“Initial relief” is one of the immediate measures that can be taken to provide rapid financial assistance to those affected by severe natural disasters. However, emergency aid is granted under specific terms and conditions to ensure that support reaches those who truly need it. The measure is activated in cases where extensive and severe property damage has been caused by an extreme natural phenomenon and may take the following forms:
a) Initial relief in the form of a grant to businesses and/or agricultural operations whose assets (excluding buildings) have been damaged due to a natural disaster. It is a lump-sum payment against the final grant to which a business is entitled; its amount depends on the extent of the damage suffered by the business and is offset against the final grant.
b) Initial assistance in lieu of housing aid to citizens and businesses for buildings damaged by a natural disaster, depending on the severity of the damage. This is a lump-sum payment in lieu of the housing assistance to which an applicant is entitled; the amount depends on the extent of the damage to the building and is offset against the housing assistance.
c) Compensation for household goods for affected households whose homes have been damaged due to a natural disaster.
Implementation of the initial grant-based assistance for the 2021 fires
This measure was first activated in response to the fires that occurred from May 1, 2021, to September 2, 2021, in various regions of the country, in accordance with the Act of August 13, 2021, as ratified by Articles 2 and 3 of Law 4824/2021. Specifically, regarding the provision of initial relief in the form of a grant to businesses and agricultural and livestock farms, Joint Ministerial Decision (JMD) No. ΓΔΟΥ 841/August 18, 2021 (B’ 3853), the payment of aid was provided for as follows:
a) 2,000, 4,000, or 8,000 euros to businesses and organizations, depending on the extent of the damage they suffered, and
b) 1,000, 2,000, or 4,000 euros to farms, depending on the area of their damaged crops.
Procedure for Submitting Applications for Initial Relief Grants
The applicant submitted an application for initial relief digitally at arogi.gov.gr, which also served as a sworn statement. In this application, the applicant declared, among other things:
- that they had suffered property damage caused by the 2021 wildfires, as well as the severity of the damage,
- that they met the requirements of the August 13, 2021, Act of Legislative Content (A’ 143), as well as Law 4797/2021 (A’ 66) and the decision dated June 23, 2021, ref. no. 74617EX2021/23.06.2021 (B’ 2670) regarding the grant for damage relief.
Upon submission of the application, the applicant was provided with detailed information regarding the terms and conditions for the granting of the initial assistance, the obligations arising from receiving it, matters regarding offsets against the final amount to which they are entitled as a final grant, as well as the potential obligation to repay amounts paid in error.
Reimbursement of Unduly Paid Amounts
It is reiterated that the initial assistance is granted as a one-time payment against the final grant to which the affected party is entitled. Therefore, the aid recipient must subsequently submit an application to the competent Regional Authority for the recording and assessment of the damage by the state aid committees, as well as a complete application package for the grant under Law 4797/2021 (A’ 66).
The initial deadline for submitting the application and documentation was January 31, 2022. However, for the purpose of reimbursing the amounts of the first round of aid, a four-year deadline was applied from the date of each fire, thereby exhausting the four-year period permitted by Regulations (EU) 651/2014, 2022/2472, and 2022/2473 for the granting of aid.
Cases of Reimbursement of Unduly Paid Amounts
- If an application or dossier is not submitted within four years of the fire, or if the recipient of initial assistance is not deemed eligible for a grant by the competent regional state aid committees, then the total amount of aid must be repaid to the Greek State as an overpayment, with interest calculated from the date it was made available to the beneficiary and in accordance with the European Commission’s recovery interest rate.
- The same applies in cases of false statements or failure to comply with the conditions for granting the aid.
- If the amount of the final grant to which the beneficiary is entitled—which is based on the damage assessment by the competent state aid committees—is less than the amount the beneficiary received as initial aid, then the excess amount is repaid to the Greek State as an overpayment, with interest.
Procedure for the Reimbursement of Unduly Paid Amounts
In this context and following cooperation among all relevant agencies, the procedure for the refund of amounts unduly paid, in accordance with Joint Ministerial Decision No. 841/August 18, 2021 (B’ 3853), is as follows:
- In cases where no application or supporting documentation was submitted to the Regional Authority, as well as in cases where the damage was assessed as zero, the General Secretariat for Natural Disaster Recovery and State Aid of the Ministry of Climate Crisis and Civil Protection is required to send the Independent Authority for Public Revenue (AADE) lists containing data submitted by the Regions. The AADE cross-checks the data against the initial relief payments and calculates the amounts unduly paid, along with the corresponding interest. It then sends a list of those required to make a refund to the General Directorate of Financial Services (GDFS) of the Ministry of National Economy and Finance.
- In cases where applications are submitted with incomplete supporting documents, or where applications are submitted with complete supporting documents but the grant amount is less than the initial aid granted, the General Secretariat for Natural Disaster Recovery and State Aid forwards the files to the General Directorate of Public Debt (G.D.P.D.) of the Ministry of National Economy and Finance for review and settlement. The General Directorate of Public Revenue determines the amount to be repaid and sends the Independent Authority for Public Revenue (IAPR) a list of those liable for repayment, so that the IAPR can cross-check the information against the initial relief payment and calculate the amounts and the corresponding interest.
- The General Directorate of Public Revenue (GDPR) then issues a refund decision, which is digitally notified to the liable parties via their AADE account. The AADE will then issue the relevant debt identification numbers and an individual notification via myAADE, while the taxpayer will also be notified by email.
It should be noted that, in the case of agricultural holdings, any amounts unduly paid have already been offset against the subsidy they received for crop damage through ELGA; consequently, the refund pertains to the remainingamount that could not be offset.
In total, following the offsetting by ELGA, approximately 814 businesses and 2,880 farmers are required to repay all or part of the initial aid they received. Specifically, 771 businesses and 2,339 farmers who did not submit an application within four years of the fire must repay the initial aid, while 43 businesses and 541 farmers who did submit an application but for whom the grant to which they are entitled is less than the amount of the initial aid they received, or who are deemed ineligible because they do not meet the necessary requirements, must repay part or all of the initial aid, respectively.
Option to settle amounts paid in error
It should be noted that, regarding the repayment of amounts paid in error and the corresponding interest, relevant legislation provides for the possibility of a debt settlement arrangement.
Specifically, recipients of the first round of financial aid who are required to repay the amount of that aid, plus interest, as an overpayment, may pay the amount in question either in a lump sum or arrange a repayment plan for their debt pursuant to Article 23 of Law 5116/2024 (A’ 140) and Circular No. A1091/08.07.2025 (B’ 3728) Joint Ministerial Decision, in up to forty-eight (48) monthly installments, in accordance with subparagraph A.2 of paragraph A of Article 1 of Law 4152/2013 (A’ 107), concerning the permanent settlement of debts.