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32 responses to “PART C AUDIOVISUAL PROJECT SUPPORT PROGRAMME IN GREECE: CASH REBATE GREECE (CRGR) (Articles 22-41)”

1. 

   7775

   May 15, 2026

   Dear Sir/Madam,

   the non-assignment of the Cash Rebate to entities other than the Greek banks is incorrect as the banks do NOT finance productions. Better yet, generally allow the rebate to be assigned in accordance with the applicable provisions on assignments. At the same time 1) prohibit the assignment to entities based in non-cooperative tax countries and 2) oblige them to collect the assigned claim only to EU banking institutions that have KYC/AML obligations similar to ours in Greece. This is in order to enable the State to ensure that the recipient/transferee has been checked for AML/KYC as the banks owe. It is noted that the privilege for Greek banks is a violation of EU law - a corresponding privilege for stamp duty was found unconstitutional and abolished.

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   📍 Allow the general assignment of the Cash Rebate to all entities 2 B.C.

   🟢 The current limited assignment is incorrect because banks do not finance productionsFact check

   🟢 Privilege for Greek banks violates EU law like stamp dutyFact check

   📍 Prohibition of assignment to entities based in non-cooperative tax countries 1 business

   🟢 Must be banned to ensure AML/KYC controlFact check

   📍 To oblige collection assignment only to EU banks with equivalent KYC/AML requirements 1 business

   🟢 Ensures the State can control AML/KYC as banks requireFact check

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2. 

   7777

   May 15, 2026

   In Article 26 ‘Integrated and non-investment projects’ in 2 (eligible costs), (a) increased from EUR 100 000 to EUR 200 000, thus excluding low-budget productions, which in Greece are many (other than 100 – 200 and another 200 – …), I propose that it be kept as it is. Also in (b) I think that the amount of sixty thousand (60,000) euros for Greek shorts is excessive and could go down to 40,000 euros. In (c) I propose that the mini-episodes of a TV series, such as abroad, be 6 to 8 and in (d) that 15 be the maximum episode limit per cycle.

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   📍 Keep unchanged the limit of 200.000 € in article 26 (a) 1 business

   🟢 Excludes low ‑budget productions, which are many in GreeceFact check

   📍 Reduction of the amount for Greek shorts to 40,000 euros 1 business

   🟢 The amount of 60,000 euros is excessiveFact check

   📍 The mini-episodes of a TV series should be 6–8 episodes 1 business

   🟢 According to practice abroadFact check

   📍 The maximum number of episodes per cycle is 15 0 business

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3. 

   7778

   May 15, 2026

   Gentlemen, sirs.

   -It is unacceptable for opengov.gr not to httpS.-

   A) Unclear description of the obligation of 3 minutes of material
   1) there is no dropping of beneficial material 2)maybe material making off;

   B)13 regional film offices.No special incentives, decentralization and quota are given.For Evros, Epirus in general the privileged areas.Which series will leave the "rule" 30km from the Constitution.It is not profitable,the expenses do not come out.

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   📍 HTTPS Requirement for opengov.gr 1 business

   🟢 The absence of HTTPS is considered unacceptableFact check

   📍 Clarification of the description of the obligation of 3 minutes of material 1 business

   🟢 Current wording is unclear and does not cover useful materialFact check

   📍 Incentives, decentralisation and quota for the 13 regional film offices 2 B.C.

   🟢 Currently no identified incentives or quotaFact check

   🔴 Proposal is not profitable and costs do not payFact check

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4. 

   7780

   May 15, 2026

   Right for the province but also incentives

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   📍 Proposal Adding Incentives 1 business

   🟢 This proposal is right for the provinceFact check

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5. 

   7784

   May 15, 2026

   In Article 26(2), the amounts defined as a minimum amount of eligible costs are unrealistic for Greek production:

   The 200,000 euros from 120,000 for a feature film (the moment most films are made with 20-50,000 euros and friendly participations).
   The 60,000 euros for shorts and documentaries (at a time when the majority of films are filmed with 10-20,000 euros).

   There are also no international mini-series of 16 episodes. The episodes for mini-series are 6 to 8 max.
   Even for 16 episodes we have a minimum of 120,000 euros but if someone does one more, ie 17 episodes, the cost falls to 30%) That's $35,000!! (Photographing specific production companies that work with specific TV channels that constitute the industry's oligopoly).

   Instead of the legislator setting qualitative funding criteria, as the main minister had promised in his interview with a Sunday newspaper, the old regime that over-indebted EKOME continues for the TV series.

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   📍 Reduction of the minimum amount of eligible costs for feature films 2 B.C.

   🟢 Most Greek feature films are made with 20‑50 km eurosFact check

   🟢 The current limit of 200 000 euros is unrealisticFact check

   📍 Reduction of the minimum amount for short films and documentaries 2 B.C.

   🟢 Most small films and documentaries are made with 10‑20 km eurosFact check

   🟢 The current threshold of 60 000 euros is excessiveFact check

   📍 Recognize small series (6‑8 episodes) as mini‑series and customize funding 2 B.C.

   🟢 Internationally there are no 16-episode mini‑series, but 6‑8Fact check

   🟢 The minimum of 120 000 euros for 16 episodes is unfairFact check

   📍 Introduction of quality funding criteria for TV series 2 B.C.

   🟢 The Minister promised quality criteria in an interviewFact check

   🟢 The existing system favors specific companies and overcharges EKOMEFact check

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6. 

   7789

   May 15, 2026

   The ASSOCIATION OF DIRECTORS CREATORS (ESD) had from the first moment strongly expressed its reaction to the ECC-EKOME Merger, with announcements and actions, informing the representatives of the parties but also the responsible parties themselves, with arguments and counter-proposals. What we see today justifies our original certainty: The bill eliminates the CySEC and pushes Greek Cinematic Art to the mercy of a market perception of culture.
   The critical role of the CySEC is eliminated, since there is no clear, binding, legal wording in the proposed draft law, with a distinct source of funding, for the enhancement of Greek Cinema, from the original idea of the creator, to the screening in the theaters. Although the Directorate-General for Cinema and the Directorate-General for Audiovisual, Technology and Creation are separate directorates, there is no dividing line in the ways and conditions of funding, identifying the television product with the film (GRGR-FTV).
   As an exclusive financing route, the cash rebate appears, i.e. Film Art is treated only as an investment incentive. At the same time, raising the limit of eligible costs to €200,000 for feature fiction and €60,000 for documentaries and short films - amounts that are outside the Greek reality - excludes access to the cash rebate, a large, critical part of the Greek audiovisual community, largely killing off the "nursery" of Greek production.
   There is a persistent imposition of a “policy for the domestic film sector” that will be shaped by the ministry and the government up to the respective CEO , without the participation and ignorance of the people of Greek Cinema. How is it possible to shape any positive and sustainable policy for Greek Cinematic Art, without the participation of the people who produce it and live from it?
   The director-creator, the dominant pillar of Greek Cinema, is not mentioned anywhere in the articles of the law, on the contrary, the limits of the budgets set, exclude him through the side road. Reading it, one feels that it is not a bill on culture, but on facilitating investment, in which cinema and audiovisual creation in general are not treated as art, but as a by-product of the tourism industry.
   It is a bill that continues to blatantly boost TV production by setting very low budget limits, especially for television productions over 17 episodes, while not daring to set a legal payment of 1.5.%) on turnover from nationwide television stations, as a necessary condition for the financial support of their producers.
   The creation of the digital repository, while it already exists in the responsibilities of EKOME, is being re-announced! While it is stated that the “delivery of the work does not give the Company exploitation powers”, it is not specified whether the works of the repository will be included in the national archive, for which it clearly provides for exploitation, which would circumvent the statutory copyright of audiovisual work creators at the risk of introducing the logic of buy out (one-off acquisition or assignment of rights) .
   The involvement of the new entity in education is also unclear, while it is doubtful whether labour rights and the impact of the training that is being advertised for professionals in the field have been taken into account, contrary to the long-standing demand of the whole sector for a university-level audiovisual arts school.
   In conclusion, we still find destructive and incomprehensible the insistence on merging two such different bodies, and our initial position is confirmed, that this is primarily an overt disappearance of the CySEC, the main institution supporting Greek Cinema.
   ASSOCIATION OF DEPARTERS OF CREATORS (NAS)

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   📍 Opposition to the proposed merger of EKK with EKOME 7 B.C.

   🟢 The bill eliminates the CySEC, harming Greek film artFact check

   🟢 Absence of a clear, binding legal provision for ECC fundingFact check

   🟢 Cash Rebate Restricts Access to a Large Audiovisual CommunityFact check

   🟢 Politics is shaped without the participation of the creators of Greek cinemaFact check

   🟢 Low budget limits exclude TV productions and lack enforcement measures 1.5%) turnoverFact check

   🟢 New digital repository may undermine copyright through buy‑outFact check

   🟢 Uncertainty in the integration of the new body in education and lack of an audiovisual arts schoolFact check

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7. 

   7790

   May 15, 2026

   No matter how well-meaningly one reads this diligently vague bill, one stumbles upon loopholes. First of all, there is no justification for the need for such a merger. Nothing prevents the government from implementing all that is announced, having two distinct bodies, and strengthening through the CySEC the field of new technologies and artificial intelligence, (the elephant in the room), since it correctly recognizes the new data in the space. Why is a labyrinthine bureaucratic super-agency created, with an unclear number of workers and a confused division of responsibilities?

   The creative part, from the funding of the idea with zero capital, to the completion of the film, remains suspended - it is characteristic that it is not named - unlike the cash rebate. Terms such as ‘preparing programmes and actions’, ‘ensuring’, ‘developing actions’ do not constitute a legally expressed commitment that there will be regular and adequate funding of films. Are there separate, secured and watertight sources of funding for Greek Cinema?
   And if we assume that there will be continuity in the funding of Greek films, will an author be able to receive funding for the same production from two different directorates of the same organization?

   Is there a limit to the amount that the cash rebate will have per year? What is it and how will it be implemented? Will the program close when the amount is covered and whoever manages to do so? Or will priority be given to projects?
   And this dazzling board of directors will have dire financial abilities, while at the same time, will it have the artistic capacity to weigh delicate decisions of cultural significance?

   Who is targeted by a cash rebate with 200,000 eligible for feature films, and 60,000 eligible for short films and documentaries? Because it is obvious that it offers nothing to the majority of Greek creators, who usually do not have even half of the amounts corresponding to such eligible. On the contrary, in television productions that have both secured funds and profits from advertising, the eligible ones fall to 35,000 and 25,000 respectively. What is the logical explanation for this?

   How much will this organization cost? Where will it be housed? How many will work, with what fees? The monthly salary of Heads of Directorates-General is only 5 200 (https://www.e-nomothesia.gr/kat-oikonomia/n-4972-2022.html), in a place where the creators fall. Why is it even involved in education, instead of the ministry responsible for education?
   What conceals the thoughtful formulation that overlooks the directors and omits that they are the driving force of Greek cinematographic (often television) production?
   After all, reading the bill leaves a sense that it does not refer to cultural creations, with multiple effects on society, but to an irrational business investment.

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   📍 Not to create a new super-body 2 B.C.

   🟢 Creates labyrinthine bureaucratic super-body with unclear responsibilitiesFact check

   🟢 No justification for the need for the mergerFact check

   📍 Add a legal commitment to regular film funding 2 B.C.

   🟢 Current wording does not ensure legal commitment of fundingFact check

   🟢 Funding remains unclear and non-nominalFact check

   📍 Prohibit double funding within the same organisation 2 B.C.

   🟢 Double funding can lead to misuse of resourcesFact check

   🟢 There is no clear regulation to avoid double fundingFact check

   📍 To set an annual ceiling for the cash rebate 2 B.C.

   🟢 Without limit, the program can be exhausted earlyFact check

   🟢 Transparency requires a fixed maximum amountFact check

   📍 To adjust the eligible cash rebate amounts for short and long 2 B.C.

   🟢 Current amounts (200k, 60k) are insufficient for a majority of creatorsFact check

   🟢 TV Movies Receive Lower Amounts, Creates InequalitiesFact check

   📍 Remove the organization's involvement in education 2 B.C.

   🟢 Education is the responsibility of the Ministry of Education, not the organizationFact check

   🟢 Mixing increases costs and bureaucracyFact check

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8. 

   7793

   May 15, 2026

   COMMENTS AND PROPOSALS OF THE ASSOCIATION OF INDEPENDENT AUDIOVISUAL PRODUCERS (SAPOE) IN THE DRAFT LAW OF THE MINISTRY OF CULTURE WITH TITLE
   ‘Creative Greece: strengthening the cinematographic, audiovisual and creative sectors, establishing a body for books and other provisions for contemporary culture’

   Article 22
   With regard to paragraph 2, we propose the following legislative adaptation:

   ‘2. The CRGR Support Program aims to enhance the production of audiovisual works in Greece and generally enhance economic growth, increase employment and promote the country as a destination for the implementation of investment projects in the audiovisual industry through the support of domestic and attracting international investments in this sector.

   Comments – Justification:
   In our view, for reasons of primarily legal-political consistency and the delimitation of the public interest in this case, it should be made clear, with the addition of an explicit reference, that the S/N aims a fortiori to enhance the production of audiovisual works in Greece, as moreover provided for in Law 4487/2017 (cf. Article 19 thereof and related references to the explanatory memorandum of Law 4487/2017). The above, moreover:
   the special nature of the aid under schemes (a) and (b) of the S/N Programme granted under, in particular, Article 54 of GBER 651/2014 for aid schemes for audiovisual works; and
   is fully in line with the request for certainty and legal certainty of the Entities as to the (actual) allocation of the budgeted amounts of total aid per year per aid scheme.

   In the context of point (b) above, please note that the S/N, like Law 4487/2017, is a specialised institutional tool for the continuous and effective support of the development of Greek audiovisual production, completely distinct from the thematic aid schemes of Law 4887/2022, which should not be treated exclusively as a means of providing occasional assistance to economic activity in general in Greece – this would call into question the compatibility of the aid granted with Article 54 of GBER 651/2014. This observation is inextricably linked to the unfortunate attempt, in our opinion, to fully harmonise the provisions of the S/N with those laid down in Law 4887/2017, as if the audiovisual industry is the 14th thematic regime of the development law, even though the CRGR Programme serves strategic objectives of public interest, beyond and outside the characteristics of a typical development law.

   With regard to paragraph 3, we would point out that ensuring, even indirectly, the constant and uninterrupted availability of the relevant amounts of aid to beneficiaries in depth is a conditio sine qua non for the effectiveness of the legislative framework to be adopted and for the successful attraction of international investment in the audiovisual production sector in Greece.

   It is well estimated that the perpetuation of uncertainty as to the substantial continuation of the Greek cash rebate in the next few years will reverse the growth path and extroversion of Greek audiovisual production, definitively undermining its prospects.

   Nevertheless, and aware of the objective impossibility of expressly providing for a specific annual minimum threshold of funds allocated per aid scheme, in order to assure Greek and foreign audiovisual production companies of the unwavering political will to support the audiovisual industry in Greece expressed through the S/S, consideration could be given to the provision of annual information by the Greek Centre for Cinema, Audiovisual Media and Creation S.A. on the total amounts of aid envisaged for the CRGR Programme each time in the Medium-Term Fiscal Strategy Framework, starting with the MTFS 2025 – 2028.

   Article 23

   With regard to paragraph 3, we would point out that the 1st or 2nd producer project has been omitted without there being a reasonable reason for this omission and contrary to the definitions in force to date. In addition, it should be noted that the threshold of EUR 500 000 is extremely low and does not correspond to the conditions and production conditions of cinematographic works in most EU Member States. Its increase from 500,000 to 1,000,000 euros is not only necessary but also in line with the GBER, as there is no doubt that it falls under the concept of "low budget".
   We therefore propose that paragraph 3 be amended as follows:
   ‘3. ‘Difficult Audiovisual Work’ means a stand-alone audiovisual work which fulfils at least one of the following conditions:
   (ha) The only original is in Greek. The use of other languages to a limited or limited extent does not negate the fulfilment of this condition;
   (hb) It is the first or second work of a director or producer;
   (hc) is a project with a budget of up to EUR 1 million (1 000 000);
   (hd) is a short film or documentary work;
   (he) has limited possibilities for commercial exploitation’.

   We propose the following amendment to paragraph 6:
   "…End of investment plan: the completion of the physical and financial object of the production works related to the investment, which is considered to occur on the date of the application for the appointment of a chartered accountant or auditing company, in order to start the process of certification of expenditure, referred to in the decision to include financing of the investment project. The end date of an investment plan may not exceed three (3) years from the start date of the investment plan, unless there has been an extension of the end time of the investment plan in accordance with Article 32(3)(c). c) of this Law.
   Comments – Justification: The substantive definition of the concept of the end of the investment project should be added, also in order to avoid requests for the appointment of a certified auditor/accountant on investment projects that are partially completed/not mature for audit.
   Furthermore, as regards the maximum duration of the investment plan, account should also be taken of any extension of its expiry time following an amendment in accordance with the procedure laid down in Article 32 of the S/N.

   In paragraph 7, the name of the Company is erroneously referred to as NATIONAL CINEMA CENTER etc. instead of the correct GREEK CINEMA CENTER etc.

   Article 24

   With regard to paragraph 2, we propose the following legislative adaptation:

   "…This limit is extended to sixty percent (60%) ) the eligible costs of the total cost of production of the audiovisual work in the case of cross-border production and 80 % (10080%) ) the eligible costs of the total cost of production of the audiovisual work in case of production of a difficult audiovisual work …'
   Comments – Justification:
   (i) The proposed regulation requires targeted adjustments since the intensity of all State aid is consistently calculated as a percentage of the total production costs of the aided audiovisual work and not (only) of the eligible costs of the investment project implemented in the Greek territory. Otherwise, the total amounts of State aid allowed per investment project will be dramatically reduced. Furthermore, to the extent that the proposed wording of Article 24(2)(ab) of the S/N goes back to and aims at incorporating the corresponding wording of EU General Block Exemption Regulation 651/2014 (‘GBER’) into Article 54(7) thereof, it should be noted that the GBER, for the purposes of calculating the maximum aid intensity for cross-border producers, in this case refers to the total eligible costs implemented in all Member States, i.e. the total production costs of the aided audiovisual work, and not individually to the eligible costs implemented per Member State. Therefore, the arrangement under consultation in Article 24(2) of the S/N should be amended so that the maximum aid intensity for cross-border production (60%) be calculated as a percentage of the total production cost of the audiovisual work, as expressly provided for under the current framework (cf. Article 27(4) of Law 4487/2017).

   (ii) With regard to the maximum aid intensity in the case of production of a difficult audiovisual work, in our view, it is reasonable to raise the ceiling to 100%) the total cost of production, instead of keeping it at the current level of 80%) , which will make a significant contribution to the development of this particularly demanding and technically sensitive category of audiovisual works. Please note that the above is fully in line with Article 54(7) of the GBER, which provides that the maximum aid intensity for difficult audiovisual works may amount to 100%) the (total in all Member States) eligible costs.

   Article 25

   With regard to paragraph 1, we propose the following amendment:
   ‘1. The investment projects for audiovisual works included for financing under the CRGR-FTV and CRGR-Animate schemes are supported through the provision of an investment incentive, which consists in the provision of a grant by the Greek State to cover part of the eligible costs of the investment project, which is calculated, after the certified end of the investment project, as a fixed percentage of forty percent (40%) ) on the value of the eligible production costs, as defined in paragraph 3 hereof. The amount of the aid shall be paid in a single payment to the beneficiary.’
   Comments – Justification: For reasons of legal accuracy and to ensure the tax treatment of the aid granted, it should be explicitly clarified that the aid consists in the free provision of a sum of money to the beneficiary, as provided for in Law 4487/2017. Furthermore, a reference should be included to the method of payment of the aid, which is an essential feature of the aid – to this end, the corresponding reference to Article 35 of the Income Tax Code is not sufficient. Moreover, in our view, where the Income Tax Code refers to a ‘grant’, the relevant term should be replaced by the terms ‘investment incentive’, ‘payment’ and/or ‘aid’. The term ‘subsidy’, apart from being legally inappropriate and typologically inaccurate, appears to be essentially misplaced, as it does not comply with the specificity of the aid mechanism in question as a fully-fledged investment tool with multiple benefits for the national economy and a contribution to GDP growth in the country, as documented by relevant studies known to the competent Ministry.

   With regard to paragraph 2, we propose the following amendment:
   ‘…Incentive effect: the aid has an incentive effect only if the beneficiary has applied for funding to be included in the aid scheme before the start of work on the investment project, as defined in Article 2 pt. 23 of the GAC. Where the economic object of the inclusion decision is amended in accordance with Article 32(3)(e) of this Law, the incentive effect of the aid shall be maintained only if the beneficiary has submitted the application for amendment before the start of the relevant works.’
   Comments – Justification: As long as the current possibility of a limited increase in the total amount of eligible expenditure authorised in the CRGR-FTV aid scheme is maintained in the proposed S/N, with the addition of new eligible expenditure, clarification will be required in Article 24(2)(b) to ensure that the provision of this possibility is also legally compatible with the incentive effect of the aid under this scheme. In particular, and taking into account the provisions of Article 6(2) of GBER 651/2014, the Agency should explicitly request the addition of the new aided expenditure before the start of the works corresponding to its implementation – and therefore the incentive effect of the additional aid provided is maintained.

   With regard to paragraph 3, we propose the following amendment:
   3. The eligible costs of all the aid schemes of the Programme are the costs for the production of an audiovisual work, which are incurred in the Greek territory and do not exceed eighty per cent (80%) the total cost of all production works of the audiovisual work (eligible production costs).'
   Comments – Justification: The proposed provision is a verbatim transposition of Article 26(1) of Law 4487/2017. However, the latter provision had in some cases been the subject of an incorrect legal interpretation by the competent services of EKOME, with the result that, for the implementation of post-production operations only in Greece, only the post-production costs of the investment project were taken into account for the purposes of determining the total production costs – a practice which, it should be noted, was contrary, inter alia, to Article 54(9) of GBER 651/2014.
   Therefore, and in order to remove any relevant doubt as to the concept of total production costs, it is proposed to include an explicit clarification in this provision that the calculation of the total production costs of the investment project should take into account the costs of all production operations.

   Article 26

   With regard to paragraph 2(b), please note that the minimum eligible expenditure of EUR 60 000 for the short film, cinematographic or television, in order for it to be included in the cash rebate, is extremely high and does not correspond to the production conditions for short films in Greece. If the arrangement remains unchanged, almost all short films will be excluded from inclusion in the aid scheme. Therefore, we propose an arrangement corresponding to point (d) of the same paragraph and an adjustment of the prescribed limit to EUR 35 000.
   As regards paragraph 6, as it stands, interpretative difficulties arise and the true meaning of this provision should therefore be clarified.
   According to Article 54(4) of GBER 651/2014, if a Member State requires a minimum level of production activity to take place in its territory for a project to be eligible for aid, that level shall not exceed 50%) of the total production budget. Moreover, in accordance with the above provision of Article 54 of the GBER, the maximum amount of expenditure subject to territorial obligations shall in no case exceed 80%) of the total production budget.
   Given this, for reasons of legal certainty, it should be expressly provided what exactly will apply in the event that the thresholds of the minimum eligible costs required under Article 26(2) to (4) of the S/N infringe, in cases of an extremely limited overall production budget, the thresholds laid down in Article 54(4) of GBER 651/2014.
   In our view, in such a - not unlikely - case, the amounts of the minimum eligible costs required should be adjusted downwards without rejecting the inclusion of the investment project in one of the aid schemes of the S/N.

   Article 27

   With regard to Article 27, we propose the following legal wording:
   ‘4. Enterprises implementing investment projects carried out on the initiative of and on behalf of the public sector or the television station of the Hellenic Parliament, on the basis of a contract for the execution of works, concessions or the provision of services, with the exception of ERT S.A., shall not be considered to be beneficiaries of the aid under this scheme:… (c) enterprises implementing investment projects carried out on the initiative of and on behalf of the public sector or the television station of the Hellenic Parliament, on the basis of a contract for the execution of works, concessions or the provision of services, with the exception of ERT S.A.’
   Comments – Justification: To remove any doubts, it is proposed to include an explicit reference to the ERT exemption, as provided for in Article 25(5)(c). Law 4487/2017.

   Article 28

   On paragraph 1, we stress the need to explicitly include borrowing costs and bank charges in the total eligible production costs, in stark contrast to the existing regulatory plan. In the Greek environment, which lacks an organised and effective strategy to support the sector from the financial system, it is incorrect and anti-developmental not to include the relevant costs in the eligible costs. Greek production companies inflexibly bear the relevant costs, without balancing mechanisms, thus making their activity more difficult, and the often observed delays in the implementation of the investment plan entail even greater bank costs. This is therefore the right opportunity to partially improve the existing regime by changing the provision in the direction we propose.

   In addition, we propose adding to paragraph 1(b) the costs of purchasing equipment and consumables that are not fixed assets.
   The proposed addition resolves the critical issue for the bodies of the eligibility of the specific expenditure in a manner consistent with the provisions of point (ca) of the above provision.
   In this regard, it should be noted that, in the context of the application of Law 4487/2017, EKOME has consistently rejected as ineligible incurred costs incurred by the Entities for the purchase of equipment used as a backdrop for the production needs of the audiovisual work and then either it is destroyed/consumed according to the programming/scenario during the execution of the work, or it ceases to have the slightest usefulness for the Entities after the end of the filming (due to the customised modifications/adaptations made to it for the production needs). That was so, even though the impossibility of leasing that equipment was obvious, since it was reasonable for no one to lease equipment in order to destroy it or render it essentially inoperable as a result of the lessee’s specialised interventions in that regard, thus making it unavailable for further exploitation by its owner.
   Consequently, in our view, legislating as eligible expenditure for the purchase of equipment intended to be consumed in the context of the implementation of the investment plan appears perfectly reasonable and justified, all the more so in the light of the relevant definitions of the concept of fixed assets in Law 4308/2014 as well as in POL. 1073/31.03.2015.

   With regard to paragraph 3, we propose the following amendment:
   ‘3. …. In the event of commencement of the works of the investment project for expenditure before the above-mentioned date of application for inclusion of funding, with the exception of preparatory actions for expenditure for preparatory production actions which do not constitute an event of commencement of an investment project in accordance with Article 23(5), the entire investment project shall become ineligible for funding in all aid schemes under this Law.’

   Comments – Justification: In our view, consideration should be given to reinstating the corresponding wording of Article 20(5) of Law 4487/2017, which refers to the start of work on the investment plan as an event that renders the entire investment plan ineligible.
   In particular, the start of works is a broader concept than the realisation of individual costs by the Entities in time before the start of the investment plan. In practice, moreover, there is a sporadic occurrence of ineligible costs incurred by the bodies (not only for preparatory works), before the submission of the application for inclusion, in the case of advance payments against future implementation of works of the investment project – without this rendering the investment irreversible.
   Consequently, the contested subparagraph of Article 28(3) of the S/N needs to be amended in order to remove the restrictive and ineffective approach according to which expenditure of at least EUR 1 before work starts automatically leads to the rejection of the entire investment project.
   Crucially, the above position is fully supported by the provisions of Article 6(2) of GBER 651/2014, which similarly as a criterion for affirming the incentive effect of aid provides for the non-initiation of works before the submission of the application for inclusion and not the non-execution of any relevant expenditure by the bodies.

   Article 30

   With regard to paragraph 1, we propose the following legislative adaptation:
   ‘1. The procedure for assessing the application for inclusion of financing for an investment project in all aid schemes under this Programme shall be completed within three (3) months of its submission to the information system.’

   Comments – Justification: Order in the administration, as an extremely reasonable time, a time limit for the completion of the assessment of the application for the inclusion of financing of an investment project, is deemed appropriate and useful, taking into account, inter alia, the huge time delays that have generally been observed (even recently in a progressive manner) in the application of the current regime, and in several cases to the detriment of the protected rights and the legal interests of the Entities. Although the deadlines for the Administration are, in principle, indicative, the strong recommendation – through the proposed arrangement – to the competent services of the New Body to respect the set quarter as the last reasonable time to complete the evaluation process is expected to be positive for the effective and smooth functioning of the CRGR Programme.

   Regarding paragraph 3, we consider that the last sentence of the provision ("and may decide to include the … investment plan, which have more than one source of funding") presents serious interpretative difficulties in ascertaining its true meaning and its implementation is expected to be problematic. For reasons of legal certainty, all the more so since this is essentially an additional, decisive criterion for the inclusion or non-inclusion of the investment project in the aid schemes of the S/N by the Evaluation Committee, in our view the need to delete the specific subparagraph of Article 30(3) of the S/N or, alternatively, to clarify it in order to remove any misinterpretations should be examined.

   With regard to paragraph 5, we propose the following addition to the provision:
   ‘5. A precondition for issuing a decision on the inclusion of funding is the existence of a certificate from the competent financial department of the supervising Ministry on the existence of the relevant annual budget per aid scheme of the Programme. This attestation shall be issued once at the beginning of each financial year and shall relate to the total annual budget per aid scheme, taking into account the provisions of the General Part and Article 54 of the GBER. As regards the CRGR-FTV aid scheme, the ministerial decision referred to in Article 87(2) of this Law should in any case ensure a balanced reinforcement of the two pillars in the context of the use of the relevant annual budget.’

   Comments – Justification:

   (i) For reasons of legal certainty, it should be clarified what exactly will apply to submitted applications for inclusion of funding in case the relevant annual budget is not sufficient to cover the specific investment projects to be included. This is a ‘grey area’ of the S/N under consultation which should be properly regulated. In particular, the following questions are raised: in the event that the annual budget for the aid scheme applied for is not sufficient, will a financing inclusion decision be adopted despite the absence of relevant provisions in the annual budget established or not? In the event of a negative reply to point (a), will the application for inclusion of funding be rejected or retained by the Evaluation Committee (which will temporarily abstain from taking a decision) in order for the relevant decision to be issued within the next financial year and in accordance with the principle of time priority? In our view, it is reasonable and fair for the latter to apply, taking into account the principle of priority in time.

   (ii) SAPOE considers as the highest priority the legislative safeguarding and safeguarding of the real enhancement of Greek Cinema - the pre-eminent sector of the Greek audiovisual industry with an extrovert orientation and a pillar of attracting international investment in the country - in the context of the operation of the CRGR-FTV aid scheme. For this reason, and in accordance with the requirements of the principle of transparency, especially as regards the crucial issue of the allocation of public funds between the 2 pillars of the CRGR-FTV, it is proposed to include a new subparagraph in Article 30(5) of the S/N on ensuring a balanced reinforcement of the 2 pillars of the CRGR-FTV aid scheme. The proposed wording of a general principle trial is technically neutral and therefore does not raise any legal problems from the point of view of both competition law and the text of the EU State aid framework.

   Article 32

   With regard to paragraph 3(a), we propose the following legislative adaptation:
   ‘3. An application for amendment of the conditions for the inclusion of an investment project may relate exclusively to: an internal redistribution of the categories of eligible costs included in the investment project approved by increasing or decreasing them, provided that the increase exceeds twenty per cent;%) ) by category of eligible expenditure’.
   Comments – Justification: It is proposed to delete the separate reference in case of reduction of expenditure by category above 20%) , given that, with the proposed provision, even if the increase per category does not exceed 20%) after internal reallocation, any parallel decrease in other categories above 20%) necessitates a request for amendment. However, individual reductions of the authorised eligible amounts above 20%) can take place legally without the need to modify the investment, since in principle they are freely allowed, provided that at least 50%) the eligible costs, respecting these thresholds, in accordance with Article 33(6) of the S/N.
   Moreover, reductions in eligible costs per category do not in any way burden the budget of the New Entity for the provision of aid – on the contrary they have the effect of limiting the relevant public expenditure in the form of aid and therefore, in so far as they do not breach the thresholds of Articles 26 and 33(6) of the S/N, they do not call into question the service of the public interest.
   Finally, it should be noted that the requirement to amend the conditions for the inclusion of the investment in the event of an individual reduction in expenditure per category of more than 20%) (i.e. without the parallel increase exceeding this percentage) amounts to an unacceptable burden on the territoriality obligations of GBER 651/2014, which gives operators the freedom in principle to incur significantly lower costs in the Member State of the aid than initially budgeted.

   With regard to paragraph 3(c), we propose the following amendment:

   ‘3. An application for amendment of the conditions for the inclusion of an investment project may relate exclusively to: … (c) Extending the expiry time of the investment plan, as declared in the financing inclusion decision, which may not exceed six (6) three (3) months.

   Comments – Justification: The abbreviation with the proposed provision of Article 32(3)(c) of the S/N of the time extension of the duration of investment projects from 6 to 3 months, for reasons not related to the occurrence of force majeure events, excessively limits the flexibility of the bodies and does not correspond to the reality of the changing conditions for the implementation of investment plans for the production of audiovisual works (which in no way resemble at this point the investment plans of Law 4887/2022 for which an extension of their duration of maximum up to 3 months is granted).

   Therefore, a corresponding rewording of the contested provision of the S/N is required in line with what has been in force to date (cf. Article 10(3) of Joint Ministerial Decision 19292 ΕΞ 2022).

   With regard to paragraph 3(e), we propose the following adaptation:

   ‘3. An application for amendment of the conditions for the inclusion of an investment project may relate exclusively to: … (e) Addition of new aided expenditure by increasing the total amount of approved eligible expenditure by up to ten per cent (10%) the amount of eligible expenditure, within the limits of the approved budget in cases of unforeseen circumstances.';

   Comments – Justification: Maintaining the possibility for bodies to add new aided expenditure (albeit at a lower rate of increase) is welcome, but it is necessary to delete the reference ‘within the limits of the approved budget’, given that:

   (a) This petition reiterates the relevant provisions of Article 32(5) of Law 4487/2017, which, however, provided for a general possibility of adding a new aided beam without being limited to the occurrence of unforeseen circumstances as the sole justification for submitting the relevant request – hence the requirement not to exceed the total production budget in the event of an increase in eligible costs seemed perfectly reasonable;
   (b) However, the new provision substantially limits the scope of the addition of new eligible expenditure, which now only grants ΄ exceptions to ‘unforeseen circumstances’, and
   (c) The ‘unforeseen’ contribution is in fact linked not only to an increase in the amount of eligible costs, but also, as a rule, to an upward revision of the total production budget of at least the same amount.

   Therefore, in order for the bodies to make full and effective use of the possibility offered to them by the S/N, as well as further to avoid interpretative difficulties in the application of Article 32(3)(e) of the S/N in cases of domestic producers or producers of limited economic scope (cf. the problematic application to date by EKOME of the current provision of Article 32(5) of Law 4487/2017), it is proposed to delete the reference at issue ‘within the limits of the approved budget’.

   With regard to paragraph 7, we propose the following legislative adaptation:

   ‘7. The change in the total number of days of shooting or in the total number of days of other production work included in the approved investment project, provided that it occurs within the time limits for the implementation of the investment project and does not bring about or significantly alter the place of shooting as described in the approved investment project to such an extent that it affects the cultural criteria on the basis of which the investment project was approved, shall be submitted as part of the final report of the chartered accountant in accordance with Articles 33 and 34 and shall not require an amendment decision to that effect by the Granting Authority.’

   Comments – Justification: During the implementation of Law 4487/2017 and its implementing Joint Ministerial Decision, even the slightest change in the location of filming by the bodies was unlawfully treated by EKOME, in a few cases, from the outset and without further ado as a substantial amendment of the inclusion decision. For this reason, for reasons of legal certainty, a specific objective criterion should be provided on the basis of which the variation/change of the location of the filming can take place without modification of the investment in accordance with Article 32 of the Act. In our view, the variation of the location of the filming should be considered as non-substantial as long as it cannot lead to an effect on the investment’s score regarding the fulfilment of the cultural criteria (e.g. transfer of filming days to another location in the Greek territory of similar cultural importance).

   Article 33

   With regard to paragraph 1, we propose the following legislative adaptation:

   ‘1. The verification for the certification of the completion of an investment project in the aid schemes CRGR-FTV and CRGR-Animate shall be carried out at the request of the applicant company to the Granting Authority in the IT system defined by the latter at any point in time within six (6) months from the date of the

   🤖 AI AnalysisℹAI analyzed this comment and extracted the main posts expressed by the author. Each position is broken down into arguments – click to see them.✦ Created with AI

   📍 Addition of an explicit reference that the S/N supports the production of audiovisual works 1 business

   🟢 Legal certainty and public interest delineationFact check

   📍 Increase of the budget limit of a difficult project to 1.000.000 € (article 23 par.3) 1 business

   🟢 Responds to production conditions and GACFact check

   📍 Definition of the end of an investment plan to avoid incorrect submission of a certified accountant (Article 23(6)) 1 business

   🟢 Ensures clarity and prevents contestation of aid compatibilityFact check

   📍 Correction of the correctness of a name in a "Greek Film Centre" (Article 23(7)) 1 business

   🟢 Prevents incorrect legal referenceFact check

   📍 Modify percentages to 60%) for cross-border production and 100%) for a difficult task (Article 24(2)) 1 business

   🟢 Ensures correct aid intensity according to GBERFact check

   📍 Use of the term ‘investment incentive’ instead of ‘grant’ and determination of payment of aid (Article 25(1)) 1 business

   🟢 Clarifies legal nature of aid and payment methodFact check

   📍 Determination of incentive effect subject to the submission of an application before work starts (Article 25(2)) 1 business

   🟢 Uncertainty abatement and GAC compatibilityFact check

   📍 Definition of eligible costs up to 80%) total production costs (Article 25(3)) 1 business

   🟢 Establishes clear maximum limit, avoids misinterpretationFact check

   📍 Reduction of the minimum threshold for short films to €35 000 (from €60 000) (Article 26(2)) 1 business

   🟢 Prevents exclusion of small producers and promotes access to aidFact check

   📍 Clarification of territoriality conditions and expenditure limit in accordance with the GBER (Article 26(6)) 1 business

   🟢 Ensures compliance with European regulationFact check

   📍 Addition of an ERT exemption to business exclusions (Article 27) 1 business

   🟢 Complies with existing legislation Law 4487/2017Fact check

   📍 Inclusion of borrowing and bank charges as eligible costs (Article 28(1)) 1 business

   🟢 Faces lack of financial support and reduces production costsFact check

   📍 Addition of expenditure on the purchase of non-fixed equipment/consumables as eligible (Article 28(1)) 1 business

   🟢 Ensures justified equipment eligibilityFact check

   📍 Ineligibility of expenditure before submission of an application, except for preparatory actions (Article 28(3)) 1 business

   🟢 Prevents non-eligible costs and enhances clarityFact check

   📍 Setting a deadline for the evaluation of applications at 3 months (Article 30(1)) 1 business

   🟢 Ensures an effective, timely evaluation processFact check

   📍 Removal of an unclear sentence in paragraph 3 of Article 30 1 business

   🟢 Prevents misunderstandings and improves applicabilityFact check

   📍 Addition of a requirement for the establishment of an annual budget by a financial service (Article 30(5)) 1 business

   🟢 Ensures transparency and sufficient resources for reinforcementsFact check

   📍 Limitation of amendment request to expenditure increase >20%) by category (Article 32(3)(a)) 1 business

   🟢 Simplicity of procedure and avoidance of microscopic changesFact check

   📍 Limitation of extensions of the expiry of an investment plan to 3 months (Article 32(3)(c)) 1 business

   🟢 Ensures flexibility but prevents excessive extensionsFact check

   📍 Addition of new aided expenditure up to 10%) in unforeseen circumstances (Article 32(3)(e)) 1 business

   🟢 Allows to deal with extraordinary claims without over-budgetingFact check

   📍 Correction of the procedure for changing filming days without the need for modification (Article 32(7)) 1 business

   🟢 Simplifies administrative changes and prevents unnecessary bureaucracyFact check

   📍 Deadline for certification of expiry within 6 months (Article 33(1)) 1 business

   🟢 Gives clear time frame for certificationFact check

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9. 

   7796

   May 15, 2026

   Article 26(2) should be amended:
   The amounts are unrealistic for films (EUR 250 000 budget and EUR 200 000 eligible costs), the "television films" mentioned are non-existent in the Greek television industry, while for the series of 17 episodes and above (essentially photographing the daily farce and the pseudo-racial type TRUE STORIES) the bar goes down to 50%) a short film with only 35,000 euros per episode.

   Also for period films/mini-series, based on books, there is no additional incentive for better productions with better production values that can be exported. It is noted that Greek films are sold for a lentil plate with 3,500 euros and 4,500 euros on Netflix amounts that demonstrate the insignificance of Greek audiovisual production internationally. Instead of focusing on making better productions, the … lagging waters of the pond are being extended to a labyrinthine, bureaucratic organisation.

   Whether someone is doing Greek literature, or a European co-production based on a literary work, or the revolution of 1821, or a room movie with two people, or a farce of the rapist with television rioters, one and the same is for the present draft law and the existing law.
   The same is true for DOUBLE PROJECT where the same situation is maintained – since DOUBLE PROJECT refers to the quota of State aid from ECC, ERT and not to additional incentives with the score of the cultural criteria.

   It is clear that the intention is not to make better productions that can be exported but to maintain and increase the armies of civil servants 80+ employees of EKOME and the other 40 of the CySEC, without providing for the immediate future of the Greek creative industry.

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   📍 Amendment to Article 26(2) 7 B.C.

   🟢 Projected Amounts Are Unrealistic for MoviesFact check

   🟢 'Telefilms' are non-existent in the Greek television industryFact check

   🟢 The series >17 episodes have a very low budget of 35,000 eurosFact check

   🟢 Additional incentives for higher quality producers are missingFact check

   🟢 Greek films sold at very low prices on NetflixFact check

   🟢 Priority is given to a bureaucratic organization instead of qualityFact check

   🟢 Subsidies prefer to increase civil servants over industryFact check

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10. 

    7800

    May 15, 2026

    OBSERVATIONS AND PROPOSALS OF THE ASSOCIATION OF AUDIOVISUAL PRODUCERS (PACT) IN THE DRAFT LAW OF THE MINISTRY OF CULTURE WITH TITLE
    ‘Creative Greece: strengthening the cinematographic, audiovisual and creative sectors, establishing a body for books and other provisions for contemporary culture’

    Article 22
    Please note that under paragraph 3, as well as in various other points of the draft law, the investment incentive is referred to as a ‘subsidy’. We propose to avoid formulating the cash rebate incentive as a subsidy, but as an investment refund

    Article 25
    Paragraph 3
    It is proposed to clarify that the above NON-eligible production costs 20%) , can also be certified by cooperation agreements between the main actors (producer, director, screenwriter, protagonists, etc.) as capitalisation of work. Of course, in order for these costs to be included in the eligible costs, they must be accompanied by relevant documents.

    Article 26.
    Comments on the Article

    As has been announced, the annual funding limit for aid cannot exceed 50 million Euros, which practically means that the total budget of the projects that can be supported will reach 125 million Euros per year.

    Given that …

    a) The total annual budget of ONLY Greek channels in fictional works exceeds the above amount,
    b) The proposed low eligible expenditure limit of 35,000 Euros in this draft plan, along with the allowed 337 episodes for 2 cycles,
    c) Greek and international channels/studios/streamers are producers, financiers and distributors of their works,
    d) International channels, studios & streamers - even with much higher budgets - can easily cover tens of millions of productions per year,
    e) No independent producer, especially the Greeks, can have secured, timely and competitive funding unlike the channels/streamers/studios,
    g) The spread of subsidies to a larger number of companies essentially supports the mission of the Company (as provided for in Article 4 of this Law), which is to support domestic and attract foreign investment in the film/audiovisual sector, as well as in the cultural and creative sector more broadly.
    The implementation of the law as proposed, effectively excludes the participation of independent producers and becomes a financial tool addressed only to major international and Greek networks.

    For the above reason we recommend the following … safety valve

    At least 50%) the annual subcontractors to be entrusted to independent producers.

    According to the EURIMAGES definition, a production company is considered independent when less than 25%) its share capital is held by a single broadcaster or less than 50%) when several broadcasters are involved.

    Article 27.
    ‘Beneficiaries of aid’
    With a view to more effective accounting and supervisory control by the Certified Public Accountants, it is proposed that the beneficiaries of the aid should be companies that have mandatory double-entry books.

    In particular, for producers with eligible costs of more than 1,000,000 euros, the establishment of a single-purpose company (SPV) must be mandatory.

    Article 23(5) In conjunction with Article 28(3)
    ‘Rejection of an investment project in the case of preparatory actions prior to the date of submission of the application for funding’

    The wording of the above articles creates ambiguities and margins for rejecting investment plans, because it is a fact that months or even years before the submission of a request for submission, important preparatory actions have always been taken in a production, such as …

    • Purchase of rights to a book or other intellectual work.
    • Write a screenplay, with the collaboration of one or more writers.
    • Filming space discovery trips.
    • Casting protagonists.
    • Test shooting for casting auditions
    • Agreements with key actors such as Director, Protagonists, etc.
    • Agreements with key equipment providers, shooting areas, etc.
    • Company operating expenses for several months, if not years.

    For all these actions, prepayments have probably been made so that there is a commitment to cooperate.

    It is absolutely absurd for a work to be in danger of total rejection, because in the past it has carried out works that of course constitute the event of the beginning of an audiovisual work, but are extremely necessary for the submission of the request and the beginning of production.

    Especially in the cases of Production Services, as well as when only a part of the work is required to be done in Greece, it is very likely that significant expenses and filming of the project have already taken place before the date of submission of the request.

    Based on the above we propose …

    • Amendment of the relevant points in Articles 23.5 & 28.3 and replacement of the starting date of the investment plan with the date of finalisation of the submission of the application for inclusion.

    • Clarification where the rejection of an investment project can only be made in the event that the projected aid rounds have been made in Greece or part of them before the finalization of an application for inclusion.

    Article 30.
    "Procedure and content of the assessment"

    With a view to speeding up procedures and reducing red tape, it is proposed (as an optional option in the first instance) that, if the producer so requests, the maturity of the project should be assessed, so that it can be included in a PRE-APPROVAL / FAST TRACK procedure.

    Of all the documents requested today, we consider that only 5 are necessary for the pre-approval of a project, while the remaining 35 that are requested now, act as supplementary data and can be submitted in a second phase, before the approval decision of the subjection.

    The necessary 5 documents for the pre-approval of the subordination of a project are:

    1. The project budget showing eligible and ineligible costs, as well as compliance with the limited costs requested by the legislation.

    2. Completed table with cultural criteria. Please note that all the information concerning the project (summary, factors, filming areas, processing labs, etc.) can be summarized here.

    3. The financing plan, showing the sources of financing which must be supported by the relevant agreements signed by the producer and the financiers. In order for there to be no subjective interpretation of the possibility of funding, we propose as evidence that some of the following should be provided, covering a percentage of 68%) the total budget minus the amount of aid claimed, i.e.:

    a. Completion Bond; and/or
    b. Contract with streaming platforms; and/or
    c. Contract with Theatrical Distribution; and/or
    d. Approval decisions from Greek state sources (EKK, ERT, etc.) , and/or
    e. Approval decisions from European state sources (EURIMAGES, MEDIA, etc.) , and/or
    f. Approval decisions from foreign state sources; and/or
    g. The producer’s and co-producers’ own contribution should be covered by contracts or letters of guarantee from financial institutions (banks, gap financers, etc.) , and/or

    4. The production schedule (preparation, shooting, post production, completion, request for the appointment of a sworn auditor). This is necessary for the organisation to know in which year the funding will be committed.

    5. Pre-authorisation request fee

    … In the first instance the Producer presents only the above 5 documents. Within 10 days he is either given a positive response to the submission of a request for submission, or a meeting is requested where the Producer will have to provide any of the missing evidence.

    Until the producer submits the missing document, the procedure is ‘frozen’ and the complete application for inclusion in the PSKE cannot be made.

    When all the above are submitted and accepted, provided that the relevant funds are available for the period that the project will be completed (e.g. after 10-12 or more months), then EKOME gives a registration application code to the PSKE, so that the Producer can also make the complete application for registration with all the requested supporting documents.

    Article 30.
    Paragraph 5
    To be functional this article should …

    • Any decision to submit an application should be posted on the organisation's website so that it is known (at least on the date of submission of the application) whether or not funds are available. If there are NO funds for the specific year that the , repayment will be requested, applications should be accepted only for the following years where there will be available funds.
    • Generally establish the PRE-APPROVAL / FAST TRACK/ procedure so that the Producer knows immediately whether the relevant funds are available and whether or not to submit the request.

    Article 32.
    Paragraphs 3a, b, c, d.
    ‘Amendment of the conditions for the inclusion of financing for an investment project’

    It is proposed to make requests for amendment only on the following issues.

    • Significant changes in cultural criteria.
    • Reduction of the total eligible cost by more than 40%) .
    • Increase in total eligible costs by up to 10%)
    • Change of the binding date of the request for the appointment of a sworn auditor (and thus the declaration of the end of the project), for a period of more than three (3) months.
    • Change of the entity due to a merger or due to the spin-off of a branch or due to a transfer due to universal succession, which occurs during the implementation process of the investment plan

    All other changes that may occur during production are considered notifications and will be presented in the technical description of the project together with the financial report of the statutory auditor.

    We propose that the variation of eligible costs from one category to another at a rate greater than 20%) , but without an overall increase in the total eligible costs, not be considered as an amendment, but as a notification.

    Today, the 7 categories of production expenditure are an arbitrary construction, which does not correspond to the international budget specifications, which foresee only 4 categories, namely Above The Line, Below The Line, Post-Production & Other. It is known to all production companies that today's categories 2, 3, 4 & 5, operate as communicating containers and therefore constitute internationally a category called Below The Line. However, the sharing of related expenses in 4 categories, which are interconnected, affect and are directly affected by each other, creates only bureaucratic procedures, delays the completion of the project and does not serve any control.

    It is proposed to integrate categories 2,3,4 & 5 into one, namely Above The Line, Below The Line, Post-Production & Other

    Article 33. Paragraph 3
    ‘The supporting documents referred to in paragraph 2 shall be kept in the file of the granting authority for ten (10) years and for control purposes’.

    Given that, according to the current tax legislation, the retention of financial data for the producer/investor company is provided for in 6 years, we propose that the retention of the submitted documents be extended to 6 years.

    ADDITIONAL ARTICLE

    In case of cooperation of foreign production companies with domestic production service companies, both the execution of production as well as all the agreements signed between them must be in accordance with Greek and European legislation and in case of any dispute the Greek law will be applicable and the courts of Athens will have jurisdiction.

    With regard to the articles: 35, 36 and 41
    We agree with the comments of the ASSOCIATION OF INDEPENDENT AUDIOVISUAL PRODUCERS (SAPOE)

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    📍 Change of terminology "grant" to "return of investment" in cash rebate 1 business

    🟢 The "grant" terminology is misleading; ‘return on investment’ better describes the incentiveFact check

    📍 Clarification that 20%) ineligible costs can be certified through collaborative agreements as capitalisation 1 business

    🟢 Clarification ensures clarity in the certification of ineligible costsFact check

    📍 Setting a minimum of 50%) annual allocations for independent producers 2 B.C.

    🟢 Ensures the participation of independent producers and enhances diversityFact check

    🟢 Prevents fundraising only in major international networksFact check

    📍 Duplicate book obligation and creation of SPV for film productions over 1 million euros 1 business

    🟢 Double-entry books and SPV improve accounting transparency and controlFact check

    📍 Change of the definition of the start of an investment plan at the date of submission of the application for inclusion 1 business

    🟢 Past preparatory actions are necessary; Rejection for them is unfair.Fact check

    📍 Introduction of a pre-approval procedure (fast‑track) with submission of only 5 necessary documents 1 business

    🟢 Reduces bureaucracy and speeds up the start of projectsFact check

    📍 Publication of any decision to join the organisation's website 1 business

    🟢 Ensures transparency and awareness of stakeholdersFact check

    📍 Limitation of amendments to an investment plan to the specific points set out in Article 32 1 business

    🟢 Establishes clear criteria, prevents unnecessary changes and ensures stabilityFact check

    📍 Concentrate 2‑5 costs into one category so that there are only four categories: Above, Below, Post‑Production, Other 1 business

    🟢 Aligns the system with international standards and reduces bureaucratic complexityFact check

    📍 Reduction of the period of storage of documents from 10 to 6 years 1 business

    🟢 Agrees with tax legislation and avoids unnecessary requirementsFact check

    📍 Determination of Greek jurisdiction (Athens) for negotiations and disputes between foreign and Greek producers 1 business

    🟢 Ensures implementation of well-known legislation and easier adjudicationFact check

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11. 

    7801

    May 15, 2026

    It is inconceivable to me that I could read the whole piece of legislation. After all, from many years of previous experience and my close contact with the film industry, I know how wrong the rebate went, how many and who took advantage of it (so that now they call us sucker Greeks) and what huge sums got into the pockets of cunning, sophisticated foreign producers. And this was not because the previous law had many problems, but because it was rarely applied.
    We had the wrong desire to become a "housekeeper" of foreign producers, generously offering to anyone who asked, just to "suck" that we now have international productions in Greece. In order for this mockery not to continue, the legislator or the competent minister must:

    (1) To compile a complete, strict and decisive list of cultural criteria (cultural list) in order to exclude those who do not collect the necessary points.
    (2) Upload the total number of points for films claiming rebate.
    (3) Ask, among other supporting documents, for a contract of the producer with a serious and established distribution company because without it, every wannabe director/producer will ask for 40%) some non-existent film budget the series that is in the speculative stage and has no guaranteed distribution,
    (4) Gradual evaluation of creative factors. Or it's a Tom Cruise movie from a Tommy Cruzerovich movie.
    (5) No Greek (as far as I know) is a professional script reader. EKOME should hire at least two American script readers to read the script (rather than a summary) and evaluate it according to EKOME's goals.
    (6) To have a control mechanism of EKOME that monitors the shooting and determines whether it is in line with the approved scenario. A lack of such a mechanism in the past has led to a rebate of defamatory misdeeds for the country, which even recently claim over 8 million euros because … defamed Greece.
    (7) To oblige foreign producers to hire 10 interns (unpaid) Greeks, kinim graduates. Schools to create new generations of technicians and creatives who learned side by side with the best. The same applies to subsidized local films and series.
    (8) Given that foreign producers finance their film with the expected rebate (banks discounting paper), EKOME actually plays the role of co-funder. However, in the case of a significant profit (e.g. sale of a Greek series on a foreign platform with $1 million per episode) EKOME/the country should not have a dividend on the profit since they contributed 40%) the assumed total cost of the series?
    (9) EKOME must be staffed with specialists who have a thorough knowledge of international production. Without these worthy specialists, a "bagasas" stranger will always take them from us when he does not deserve them.
    (10) We see in many films, in the titles, about a dozen production companies. At the same time, we see in the same position, some state organizations of other countries that contributed indirectly or directly to the financing. EKOME should also appear in the same position (favored nations) and not in the end titles.
    (11) Communication issues, many and disproportionate/difficult to use. EKOME must have instantaneous response time, use proper cinematic language and from the context of a proposal to make a first assessment of people and factors. A first check on the IMDB, the similar door, shows exactly who is asking for 40%) .
    (12) Contact issues. EKOME must establish relations with the production presidents (presidents of physical production) of major studios and important independent production companies. The physical production president/vice president decides and recommends that a film be made before it gets a green light for principal photography. Our country must have permanent "friends" of about 30 such presidents. The rest of the smaller production companies will come for the rebate anyway. We need big productions that leave a lot of money in the country and advertise impressive culture/character/tourism of the country. Besides, smaller productions that receive a rebate with an alibi for the development of local communities and businesses (hotels, restaurants, etc.) usually ensure such services by exchanging advertising/promotion of questionable unpaid value, so that local rulers also have their dividend in photo op with a B-class star.
    (13) I consider the 40%) rebate as disproportionately high with its rebates and that the time has passed when Greece had no productions and raised the price of the rebate to attract such opportunities from competing countries.
    (14) I reject the "allibi" of the rebate, that is, that we give it to Greek technicians to have a job. Realistically, with so many local TV productions, there is no free good Greek technician to work in foreign productions, so much so that foreign producers bring technical staff from our neighboring countries.
    (15) Finally, the country, EKK and EKOME should develop, instead of the system and services of "household assistant", the international creativity of obsessively introverted Greek production, in order to open international doors to Greek intellectual property, even if we are talking about low-cost films but acceptable genre (instead of artsy films made with the aim of an award at a festival but no one sees them) so that Greek production is present on the major platforms and, why not, in the program of major producers. Culture, tourism, promotion and advertising of the country (and all this Made in Greece) should become the main goals of the new era of EKOME.
    It is inconceivable to me that I could read the whole piece of legislation. After all, from many years of previous experience and my close contact with the film industry, I know how wrong the rebate went, how many and who took advantage of it (so that now they call us sucker Greeks) and what huge sums got into the pockets of cunning, sophisticated foreign producers. And this was not because the previous law had many problems, but because it was rarely applied.
    We had the wrong desire to become a "housekeeper" of foreign producers, generously offering to anyone who asked, just to "suck" that we now have international productions in Greece. In order for this mockery not to continue, the legislator or the competent minister must:

    (1) To compile a complete, strict and decisive list of cultural criteria (cultural list) in order to exclude those who do not collect the necessary points.
    (2) Upload the total number of points for films claiming rebate.
    (3) Ask, among other supporting documents, for a contract of the producer with a serious and established distribution company because without it, every wannabe director/producer will ask for 40%) some non-existent film budget the series that is in the speculative stage and has no guaranteed distribution,
    (4) Gradual evaluation of creative factors. Or it's a Tom Cruise movie from a Tommy Cruzerovich movie.
    (5) No Greek (as far as I know) is a professional script reader. EKOME should hire at least two American script readers to read the script (rather than a summary) and evaluate it according to EKOME's goals.
    (6) To have a control mechanism of EKOME that monitors the shooting and determines whether it is in line with the approved scenario. A lack of such a mechanism in the past has led to a rebate of defamatory misdeeds for the country, which even recently claim over 8 million euros because … defamed Greece.
    (7) To oblige foreign producers to hire 10 interns (unpaid) Greeks, kinim graduates. Schools to create new generations of technicians and creatives who learned side by side with the best. The same applies to subsidized local films and series.
    (8) Given that foreign producers finance their film with the expected rebate (banks discounting paper), EKOME actually plays the role of co-funder. However, in the case of a significant profit (e.g. sale of a Greek series on a foreign platform with $1 million per episode) EKOME/the country should not have a dividend on the profit since they contributed 40%) the assumed total cost of the series?
    (9) EKOME must be staffed with specialists who have a thorough knowledge of international production. Without these worthy specialists, a "bagasas" stranger will always take them from us when he does not deserve them.
    (10) We see in many films, in the titles, about a dozen production companies. At the same time, we see in the same position, some state organizations of other countries that contributed indirectly or directly to the financing. EKOME should also appear in the same position (favored nations) and not in the end titles.
    (11) Communication issues, many and disproportionate/difficult to use. EKOME must have instantaneous response time, use proper cinematic language and from the context of a proposal to make a first assessment of people and factors. A first check on the IMDB, the similar door, shows exactly who is asking for 40%) .
    (12) Contact issues. EKOME must establish relations with the production presidents (presidents of physical production) of major studios and important independent production companies. The physical production president/vice president decides and recommends that a film be made before it gets a green light for principal photography. Our country must have permanent "friends" of about 30 such presidents. The rest of the smaller production companies will come for the rebate anyway. We need big productions that leave a lot of money in the country and advertise impressive culture/character/tourism of the country. Besides, smaller productions that receive a rebate with an alibi for the development of local communities and businesses (hotels, restaurants, etc.) usually ensure such services by exchanging advertising/promotion of questionable unpaid value, so that local rulers also have their dividend in photo op with a B-class star.
    (13) I consider the 40%) rebate as disproportionately high with its rebates and that the time has passed when Greece had no productions and raised the price of the rebate to attract such opportunities from competing countries.
    (14) I reject the "allibi" of the rebate, that is, that we give it to Greek technicians to have a job. Realistically, with so many local TV productions, there is no free good Greek technician to work in foreign productions, so much so that foreign producers bring technical staff from our neighboring countries.
    (15) Finally, the country, EKK and EKOME should develop, instead of the system and services of "household assistant", the international creativity of obsessively introverted Greek production, in order to open international doors to Greek intellectual property, even if we are talking about low-cost films but acceptable genre (instead of artsy films made with the aim of an award at a festival but no one sees them) so that Greek production is present on the major platforms and, why not, in the program of major producers. Culture, tourism, promotion and advertising of the country (and all this Made in Greece) should become the main goals of the new era of EKOME.

    🤖 AI AnalysisℹAI analyzed this comment and extracted the main posts expressed by the author. Each position is broken down into arguments – click to see them.✦ Created with AI

    📍 Compilation of a strict list of cultural criteria for the exclusion of works without necessary points 1 business

    🟢 Lack of clear list leads to malicious rebate exploitation by foreignersFact check

    📍 Increase in total number of points for films requesting rebate 1 business

    🟢 Increase points will prevent low-quality projects from receiving a free grantFact check

    📍 Requirement of a producer contract with a reputable distribution company 1 business

    🟢 Without distribution contract, producers ask for 40%) Budget in a Speculation PhaseFact check

    📍 Integration of Critical Assessment of Creative Factors 1 business

    🟢 Rating prevents bad productions such as 'Tom Cruise' formatFact check

    📍 Hire at least two American script readers for script reading 1 business

    🟢 No professional Greek script reading, specialized Americans requiredFact check

    📍 Establishment of an EKOME audit mechanism for film monitoring 1 business

    🟢 Absence of control caused rebate charges of 8 million euros for defamatory filmsFact check

    📍 Obligation of foreign producers to hire 10 unpaid Greek interns 1 business

    🟢 Hiring 10 interns will create a new generation of technicians and creatorsFact check

    📍 Avoid EKOME/country profit allocation when there is a significant producer profit 1 business

    🟢 EKOME/country should not earn a profit when it has already contributed 40%) costFact check

    📍 Reinforcement of EKOME staff with international production specialists 1 business

    🟢 Without experts, foreign producers exploit the systemFact check

    📍 Recognition of EKOME as a favored nation in film credits 1 business

    🟢 EKOME should appear as a favored nation, not just at the endFact check

    📍 EKOME response speed, use of cinematic language, early assessment via IMDB 1 business

    🟢 Slow response and poor language prevent proper evaluationFact check

    📍 Creation of EKOME relations with production presidents of large studios 1 business

    🟢 Relations with production presidents attract large investmentsFact check

    📍 Reduction of 40%) Rebate as Excessive 1 business

    🟢 The 40%) Rebate is too high in relation to the benefitsFact check

    📍 Rejection of argument that the rebate creates positions for Greek technicians 1 business

    🟢 There is no shortage of Greek techniques; Strangers bring their own staff.Fact check

    📍 Development of international creativity instead of a "household assistant" model EKOME 1 business

    🟢 Requires Greek IP forwarding instead of an assistant modelFact check

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12. 

    7802

    May 15, 2026

    It is inconceivable to me that I could read the whole piece of legislation. After all, from many years of previous experience and my close contact with the film industry, I know how wrong the rebate went, how many and who took advantage of it (so that now they call us sucker Greeks) and what huge sums got into the pockets of cunning, sophisticated foreign producers. And this was not because the previous law had many problems, but because it was rarely applied.
    We had the wrong desire to become a "housekeeper" of foreign producers, generously offering to anyone who asked, just to "suck" that we now have international productions in Greece. In order for this mockery not to continue, the legislator or the competent minister must:

    (1) To compile a complete, strict and decisive list of cultural criteria (cultural list) in order to exclude those who do not collect the necessary points.
    (2) Upload the total number of points for films claiming rebate.
    (3) Ask, among other supporting documents, for a contract of the producer with a serious and established distribution company because without it, every wannabe director/producer will ask for 40%) some non-existent film budget the series that is in the speculative stage and has no guaranteed distribution,
    (4) Gradual evaluation of creative factors. Or it's a Tom Cruise movie from a Tommy Cruzerovich movie.
    (5) No Greek (as far as I know) is a professional script reader. EKOME should hire at least two American script readers to read the script (rather than a summary) and evaluate it according to EKOME's goals.
    (6) To have a control mechanism of EKOME that monitors the shooting and determines whether it is in line with the approved scenario. A lack of such a mechanism in the past has led to a rebate of defamatory misdeeds for the country, which even recently claim over 8 million euros because … defamed Greece.
    (7) To oblige foreign producers to hire 10 interns (unpaid) Greeks, kinim graduates. Schools to create new generations of technicians and creatives who learned side by side with the best. The same applies to subsidized local films and series.
    (8) Given that foreign producers finance their film with the expected rebate (banks discounting paper), EKOME actually plays the role of co-funder. However, in the case of a significant profit (e.g. sale of a Greek series on a foreign platform with $1 million per episode) EKOME/the country should not have a dividend on the profit since they contributed 40%) the assumed total cost of the series?
    (9) EKOME must be staffed with specialists who have a thorough knowledge of international production. Without these worthy specialists, a "bagasas" stranger will always take them from us when he does not deserve them.
    (10) We see in many films, in the titles, about a dozen production companies. At the same time, we see in the same position, some state organizations of other countries that contributed indirectly or directly to the financing. EKOME should also appear in the same position (favored nations) and not in the end titles.
    (11) Communication issues, many and disproportionate/difficult to use. EKOME must have instantaneous response time, use proper cinematic language and from the context of a proposal to make a first assessment of people and factors. A first check on the IMDB, the similar door, shows exactly who is asking for 40%) .
    (12) Contact issues. EKOME must establish relations with the production presidents (presidents of physical production) of major studios and important independent production companies. The physical production president/vice president decides and recommends that a film be made before it gets a green light for principal photography. Our country must have permanent "friends" of about 30 such presidents. The rest of the smaller production companies will come for the rebate anyway. We need big productions that leave a lot of money in the country and advertise impressive culture/character/tourism of the country. Besides, smaller productions that receive a rebate with an alibi for the development of local communities and businesses (hotels, restaurants, etc.) usually ensure such services by exchanging advertising/promotion of questionable unpaid value, so that local rulers also have their dividend in photo op with a B-class star.
    (13) I consider the 40%) rebate as disproportionately high with its rebates and that the time has passed when Greece had no productions and raised the price of the rebate to attract such opportunities from competing countries.
    (14) I reject the "allibi" of the rebate, that is, that we give it to Greek technicians to have a job. Realistically, with so many local TV productions, there is no free good Greek technician to work in foreign productions, so much so that foreign producers bring technical staff from our neighboring countries.
    (15) Finally, the country, EKK and EKOME should develop, instead of the system and services of "household assistant", the international creativity of obsessively introverted Greek production, in order to open international doors to Greek intellectual property, even if we are talking about low-cost films but acceptable genre (instead of artsy films made with the aim of an award at a festival but no one sees them) so that Greek production is present on the major platforms and, why not, in the program of major producers. Culture, tourism, promotion and advertising of the country (and all this Made in Greece) should become the main goals of the new era of EKOME.

    🤖 AI AnalysisℹAI analyzed this comment and extracted the main posts expressed by the author. Each position is broken down into arguments – click to see them.✦ Created with AI

    📍 Define a complete list of cultural criteria for the rebate 1 business

    🟢 Will exclude producers who do not collect the required pointsFact check

    📍 Increase in total number of points for films claiming rebate 1 business

    🟢 Requires higher quality and greater investment from producersFact check

    📍 Requirement of a distribution contract with a serious company as a supporting document 1 business

    🟢 Prevents requests 40%) from imaginary budgets without guaranteed distributionFact check

    📍 Introduction of Critical Assessment of Creative Factors 1 business

    🟢 Distinguishes high quality works from dumb productionsFact check

    📍 Contract of two American script readers for script evaluation 1 business

    🟢 Local script readers missing; needs professional evaluationFact check

    📍 Creation of an EKOME control mechanism for film monitoring 1 business

    🟢 Absence of control led to fraudulent rebates and misuse of fundsFact check

    📍 Obligation of foreign producers to hire 10 unemployed Greek interns 1 business

    🟢 Creates a new generation of technicians and creatives in the fieldFact check

    📍 Require EKOME not to receive profit share from successful series 1 business

    🟢 EKOME already contributes 40%) cost; He should not win any more.Fact check

    📍 Reinforcement of EKOME staff with international production specialists 1 business

    🟢 Without specialists, foreign producers exploit the systemFact check

    📍 Recording EKOME in credits (favored nations) like other organizations 1 business

    🟢 Transparent relationships and recognition of EKOME's contributionFact check

    📍 Communication Improvement EKOME: immediate response, correct cinematic language 1 business

    🟢 Current communication is slow and unusableFact check

    📍 Creation of stable EKOME relations with production presidents of large studios 1 business

    🟢 Will attract large productions and investments in the countryFact check

    📍 Rebate Reduction from 40%) at a lower rate 1 business

    🟢 The 40%) is disproportionately high in relation to the benefitsFact check

    📍 Rejection of rebate for job creation to Greek technicians 1 business

    🟢 No Greek technician available; producers bring their own staffFact check

    📍 Development of international creativity and promotion of Greek IP instead of the 'household assistant' model 1 business

    🟢 will open international doors, enhance culture, tourism and promote GreeceFact check

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13. 

    7803

    May 15, 2026

    The Greek Film Centre uses readers who are also candidates for funding. In other words, they are also judges but judging and of course the intertwined go cloud (this is also proved by the press releases of the CySEC since 3-5 companies are subsidized each time taking the lion's share and the rest remain outside).

    Nowhere in the draft law are any safeguards mentioned that will prevent the scandalous way of disbursing Greek taxpayers' funds and favoritism.

    In particular, the following addresses: The Directorate-General for Film and the Directorate-General for Audiovisual, Technology and Creation must avoid a “conflict of interest” up to first-degree relatives as enshrined in Eurimages.

    It should be noted that foreign invoices and contracts cannot be checked by EKOME, either at a minimum of EUR 10 000 000 or EUR 8 000 000. The amounts reported as production costs for B movies shot in Thessaloniki with Bulgarian crews are outrageous for international standards and far from correspond to reality.

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    📍 Addition of safeguards to prevent conflicts of interest and corruption 3 Fig.

    🟢 Readers are both judges and candidates, create conflict of interestFact check

    🟢 Each time 3-5 companies are subsidized, the rest are left outFact check

    🟢 No safeguards, leading to scandalous allocation of fundsFact check

    📍 Mandatory prevention of conflict of interest up to first-degree relatives in the Directorates 3 Fig.

    🟢 Current practice presents conflicts of interest, as shown in press releasesFact check

    🟢 Eurimages includes such a term, it should be adopted here as wellFact check

    🟢 Required to avoid favoritism in the Film and Audiovisual DirectoratesFact check

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14. 

    7809

    May 15, 2026

    Comments on Part C:

    (1) Article 23(2):

    The definition of "autonomous audiovisual work" is proposed to be amended as follows:
    ‘the part of the episode or episode or series of episodes of a television series or mini-series, a television film or a cinematographic film of any length of time’.

    (2) Article 26(5):

    It is proposed that, instead of the investment aid covering only the first two cycles of television or mini-TV series, it should cover any two cycles of such series (synonymous or not). In addition, the limitation of the two cycles is expected to be absolutely discouraging for investments in infrastructure in the audiovisual production sector (in particular studio infrastructure, etc.), for the development of which in Greece it is necessary to be able to plan for longer-term productions. On the other hand, this is expected to affect the implementation of remarkable producers with a significant budget and with a long-term horizon in the Greek territory.

    For this reason, it is proposed that Article 26(5) be amended as follows:
    The investment plans of television or mini-TV series of approx. (c), (d) and (e) of paragraph 2 and point (c)paragraph 3 shall be reinforced for two cycles (coincidental or not). Any additional cycles are not an eligible investment project. The above limitation does not apply to investment projects with a budget of more than three hundred thousand (300,000) euros per episode produced.

    (3) Article 29(1)(a) (in conjunction with Article 87(5)) – Sufficient time to submit applications:

    Limiting the period during which applications for inclusion in the CRGR programme can be submitted is expected to create programming problems for potential beneficiaries. In particular, it is foreseen that this period will be determined by Joint Ministerial Decision until the end of December of the previous year, i.e. practically within a minimum period of time before the beneficiaries will be invited to submit applications for inclusion. Moreover, this period is not provided for as a fixed period in the law, but is referred to a JMD and may therefore vary from year to year. This leads to even greater uncertainty in the planning of planned investment projects, their preparation time and ultimately whether they will be able to apply for CRGR membership on time.

    For this reason, it is proposed to repeal Article 87(5) and amend Article 29(1)(a), providing alternatively for:

    – the possibility of submitting an application for integration without a time limit, recasting Article 29(1)(a), as follows:
    ‘An application for inclusion of financing of an investment project in the aid schemes of the CRGR programme shall be submitted to the granting authority, throughout the aid period, up to ten (10) days before the start date of the investment project, which shall be stated in the application for inclusion of financing, by means of an information system defined by the granting authority.’

    – or the setting by law of a specific period per year during which it will be possible to submit the application, with a recast of Article 29(1)(a), as follows:
    ‘An application for inclusion of financing of an investment project in the aid schemes of the CRGR Programme shall be submitted to the granting authority, from 15 January to 15 July of each year, up to ten (10) days before the start date of the investment project, which shall be stated in the application for inclusion of financing, by means of an information system set by the granting authority.’

    (4) Article 41(5): It is proposed to amend it by introducing the following wording:

    ‘Implementing bodies and competent state bodies shall keep files of investment projects in order to respond to audits carried out by the competent national authorities or European Union agencies. The above files shall be kept for ten (10) years from the date on which the last aid was granted.’

    (5) Transparency on the rate of consumption of the available budget of the programme:

    The draft law does not include any provision for potential beneficiaries to be aware of the available budget of the CRGR Programme, by category of audiovisual work, i.e. to ensure transparency as to the rate of consumption of the available budget by other approved investment projects and, therefore, the available balance for new investment projects at any time. The only relevant arrangement is to provide for an attestation of the existence of the relevant annual budget as a condition for the adoption of an integration decision (Article 30(5)), which however is issued after the submission of the integration application. By not knowing the amount of budget available, potential beneficiaries cannot know in advance the amount of funds available when submitting their application.
    It is proposed to introduce the possibility of informing potential beneficiaries about the available budget of the CRGR Programme – ideally through a publicly available platform or information system where the reduction of the approved budget of the Programme, per category of audiovisual works, can be monitored at any time, in the amount of aid provided for in each approval decision issued and posted on DIAVGEIA.

    Alternatively, it is proposed to submit an application for inclusion, in accordance with the terms and conditions provided for under the Joint Ministerial Decision currently in force for the allocation of the budget, regardless of the condition of having a sufficient relevant budget. In case of exhaustion of the budget for the specific year and type of audiovisual work, the beneficiary will be informed of the inability to include his investment plan at this time, due to exhaustion of the relevant budget, and the relevant application will not be rejected but will remain active, and the adoption of the approval decision will be referred to the following year, in accordance with the budget approved for this purpose.

    🤖 AI AnalysisℹAI analyzed this comment and extracted the main posts expressed by the author. Each position is broken down into arguments – click to see them.✦ Created with AI

    📍 Amendment of the definition of "autonomous audiovisual work" in Article 23(2) 0 business

    📍 Extension of investment aid coverage to any two cycles in television or mini-series (Article 26(5)) 2 B.C.

    🟢 Limiting the two cycles discourages investment in infrastructureFact check

    🟢 Affects the implementation of large-budget producersFact check

    📍 Repeal of paragraph 5 of Article 87 1 business

    🟢 Application time limitation creates planning problems and uncertaintyFact check

    📍 Amendment of Article 29(1)(a) to allow the submission of an application within the whole aid period (without time limit) 1 business

    🟢 Application time limitation creates planning problems and uncertaintyFact check

    📍 Amendment of Article 29(1)(a) to define an annual submission window 15 Jan-15 Jul 1 business

    🟢 Application time limitation creates planning problems and uncertaintyFact check

    📍 Amendment of Article 41(5) to maintain investment plan files for 10 years 0 business

    📍 Creation of a public platform for updating the available budget of the CRGR programme 1 business

    🟢 Without budget knowledge, applicants cannot appreciate funding possibilitiesFact check

    📍 Ability to submit an application regardless of the existence of a sufficient budget, with an action of applications in case of exhaustion 1 business

    🟢 The application remains active and the decision is postponed, reducing uncertaintyFact check

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15. 

    7822

    May 15, 2026

    OBSERVATIONS AND PROPOSALS OF THE ASSOCIATION OF INDEPENDENT AUDIOVISUAL PRODUCERS (SAPOE) IN THE DRAFT LAW OF THE MINISTRY OF CULTURE TITLE ‘Creative Greece: strengthening the cinematographic, audiovisual and creative sectors, establishing a body for books and other provisions for contemporary culture’

    In addition to Article 26(3)(c), we consider that the minimum threshold of eligible costs for the inclusion of animation – a fast-growing type, as you know – in the cash rebate scheme is particularly high. It is precisely because of the cost that the projects carried out are either short films or short series (children's or not) but with a large number of episodes (e.g. a classic format for children's animation is 26 episodes of 5-7 minutes each).

    Therefore, the introduction of a threshold of eligible expenditure with reference to the single episode is problematic due to the specificities of the genre and hinders its development, which, however, has been presented as a declared public policy objective in the audiovisual sector. It would therefore be more appropriate to refer to the total cost of the animated series by defining, for example, EUR 100 000 or EUR 150 000 as a reasonable ‘threshold’ of eligible costs rather than the way in which point (c) is regulated per episode.

    The cartoon in Greece is still in its infancy and its production in our country is facing serious difficulties. Adapting the provision according to our proposal will contribute to attracting international co-productions, gaining more experience and know-how in the genre and achieving the goal of the competent policy makers to enhance and develop animation, an objective that SAPOE unreservedly supports.

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    📍 Change of threshold of eligible costs from per episode to total series cost (100‑150 000 €) 4 B.C.

    🟢 The existing threshold per episode is too high for short films/series.Fact check

    🟢 The new limit per series (100‑150k€) corresponds to the nature of animation.Fact check

    🟢 It will enhance the attraction of international co-productions and know-how.Fact check

    🟢 Contributes to the achievement of the public goal of animation development.Fact check

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16. 

    7827

    May 15, 2026

    In Article 26 2.a) The amount of eligible costs of sixty thousand (60,000) euros with creative documentation content (documentary) is large for the data of Greek producers and must be reduced to the amount of forty thousand (40,000) euros.
    For b) and short productions regardless of content, but especially for documentaries, the amount of sixty thousand (60,000) euros must be reduced to twenty thousand (20,000) euros.
    We ask for the documentary and short film fiction and documentaries to be supported as a genre in all its forms.

    On the contrary, the beneficiaries are television channels, as they are financed by the Greek State in violation of international practice, 150-episode television series, while mini-series television designs containing more than 16 episodes are called mini-series, also in violation of international practice, according to which mini-series consist of 8-13 episodes with a single cycle.
    We ask that funding be set for only mini-series that include a maximum of 13 episodes and a single cycle.

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    📍 Reduction of the eligible amount for documentaries to 40.000 € 1 business

    🟢 The amount of 60.000 € is very high for Greek producersFact check

    📍 Reduction of the eligible amount for short productions to 20.000 € 1 business

    🟢 The amount of 60.000 € is very high for short productionsFact check

    📍 To consider documentary and short fiction film as a genre 1 business

    🟢 Ensures proper funding for documentaries and short fictionFact check

    📍 Fund only mini-series up to 13 episodes, one cycle 2 B.C.

    🟢 TV channels benefit, violating international practiceFact check

    🟢 International practice limits mini-series to 8–13 episodes, one cycleFact check

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17. 

    7828

    May 15, 2026

    Article 24: With regard to the maximum aid intensity in the case of production of a difficult audiovisual work, in our view, it is reasonable to raise the ceiling to 100%) the total cost of production, instead of keeping it at the current level of 80%) , which will make a significant contribution to the development of this particularly demanding and technically sensitive category of audiovisual works.

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    📍 Increase Aid Limit to 100%) production costs 1 business

    🟢 Significant enhancement of the development of demanding audiovisual worksFact check

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18. 

    7829

    May 15, 2026

    Article 23
    With regard to paragraph 3, we would point out that the 1st or 2nd producer project has been omitted without there being a reasonable reason for this omission and contrary to the definitions in force to date. In addition, it should be noted that the threshold of EUR 500 000 is extremely low and does not correspond to the conditions and production conditions of cinematographic works in most EU Member States. Its increase from 500,000 to 1,000,000 euros is not only necessary but also in line with the GBER, as there is no doubt that it falls under the concept of "low budget".
    We therefore propose that paragraph 3 be amended as follows:
    ‘3. ‘Difficult Audiovisual Work’ means a stand-alone audiovisual work which fulfils at least one of the following conditions:
    (ha) The only original is in Greek. The use of other languages to a limited or limited extent does not negate the fulfilment of this condition;
    (hb) It is the first or second work of a director or producer;
    (hc) is a project with a budget of up to EUR 1 million (1 000 000);
    (hd) is a short film or documentary work;
    (he) has limited possibilities for commercial exploitation’.

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    📍 Amendment of paragraph 3 to include the first or second project and increase the threshold to EUR 1 000 000 3 Fig.

    🟢 The omission of the 1st or 2nd project is irrelevant and without reasonable causeFact check

    🟢 The threshold of €500 000 is very low compared to other EU countriesFact check

    🟢 An increase to 1 000 000 € is necessary and in line with the GBERFact check

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19. 

    7830

    May 15, 2026

    Article 41
    Paragraph 2
    ‘2. After the end of the investment project, an exact copy of the audiovisual work (digital or in any form that allows access to it during the screening process) must be handed over to the Granting Authority by the applicant undertaking at its own expense. Such delivery shall take place no later than six (6) months after its first public commercial display.’

    we propose the following amendment:

    2. After the end of the investment project, a file of the audiovisual work (digital or in any form that allows access to it during the screening process) must be handed over to the Granting Authority by the applicant undertaking at its own expense.

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    📍 Remove exact copy requirement and 6 months deadline 0 business

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20. 

    7837

    May 15, 2026

    COMMENTS AND PROPOSALS OF THE ASSOCIATION OF DIRECTORS-PRODUCERS OF GREEK CINEMA (ESPEK) IN THE DRAFT LAW OF THE MINISTRY OF CULTURE WITH TITLE
    ‘Creative Greece: strengthening the cinematographic, audiovisual and creative sectors, establishing a body for books and other provisions for contemporary culture’

    Following consultations with the relevant associations on this draft law, we endorse the following comments on Articles 22-25:

    ARTICLE 22

    With regard to paragraph 2, we propose the following legislative adaptation:

    ‘2. The CRGR Support Program aims to enhance the production of audiovisual works in Greece and generally enhance economic growth, increase employment and promote the country as a destination for the implementation of investment projects in the audiovisual industry through the support of domestic and attracting international investments in this sector.

    Comments – Justification:
    In our view, for reasons of primarily legal-political consistency and the delimitation of the public interest in this case, it should be made clear, with the addition of an explicit reference, that the S/N aims a fortiori to enhance the production of audiovisual works in Greece, as moreover provided for in Law 4487/2017 (cf. Article 19 thereof and related references to the explanatory memorandum of Law 4487/2017). The above, moreover:
    the special nature of the aid under schemes (a) and (b) of the S/N Programme granted under, in particular, Article 54 of GBER 651/2014 for aid schemes for audiovisual works; and
    is fully in line with the request for certainty and legal certainty of the Entities as to the (actual) allocation of the budgeted amounts of total aid per year per aid scheme.

    In the context of point (b) above, please note that the S/N, like Law 4487/2017, is a specialised institutional tool for the continuous and effective support of the development of Greek audiovisual production, completely distinct from the thematic aid schemes of Law 4887/2022, which should not be treated exclusively as a means of providing occasional assistance to economic activity in general in Greece – this would call into question the compatibility of the aid granted with Article 54 of GBER 651/2014. This observation is inextricably linked to the unfortunate attempt, in our opinion, to fully harmonise the provisions of the S/N with those laid down in Law 4887/2017, as if the audiovisual industry is the 14th thematic regime of the development law, even though the CRGR Programme serves strategic objectives of public interest, beyond and outside the characteristics of a typical development law.

    With regard to paragraph 3, we would point out that ensuring, even indirectly, the constant and uninterrupted availability of the relevant amounts of aid to beneficiaries in depth is a conditio sine qua non for the effectiveness of the legislative framework to be adopted and for the successful attraction of international investment in the audiovisual production sector in Greece.

    It is well estimated that the perpetuation of uncertainty as to the substantial continuation of the Greek cash rebate in the next few years will reverse the growth path and extroversion of Greek audiovisual production, definitively undermining its prospects.

    Nevertheless, and aware of the objective impossibility of expressly providing for a specific annual minimum threshold of funds allocated per aid scheme, in order to assure Greek and foreign audiovisual production companies of the unwavering political will to support the audiovisual industry in Greece expressed through the S/S, consideration could be given to the provision of annual information by the Greek Centre for Cinema, Audiovisual Media and Creation S.A. on the total amounts of aid envisaged for the CRGR Programme each time in the Medium-Term Fiscal Strategy Framework, starting with the MTFS 2025 – 2028.

    ARTICLE 23

    With regard to paragraph 3, we would point out that the 1st or 2nd producer project has been omitted without there being a reasonable reason for this omission and contrary to the definitions in force to date. In addition, it should be noted that the threshold of EUR 500 000 is extremely low and does not correspond to the conditions and production conditions of cinematographic works in most EU Member States. Its increase from 500,000 to 1,000,000 euros is not only necessary but also in line with the GBER, as there is no doubt that it falls under the concept of "low budget".
    We therefore propose that paragraph 3 be amended as follows:
    ‘3. ‘Difficult Audiovisual Work’ means a stand-alone audiovisual work which fulfils at least one of the following conditions:
    (ha) The only original is in Greek. The use of other languages to a limited or limited extent does not negate the fulfilment of this condition;
    (hb) It is the first or second work of a director or producer;
    (hc) is a project with a budget of up to EUR 1 million (1 000 000);
    (hd) is a short film or documentary work;
    (he) has limited possibilities for commercial exploitation’.

    We propose the following amendment to paragraph 6:
    "…End of investment plan: the completion of the physical and financial object of the production works related to the investment, which is considered to occur on the date of the application for the appointment of a chartered accountant or auditing company, in order to start the process of certification of expenditure, referred to in the decision to include financing of the investment project. The end date of an investment plan may not exceed three (3) years from the start date of the investment plan, unless there has been an extension of the end time of the investment plan in accordance with Article 32(3)(c). c) of this Law.
    Comments – Justification: The substantive definition of the concept of the end of the investment project should be added, also in order to avoid requests for the appointment of a certified auditor/accountant on investment projects that are partially completed/not mature for audit.
    Furthermore, as regards the maximum duration of the investment plan, account should also be taken of any extension of its expiry time following an amendment in accordance with the procedure laid down in Article 32 of the S/N.
    In paragraph 7, the name of the Company is erroneously referred to as NATIONAL CINEMA CENTER etc. instead of the correct GREEK CINEMA CENTER etc.

    ARTICLE 24

    With regard to paragraph 2, we propose the following legislative adaptation:
    "…This limit is extended to sixty percent (60%) ) the eligible costs of the total cost of production of the audiovisual work in the case of cross-border production and 80 % (10080%) ) the eligible costs of the total cost of production of the audiovisual work in case of production of a difficult audiovisual work …'
    Comments – Justification:
    (i) The proposed regulation requires targeted adjustments since the intensity of all State aid is consistently calculated as a percentage of the total production costs of the aided audiovisual work and not (only) of the eligible costs of the investment project implemented in the Greek territory. Otherwise, the total amounts of State aid allowed per investment project will be dramatically reduced. Furthermore, to the extent that the proposed wording of Article 24(2)(ab) of the S/N goes back to and aims at incorporating the corresponding wording of EU General Block Exemption Regulation 651/2014 (‘GBER’) into Article 54(7) thereof, it should be noted that the GBER, for the purposes of calculating the maximum aid intensity for cross-border producers, in this case refers to the total eligible costs implemented in all Member States, i.e. the total production costs of the aided audiovisual work, and not individually to the eligible costs implemented per Member State. Therefore, the arrangement under consultation in Article 24(2) of the S/N should be amended so that the maximum aid intensity for cross-border production (60%) be calculated as a percentage of the total production cost of the audiovisual work, as expressly provided for under the current framework (cf. Article 27(4) of Law 4487/2017).

    (ii) With regard to the maximum aid intensity in the case of production of a difficult audiovisual work, in our view, it is reasonable to raise the ceiling to 100%) the total cost of production, instead of keeping it at the current level of 80%) , which will make a significant contribution to the development of this particularly demanding and technically sensitive category of audiovisual works. Please note that the above is fully in line with Article 54(7) of the GBER, which provides that the maximum aid intensity for difficult audiovisual works may amount to 100%) the (total in all Member States) eligible costs.

    ARTICLE 25

    With regard to paragraph 1, we propose the following amendment:
    ‘1. The investment projects for audiovisual works included for financing under the CRGR-FTV and CRGR-Animate schemes are supported through the provision of an investment incentive, which consists in the provision of a grant by the Greek State to cover part of the eligible costs of the investment project, which is calculated, after the certified end of the investment project, as a fixed percentage of forty percent (40%) ) on the value of the eligible production costs, as defined in paragraph 3 hereof. The amount of the aid shall be paid in a single payment to the beneficiary.’
    Comments – Justification: For reasons of legal accuracy and to ensure the tax treatment of the aid granted, it should be explicitly clarified that the aid consists in the free provision of a sum of money to the beneficiary, as provided for in Law 4487/2017. Furthermore, a reference should be included to the method of payment of the aid, which is an essential feature of the aid – to this end, the corresponding reference to Article 35 of the Income Tax Code is not sufficient. Moreover, in our view, where the Income Tax Code refers to a ‘grant’, the relevant term should be replaced by the terms ‘investment incentive’, ‘payment’ and/or ‘aid’. The term ‘subsidy’, apart from being legally inappropriate and typologically inaccurate, appears to be essentially misplaced, as it does not comply with the specificity of the aid mechanism in question as a fully-fledged investment tool with multiple benefits for the national economy and a contribution to GDP growth in the country, as documented by relevant studies known to the competent Ministry.

    With regard to paragraph 2, we propose the following amendment:
    ‘…Incentive effect: the aid has an incentive effect only if the beneficiary has applied for funding to be included in the aid scheme before the start of work on the investment project, as defined in Article 2 pt. 23 of the GAC. Where the economic object of the inclusion decision is amended in accordance with Article 32(3)(e) of this Law, the incentive effect of the aid shall be maintained only if the beneficiary has submitted the application for amendment before the start of the relevant works.’
    Comments – Justification: As long as the current possibility of a limited increase in the total amount of eligible expenditure authorised in the CRGR-FTV aid scheme is maintained in the proposed S/N, with the addition of new eligible expenditure, clarification will be required in Article 24(2)(b) to ensure that the provision of this possibility is also legally compatible with the incentive effect of the aid under this scheme. In particular, and taking into account the provisions of Article 6(2) of GBER 651/2014, the Agency should explicitly request the addition of the new aided expenditure before the start of the works corresponding to its implementation – and therefore the incentive effect of the additional aid provided is maintained.

    With regard to paragraph 3, we propose the following amendment:
    3. The eligible costs of all the aid schemes of the Programme are the costs for the production of an audiovisual work, which are incurred in the Greek territory and do not exceed eighty per cent (80%) the total cost of all production works of the audiovisual work (eligible production costs).'
    Comments – Justification: The proposed provision is a verbatim transposition of Article 26(1) of Law 4487/2017. However, the latter provision had in some cases been the subject of an incorrect legal interpretation by the competent services of EKOME, with the result that, for the implementation of post-production operations only in Greece, only the post-production costs of the investment project were taken into account for the purposes of determining the total production costs – a practice which, it should be noted, was contrary, inter alia, to Article 54(9) of GBER 651/2014.
    Therefore, and in order to remove any relevant doubt as to the concept of total production costs, it is proposed to include an explicit clarification in this provision that the calculation of the total production costs of the investment project should take into account the costs of all production operations.

    ARTICLE 26

    With regard to paragraph 2(b), please note that the minimum eligible expenditure of EUR 60 000 for short films, whether cinematographic or television, for inclusion in the cash rebate is extremely high and does not correspond to the production conditions for short films in Greece. If the arrangement remains unchanged, almost all short films will be excluded from inclusion in the aid scheme. Therefore, we propose an arrangement corresponding to point (d) of the same paragraph and an adjustment of the prescribed limit to EUR 35 000.
    Similarly, with regard to point (a), the minimum eligible expenditure threshold for feature films could be reduced to 120,000 (double that of documentary films) in order to support low-budget films.
    As regards paragraph 6, as it stands, interpretative difficulties arise and the true meaning of this provision should therefore be clarified.
    According to Article 54(4) of GBER 651/2014, if a Member State requires a minimum level of production activity to take place in its territory for a project to be eligible for aid, that level shall not exceed 50%) of the total production budget. Moreover, in accordance with the above provision of Article 54 of the GBER, the maximum amount of expenditure subject to territorial obligations shall in no case exceed 80%) of the total production budget.
    Given this, for reasons of legal certainty, it should be expressly provided what exactly will apply in the event that the thresholds of the minimum eligible costs required under Article 26(2) to (4) of the S/N infringe, in cases of an extremely limited overall production budget, the thresholds laid down in Article 54(4) of GBER 651/2014.
    In our view, in such a - not unlikely - case, the amounts of the minimum eligible costs required should be adjusted downwards without rejecting the inclusion of the investment project in one of the aid schemes of the S/N.

    Following the consultations of GSPEK with the relevant associations on this draft law, we endorse the following comments on Articles 27-41:

    ARTICLE 27

    With regard to Article 27, we propose the following legal wording:
    ‘4. Enterprises implementing investment projects carried out on the initiative of and on behalf of the public sector or the television station of the Hellenic Parliament, on the basis of a contract for the execution of works, concessions or the provision of services, with the exception of ERT S.A., shall not be considered to be beneficiaries of the aid under this scheme:… (c) enterprises implementing investment projects carried out on the initiative of and on behalf of the public sector or the television station of the Hellenic Parliament, on the basis of a contract for the execution of works, concessions or the provision of services, with the exception of ERT S.A.’
    Comments – Justification: To remove any doubts, it is proposed to include an explicit reference to the ERT exemption, as provided for in Article 25(5)(c). Law 4487/2017.

    ARTICLE 28

    On paragraph 1, we stress the need to explicitly include borrowing costs and bank charges in the total eligible production costs, in stark contrast to the existing regulatory plan. In the Greek environment, which lacks an organised and effective strategy to support the sector from the financial system, it is incorrect and anti-developmental not to include the relevant costs in the eligible costs. Greek production companies inflexibly bear the relevant costs, without balancing mechanisms, thus making their activity more difficult, and the often observed delays in the implementation of the investment plan entail even greater bank costs. This is therefore the right opportunity to partially improve the existing regime by changing the provision in the direction we propose.

    In addition, we propose adding to paragraph 1(b) the costs of purchasing equipment and consumables that are not fixed assets.
    The proposed addition resolves the critical issue for the bodies of the eligibility of the specific expenditure in a manner consistent with the provisions of point (ca) of the above provision.
    In this regard, it should be noted that, in the context of the application of Law 4487/2017, EKOME has consistently rejected as ineligible incurred costs incurred by the Entities for the purchase of equipment used as a backdrop for the production needs of the audiovisual work and then either it is destroyed/consumed according to the programming/scenario during the execution of the work, or it ceases to have the slightest usefulness for the Entities after the end of the filming (due to the customised modifications/adaptations made to it for the production needs). That was so, even though the impossibility of leasing that equipment was obvious, since it was reasonable for no one to lease equipment in order to destroy it or render it essentially inoperable as a result of the lessee’s specialised interventions in that regard, thus making it unavailable for further exploitation by its owner.
    Consequently, in our view, legislating as eligible expenditure for the purchase of equipment intended to be consumed in the context of the implementation of the investment plan appears perfectly reasonable and justified, all the more so in the light of the relevant definitions of the concept of fixed assets in Law 4308/2014 as well as in POL. 1073/31.03.2015.
    With regard to paragraph 3, we propose the following amendment:
    ‘3. …. In the event of commencement of the works of the investment project for expenditure before the above-mentioned date of application for inclusion of funding, with the exception of preparatory actions for expenditure for preparatory production actions which do not constitute an event of commencement of an investment project in accordance with Article 23(5), the entire investment project shall become ineligible for funding in all aid schemes under this Law.’
    Comments – Justification: In our view, consideration should be given to reinstating the corresponding wording of Article 20(5) of Law 4487/2017, which refers to the start of work on the investment plan as an event that renders the entire investment plan ineligible.
    In particular, the start of works is a broader concept than the realisation of individual costs by the Entities in time before the start of the investment plan. In practice, moreover, there is a sporadic occurrence of ineligible costs incurred by the bodies (not only for preparatory works), before the submission of the application for inclusion, in the case of advance payments against future implementation of works of the investment project – without this rendering the investment irreversible.
    Consequently, the contested subparagraph of Article 28(3) of the S/N needs to be amended in order to remove the restrictive and ineffective approach according to which expenditure of at least EUR 1 before work starts automatically leads to the rejection of the entire investment project.
    Crucially, the above position is fully supported by the provisions of Article 6(2) of GBER 651/2014, which similarly as a criterion for affirming the incentive effect of aid provides for the non-initiation of works before the submission of the application for inclusion and not the non-execution of any relevant expenditure by the bodies.

    ARTICLE 30

    With regard to paragraph 1, we propose the following legislative adaptation:
    ‘1. The procedure for assessing the application for inclusion of financing for an investment project in all aid schemes under this Programme shall be completed within three (3) months of its submission to the information system.’
    Comments – Justification: Order in the administration, as an extremely reasonable time, a time limit for the completion of the assessment of the application for the inclusion of financing of an investment project, is deemed appropriate and useful, taking into account, inter alia, the huge time delays that have generally been observed (even recently in a progressive manner) in the application of the current regime, and in several cases to the detriment of the protected rights and the legal interests of the Entities. Although the deadlines for the Administration are, in principle, indicative, the strong recommendation – through the proposed arrangement – to the competent services of the New Body to respect the set quarter as the last reasonable time to complete the evaluation process is expected to be positive for the effective and smooth functioning of the CRGR Programme.
    Regarding paragraph 3, we consider that the last sentence of the provision ("and may decide to include the … investment plan, which have more than one source of funding") presents serious interpretative difficulties in ascertaining its true meaning and its implementation is expected to be problematic. For reasons of legal certainty, all the more so since this is essentially an additional, decisive criterion for the inclusion or non-inclusion of the investment project in the aid schemes of the S/N by the Evaluation Committee, in our view the need to delete the specific subparagraph of Article 30(3) of the S/N or, alternatively, to clarify it in order to remove any misinterpretations should be examined.
    With regard to paragraph 5, we propose the following addition to the provision:
    ‘5. A precondition for issuing a decision on the inclusion of funding is the existence of a certificate from the competent financial department of the supervising Ministry on the existence of the relevant annual budget per aid scheme of the Programme. This attestation shall be issued once at the beginning of each financial year and shall relate to the total annual budget per aid scheme, taking into account the provisions of the General Part and Article 54 of the GBER. As regards the CRGR-FTV aid scheme, the ministerial decision referred to in Article 87(2) of this Law should in any case ensure a balanced reinforcement of the two pillars in the context of the use of the relevant annual budget.’

    Comments – Justification:
    (i) For reasons of legal certainty, it should be clarified what exactly will apply to submitted applications for inclusion of funding in case the relevant annual budget is not sufficient to cover the specific investment projects to be included. This is a ‘grey area’ of the S/N under consultation which should be properly regulated. In particular, the following questions are raised: in the event that the annual budget for the aid scheme applied for is not sufficient, will a financing inclusion decision be adopted despite the absence of relevant provisions in the annual budget established or not? In the event of a negative reply to point (a), will the application for inclusion of funding be rejected or retained by the Evaluation Committee (which will temporarily abstain from taking a decision) in order for the relevant decision to be issued within the next financial year and in accordance with the principle of time priority? In our view, it is reasonable and fair for the latter to apply, taking into account the principle of priority in time.

    (ii) GSPR considers as the highest priority the legislative safeguarding and safeguarding of the real strengthening of Greek Cinema - the pre-eminent sector of the Greek audiovisual industry with an extrovert orientation and a pillar of attracting international investment in the country - in the context of the operation of the CRGR-FTV aid scheme. For this reason, and in accordance with the requirements of the principle of transparency, especially as regards the crucial issue of the allocation of public funds between the 2 pillars of the CRGR-FTV, it is proposed to include a new subparagraph in Article 30(5) of the S/N on ensuring a balanced reinforcement of the 2 pillars of the CRGR-FTV aid scheme. The proposed wording of a general principle trial is technically neutral and therefore does not raise any legal problems from the point of view of both competition law and the text of the EU State aid framework.

    ARTICLE 32

    With regard to paragraph 3(a), we propose the following legislative adaptation:
    ‘3. An application for amendment of the conditions for the inclusion of an investment project may relate exclusively to: an internal redistribution of the categories of eligible costs included in the investment project approved by increasing or decreasing them, provided that the increase exceeds twenty per cent;%) ) by category of eligible expenditure’.

    Comments – Justification: It is proposed to delete the separate reference in case of reduction of expenditure by category above 20%) , given that, with the proposed provision, even if the increase per category does not exceed 20%) after internal reallocation, any parallel decrease in other categories above 20%) necessitates a request for amendment. However, individual reductions of the authorised eligible amounts above 20%) can take place legally without the need to modify the investment, since in principle they are freely allowed, provided that at least 50%) the eligible costs, respecting these thresholds, in accordance with Article 33(6) of the S/N.
    Moreover, reductions in eligible costs per category do not in any way burden the budget of the New Entity for the provision of aid – on the contrary they have the effect of limiting the relevant public expenditure in the form of aid and therefore, in so far as they do not breach the thresholds of Articles 26 and 33(6) of the S/N, they do not call into question the service of the public interest.
    Finally, it should be noted that the requirement to amend the conditions for the inclusion of the investment in the event of an individual reduction in expenditure per category of more than 20%) (i.e. without the parallel increase exceeding this percentage) amounts to an unacceptable burden on the territoriality obligations of GBER 651/2014, which gives operators the freedom in principle to incur significantly lower costs in the Member State of the aid than initially budgeted.
    With regard to paragraph 3(c), we propose the following amendment:
    ‘3. An application for amendment of the conditions for the inclusion of an investment project may relate exclusively to: … (c) Extending the expiry time of the investment plan, as declared in the financing inclusion decision, which may not exceed six (6) three (3) months.

    Comments – Justification: The abbreviation with the proposed provision of Article 32(3)(c) of the S/N of the time extension of the duration of investment projects from 6 to 3 months, for reasons not related to the occurrence of force majeure events, excessively limits the flexibility of the bodies and does not correspond to the reality of the changing conditions for the implementation of investment plans for the production of audiovisual works (which in no way resemble at this point the investment plans of Law 4887/2022 for which an extension of their duration of maximum up to 3 months is granted).
    Therefore, a corresponding rewording of the contested provision of the S/N is required in line with what has been in force to date (cf. Article 10(3) of Joint Ministerial Decision 19292 ΕΞ 2022).
    With regard to paragraph 3(e), we propose the following adaptation:
    ‘3. An application for amendment of the conditions for the inclusion of an investment project may relate exclusively to: … (e) Addition of new aided expenditure by increasing the total amount of approved eligible expenditure by up to ten per cent (10%) the amount of eligible expenditure, within the limits of the approved budget in cases of unforeseen circumstances.';

    Comments – Justification: Maintaining the possibility for bodies to add new aided expenditure (albeit at a lower rate of increase) is welcome, but it is necessary to delete the reference ‘within the limits of the approved budget’, given that:
    (a) This petition reiterates the relevant provisions of Article 32(5) of Law 4487/2017, which, however, provided for a general possibility of adding a new aided beam without being limited to the occurrence of unforeseen circumstances as the sole justification for submitting the relevant request – hence the requirement not to exceed the total production budget in the event of an increase in eligible costs seemed perfectly reasonable;
    (b) However, the new provision substantially limits the scope of the addition of new eligible expenditure, which now only grants ΄ exceptions to ‘unforeseen circumstances’, and
    (c) The ‘unforeseen’ contribution is in fact linked not only to an increase in the amount of eligible costs, but also, as a rule, to an upward revision of the total production budget of at least the same amount.
    Therefore, in order for the bodies to make full and effective use of the possibility offered to them by the S/N, as well as further to avoid interpretative difficulties in the application of Article 32(3)(e) of the S/N in cases of domestic producers or producers of limited economic scope (cf. the problematic application to date by EKOME of the current provision of Article 32(5) of Law 4487/2017), it is proposed to delete the reference at issue ‘within the limits of the approved budget’.
    With regard to paragraph 7, we propose the following legislative adaptation:
    ‘7. The change in the total number of days of shooting or in the total number of days of other production work included in the approved investment project, provided that it occurs within the time limits for the implementation of the investment project and does not bring about or significantly alter the place of shooting as described in the approved investment project to such an extent that it affects the cultural criteria on the basis of which the investment project was approved, shall be submitted as part of the final report of the chartered accountant in accordance with Articles 33 and 34 and shall not require an amendment decision to that effect by the Granting Authority.’

    Comments – Justification: During the implementation of Law 4487/2017 and its implementing Joint Ministerial Decision, even the slightest change in the location of filming by the bodies was unlawfully treated by EKOME, in a few cases, from the outset and without further ado as a substantial amendment of the inclusion decision. For this reason, for reasons of legal certainty, a specific objective criterion should be provided on the basis of which the variation/change of the location of the filming can take place without modification of the investment site in accordance with Article 32 of the S/N. In our view, the variation of the location of the filming should be considered as non-substantial as long as it cannot lead to an effect on the investment's score regarding the filling of the p

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    📍 Amendment of Article 22(2) – insertion of an explicit reference to aid for the production of audiovisual works 2 B.C.

    🟢 Alignment with Law 4487/2017 and ensuring legal certaintyFact check

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    🟢 Solve Equipment Eligibility Problem ConsumedFact check

    📍 Amendment of Article 28(3) – preparatory expenditure is not the start of an investment project 1 business

    🟢 Prevents automatic rejection of the project due to small preparatory costsFact check

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    🟢 Reduces administrative delays and improves efficiencyFact check

    📍 Removal of an unclear sentence in Article 30(3) 1 business

    🟢 The terrain creates interpretative difficultiesFact check

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    🟢 Ensures legal certainty and transparency in fundingFact check

    📍 Amendment to Article 32(3)(a) – removal of amendment requirement for reductions >20%) expenditure 1 business

    🟢 Reductions do not affect the budget and do not require additional requestsFact check

    📍 Amendment of Article 32(3)(c) – limitation of the extension of the end of the project to 3 months 1 business

    🟢 Agrees with other laws and prevents excessive prolongationFact check

    📍 Amendment of Article 32(3)(e) – removal of a restriction "within the limits of the approved budget" 1 business

    🟢 Gives flexibility in unforeseen situations without limiting reinforcementFact check

    📍 Amendment of Article 32(7) – possibility of small location changes without an amendment decision 1 business

    🟢 Prevents unnecessary administrative procedures for insignificant changesFact check

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21. 

    7841

    May 15, 2026

    ARTICLE 22
    As we pointed out in our general position, we consider it a very important shortcoming not to specify in any way the funds of the selective strand and that of the “automated mechanism”, neither as a percentage of the State budget, nor as a minimum lump sum. Equally important is the lack of determination of the ratio between them.

    ARTICLE 23
    We believe that the criteria for classifying an audiovisual work as “difficult” should include the 1st or 2nd producer’s work, as well as short films and documentary works, as is the case with the current legal framework. We also believe that the budget ceiling for a project with the same designation should be €1,000,000 instead of the 500,000 provided for in this bill.

    ARTICLE 27
    We believe that a clear provision should be added for the audiovisual investment projects of independent producers that have received financial support from ERT to ensure that they can apply to the CRGR-FTV programme.

    ARTICLE 28
    We consider that the costs identified as eligible for the CRGR-FTV programme should be enriched and updated in order to meet the real requirements of audiovisual productions and to include costs such as, for example, those relating to bank loans necessary for the productions' cash flow.

    ARTICLE 41
    The provision of the article for an obligation to deliver to the Agency an unaltered copy of the audiovisual work as well as its use by other public bodies is particularly problematic and unrealistic, whether it is a Greek production or an international co-production, as it conflicts with a number of legal issues of intellectual property and ignores or ignores the way the international audiovisual industry operates.

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    📍 Specify the allocations of the selective arm, the automated mechanism and their proportion 1 business

    🟢 The lack of identification is a serious lack of transparencyFact check

    📍 To include the 1st ‑2nd producer's works, short films and documentaries in the "difficult" criteria 1 business

    🟢 This is in line with the current legal frameworkFact check

    📍 Increase the budget ceiling to 1,000,000 euros 1 business

    🟢 Realistically reflects project costsFact check

    📍 To explicitly provide that independent audiovisual investment projects with ERT support can apply to the CRGR‑FTV programme 1 business

    🟢 Ensures the right to apply for these projectsFact check

    📍 Enrich the eligible costs of the CRGR‑FTV programme, including bank loans for cash flow 1 business

    🟢 Addresses the real needs of producersFact check

    📍 Remove the obligation to deliver a copy of the work to the Organization and its use by other public organizations 1 business

    🟢 Violates copyright and does not align with international practiceFact check

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22. 

    7844

    May 15, 2026

    GENERAL PRINCIPLES – CREATION

    The main purpose of a Law on Greek Cinema is clearly stated in the first -and demonstrably better- most effective Law of Nikolaos Martiou, 1961: “THE DEVELOPMENT OF THE ART OF GREEK CINEMA”.

    Development is not a mechanism that works automatically, but precedes the CREATION, cultivation, education, talent and capacities of a HUMAN in this case the DIRECTOR.

    It is he who creates the PROJECT, or even better, the MODEL of the work, which serves nothing but the production of IMPACTS. And these copies, sometimes on a physical substrate (copies) or in digital transcription and in any case in intangible projection-transmission, constitute the PRODUCT for exploitation and exploitation.

    In the production-creation phase, the alleged Main Producer IS NOT THE FINANCER, but an Executive Producer, working with the director on the financing, and production processes of the film. It is for this reason that he is granted the Relative Spiritual Right.

    Throughout the production/creation phase, there is no “property right”, except when the work is completed and the product(s) are made available for exploitation/exploitation, i.e. development.

    A second issue formulated in the European Charter of Delphi for Audiovisual and adopted by the EU, is the finding that Television, as far as fiction is concerned, is a child of Cinema, and that is why the institution of the percentage aid for the production of CINEMA FILMS was adopted. If cinema, a space of creation and a testing ground for the renewed language of cinema, disappears, TV will be immersed in boredom and uselessness.

    GENERAL COMMENTS

    It is impossible to study in a few days a long text that was obviously written by people who do not know cinema, and which will unfortunately prove to be not only ineffective, but also disastrous for the Audiovisual in Greece. Competitiveness with other cinemas is reduced to zero. The mere lack of reference in the proposed Bill to the role of the Director is a global originality, which makes the Law a tool of intertwining and scandals, to a multiple extent than the effects of the Geroulanos Law.

    It is not only the conflict with other Laws, but above all the SECURITY - as I pointed out to Mrs. Minister about four years ago, which allows any kind of interweaving and serving personal interests and unfair competition.

    In brief and with titles I will mention a small part of the substantive remarks, which I had supported together with the then President Panos Loukakos, in our short term of office on the Board of Directors of the Greek Film Centre.

    1. Transparency, Equality, Meritocracy.
    2. Objective criteria clearly formulated at all levels.
    3. Reporting at all levels by outcome.
    4. Creation of a Register of Producers, and evaluation of the results.
    5. Collaboration and advice of experts, who are the people of cinema.
    6. Creating incentives, not encouraging directives.

    In the latter, I will refer to the also unprecedented paragraph on “the theme to be proposed each year by the Ministry” for the creation and production of films to be funded”. It is just a ridiculous proactive one, far worse than the Preventive Censorship of old, which not even Zhdanov - a cultural professor of Stalin's time - had dared to apply.

    This note was written out of the desperation of a man who contributed with all his generation to the creation of a reliable Greek cinema, and sees him today disintegrating into what he composed.

    Persuasion
    Kostas Ferris

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    📍 Addition of a transparent, egalitarian and meritocratic framework to the law 1 business

    🟢 Lack of transparency, equity and meritocracyFact check

    📍 Establishment of objective evaluation criteria at all levels 1 business

    🟢 Absence of clear criteria leads to undue discretionFact check

    📍 Integrate a results report at all levels of the process 1 business

    🟢 Lack of Reporting Prevents AccountabilityFact check

    📍 Creation of a register of producers and evaluation of their results 1 business

    🟢 Without register producers exploit the systemFact check

    📍 Cooperation and advice of specialized film experts 1 business

    🟢 Film experts are the right consultantsFact check

    📍 Creating incentives instead of encouraging guidelines for producers 1 business

    🟢 Incentives promote creation, conversely the instructions limitFact check

    📍 Removal of a paragraph that imposes an annual theme by the Ministry 1 business

    🟢 The annual theme limits creative freedomFact check

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23. 

    7849

    May 15, 2026

    COMBATING INTERNET PIRAEUS AS THE MAIN MEANS OF SUPPORTING THE AUDIOVISUAL SECTOR
    Article 4 of the draft law on the mission of the Société Anonyme, entitled ‘Hellenic Centre for Film, Audiovisual and Creation S.A.-Creative Greece S.A.’, includes, inter alia, (e) ‘its contribution to the fight against piracy, whether online or technological or otherwise, in the cinematographic, audiovisual and creative sectors of the country in cooperation with jointly competent bodies’, and (w) ‘[to] contribute to the policy for the fight against piracy, whether online, technological or otherwise, in audiovisual media through actions and interventions of a technological or non-technological nature and shall be recommended to the competent bodies of the Ministry of Culture’.
    The Motion Picture Association of Europe, Middle East and Africa (MPA-EMEA) welcomes this enhanced competence of the new body to contribute to the fight against piracy and to make recommendations for a higher level of protection of intellectual property rights in Greece. This legislative objective can be effectively achieved in practice, if and when Law 2121/1993 on Copyright and Related Rights is amended in such a way that it explicitly allows for the immediate dynamic interruption of access to audiovisual content offered by illegal websites and sites (full dynamic site blocking ) by administrative decisions of the Committee for the Notification of Online Infringement of Copyright and Related Rights (EDPPI) and in particular the interruption of access not only to "live events", but also to audiovisual works available on request (VOD). This issue - identified as of paramount importance for authors and rightholders of audiovisual works - remains unresolved in Greece. Best practices have been fully adopted in other countries, such as Italy, Spain, Ireland, the Netherlands, Sweden, Denmark, Lithuania, the United Kingdom. We hope that the Greek government will adopt the proposals of MPA-EMEA and many Greek beneficiaries, such as the Society for the Protection of Audiovisual Works (EPOE), who have strongly supported legislative intervention to increase the effectiveness of the Greek administrative regime for blocking access to illegal websites and sites.

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    📍 Amendment to Law 2121/1993 on dynamic blocking of access to illegal websites 4 B.C.

    🟢 Improves the protection of authors' rightsFact check

    🟢 Agrees with best practices of other countriesFact check

    🟢 MPA-EMEA supports enhanced competenceFact check

    🟢 Required for an effective fight against digital piracyFact check

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24. 

    7855

    May 15, 2026

    With the abolition of ECC-EKOME, we find that there is no longer any state concern for Greek cinema, as is the case in all European states that respect their modern culture and as should be the case in Greece.
    The lack of reference to the entire draft law on how much and from where Greek Cinema will be financially supported indicates the disdain of the Ministry of Culture and the government towards domestic cinema, directors, technicians, actors living and working in Greece.
    The disappearance of the obligation to collect 1.5 %) From the channels to the cinema which for years has been a demand of the entire cinema, but also a law of the Greek state, makes even more obvious the desire of the government to constantly strengthen the canalists on the backs of the taxpayer citizen.
    It is clear the gifts to the private channels trying to legislate once again through this draft law, as well as the complete ignorance of the legislators involved as to the economic conditions of production of Greek films, but also of the fiction series of the private channels.
    For this reason, we are opposed to the separation of cinematographic films – telefilms.
    We are opposed to receiving a tax refund for television episodes with a production cost of less than €120 000.00 (which is also marginal).
    If the Greek state really wants to stand by the Greek productions of documentaries and short films, the cost should be set at 35.000 €.
    No deposit on foreign productions or TV series of private channels. Advance payment only to Greek films in the same context as defined by the CySEC.
    The Ministry of Culture, even at this last moment, must withdraw the bill, so that it can be rewritten from the beginning based on Greek cinema and its needs, as well as with safeguards against the overpricing of Greek serials and foreign films that paved the way for the economic collapse of EKOME.

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    📍 Do not separate cinematographic films from telefilms 1 business

    🟢 Separation reduces support for Greek filmmakingFact check

    📍 No tax refund for TV episodes under €120,000 1 business

    🟢 The €120,000 limit is marginal and does not encourage producersFact check

    📍 To set a production cost limit for tax refund at 35.000 € 1 business

    🟢 Cost 35.000 € will support documentaries and shortsFact check

    📍 Allow advance payment only in Greek films, not in foreign films 1 business

    🟢 Advance payment only in Greek films supports domestic productionFact check

    📍 To withdraw the bill so that it can be rewritten based on Greek cinema 2 B.C.

    🟢 The bill ignores the needs of Greek cinemaFact check

    🟢 Promotes overpricing and financial collapse of EKOMEFact check

    📍 Abolition of the obligation to collect 1.5%) from the channels to the cinema 1 business

    🟢 The collection 1.5%) It favours canalists at the expense of cinema.Fact check

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25. 

    7857

    May 15, 2026

    As a member of the Greek Documentary Association I agree with the observation in Article 26 2a and 2b. I think it is extremely important to treat this film genre with special attention and sensitivity.
    In Article 26 2.a) The amount of eligible costs of sixty thousand (60,000) euros with creative documentation content (documentary) is large for the data of Greek producers and must be reduced to the amount of forty thousand (40,000) euros.
    For b) and short productions, and especially for short documentaries, the amount of sixty thousand (60,000) euros must be reduced to twenty thousand (20,000) euros.

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    📍 Reduction of the amount of eligible costs for documentaries in Article 26 2a to EUR 40 000 2 B.C.

    🟢 The current amount of 60 000 euros is large for Greek productionsFact check

    🟢 The species needs special attention and sensitivityFact check

    📍 Reduction of the amount of eligible costs for short documentaries in Article 26 2b to EUR 20 000 2 B.C.

    🟢 The current amount of 60 000 euros is large for short documentariesFact check

    🟢 The species needs special attention and sensitivityFact check

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26. 

    7858

    May 15, 2026

    I am in favour of the EEN’s requests:
    Article 23: With regard to paragraph 3, we would point out that the 1st or 2nd producer project has been omitted without there being a reasonable reason for this omission and contrary to the definitions in force to date. In addition, it should be noted that the threshold of EUR 500 000 is extremely low and does not correspond to the conditions and production conditions of cinematographic works in most EU Member States. Its increase from 500,000 to 1,000,000 euros is not only necessary but also in line with the GBER, as there is no doubt that it falls under the concept of "low budget".
    We therefore propose that paragraph 3 be amended as follows:
    ‘3. ‘Difficult Audiovisual Work’ means a stand-alone audiovisual work which fulfils at least one of the following conditions:
    (ha) The only original is in Greek. The use of other languages to a limited or limited extent does not negate the fulfilment of this condition;
    (hb) It is the first or second work of a director or producer;
    (hc) is a project with a budget of up to EUR 1 million (1 000 000);
    (hd) is a short film or documentary work;
    (he) has limited possibilities for commercial exploitation’.

    Article 24: With regard to the maximum aid intensity in the case of production of a difficult audiovisual work, in our view, it is reasonable to raise the ceiling to 100%) the total cost of production, instead of keeping it at the current level of 80%) , which will make a significant contribution to the development of this particularly demanding and technically sensitive category of audiovisual works.

    Article 26: With regard to paragraph 2(a), the minimum eligible expenditure of EUR 60 000 relating to a documentary film is high. We therefore wish it to be adjusted to EUR 40 000. With regard to paragraph 2(b), we would point out that the minimum eligible expenditure threshold of EUR 60 000 for the short film, cinematographic or television, in order for it to be included in the cash rebate, is extremely high. We therefore propose an arrangement corresponding to that laid down in paragraph 2(d) and an adjustment of the prescribed threshold to EUR 25 000.

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    📍 Amendment of Article 23(3): adding a definition of "Difficult Audiovisual Work" 2 B.C.

    🟢 Skip 1st/2nd project without cause contradicts definitionsFact check

    🟢 Limit of €500,000.00 very low; increase to 1,000,000 € is necessary and in line with GACFact check

    📍 Increase of Article 24 aid to 100%) production costs 1 business

    🟢 Increase to 100%) significantly enhance the development of demanding projectsFact check

    📍 Reduction of minimum expenditure for documentaries from €60,000 to €40,000 1 business

    🟢 The current threshold of €60,000 is considered highFact check

    📍 Reduction of minimum expenditure for short films from €60,000 to €25,000 1 business

    🟢 The threshold of €60,000 is extremely high; proposal for alignment with other projectsFact check

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27. 

    7860

    May 15, 2026

    COMMENTS AND PROPOSALS OF THE ASSOCIATION OF CREATORS OF DIGITAL GAMES OF GREECE (GDA GREECE) IN THE DRAFT LAW OF THE MINISTRY OF CULTURE WITH TITLE
    ‘Creative Greece: strengthening the cinematographic, audiovisual and creative sectors, establishing a body for books and other provisions for contemporary culture’

    > In principle
    This bill, even in its current form, we consider to be a positive development in the right direction for the industry of video game development. This means of artistic expression is fundamentally different from the art forms that came before it, due to its interactive nature and beyond. As an Association, we congratulate the effort for distinctness of the independent arts, and we will focus our comments on CRGR-VGD which concerns us directly.
    VGD, which is the name of our holistic proposal for the start-up and then the potential sustainable development of our industry, is a series of financial tools, which as a body we have proposed. This proposal contains, among other things, a section (name VGD2.0 which we have already communicated to EKOME), which is quite close to the format of the CRGR-VGD, since it focuses on supporting new efforts of existing businesses, an important part of the “puzzle”, which needs immediate attention.
    We believe that with specific, pivotal changes, not to the overall structure of the CRGR-VGD but to its individual points, it can deliver what we wanted to achieve when we proposed VGD2.0 – and that is where we will focus on the present.

    > Article 23
    We would point out on paragraph 2(c) that, although in an academic and philosophical context games are in all respects a recognised form of contemporary art, and should therefore be cultural products in themselves, we do not have any such provision in law in Greece to date. In view of this, and in order to avoid excluding a significant part of our industry, we propose to reformulate it as follows: “.., digital play, cultural, educational, and/or recreational”.
    Also in paragraph 5(c), the description of the game design document (GDD) can be better formulated, since the “mathematical statistical analysis of the mechanisms” is something that does not correspond to a widely accepted description of a GDD. In addition, the initial production phase rarely starts with the writing of the GDD, but with the creation of small software prototypes (first playable), and the mapping of the central elements of the game under development into a concept document, the form of which depends quite a lot on the type of game (genre), but indicatively contains concept art, summary narrative overview, gameplay elements, distribution platforms, audience, etc. Thus, within (indicatively) 3-12 pages, the central idea is communicated and how its implementation will be approached.

    > Article 24
    Paragraph 2(ab) on difficult audiovisual works and 80%) , we agree with the statements of the Greek Film Directors-Producers Association (ESPEK) and the Association of Independent Producers of Audiovisual Works (SAPOE) on the same Article (ii), and we consider it reasonable to raise the threshold to 100%) .

    > Article 25
    On paragraph 2, while the base is close to the desired support mechanism, the numbers are not in line with the reality of the production process of a digital game.
    Most digital games that manage to secure external financing for publishing or investment achieve this when they have produced about the equivalent of 30.%) the production process (vertical slice).
    We believe that the aim of such a support mechanism (which does not cover the full amount of production) should be primarily to attract such external investments, and therefore focus on helping production reach the vertical slice.
    By extension, our proposal for paragraph 2 can be summarised as follows:
    In point (a), correct the initial production phase to indicate “prototype” rather than vertical slice, which is closer to what can be produced with 10%) of the project.
    Point (b) specifies that the production sub-phases, e.g. “demo”, “vertical slice” and “release”, may each have their own part of the grant: indicatively, 10%) each one.
    This will allow sufficient support for the creators to reach the focal point of the vertical slice faster (approximately 30%) production), in which external investments are highly likely, as some Greek studios have already proved.
    Alternatively, separating 10-30 could be done 30-10 without changing the text and have a similar effect, but we consider that the above changes offer a more accurate and comprehensible description. .
    Paragraph 3 on the upper limit of 80%) on eligible costs, we agree with the positioning of the Association of Audiovisual Producers (PACT) on the same article, and the positioning of the Association of Greek Cinema Directors-Producers (ESPEK) on the same article, point (3), and we also consider it reasonable to increase the limit to 100%) .

    >Article 26
    On paragraph 4, we consider that while the range of EUR 60,000-1,000,000 covers a large group of producers, there is another non-negligible group of smaller projects, in the range of EUR 45,000-60,000, which would make sense to examine. We therefore propose to lower the threshold for inclusion to EUR 45,000.
    On paragraph 7, point (j), our Association welcomes and considers crucial the decision not to include games of chance in the context of this funding.

    >Article 27
    On paragraph 2, we welcome the inclusion of all types of companies in the grant, as well as the margin for them not to be established during their application. These two points (as paragraph 3 also verifies), cover sole proprietorships that are an important part of our industry, and attract foreign companies respectively, which we find very positive.
    In point (b) of paragraph 2, however, it would be appropriate to extend the restriction as follows:
    Raise the threshold to years, and make it “within the last 3 years”
    Add alternative “… or have as their main income, receipts from games released in the last 10 years”
    These changes more realistically cover the nature of our industry.

    > Article 28
    On paragraph 2, we acknowledge the effort to integrate our proposals, however we would like to draw attention to the . numbers themselves.
    We propose the following changes:
    In point (b), the percentage rises to 20-30%) , since many types of digital games rely to a very large extent on quality writing, acting and translation into languages other than Greek.
    At point (e), the percentage rises to 10-20%) , and insert in addition the clause “and not to exceed EUR 20,000”. This double limitation reflects the way in which this cost scales up in terms of the overall size of production.
    Although point (f) was part of our initial discussions, we believe that it can be either limited or removed, as it is significantly less linked to production than other costs.

    > Article 29
    On paragraph 3, we consider that some changes are needed to bring the application process closer to the nature of the production of a digital game.
    We propose the following changes:
    In point (b) on cultural eligibility criteria, please refer to our comments on Article 23(2)(c).
    In point (b) on script summary, replace with a “concept document”, which is for games what the script summary is for films. Indicatively, it contains concept art, narrative overview, gameplay elements, distribution platforms, target audience, etc.
    In point (b) on the workers to be employed, we propose a quantified rather than a nominal reference to them, as well as a moderate commitment on the part of the applicants in this regard.
    We also propose the following addition, provided that the changes we propose for financing itself are included in Article 25:
    The delivery and evaluation of a first playable/tech “demo” file showing the main mechanics of the game and the USPs (unique selling points) that define it.
    We believe that this will prevent abusive practices towards the grant programme, without constituting a substantial obstacle to applicants who are able to carry out the project
    It should be clarified that we propose this addition, only under the above condition, since we believe that without the changes to Article 25, there is, on the one hand, a lesser need for the addition of this deliverable, and, on the other hand, it may act negatively.

    > Article 30
    On paragraph 1, we welcome the capping of the evaluation process at draft level, as we believe it will have a catalytic role in the longevity of the grant programme.

    > Article 34
    On paragraph 1, we consider it necessary - so that we can have a substantive discussion on further details - to clarify the definitions of phases a and b, as these are not sufficiently defined in paragraph 2 of Article 25.

    > Article 35
    With regard to paragraph 2, the wording seems to contradict the reference to an advance payment in Article 25(2)(a). We also consider it important to allow individual instalments to be paid in the sub-phases of the project. As mentioned in the comments on Article 25(2)(b), we propose the following wording: “… shall be paid to the beneficiary in instalments defined by the phases and sub-phases hereof, not exceeding one million … in total”

    > Article 38
    The wording of paragraph 4 leaves room for misinterpretation. We would like it to be clarified, in particular on the basis of which criteria the competent operator can recommend such a withdrawal, and what the recipient of the aid scheme can appeal against.

    > Article 39
    On paragraph 2, we welcome the transparency of the selection of a committee, and of the posting in DIAVGEIA.
    On paragraph 3, we welcome the reference to experts, but we propose the following changes to ensure the grant programme:
    Evaluation and selection of experts through independent authorities, with full transparency regarding the selection process, notably merit-based selection based on CV (studies and professional experience in related subjects). As an example, we bring the GSRT register and other corresponding registers that operate for the evaluation of funded projects.
    Ensure at least two (2) experts in the Committees (a) and (b), as the assistance of two specialists would be very positive and there would be a plurality of informed opinions at the discretion of the project.

    > Epilogue
    Finally, as the Association of Digital Game Makers of Greece (GDA Greece) we hope to see CRGR-VGD take its full form, ideally including the changes we propose. We believe that in this way it will be transformed into an important tool for supporting existing businesses, as well as an essential step for a more holistic support framework for our industry in the near future. We remain at the disposal of the state for further dialogues, both on the details of the implementation of the present, as well as on our complete and comprehensive proposal which addresses the difficulties of the sector at its root (first efforts, education, independent small productions), its trunk (medium and large productions from existing groups) and finally its fruits (missions to foreign conferences and organization of a national conference).

    🤖 AI AnalysisℹAI analyzed this comment and extracted the main posts expressed by the author. Each position is broken down into arguments – click to see them.✦ Created with AI

    📍 To reformulate point (c) of Article 23 to include 'digital play, cultural, educational, and/or recreational' 1 business

    🟢 Prevents the exclusion of the sector as a cultural productFact check

    📍 To amend the description of the GDD in Article 23(5)(c) by removing 'mathematical statistical analysis' 1 business

    🟢 Current wording does not correspond to the commonly accepted description of the GDDFact check

    📍 Raise the 80 limit%) in 100%) for difficult audiovisual works (Article 24(2)(ab)) 1 business

    🟢 Agreement with SEPEK and SAPOE, logical increaseFact check

    📍 In Article 25(2)(a) replace 'vertical slice' with 'prototype' 1 business

    🟢 Prototype is more realistic for 10%) productionFact check

    📍 Allow grant allocation per sub‑phase (demo, vertical slice, release) with 10%) each 1 business

    🟢 Helps Creators Reach Vertical Slice FasterFact check

    📍 To lower the transposition threshold from €60 000 to €45 000 (Article 26(4)) 1 business

    🟢 There is a significant group of smaller projects that need this supportFact check

    📍 Extend the year limit to 'within the last 3 years' for business eligibility (Article 27(2)(b)) 1 business

    🟢 Best Covers the Nature of Our IndustryFact check

    📍 Add revenue criterion for games released in the last 10 years (Article 27(2)(b)) 1 business

    🟢 Realistically reflects the business model of the industryFact check

    📍 To increase the percentage in point (b) of Article 28 to 20‑30%) 1 business

    🟢 Many games depend on quality writing, acting, translationFact check

    📍 To increase the percentage in point (e) of Article 28 to 10‑20%) and to add a limit of € 20 000 1 business

    🟢 This double limitation reflects the size of the productionFact check

    📍 Limit or remove point (f) of Article 28 1 business

    🟢 This point is less linked to productionFact check

    📍 Replace the script summary with a concept document that includes concept art, narrative overview, etc. (Article 29) 1 business

    🟢 The concept document is the equivalent for gamesFact check

    📍 Quantify employees instead of nominal reporting (Article 29) 1 business

    🟢 Provides clarity in evaluationFact check

    📍 Add first playable/tech demo delivery as deliverable, subject to article 25 changes 1 business

    🟢 Prevents abusive practices without hindering competent applicantsFact check

    📍 Clarify the definitions of phases a and b in Article 25(2) 1 business

    🟢 Necessary for a substantive discussion of detailsFact check

    📍 Allow payment of instalments according to phases and sub-‑phases, up to EUR 1 million (Article 35) 1 business

    🟢 Aligns the payment with the project scheduleFact check

    📍 Clarify the revocation criteria and the possibility of appeal for beneficiaries (Article 38) 1 business

    🟢 Current wording leaves room for misinterpretationFact check

    📍 Selection of experts through independent authorities with transparency and meritocracy (Article 39) 1 business

    🟢 Ensures a transparent and fair selection processFact check

    📍 Appoint at least two experts per committee (Rule 39) 1 business

    🟢 Offers pluralism and informed decisionsFact check

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28. 

    7865

    May 15, 2026

    Panhellenic Federation of Spectacle - Hearing
    Our Federation represents artists and employees in the Audiovisual sector.
    Dear Sir/Madam,
    We set out our concerns regarding the draft law submitted by the Ministry of Culture for public consultation entitled ‘Creative Greece: strengthening the cinematographic, audiovisual and creative sectors, establishing a body for books and other provisions for contemporary culture".
    The Draft Law was formed in absentia of the collective bodies of cinema and television, who are familiar with contemporary issues, since they have proven to have many years of national and European knowledge and experience.
    What we observe, from the beginning, is the Greek Film Centre, the main body for the exercise of cinematic policy and the main institution supporting Greek cinema to date, with all its institutionalized aims, given its actions to date, the regular and adequate funding of films is not ensured, and the only thing that is preserved is the title. The draft law promotes the notion of commercialization of film art, while it has failed to incentivize new creators.
    The new body that is being created lacks the organisational chart, the operation, the funding procedure, the budget and the individual funding programmes that are responsibilities of the Directorate-General for Cinema and concern domestic film productions. The process of advance payments should be clarified that it will only be implemented for domestic productions where there is a substantial need. Nowhere is it mentioned and therefore we do not know the total amount of the annual grants of the new Agency. There is no mention of creating or finding new funding mechanisms for film art, supporting the primary importance of the script, highlighting new creative talents.
    In particular, Article 4 in five pages describes "the mission and responsibilities" of the new Agency. What we find is that film is treated as a production for profit, ignoring and degrading its status as a work of art as well as its social and cultural role.
    Greek cinematic art, which is always referred to in the Draft Law, simply as cinematic production, is degraded. The reference to the support of audiovisual production means that the new operator will finance the TV series of private channels, thus continuing the political perception of E.KO.ME. This philosophy is not innocent, because it aims to equate cinematic art with television programs at the expense of financing an autonomous cinema that will support cinema as an art and social good.
    The legal obligation for TV stations to pay 1.5 is finally entombed.% their annual revenue for the production of films. On the contrary, the owners of private television stations who for decades did not comply with the Act of Performance of 1.5% are rewarded with millions of euros per year for Greek serials. The state, that is, the citizens, will pay for the series of private television stations.
    Moreover, at a time when the development of film production needs a truly new ground-breaking, flexible, democratic and immediately effective modern legislative development framework that ensures transparency, fair and inclusive allocation of resources for a diverse expression, the Draft Law with its absolute centralization by an appointed board of directors is a blow to freedom of expression.
    Our general view regarding television series is that the total eligible costs should be defined regardless of the number of episodes. The aim of this funding should be to promote and create quality television productions that include some quality standards. A similar arrangement is proposed to be set for short documentaries.
    Most of the Draft Law (PART C), consisting of 20 articles, describes a programme of support for audiovisual works to be filmed in Greece: Cash Rebate Greece. All articles are devoted to the detailed description of the terms and conditions of funding of foreign film television and film productions that will be filmed in Greece. It provides for 3 ways of financing in order to attract foreign investment to the country. The three distinct aid schemes will be: 1) Cash Rebate Greece – Film and TV 2) Cash Rebate Greece Animate 3) Cash Rebate Greece – Original computer accounting games. The grant amounts foreseen in each case are for films, television programmes and animates up to EUR 8 million per project and for projects of national development importance up to EUR 10 million. For the original accounting games the grant amount reaches 1 million euros for each.
    As it becomes obvious, this Law is mainly made to enhance the attraction of foreign producers to the country, for which tens of millions of euros will be available. At the same time, the new organization with a few tens of millions of euros will support the productions of private television channels. Greek film art will continue to be underfunded and degraded once again by the state, as has been the case in recent decades.
    Therefore, the issue of cash rebate should be better understood and raised. There is a confusion in the draft law regarding the term, which he calls a subsidy at the time when it acts as a tax refund. Moreover, with regard to the cash rebate, there is no reference to an obligation for international producers receiving cash rebates to cooperate with Greek film professionals. Incentives should be provided through a register of professional technicians and artists and through the conclusion of a Collective Labour Agreement to protect technical staff.
    A major problem that exists in the draft law concerns the many ambiguities that (it seems) will be clarified by Ministerial Decisions or Joint Ministerial Decisions. The draft law provides several empowerments. This will allow many basic regulations of the law to be changed directly through the Joint Ministerial Decisions. It should be replaced by a broad consultation with the institutional representatives of workers, professionals and creators of the sector before the Joint Ministerial Decisions are issued.
    A further shortcoming of the draft law concerns the Regional Programmes. These are reported within the plan without any further explanation. What will these programs be? How will they work? Under what responsibility will they operate?
    Important footnote: According to the draft law, the auditee also checks the auditor because both the management and the control mechanism are defined and terminated by decision of the General Assembly. There must be a social safety net, such as the inclusion in the screening process of representatives of the film community.

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    📍 Clarification of an advance payment procedure only for domestic productions with substantial need 2 B.C.

    🟢 Ensures a fair allocation of resources for productions with a real needFact check

    🟢 Prevents abusive advances on inefficient moviesFact check

    📍 Creation of new funding mechanisms for film art, scripts and new oscillators 2 B.C.

    🟢 The plan omits the creation of such mechanismsFact check

    🟢 Young creators need financial support to growFact check

    📍 Recognition of film as a work of art, not only profitable production 2 B.C.

    🟢 Ignores the cultural value of the film, which is a work of artFact check

    🟢 Current treatment reduces the importance of cinemaFact check

    📍 Separation of Film Art Funding from TV Series 2 B.C.

    🟢 Merging with TV content undermines autonomous cinematic creationFact check

    🟢 Creates competition that reduces the quality of artFact check

    📍 Restoration of liability 1.5%) revenue from television channels for film financing 2 B.C.

    🟢 The Abolition of 1.5%) Reduces funding for domestic filmmakingFact check

    🟢 Private serials receive more beneficial financial support at the expense of the stateFact check

    📍 Determination of eligible costs for TV series regardless of episodes, same rule for short documentaries 2 B.C.

    🟢 Current funding based on number of episodes reduces qualityFact check

    🟢 New rule will encourage high-level productionFact check

    📍 Clarification cash rebate as a grant, not a tax, with an obligation to cooperate with Greek professionals through a register 2 B.C.

    🟢 There is confusion between cash rebate as a grant or tax refundFact check

    🟢 Requires collaboration with Greek professionals to protect local workforceFact check

    📍 Replacement of Joint Ministerial Decisions with broad consultation of employees and creators prior to publication 2 B.C.

    🟢 Joint Ministerial Decisions allow for changes without adequate consultationFact check

    🟢 Consultation with representatives ensures democracy and prevents wrong regulationsFact check

    📍 Provision of a detailed description of the Regional Programmes, operation and responsibility 2 B.C.

    🟢 Lack of information on regional programmes creates uncertaintyFact check

    🟢 Detailed description will enhance transparency and correct implementationFact check

    📍 Inclusion of film community representatives in the audit process of the organization 2 B.C.

    🟢 Without involvement of the film industry the audit may be non-independentFact check

    🟢 The presence of representatives will ensure accountability and social controlFact check

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29. 

    7869

    May 15, 2026

    I fully agree with the EYE remarks but note the following:

    In Article 26 2.a) The amount of eligible costs of sixty thousand (60,000) euros with creative documentation content (documentary) is large for the data of Greek producers and must be reduced to the amount of forty thousand (40,000) euros. It is important to lower the amount in order to allow documentary films to be made due to difficult economic conditions.
    For b) and short productions regardless of content, but especially for documentaries, the amount of sixty thousand (60,000) euros must be reduced to twenty thousand (20,000) euros.
    We ask for the documentary and short film fiction and documentaries to be supported as a genre in all its forms.

    Article 23
    Amend paragraph 3 to read as follows:
    ‘3. ‘Difficult Audiovisual Work’ means a stand-alone audiovisual work which fulfils at least one of the following conditions:
    (ha) To be in the Greek language. The use of other languages to a limited or limited extent does not negate the fulfilment of this condition;
    (hb) It is the first or second work of a director or producer;
    (hc) is a project with a budget of up to EUR 1 million (1 000 000);
    (hd) is a short film or documentary work;
    (he) has limited possibilities for commercial exploitation’.

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    📍 Reduction of eligible costs to 40,000 euros for documentaries 1 business

    🟢 The amount is too high for Greek productions and difficult economic conditionsFact check

    📍 Reduction of the amount of eligible costs to 20.000 euros for b and short productions 1 business

    🟢 The amount of 60,000 euros is excessive for short productions, especially documentariesFact check

    📍 To be considered documentaries and short fiction as a genre in all forms 0 business

    📍 Amendment of Article 23(3) with a new definition of ‘Difficult Audiovisual Work’ 0 business

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30. 

    7871

    May 15, 2026

    COMMENTS AND PROPOSALS OF THE ASSOCIATION OF CREATORS OF DIGITAL GAMES OF GREECE (GDA GREECE) IN THE DRAFT LAW OF THE MINISTRY OF CULTURE WITH TITLE
    ‘Creative Greece: strengthening the cinematographic, audiovisual and creative sectors, establishing a body for books and other provisions for contemporary culture’

    > In principle
    This bill, even in its current form, we consider to be a positive development in the right direction for the industry of video game development. This means of artistic expression is fundamentally different from the art forms that came before it, due to its interactive nature and beyond. As an Association, we congratulate the effort for distinctness of the independent arts, and we will focus our comments on CRGR-VGD which concerns us directly.
    VGD, which is the name of our holistic proposal for the start-up and then the potential sustainable development of our industry, is a series of financial tools, which as a body we have proposed. This proposal contains, among other things, a section (name VGD2.0 which we have already communicated to EKOME), which is quite close to the format of the CRGR-VGD, since it focuses on supporting new efforts of existing businesses, an important part of the “puzzle”, which needs immediate attention.
    We believe that with specific, pivotal changes, not to the overall structure of the CRGR-VGD but to its individual points, it can deliver what we wanted to achieve when we proposed VGD2.0 – and that is where we will focus on the present.

    > Article 23
    We would point out on paragraph 2(c) that, although in an academic and philosophical context games are in all respects a recognised form of contemporary art, and should therefore be cultural products in themselves, we do not have any such provision in law in Greece to date. In view of this, and in order to avoid excluding a significant part of our industry, we propose to reformulate it as follows: “.., digital play, cultural, educational, and/or recreational”.
    Also in paragraph 5(c), the description of the game design document (GDD) can be better formulated, since the “mathematical statistical analysis of the mechanisms” is something that does not correspond to a widely accepted description of a GDD. In addition, the initial production phase rarely starts with the writing of the GDD, but with the creation of small software prototypes (first playable), and the mapping of the central elements of the game under development into a concept document, the form of which depends quite a lot on the type of game (genre), but indicatively contains concept art, summary narrative overview, gameplay elements, distribution platforms, audience, etc. Thus, within (indicatively) 3-12 pages, the central idea is communicated and how its implementation will be approached.

    > Article 24
    Paragraph 2(ab) on difficult audiovisual works and 80%) , we agree with the statements of the Greek Film Directors-Producers Association (ESPEK) and the Association of Independent Producers of Audiovisual Works (SAPOE) on the same Article (ii), and we consider it reasonable to raise the threshold to 100%) .

    > Article 25
    On paragraph 2, while the base is close to the desired support mechanism, the numbers are not in line with the reality of the production process of a digital game.
    Most digital games that manage to secure external financing for publishing or investment achieve this when they have produced about the equivalent of 30.%) the production process (vertical slice).
    We believe that the aim of such a support mechanism (which does not cover the full amount of production) should be primarily to attract such external investments, and therefore focus on helping production reach the vertical slice.
    By extension, our proposal for paragraph 2 can be summarised as follows:
    In point (a), correct the initial production phase to indicate “prototype” rather than vertical slice, which is closer to what can be produced with 10%) of the project.
    Point (b) specifies that the production sub-phases, e.g. “demo”, “vertical slice” and “release”, may each have their own part of the grant: indicatively, 10%) each one.
    This will allow sufficient support for the creators to reach the focal point of the vertical slice faster (approximately 30%) production), in which external investments are highly likely, as some Greek studios have already proved.
    Alternatively, separating 10-30 could be done 30-10 without changing the text and have a similar effect, but we consider that the above changes offer a more accurate and comprehensible description. .
    Paragraph 3 on the upper limit of 80%) on eligible costs, we agree with the positioning of the Association of Audiovisual Producers (PACT) on the same article, and the positioning of the Association of Greek Cinema Directors-Producers (ESPEK) on the same article, point (3), and we also consider it reasonable to increase the limit to 100%) .

    >Article 26
    On paragraph 4, we consider that while the range of EUR 60,000-1,000,000 covers a large group of producers, there is another non-negligible group of smaller projects, in the range of EUR 45,000-60,000, which would make sense to examine. We therefore propose to lower the threshold for inclusion to EUR 45,000.
    On paragraph 7, point (j), our Association welcomes and considers crucial the decision not to include games of chance in the context of this funding.

    >Article 27
    On paragraph 2, we welcome the inclusion of all types of companies in the grant, as well as the margin for them not to be established during their application. These two points (as paragraph 3 also verifies), cover sole proprietorships that are an important part of our industry, and attract foreign companies respectively, which we find very positive.
    In point (b) of paragraph 2, however, it would be appropriate to extend the restriction as follows:
    Raise the threshold to years, and make it “within the last 3 years”
    Add alternative “… or have as their main income, receipts from games released in the last 10 years”
    These changes more realistically cover the nature of our industry.

    > Article 28
    On paragraph 2, we acknowledge the effort to integrate our proposals, however we would like to draw attention to the . numbers themselves.
    We propose the following changes:
    In point (b), the percentage rises to 20-30%) , since many types of digital games rely to a very large extent on quality writing, acting and translation into languages other than Greek.
    At point (e), the percentage rises to 10-20%) , and insert in addition the clause “and not to exceed EUR 20,000”. This double limitation reflects the way in which this cost scales up in terms of the overall size of production.
    Although point (f) was part of our initial discussions, we believe that it can be either limited or removed, as it is significantly less linked to production than other costs.

    > Article 29
    On paragraph 3, we consider that some changes are needed to bring the application process closer to the nature of the production of a digital game.
    We propose the following changes:
    In point (b) on cultural eligibility criteria, please refer to our comments on Article 23(2)(c).
    In point (b) on script summary, replace with a “concept document”, which is for games what the script summary is for films. Indicatively, it contains concept art, narrative overview, gameplay elements, distribution platforms, target audience, etc.
    In point (b) on the workers to be employed, we propose a quantified rather than a nominal reference to them, as well as a moderate commitment on the part of the applicants in this regard.
    We also propose the following addition, provided that the changes we propose for financing itself are included in Article 25:
    The delivery and evaluation of a first playable/tech “demo” file showing the main mechanics of the game and the USPs (unique selling points) that define it.
    We believe that this will prevent abusive practices towards the grant programme, without constituting a substantial obstacle to applicants who are able to carry out the project
    It should be clarified that we propose this addition, only under the above condition, since we believe that without the changes to Article 25, there is, on the one hand, a lesser need for the addition of this deliverable, and, on the other hand, it may act negatively.

    > Article 30
    On paragraph 1, we welcome the capping of the evaluation process at draft level, as we believe it will have a catalytic role in the longevity of the grant programme.

    > Article 34
    On paragraph 1, we consider it necessary - so that we can have a substantive discussion on further details - to clarify the definitions of phases a and b, as these are not sufficiently defined in paragraph 2 of Article 25.

    > Article 35
    With regard to paragraph 2, the wording seems to contradict the reference to an advance payment in Article 25(2)(a). We also consider it important to allow individual instalments to be paid in the sub-phases of the project. As mentioned in the comments on Article 25(2)(b), we propose the following wording: “… shall be paid to the beneficiary in instalments defined by the phases and sub-phases hereof, not exceeding one million … in total”

    > Article 38
    The wording of paragraph 4 leaves room for misinterpretation. We would like it to be clarified, in particular on the basis of which criteria the competent operator can recommend such a withdrawal, and what the recipient of the aid scheme can appeal against.

    > Article 39
    On paragraph 2, we welcome the transparency of the selection of a committee, and of the posting in DIAVGEIA.
    On paragraph 3, we welcome the reference to experts, but we propose the following changes to ensure the grant programme:
    Evaluation and selection of experts through independent authorities, with full transparency regarding the selection process, notably merit-based selection based on CV (studies and professional experience in related subjects). As an example, we bring the GSRT register and other corresponding registers that operate for the evaluation of funded projects.
    Ensure at least two (2) experts in the Committees (a) and (b), as the assistance of two specialists would be very positive and there would be a plurality of informed opinions at the discretion of the project.

    > Epilogue
    Finally, as the Association of Digital Game Makers of Greece (GDA Greece) we hope to see CRGR-VGD take its full form, ideally including the changes we propose. We believe that in this way it will be transformed into an important tool for supporting existing businesses, as well as an essential step for a more holistic support framework for our industry in the near future. We remain at the disposal of the state for further dialogues, both on the details of the implementation of the present, as well as on our complete and comprehensive proposal which addresses the difficulties of the sector at its root (first efforts, education, independent small productions), its trunk (medium and large productions from existing groups) and finally its fruits (missions to foreign conferences and organization of a national conference).

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    📍 Change of wording in Article 23(2)(c) to include "digital play, cultural, educational and/or recreational" 1 business

    🟢 Digital games are modern art and should be considered a cultural product to avoid exclusionFact check

    📍 Improvement of the wording of the game design document in Article 23(5)(c) 1 business

    🟢 The current description "mathematical statistical analysis of mechanisms" is not acceptable; Production starts with prototype, not GDDFact check

    📍 Increased participation threshold for difficult audiovisual works from 80%) in 100%) in Article 24(2)(ab) 1 business

    🟢 Other sectors (ESPEK, SAPOE) consider it reasonable to increase the thresholdFact check

    📍 Replacement of the term ‘vertical slice’ with ‘prototype’ in Article 25(2)(a) 1 business

    🟢 Prototype is more realistic; corresponds to 10%) of the projectFact check

    📍 Management of sub-‑ production phases (demo, vertical slice, release) so that each receives 10%) of the grant referred to in Article 25(2)(b) 1 business

    🟢 Ensures sufficient support to achieve the vertical slice (≈30%) production)Fact check

    📍 Reduction of the minimum membership threshold from €60,000 to €45,000 in Article 26(4) 1 business

    🟢 There is a significant group of smaller projects that need this supportFact check

    📍 Extension of the time limit for the grant to "within the last 3 years" and addition of a criterion for income from games of the last 10 years in Article 27(2)(b) 1 business

    🟢 Makes the system more realistic for the industryFact check

    📍 Increase of grant rate in point (b) of Article 28 to 20‑30%) 1 business

    🟢 Many games require significant quality in writing, acting, translationFact check

    📍 Increase of grant rate in point (e) of Article 28 to 10‑20%) up to a maximum of €20,000 1 business

    🟢 Double Limitation Reflects Production ScaleFact check

    📍 Removal or limitation of point (f) of Article 28, as it is less relevant to production 1 business

    🟢 This element is significantly less linked to productionFact check

    📍 Replacement of the "scenario summary" with a "concept document" in Article 29(2)(b) 1 business

    🟢 Concept document includes elements more suitable for gamesFact check

    📍 Quantification of workers instead of a nominal reference in Article 29(2)(b) 1 business

    🟢 Provides a clear picture of staff requirementsFact check

    📍 Addition of an obligation to deliver a first playable/tech demo in Article 29, subject to changes in Article 25 1 business

    🟢 Will prevent abusive practices and ensure project feasibilityFact check

    📍 Clarification of the definitions of phases a and b in Article 34(1) 1 business

    🟢 Necessary for a substantive discussion of detailsFact check

    📍 Possibility of paying individual instalments in the sub-‑phases of the project in article 35 par.2 1 business

    🟢 Important for funding flexibility, capped at EUR 1 millionFact check

    📍 Clarification of criteria for withdrawal of aid and right of appeal in Article 38(4) 1 business

    🟢 Restores the ambiguity of the wordingFact check

    📍 Selection of experts through independent authorities in a transparent manner and at least two experts per committee in Rule 39(3) 1 business

    🟢 Will enhance transparency and merit-based choice, improving evaluationFact check

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31. 

    7874

    May 15, 2026

    The positions of the ASSOCIATION OF AUDIOVISUAL PRODUCERS (PACT) and Mr. Eleftherios Rantos agree with the SAPOE, move in the right direction and SAPOE will support any initiative and positioning that contributes to strengthening the audiovisual industry, simplifying procedures, reducing bureaucracy and generally adapting legislation to the needs and specificities of the sector.

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32. 

    7879

    May 15, 2026

    We note that we consider it unacceptable that there is no reference to an obligation for international producers who receive a cash rebate with Greek film professionals to cooperate at least 40 times.%) to ensure work for Greek technicians and to avoid the influx of foreign technicians into our country.
    We also consider it unacceptable that director's fees, two protagonists and animator's fees with documents issued in a foreign country should be considered eligible costs in any case.
    When submitting a request for an investment project, the potential beneficiary should be immediately informed of the funds available to the organisation in the current year in order to avoid delays in repayments due to a lack of available resources.

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    📍 Obligation of cooperation of international producers with Greek technicians at least 40%) 1 business

    🟢 secures work for Greek technicians and limits inflow of foreignersFact check

    📍 Exclusion of director's fees, two protagonists and animator billed abroad from eligible costs 1 business

    🟢 Fees should not be considered eligible regardless of countryFact check

    📍 Immediately informing the beneficiary of available funds when submitting an investment plan 1 business

    🟢 Delays in repayments are avoided due to lack of resourcesFact check

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