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Greece Action Plan Review 2022-2024

Greece’s fifth action plan includes promising commitments on lobbying regulation, whistleblower protection and open land administration data. While there were improvements to the co-creation process compared to the previous action plan cycle, the brief timeframe limited the opportunities for civil society organizations (CSOs) to develop the action plan with the government. Greater dialogue between government and civil society during implementation would strengthen the OGP process and help achieve stronger results.

AT A GLANCE

Participating since: 2011

Action plan under review: 2022–2024

IRM product: Action Plan Review

Number of commitments: 19

Overview of commitments:

Commitments with an open government lens: 19 (100%)

Commitments with substantial potential for results: 3 (15%)

Promising commitments: 5 (26%)

Policy areas:

Carried over from previous action plans:

  • Digital transformation
  • Whistleblowing protection
  • Public administration reforms
  • Open parliamentary data
  • Open data on migration

Emerging in this action plan:

  • Lobbying regulation
  • Local level engagement
  • Open land administration data

Compliance with OGP minimum requirements for co-creation: No

Greece’s fifth action plan contains 19 commitments covering transparency and accountability, anti-corruption, open data, public participation, and services for citizens and businesses.[1] Some commitments continue policy areas from previous action plans, such as digital transformation, access to information, open data, public administration reform, and open parliamentary data. A commitment on holding two public deliberations on the public participation platform of the municipality of Moschato-Tavros is also included.[2]

Promising commitments on lobbying regulation and whistleblower protection have modest potential for results. Commitment 7 would record and publish lobbying activities in the new online Transparency Register, lobbying statistics and any sanctions imposed. Commitment 8 would create an online platform for reporting whistleblowing on breaches of European Union (EU) law. While they address their thematic priorities, CSOs believe the commitments have a narrower scope of work than what they would have liked.[3] A cluster comprising Commitments 11–13 is also assessed as promising and has substantial potential for results. It could provide open, standardized, and accurate statistical data of land transactions, as well as georeferenced addresses and toponyms of high value, particularly in climate-related emergencies.

The Ministry of Digital Governance and a multi-stakeholder Focus Group oversaw the development of the action plan.[4] Ministry officials published an open invitation on the opengovmonitor.gr website for a workshop on open governance at the 12th Annual Conference e-Government Forum where participants could submit thematic ideas for further discussion as commitment proposals.[5] After the workshop, officials also posted an open call form for public proposals which would meet commitment criteria on opengovmonitor.gr.[6] The draft plan was published for public comments on the opengov.gr consultation website. Twelve CSOs set out their concerns about the co-creation process and the final action plan in a public letter sent via opengov.gr to the Minister of Digital Governance in December 2022.[7] A meeting organized with the minister to address the CSO letter occurred after the submission of the action plan to OGP. While the government produced reasoned response to the other comments received via opengov.gr, it was not shared with those stakeholders or made public before the submission of the action plan. Representatives from the Ministry of Digital Governance stated that publishing the reasoned response was paused until they held the meeting with the minister on the CSO letter.

Despite an improved process compared to the previous cycle, Greece did not meet OGP minimum requirements for co-creation because while reasoned response to proposals or input received from the participants of the co-creation process was developed, it was not shared with stakeholders or made public before the submission of the action plan. The government stated that civil society proposed most of the policy areas covered in the action plan.[8] It also acknowledged that the breadth of citizen and civil society participation in the OGP process was limited.[9] Some Focus Group members reported that the three-month timeline to co-create the action plan either did not provide adequate time to submit proposals and get feedback on meetings and proposals or fell short of involving diverse voices.[10] Through education and robust communication, the Ministry of Digital Governance wants to reestablish trust between the government and other stakeholders and broaden public participation in the co-creation and implementation of current and future action plans.[11]

Although the Focus Group was constituted for the purposes of the co-creation process, private sector participants expressed wish to continue their involvement in implementing and monitoring the action plan.[12] Civil society would like the Ministry of Digital Governance to clarify the role of the Focus Group during implementation and to provide a timeline for the changes to the group’s framework for overseeing implementation.[13] The Ministry of Digital Governance has stated it is working to develop a mechanism for ongoing dialogue with civil society during the implementation period.[14] The IRM recommends more regular updates to the website and repository, as well as regular dialogue with civil society and private sector stakeholders to oversee implementation of the plan, ideally through a multistakeholder forum.

The commitments not analyzed further in Section II have modest or unclear potential for results. Commitments 2–4 build on earlier commitments to improve access to parliamentary information, they offer only immediate technical solutions. Commitment 9 sets out Greece’s open data training framework but does not actually commit to training public officials. The potential of Commitments 15, 18, and 19 to generate results is unclear. Joint implementation of Commitment 14 by government and CSOs could reach the goal to improve transparency and accountability around organizations that receive state funding as well as Commitment 17 to encourage data reuse.[15]

Promising Commitments in Greece’s 2022–2024 Action Plan

The following review looks at one commitment and a cluster of three commitments that the IRM has identified as having the potential to realize the most promising results. Promising commitments address a policy area that is important to stakeholders or the national context. They must be verifiable, have a relevant open government lens, and have modest or substantial potential for results. This review also provides an analysis of challenges, opportunities, and recommendations to contribute to the learning and implementation process of the action plan.

Table 1. Promising commitments

Promising Commitments
Commitment 7: Lobbying Activity. This commitment seeks to ensure implementation of Greece’s lobbying regulation law 4829/2021 and compliance with the requirements of Greece’s recently-launched Transparency Register.
Commitment 8: Whistleblowing platform in accordance with EU Directive 2019/1937. This reform would implement an online whistleblowing reporting platform according to the requirements of the EU Whistleblower Directive (transposed in Greece as Law 4990/2022) that introduced common standards for the protection of whistleblowers.
Commitments 11–13: Open land administration data. This cluster of commitments looks to improve the data held by the Hellenic Cadaster. The actions would improve the quality and increase the quantity of data in relation to land transactions, as well as provide complete public datasets of georeferenced postal addresses and toponyms.

[1] “Greece Action Plan 2022–2024,” Open Government Partnership, 9 January 2023, https://www.opengovpartnership.org/documents/greece-action-plan-2022-2024-december, 6.

[2] While this is not the first time Greece has included a commitment to be implemented by a local municipality in its action plan, it is the first such commitment since the 2016–2018 action plan.

[3] Angelos Kaskanis (Transparency International Greece), interview by IRM researcher, 4 April 2023; Stefanos Loukopoulos (Vouliwatch), interview by IRM researcher, 29 March 2023.

[4] The multistakeholder working group comprised the Secretariat General for Coordination of the Presidency of the Government, the National Network of Technology and Research Infrastructure, the Central Union of Municipalities of Greece, GFOSS Open Technologies Alliance, Solidarity Now, Association of Businesses and Industries, Transparency International Greece, and Expertise France.

[5] “Invitation to a conference,” OGP Greece, updated 1 November 2022, https://opengovmonitor.gr/callforworkshop.

[6] These 12 criteria ranged from thematic relevance to open government, financial resources, responsibilities, and more as listed on: “Call for collaborative planning of the 5th national open government action plan,” OGP Greece, 31 October 2022, https://opengovmonitor.gr/callforcodesign/.

[7] “CSO letter to the Minister of Digital Development,” GFOSS Open Technologies Alliance, 19 December 2022, https://eellak.ellak.gr/wp-content/uploads/sites/23/2022/12/epistoli-organwsewn-ktp.pdf.

[8] Anastasios Papazarifis (OGP Point of Contact), written correspondence with the IRM, 6 April 2023.

[9] Presidency of the Government, written answer to the IRM, 30 April 2023.

[10] Alexandros Melidis (GFOSS Open Technologies Alliance), interview by IRM researcher, 28 March 2023; Lefteris Antoniadis (Solidarity Now), interview by IRM researcher, 12 April 2023; Athena Vounatsou and Maria Bozoudi (SEV Hellenic Federation of Enterprises), interview by IRM researcher, 12 April 2023.

[11] Papazarifis, written correspondence.

[12] Vounatsou & Maria Bozoudi, interview: “We would be eager to continue working on the plan. We would like to be part of this process throughout the implementation as well as start with the preparation, instead of a few months rush.”

[13] Antoniadis, interview.

[14] Ministry of Digital Governance, letter to the IRM during the pre-publication review, 2 August 2023.

[15] “Greece Action Plan 2022–2024,” Open Government Partnership, 18.

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