Greece: Provision of clarifications regarding persons required to submit Declarations of Assets (A.D.) and Declarations of Financial Interests (D.F.I.) pursuant to Article 14(d)

Pursuant to an informational note issued by the Audit Committee of the Hellenic Parliament on 10 February 2026, further clarifications were provided regarding the persons liable to submit a Declaration of Assets (A.D.) and a Declaration of Financial Interests (D.F.I.), where such persons relate to Legal Entities entering into public contracts (Law No. 5026/2023, Article 14(d)).

More specifically:

1. Only “executive” members of the Boards of Directors of Legal Entities entering into public contracts are considered liable to submit Declarations of Assets and Financial Interests.
2. Where a legal person is a principal shareholder, partner, or holds another critical capacity in a Legal Entity entering into public contracts, the obligation to submit Declarations of Assets and Financial Interests does not extend to the individuals associated with that legal person, unless expressly provided for by law.
3. Holding the position of Chairman of a Legal Entity entering into public contracts does not automatically entail an obligation to submit Declarations of Assets and Financial Interests, since the additional statutory conditions provided by law must also be met.
4. The deadline for the first (initial) submission of the Asset Declaration and the Declaration of Financial Interests starts at the time when:

a) a public contract is concluded for the first time, while the liable person already holds the capacity of principal shareholder, partner, or another critical capacity. or

b) the liable person acquires for the first time a “critical capacity” (e.g. Chief Executive Officer, member of the Board of Directors, shareholder, etc.), while a public contract is already in force.