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Christianna Stylianidou 31 • 12 • 2025

Legislative drafting process 2025: Concerns regarding the public consultation procedure

Christianna Stylianidou
Legislative drafting process 2025: Concerns regarding the public consultation procedure
31 • 12 • 2025

The public consultation procedure followed for the laws adopted in 2025 raises concerns and doubts as to whether the requirements of Law 4622/2019 and the principles of good law‑making are being substantively observed, despite some positive developments.

A. Legal framework for public consultation

Articles 57 and following of Law 4622/2019 regulate the legislative drafting process and good law‑making.

According to Article 61:

  • Public consultation is achieved through the publication of the planned regulation “with appropriate means,” ensuring timely information and participation of all interested parties.
  • Consultation on bills lasts two weeks. During this period, a draft of the bill and a preliminary Regulatory Impact Assessment must be posted online, with the possibility of article‑by‑article comments.
  • The competent ministry’s Coordination Service must prepare a public consultation report, include it in the final Regulatory Impact Assessment, upload it on the consultation website and send it by email to all contributors.

The Legislative Drafting Methodology Handbook further emphasises that good law‑making requires an open and transparent process. Consultation is not a mere formality but a substantive stage intended to improve the bill, verify whether the public understands the proposed regulations and collect comments that may lead to improvements. Legislative committees must be ready to amend the bill based on consultation feedback.

However, several concerns persist:

1. Non‑publication of consultation reports

Despite Article 61(4):

  • The consultation report was uploaded on opengov.gr in only 2 out of 47 cases.
  • The obligation to send the report by email to participants does not appear to be followed in practice. Members of Vouliwatch and other civil society actors who submitted comments report that they did not receive the required email.

2. Articles bypassing public consultation

A significant number of provisions appear not to have gone through consultation:

  • In 42 out of 47 cases, the bill submitted to Parliament contained articles not included in the version posted for consultation.
  • The bills submitted to Parliament contained 3,602 articles, but only 3,348 of these appeared in the consultation drafts.

3. Missing preliminary Regulatory Impact Assessments

Some bills were posted for consultation without the required preliminary Regulatory Impact Assessment.

The Economic and Social Council also highlighted delays in posting these assessments, noting that such delays hinder timely and accurate evaluation of proposed regulations.

4. Limited evidence that consultation comments are substantively considered

Doubts remain as to whether comments submitted during consultation are meaningfully taken into account.

This concern is reinforced by:

  • Bills being submitted to Parliament very shortly after consultation ends
  • Instances where even technical comments did not appear to be evaluated

The dataset underlying these findings is available here.

Further issues regarding the 2025 legislative process can be found in the Joint Report on the State of the Rule of Law in Greece.

Where is the problem with the rule of law?

Good law‑making is a constitutional objective and is closely linked to the principle of the Rule of Law.

Chapter C of Part C of Law 4622/2019 (Articles 57 and following) sets out rules on legislative drafting and good law‑making, further elaborated in the Legislative Drafting Methodology Handbook. These include the rules and principles governing public consultation.

For yet another year, however, several issues cast doubt on the substantive compliance with Law 4622/2019 and the principles of good law‑making during the consultation stage.

Christianna Stylianidou
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