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Improvement of the Open Deliberation Procedure (GR0036)



Action Plan: Greece National Action Plan 2016-2018

Action Plan Cycle: 2016

Status: Inactive


Lead Institution: Ministry of Interior& Administrative Reconstruction – Sector of Administrative Reform & E-Government – for the regulatory framework / National School of Public Administration and Local Government-for the technical and operational part. Alternate Minister of Interior& Administrative Reconstruction– due to reform issues, President of the National School of Public Administration And Local Government

Support Institution(s): NA

Policy Areas

Capacity Building, E-Government, Legislation & Regulation, Public Participation, Regulatory Governance

IRM Review

IRM Report: Greece Mid-Term Report 2016-2018, Greece End-of-Term Report 2016-2018

Starred: No

Early Results: Did Not Change

Design i

Verifiable: Yes

Relevant to OGP Values: Civic Participation

Potential Impact:

Implementation i



Context The electronic platform for the network annotation of suggested acts ( initiated at October 2009 aiming at the publication and the annotation of any plan of body of laws (in separate space that was created for every ministry in prior to their submission in the parliament. Civilians and organizations are lodging annotations, proposals and views, article to article, in order all these to be gathered and be estimated by the public bodies that are being responsible for the each time law deliberation. This effort has been outstripped with the legislative enactment of basic terms for the public deliberations by the law 4048 (gps 34/23-02-2012). More specifically, in the 6th article of this law, are determined the means by the expression “The deliberation is obtained by the publication, with the use of appropriate means, of the planned regulation, aiming at the timely information and the participation of the civilians, social bodies and everybody concerned” and by the phrase “The deliberation of any draft of law is becoming also through the web site”. Still, it is appointed that “The obliged for the deliberation procedure actuation is the minister with the initiative act”. In addition, as the law dictates, the deliberation is conducted in two phases that may take place simultaneously. 1. The first phase of the deliberation lasts two weeks at least. The deliberation’s object is the information and the allowance for annotation potentiality with regard to the objective and the pursued result of the planned regulation, the alternative choices, the cost, the benefits and the risks that may appear due to the deliberation itself. 2. The second phase lasts three weeks at least. During the second phase of the deliberation, a draft of the bill terms is posted at the web site and the potentiality of an article to article annotation is allowed. In case that a draft of terms is existed, the first phase is omitted with the initiative of the due minister and the second phase is getting prolonged to one more week. 3. The deliberation may be interrupted or abbreviated or time prolonged, with the initiative of the due minister for adequately documented reasons, which are mentioned at the report for the public deliberation that accompanies the regulation. 4. The Bureau of Legislative Initiation, of the due Ministry, compose a report for the public deliberation, in which the comments and suggestions by the civilians took part at the deliberation, are presented in groups and their incorporation or non - incorporation is documented at the final terms. The report accompanies the regulation during its reposition at the Parliament, is posted at the web site that the deliberation took place and is sent by email to the accounts that the comments came from. The above that law dictates, are deemed as sufficient in legislation regard, in relation to the draft of the law. Still, there is a need for legislative intervention within the frame of a public deliberation provision and other documents of public interest such as draft supplies proclamations, decisions and technical specs. According the above and taking into consideration the noticed glitch: There is no adequate information of the stakeholders with regard to the law, There is no adequate information with regard to the duration obligation, There is no flexibility for a ministry, to hook up directly a deliberation, The participants have no trust in the consideration(or not) of their comments It must legislatively be anticipated that there will be potentiality for deliberations and other normative acts, draft contracts, According the above, are suggested: The conduct of training seminars for the information of the stakeholders in regard to the law 4048 (gps 34/23-02-2012), The conduct of hands-on-training seminars for the stakeholder ministries officers, in terms of the use of the relative platform, to gain the ability to hook up draft of laws on behalf of the ministries, as well as the editing of relative accompany reports and documents. In order the function of the open deliberation to be more effective and its role not to be impoverished in the mind of people and in the legislative procedure, this is why a strong demand is the improvement of its characteristics. Commitment Description Enhancement of the bill deliberation procedure in all levels (institutional, legal, operational, technical). The Enhancement of the deliberation procedure between other things will include improvements at the following sectors: Stipulated consolidation of the methodology and of the obligation for rational response, in bounded time limits. For these two stages there will be for the 1st one, specialization and criteria institution and method for the procedure with bounded time frame and for the 2nd one there will be documented response for the incorporation (or not) of the citizens’ comments into the bill’s text with boundary time frame and enact of methodology. Institutional: Enhancement of the existing institutional framework with information and training of the stakeholders. The officers of the ministries to be trained so as these stakeholders to hook up the deliberations of the ministries Technical: The electronic platform must comprise the central point of information and conduct of deliberations for the whole spectrum of the public sector. Also the mechanisms for the deliberations diffusion must be reinforced. Operational: o Entry of new methodology deliberation code that will stand for all public bodies. o Appointment of good practices. Deliberation analysis for those of great deal of participation. o Identification of deliberations and submitted bills. There must be connection between the deliberation that was realized and the final bill (there will also be included array of results with suggestions derived from the public deliberation and were taken into consideration). Adoption of the same deliberation codes and of article codes of voted bills for the direct correlation. o Improvement of the pattern for the deliberation report. o Development and comments response with a particular methodology and rational reply for every comment, for its accession or not in the bill and in specific time. o Development of toolkit for the estimation of the public deliberation on the ground of documented criteria by the side of the expedited ministry. o A semester evaluation of the deliberations o Training and development of the officers Adoption of mechanisms for the approach and mobilization of the civilians. At this procedure will be pursued the engagement of bodies by the society of the citizens. o Structured communication with all the groups of interest. Gradual deliberations accession in regional and domestic level (municipalities) in matters concerning the everyday life of the citizen. OGP Values Participation of the civilians, accountability, technology and innovation for transparency Implementation Bodies Implementation: Ministry of Interior& Administrative Reconstruction – Sector of Administrative Reform & E-Government – for the regulatory framework / National School of Public Administration and Local Government-for the technical and operational part. Alternate Minister of Interior& Administrative Reconstruction– due to reform issues, President of the National School of Public Administration And Local Government Objectives For the complete function of the Open Deliberation it stands as necessity the enactment of specific methodology and the specific consolidation of time boundaries of the pre-legislative and the deliberation for the bill. In this way the Open Deliberation will be able to more effective, implementing more complete its purpose. The Enhancement of the democratic institutions in the consciousness of the citizens and the openness of the state during the legislative procedure induces total improvement at the consolidation of the constitutional rights. The politics for Openness are served if the institutional tools function effectively and the more complete function of the Open Deliberation helps to the diffusion of the Openness. Means for the implementation The regulatory regulations for the achievement of the commitment will be contributed by the Ministry of Interior& Administrative Reform, the Ministry of Interior& Administrative Reform – Sector of Administrative Reform & E-Government and the technics and operational regulations by the National School of Public Administration and Local Government.

IRM End of Term Status Summary

Commitment 1 and 6: Regulatory Reform

Commitment 1. Framework law on Open & Participative Governance  

Commitment Text:

Drafting and submission of a bill to Parliament for an Open and Participative Governance in view of a comprehensive regulation of the relevant issues and the promotion of the respective policies.

Responsible Institution(s): Ministry of the Interior and Administrative Reform- division of Administrative Reconstruction & e-Government, Alternate Minister for Reform, Deputy Secretary General

Supporting Institution(s): None

Start Date:  July 2016 End Date: March 2018

Commitment 6. Improving of the Open Deliberation procedure

Enhancement of the bill deliberation procedure in all levels (institutional, legal, operational, technical).

Responsible Institution(s): Ministry of Interior & Administrative Reform – Sector of Administrative Reform & E-Government – for the regulatory framework; National School of Public Administration and Local Government.

Start Date:  July 2016 End Date: December 2017

Editorial Note: Commitment text has been abridged by the IRM. To see the full action plan, please refer to

Commitment Aim:

1. Framework law on Open & Participative Governance

This commitment aimed to address a recurring theme regarding the coordination of open government policies in Greece by putting forward a binding legal mandate. At the time this commitment was adopted, the government relied on a small team within the Ministry of Administrative Reform that in most cases reported directly to the Minister.[Note 14: Nancy Routzouni, national point of contact, IRM researcher interview, 7 August 2017.] The government sought to improve the ownership of the action plan formulation and implementation by creating a new law that would encompass OGP commitment proposals by different government departments and civil society. The government also aimed to cover the day-to-day management of OGP processes, commitment implementation overview and production of self-assessment reports.[Note 15: Ibid.] A permanent multi-stakeholder forum that would facilitate a regular dialogue process and submission of comments and opinions was also considered a priority to be included in the legal text.[Note 16: Despina Mitropoulou, General Director of Open Technologies Alliance (GFOSS), telephone interview with IRM researcher, 5 May 2017.]

The law would cover:

  • Open meeting rules at the subnational level;
  • Establishment of advisory, multi-stakeholder working groups at each agency;
  • Establishment of an inter-ministerial working group on governance; and
  • Digital transparency on personnel and administrative actions.

6. Improving of the Open Deliberation Procedure

This commitment aimed to improve the legal, technical and operational aspects for online consultations between ministries and citizens on draft bills. It would try to achieve this by amending the relevant legal framework on good legislative practices.[Note 17: “Improving the production rules of the legislative work and, consequently, the quality of the legislation produced”, Law 4048/2012 (in Greek), ] At the time of the adoption of this commitment, although the existing legal framework promoted transparency and public consultation via certain processes (e.g. providing for specific stages and timeframes), it did not set specific means to address deviations from the procedure itself.

This commitment would provide guidance on how deliberation stakeholders are defined; training of government officers involved in the deliberation process; and guidelines on how public consultations should be conducted, including outlining standards for a “reasoned response” to public inputs during policy making.


Commitment 1. Framework law on Open & Participative Governance

Midterm: Limited

According to the action plan timeline the law should have been passed in March 2017. By the end of the mid-term assessment period, the law preparation committee had been created and had held two discussions on the content of the law. During the midterm assessment the government had not yet presented the new law in parliament for voting and thus the commitment was behind schedule. According to the Ministry of Administrative Reconstruction (MAR) OGP team,[Note 18: Nancy Routzouni, national point of contact, response to IRM researcher questionnaire, 26 September 2018.] there was insufficient inter-ministerial coordination to finalize the draft. Some ministries could not identify how to introduce the collaborative model into their operations. The MAR shared a first version of the drafted law document with the IRM researchers. However, the online public consultation and the parliamentary discussion on the draft law were still pending. For more information, please see the 2016-2018 midterm report on the Greek action plan. [Note 19: OGP, “Independent Reporting Mechanism (IRM) Progress Report 2016–2018: Greece”,]

End of term: Limited

Based on the IRM researchers’ monitoring of the parliamentary website section on new legislation[Note 20: Hellenic Parliament – Submitted Draft Bills website (in Greek),] no draft legal act for open government was introduced. Additionally, no draft text has been made available on the online consultations website.[Note 21: Open Government Consultations website (in Greek),] According to IRM interviews carried out in June 2018 with the General Director of MAR[Note 22: Nikos Michalopoulos, General Secretary for Open Government, Ministry of Administrative Reconstruction, IRM researcher interview, 23 June 2018.], the framework law has ceased being a priority for the Ministry due to limited human resources.[Note 23:  Ibid.] Some of the work completed by the inter-ministerial team on the preparation of a legal text on open government is available online after the IRM researchers requested this.[Note 24: Greek government deliberation website (in Greek), IRM researchers were observing the workings of the law drafting committee] According to the national point of contact for OGP, the update of the decision on the design and drafting of legislation for the promotion of Open and Participatory Governance policies is still pending because most of the involved ministries have not yet formed the required internal open government working groups.[Note 25: Nancy Routzouni, national point of contact, response to IRM researcher questionnaire, September 2018.] For these reasons the IRM researchers consider that although some progress had been made by the end-of-term period, the completion level remained limited.

Commitment 6. Improving of the Open Deliberation Procedure

Midterm: Limited

During the midterm evaluation there was no indication that the government would put forward a plan to revise the legal framework concerning public participation in drafting laws (Law 4048/2012). The National Center for Public Administration continued to provide technical support, user training and operational coordination to public employees from all ministries involved in online public consultations.[Note 26: Dimitris Tsimaras, National Center for Public Administration, interview with IRM researcher, Athens, September 2017.] For more information, please see the 2016-2018 midterm IRM report on the Greek action plan.[Note 27: OGP, “Independent Reporting Mechanism (IRM) Progress Report 2016–2018: Greece”,]

End of term: Limited

The National Center for Public Administration continues to use the pre-existing deliberation methodology. Open deliberation on draft laws takes place regularly in the platform. The IRM researchers reviewed recent deliberations and observed that a new mechanism to report the consultation results to participants is not yet available.[Note 28: consultation platform, examples of recent consultations can be viewed (in Greek),

: and] Transparency International Greece also indicated the lack of an online feature that provides feedback to participants regarding the consultation results.[Note 29: Dr. D. Rigopoulos, Associate at Transparency International Greece, interview with IRM researcher, Athens, 21 November 2017.] There is no evidence on the parliamentary legislation website[Note 30: Hellenic Parliament – Submitted Draft Bills (in Greek),] that MAR has moved forward with its plans to amend the regulatory framework needed to improve the process. Since there is no further government action planned to improve the open deliberation procedure the implementation of this commitment remained limited.   

Did It Open Government?

Commitment 1. Framework law on Open & Participative Governance

Access to Information: Did Not Change

Civic Participation: Did Not Change

Since the implementation of this commitment was limited and there was no change in the legal framework, it has not resulted in any changes in government practice on access to information and citizen participation.

Commitment 6. Improving of the Open Deliberation Procedure

Civic Participation: Did Not Change

Since the implementation of this commitment was limited and there was no change —neither in the legal framework nor in the consultation guidelines— it has not resulted in any change of government practice on civic participation.

Carried Forward?

MAR representatives[Note 31: Ibid.] indicated that these commitments will not be carried forward into the next action plan. Although MAR representatives and the national point of contact had indicated to IRM researchers that a new action plan would be developed[Note 32: Ibid.], the Greek government had not released a concrete timeline at the time of writing this report. The IRM researchers recommend the government to publish the draft work carried out on the framework law on open government, to specify the necessary legal amendments and assign a timeframe for online, in person and parliamentary consultation.[Note 33: OGP, “Independent Reporting Mechanism (IRM) Progress Report 2016–2018: Greece”,



  1. Open Education Data

    GR0065, 2019, Access to Information

  2. Open Rural Development Data

    GR0066, 2019, Access to Information

  3. Open Immigration Data

    GR0067, 2019, Access to Information

  4. Open National Defense Data

    GR0068, 2019, Access to Information

  5. Open Ministry of Interior Data

    GR0069, 2019, Access to Information

  6. Open Administrative Reconstruction Data

    GR0070, 2019, Access to Information

  7. Open Economic Data

    GR0071, 2019, Access to Information

  8. Open Local Government Data

    GR0072, 2019, Access to Information

  9. Open Justice Data

    GR0073, 2019, Access to Information

  10. Open Environmental Data

    GR0074, 2019, Access to Information

  11. Open Culture and Sports Data

    GR0075, 2019, Access to Information

  12. Sports whistleblower platform

    GR0076, 2019, Anti-Corruption

  13. Open data from Ministry of Culture & Sports

    GR0077, 2019, Access to Information

  14. Publish anonymized open agricultural data

    GR0078, 2019, Access to Information

  15. Promoting open agricultural data to interested stakeholders

    GR0079, 2019, E-Government

  16. Citizen participation for update of Digital Transformation Bible

    GR0080, 2019, E-Government

  17. Monitoring platform for action plan

    GR0081, 2019, E-Government

  18. Amend EETT regulation

    GR0082, 2019, Access to Information

  19. Framework Law on Open & Participative Governance

    GR0031, 2016, Capacity Building

  20. Participation in the Assessment of the Public Sector

    GR0032, 2016, Capacity Building

  21. Publicity of Organisational Charts & Entities of the Public Sector

    GR0033, 2016, E-Government

  22. Accountability and Settlement of Disputes Between the Citizens and the Public Sector

    GR0034, 2016, Legislation & Regulation

  23. Guide and Standardization for the Provision of Services & for Procedures Per Service/Entity

    GR0035, 2016, Capacity Building

  24. Improvement of the Open Deliberation Procedure

    GR0036, 2016, Capacity Building

  25. National Register of Line Managers of the Public Administration (Register)

    GR0037, 2016, Capacity Building

  26. Implementation of the Assessment of Employees and Services and Control Methods

    GR0038, 2016, Capacity Building

  27. Implementation of a System for the Selection of Managers

    GR0039, 2016, Capacity Building

  28. Digital Repository for Pubic Administration Studies

    GR0040, 2016, Capacity Building

  29. Provision of Open Cultural Data

    GR0041, 2016, Access to Information

  30. Geospatial Maritime Data

    GR0042, 2016, Access to Information

  31. Ship/Company and Seafarer Registers

    GR0043, 2016, Access to Information

  32. Marine and Maritime Activity

    GR0044, 2016, Access to Information

  33. Starred commitment Public Property Open Data

    GR0045, 2016, Access to Information

  34. KPI’s for the Implementation of Public and EU Financed Projects

    GR0046, 2016, E-Government

  35. Data and Statistics for Greek National Exams

    GR0047, 2016, E-Government

  36. Protocol Digitization

    GR0048, 2016, E-Government

  37. Informative Actions on Open Data for Young People in Secondary and Higher Education

    GR0049, 2016, Access to Information

  38. Open Education

    GR0050, 2016, Access to Information

  39. Provision of Open Data for Justice

    GR0051, 2016, Access to Information

  40. Enhanced Statistical Data of Justice Open to the Public

    GR0052, 2016, E-Government

  41. Open Provision of Geo-Data

    GR0053, 2016, Access to Information

  42. Open-Participatory Budget

    GR0054, 2016, Access to Information

  43. Regional Council Platform (Open Regional Council)

    GR0055, 2016, E-Government

  44. Open - Participatory Budget

    GR0056, 2016, E-Government

  45. Capture and Evaluation Platform for Regional Technical Projects

    GR0057, 2016, E-Government

  46. City Dashboard

    GR0058, 2016, Access to Information

  47. Online Consultation Platform

    GR0059, 2016, E-Government

  48. Open Data Index for Cities and Local Administrations

    GR0060, 2016, Access to Information

  49. Linked, Open and Participatory Budgets

    GR0061, 2016, E-Government

  50. School of Data for Public Servants

    GR0062, 2016, Access to Information

  51. The Collaborative Wikification of Public Services Procedures

    GR0063, 2016, Capacity Building

  52. Strengthening Openness and Accessibility of the Parliament

    GR0064, 2016, Access to Information

  53. Institutional and Technological Upgrading of Transparency Program

    GR0012, 2014, Access to Information

  54. Public Participation in Decision Making

    GR0013, 2014, Capacity Building

  55. Integration of PSI Directive on the Re-Use of Public Sector Information

    GR0014, 2014, Access to Information

  56. Regulatory Amendments for the Management and Provision of Open Data

    GR0015, 2014, Access to Information

  57. Implementation of Platform for Central Distribution of Public Open Data

    GR0016, 2014, Access to Information

  58. Provision of Open Geospatial Data

    GR0017, 2014, Access to Information

  59. Provision of Open Cultural Data

    GR0018, 2014, Access to Information

  60. Provision of Open Data for Offshore Companies

    GR0019, 2014, Access to Information

  61. Open Provision of Public Sector Critical Data Sets

    GR0020, 2014, Access to Information

  62. Open Invitations for Filling Posts in the Public Sector

    GR0021, 2014, E-Government

  63. Public Administration Organizational Chart Publication

    GR0022, 2014, Capacity Building

  64. Coordination and Monitoring of Open Government Policy

    GR0023, 2014, Anti-Corruption

  65. Reorganization of Inspectorate Bodies and Strategic Alliance Development Against Corruption

    GR0024, 2014, Anti-Corruption

  66. Tracking Changes on Bills (From Submission to Voting by Plenum)

    GR0025, 2014, E-Government

  67. Usability and Functionality Improvements of the ‘Parliamentary Transparency’ Section of the Hellenic Parliament Website

    GR0026, 2014, E-Government

  68. Improvement of the Hellenic Parliament Website and Implementation of New Standards-Technologies

    GR0027, 2014, Access to Information

  69. Provision of Historical Parliamentary Documents to the Public

    GR0028, 2014, E-Government

  70. Enhancement of Social Media Policy in the Hellenic Parliament

    GR0029, 2014, E-Government

  71. On Line Provision of Exhibitions

    GR0030, 2014, Capacity Building

  72. Increase Number of Legislative Acts Going Through Online Deliberation

    GR0001, 2012, Legislation & Regulation

  73. Capitalize on Citizen Comments and Suggestions

    GR0002, 2012, Public Participation

  74. Operate Central e-Procurement Information System

    GR0003, 2012, Anti-Corruption

  75. Operate Central ERP Information System

    GR0004, 2012, E-Government

  76. Operate Central HRMS Information System

    GR0005, 2012, E-Government

  77. Open Data Regarding Prices, as Collected by Prices Observatory

    GR0006, 2012, Access to Information

  78. Resolve Legal Issues Regarding State Geo-Data

    GR0007, 2012, Land Rights & Spatial Planning

  79. Offer Additional Taxation Data

    GR0008, 2012, Fiscal Openness

  80. Augment Functionality of the Transparency Program

    GR0009, 2012, E-Government

  81. Publicise Public Sector Procurement Information

    GR0010, 2012, Anti-Corruption

  82. Enable Open, Transparent and Safeguarded Document Circulation

    GR0011, 2012, E-Government

Open Government Partnership