement the 14 measures included in the
EOPYY Action Plan to reduce the amount of excess spending;
c. by May 2018, they will develop a mapping of overall public sector capacity; by
December 2018, based on this mapping, the authorities will develop an in-depth
assessment to be used in the future to commission private providers per region
subject to insufficient public capacity;
d. implement a new system of electronic referrals (e-referrals) to secondary care to be
used by family doctors. (May 2018);
e. develop, by May 2018, a critical mass of prescription guidelines and therapeutic
protocols for patient care pathways (primary and secondary care) for the
pathways that have the greatest therapeutic and cost implications, to feed into the
e-prescription system; as a prior action, at least additional (compared to
December 2017) 20 of these therapeutic protocols will be introduced in the e-
f. develop an annual report on human resources for the whole health care sector (to be
used as a human resource planning instrument) with a focus on PHC (first report to
be published by May 2018);
g. closely monitor and fully implement universal coverage of health care and
inform citizens of their rights in that regard and proceed with the gradual
implementation of the new Primary Health Care System. To this end, the
authorities have adopted all the necessary legislation to implement this new
system in May 2017. Within this framework, EOPYY will change the way it
provides primary health care by introducing compulsory patient registration with a
family doctor, who will act as a gatekeeper in charge of referrals to specialists. As
a prior action: a) the complete matching of all Social Security Number (AMKA)
holders with the avaliabe family doctors will be finalised by May 2018 and b) the
complulsory patient registration system with a family doctor, who will act as a
gatekeeper, will be in place and fully operational by end of May 2018, with
gatekeeping to be gradually implemented over 2018.In parallel, the roll-out of
Local Health Units, started in December 2017, will lead to creation of a critical
mass of Local Health Units (at least 85) by May 2018, with full implementation to
be achieved subsequently. As new Local Health units become operational, the
existing contractual arrangements of EOPYY with private GPs will be
correspondingly reduced so as to avoid duplications in the local provision of
126.96.36.199. Execution of clawbacks and regular audit1
a. The authorities will execute the clawbacks every six months and perform regular
b . The authorities will continue to collect relevant data from EOPYY, the National
Organisation for the Provision of Health Services, and regularly publish it.
c. The authorities will apply and collect outstanding claws backs, continuously until
they are cleared. As a prior action, (i) EOPYY will finalise the legal procedure for
the offsetting of the residual outstanding clawback (2013-2015) for all outstanding
amounts except those for which it is not legally/technically possible to perform the
offset; (ii) any outstanding uncollected clawback amount related to 2016 will
be offset and collected for health care providers and (iii) the authorities will extend
the clawback ceilings for diagnostics, private clinics, pharmaceuticals up to 2022.
The ceiling will rise in line with the authorities' forecast of the annual growth of GDP
at constant prices; (iv) the clawbacks of 2017 (and for 2016, for pharmaceutical
companies) will be collected/offset according to the timetable specified in the TMU
d. To assess and improve the performance of health care providers, EOPYY will carry
out systematic monthly auditing of private clinics.
1 Details on specific targets by deadline contained in the TMU (Section M ¶57-59).
188.8.131.52. Measures to improve the financial management and cost effectiveness of
The authorities will:
a. take concrete steps to increase the proportion of centralised procurement by May
2018, following the adoption of the Law on centralised health procurement; for
details see TMU (Section P); in May 2018 present the plan to increase the proportion
further in 2019.The appointment procedures under the rules set by Law 4369/2016
will be started as a prior action (see TMU section xx).
b. by December 2018, reduce waiting times (including for elective surgery) with respect
to the previous year in line with the Social Pillar and reduce unwarranted variation in
waiting times across providers and patients (including across socio-economic and
other patient characteristics); for details see TMU (Section P);
c. by May 2018, start the implementation of the DRGs system in pilot hospitals;
d. produce regular quarterly and yearly reports, based on financial data for hospitals
and hospital performance (benchmarking based on activity related indicators).
184.108.40.206. Reducing pharmaceuticals spending through generic penetration and price
a. The authorities will update and publish on a regular basis (for details see TMU
Section P), and at least every six months, the positive and the negative list.
b. As a prior action, the authorities will publish a revised price bulletin in May 2018.
c. As a prior action, the authorities will adopt further measures to improve cost-
effectiveness of pharmaceutical spending with a view to reaching the 40% generics
penetration target. These measures may target many relevant areas, such as
updating the set-up of reimbursed prices and of patients' participation to ensure they
promote the choice of cost-effective drugs and by further improving the incentive
structure of pharmacists to encourage the sale of less costly drugs for any given
active substance prescribed.
d. To further reduce prices, they will make use of the negotiating committee to develop
price volume and risk agreements, such as MEAs (Managed Entry Agreements), in
line with other EU countries standards and international expertise, especially for
innovative and high cost drugs and regularly report on the progress. The authorities
will set-up a Health Technology Assessment (HTA) centre to evaluate which
products to reimburse and under what conditions and agreements, in line with
existing guidelines and with evidence of best-practice in the EU, to become active
once fully operational after June 2018.
2.5.3 Social safety nets and activation
The economic crisis has had an unprecedented impact on social welfare. The most pressing
priority for the government remains to provide immediate support to the most vulnerable to
help alleviate the impact of the crisis. A fairer society will require that Greece improves the
design of its welfare system in line with EU best practices, so that there is a genuine social
safety net which targets scarce resources to those in most need.. The SSI was successfully
rolled out at national level in February 2017. To further support the smooth implementation of
the scheme the authorities have established a disputes resolution system and developed an
internal capacity to provide risk assessment, auditing, and inspections.
The social inclusion component (2nd pillar) of the SSI scheme includes linkages with social
services and other benefits. The objective is to widen access to the existing available social
services (such as psycho-social and health-related support and legal counselling) aiming at
inclusion and removing barriers to work. The Greek authorities have adopted an operational
strategy for the delivery of this 2nd pillar. The registries of social services and service
providers have become operational at the end of February 2018 and will be maintained up to
date on a real time basis. Links between the Community Centres, municipal social services
and service providers are being further developed including by establishing an automatic
exchange of information with major providers.
With regards to the activation component (3rd pillar) of the SSI, the Greek authorities will
formalise the cooperation arrangements between the municipalities/community centres and
the local offices of the public employment services, also in light of the results of the pilot
testing the new delivery model of ALMPs. As a prior action, the requirement will be
introduced for all individuals in SSI-beneficiary households who are able to work and are not
employed nor in education or training, to register as jobseekers at OAED. Individuals in
beneficiary households who can be integrated in the labour market will be offered access to
personalised active labour market (ALM) measures. This will include the systematic
preparation of individual action plans by OAED employment counsellors. The menu of ALM
measures offered to SSI beneficiaries will include amongst others training, reintegration
employment schemes (including public work schemes with an embedded training
component), participation in activation and job search assistance sessions, mentoring,
apprenticeships/traineeships. The aforementioned ALM measures will be progressively
offered under the open-framework delivery model as described in Section 4.1.
The authorities will agree with the institutions, the implementation of the next steps towards
further welfare reforms and specifically as prior actions:
i. with the view to apply a new disability assessment to all contributory disability and
welfare benefits (including under Law 4387/2016) by end-2018, on the basis of the
results from the on-going pilot programme, adopt legislation to extend gradually to
the entire country the new business processes for disability welfare benefits and to
expand the pilot testing of the new functional disability assessment;
ii. commence the implementation of the reform of the system of transport subsidies,
following the introduction of the electronic ticket reform by transportation
companies, starting from the city of Athens;
iii. adopt new legislation to specify the design of a means-tested housing benefit,
developed with advice from the World Bank, to be rolled out as part of the growth-
With regards to institutional welfare reforms, the authorities have:
i. implemented the National Mechanism for the Coordination, Monitoring and
Evaluation of social inclusion and social cohesion policies, which is fully operational
since February 2018;
ii. established in February 2018 a benefits agency (OPEKA) as a single payment
authority for all welfare benefits.
3. Safeguarding financial stability
All necessary policy actions will be taken to safeguard financial stability and strengthen the
viability of the banking system. No unilateral fiscal or other policy actions will be taken by the
authorities, which would undermine the liquidity, solvency or future viability of the banks. All
measures, legislative or otherwise, taken during the programme period that may have an
impact on banks' operations (i.e. solvency, liquidity, asset quality etc.) should be taken in
close consultation with the institutions.
The authorities will proceed with actions in a timely manner included in the comprehensive
strategy for the financial system related to reinforcing the banking sector by (i) normalising
liquidity and payment conditions and strengthening capital, (ii) addressing NPLs and (iii)
enhancing governance of the financial institutions.
3.1 Preserving liquidity and capital in the banking system
The authorities are committed to preserving sufficient liquidity in the banking system in
compliance with Eurosystem rules and to achieving a sustainable bank funding model for
the medium term. In this context, banks are required to submit quarterly funding plans to the
Bank of Greece so as to ensure continuous monitoring and assessment of their liquidity
The impact of the capital controls will be monitored with full information sharing with the
institutions. The authorities are committed to the implementation of the published roadmap
aiming to ultimately abolish capital controls consistent with the milestones. They will
manage, in timely consultation with the institutions, the process for implementing the
relaxation steps, taking into account liquidity conditions of the banking system and aiming to
minimise the macroeconomic impact of the controls. The Bank of Greece will send quarterly
to the institutions a standardised report on agreed key statistics related to capital controls
and liquidity, as well as its assessment and proposals for actions. The banks should keep
adequate cash buffers to facilitate the smooth implementation of the relaxation of capital
Taking into account regulatory requirements, including the latest Supervisory Review and
Evaluation Process (SREP) decision by the Bank of Greece, any potential capital shortfalls
in the cooperative banks will be addressed by June 2018.
3.2 Resolution of Non-Performing Loans (NPLs)
3.2.1 Enable an active NPL secondary market
The authorities will continue to take any necessary actions to enhance the functioning of a
dynamic NPLs' secondary market as a prior action (see TMU section xx).
3.2.2 Monitoring the banks' non performing exposure
The Bank of Greece, in cooperation with the ECB-SSM, will make every effort to ensure that
the NPE targets remain both realistic and ambitious and that banks' NPE strategies are
adequately designed and executed to reach the targets. The Bank of Greece will assess and
analyse banks' performance in achieving targets on an ongoing basis. The Bank of Greece
will publish quarterly an aggregated summary report on the developments with regard to
banks' NPE strategies and targets. Furthermore, the Bank of Greece will, on a quarterly
basis, present to the institutions a report, which includes a) detailed analyses on the
developments of the targets and KPIs, b) the reasons for missed targets and
underperformance, and c) recommendations to remedy the problems' drivers.
3.2.3 Debt restructuring and insolvency procedures
Out-of-Court Debt Workout (OCW)
In order to improve the application of the OCW framework, the authorities, on the basis of
the assessment of administrative and technical impediments to filing a complete application
and reaching an agreement between debtors and borrowers, will address these
impediments as a prior action, including through necessary legal amendments (see TMU
The authorities will by June 2018 appoint the new support staff for the trial of household
insolvency cases selected through the ASEP competition launched on March 2017, in order
to reduce the backlog of pending applications under law 3869/2010.
As a prior action, the authorities will amend the household insolvency law and take
additional actions to address the identified shortcomings as specified in the Technical
Memorandum of Understanding (Section xx), most notably by putting in place an appropriate
mechanism for filtering out non-admissible petitions and for taking all necessary actions to
significantly shorten the time span between the filing of the petition and the issuance of the
court decision as well as eliminating the backlog of cases.
Starting from April 2017, the Ministry of Justice has been providing, on a quarterly basis,
detailed information to the institutions on the backlog and processing of cases related to Law
3869/2010. The Ministry of Finance and the Secretariate of Private Debt will, on a quarterly
basis, provide information to the institutions on the take-up of state subsidies related to Law
3.3 Governance of the HFSF and the banks
As a prior action, the authorities will take all necessary actions to ensure that any future
ordinary shareholdings of the central administration (State) in credit institutions will be
transferred ipso jure to the HFSF.
As a prior action, the current mandate of the HFSF shall be extended until end-2022. The
independence of the HFSF will be fully respected, its governance reinforced and it shall
operate under commercial terms and without any political or other interference.
The independence of the management, decision-making and commercial operations of
banks will be fully respected and the banks will continue to operate strictly in accordance
with market principles. Any potential replacement of board members and senior
management of the banks will be carried out without any political or other interference.
Appointments will be made in line with best international practice.
The HFSF will continue to make every reasonable effort to ensure the compliance of all four
systemic banks' board members with the eligibility criteria of the HFSF law. The authorities
will also ensure that potential future Greek State representatives will meet these eligibility
Following the review and reconstitution of the banks' boards, the HFSF will make every
effort through its representative on the boards of the banks, on the basis of the Relationship
Framework Agreements (RFAs) and as an active shareholder, to ensure that the boards
function effectively in overseeing the performance of management. The HFSF as
shareholder and also on the basis of the RFAs should assess regularly, using if needed
external expertise, the banks' overall governance framework and the performance of the
banks’ Boards of Directors and recommend, if needed, changes. The HFSF will make every
reasonable effort to ensure that the banks’ Boards of Directors assess regularly, using if
needed external expertise, the effectiveness of Banks’ middle and senior management.
4. Structural policies to enhance competitiveness and growth
4.1 Labour market and human capital
In recent years, major changes have been made to Greek labour market institutions and
wage bargaining systems to make the labour market more flexible. The Greek authorities
are committed to achieve EU best practice across labour market institutions and to foster
constructive dialogue amongst social partners. The approach not only needs to balance
flexibility and fairness for employees and employers, but also needs to consider the very
high level of unemployment and the need to pursue sustainable and inclusive growth and
Review of labour market institutions. Following up on the labour market review undertaken
in the context of the second review, the authorities will implement the following measures:
i. With a view to promote and monitor the representativeness of sectoral collective
agreements, the government, after consultation with the social partners and in
agreement with the institutions, will issue a circular specifying the administrative
procedure to assess representativeness at sectoral level (prior action).
ii. The authorities have delivered a report early May 2018 with an independent
legal opinion on the role of arbitration in collective bargaining. As a prior action,
the authorities, taking account of the independent legal report and the outcome
of the consultations with the social partners, will adopt legislation to :
a. reintroduce the discretion of the mediator to submit a proposal to allow
parties to resume bilateral negotiations;
b. allow the unilateral recourse to arbitration only for the party that has
accepted a mediation proposal while the other refused it, or in case that the
other party had refused to enter in the mediation procedure;
c. extend the duration of the term of the OMED Board members;
d. review the list of criteria to be taken into account in the arbitration decision
to add the purchasing power of wages.
In addition, the authorities will take appropriate measures in conjunction with OMED to
ensure the expertise of mediators and arbitrators, by improving the selection and evaluation
Simplification of labour legislation. Existing labour laws will be streamlined and rationalised
through the codification into a Labour Law Code and a Code of Labour Regulatory
Provisions. In line with the dedicated technical support project which was launched in June
2017, the first draft of the Labour Law Code will be delivered by May 2018.
Undeclared work. The authorities in cooperation with the social partners will continue the
implementation of the Action Plan for fighting undeclared work. In particular:
i. the existing system of fines for undeclared work will be revised in May2018,
providing sufficient incentives for compliance, promoting the regularisation of
workers found undeclared and discouraging fraudulent behaviour (repeated
offences in particular);
ii. as a prior action, the automatic exchange of information between the
databases of the Ministry of Labour, the Ministry of Finance, SEPE, IAPR,
OAED, IKA (EFKA) and the Greek police will be completed.
Vocational education and training (VET). As part of the 3rd review, the authorities have
launched pilot tenders for a series of major business community-led partnerships for VET
involving sectoral and local employer representative bodies and social partners, targeting a
total of 4,000 apprenticeship places between 2017-18 and 2018-19. In order to reach the
desired targets, the Ministry of Labour with the support of the Public Employment Service
(OAED), the Ministry of Education and relevant stakeholders will have made fully operational
these major VET partnerships by May 2018 (implementation report to be provided). The
partnerships will inter alia provide outreach to companies and find apprenticeship places,
provide training and mentoring services, and verify, foster and enhance the quality and
effectiveness of apprenticeships. As part of the 3rd review, a cohesive and inclusive
governance structure for VET has been put in place (JMD). In addition, local apprenticeship
coordination committees (OYM) will be activated in the KPAs of OAED taking on board the
role of the newly introduced employer counsellors in OAED and extending their composition
to include representatives of local employer bodies by May 2018. By May 2018 a technical
assistance contract will be signed with SRSS to prepare an integrated plan for Human
Capital development of the Labour Force addressing economic growth and supported by the
Capacity building. The need has been identified to strengthen over the medium term the
institutional capacity in the field of labour administration (encompassing the Ministry of
Labour as well as all responsible implementing bodies and agencies). The on-going
exercise of upgrading and reinforcing the public employment service (OAED) will ensure
that by May 2018: (i) the role of employer counsellors is fully activated in all local offices
(KPAs) and the counsellors play a proactive role in engaging employers; (ii) quality
employment counselling is provided to jobseekers of priority groups through regular pre-
scheduled appointments with employment counsellors; (iii) along with the roll-out of the new
profiling and segmentation methodology, individual action plans are upgraded to offer tailor-
made activation paths.
Active labour market policies. The Ministry of Labour will engage in further improving the
design, impact and efficiency of the active labour market programmes (ALMPs), in line with
the adopted ALMP strategy. The implementation of the strategy encompasses the following
a. the application of the reformed mutual obligations, adopted in April 2018;
b. a new framework of quality specifications for ALMP training providers, to be finalised
in cooperation with the Ministry of Education by May 2018;
c. a blueprint, to be drafted by June 2018, for establishing an evaluation and monitoring
system to draw lessons and inform the design of future ALMPs;
d. the phased introduction of a new delivery model for ALMPs, starting with the launch
of a pilot project as a prior action. The new delivery model for ALMPs will
encompass open framework programmes to ensure the continuous availability of a
core menu of actions and services and the enhanced role of employment counsellors
in referring the jobseekers to ALMPs based on individual profiling.
e. a reform to further upgrade the design of ALMPs, in line with technical support
provided by the World Bank.
Education. Greece will further modernize its education system at all levels to substantially
improve educational outcomes while safeguarding equity. The final report of the OECD
review of the Greek educational system was published by the OECD in April 2018. The
authorities will address the recommendations of the Report through a concrete action plan to
be adopted with technical support by July 2018.
In agreement with the institutions, the authorities will, as a prior action: (i) adopt legislative
measures on future appointments and evaluation of head teachers and senior ministry of
education staff to ensure a depoliticised, transparent and meritocratic process including the
involvement of ASEP in relevant committees and upgrade their role within the school units
and specifying their career prospects (ii) pass a law on upgrading the bodies responsible for
evaluations and (iii) pass a law on the evaluation of senior education staff, school self-
evaluation and rational use of resources. By May 2018 they will adopt a strategy on initial
and continuous teacher training in pre-primary, primary and secondary education; the
authorities will agree with the institutions the fiscal aspects of changes in the organisation of
secondary and higher education and will safeguard the revenues of HEI coming from
overheads, fees for graduate education, services to third parties and exploitation of
The framework for dismissals legislated in the Private Education Act Art. 56 of Law
4472/2017 has been assessed in April 2018. Any amendments deemed necessary will be
taken up in consultation the institutions and legislated by May 2018 and put into effect for the
school year 2018-19.
4.2 Product markets and business environment
More open markets are essential to create economic opportunities and improve social
fairness, by curtailing rent-seeking and monopolistic behaviour, which has translated into
higher prices and lower living standards. In this context, the alleviation of unjustified and
disproportionate restrictions in the access to market and the conduct of professions and
economic activities shall adhere to the principles of proportionality, justification of any
restrictions and non-discrimination. In line with their growth strategy, the authorities will
intensify their efforts to bring key initiatives and reform proposals to fruition as well as enrich
the agenda with further ambitious reforms that will support the country’s return to sustainable
growth, attract investments and create jobs.
The authorities will adopt the following measures:
Competition: Toolkit I recommendations: On building materials, the authorities will, as prior
action, enter into a contract with the Standardisation Body in order to start by June 2018
the harmonisation of the 372 technical specifications according to its categorisation (Project
Investment licensing. The authorities have agreed with the institutions to implement as prior
actions: (i) horizontal reforms on specific sectors (see TMU Section xx); (ii) the launch of the
tender to renew the licensing ICT system for notifications, approvals and inspections; (iii) the
second phase of installation licensing. A mapping of the status of investment licensing reform
in the Greek economy will be completed as a prior action, including sectors included in law
4442/2016 as well as the rest of the economy. Following the time-bound action plan for the
promotion of effective and coordinated ex-post controls and inspections for businesses,
implementation of pilot projects is progressing in the areas of slaughterhouses, hygene
inspections for food and service businesses, and fire safety inspections. For
slaughterhouses, the training activities will be finalised and pilot inspections will be launched
as a prior action.
On competition, investment licensing and administrative burden: as prior actions, the
i. address the pending recommendations no. 4 and 17 of the ex-post assessment on
business parks through the publication of a KYSOIP decision and the issuance of a
ii. address the recommendations of the ex-post assessment on book prices; and
iii. address the recommendations of the ex-post assessment on tourism;
(see TMU section xx).
To modernize company law, the government
a) has prepared a review on changes needed to bring Law 3190/1955 in line with best
practices. Based on the recommendations of the review, the government will, as a
prior action, amend Law 3190/1955;
b) has prepared an assessment in cooperation with the European Commission and
involving the consultation of key stakeholders. Based on the recommendations of the
review, the government will, as a prior action, submit a progress report, along with
draft provisions on mergers and acquisitions, with a view to adopting legislation by
c) has prepared a review on changes needed to bring Law 2190/1920 in line with best
practices. Based on the recommendations of the review, the government will, as a
prior action amend Law 2190/1920.
On regulated professions, the authorities will, following agreement with the institutions, as a
prior action, place under public consultation the draft law relating to the requirements and
procedure for the establishment of private clinics with a view to adopting it by mid-July 2018.
On one-day clinics, the authorities will as a prior action amend the legal framework in
agreement with the institutions in order to reduce restrictions (including on different medical
specialties and on mixed operations) to the establishment and operation of one-day clinics,
taking into consideration EU best practices.
On export promotion, the authorities with the participation of public and private
stakeholders, will proceed with the timely implementation of the agreed export promotion
action plan, whose implementation is monitored on a quarterly basis.
On land use, the authorities have continued with the adpotion of secondary legislation related
to the implementation of law 4447/2016. They have adopted a Ministerial Decision with the
technical specifications for special spatial plans and town plans in January 2018. They will
further adopt a Ministerial Decision with technical specifications for regional spatial plans by
In addition to the forest maps covering 35.72% of the country which were uploaded in 2017
forest maps covering an additional 9% of the country's surface completed by the Hellenic
Cadastre or forestry services and endorsed by the forestry services have been uploaded for
public consultation. Another 8% is pending for upload until September 2018, while the
drafting of forest maps for the rest of the country will take place in the period summer 2018 to
summer 2019 (14 months). To date date, 32.2% of the country's surface has ratified and
definitive maps. In areas where objections were raised during 2107, the ratification will follow
the prescribed process, and will be completed at the latest by November 2018 following the
relevant legislative provisions.
On cadastre, the authorities will, as a prior action, produce and agree with the institutions a
roadmap and timetable with key steps for a) the completion of the cadastral mapping and b)
the completion and ratification of the forest maps, with a final deadline 31/06/2021 for both.
On agriculture, the rural development strategy will be formally adopted by the government
by May 2018. In accordance with the strategy, by June 2018, the authorities will make
proposals to (a) introduce incentives to boost the organisation of farmers into producer
groups, and (b) in support of young farmers, aged up to 40 years of age.
With a view to limiting the risk of financial corrections relating to direct aid, the government
a) Renew by 50% the ortho-photos by May 2018, with the most recent imagery, digitise
and update the corresponding reference parcel boundaries and maximum eligible
area in accordance with the requirements of the European Commission and
implement an appropriate and continuous update of the system thereafter.
b) as a prior action, ensure that the Greek Payment Authority of Common Agricultural
Policy Aid Schemes (OPEKEPE) is staffed with the necessary permanent staff in
specific fields (technicians, agronomists and surveyors) trained in Geographic
Information System and photo-interpretation in order to perform the regular update of
the Land Parcel Information System (LPIS) and assure the correct yearly execution
of the LPIS Quality Assessment, including the definition of appropriate remedial
action when so required.
On structural funds, the Ministerial Decision associated with legislation setting up a registry
of experts to ensure the supervision of co-financed projects will be agreed with the
institutions and adopted as a prior action.
Significant municipal engineering projects of a value in excess of 500,000 EUR (water
supply, sewerage & waste water treatment, and solid waste management) in municipalities
with up to 10,000 inhabitants that are co-financed with EU funds will be supported with a
Technical Advisor encompassed in the design contract according to law 4412/2016
(especially articles 136, 144) for new projects or through the register of experts of article
28.8 of law 4314/2014 for on-going projects.
The selection and apointment of the Director General and Director positions for all ESPA
structures will be completed by July 2018.The authorities will also implement the new rules
for evaluation and mobility of staff.
The authorities have agreed with the European Commission as part of the 3rd review a list of
15 to 20 large, emblematic projects for the period 2014-2020 including timelines from
approval to completion. The inter-ministerial committee on major projects will convene after
a proposal of the Alternate Minister of Economy and Development responsible for ESIF to
its Chair to consider the progress made with these 2014-2020 projects and to resolve any
blockages as may occur. The General Secretariat for Public Investments and Structural
Funds will send regular reports to the Commission.
The authorities have committed that the Information System for State Aid (PSKE): (i)
remains the sole and unique management tool for co-financed state aid operations under all
ESIF programmes, (ii) includes on a continuous basis all relevant data to verify the legality
and regularity of all such co-financed state aid operations, (iii) provides all necessary means
(staffing, organisation, processes) in order to achieve a smooth and fully integrated
management - within the PSKE system - of all incoming requests for state aid operations
emanating from managing authorities of ESIF programmes, and (iv) will be technically
upgraded in order to increase speed and capacity.
On technical support, in order to ensure an effective reform implementation the authorities
will continue the support as appropriate in the critical areas of a) the investment licensing
reform with support of the World Bank; b) education; c) export promotion; d) trade
facilitation, e) competition, f) environment including, the completion of the national cadastre
and the systematisation and digitasation of environmental legislation. The authorities will
use technical support in other areas as needed, including through Commission services,
Member State experts, international organisations, and independent consultants. This
includes areas such as, agriculture and fisheries and structural funds.
4.3 Regulated Network Industries (Energy, Water, Transport)
The Greek energy markets need wide-ranging and structural reforms to bring them in line
with EU legislation and policies, make them more modern and competitive, reduce
monopolistic rents and inefficiencies, promote innovation, favour a wider adoption of
renewable energy and gas, and ensure the transfer of benefits of all these changes to
i. Structural measures relating to lignite-fired generation capacity.
With a view to complying with recent judgments of the European Courts in relation to
Commission decisions C(2008) 824, C(2009) 6244 and C(2018) 2104 (adopted on 17 April
2018) on lignite, the authorities have agreed to implement structural measures relating to
lignite-fired generation capacity.
The following principles, which have been endorsed by KYSOIP, apply to the structural
measures relating to lignite-fired generation capacity:
a. The measures shall consist of the divestment of the Public Power Corporation’s
(PPC) lignite-fired generation capacity to existing or new alternative suppliers
and other investors.
b. PPC shall not have any participation or link, including preferential supply of
electricity, with any divested entity. In line with the European Commission’s
practice as set out in the merger remedies notice, the purchaser(s):
• shall be independent of and unconnected to PPC and its affiliated
• shall have the financial resources, proven expertise and incentive to
maintain and develop the divested generation capacity as a viable and
active competitive force in competition with PPC and other competitors;
• shall neither be likely to create, in light of the information available,
prima facie competition concerns nor give rise to a risk that the
implementation of the structural measures will be delayed.
c. The divestment shall represent around 40% of PPC’s lignite-fired generation
capacity, in accordance with the Commission Decision (C(2018) 2104) adopted
on 17 April 2018 and the law "Structural measures on access to lignite and the
further opening of the wholesale electricity market and other provisions" (FEK A
75/2018, Law 4533/2018) that was passed by the Hellenic Parliament on 25
April 2018. The exact percentage will be defined with technical discussions with
Commission, according to the aforementioned judgments and decisions on
lignite. The divestment shall have equivalent economic characteristics to PPC's
lignite-fired generation capacity, in particular in terms of efficiency and lifetime,
reflecting commissioning and decommissioning of lignite-fired generation
d. The measures will be designed and implemented following the applicable
competition procedural rules.
Commission Decision C(2018) 2104 and Law 4533/2018 confirm the divestment through two
spin-off businesses of (1) the lignite-fired plant of Meliti 1 and option for a new Meliti 2 plant;
and (2) units 3 and 4 of Megalopoli and of all related assets and resources as described in
the Schedule of the Commitments (hereafter the Divestment Business(es)) as going
concern(s) to one or more purchaser(s), according to the terms of sale, divestment procedure
and timeframe approved by the Commission. The adopted law by the Parliament also
includes specific rules as concerns the employees at the Divestment Business(es).
Regarding the lignite-fired power plants which are not part of the Divestment Business(es) as
defined in the Commitments, it is upon PPC to decide on investments and consider life-time
Following the adoption of Law 4533/2018, the Hellenic Republic will, as a prior action, fully
and correctly implement all the necessary steps for the effective divestment to the
purchaser(s) of the Divestment Business(es) in accordance with the Commission Decision
(C(2018) 2104), including the adoption of all the necessary legislative, regulatory and
corporate measures and/or resolutions, the carve-out and spin-off of the Divestment
Business(es), as well as the official launch of the international open tender procedure run by
PPC, that will be based on a fair valuation and will ensure the legitimate financial interests
of the company and its shareholders. The Divestment will effectively be completed by end-
ii. NOME auctions and possible additional structural measures
NOME auctions will be continued, with the quantities to be auctioned adjusted following the
monitoring mechanism, so that, in combination with the adopted structural measures, they
ensure the agreed market share reduction targets for PPC, as laid down in the MoU. With a
view to continuing reducing, progressively, PPC’s retail and wholesale market share below
50% in a sustainable and permanent way, promoting competition in the electricity market and
removing distortions, RAE has decided, in accordance with the provisions of the KYSOIP
NOME Action Plan, (i) the overall ex-ante quantities to be auctioned for 2018, i.e. 19% (13%
multiplied by the total volume of electricity in the interconnected system in 2017 plus 6%
rollover of the 2016 total volume in the interconnected system, with the physical deliveries of
the rollover starting in December of the year), unless promptly adjusted by the monitoring
mechanism in the two auctions following the ascertainment of a deviation, (ii) the number of
auctions which will need to be launched in 2018 in order to achieve the target and (iii) the
quantities per auction.
In June 2018, the authorities will, as a prior action, revise the reserve price of the auctions
based on RAE’s proposal, to incorporate (i) CO2 prices as specified in law 4389/2016, as
amended by law 4393/2016, and (ii) updated data for PPC production costs, in line with the
methodology deriving the initial Reserve Price.
Following the first joint assessment with the institutions, taking into account the lignite
structural measures and the indicative plan for the introduction of the forward market under
the Target Model, the authorities will, as a prior action, amend the KYSOIP action plan and
legislation related to NOME. In particular:
a. Once the launch of the international tender and the spin-off of the lignite
divesture businesses takes place, additional quantities due to the adjustment
mechanism on the assessment of the interim targets of June 2018 will be
reduced by 50%. RAE will implement the modified monitoring mechanism,
such that the adjusted quantities will be equally spread over the two auctions
following the ascertainment of a deviation, which occurred in semester S;
b. Once the selection of preferred bidder(s) and the signature of the SPA with
the selected bidder(s) regarding the lignite divesture will be finalized, the
above adjustment mechanism will cease to be in effect;
c. Once the financial closure of the agreement(s) and the selected bidder(s) take
over the management of the respective plant(s) the overall NOME quantities
to be auctioned in 2019 will be 13% multiplied by the total volume of electricity
in the interconnected system in 2018;
d. When the new electricity markets are introduced under the Target Model, the
NOME regulated forward products characteristics will converge with the
characteristics of the new markets (forward, day-ahead and balancing), in
particular with respect to their financial settlement, physical delivery and
The authorities will undertake a new joint assessment by September 2019 with the
institutions in addition to the already existing semestrial impact assessment, inter alia taking27
• the introduction of the new markets under the Target Model, including the
• the completion of the structural measures relating to lignite-fired generation
• the effect of the NOME mechanism in the electricity market,
• the evolution of the retail market shares,
• the potential need for alternative policy and/or structural measures with the
overall objective of maximizing the benefit to consumers.
The first such joint assessment by the authorities and institutions has taken place regarding
the adjustment of the NOME mechanism due to the structural measures relating to lignite-
fired generation capacity. For the future planned joint assessments the authorities will
provide all relevant information for this assessment to the institutions (see TMU Section QQ);
LAGIE shall provide full and timely information on auction results, nominations, deliveries
and re-sales on the secondary market, as well as market shares per player, on a monthly
basis (see TMU Section PP).
iii. PPC financial situation.
PPC will implement the action plan to address arrears agreed as part of the second review
and report on its implementation. In particular, the authorities will (i) as a prior action,
finalise the electricity supply contract between the Hellenic Republic and PPC for public
entities as agreed in the 3rd review and clear all arrears of public sector entities covered by
this supply contract; and (ii) take all necessary action to ensure the smooth implementation of
the action plan and provide a detailed report on its implementation, including the report
submitted by the contracted consultant, on the basis of which further potential efforts
regarding private sector arrears can be specified. As a prior action the authorities will
introduce a legislative amendment in the Law 4067/2012 that will ensure that no fiscal issue
will arise for the years 2018, 2019 and 2020 from the review of the Social Residential Tariff
for electricity that is part of the PSO account (see TMU section xx).
The PSO level going forward will be adjusted as needed, such that no new deficit will be
accumulated on an annual basis, taking into account the interconnections entering into
operation in each year, which will be ensured by a monitoring and adjustment mechanism
that provides for the respective actions taken through secondary legislation in case of any
over or under performance of the PSO account. Any financing from the State budget will be
dependent on the available fiscal space for that year.
iv. RES account.
As a prior action, (i) the supplier surcharge will be reduced by the forecast annual surplus in
the RES account for 2018 (Step 1 – amendment adopted on 25 April 2018 by the Hellenic
Parliament, Article 143 of Law 4001/2011, included as Article 12 of FEK A 75/2018); (ii) the
supplier surcharge will be further reduced and equal (a) by 1 January 2019, 50% of the total
charge; and (b) further reduced by 1 January 2020, 30% of the total charge; and (c) will be
completely phased out by end of 2020; (iii) the CO2 permission rights (current revenue
stream of RES account) will be set at least at 65% for 2019 and 2020; (iv) any surplus of the
RES account, beyond the buffer, until full removal of the supplier surcharge will be allocated
to the reduction of the supplier surcharge; (v) commitment to maintain a buffer of EUR 70
million; and (vi) if a deficit arises of the RES account other revenue streams, including the
ETMEAR will need to be increased accordingly. Further, the authorities commit to maintain
the RES account in balance, for example through committing to notify to EC and introduce a
new RES revenue scheme that will become operational in 2021 and be fully compliant with
the Energy and Environmental Guidelines (EEAG). The reformed scheme and any additional
revenues to be applied as of January 2021 should ensure that RES account remains in
balance and viable on the way forward.
v. Capacity mechanism.
The authorities will, as a prior action, notify a new flexibility mechanism, replacing the
temporary one, which has expired in April 2017, in line with Energy and Environmental Aid
Guidelines. In particular, the flexibility mechanism should be based on a thorough adequacy
assessment including a reliability standard and it should be based on a competitive
allocation process. In order to achieve this, the authorities will also implement the
commitments agreed with the European Commission under the approval decision on the
temporary flexibility mechanism scheme (review of secondary reserve price cap, actual
hydro power availability, market-based methods for tertiary reserve). Subsequently, the
authorities will also notify, based on a thorough adequacy assessment including a reliability
standard, and implement a permanent capacity mechanism in line with the Energy and
Environmental Aid Guidelines, including a competitive allocation process and open to all
potential capacity providers.
vi. Gas market roadmap.
The authorities will, as a prior action, agree with the institutions on the overall corporate
restructuring and tender structure for DEPA assuming the successful completion of
transactions for the EPAs and in a way that will eliminate any horizontal or vertical conflict of
interest for the entity(ies) to be sold and, if/where applicable, propose specific and effective
mitigating measures. The agreement reached as concerns the overall tender structure of
DEPA will need to be consistent with the agreed privatisation commitments of HELPE.
vii. Gas release programme.
Quarterly auctions under the revised gas release programme as endorsed by decision of
HCC will take place according to schedule. The quantity auctioned for 2018 will amount to
17% of DEPA's yearly gas supply to customers. HCC and RAE will provide the institutions,
after every auction, with a report on its outcomes (see TMU Section RR).
viii. Renewable energy support.
In April 2018, the authorities issued the two Ministerial Decisions setting a new framework for
the support of renewable energies. The first auctions will take place in July 2018.
ix. Target model.
Following the entry into force of EU Regulation 2015/1222 establishing a guideline on
capacity allocation and congestion management (CACM)2 and EU Regulation 2017/2195
establishing a guideline on electricity balancing, Greece needs to take the necessary steps
2 Commission Regulation (EU) 2015/1222 of 24 July 2015 establishing a guideline on capacity allocation and congestion management.
for joining the day-ahead and intraday market coupling on its borders and establish the
balancing market (Target model). LAGIE (and Hellenic Energy Exchange (HENEX) as its
successor), acting as the nominated electricity market operator (NEMO) in accordance with
CACM and national legislation/decisions put in place in 2016, needs to have all required
codes and technical means in place to comply with the obligations of CACM or appoint
another third party to perform these tasks. Respective codes need to be drafted by LAGIE
(or HENEX) and approved by RAE. ADMIE will act as the operator of the balancing market
based on the balancing code to be drafted by ADMIE and approved by RAE. The authorities
will launch the Target Model, including the day-ahead, intraday, forward and balancing
markets by April 2019. To implement this, the authorities will, as prior action, (i) set up the
entity to be created as a successor of LAGIE (i.e. HENEX3
); (ii) ensure that HENEX and
IPTO will submit to the Regulator all market Rulebooks for day-ahead, intraday and
balancing markets, removing any bidding restrictions such as maximum and minimum
bidding and clearing prices without prejudice to the maximum and minimum technical limits
set in accordance with Article 41(1) and 54(1) of Regulation 2015/1222, in order to be fully
compliant with EU legislation at the time the Target Model will be launched in April 2019; (iii)
ensure that HENEX will complete the functional design specifications for the IT systems for
the day-ahead and intraday market; and (iv) undertake a joint assessment with the
institutions on the progress made regarding the corporate and technical aspects of the
project, and take the necessary actions in line with the agreed roadmap to ensure that the
Target Model is functioning will be launched by April 2019. The authorities will ensure that
the Rulebook for the forward market will be submitted by HENEX to the Regulator by August
2018. The authorities will ensure that functional IT systems is put into place for the day
ahead and intraday markets by December 2018 and for the forward and balancing market by
February 2019. The authorities will also ensure that all necessary licenses for the operation
of the markets will be obtained by the responsible legal entities by the time of approval of the
day-ahead, intraday and balancing market Rulebooks (September 2018).
x. Day-ahead market coupling
For day-ahead market coupling (Italy-Greece and Bulgaria-Greece), the authorities will
ensure that Greece is coupled with Italy and Bulgaria on the day-ahead timeframe at the
time of the go-live of the new day-ahead market in Greece; and utmost effort is made to
achieve intraday coupling with Italy and Bulgaria through continuous trading or auctions as
soon as possible and in accordance with CACM. The authorities will provide to the
institutions information about the progress as specified in the TMU (Section xx).
The authorities will make use of technical support, provided by the SRSS of the European
Commission, for implementing all energy market reforms.
3 In accordance with the omnibus law (FEK A 5/2018, Law 4512/2018, Article 96, 15th January 2018) the electricity
exchange should had been established by 15 April 2018.
A stable regulatory regime is key for allowing much needed investment in the water
networks and to protect consumers in terms of pricing policies.
As prior action,
i. the SSW, with technical support, will deliver an evaluation report on the existing
system of regular collection of information and on the progress towards the
development of the Full Information System. It will also finalise the assessment of
the business plans of the Athens Water Company (EYDAP) and the Thessaloniki
Water Company (EYATH);
ii. the authorities, with technical support, will launch: (ii.a) the strategic plan for SSW
for a six year period, from 2018 to 2023, with the aim to strengthen the governance,
the administrative capacity and the financial autonomy of the SSW within the
Ministry of Environment and Energy; (ii.b) an operational plan for the years of 2018-
2019 including specific actions, steps, timelines for the remainder of 2018 and for
2019, that will contribute to the implementation of the 6 year Strategic Plan; (ii.c) the
authorities will provide input to the Plans specifying the role, mission and
competences for the SSW in relation to other organisations in the water sector; (ii.d)
in the context of the preparation of the Strategic Plan, the authorities will ensure
access to information to SSW from the relevant ministries and local authorities on
water companies, in order for them to have a full picture of the sustainability and
needs of the water system. Inter alia, the required information set includes data on
water quality and data and projections on detailed administration costs and
revenues, physical assets and investments of water companies;
iii. the authorities will amend law 3199/2003 to further strengthening the inclusiveness,
transparency, and efficiency of the decision-making process in the water system by
reviewing the composition and functioning of the National Water Commission, the
National Water Committee and the Advisory Commission for Water;
iv. the new unit "Costing & Pricing of Water Services" of SSW will be operational.
Transport and logistics
The authorities will undertake reforms to increase the efficiency and viability of the urban
bus transportation in Thessaloniki (OASTH). By May 2018 the government, in agreement
with the institutions, will take action to ensure a maximum deficit before any state transfer
of EUR 40 mn per year for the remaining duration of the concession. In order to show
progress towards this objective, the authorities will provide a quarterly update on the
evolution of operational savings.
The authorities will ensure stronger governance, financial autonomy through distinct
budgeting and enhance the administrative capacity of the Regulatory Authority for
Passenger Transport (RAEM) (see section 5.4) taking into account Law 4199/2013.
The authorities have launched a general transport master plan for Greece covering all
transport modes (road, railways, maritime, air and multi-modal, including logistics aspects),
and appointed a steering committee and project team for the preparation and monitoring of
the master plan. The authorities will continue with the timely implemenation of the Transport
master plan; to this end the authorities will report to the institutions every two months on the
project implementation progress.
On logistics, the authorities have activated the logistics law by issuing the JMD of art. 8, par.
8 law 4302/2014 and adopted the logistics strategy with a time-bound action plan.As part of
the logistics action plan, the authorities will complete the modernisation of the legislative
framework affecting logistics.
In line with the logistics strategy and action plan, the authorities will ensure the operation and
maintenance of the Logistics centre (Freight Centre) on the 588 acres foreseen by the
Thriassio Complex Freight Centre, by signing a concession contract after the approval by the
Court of Auditors. The maintenance and operation of the other (1,600) acres of the Thriasio
Freight Complex will be secured through a PPP following another international tender
In view of the above, the following actions will have to be achieved: i) parliamentary
ratification of the concession contract for the 588 acres Logistics center by end of June 2018,
ii) completion of the options analysis for the PPP scheme for the operation and maintenance
of the other (1,600) acres of the Thriassio Freight Complex by end of May 2018, iii) decision
on PPP scheme for the operation and maintenance by June 2018 and iv) the tender
documents of the international tender for the PPP scheme on operation and maintenance will
be finalised by July 2018.
In support of this reform agenda on network industries, the authorities intend to use
technical support as needed, including on transport and logistics and on the strengthening
of regulators (for the latter, see section 5.4).
Privatisation can help to make the economy more efficient and contribute to reducing public
debt. The government and the Hellenic Republic Asset Development Fund (TAIPED) have
taken important steps in advancing the privatisation programme forward and are committed
to proceed with the ambitious, ongoing privatisation programme of TAIPED.
Implementation of the agreed TAIPED Asset Development Programme (by means of direct
sale, concessions, securitisations, or other forms of monetisation) regarding all its core
assets is key to stimulate private investment, increase efficiency, and provide financing to
To maintain investor interest in key tenders, the Hellenic Republic commits to proceed with
the on-going privatisation programme. The Board of Directors of the TAIPED will approve its
updated Asset Development Plan (ADP), which includes for privatisation assets under
TAIPED as of April 2018. It will be subsequently endorsed by KYSOIP. HCAP in mid-2019
will review the mandate of TAIPED.
The implementation of this programme aims to generate further annual proceeds (excluding
bank shares) for 2018 and 2019 of EUR 2.0 bn and EUR 1.0 bn, respectively, on top of
EUR 0.3 bn, EUR 0.5 bn and EUR 1.4 bn collected in 2015, 2016 and 2017, respectively.
The government commits to facilitate the privatization process and complete all needed
government actions to allow tenders to be successfully executed. In this respect, it will
complete all actions needed as agreed on a quarterly basis between TAIPED, the
institutions and the government. The list of Government Pending Actions is attached to this
Memorandum as an Annex and constitutes an integral part of this agreement.
As prior actions:
i. The Asset Development Plan (ADP) is attached to this Memorandum as Annex and
constitutes an integral part of this agreement. The ADP will be updated on a semi-
annual basis and approved by TAIPED. KYSOIP will endorse the updated plan;
ii. The authorities will conclude the remaining Government Pending Actions identified
by the institutions and TAIPED and which are due by May 2018 and that are not
listed in this section (continuous action).
iii. On DESFA, the nomination of the preferred bidder has been completed on 19 April
2018. The Share Purchase Agreement and Shareholders’ Agreement will be signed
(subject to approval by the Court of Audit), with a view to achieve a financial closing
by the end of 2018.
iv. On Egnatia,
(a) By 22 May, the Minister for Infrastructure and Transport and the Minister for
Finance in agreement with the institutions and TAIPED will revise Joint
Ministerial Decision (JMD) 6686/2014 (as in force) to provide for the
disconnection/exemption of the Egnatia motorway concession from the
ongoing e-tolls tendering process of the Ministry of Infrastructure and
Transport. The Concession Agreement for Egnatia will provide that the
EGNATIA concessionaire will be:
1. free to select, design/procure, finance, install, and operate a distance-
based e-toll system (GNSS technology for heavy vehicles over 3.5 tons,
ANPR technology for all other vehicle) or decide to join the system
procured by the Ministry of Infrastructure and Transport for the other
motorways, if applicable;
2. allowed to design and operate the above system as a barrier controlled
3. exclusively responsible for the management and control of Egnatia toll
4. required to ensure that the tolls system implemented in Egnatia is
compliant with applicable EU law; and
5. required to ensure that the tolls system implemented in Egnatia is
interoperable and compatible with the electronic tolls system of the
Ministry of Infrastructure, if applicable, and those of other EU member
The revised JMD should also guarantee the above under 1-5.
The JMD will be accompanied by a relevant amendment of the tender
documents of the ongoing e-tolls tendering procedure of the Ministry of
Infrastructure to implement the disconnection of the two projects by 15 June
(b) Following the adoption of the revised JMD and the amendment of the tender
documents, TAIPED will release the draft Concession Agreement to the tender
participants by 15 June; in this regard, by 30 May, the Ministry of Infrastructure
and Transport will provide to TAIPED all necessary technical specifications to
allow TAIPED prepare the draft Concession Agreement.
(c) By 22 May, the Ministry of Infrastructure and Transport, in cooperation and in
agreement with TAIPED, will submit its response to the clarification questions
sent by DG MOVE regarding the new tolling policy that will be implemented in
the Egnatia motorway and its vertical axes.
(d) By 30 May, the Ministers of Infrastructure and Transport and Finance will issue
a JMD providing for the new toll pricing policy for the Egnatia motorway and its
vertical axes. The JMD will provide for the implementation of the toll pricing
policy which was approved by the Board of TAIPED and notified by the Greek
authorities to DG MOVE for clearance. The JMD will stipulate that this new
tolling policy will enter into force in Egnatia motorway on 1/1/2019 subject to
clearance by DG MOVE. If DG MOVE's decision clears a different pricing
policy, the JMD and the draft Concession Agreement will be revised
accordingly. The Ministry of Transport and Infrastructure will issue a new MD
(or amend the existing MD) providing that the applicable exemptions granted
to residents and businesses in several prefectures and municipalities adjacent
to the Egnatia motorway from payment of tolls will apply until 31/12/2018 and
no further extension will be given.
(e) By 22 May, Egnatia S.A. will sign the contract for the construction of the
Asprovalta toll station with the preferred bidder and instruct the constructor to
commence its construction immediately. Within a week upon completion of the
construction of the toll stations of Asprovalta and Thessaloniki
(Oreokastro), the Minister for Infrastructure and Transport and the Minister of
Finance will adopt, in agreement with TAIPED, a JMD by virtue of which (a)
the abovementioned toll stations will be put in operation and (b) the toll rates to
be applied respectively shall be determined based on the current toll pricing
policy applied to the already existing Egnatia toll stations.
(f) By 22 May, Egnatia SA will immediately instruct the contractor of the two, new
Operations & Maintenance Contracts (O&M) to commence construction of the
Frontal Toll Stations of Strymoniko and Kavala.
(g) Upon the approval of the modification of environmental terms permits by the
competent Ministry for Energy & Environment (no later than mid-June 2018),
Egnatia SA will immediately trigger and put in effect the options of the two
O&M contracts for the immediate commencement of construction of all
remaining Frontal Toll Stations and of all Lateral Toll Stations (except four, for
which the commencement of the construction will follow by the end of July)
envisaged in JMD 6686/29.5.2017 (no later than end-June 2018).
(h) By 30 May, the Inter-ministerial Committee of Assets Restructurings and
Privatizations will issue a decision (text to be agreed with TAIPED), in
accordance with article 2 par. 5 of Law 3986/2011, pursuant to which TAIPED
shall be entitled to include in the scope of the services concession agreement
of the Egnatia tender the obligation of the concessionaire to finance, study
and perform all the necessary works pertaining to the upgrade of motorway
standards of (a) the Halastra – Polykastro section of the Halastra – Evzoni
vertical road axis and (b) the Christos – Ambela section of the Thessaloniki –
Serres – Promachonas vertical road axis, such sections measuring
approximately 54 km in total. Egnatia S.A. will be transferred to the Ministry of
Infrastructure and Transport following the date of commencement of the
v. On Hellenikon, the authorities will complete (a) the relocation of the existing users
(actions included in the GPAs); (b) the enactment of a law for the establishment of
the management authority of open and public areas and facilities and (c) implement
the revised timetable agreed in the working group on the fulfilment of all Conditions
Precedent relating to the adoption of the necessary ministerial decisions and the
award of the casino licence (actions included in the GPAs) to ensure financial
closing by December 2018.
vi. Other projects:
(a) The authorities have launched the tender for the sale of 5% of OTE and for
the joint sale (by PANEUROPEAN and TAIPED) of at least 50.1% of HELPE. The
unsold stake of TAIPED (15.5%) will be transferred to HCAP. They will launch the
tender for the sale of 30% of AIA (subject to clearance of the extension of the
concession agreement by DG COMP).
(b) On DEPA: the updated ADP will provide for the sale of 65 percent of DEPA
or another form of transaction of equivalent effect. To this end, the ADP will provide
for the agreed privatization transaction structure between the Greek authorities and
the institutions. The tender will be launched once the assessment of potential
obstacles to competition, as a result of the exit of any of the current shareholders of
the EPAs, will be concluded.
(c) On PPC: the launch of the tender for the sale or other form of monetization
of 17% of PPC provided it generates at least equivalent financial benefits to the
Hellenic Republic compared to the sale will follow at a subsequent stage.
vii. On Athens International Airport the extension of the concession agreement will
be ratified in Parliament (subject to the prior issuance of the required decisions by
the relevant European authorities).
viii. On OLTH the concession agreement has been ratified in Parliament.
ix. The Board of Directors of TAIPED, with the help of external advisors, will (a) review
the corporate governance structure of DEPA and Egnatia S.A. and assess the
Board of Directors of the specific companies and (b) replace executive and non-
executive members if needed.
Hellenic Corporation of Assets and Participations
The Hellenic Corporation of Assets and Participations (HCAP), which will have in its
possession valuable Greek assets, was established through law 4389/2016 in line with the
statement of the Euro Summit of 12 July 2015. The overarching objective of the Fund is to
manage valuable Greek assets; and to protect, create and ultimately maximize their value
which it will monetize through privatisations and other means. The Fund is established in
Greece and is managed by its Board of Directors, overseen by a Supervisory Board; two
members of the Supervisory Board have been nominated jointly by the European
Commission and the ESM and appointed by the Minister of Finance, together with three
members nominated by the Minister. The Fund is expected to fulfil its objective by adhering
to international best practices and OECD guidelines in terms of governance, oversight and
transparency of reporting standards, and compliance, as well as best practices for socially
and environmentally sustainable business and consultation with stakeholders. The Fund
and its assets will be under professional management at arm's length from the State. The
monetisation of the assets will be one source to make repayments of the new loan of ESM,
in line with the Euro Summit Statement.
As prior actions:
i. The General Assembly shall adopt the chapter of the company's internal
regulation on the investment policy, following agreement with the institutions on
the specific content of this document;
ii. Submission of business plans to HCAP by the SOEs transferred to HCAP, in
which HCAP is the majority shareholder;
iii. The Board of Directors of HCAP will review the Boards of ELTA, OASA and
replace executive and non-executive members if needed. For the listed
companies, the review and replacement of executive and non-executive
members if needed, will be in full compliance with the regulatory framework in
iv. The additional non-executive members of the Board of Directors of HCAP have
v. Based on the process agreed among the authorities and the institutions,
identification of the real estate assets to be transferred, and completion of the
transfer of the real estate assets;
vi. SOEs transfer to HCAP: (i) Amendment of the articles of association of the
SOEs transferred to HCAP, in which HCAP has the majority shareholding, so
that there is compliance with the codified company law 2190/1920. (ii) Due to
implementation difficulties related to the carve-out of GAIAOSE assets and
rights from the company as set out in the TMU of July 2017, the HCAP law will
be amended for the transfer of the shares of GAIAOSE to HCAP. Policy goals
relevant to the company will be addressed in accordance with the HCAP
coordination mechanism. The transfer will be effective from 1 July 2018. (iii)
With a view to transferring OAKA to HCAP by the end of 2018, and as a prior
action, the authorities shall provide a list of actions needed to achieve this
transfer, and a timetable for their completion. The list shall include the
determination of the amounts needed to maintain or overhaul OAKA facilities as
applicable, provision for these amounts by the State in compliance with any
applicable legal constraints, conversion of OAKA to a sufficiently capitalised
societe anonyme, and transfer to HCAP. As a further prior action, the
authorities shall establish a committee or working group, including
representatives of HCAP, to oversee implementation of those actions.
The Ministry of Finance, using the technical support of HCAP or other experts as it judges
appropriate, will review on a regular basis the portfolio of real estate assets belonging to the
state as well the portfolio of SOEs (including newly set up SOEs). Within this framework, the
real estate assets of OSE will be reviewed following their transfer to the Greek State. The
State shall transfer to HCAP those complying with the purposes of HCAP.
5. A modern State and Public Administration
5.1. Public administration
The authorities will contiue to modernise and significantly strengthen the Greek
administration, and to put in place a programme, in close collaboration with the European
Commission, for capacity-building and de-politicizing the Greek administration at all levels.
Significant reforms have already been adopted in the context of the ESM Programme, and
now attention is turned to their full implementation.
In this context:
(i) Mobility. The authorities are already implementing the new mobility scheme. The
appointing authorities of the receiving services will as a prior action i) issue the
selection certificates regarding the first cycle signifying the completion of the
selection process and ii) adopt a legal amendment to facilitate the swift completion
of the salary fiche allowing for the actual transfer to take place without the risk of the
originating entity holding it up. Actual transfers will be completed by July 2018.
Final decision on employee mobility will be taken by the receiving service with a
vacant position, without involvement of the political level, and according to pre-
defined rules to limit disruption in the departing service. This will rationalize the
allocation of resources as well as the staffing across the general government.
According to Law 4440/2016, mobility is primarily carried out in the form of
transfers, whereas secondments are only allowed in special circumstances and for
strict time periods that cannot be extended.
• As prior action, (a) the authorities will complete a study in conjunction with
technical support of the minimum requirements of the job announcements
for all Administrative, Alternate Administrative and (Special) Sector-Level
Secretaries positions listed in the TMU, taking into account the factors
included in Article 7 of 4369/2016. Based on the results of the study the
authorities will take appropriate actions where needed by July 2018.; (b) the
appointments of 55 thematic Directors General will be completed with the
remaining 35 thematic Directors General by July; and (c) the call for 220 of
all Directors will be launched with the remaining 175 by July.
• All Directors will be appointed by October 2018. The call for all Heads of
Division will be launched in October 2018 with all appointments completed
by December 2018.
• The authorities will provide a detailed report on the implementation of the
above actions by June 2018 (see TMU section WW).
(iii) Performance assessment. As a prior action (i) the web-based/online tool/platform
for performance assessment, at the initiative of M.A.R., has been launched and is
fully operational; (ii) a Ministerial Decision, setting the timeframe for the second
performance assessment will be issued and iii) the first step (self-assessment by
the employee) will be completed for the majority of positions, with the remaining
steps to be completed by July.
(iv) Organigrams and job descriptions: A comprehensive Human Resource
Management System (HRMS) will be created that will allow for the effective
management of the all public administration’s personnel. As a first step the
authorities will initiate a platform in which both digital organigramms and job
descriptions will be interconnected. As a prior action a manual will be circulated to
all public sector entities and a training programme started on populating the
database; and a selective number of pilot entities will complete organigrams and job
descriptions thorugh setting out at the unit level respective job descriptions for all
(v) Allowances. As a prior action, the authorities will (i) publish the short-term plan on
protection and prevention as specified in the law, (ii) provide to the institutions the
initial opinion of the Committee regarding allowances for hazardous and dangerous
work, together with the detailed study and provisional quantifications, as specified in
the law, and (iii) agree with the institutions the guidance provided by the ministers to
(vi) Coordination. The authorities will strengthen the capacity for coherent policy
making, to ensure effective planning and coordination of governmental work, of
legislative initiatives, of monitoring of implementation of reforms, and of arbitrage
functions on all policies. As a prior action, following the submission of an Inter-
Ministerial Coordination Manual in April 2018, the authorities will (i) formally adopt
the Manual to enhance structures and procedures within the government and the
public administration, which includes the preparation, coordination and arbitration of
policies, and (ii) commit to an implementation plan of how the structure and
procedures will be applied by the government, notably by re-enforcing the role of
the existing Secretariat General for Coordination.
Further actions include:
i. Curricula. By mid-June the current 'klados' system will be mapped and streamlined
with the generic and specific job descriptions with the cooperation of the available
ii. Wage bill. The MTFS 2019-22 will establish ceilings for the wage bill and the level of
public employment consistent with achieving the fiscal targets and ensuring a
declining path of the wage bill relative to GDP during the period, inter alia through
the use of the attrition rule which will go from 1:3 in 2018 to 1:1 from 2019 onwards,
while exempting from the calculation of the total annual number of hirings those that
are due to staff mobility within the public sector, except from Chapter B companies.
Conversions of temporary contracts into permanent contracts following a final Court
decision will require action to ensure adherence to the projected wage bill in the
2018 budget and the 2019-22 MTFS.
Furthermore, a ceiling on temporary contracts will be introduced to ensure that the
average number of contracts burdening the budget, as reported in the Census
database, remains unchanged in 2018, preserving the projected general
government wage bill. Additional temporary contracts to cover needs coming from
the refugee crisis, natural disasters and humanitarian crisis will be exempt from the
iii. ASEP (Supreme Council for Civil Personnel Selection): Setting up a committee to
provide a detailed review of ASEP's existing capacity and develop an action plan to
ensure that ASEP has the resources required to fulfil its mandate, including
ensuring appointments/recruitments within a reasonable time plan, which needs to
be defined for each appointment/selection process.
iv. Illegal hires. The authorities will continue to identify illegal hires and temporary
injunctions, as well as disciplinary cases, and take appropriate enforcement action.
v. Development of an Internal Control System. To strengthen the transparency and
accountability of the public administration, the authorities will develop and
implement a system of internal control including internal audits, making the best use
of technical support. By May 2018, the authorities will present to the Commission
the proposal of the system of internal control including internal audit in view of its
subsequent implementation. The internal control systems will be developed in close
cooperation with the on-going technical support activities on Anti-Corruption and on
Administrative Reform undertaken respectively by the OECD and Expertise France.
vi. Access to law. The authorities will engage, with the help of technical support, in a
programme to improve access to law by citizens. This includes a long-term plan of
codification of the main legislations which will be proposed by May 2018, with a
view to fully implement it by the end of 2018. This also includes the creation of a
publicly and freely accessible electronic portal giving access to legislation, both in
the form published in the Gazette (FEK form) and in the consolidated version of the
The authorities will implement the three-year strategic plan for the improvement of the
functioning of the judicial system. The plan encompasses key actions aimed at enhancing
judicial efficiency, speeding up judicial proceedings and addressing shortcomings in the
functioning of courts such as, but not limited to, collecting information on the situation of the
courts, computerization, developing alternative means for dispute resolution, such as
mediation, rationalizing the cost of litigation and improving in court functioning and court
The authorities will continue to ensure a regular and unimpeded flow of e-auctions (see TMU
In order to support lenders' capacity to auction foreclosed properties, the authorities will make
an assessment of potential legal and technical impediments to the further improvement of
electronic auctions by May 2018. These impediments, if any, will be addressed, by adopting
necessary legal amendments as a prior action including a review of the mechanism for
decreasing the asking price in the event of failed auctions.
The authorities, making use of technical support as appropriate, will:
i. Integrate in the growth strategy the three-year strategic plan for the improvement of
the functioning of the judicial system, since timely, efficient and reliable justice is a
key driver for growth, and implement the plan according to its schedule; submit
biannual reports to the institutions on the progress of integration, starting from June
2018. Assess the implementation and effectiveness of proposed measures to
reduce the backlog of cases in civil courts, and deliver to the institutions a report by
June 2018 Potential identified problems, impediments or shortcomings will be
addressed, including by enacting the necessary legal amendments, by December
Assess the implementation and effectiveness of proposed measures comprised in the
agreed action plans to improve e-justice, mediation and judicial statistics by June 2018.
Disseminate the relevant information on the new legal framework of mediation to the legal
practitioners and the public at large, so as to increase awareness of the availability of this
mechanism and encourage its use (June 2018).
The authorities will fully implement the legal framework for the financing of the political
parties, notably by ensuring that all necessary secondary legislation is adopted (prior
action, TMU Section XX). They will also ensure the publication of the report from the
authority in charge of controlling the financing of the 2015 elections by May 2018.
The authorities will revise the legal framework of the declaration of assets system in light of
the recent Council of state ruling. This implies revising primary legislation and ensuring that
secondary legislation is fully in place by June 2018. The authorities will also ensure that the
bodies in charge of controlling the declarations of assets are fully staffed and operational by
May 2018. The authorities will ensure that all declarations up to 2016 (based on 2015
income) are processed by December 2018.
The authorities will continue to implement the Strategic Plan against corruption in full and in
line with its timeline. The update of the national anti-corruption plan (prior action, TMU
Section ZZ) will include a commitment to assess the implementation of the Code of Conduct
of members or Parliament and, based on this assessment, it will be revised, if needed, by
June 2018. The updated plan will also include the creation by September 2018 of a
monitoring mechanism of a selection of important financial crimes, including notably
corruption and money laundering cases with the objective to build a credible track-record of
prosecuting and sanctioning such crimes (TMU Section ZZ).
Following the assessment of the reduction of penalties for financial crimes provided by Law
4312/2014, the authorities will by October 2018 deliver a draft and by December 2018
amend this legislation.
The authorities will continue to pursue technical support with the European Commission
SRSS in the fields of anti-corruption.
5.4 Independent agencies and regulatory bodies
Hellenic Statistical Authority (ELSTAT)
The government fully respects the independence of ELSTAT in carrying out its tasks and
providing high quality statistics in a timely manner. For this, the government will continue
implementing necessary reforms and investigate all the support possibilities available to
provide ELSTAT with adequate human resources, sufficient financial means and continue
providing effective access to administrative data.
This follows up the commitments taken by the government in the Commitment on
Confidence in Statistics signed in March 2012, in order to support ELSTAT in upholding
confidence in Greek statistics and to defend them against any efforts to undermine their
credibility, as well as to report annually to the Hellenic Parliament and to the European
Independent agencies and entities
A unified approach should be adopted towards all independent agencies, irrespective of
whether they are constitutionally protected or not. A common set of rules, applicable
horizontally, would simplify the normative framework and would enhance effective
governance of the relevant agencies and unhindered performance of their functions.
Following the agreement on the principles and key elements to strengthen the autonomy
and effectiveness of all independent agencies and entities in the context of the second
review, the authorities will, as a prior action, enact legislation to reorganize the field,
including, where appropriate, merging eligible entities, reassigning functions to relevant
services of the central administration and abolishing redundant entities; and finalize and
enact, after consultation with the institutions, the legislation on bringing horizontal provisions
in line with the results of the horizontal review and best practices.
i. Hellenic Competition Commission (HCC): the government commits to safeguard the
independence and the effectiveness of the Hellenic Competition Commission in line
with EU requirements. As a prior action, the authorities will agree with the
institutions the principles of future legislation, included detailed drafting where
possible so as to bring these in line with best practices, including on issues relating
to the conflicts of interest of the HCC's Board members and the staffing of the HCC’s
internal legal office, consistent with the general framework for the appointment of
legal staff of the entities of the public sector, as defined by law. The advocacy unit of
the Hellenic Competition Commission will be strengthened by twelve additional posts
and a review will be conducted with the support of the European Commission and
international expertise to ensure that the competition law is in line with EU best
practice. This legislation shall be adopted by July 2018, in agreement with the
institutions and after consulting the relevant Commission services.
ii. Regulatory Authority for Energy (RAE): As a (prior action), the authorities will
agree with the institutions the principles of future legislation, included detailed
drafting where appropriate, so as to bring these in line with best practices. By July
2018, the authorities, in agreement with the institutions and after consulting the
relevant services of the European Commission, will adopt or amend any primary
and secondary legislation, including the Internal Operation Rules of RAE under
Article 45 of Law 4001/2011.
iii. Regulatory Authority for Passenger Transport (RAEM): As a prior action, the
authorities will agree with the institutions the principles of future legislation, included
detailed drafting where appropriate, so as to bring these in line with best practices.
By July 2018, in agreement with the institutions and after consulting the relevant
Commission services, the legislation will be adopted.