By letter to the Deputy Prime Minister, Kostis Hatzidakis, the Pangretian Association of Farmers and Studyers of Agricultural Technologists says the amendment at issue will have the opposite of the expected results.
As he points out in the light of the fact that 97% of the declarations are made through the IACS and with this amendment you are putting the ICCs out of action (just before August and in a system that has not yet been tested) it is not possible to make a smooth and legal IACS declaration for 2026, resulting in problematic payments that will bring about fines for the country.
In particular, the letter states:
By Article 96 of the passed Law of the Ministry of Social Cohesion and Family entitled "Personal Assistant, Early Intervention and other active policies for disabled persons, housing policy arrangements and other provisions" Article 63A was added to Law 5264/2025 with the aim of regulating certain issues related to the transition of OPECEPE to AIA and the procedure for the submission of IACC declarations.
On the text of the Law we have many observations, which are discussed below. In our opinion, as we will set out below, the proposed provisions will have the opposite effect.
Remarks:
Point 1 of Article 63A reads "Registration Centers (CSOs), as well as natural persons engaged in the occupation of agronomist, geotechnical and accountant, as well as legal persons or legal entities active in the respective sectors may be modified and generally managed for remuneration of one-off aid applications (AEs)".
In ID 344/2000, which regulates the professional rights of Geotechnicalians, as amended and in force, in Article 9 – Compulsory employment, in point 1 refers to "1.Employment, with remuneration, agronomist with a relation to dependent labour or a contract of employment or consultant, is compulsory in the following cases: (...) m) In the programme to supplement declarations under the Integrated Management and Control System (AED)."
The EAEs are statements submitted within the IACC. Therefore, a natural person exercising the profession of accountant cannot modify and manage OAU, this is a gross violation of the professional rights of farmers.
Also in point 1, in the last sentence of paragraph, persons having direct or indirect economic, professional, family or other personal interest which may affect the non-discriminatory fulfilment of their obligations shall be indicated. "
All the existing IACC declaration bodies (student offices, cooperatives, etc.) have other economic activities (studies and support for the implementation of IACS interventions, licensing, agricultural advice, drafting of ICCs, marketing of agricultural supplies and agricultural products, etc.) which often operate cooperatively with the IACC or form part of wider services that they provide or the purpose statutes of rural cooperatives.
Practically the incompatible as described excludes a large part of the producers from cooperation at the IACC and will lead to the creation of unsustainable financial offices with the sole object of receiving IACC declarations. Most existing structures (KYDs) operate in the province and the reception of OSA declarations alongside other services are vital for maintaining the operation of these structures in the province and near the farmer, becoming a one-stop service for farmers.
Finally, the imposition of such an incompatibility only makes sense in the case of an auditor and consultant.
The reception of OAUs also includes advisory services, such as information to producers about their obligations, eligibility of parcels, results of cross-checks and submission of amendments, objections, available options in ecological schemes and obligations associated with them, associated schemes and related obligations, etc.
Also, the IACC statement is necessary for all the interventions of the PAA as well as for the insurance of cultivation and many administrative work (licensations, marketing of products in popular markets, etc.). In other words, the provision of advisory services during the submission process of the EEA is necessary, especially as the regulation of the CFP is becoming increasingly demanding.
The acceptance of IACC declarations is an advisory service, therefore it is not justified to impose such restrictions (uncompromising) on the exercise of this activity.
Point 2d of Article 4, which refers to due diligence, reads "to carry out a check of completeness and correctness of the data submitted on the basis of the supporting documents submitted, to refrain from finalising the action in question, where the system's data show obvious incompatibility and do not cooperate in any way liable to a false statement."
Checking the completeness of the supporting documents was and is an undeniable obligation. However, correctness control is difficult to do and risks a breach within the meaning of point 3 without being liable. As an example, it should be mentioned that the data of the parcels are listed in four databases, the Land Register, the E9 (which will be transferred at some point to the MID), the IACC and the Olive/ Vineyard Register.
Apart from E9 in the other databases there is also geospatial information. As a rule, the data from these 4 databases do not agree with each other. This means that practically few applications will raise the conditions for submission, especially as long as the IAD is not working yet. We also note that, with the constant amendments to the circular checks, other supporting documents should be requested during the submission of the EEE (e.g. E9, leases) and other supporting documents during the administrative audit (strong instruments of ownership) by DGELEP.
However, in addition to the objective difficulties of carrying out correctness checks on the supporting documents provided, as mentioned above, the acceptance of the IACC declarations is an advisory service and not auditative, so correctness checks are not consistent with the nature of the service.
In addition, point 3 provides for exhaustive, non-proportional, fines for infringements which are in fact obvious errors, such as "deficient capture and transfer to the IACS of data to be recorded", i.e. human daily obvious errors.
It shall be entered as an infringement "Incompletely keeping a documentation file". The documentation of the application is the responsibility of the applicant, i.e. the producer. It cannot be the responsibility of the registrant to control and observe all the evidence by replacing the control mechanisms. The role of the registrant is to control the completeness of the supporting documents alone.
The imposition of fines of 5,000 to 20,000 euros per case and exclusion for up to 2 years, for human and obvious errors is an outright non-proportional fine.
In point 3 again, below, it reads "The fines of c. b) are not imposed if the person tested proves that he acted without fault". We believe that the burden of proof is borne by the controller and not by the controller. Practices which we have seen applied and during the tax controls carried out in the autumn of 2025 by first imposing the fine with incomplete documentation and then bearing the burden of proof we consider to be in breach of the fundamental principles of the rule of law, proportionality and presumption of innocence. Especially when it comes to serious infringements such as those described in point 3b (submission of false applications, withholding data, use of false or fraudulent supporting documents, etc.).
Point 5 refers to "Since the entry into force of the decision of c. a) paragraph 5 of Article 78, the Quality of Services and Information Security Contracts (S.D. Hey. P.Y.A.P.) concluded between OPEKEPE and the Statement Centers, are automatically resolved."
The termination of contracts may seem reasonable to the Administration after the introduction of obligations to respect confidentiality and data security conditions and to assume specific responsibilities.
With the solution of the SDEYAP, however, we see an effort to discharge its responsibilities as the SDEYAP also provided obligations on the part of OPEKEPE (in addition to ADE/GDELEP), such as the obligation to inform and train the KSOs and to check their operating conditions.
Regular information through exclusive communication channels (specialized secretariat, specialized call centre) is necessary for the successful execution of the project. It is something that has been missing in the last year and has been extremely incomplete in previous years. The bad results of misinformed information are seen today. The OPEKEPE obligations referred to in the SPEPYAP should therefore be regulated.
Article 5 of the proposed provisions confers on the Administrative Authority a decision on specific implementation issues, such as the necessary supporting documents, the content of the documentation dossier, the authorisation procedure, the properties, conditions and obstacles of persons who will take over the reception of the EAE and so on. Taking into account the provisions set out in point 1 and 2 of Article 4, all such decisions, as well as all circulars relating to the submission of EAE and ecological schemes should have been issued before the start of submission of EAEEE to the OAED 2026.
Conclusions
A year from the moment the AADE took responsibility for OPEKEPE is soon completed. Just before August not only has the system not been opened but you are tabling an amendment that blows up the payment system.
Although until yesterday the CDCs (private and cooperative) had a contract with OPEKEPE and have been operating until now to serve on their part the needs of the activation of the rights of producers (establishments, staff, information) you are tabling an amendment by surprise, without any consultation, which practically does not allow the CDCs to operate.
So with this, we're documenting the alarm.
Given that 97% of the declarations are made through the IACS and with this amendment you are taking the ICCs out of action (just before August and in a system that has not yet been tested) it is not possible to make a smooth and legal IACS declaration for 2026 resulting in problematic payments that will bring fines for the country. So you take full responsibility with the implementation of this amendment for the 2026 IACS declaration.
The aim of the market opening was, according to a statement by the Deputy Prime Minister Kostis Hatzidakis, to reduce the cost of submitting OSA declarations. The above provisions, both for the provision of authorisation and for the introduction of responsibilities beyond liability to the producer that we had in any case, are going to have the opposite effect. The cost of submitting applications is expected to be at least doubled.
We have no responsibility as under the draft law
The CSRs of Crete are not legalized to activate for the vast majority of their clients (see observation 2). Therefore, AADE should contact the producers and indicate how the producers themselves will activate their rights in 2026, taking responsibility for the result.
For customers of the KYDs which are not identified by the law incompatible, AADE must also provide the full legal framework of the activation before concluding contracts with producers. Until the completion of your service of our working framework and the study of your decision, it is obviously not possible to start knowing only the fines that AADE can charge us.
The system has not yet been opened and no information on how it operates has obviously been made. For as many cases as the law will allow us to take over, you should also inform us responsibly of how the new IACC environment works.
For the Board
Koutentakis Nikolaos Peponakis Konstantinos
President
Pangretian Association of Farmers and Studyers of Agricultural Technicians
