EUROPEAN

COMMISSION

Luxembourg, 13.7.2022
SWD(2022) 508 final

COMMISSION STAFF WORKING DOCUMENT

2022 Rule of Law Report

Country Chapter on the rule of law situation in Greece

Accompanying the document

Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions

2022 Rule of Law Report

The rule of law situation in the European Union

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ABSTRACT

A number of measures aiming at improving the efficiency and the quality of the Greek justice
system are being implemented. The 2021 reform of the School of Judges aims at increasing
the quality of judges’ training, and the planned creation of a National School for Judicial
Clerks would help to improve the quality of the assistance to judges and of the management
of the courts. The revised Code of Civil Procedure in 2021 seeks to have a positive impact on
the efficiency of justice, in particular as regards delays in civil justice and the coherence of
the case law. A code of conduct for the judges of the Council of State was adopted in March
2022. Draft legislation on the promotion of judges and prosecutors and the organisation of the
courts was adopted by the Parliament in June 2022. Measures are being implemented to
improve the quality of justice, in particular as regards digitalisation. The draft legal text is
being finalised to create a formal legal framework for the office for the collection and
processing of judicial statistics established in the Ministry of Justice at the end of 2020.
Concerns remain regarding the appointment procedure for the most senior positions of judges
and prosecutors, including the lack of judicial involvement in the selection process.

The new National Anti-Corruption Action Plan for 2022-2025 was approved. The
cooperation between anticorruption bodies and entities from the private and public sector is
being developed. Provisions for the regulation of lobbying were recently adopted. A limited
number of prosecutions related to corruption was taken forward, although progress on final
decisions remains to be established. While the number of asset declarations being filed has
increased and all are verified for their completeness, their accuracy is only verified in a
limited percentage. Rules on the ethics of civil servants continued to be implemented, but
concerns persist as regards the integrity within the police force. Regular auditing activities
aim at detecting and preventing corruption. Specific actions to counter the risk of corruption
during the COVID-19 pandemic continued to be applied.

Freedom of expression and the right of access to information are legally and formally
protected in the Constitution and sectorial legislation. The Greek government has taken steps
to strengthen the transparency of media ownership, through recently adopted legislation.
However, the situation of journalists raises significant concerns due to the fact that they
continue to face threats and attacks while their professional environment has further
deteriorated. The allocation of state advertising as regards, in particular the non-transparent
distribution of state funding, is also an issue. While public service media is regulated by a
strong legal framework, there are concerns with regard to potential political influence in the
appointment of board members. Challenges persist with regard to the adequacy of the media
regulator’s financial and human resources.

As regards checks and balances, work on improving the quality of legislation is progressing
in particular as regards the compatibility of draft laws with the Constitution and EU law.
Codification of legislation is also progressing with the adoption of a number of legal codes in
different areas of legislation. The number of last-minute amendments for draft legislation is
decreasing. However, stakeholders are often left with insufficient time to comment on draft
laws. The Ombudsperson is working on strengthening the capacities of the institution
including by securing the independence of his budgetary resources and also developing
international cooperation. New legislation seeks to improve the framework of an enabling
environment for civil society organisations, although some modalities of the registration
requirements, continue to be considered cumbersome by some civil society organisations
while a review of the existing legislation is pending before the Council of State.

1
RECOMMENDATIONS

In addition to recalling the commitments made under the national Recovery and Resilience
Plan relating to certain aspects of the justice system and the anti-corruption framework, it is
recommended to Greece to:

• Address the need for involvement of the judiciary in the appointment of President and
Vice-President of the Council of State, the Supreme Court and the Court of Audit taking
into account European standards on judicial appointments.
• Ensure the effective and systematic verification of the accuracy of asset disclosures filed
by all types of public officials.
• Increase efforts to establish a robust track record of prosecutions and final judgments in
corruption cases.
• Establish legislative and other safeguards to improve the physical safety and working
environment of journalists, in line with the recently adopted Memorandum of
Understanding and taking into account European standards on the protection of
journalists.
• Ensure that registration requirements for civil society organisations are proportionate in
view of maintaining an open framework for them to operate.

2
I. JUSTICE SYSTEM

The Greek judicial system consists of 217 first instance courts (154 magistrate courts and 63
first-instance courts of general jurisdiction) 1. There are 19 second instance courts (courts of
appeal) of general jurisdiction and the Supreme Court as the highest court of general
jurisdiction2. Mixed criminal courts are composed by professional and lay judges 3. Within the
courts of first instance and courts of appeal of large cities, there are special chambers, tasked
with adjudicating in special categories of law (e.g. family law, commercial law, etc.) 4.
Administrative courts are organised into 30 administrative courts of first instance, 9
administrative courts of appeal and the Council of State 5 which exerts retrospective control
over ‘enforceable acts’ of administrative authorities regarding their constitutionality and
legality, with the exception of the Acts of Government 6. The Court of Audit is the Supreme
Financial Court and Audit Institution auditing the use of public funds in Greece, the
jurisdictional, auditing and advisory competences thereof being grounded on the
Constitution.7 Judges and prosecutors form a consolidated body subject to a system of
recruitment, career, rights and obligations, which is largely homogeneous for all. Judges are
appointed to civil and penal jurisdictions and to administrative courts. Promotions,
assignments to posts, transfers and secondments, are effected by presidential decree and
issued after prior decision by the Supreme Judicial Council 8. As regards prosecution
authorities,9 they are organised into 63 prosecution offices at the courts of first instance, 19
prosecution offices at the courts of appeal and the General Prosecutor of the Supreme Court.
Greece participates in the European Public Prosecutor’s Office (EPPO). There are 63 bar
associations in Greece, one at the seat of each court of first instance.

1
Ministry of Justice website, https://ministryofjustice.gr/English/.
2
CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States, p. 638.
3
Constitution of Greece, Art. 97, para. 1: ‘Felonies and political crimes shall be tried by mixed jury courts
composed of ordinary judges and jurors, as specified by law. The judgments of these courts shall be subject
to the legal remedies specified by law’.
4
As far as other special courts are concerned, special provisions regulate the operation of courts for juveniles,
military, navy and air force courts. The military, navy and air force courts are under the jurisdiction of the
Ministry of National Defence. Juvenile courts are part of the courts of first instance and do not represent
separate legal entities. CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States,
p. 638.
5
Ibid.
6
‘Codification of Law concerning the Council of State’, Presidential Decree, 18/1989, Article 45, paragraph
5. Acts of Government are classified into three categories: (i) those concerning the relations between the
President of the Republic with Parliament and the Government (e.g. decree dissolving the Parliament and
announcing elections, decree accepting the resignation of a minister or the Government, decree proclaiming
a referendum, etc.); (ii) acts declaring the mobilisation of the Armed Forces and granting grace; and (iii) acts
relating to international relations of Greece with third countries. GRECO Fifth Evaluation Round –
Evaluation Report, p. 25.
7
Constitution of Greece, Article 98.
8
There are three supreme judicial councils, one for each of the branches of the judiciary, which are composed
only by members of the judiciary. These councils decide on appointments, promotions, transfers and
secondments of judges in the respective branches of the judiciary and prosecutors. Constitution of Greece,
Article 90, paragraph 1. 2020 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p.
2-3 and 2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 2.
9
CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States, p. 641.

3
Independence

The level of perceived judicial independence in Greece continues to be average among

the general public and is now average among companies. Overall, 53% of the general
population and 59% of companies perceive the level of independence of courts and judges to
be ‘fairly or very good’ in 2022 10. According to data in the 2022 EU Justice Scoreboard, no
clear trend can be identified in the evolution of the perceived level of independence since
2016. Both figures have decreased in comparison to 2021 (55% for the general public and
60% for companies), but they are higher than in 2016 (47% for the general public and 37%
for companies).

The appointments procedures for the highest senior positions of judges and prosecutors
continue to raise concerns. As reported in the previous Rule of Law Reports, the system of
appointments raises concerns as being subject to a potentially strong influence from the
executive11. The relevant legislation 12 stipulates that appointments of judges and prosecutors
in the most senior positions 13 – such as the President and Vice-President of the Council of
State, of the Supreme Court or of the Court of Audit – be effected by presidential decree,
following a recommendation by the Council of Ministers based on a proposal by the Minister
of Justice and an opinion of a parliamentary body. There is no involvement of the judiciary in
the appointment procedure and the Constitution excludes 14 unsuccessful candidates from
contesting before an independent court the decision not to recommend them for appointment.

10
Figures 50 and 52, 2022 EU Justice Scoreboard. The level of perceived judicial independence is categorised
as follows: very low (below 30% of respondents perceive judicial independence as fairly good and very
good); low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%).
11
2020 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 3 and 2021 Rule of
Law Report, Country Chapter on the rule of law situation in Greece, p. 3. In November 2020, GRECO raised
concerns regarding the system of appointments for the most senior positions in the judiciary (including the
Supreme Court President), notably that these positions are subject to a potentially strong influence of the
executive and recommended to revise the method of selection and ensure the involvement of the judiciary in
the process, GRECO Fourth Evaluation Round - Second Compliance Report, recommendation xii, p. 7.
More recently, the same issue is raised by the Council of Bars and Law Societies of Europe in its
contribution for the 2022 Rule of Law Report, p. 30.
12
The applicable legislation is: i) Constitution of Greece, Art. 90 para. 5, ii) Regulation of the functioning of
the Greek Parliament, Art. 12 and 13, iii) ‘On the selection of magistrates for the top posts of Justice and the
reinstatement of the self-governance on courts’ Law 3841/2010 and the most recent iv) ‘Code of the
organisation of the courts and status of judges’ Law 4938/2022. In practice, there is a list of candidates
established by the Minister of Justice based on seniority. The list is discussed by the conference of the
Presidents (speakers) of the Parliament. The Minister of Justice is not obliged to follow the opinion of the
Parliament. The practice of establishing the list of candidates on the basis of seniority has been enshrined in
the recent Law 4938/2022 (paragraph 3 of Article 59) which provides that: ‘For promotions to the posts of
Vice-Presidents of the Council of State, the Supreme Court and the Court of Auditors, the selection shall be
made from among the ten most senior of the judges who have the formal qualifications, when the post to be
filled is one. For each additional post, the number of candidates to be selected shall be increased by four.’
13
As regards all other members of the judiciary see above p. 3.
14
Article 90, paragraph 6: ‘Decisions or acts in compliance with the provisions of the present article shall not
be subject to remedies before the Supreme Administrative Court’. According to the Greek authorities against
the presidential decree for the appointment to the post of President or Vice-President, a petition for
annulment can be filed before the Council of State, despite the provisions of par. 6 of art. 90 of the
Constitution. However, the Court cannot control the exercise of the discretion of the Cabinet with regard to
the person chosen for the post or the evaluated criteria for such choice. Are deemed admissible, though,
grounds of annulment pertaining to terms or conditions of the promotion directly set by the constitutional
previsions and not by the legislator.

4
According to European standards, an independent and competent authority drawn
substantially from the judiciary should be authorised to make recommendations or express
opinions which the government follows in practice. In addition, an unsuccessful candidate
should have the right to challenge the decision of the Government, or at least the procedure
under which the decision was made 15. These specific issues are per se not addressed in the
new law ‘Code on the organisation of the courts and the status of judges’ dealing among
others with the promotion of judges 16. Given the fact that addressing the concerns would
imply the revision of the Constitution as well as the revision of the Regulation on the
functioning of the Parliament, the new Code, according to the Greek authorities, made the
effort to limit the discretionary power of the Council of Ministers by including a seniority
criterion to the eligibility of the candidate judges: from now on, only the most senior of
judges are eligible to be Vice-President of the Supreme Courts. Similar limitations are also
included for the positions of the Presidents of the Supreme Courts.

Legislation on the organisation of the courts and the status of judges has been adopted.
The code on the organisation of the courts and the status of judges and prosecutors 17 has been
adopted by the Parliament on 6 June 2022 18. The legislation aims to have a positive impact on
the efficiency and quality of justice, in particular as regards the use by judges of digitalised
procedures and the acceleration of the administration of justice 19. In addition, the draft law
provides for criteria for the promotion of judges and prosecutors such as quantitative and
qualitative performance. These criteria take into consideration the difficulty of the cases the
judge has dealt with, efficiency in the administration of justice and professional knowledge
acquired including in the framework of their participation to seminars organised by the
National School of Judges20.

The Council of State and the Court of Audit are taking action to ensure standards of
integrity in their members. Following the adoption in 2020 of the Code of Conduct of the

15
Recommendation CM/Rec(2010)12 of the Committee of Ministers of the Council of Europe to member
states on judges: independence, efficiency and responsibilities, paras. 46-48.
16
Art. 59, paragraph 3 of the law does not provide for any changes as regards the non-involvement of the
judiciary, the strong influence of the executive and the absence of legal remedies in the appointment
procedure in the most senior positions of judges and prosecutors. For more details on this draft legislation,
see next paragraph in the main text.
17
In the framework of the 2021 Rule of Law Report, the Greek authorities indicated that a draft law was under
preparation, in view of adoption in the third quarter of 2021, in order to amend the ‘Code on the organisation
of the courts and the status of judges’ so as to modernise the system of promotion for judges and
prosecutors. 2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 3-4.
18
See also above. Written contribution from the Ministry of Justice in the context of the country visit to
Greece. The draft law was also published in the website of the Ministry of Justice. The draft legislation was
also examined in the context both of the enhanced surveillance framework and is part of the national
Recovery and Resilience Plan. European Commission (2022), Enhanced Surveillance Report, Greece, p. 14.
19
Judges who delay without justification issuing their decisions can face disciplinary procedures, Article 109
of the legislation.
20
The Association of Judges and Prosecutors considers that the draft provisions on the promotion and the
disciplinary procedures of judges do not raise any issue as regards the independence of the judiciary.
Information received from the Association of Judges and Prosecutors in the context of the country visit to
Greece and also written comments on the draft legislation published in the website of the Association. All
the remarks of the Association were taken into consideration by the Ministry of Justice during the
elaboration of the draft. Press release of the Association of Judges of 8 April 2022, published on the website
of the Association and written contribution from the Ministry of Justice in the context of the country visit to
Greece, p. 1.

5
Court of Audit, which is currently being implemented21, the Council of State adopted a code
of conduct for its members on 23 March 2022 22. Both documents take into consideration the
best practices and international texts in this area, including the so-called ‘Bangalore
Principles of Judicial Conduct’ 23. The implementation of the codes of conduct takes place
under the responsibility of a committee. As regards the Council of State, the committee
consists of the President and two councillors proposed by the plenum and the association of
the judges of the Council of State. As regards the Court of Audit the committee consists of
the Vice President and a councillor proposed by the plenum and one judge proposed by the
association of the judges of the Court of Audit 24. As regards civil and criminal justice, the
work of a special working group established by the President of the Supreme Court is
actively working on the preparation of a code of conduct 25.

Quality

Digitalisation of administrative justice is well advanced, while further steps are needed
to address shortcomings in the digitalisation of all branches of the judiciary including
civil justice26. In administrative justice, centralised case management and case law systems
are now fully operational with a portal through which all interested parties can access a
unified Database of Administrative Justice. Through the system, lawyers and public bodies
are provided with updated information and can follow up on the case process as well as file
all type of remedies, including appeals, online through the Hellenic Bar Association portal
that authenticates them as lawyers. Entitled applicants can also request legal aid via the
system. In addition, through the same system the handling of documents is operated
electronically, as is the notification of decisions and the filing of applications for issuing
certificates 27. Lawyers can also lodge procedural documents to the administrative courts
through the Hellenic Bar Association’s portal28. Fully anonymised case law is accessible to
the public through the administrative justice portal29. As regards civil and criminal courts, a
new platform30 launched in December 2021 is offering real-time information regarding trial

21
‘Charter of deontology of the judges of the Court of Audit’, OJ, 4942B, 09.11.2020. Input from Greece for
the 2022 Rule of Law Report, p. 5 and 2021 Rule of Law Report, Country Chapter on the rule of law
situation in Greece, p. 4, footnote 22.
22
Published on the website of the Council of State on 23 March 2022. Written contribution from the Council
of State in the context of the country visit to Greece.
23
In particular as regards the core values of the judiciary: Independence, Impartiality, Integrity, Propriety,
Equality, Competence and Diligence. The Council of State Code refers to the ‘Bangalore Principles’ in
paragraph 4 and the Court of Audit Code in paragraph 6 of the respective codes of conduct. For the
Bangalore principles, see
https://www.unodc.org/pdf/crime/corruption/judicial_group/Bangalore_principles.pdf.
24
Information received from the Court of Audit and the Council of State in the context of the country visit to
Greece.
25
Due mainly to the need to restructure the working group following the retirement of some of its members
there was some delay. The retired President of the working group has been replaced by the President of the
Supreme Court in April 2022 and the work on the draft Code has been resumed.
26
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, pp. 4-5.
27
Contribution from the Association of European Administrative Judges for the 2022 Rule of Law Report, pp.
12-13.
28
Input from Greece for the 2022 Rule of Law Report, pp. 11-19.
29
Ibid; For the website of the administrative justice portal seehttp://www.adjustice.gr/; Ministry of Justice
(2021), Presentation summary of the Integrated Judicial Management System for Administrative Justice.
30
dikes.moj.gov.gr (under: portal gov.gr). Any person who wishes to know about a certain trial, has access to
every case of the daily board of the courts. Anyone interested is offered the possibility to search a case, by a

6
boards and hearings 31. However, shortcomings still exist in civil justice, in particular as
regards the possibility for courts to communicate electronically between themselves in a
secure manner as well as with legal professionals and other institutions, and to the use of
digital solutions to initiate and follow proceedings in civil and commercial cases 32.
Digitalisation of justice has been identified as one of the priority areas in the national
Recovery and Resilience Plan (RRP)33 in combination with an important programme of
upgrading existing court buildings and the construction of new ones taking into consideration
digital justice needs34.

The Government is taking measures aimed at improving access to justice for persons
with disabilities. Persons with disabilities face difficulties as regards their access to
justice35. The Ministry of Justice is committed to continue improving the accessibility of
court buildings for persons with disabilities until 2027 to cover all the court buildings of
Greece. Furthermore, the possibility of enhancing accessibility to deaf and hard-of-hearing
people in courtrooms through the use of digitalised procedures in combination with the
existing infrastructure started in 2022 and is planned to be completed in 2026 36.

The implementation of the system for the collection of judicial statistics is progressing.
An office for the collection and processing of judicial statistics was established in the
Ministry of Justice at the end of 2020 37, with the objective of systematic collection of
qualitative and quantitative statistical data 38. The functioning of the office 39 has been
formalised with a Presidential Decree 40, which is currently being elaborated by the Ministry
of Justice. A call for the procurement of the relevant infrastructure and services will be
launched in the near future41.

court building number, or room number, or even board code, with no need for authentication or special
registration procedure.
31
Input from Greece for the 2022 Rule of Law Report, p. 16, www.solon.gov.gr.
32
Figures 43, 44 and 46, 2022 EU Justice Scoreboard. In certain areas as for example the issuing of digital
judicial certificates important delays are experienced due mainly to the lack of personnel able to manage the
relevant digital tools. Information received from the Bar Association in the context of the country visit to
Greece.
33
European Commission, Report on the Ιmplementation of the Recovery and Resilience Facility 2022, p. 40.
34
Input from Greece for the 2022 Rule of Law Report, pp. 8-9 and information received from the Ministry of
Justice in the context of the country visit to Greece.
35
Such as the availability of information in accessible formats, the availability of digital solutions for civil,
commercial, administrative and criminal cases before first instance courts or the lack of adjusted alternative
dispute resolution method. Figure 29, 2022 EU Justice Scoreboard.
36
Input from Greece for the 2022 Rule of Law Report, p. 8-9.
37
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 5.
38
This project will be further developed in the framework of Greece’s Recovery and Resilience Plan;
European Commission (2022), Report on the Implementation of the Recovery and Resilience Facility, p. 42.
39
The office already provides judicial statistics, which are regularly published in the website of the Ministry of
Justice.
40
‘Establishment, organization and operation of the Office for the Collection and Processing of Judicial
Statistics at the Central Service of the Ministry of Justice’, Presidential Decree 47/2022, published in the
Government Gazette A' 114/17.06.2022. The Decree provides in Article 4, that the office will be responsible
for collecting and transmitting judicial statistics to the European Commission for the Efficiency of Justice
(CEPEJ).
41
Information received from the Ministry of Justice in the context of the country visit to Greece.

7
The School of Judges was reformed in December 2021 to improve the training of judges.
The reform of the School of Judges42 aims at increasing the quality of judges’ training. The
School provides introductory and lifelong training for judges including, for the first time, for
magistrates 43, with regular mandatory training programmes. Ad-hoc training programmes are
provided for judges of all branches and ranks who are called upon to implement new laws
and regulations. In addition, international training or further training programmes for judges
will be extended due to the School's cooperation with the European Union Agency for
Asylum and the Academy of European Law 44. The training of trainers is established in
accordance with the provisions of the European Network for the Exchange of Information
between those responsible for providing Judicial Training 45. For the first time, the list of
mandatory courses includes children’s rights as well as principles of child-friendly justice46.
Ethics and anti-corruption are essential courses in the School’s curriculum 47.

The planned creation of a National School for Judicial Clerks aims at ensuring better
assistance to judges. The judge/judicial clerk ratio has been decreasing since 2015 and is
currently 1.09 judicial clerks per judge 48. The aim of the Ministry of Justice is to increase this
ratio to three judicial clerks per judge 49. The planned creation of a National School for
Judicial Clerks (NSJC)50 aims at increasing the quality of the assistance to judges and the
quality of court management 51. The courts will have the possibility to directly hire judicial
clerks from the NSJC. Training and lifelong training of judicial clerks by the NSJC will cover
topics that are essential for their duties, including the management and organisation of court
service, digital skills, and procedural and substantive law 52. In addition, public sector officials
will have the possibility to be transferred to courts services and become full time judicial

42
‘Reform of the National School of Judges’, Law 4871/2021 of 10 December 2021. For the website of the
School of Judges, see https://www.esdi.gr/.
43
Magistrates chair the magistrate courts which are the lowest jurisdictions.
44
Since March 2022, the School has participated in seminars on EU tax law, legal language training in
cooperation in Asylum and Refugees, the Brussels Ia, Rome I and II Regulations, and asset recovery and
confiscation in the EU,
https://www.esdi.gr/%ce%b4%ce%b9%ce%b5%ce%b8%ce%bd%ce%b5%ce%af%cf%82-
%cf%83%cf%87%ce%ad%cf%83%ce%b5%ce%b9%cf%82/. The seminars were organised by the European
Judicial Training Network (EJTN).
45
Law 4871/2021 Article 47 and input from Greece for the 2022 Rule of Law Report, pp. 10-11.
46
Ibid, Article 42c. Also see National School of Judges (2022), ‘Curriculum for the 28 th cohort of trainees in
the administrative justice orientation’, ‘Meetings: c. “EU Charter of Fundamental Rights – Children’s rights
– Child-friendly justice”’, p. 4; National School of Judges (2022), ‘Curriculum for the 28th cohort of trainees
in the civil and criminal justice orientation and magistrates orientation’, ‘Meetings: c. “EU Charter of
Fundamental Rights – Children’s rights – Child-friendly justice”’, p. 4; National School of Judges (2022),
‘Curriculum for the 28th cohort of trainees in the prosecution service orientation’, ‘Meetings: c. “EU Charter
of Fundamental Rights – Children’s rights – Child-friendly justice”’, p. 4. A training seminar on children’s
rights and child-friendly justice, for judges and prosecutors currently in office, was held between 5-6 May
2022, https://www.esdi.gr/wp-content/uploads/2022/05/programmsemmap_2022.pdf.
47
Information received from the representatives of the School of Judges in the context of the country visit to
Greece.
48
The ratio between professional judges and non-judge staff decreased substantially in Greece from 2015 (1
judge for 2.53 clerks) to 2020 (1 judge for 1.09 clerk). CEPEJ (2021), Study on the functioning of judicial
systems in the EU Member States, p. 640.
49
Input from Greece for the 2022 Rule of Law Report, p. 10-11.
50
The Code of Judicial Staff (Clerks) was adopted on 24 April 2021; 2021 Rule of Law Report, Country
Chapter on the rule of law situation in Greece, p.5.
51
The NSJC will be created with the assistance of the Recovery and Resilience Plan for Greece. Input from
Greece for the 2022 Rule of Law Report, p. 10.
52
Ibid.

8
clerks after their evaluation by the relevant Judicial Council 53. Officials specialised in
information technologies will also have the possibility to be transferred to the Council of
State and to administrative courts 54.

The reform of the judicial map is ongoing. As regards administrative justice, the working
group on the reform of the judicial map, established by an act of the President of the Council
of State of 24 March 2021, continues its work55. The relevant matters have already been
under consultation with all administrative courts and are currently under consultation with the
bar associations nationwide 56. As regards civil and criminal justice, the Ministry of Justice
has signed on 30 March 2022 an agreement with the International Bank for Reconstruction
and Development for the support of the reform of the judicial map. The technical assistance
will propose an integrated plan for the reform of the judicial map due to be submitted for
consultation with all relevant stakeholders, in order to have a draft law prepared by the end of
202357. If the reform were to involve a transfer of judges, according to European standards,
judges who would be transferred in the course of the reform without their consent should
benefit from procedural safeguards in order to ensure that their independence is not
jeopardised58.

Efficiency

Civil justice continues to face challenges regarding its overall efficiency, while
improvements are noticed in administrative justice. Judicial statistics show that the civil
court system faces efficiency challenges, as the time needed to resolve litigious civil and
commercial disputes in first instance has increased (637 days in 2019 59 compared to 559 days
in 2018)60. In administrative justice, the clearance rate has remained high (162.8% in 2020
compared to 163.5% in 2018 61) and the disposition time has decreased (to 551 in 2020 from
601 days in 2018)62.

The adoption of the reviewed Code of Civil Procedure seeks to introduce improvements
as regards delays and the coherence of the case law. On 13 October 2021, the new Code of

53
‘Code of Judicial Staff’, Law 4798/2021, Article 238. Input from Greece for the 2022 Rule of Law Report,
p. 10.
54
‘Acceleration of pending judicial cases’, Law 4745/2020, Article 37 and ‘Speedy civil procedures’, Law
4842/2021 Article 93. Input from Greece for the 2022 Rule of Law Report, p. 9.
55
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 5.
56
Input from Greece for the 2022 Rule of Law Report, p. 17.
57
Ibid. This specific reform is part of Greece’s Recovery and Resilience Plan.
58
Pursuant to European standards, it is allowed, in exceptional cases, to transfer judges without their consent,
provided that sufficient safeguards are in place. These safeguards include a requirement that the judge may
not be transferred to a court of a lower instance and that he or she has recourse to judicial review.
Recommendation CM/Rec(2010)12 of the Committee of Ministers of the Council of Europe, para. 52;
European Charter of the Stature of Judges, Arts. 1.4., 3.4.; European Network of Councils for the Judiciary,
Development of Minimal Judicial Standards III – Minimum Standards regarding the evaluation of
professional performance and irremovability of members of the judiciary – Report 2012-2013, proposal
4.21; judgment of the European Court of Human Rights of 9 March 2021, Bilgen v Turkey, 1571/07, para.
96.
59
There is no data available for 2020 for civil and commercial justice.
60
Figure 6, 2022 EU Justice Scoreboard.
61
Figure 12, 2022 EU Justice Scoreboard. There are no available data for 2019 for administrative justice.
62
Figure 8, 2022 EU Justice Scoreboard.

9
Civil Procedure was adopted 63 aiming to modernise civil procedure. Specific provisions of
the new Code introduce a general use of digitalised procedures64 and a number of other
innovations 65, namely pilot trials in civil cases 66. This procedure allows the Supreme Court to
decide on a legal matter brought before it by a three-member council67 after an application by
a party to a pending case or by a preliminary question from a lower court judge. This
provision is designed to deal with legal matters that affect a wide circle of parties, with the
goal of providing legal certainty while at the same time helping with the swift resolution of
the specific cases 68. Taking into consideration the important innovations the Code brings into
the legal system, training of practitioners including judges and lawyers 69 would help the swift
implementation of the reviewed Code.

II. ANTI-CORRUPTION FRAMEWORK

The National Transparency Authority (NTA) 70 oversees the implementation of the National
Anti-Corruption Action Plan (NACAP) for 2022-2025, conducts investigations on corruption
cases, monitors the implementation of provisions related to asset declarations and lobbying
activites, and takes the necessary actions to ensure the coherence and effectiveness of the
national strategy, with particular emphasis on coordination of control bodies and the
efficiency of their operations, and provide relevant instructions. The Directorate General of
Financial and Economic Crime Unit (DG SDOE) is the law enforcement agency of the
Ministry of Finance, whose main focus is the detection of fraud and corruption cases 71.The

63
‘Expedited civil trial, adaptation of the provisions of civil procedure for the digitalisation of civil justice,
other amendments to the Code of Civil Procedure and other urgent provisions’, Law 4842/2021.
64
Namely, Articles 122A, 959A, 1054 para 4 of Law 4842/2021.
65
Input from Greece for the 2022 Rule of Law Report, p. 18-19.
66
Article 20A of the Code. A comparative study on legislation and practices concerning pilot judgment
procedures was part of a project of technical assistance the Commission has been providing (between 30
June 2020 and 5 July 2022) to the Greek Ministry of Justice through the general project under the title
‘Enhancing the reform of the court system in Greece’ funded under the Structural Reform Support
Programme. The pilot trial procedure follows the example of the same practice in administrative justice
which was introduced for the first time with Law 3900/2010, ‘Rationalization of procedures and expedited
administrative trial’, Article 1.
67
Composed of the President of the Supreme Court, the oldest in hierarchy Vice President and the competent
by substance Vice President or the Prosecutor of the Supreme Court.
68
The Association of Judges and the Bar Association have expressed their doubts as of the expected efficiency
of Pilot Trials in civil procedure. They both consider that very few cases would be concerned and this would
have a very limited effect on the speeding of procedures. Information received from the Association of
Judges and the Bar Association in the context of the country visit to Greece. The Ministry of Justice agrees
that the procedure will be used once or twice a year but its effect on the speeding of justice would be
positive. Written input received from the Ministry of Justice following the country visit to Greece.
69
On 29 March 2022, the Athens Bar Association organised a first training seminar addressed to lawyers on
the innovations in the civil procedure. See website of the Athens Bar Association, https://www.dsa.gr/.
70
In line with the milestone foreseen under the Greek Recovery and Resilience Plan (RRP), new business
premises for NTA shall be developed by the end of 2025. NTA is the Greek designated authority responsible
for coordinating the fight against fraud (AFCOS) in accordance with the Regulation (EE, Euratom) No.
883/2013 of the European Parliament and the Council of September 11, 2013 (EU L248). The NTA is
subject to parliamentary scrutiny.
71
SDOE’s staff consists of 45 employees serve at the Central Unit and 193 employees and auditors at the
Operational Directorates. Input from Greece for the 2022 Rule of Law Report, p. 22.

10
Directorate of Internal Affairs is tasked to tackle corruption within the Independent Authority
for Public Revenue (IAPR) 72.

The perception of public sector corruption among experts and the business community
is that the level of corruption in the public sector is high. In the 2022 Corruption
Perceptions Index by Transparency International, Greece scores 49/100 and ranks 17th in the
European Union and 58th globally73. This perception has been relatively stable over the past
five years 74. The 2022 Special Eurobarometer on Corruption shows that 98% of respondents
consider corruption widespread in their country (EU average 68%) and 59% of respondents
feel personally affected by corruption in their daily lives (EU average 24%) 75. As regards
businesses, 90% of companies consider that corruption is widespread (EU average 63%) and
76% consider that corruption is a problem when doing business (EU average 34%) 76.
Furthermore, 30% of respondents find that there are enough successful prosecutions to deter
people from corrupt practices (EU average 34%)77, while 19% of companies believe that
people and businesses caught for bribing a senior official are appropriately punished (EU
average 29%)78.

The anticorruption institutions continue to develop cooperation with private and public
entities. In 2021, the National Transparency Authority (NTA) continued supporting entities
in both the public and private sectors 79 by advising on fraud risk management 80 and
developing anticorruption policies 81. In this context, the NTA signed a series of agreements
with public entities 82. In the same year, the Directorate of Internal Affairs of the Independent
Authority for Public Revenue has conducted 85 controls of property of the authority
employees83.

The new National Anti-Corruption Action Plan (NACAP) for 2022-2025 was approved.
Following the completion of the NACAP 2018-2021, in line with the Recovery and
Resilience Plan (RRP), in March 2022 the Council of Ministers approved the national Action

72
Other tasks include monitoring on disciplinary misconduct, ensure the lawful conduct of its employees, as
well as to investigate their assets. Input from Greece for the 2022 Rule of Law Report, p. 23.
73
Transparency International (2022), Corruption Perceptions Index 2021, pp. 2-3. The level of perceived
corruption is categorised as follows: low (the perception among experts and business executives of public
sector corruption scores above 79); relatively low (scores between 79-60), relatively high (scores between
59-50), high (scores below 50).
74
In 2017 the score was 48, while in 2021 the score is 49. The score significantly increases/decreases when it
changes more than five points; improves/deteriorates (changes between 4-5 points); is relatively stable
(changes from 1-3 points) in the last five years.
75
Special Eurobarometer 523 on Corruption (2022). The Eurobarometer data on citizens’ corruption
perception and experience is updated every second year. The previous data set is the Special Eurobarometer
502 (2020).
76
Flash Eurobarometer 507 on Businesses’ attitudes towards corruption in the EU (2022). The Eurobarometer
data on business attitudes towards corruption as is updated every second year. The previous data set is the
Flash Eurobarometer 482 (2019).
77
Special Eurobarometer 523 on Corruption (2022).
78
Flash Eurobarometer 507 on Businesses’ attitudes towards corruption in the EU (2022).
79
Starting October 2021, NTA delivered six webinars on the integrity in the private sector. Input from Greece
for the 2022 Rule of Law Report, p. 45.
80
Information received from the National Transparency Authority in the context of the country visit to Greece.
81
Ibid.
82
Input from Greece for the 2022 Rule of Law Report, p. 20.
83
Information received from the Ministry of Justice in the context of the country visit to Greece.

11
Plan for 2022-202584. Its implementation remains under the remit of the National
Transparency Authority. The lack of comprehensive involvement of civil society in the
development of anticorruption strategies remains a point of concern 85.

A limited number of prosecutions related to corruption were taken forward, although

progress on final decisions remains to be established. In December 2021, the Criminal
Code’s provisions on active and passive bribery were amended 86 in line with the
recommendations from the Group of State against Corruption (GRECO) 87. In 2021, the
Prosecutor for Financial Crimes (with 13 prosecutors and 13 investigators 88) treated 266
cases in total, with 81 cases closed, and 19 cases with charges pressed, while 156 cases
remain still pending 89. There is no data available on the number of criminal sentences on
cases of corruption by criminal courts. In September 2021, two cases for active bribery were
closed due to the statutory limitation90. The OECD has raised concerns on the investigation
and the legislation, including sanctions for natural and legal persons, related to foreign
bribery91.

Asset declarations are filed in great numbers but only a limited percentage of them are
verified on their accuracy. The system of asset declarations is divided among four oversight
bodies92. The National Transparency Authority (NTA) is responsible for receiving and
verifying the asset declarations of all administrative control authorities (inspectors, auditors,
investigators). While the completeness of asset declarations is regularly checked, relying on a
risk-based assessement, in 2021 the NTA verified the accuracy of only 139 declarations of
assets; seven cases were referred to the tax authorities for further investigation, and in one

84
By art.1 of Law 4915/2022, the Council of Ministers approved the NACAP 2022-2025. In the context of
Greece’s RRP, actions concerning the National Anti-Corruption Action Plan are expected to be implemented
by the end of 2022, namely milestone n.210 on the adoption by the National Transparency Authority of the
National Anti-Corruption Action Plan for the period 2022-2025, including the specification of: (i) actions to
enhance transparency and accountability across public administration; (ii) targeted interventions to detect
and prevent corruption in high-risk areas (including, for example, health, public finances, investments); (iii)
necessary regulatory interventions in selected policy fields.
85
GRECO Fifth Evaluation Round – Evaluation Report, p. 23, in addition to the information received by civil
society organisations in the context of the country visit to Greece. According to the Greek authorities there
were consultations with 24 relevant public and private stakeholders of which 5 Civil Society Organisations.
86
‘Amendments to the Penal Code and the Code of Criminal Procedure’, Law 4855/2021, 12 November 2021.
87
GRECO Fifth Evaluation Round – Evaluation Report, p. 7.
88
Information received from the Public Prosecutor’s Office in the context of the country visit to Greece.
89
Ibid.
90
Information received from the Ministry of Justice in the context of the country visit to Greece.
91
OECD (2022), Implementing the OECD Anti-Bribery Convention, Phase 4 Report, Greece, p. 5.
92
There are four main authorities in charge of receiving and auditing asset declarations: i) the Committee of
Parliament for the Investigation of Declarations of Assets (CIDA), the so-called Committee 3-A, is
responsible for the oversight and sanctions on political entities’ (such as parties and persons) financing, and
on asset declarations; ii) the Source of Funds Investigation Unit (SFIU) of the Anti-Money Laundering
Authority, which is responsible for the audit of asset declarations of several categories of public officials, as
well as for individuals performing management duties in specific private legal entities; iii) the Hellenic
Internal Affairs Agency of Law Enforcement Bodies, which is responsible for the audit of asset declarations
of Hellenic Police Personnel, Hellenic Coast Guard Personnel and Fire Brigade Personnel, as well as Public
Servants of the wider public sector, and (iv) the National Transparency Authority who is responsible for
receiving and verifying the asset declarations of administrative control authorities (inspectors, auditors,
investigators). 2020 and 2021 Rule of Law Reports, Country Chapter on the rule of law situation in Greece,
p. 7 and p. 8 respectively.

12
case a situation of conflict of interests was found 93 (compared to 15 cases of non-declared
revenues and two cases of possible conflict of interest in 2020). The Committee of Parliament
for the Investigation of Declarations of Assets (CIDA), which is responsible for the
verification of the asset declarations of Members of the Parliament, political parties and
members of the judiciary, 94 manages an annual workload of several thousands of
declarations 95. In 2021, it received eight whistleblowing reports, and three questions from the
members of the judiciary; four reports were closed with no sanction 96, and the other four
cases remain pending 97. In 2021, CIDA verified 23 financial declaration of political parties
(for the year 2019), and found eight minor violations on the use of public funds 98. In 2021,
the Source of Funds Investigation Unit of the FIU (SFIU) of the Hellenic anti-money
laundering authority received 83 528 asset declarations, performed 659 verifications and
asked clarifications for 124 of the declarations verified 99. For the same year, violations
(mainly for non-submission) were found in 27 cases, which were forwarded to the competent
prosecutorial authorities100. The verification on the accuracy of the information declared is
performed only at the request of the prosecutor on an ad hoc basis 101. Following verifications
by the Hellenic Internal Affairs Agency of Law Enforcement Bodies, 34 audit reports for
non-declaration and 56 reports for inaccurate declarations (concerning 727 obligated persons)
were transmitted to the prosecution authorities 102. In 2021, the same unit received
approximately 990 complaints from whistleblowers concerning mainly cases of abuse of
power, bribery, drugs dealing and gambling, which brought to open examinations on about
1 345 cases 103. GRECO recommends further streamlining the declarations of assets of
persons entrusted with top executive functions 104. The RRP foresees the revision of the legal
framework for asset declarations (Law 3213/2003), the simplification of the electronic

93
In December 2021, the Internal Regulation of Asset Declaration Audit was updated after ‘Common
Regulation on the Methodology of Asset Declaration Audits’, as well as the Risk Analysis Criteria Manual.
Information received from the National Transparency Authority in the context of the country visit to Greece,
and input from Greece for the 2022 Rule of Law Report, p. 36.
94
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 8. In order to protect
sensitive data of the declarants, the declarations of Members of Parliament are done in a non-machine
readable manner. Information received from CIDA in the context of the country visit to Greece.
95
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 8.
96
Information received from CIDA in the context of the country visit to Greece.
97
By the end of 2021, the backlog of 20 000 declarations of assets to be verified was resolved. 2021 Rule of
Law Report, Country Chapter on the rule of law situation in Greece, p. 8. Information received from CIDA
in the context of the country visit to Greece.
98
The findings concerned inaccuracy in the declarations. The President of the Parliament issued sanctions on
all eight cases. Information received from CIDA in the context of the country visit to Greece.
99
Information received from the Source of Funds Investigation Unit in the context of the country visit to
Greece.
100
Information received from the Source of Funds Investigation Unit in the context of the country visit to
Greece.
101
The annual number of asset declarations verified for accuracy varies depending on different elements, such
as the complaints, prosecutor’s orders, complexity of cases, among others. Information received from the
Hellenic Internal Affairs Agency of Law Enforcement Bodies in the context of the country visit to Greece.
102
Written contribution from the Hellenic Internal Affairs Agency of Law Enforcement Bodies in the context of
the country visit, p. 1.
103
Information received from Hellenic Internal Affairs Agency of Law Enforcement Bodies in the context of
the country visit to Greece.
104
The GRECO report indicates that ‘further initiatives can be taken to maximise synergies and enhance
information exchange on best practice and lessons learned on the basis of the experience already gained by
the responsible bodies’. ‘Drawing on the experience gained in this area, further streamlining of the system
and better coordination are desirable’, GRECO Fifth Evaluation Round – Evaluation Report, p. 35.

13
submission process and to upgrade the IT platform for asset declaration and management by
the end of 2023105.

Provisions for the regulation of lobbying were adopted, but it is still early to assess their
implementation. Following the adoption in September 2021 106 of the new legislation on
transparency and accountability, five ministerial implementing decisions were issued for the
part concerning lobbying. The Ministry of Digital Governance is in the process of developing
a specific platform for the Lobbying Registry, which will be managed by the National
Transparency Authority107. The recently adopted law on lobbying does not mandatorily apply
to civil society organisations 108. In the context of Greece’s RRP, actions aimed to strengthen
the implementation of lobbying regulations (such as the development of the lobbying
registry) are expected to be developed by the end of 2023.

Measures on the integrity of civil servants continue to be taken forward, although the
conflict of interests system and integrity within the police are matters of concern. In
2021, the code of ethics and deontology was adopted for the personnel of the General
Secretariat for Citizenship within the Ministry of Interior as well as that for the Hellenic Food
Authority109. In 2021, the Ethics Committee of the National Transparency Authority
examined three cases and imposed a restriction on post-employment in one case110. The new
legislation on enhancing transparency and accountability regulates also the gift policy that
applies to the President of the Republic, the members of the Government and the Deputy
Ministers111. In December 2021, GRECO issued recommendations on matters of concern
related to managing conflicts of interest of persons entrusted with top executive functions 112,
including a post-employment regime113. In June 2022 a law was adopted, on the enhancement

105
These RRP actions aim to streamline the asset declaration process and eliminate excessive and unnecessary
burden on obligated persons for asset declarations.
106
‘Strengthening Transparency and Accountability of State Institutional Bodies’, Law n. 4829 of 10 September
2021. Input from Greece for the 2022 Rule of Law Report, p. 34.
107
Information received from the National Transparency Authority in the context of the country visit to Greece.
108
According to the Ministry of Justice, the law covers lobbying activities with remuneration. Associations,
civil society organisations and other types of non-professional interest representatives may register on a
voluntary basis and acquire the rights and obligations of professional lobbyists under the Law. Transparency
International Greece expressed concerns that the recently adopted law on lobbying does not apply to non-
professional lobbyists, such as associations, civil society organisations and other types of non-professional
interest representatives. Information received from the Ministry of Justice and Transparency International
Greece respectively, in the context of the country visit to Greece.
109
Additionally, a general code of conduct for officers in in local and regional governance is expected to be
published in 2022, in line with the milestone foreseen under the recovery and resilience plan. Information
received from the National Transparency Authority in the context of the country visit to Greece.
110
Written contribution received from the National Transparency Authority in the context of the country visit,
p. 6.
111
Supra, part B’ of law 4829/2021. Input from Greece for the 2022 Rule of Law Report, p. 37. NTA and the
Ministry of the Interior are drafting the ministerial implementing decisions. Information received from the
National Transparency Authority in the context of the country visit to Greece and written contribution from
the National Transparency Authority in the context of the country visit, p. 3.
112
By (i) removing decision-making power from the Prime Minister and enhancing the competences of the
General Secretariat for Legal and Parliamentary Affairs of the Presidency of Government; (ii) using
declarations of conflicts of interest for counselling purposes; (iii) making disqualification decisions available
to the public; (iv) articulating a complaint mechanism by the public or other institutions... GRECO Fifth
Evaluation Round - Evaluation Report, pp. 29.
113
The post-employment regime be reviewed in order to assess its adequacy and that it be strengthened by
broadening its scope in respect of persons with top executive functions. GRECO Fifth Evaluation Round -
Evaluation Report, p. 32.

14
of transparency for high level officials working at the Offices of Members of the Government
and General Secretaries in Ministries 114. It is too early to assess the effectiveness of this new
law. Moreover, GRECO recommended to address integrity in the Police force, including by
carrying out a comprehensive risk assessment of corruption in the Police; updating the Code
of Ethics for the Police; strengthening integrity checks during staff recruitment and to provide
for independent and effective investigation into police complaints 115. In the context of
Greece’s RRP, actions aimed to review policies and provisions on conflict of interests are
expected to be implemented by the end of 2024 116.

Greece lacks a comprehensive legislative framework for the protection of

whistleblowers 117 and has yet to transpose the Directive on the protection of
whistleblowers 118. The Committee tasked to develop a draft law on the protection of
whistleblowers submitted the draft legislation to the Minister of Justice at the end of 2021
which is planned to be posted for public consultation in July 2022119. NGOs criticised their
non-involvement since the early phase of development of this draft law 120. The OECD has
recently urged Greece to implement new legislation for whistleblowers, for cases of foreign
bribery121. GRECO recommended Greece to strengthen the protection of whistleblowers
within the Police122.

Specific actions to counter the risk of corruption during the COVID-19 pandemic
continued to be implemented. In June 2021, the Hellenic Single Public Procurement

114
‘System of evaluation in view of enhancing the efficiency of the public administration’, Law 4940/2022. The
law aims to ensure integrity and accountability for high-level officials, including political advisors, by the
publication of their data, and by clarifying their obligations, impediments and incompatibilities, including
post-employment restrictions.
115
GRECO Fifth Evaluation Round – Evaluation Report, pp. 42-57.
116
Actions include development of policy framework, guidelines, toolkit for practitioners; the establishment of
a national network of Integrity Advisors in the Public Administration.
117
Whistleblower protection exists in administrative law for the protection of civil servants against retaliation
and in criminal law for the protection of ‘public interest witnesses’ in penal cases. 2021 Rule of Law
Reports, country chapter on the rule of law situation in Greece, p. 9.
118
Directive (EU) 2019/1937 on the protection of persons reporting on breaches of Union law, p. 17. The
deadline for the transposition of the Directive into national law expired on 17 December 2021. The Draft
Law has been submitted to the General Secretariat for Legal and Parliamentary Affairs of the Presidency of
Government.
119
Input from Greece for the 2022 Rule of Law Report, p. 40 and written contribution from the Ministry of
Justice in the context of the country visit, p. 3.
120
Information received from Transparency International Greece in the context of the country visit to Greece.
However, the Ministry of Justice of Greece argues that the Transparency International Greece was invited to
submit in writing its proposals, comments or other feedback as to specific points of the Directive so as to be
taken into consideration by the members of the legislative committee. Despite this invitation, the NGO did
not submit any relevant proposal or other material. Information received from the Ministry of Justice in the
context of the country visit to Greece.
121
OECD (2022), Implementing the OECD Anti-Bribery Convention, Phase 4 Report, Greece, p. 5. The OECD
report indicated that ‘To date, no foreign bribery cases have been detected through whistleblower reporting
in Greece and the situation for whistleblowers remains precarious. During the on-site visit, civil society and
private sector representatives cited the fear of retaliation and the negative perception of whistleblowers, due
to historical reasons, as the main reasons for the lack of whistleblower reporting. Recent reports about
alleged retaliation against the whistleblowers in the Pharmaceutical company case, and attempts to unveil
their identity, have caused greater damage to the perception of whistleblowers and have had an additional
deterrent effect on those who could potentially report allegations of corruption and foreign bribery’.
122
GRECO Fifth Evaluation Round – Evaluation Report, pp. 42-57.

15
Authority (HSPPA) issued guidelines123, with the aim of facilitating and assisting the work of
contracting authorities in the correct implementation of the legislation, so as to avoid risks of
corruption124. To the same end, the collaboration continues among the NTA, the SDOE, and
HSPPA. In 2021, 21 targeted audits were performed on specific cases 125.

III. MEDIA PLURALISM AND FREEDOM

The Greek legal framework regulating media pluralism is established by the Constitution and
specific sectorial legislation. The Greek Constitution provides for freedom of expression and
press freedom126. It also provides for a right of access to information. Restrictions to this right
may be imposed only insofar as they are absolutely necessary and justified for reasons of
national security, combating crime or protecting the rights and interests of third parties.
Legislation transposing the Audiovisual Media Services Directive has been in place since
February 2021127.

There have been no significant changes to the legal framework regulating the media
regulator and concerns remain with regard to its financial capacity and human
resources. The Constitution guarantees the independence of the main media regulatory
body128, the National Council for Radio and Television (NCRTV). According to Law
4779/2021129, NCRTV enjoys full operational independence from the government and from
any other public and private body. Moreover, the NCRTV exercises ‘its responsibilities
impartially and transparently’130. Although the law implementing the Audiovisual Media
Services Directive assigns new tasks and responsibilities to the NCRTV, there have been no
additional financial or human resources allocated 131 which would improve the effective
functioning and monitoring duties of the media regulator 132. Understaffing has been
highlighted as a matter of concern in a recent publication issued by the European Audiovisual
Observatory and the European Platform of Regulatory Authorities (EPRA) 133. For these
reasons, the Media Pluralism Monitor (MPM 2022) considers the independence and
effectiveness of the media authority to be an area of medium risk. 134 Concerning operating
licencing, according to the legislation in place 135, the NCRTV issues free-to-air terrestrial
digital TV licences. The duration of each licence is 10 years. Each licence is granted for the
purposes of a free-to-air terrestrial digital broadcasting and therefore the terms of its use
cannot be modified by the licensee 136.

123
N.27 of June 2021.
124
Input from Greece for the 2022 Rule of Law Report, p. 42.
125
Information received from the National Transparency Authority in the context of the country visit to Greece.
126
Article 14.
127
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 9. Greece ranks 108th
in the 2022 Reporters without Borders World Press Freedom Index, compared to 70th in the previous year.
128
Constitution of Greece, Art. 15(2).
129
Article 33(1).
130
Article 33(2) of Law 4779/2021.
131
The Greek Government requested the NCRTV to submit an action plan indicating resources and technical
equipment needed for the new enhanced tasks.
132
Information received from the NCRTV in the context of the country visit to Greece.
133
IRIS Plus (2021), Joint publication of the European Audiovisual Observatory and the EPRA: ‘Media
regulatory authorities and the challenges of cooperation’, p. 36.
134
2022 Media Pluralism Monitor, country report for Greece, p. 10.
135
‘Licencing operators…’, Law 4339/2015.
136
Input from Greece for the 2022 Rule of law Report, p. 56.

16
The Greek Government has taken some steps to strengthen transparency of media
ownership. Legal safeguards to ensure transparency of media ownership consist in Law
4779/2021137 which stipulates that media service providers shall register in the NCRTV’s
Business Register. A recently adopted Law includes obligations for the newspapers to
expressly indicate the ownership structure and the legal representatives 138.Media legislation
contains safeguards to prevent a high degree of horizontal concentration in the media sector.
The MPM 2022 indicates a medium risk for news media concentration 139.

The allocation of state advertising raises some concerns. The lack of transparency in the
distribution of state subsidies to media outlets was highlighted by both the Media Freedom
Rapid Response (MFRR) fact-finding mission to Greece140 and the 2022 Media Pluralism
Monitor (MPM 2022)141, pointing in particular to the non-transparent allocation of state
funding for a health awareness campaign during the COVID-19 pandemic. A parliamentary
inquiry was launched in November 2021, to investigate the funding of media outlets by the
Government in this context. The competent body of the Hellenic Parliament, established on
12 November 2021, stated that the campaign was assigned on objective standards such as
quantitative criteria on audience viewing, circulation, affinity indexes on target groups as
well as qualitative criteria such as brand safety. However, the detailed information on the
implementation of the public contract concerning the criteria used for the distribution of
funds and the amount received by the different media have not been entirely disclosed 142. A
request demanding the disclosure of the detailed award criteria filed by a non-profit
organisation143 was tacitly rejected by the authorities. In February 2022 the Administrative
Court of Appeal of Athens found this rejection to be unlawful and ordered that the case be
referred back to the administration144. Following the Administrative Court of Appeal’s
decision, the National Transparency Authority (NTA) examined the appeal and concluded
that the non-profit organization could not establish a legal right to access the required
documentation145.

Legal safeguards are in place to ensure the independence of Greek public service media
(ERT), however there are concerns with regards to potential political influence in the
appointment of the board members. The Greek public service media is regulated by the
Law on the Hellenic Radio and Television which provides that ERT is a limited liability
company belonging to the public sector and supervised by the State 146. The governing Board
of ERT comprises seven members: the President, the Managing Director, two representatives
of ERT’s employees (one of whom shall be a journalist) and three members with specialised
knowledge and expertise, appointed for a five-year term which can be renewed once 147. The

137
Article 3 of Law 4779/2021.
138
‘National Strategic Plan on the fight against corruption’, Law 4915/2022, Article 110.
139
2022 Media Pluralism Monitor, country report for Greece, p. 12.
140
Media Freedom Rapid Response (2022), ‘Controlling the Message: Challenges for independent reporting in
Greece – key findings from the Media Freedom Rapid Response (MFRR online fact-finding mission to
Greece)’, p.12.
141
2022 Media Pluralism Monitor, country report for Greece, p. 14.
142
Media Freedom Rapid Response (2022), Controlling the Message: Challenges for independent reporting in
Greece – key findings from the Media Freedom Rapid Response (MFRR online fact-finding mission to
Greece)’, p. 12.
143
Greek non-profit organisation Vouliwatch.
144
Decision no.56/2022 of the Administrative Court of Appeal of Athens.
145
Decision 16647/7.6.2022 of the Administrative Court of Appeal of Athens.
146
‘Regulating the Greek Radio-Television SA’, Law 4324/2015, of 29 April 2015.
147
Ibid, Article 9.

17
members of the Board are appointed by the Minister responsible for the media after the
Committee on Institutions and Transparency of the Parliament has given its opinion on the
Minister’s recommendation148. This procedure raises concerns as regards the independence
from the Government and potential political influence, as indicated by the MPM 2022, which
considers this to be an area of high risk149. Safeguards against arbitrary dismissals are in
place150. The monitoring of compliance with program obligations and principles is under the
responsibility of the NCRTV, which publishes an annual report on ERT’s compliance with its
obligations.

Attacks and threats against journalists persist151 and journalists’ professional

environment has deteriorated further. Since the 2021 Rule of Law Report, 16 alerts have
been published for Greece on the Council of Europe’s Platform to promote the protection of
journalism and safety of journalists 152. They range from physical attacks 153 to threats and
arbitrary detainment. Journalists also continue to face criminal lawsuits 154 in the form of
accusations and lawsuits for defamation or violation of one’s privacy and exposure of
personal data155. It was moreover reported that one Greek journalist has been targeted by
spyware surveillance software equivalent to Pegasus (Predator)156, while another journalist
was allegedly monitored by the national intelligence service (EYP) 157. The Media Freedom
Rapid Response (MFRR) fact-finding mission to Greece highlighted legal threats as a
significant problem for media freedom in Greece, including Strategic Lawsuits Against
Public Participation (SLAPP)158 targeting mostly government-critical outlets and journalists
who report on corruption159. Such legal threats can lead to self-censorship and pose an
additional economic risk to Greek media outlets and journalists who are already under-
resourced160. Moreover, respect for professional standards is not effectively guaranteed 161.

148
Ibid and input from Greece for the 2022 Rule of Law Report, p. 55.
149
2022 Media Pluralism Monitor, country report for Greece, p. 15.
150
‘General Staff Regulation of ERT’, Decision 3150/11.3.2020 of the ERT Board, Articles 23-40.
151
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 10.
152
Council of Europe, Platform to promote the protection of journalism and safety of journalists, Greece.
153
The murder of journalist Giorgos Karaivaz in April 2021 is under investigation by the authorities in Greece,
and little official information has been made public.
154
Two recent alerts concern two Journalists who faced criminal conspiracy charges linked to their reporting on
the Novartis case and the ‘Lagarde list’. The journalists were subsequently acquitted.
155
Contribution from Reporters without Borders for the 2022 Rule of Law Report, p. 18.
156
The Greek authorities replied to this alert on 16 June 2022 highlighting that ‘the Greek authorities do not use
the specific software described in these complaints. The Greek State does not trade with any of the
companies that manufacture or market such software’ and ‘the National Transparency Authority has rightly
intervened on its initiative to investigate the matter’.
157
Council of Europe, Platform to promote the protection of journalism and safety of journalists, Greece
158
In November 2021, a Strategic Lawsuit Against Public Participation targeted against the independent media
outlet Alterthess.gr and its journalist Stavroula Poulimeni by a Greek gold mining executive convicted of
serious environmental crimes, raised serious concerns. See contribution from Reporters without Borders for
the 2022 Rule of law Report, p. 20.
159
The Media Freedom Rapid Response (MFRR) online fact-finding mission to Greece took place between 1
and 15 December 2021 and was led by the European Centre for Press and Media Freedom joined by
representatives of MFRR partners ARTICLE 19, the European Federation of Journalists (EFJ), the
International Press Institute (IPI), the Osservatorio Balcani e Caucaso Transeuropa (OBCT), and a
representative of Reporters without Borders (RSF).
160
Media Freedom Rapid Response (2022), ‘Controlling the Message: Challenges for independent reporting in
Greece – key findings from the Media Freedom Rapid Response (MFRR online fact-finding mission to
Greece)’, p. 5. According to the Greek authorities, following a request from the Ministry of Justice the
National School of Judges has already successfully completed 2 mandatory seminars on SLAPP for all
judges, magistrates, prosecutors and the candidate judges.

18
The Greek Government has recently signed a ‘Memorandum of Understanding on the
protection, safety and empowerment of journalists and other media professionals’, which
contains a common framework of cooperation among the different ministries including the
preparation of proposals for legislative and non-legislative initiatives to ensure the protection
of journalists 162. The MPM 2022 has highlighted the deteriorating conditions faced by
journalists as an issue presenting an increased risk 163. Concerns have been expressed about
the risks for the right of journalists to disseminate information of general interest deriving
from new legislation amending Article 191 of the Greek Criminal Code 164 aiming at
preventing the spread of disinformation. The new provision stipulates that whoever, publicly
or through the internet, creates or distributes in any way, fake news that may provoke anxiety
or fear in citizens, or shake citizens’ trust in the national economy, or public health, is
punishable by a prison sentence of at least three months and a fine. Several associations and
interlocutors interviewed by the MFRR fact-finding mission have expressed serious concerns
with regard to this provision165.

IV. OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES

Greece is a parliamentary democracy with a unicameral Parliament. The separation of powers

is enshrined in the Constitution with legislative power vested in the Parliament and the
President. The right to introduce legislation belongs to the Parliament and the Government 166.
All courts, irrespective of their position in the judicial hierarchy, can review the
constitutionality of legislation and are bound to disapply a law whose content they deem
contrary to the Constitution 167. There are a number of national independent authorities,
organisations and institutions that aim to protect and safeguard human rights, including the
Greek National Commission for Human Rights accredited with A status by the Global
Alliance of Human Rights Institutions 168.

Work on improving the quality of the legislative process continues, but stakeholders are
often left with insufficient time to comment on draft legislation. The Committee for the
Evaluation of the Quality of the Law-making Process169, assessed 49 legislative proposals –
out of 100 – in the last two years focusing mainly on checking the compatibility of the draft
laws with the Constitution and EU law, ensuring the coherence of the drafts, in particular as
regards the relevance of the subjects provided for 170 and that the impact assessment is

161
Contribution from Reporters without Boarders for the 2022 Rule of law Report, p. 18.
162
The Memorandum of Understanding, initiated by the Secretariat General for Communication and Media
with the participation of five competent ministries, was signed on 23 May 2022.
163
2022 Media Pluralism Monitor, country report for Greece, p. 10.
164
‘Revision of the criminal code…’ , Law 4855/2021, 12 November 2021.
165
Contribution from RSF, and from the European Center for Press and Media Freedom (ECPMF) for the 2022
Rule of law Report, p.10 and p. 19 respectively. Media Freedom Rapid Response (2022), ‘Controlling the
Message: Challenges for independent reporting in Greece – key findings from the Media Freedom Rapid
Response (MFRR online fact-finding mission to Greece)’, p. 21.
166
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 11.
167
Greek Constitution, Article 93, paragraph 4.
168
Website of the Global Alliance of Human Rights Institutions, https://ganhri.org/. See Chart of the status of
national institutions – Accreditation status as of 27 April 2022
https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/StatusAccreditationChartNHRIs.pdf.
169
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 11.
170
Often legislative proposals in various sections include subjects not related to the main subject.

19
accurate and factually relevant 171. The Central Codification Committee 172 continued its work
with the codification173 of a number of legislative texts with the adoption by the Parliament of
four codes and the elaboration of four draft codes. Currently, the Committee is working on
the elaboration of 20 additional codes 174. In addition, the Greek authorities have reported that
the practice of last-minute amendments submitted to Parliament very close to the end of the
parliamentary debate is almost eliminated 175, although civil society organisations (CSOs),
including professional associations, often complain not to receive draft legislation in a timely
manner176. According to the European Network of National Human Rights Institutions, there
is extensive use of the expedited legislative process by the Government, by which many laws
have been adopted 177. This process could significantly restrict the discussion in Parliament
and the timely consultation of stakeholders. The Government is trying to minimise this
practice despite the circumstances created by the COVID-19 pandemic178. The quality of law-
making is an important factor for investor confidence and a reason for concern about
effectiveness of investment protection for 50% of companies in Greece 179.

The Ombudsperson is working on strengthening the capacities of the institution and its
international cooperation. The Ombudsperson submitted proposals to the Government in
December 2021 aiming at further ensuring the autonomy of the Ombudsperson to recruit his
own staff and at securing the independence of his budgetary resources, in line with
recommendations of the Venice Commission180. In parallel, and in order to not rely only on
the State budget, in November 2021, the Ombudsperson started implementing a project under
171
Information received from the Committee for the Evaluation of the Quality of the Law-making Process in
the context of the country visit to Greece.
172
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 11.
173
The Ministry of Digital Governance is running the project of the National Portal for Codification and Reform
of Greek Legislation, which will be the electronic hub of codified legislation, available free of charge to the
public. The project will also include the platform through which all the law-making and regulatory flows
will be standardised, the codification will be facilitated, and the operation of the competent authorities will
be supported. The project is expected to be completed in October 2023.
174
The four adopted Codes are: 1) Code of legislation for the protection of antiquities and cultural heritage in
general (Law 4858/2021), 2) Code of legislation on the financing of political parties (Decree 15/2022), 3)
Code of legislation for the maritime policy in the island area (Law 4832/2021) and 4) Code of
Administrative Procedures of the Hellenic Police (Decree 103/2021). Written input from the Central
Codification Committee in the context of the country visit to Greece. In addition, the Ministry of Digital
Governance has created the ‘Special Administrative Codification of urgent regulatory measures to prevent
and limit the spreading of coronavirus COVID-19 and to deal with relevant problems’, which contains all
COVID-19 regulatory measures in a consolidated form.
175
In 2017, 74% of all amendments were last minute amendments; in 2021 they were reduced to 11% and the
trend continues in the first three months of 2022 with only 2%. 2021 Rule of Law Report, Country Chapter
on the rule of law situation in Greece, p. 11; written contribution from the Secretariat General of Legal and
Parliamentary Affairs in the context of the country visit to Greece, p. 2.
176
Contribution from the Association of Judges and Prosecutors for the 2022 Rule of Law Report, pp. 11, 12,
17; Contribution from the European Network of National Human Rights Institutions for the 2022 Rule of
Law Report, Greece, p. 290; information received from the Ombudsperson in the context of the country visit
to Greece.
177
Contribution from the European Network of National Human Rights Institutions for the 2022 Rule of Law
Report, Greece, p. 290.
178
Written contribution from the Secretariat General of Legal and Parliamentary Affairs in the context of the
country visit to Greece, p. 2.
179
Figure 55, 2022 EU Justice Scoreboard indicates that ‘Frequent changes in legislation or concerns about
quality of the law-making process’ is a significant reason for concerns about effectiveness of investment
protection among companies in Greece.
180
Venice Commission opinion (CDL-AD(2019)005), paragraphs, 21 and 22; Information received by the
Ombudsperson in the context of the country visit to Greece.

20
the programme ‘Good Governance, Institutions and Transparency’ of the European
Economic Area Financial Mechanism. Overall, the project focuses on strengthening the
capacities of the Ombudsperson both as regards his human resources and the infrastructure.
The final aim of the programme is the capacity of the Ombudsperson to further reduce
maladministration in the public sector 181. Given the relevance of migration and asylum in
Greece, the Ombudsperson intervenes on these issues and recently published an own
initiative report on allegations of pushbacks 182.

On 1 January 2022, Greece had 34 leading judgments of the European Court of Human
Rights pending implementation183. At that time, Greece’s rate of leading judgments from
the past 10 years that remained pending was at 35%, and the average time that the judgments
had been pending implementation was 6 years and 5 months 184. The oldest leading judgment,
pending implementation for 18 years, concerns the access to and the efficient functioning of
justice due to the lack and the delayed enforcement of domestic judicial decisions 185. On 1
July 2022, the number of leading judgments pending implementation has decreased to 30186.

The requirements for the registration of CSOs specifically active in the area of asylum,
migration and social inclusion187 continue to raise concerns and the issue is pending
before the Council of State. The 2021 Rule of Law Report188 noted concerns regarding the
ability of CSOs active in these areas to operate in Greece and to receive financial support in
light of the rules on the registration and certification introduced in 2020. Three appeals are
pending before the Council of State challenging some aspects of the legality of legislation on
the registration of CSOs189. All these cases were set to be heard by the Plenary Session of the
Council of State on 3 June 2022 but have been postponed to early December 2022190.

New legislation raises expectations as regards support to CSOs civil society organisation
in general, although doubts are expressed by some CSOs on some modalities of the new
registration procedure. A new law which entered into force in April 2022 191 aims at

181
With the participation of the European Union Agency for Fundamental Rights (FRA), the budget of this
project is EUR 1 938 million. Website of the Ombudsperson and information received from the Ombudsman
in the context of the country visit to Greece. For the website of the Ombudsperson see
https://www.synigoros.gr/en.
182
Greek Ombudsman (2022), ‘Special report of the Ombudsman on returns of third-country nationals 2021’.
183
The adoption of necessary execution measures for a judgment by the European Court of Human Rights is
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group
cases against a State requiring similar execution measures, particularly general measures, and examine them
jointly. The first case in the group is designated as the leading case as regards the supervision of the general
measures and repetitive cases within the group can be closed when it is assessed that all possible individual
measures needed to provide redress to the applicant have been taken.
184
All figures are calculated by the European Implementation Network and are based on the number of cases
that are considered pending at the annual cut-off date of 1 January 2022. See Contribution from the
European Implementation Network for the 2022 Rule of Law Report, p. 46.
185
Judgment of the European Court of Human Rights of 27 March 2003, Satka and Others v. Greece, 55828/00,
pending implementation since 2003.
186
Data according to the online database of the Council of Europe (HUDOC).
187
2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, pp. 12-13.
188
Ibid.
189
Ibid.
190
Input from Greece for the 2022 Rule of Law Report, p. 66.
191
Adopted on 16 December 2021, ‘Protection of volunteering, strengthening the action of the Civil Society,
tax incentives for the strengthening of the public benefit action of the CSOs and other provisions’, Law
4873/2021.

21
supporting all types of CSOs. The law establishes a new database and a public registry for
CSOs, introduces state financial support and tax exemptions, and provides monetary
incentives to private actors in order to encourage donations to CSOs. While it is not
mandatory for CSOs to register in the new database and registry, only registered
organisations benefit from the tax exemptions and may request state financial support. The
registration is subject to certain conditions and administrative requirements which aim at
strengthening transparency but some modalities have been criticised as overly cumbersome,
especially for smaller CSOs which lack the necessary administrative capacity 192. The result is
that the civil society space is considered to be narrowed 193. More than 300 CSOs signed a
statement194 before the adoption of the law urging the Government to reconsider its rationale.
They argue that the law impinges on the independence of CSOs, creates an uneven playing
field and a two-speed civil society, to the detriment, in particular, of smaller and newly
formed CSOs, and fails to establish an appropriate framework for the interaction of state and
civil society195. While the Ombudsperson has a generally positive position on the new
legislation, in particular as regards transparency, the Ombudsperson considers that the
concerns of some CSOs related to the requirements for registration could be cumbersome for
smaller entities196. In addition, following a new law of 4 September 2021 197, CSOs providing
services in areas within the competence of the Hellenic Coastguard, especially NGOs
engaged in search and rescue missions at sea, have the obligation to act only after prior
authorisation of the Hellenic Coastguard. If the NGOs in question do not respect this
obligation, the responsible persons face penalties that could entail a custodial sentence up to
one year198.

192
Contribution from the European Union Agency for Fundamental Rights for the 2022 Rule of Law Report,
‘legal environment and space of civil society organisations in supporting fundamental right and the rule of
law’, Greece, p. 6.
193
Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressed
and closed. Civicus (2022), Monitor tracking civic space-Greece.
194
Franet (2022), Country research – legal environment and space of civil society organisations in supporting
fundamental rights – Greece, p. 6; Higher Incubator Giving Growth & Sustainability (HIGGS) (2021), ‘Joint
Statement of 303 organisations on the new bill on CSOs’.
195
Contribution from European Civic Forum for the 2022 Rule of Law Report, Greece, p. 3.
196
Information received from the Ombudsperson in the context of the country visit to Greece.
197
‘Revision of expulsion proceedings …. ‘, Law 4825/2021 (Article 40).
198
The criminalisation of certain rescue at sea activities of CSOs has been criticised by the Ombudsman (in his
annual report published on 31 December 2021)..

22
Annex I: List of sources in alphabetical order*

*The list of contributions received in the context of the consultation for the 2021 Rule of Law report
can be found at https://ec.europa.eu/info/publications/2022-rule-law-report-targeted-stakeholder-
consultation_en.
Administrative Court of Appeal of Athens, decision no. 56/2022.
Association of European Administrative Judges (2022), Contribution from the Association of
European Administrative Judges for the 2022 Rule of Law Report.
Association of Judges and Prosecutors (2022), Contribution from the Association of Judges and
Prosecutors for the 2022 Rule of Law Report.
Association of Judges and Prosecutors (2022), Press release of 8 April 2022 ‘Outcome of meeting
with the Minister of Justice regarding the new Code on the organisation of the courts and the status of
judges and prosecutors’ (‘Τα αποτελέσματα της συνάντησης με τον Υπουργό Δικαιοσύνης για τον νέο
Κώδικα Οργανισμού Δικαστηρίων και Κατάστασης Δικαστικών Λειτουργών’)
https://ende.gr/%ce%b4%ce%b5%ce%bb%cf%84%ce%b9%ce%bf-
%cf%84%cf%85%cf%80%ce%bf%cf%85-%cf%84%ce%b1-
%ce%b1%cf%80%ce%bf%cf%84%ce%b5%ce%bb%ce%ad%cf%83%ce%bc%ce%b1%cf%84%ce%
b1-%cf%84%ce%b7%cf%82-%cf%83%cf%85%ce%bd%ce%ac/.
Centre for Media Pluralism and Media Freedom (2021), Media pluralism monitor 2021 – country
report for Greece.
Centre for Media Pluralism and Media Freedom (2022), Media pluralism monitor 2022 – country
report for Greece.
CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States.
Civicus (2022), Monitor tracking civic space-Greece https://monitor.civicus.org/country/greece/.
Council of Bars and Law Societies of Europe (CCBE) (2022), Written contribution from the Council
of Bars and Law Societies of Europe for the 2022 Rule of Law Report in the context of the country
visit.
Council of Europe: Committee of Ministers (2010), Recommendation CM/Rec(2010)12 of the
Committee of Ministers to member states on judges: independence, efficiency and responsibilities.
Council of Europe, Platform to promote the protection of journalism and safety of journalists –
Greece https://fom.coe.int/en/alerte?years=2022&typeData=1&time=1653914309287.
Council of Europe: Venice Commission (2019), Principles on the Protection and Promotion of the
Ombudsman Institution (the Venice Principles) (CDL-AD(2019)005).
Council of State (2022), Contribution from the Council of the State for the 2022 Rule of Law Report.
Council of State (2022), Code of Conduct (Χάρτης Δεοντολογίας των Δικαστικών Λειτουργών του
Συμβουλίου της Επικρατείας)
http://www.adjustice.gr/webcenter/portal/ste/pageste/epikairotita/anakoinwseis?contentID=SNEWS-
TEMPLATE1648040999911&_afrLoop=31807212245395061#!%40%40%3F_afrLoop%3D3180721
2245395061%26centerWidth%3D65%2525%26contentID%3DSNEWS-
TEMPLATE1648040999911%26leftWidth%3D0%2525%26rigthWidth%3D35%2525%26showFoot
er%3Dfalse%26showHeader%3Dtrue%26_adf.ctrl-state%3Djsbrkd45o_446.
Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23 October 2019 on the
protection of persons reporting on breaches of Union law, OJ L 305.
Directorate-General for Communication (2019), Flash Eurobarometer 482: Businesses' attitudes
towards corruption in the EU.
Directorate-General for Communication (2020), Special Eurobarometer 502: Corruption.

23
Directorate-General for Communication (2022), Flash Eurobarometer 507: Businesses' attitudes
towards corruption in the EU.
Directorate-General for Communication (2022), Special Eurobarometer 523: Corruption.
European Civic Forum (2022), Contribution from the European Civic Forum for the 2022 Rule of
Law Report.
European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation
in Greece.
European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation
in Greece.
European Commission (2022), Report on the implementation of the Recovery and Resilience Facility.
European Commission (2022), EU Justice Scoreboard.
European Commission (2022) Enhanced Surveillance Report, Greece.
European Court of Human Rights, judgment of 27 March 2003, Satka and Others v. Greece,
55828/00.
European Court of Human Rights, judgment of 9 March 2021, Bilgen v Turkey, 1571/07.
European Implementation Network (2022), Contribution from the European Implementation Network
for the 2022 Rule of Law Report.
European Network of Council for the Judiciary (ENCJ), Development of Minimal Judicial Standards
III - Minimum Standards regarding evaluation of professional performance and irremovability of
members of the judiciary – Report 2012-2013
https://www.encj.eu/images/stories/pdf/workinggroups/final_report_encj_project_minimum_standard
s_iii_corrected_july_2014.pdf.
European Network of National Human Rights Institutions (2022), Contribution from the European
Network of National Human Rights Institutions for the 2022 Rule of Law Report.
Franet, Centre for European Constitutional Law (2022), Country research - Legal environment and
space of civil society organisations in supporting fundamental rights – Greece, Vienna, EU Agency
for Fundamental Rights https://fra.europa.eu/en/publication/2022/civic-space-2022-update#country-
related.
Global Alliance of Human Rights Institutions (2022), Chart of the status of national institutions –
Accreditation status as of 27 April 2022
https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/StatusAccreditationChartNHRI
s.pdf.
Greek Government (2022), Input from Greece for the 2022 Rule of Law Report.
Greek Ombudsman (2021), Annual report 2021 (Η ετήσια έκθεση του Συνηγόρου του Πολίτη για το
2021) https://www.synigoros.gr/?i=stp.el.annreports.945511.
Greek Ombudsman (2022), Special report of the Ombudsman on returns of third country nationals
(Ειδική Έκθεση Συνηγόρου του Πολίτη για τις Επιστροφές Αλλοδαπών 2021)
https://www.synigoros.gr/el/category/default/post/special-report-2021-on-returns-of-third-country-
nationals.
GRECO (2020), Fourth Evaluation Round – Second Compliance Report on Greece on preventing
corruption in respect of members of parliament, judges and prosecutors.
GRECO (2022), Fifth Evaluation Round – Evaluation Report on Greece on preventing corruption
and promoting integrity in central governments (top executive functions) and law enforcement
agencies.

24
Higher Incubator Giving Growth & Sustainability (HIGGS) (2021), Joint statement of 303
organisations on the new bill on CSOs (Κοινή Δήλωση 303 Οργανώσεων για το νέο Νομοσχέδιο της
ΚτΠ) https://higgs3.org/koini-dilosi-287-organoseon-gia-to-neo-nomoschedio-tis-ktp/.
Hellenic Internal Affairs Agency of Law Enforcement Bodies (2022), Written contribution from the
Hellenic Internal Affairs Agency of Law Enforcement Bodies for the 2022 Rule of Law Report in the
context of the country visit.
IRIS plus (2021), Joint publication of the European Audiovisual Observatory (EAO) and the
European Platforms of Regulatory Authorities (EPRA) - Media regulatory authorities and the
challenges of cooperation https://rm.coe.int/iris-plus-2021en2-media-regulatory-authorities-and-the-
challenges-of-c/1680a55eb1.
Media Freedom Rapid Response (2022), Controlling the Message: Challenges for independent
reporting in Greece – key findings from the Media Freedom Rapid Response (MFRR online fact-
finding mission to Greece) https://www.mfrr.eu/controlling-the-message-challenges-for-independent-
reporting-in-greece/.
Ministry of Justice, Presentation summary of the Intergrated Judicial Management System for
Administrative Justice (Σύνοψη παρουσίασης για το Ολοκληρωμένο Σύστημα Διαχείρησης Δικαστικών
Υποθέσεων για τη Διοικητική Δικαιοσύνη) https://www.ministryofjustice.gr/?page_id=3014.
Ministry of Justice (2022), Written contribution from the Ministry of Justice for the 2022 Rule of Law
Report in the context of the country visit.
National Audiovisual Regulator (ERT), General Staff Regulation of ERT, Decision 3150/11.3.2020.
National School of Judges (2022), Curriculum for the 28th cohort of trainees in the administrative
justice orientation (Πρόγραμμα Σπουδών 28ης Σειράς Διοικητικής Κατεύθυνσης)
https://www.esdi.gr/wp-content/uploads/2022/03/2o_stadio_dioik28cc-1.pdf.
National School of Judges (2022), Curriculum for the 28th cohort of trainees in the civil and criminal
justice orientation and magistrates orientation (Πρόγραμμα Σπουδών 28ης Σειράς Κατευθύνσεις
Πολιτικής-Ποινικής Δικαιοσύνης και Ειρηνοδικών) https://www.esdi.gr/wp-
content/uploads/2022/03/1_stadio_28poleir.pdf.
National School of Judges (2022), Curriculum for the 28th cohort of trainees in the prosecution service
orientation (Πρόγραμμα Σπουδών 28ης Σειράς Κατεύθυνση Εισαγγελέων) https://www.esdi.gr/wp-
content/uploads/2022/03/1o_stadio_eisagg28.pdf.
National Transparency Authority (2022), Written contribution from the National Transparency
Authority for the 2022 Rule of Law Report in the context of the country visit.
OECD (2022), Implementing the OECD Anti-Bribery Convention, Phase 4 Report Greece
https://www.oecd.org/daf/anti-bribery/Greece-Phase-4-Report-EN.pdf.
Public Prosecutor’s Office (2022), Contribution from the Public Prosecutor’s Office for the 2022 Rule
of Law Report.
Regulation (EU, Euratom) No 883/2013 concerning investigations conducted by the European Anti-
Fraud Office (OLAF).
Reporters without Borders – Greece https://rsf.org/en/country/greece.
Reporters without Borders (2022), Contribution from Reporters without Borders for the 2022 Rule of
Law Report.
Secretariat General of Legal and Parliamentary Affairs (2022), Written contribution from the
Secretariat General of Legal and Parliamentary Affairs for the 2022 Rule of Law Report in the
context of the country visit.
Transparency International (2022), Corruption Perceptions Index 2021.

25
United Nations Office on Drugs and Crime, Bangalore Principles of Judicial Conduct
https://www.unodc.org/pdf/crime/corruption/judicial_group/Bangalore_principles.pdf.

26
Annex II: Country visit to Greece

The Commission services held virtual meetings in March 2022 with:

• Athens Bar Association

• Central Codification Committee
• Committee for the Evaluation of the Quality of the law-making process
• Committee of Parliament for the Investigation of Declarations of Assets (CIDA, or
Committee 3-A).
• Council of State
• Court of Audit
• Greek Association of Judges
• Greek Bar Association
• Hellenic Internal Affairs Agency of Law Enforcement Bodies
• Journalists’ Union ESIEMTH
• Ministry of Justice
• National Audiovisual Regulator
• National School of Judges
• National Transparency Authority
• Ombudsman
• PRAKSIS
• Prosecutor for Financial Crimes and the Financial Police Division
• Prosecutor's Office to the Supreme Court
• Refugee Support Aegean
• Supreme Court
• Transparency International Greece

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

• Article 19
• Civil Liberties Union for Europe
• Civil Society Europe
• European Centre for Press and Media Freedom
• European Civic Forum
• European Federation of Journalists
• European Partnership for Democracy
• European Youth Forum
• Free Press Unlimited
• Human Rights Watch
• ILGA Europe
• International Federation for Human Rights (FIDH)
• International Press Institute
• Open Society European Policy Institute ( OSEPI)
• Osservatorio Balcani e Caucaso Transeuropa
• Philea
• Reporters Without Borders
• Transparency International Europe

27