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List of 48 Prior Actions Greece needs to implement asap to get €2bn (PART I)

The long and winding road that leads to a 2-billion-euro bailout disbursement. The Euro Working Group agreed on Friday on …not one, not ten, not twenty… but forty eight (48) prerequisites (prior actions_ that Greece has to implement in the next two weeks in order to receive the first trance of the 3.bailout package totaling 86 billion euro.

The long list contains mainly so-called “structural reforms” that have been due since 2010 and 2012. That is when the first and the second bailout adjustment programs (Memorandum of Understanding) were singed between the Troika and the Papandreou/Papadimos/Samaras governments. And a little more…

The catalog of Things to Do is a long list of legislation acts that need to pass through the Parliament and secure the future of among others: banks subsidiaries, changes in the pensions and supplementary pensions schemes, liberalization of the energy market, finalization of the privatization of the regional airports to Fraport, “red loans”, tax evasion and fraud, ‘tightening’ of the Law for the protection of primary residence, some OECD toolkits like “opening of pharmacists” professions. Or some weird things like “penalties for not correct prescription of medicine” or “transfer of Financial Crime Units to Public revenues secretariat” or .

I write weird because I don’t know why these legislations should be a precondition for the 2-billion-euro tranche payment.

The EWG list of the 48 prior actions will be taken up and most likely approved as such at the Eurogroup meeting tomorrow Monday.

If these are the prior actions for 2 billion euro I wonder what are the terms & conditions for the remaining  €84 billion bailout to come to Greece in the next three years. EU Monetary Affairs Commissioner Pierre Moscovici heralded already that “more measures will be needed.” Of course.

According to Greek daily Naftemporiki the full list of prior actions includes:

Prior Actions Part I Number 1. to 24

1. Banks: Completion of the strategy for the financial system (normalization of liquidity and the payment conditions and strengthen bank capital, strengthen governance and tackle the problem of non-performing loans). This strategy, based on the Memorandum of Undestanding , will include projects related to foreign subsidiaries of Greek banks in accordance with the restructuring programs that have been approved by the European Commission and aim to attract international strategic investments and return them to private ownership in medium-term.

2. The Bank of Greece will do all necessary steps in order to adopt the Code of Conduct.

3. Completion of the medium-term technical assistance program in cooperation with the European Commission.

4. Establishment of new criminal law provisions on tax evasion and fraud, in order to modify the specific Penal Law 2523/1997 and to replace Article 55, paragraphs 1 and 2 of KFD. Aimed are the modernization and enlargement the definition of tax fraud and evasion in all taxes. All penalties on Books & Date Records Code,  including those imposed by law 2523/1997 should be abolished.

5. Establishment of appropriate penalties for simple breaches of  Books & Data Records Code. Failure to issue receipt or the inaccurate receipt will be treated as a simple but serious breach of the Value Added Tax code of conduct.

6. Bank transactions – Tax office access: Issue a ministerial decision to expand the indirect register of banking transactions history up to 10 years.

7. Issue a ministerial decision to transfer the staff of the Financial Crime Units (SDOE) to the General Secretariat of Public Revenue.

8. The Bank of Greece and the Private sector will work out a plan to promote and facilitate the use of electronic payments and reducing the use of cash.

9. Adoption of additional legislation for the Financial Council.

10. Promote legislation to upgrade the budget law (establishing a framework for independent bodies, gradual abolition of ex ante controls by the Court of Auditors, etc.).

11. Presentation of a plan plan for liquidation of arrears, as well as for tax refund and pensions claims.

12. Agreement with the European Commission on an action plan on ‘public procurement’.

13. Extension over the next three years of the highest cap for 2015-refunds for diagnostic tests, private clinics and pharmaceutical products.

14. Preparations for the gradual implementation of the national guarantee minimum income (IEE), establishing a registry of benefits and a strategy to ensure the inclusion of vulnerable groups and to prevent fraud.

15. Approval of a roadmap for the reform of investment licensing, including the hierarchy of priorities.

16. Creation of three mobile teams of law enforcement to combat smuggling.

17. Convening of inter-ministerial planning committee, involving independent experts.

18. Issue Joint Ministerial Decision of the Justice and Finance Ministers to reduce the rate of remuneration for notarial acts for transactions values up to   120,000 euro (Ed .: the new rate should be 0.8% from 1% today) .

19. Additional review of the impact assessment of selected reforms relating to competition, licensing of investments and administrative costs.

20. Energy Reform: authorities will implement a scheme for temporary and permanent system of capacity payments; they will change the rules of the electricity market in order to prevent the enforced operation of the plants below their variable costs and will establish rules under the final decision of the State Council on the settlement of debts between the Public Power Company and the market operator. They will start implementing the natural gas market reform according to the agreed timetable, while prioritizing the distribution tariffs. They will implement interruptible contracts as approved by the European Commission. They will review the PPC tariffs based on costs, including replacement of the 20% discount for high voltage users.

21. Legislative approval of the restructuring program of ‘OASA – Athens Public Transportation’ as agreed with the institutions.

22. Develop a roadmap for the implementation of the revised Code of Civil Procedural Law.

23. Issue a Presidential Decree which will clarify the terms and details of the website through which auctions will be announced electronically.

24. Actions so that the Greek Statistics Agency (ELSTAT) gains gain access to administrative data sources in accordance with Article 17 of Law 4174/2013 as amended by Laws 4254/2014 and 4258/2014 and the Memorandum of Understanding signed on 04.17.2014 between ELSTAT , the Ministry of Finance , the Secretary-General of Public Revenue and the Private Sector Insurance Fund IKA.
source in Greek:

Prior Actions No 25-48 Part II Here


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  1. René Henri Pasche

    to “implement” in the next two weeks? Let us better say “initiate” i.e. make a beginning; set something going.

    • keeptalkinggreece

      don’t panic! implementation = legislation, I understand

      • René Henri Pasche

        “Management by objectives” seems to be the method applied here. So we have 48 objectives under the permanent control of the Euro Working Group (Monitoring/Controlling). At regular intervals the state of every objective will be examined and marked with a green, yellow or red dot. If the picture is not only red but chiefly green and yellow everybody will be happy.

  2. Did you see Konstantopoulous UN speech?

    NEVER forget that #thisisacoup

  3. Don’t worry ktg, it will only get worse and worse until you have lost everything. That’s the idea.

    That’s the price for voting “YES” “Tsipras” and “euro”, so everyone should be very very happy.