The company ena Development Consultants, based in Xanthi and active throughout Greece, recognizes that sustainable development and the productive transformation of the Greek economy require not only strong financial tools but also an efficient, transparent, and reliable implementation framework.
With over 20 years of experience and extensive expertise in submitting and implementing investment plans under the Development Law, the company has actively shaped the development path of hundreds of small and large businesses.
This dynamic is further reinforced by the fact that three certified employees of the company have been participating since 2011 in the Registry of Certified Evaluators and Auditors of the Development Law (EMPA & EMPE), providing the company with substantive expertise and in-depth understanding of the institutional framework.
The total impact exceeds €200 million in approved investment projects—€50 million of which falls under Law 4887/2022, all of which have received positive evaluations. This establishes ena Development Consultants as a strategic partner for companies investing with vision and consistency.
Guided by strategic experience and a deep understanding of development policy, and aiming to continuously improve procedures that enhance Greek entrepreneurship, ena Development Consultants submits a set of proposals during the public consultation of the draft law from the Ministry of Development titled:
"Sustainable Development, Productive Transformation of the Greek Economy – Amendment of Provisions of Development Law 4887/2022 – Strong Growth Greece and Other Provisions"
The proposals aim to create a more functional, fair, and efficient mechanism that serves both investors and the competent evaluation and audit bodies, strengthening the investment climate and development prospects of the country.
1. Investment Grants in Eastern Macedonia and Thrace
According to the latest Regional Aid Map, the maximum grant rate provided to large enterprises is 60% in Crete, 50% in the South Aegean, and 50% in Thrace. This represents a clear injustice and a flawed distribution of incentives, which hinders balanced development across the entire territory of the country. It is inconceivable that the poorest region of the country, and one of the most crucial for national sovereignty, should have lower or equal incentives compared to the wealthier regions when it comes to implementing investment plans. A region with weak tourism development cannot be expected to offer the same incentives as, for example, Rhodes, or even lower than Chania, in the tourism sector. Similarly, it is unacceptable that Thrace, which is in great need of productive investments—such as processing units in the agri-food sector—offers lower incentives than Crete for the establishment of such facilities.
Ena Proposal:The aid rate for the Region of Eastern Macedonia and Thrace should be equalized to at least the highest rate on the current Regional Aid Map.
2. Investment Grants for Medium and Large Enterprises in Eastern Macedonia and Thrace
According to the draft law, “the grant incentive is also provided under the current schemes, at a rate of sixty percent (60%) for the Regional Unit of Evros and thirty percent (30%) for the Regional Units of Rodopi and Xanthi, based on the overall aid rate provided by the relevant provisions of this law. The remaining percentages are covered by tax exemptions, amounting to forty percent (40%) and seventy percent (70%) respectively.”
It is absolutely essential to implement investment projects by medium and large enterprises in Eastern Macedonia and Thrace. Reversing the region’s decline and encouraging the return of population from both major urban centers and abroad should be a priority for any government, regardless of political orientation. To achieve tangible results, only productive investments by medium and large enterprises can make a real difference by creating significant and well-paid jobs. Furthermore, the proposed differentiation of incentives between Evros, Rodopi, and Xanthi is entirely flawed and contradicts the core philosophy behind the creation of the Region of Eastern Macedonia and Thrace under Greece’s administrative division through the "Kallikratis" Program. The Region of Eastern Macedonia and Thrace is a geographically and demographically unified entity, and all of its areas should be treated equally.
Ena Proposal:A grant rate for investment projects of Medium Enterprises should be established at 100% of the rate provided in the other provisions of Law 4887/2022. In other words, a grant rate of 60% should apply to all investment plans by Medium Enterprises throughout the Region of Eastern Macedonia and Thrace. Likewise, a grant rate for investment projects of Large Enterprises should be set at 50% of the corresponding rate under Law 4887/2022—meaning a 25% grant rate for all such projects in the region. The remaining aid rate may be covered through tax exemptions.
3. Evaluation Timeframes for Investment Projects
According to the draft law, “the evaluation of project applications begins from the closing date of the submission period under the relevant scheme and must be completed within a period of one hundred (100) days. Under the current law, the deadline was 45 days. As you know, the average evaluation time reached 18–24 months. Therefore, simply stating deadlines that are not met is meaningless. There must be a deadline and corrective measures that come into force if it is not met. These measures need not be punitive. For example, the evaluation could be assigned to external consultants if the deadline is exceeded. However, it cannot continue that an investor receives the evaluation result two years after the application and is then pressured to implement multi-million-euro projects within two years amid subsequent changes. Furthermore, the possibility of assigning project evaluation to financial institutions must be removed. Banks do not have the expertise to assess proposals under the Development Law.”
Ena Proposal:Clear corrective actions should be defined for cases where the evaluation deadline is exceeded. The option to assign the evaluation of investment projects to financial institutions should be removed.
4. Submission Authorities for Investment Applications
It is not functional for all investment project applications to be submitted to the General Directorate of Development Laws & Foreign Direct Investment in Athens.
Ena Proposal:Investment projects with a budget of up to €2 million should be submitted to the local regional authorities. Projects exceeding €2 million that will be implemented in the regions of Eastern Macedonia and Thrace, Central Macedonia, and Western Macedonia should be submitted to the Ministry of Interior (Macedonia–Thrace sector). All other applications can continue to be submitted to the General Directorate of Development Laws & Foreign Direct Investment in Athens.
5. Scoring Criteria – Creation of New Jobs
The scoring system for investment projects as outlined in Law 4887/2022 is unrealistic in terms of new job creation. Under the current framework, a project only begins receiving points if it forecasts at least one new job for every €250,000 of budget. This means a €1 million project from a small business must plan for at least 4 new jobs. Considering the current necessity for automation to boost productivity, this criterion is illogical.
Ena Proposal:Lower the threshold for receiving scoring points to one new job per €150,000 of eligible investment cost.
6. Scoring Criteria – Participation in Eligible Costs
There is no technical or economic justification for a business that funds its equity contribution entirely from its own capital to receive a lower score than one that relies on bank loans. This provision, introduced as an “innovation” in Law 4887/2022, is illogical and undermines the viability of the investment project.
Ena Proposal:Revise the scoring criterion so that maximum points are awarded to projects where equity participation is covered by the company’s or shareholders’ own funds. Lower scores should apply when the equity portion is entirely covered by loans.
7. Compensation for Evaluators and Auditors under the Development Law
Based on experience from participation in both evaluator (EMPE) and auditor (EMPA) registries, it is clear that the extremely low compensation is a major disincentive for timely and thorough project evaluations and audits. This issue worsened with the involvement of Certified Public Accountants (CPAs), who are paid based on private negotiations, creating a two-tier system. The €300 gross payment for evaluating or auditing multi-million-euro investment projects is clearly unproductive—especially considering that investors pay significantly more in application fees. Delays in paying compensations further exacerbate the problem. We believe you're aware that forming Audit Committees is now difficult, as many auditors still await payment for projects completed in 2023 and are unwilling to accept new assignments.
Ena Proposal:Evaluator and auditor compensation under the EMPE registry should be scaled based on the project’s budget. Compensation amounts must be standardized whether for EMPE/EMPA members or CPAs. Evaluation decisions and audit approvals should only be issued once funding for the relevant compensations has been secured.
8. Major and Minor Project Modifications
Under current legislation, practically any deviation from the originally approved project requires modification of the physical and financial plan, a process that significantly delays implementation. Even simple changes—like replacing a single machine—can take over a year for approval, consuming a third of the project’s execution window. Businesses have lost confidence in the system, perceiving that while they are required to rigorously meet obligations, the state consistently fails to meet its own. It's a double standard.
Ena Proposal:Clearly distinguish between major and minor modifications. Only major modifications should require approval, including:
- Changes in financing structure
- Relocation of the investment site
- Modifications of over 25% in any cost category of the physical plan
- Allow simultaneous submission of modification and completion requests, so both decisions can be issued together.
9. Notification of Information Changes and Penalties
According to Article 25 of the draft law, companies must notify authorities of any changes (name, legal form, headquarters, contact information, ownership structure) within two months—or face a fine of up to 5% of the grant. This two-month period is extremely short. Furthermore, in most cases, such updates have no impact on evaluation or project implementation. It is unjust for a company to face thousands in fines for, say, failing to report a contact detail change within two months. Meanwhile, the same state imposes long delays in reviewing evaluations, modification requests, and audits—sometimes over a year—with no penalties.
Ena Proposal:If the change does not affect evaluation criteria or project eligibility under the Development Law, no penalty should be imposed. For changes that do affect those terms, extend the reporting deadline from 2 months to 6 months.
10. Obligation to Request Extension After 50% or 65% Project Completion
According to the draft law, businesses must submit a request for an extension after certifying 50% or 65% of their project. But if that level of implementation has already been certified, what purpose does another formal request serve? It adds unnecessary bureaucracy and penalizes businesses for a formality, despite having met core implementation targets.
Ena Proposal:According to the draft law, businesses must submit a request for an extension after certifying 50% or 65% of their project. But if that level of implementation has already been certified, what purpose does another formal request serve? It adds unnecessary bureaucracy and penalizes businesses for a formality, despite having met core implementation targets.
11. Duration of Long-Term Obligations
Law 4887/2022 set a universal 6-year duration for long-term obligations for all business sizes (small, medium, and large), replacing the previous 3–5–7 year tiered system. This shift was never justified, even though EU frameworks and other funding tools (e.g., NSRF, Just Transition Fund) maintain a 3–5 year obligation period.
Ena Proposal:Reintroduce the tiered structure: 3 years for small enterprises 5 years for medium 7 years for large Measured from the date of project completion.
12. Review of CPA Audit Reports
Significant delays are being observed in issuing certification decisions (50%, 65%, or full project completion), as government services re-check all documentation even after CPA-led audits. This defeats the original purpose of involving CPAs—to speed up the process. Not only are timelines extended, but investors also face high costs for redundant audits.
Ena Proposal:Implement random sampling audits on 15% of CPA reports. In cases of serious errors, impose appropriate penalties. For the remaining 85%, certification decisions should be issued based directly on the CPA report.
13. Project Completion Timeline under Law 4399/2016 (Before May 21, 2021)
In 2024, only a 6-month extension was granted to investment projects approved before May 21, 2021, under Law 4399/2016. Later projects (approved after this date) received a 2-year extension. This inconsistent treatment is unfair—especially when projects under even older laws (e.g., Law 3908/2011) have been granted further extensions, with some now completing in 2024 even though they were approved as early as 2013–2014.
Ena Proposal:All projects under Law 4399/2016 should be granted a unified extension to achieve 50% or 65% implementation by December 31, 2026.
