Subject: Legality Audit of the Decision Establishing Ship Waste Fees by a Municipal Port Fund of a First-Degree Local Government Authority in the South Aegean Region

Following a complaint submitted to the Ministry of the Interior and forwarded to the National Transparency Authority (NTA) for examination of the allegations contained therein, the Authority conducted a systemic audit of a Municipal Port Fund of a First-Degree Local Government Authority in the South Aegean Region regarding the setting of waste fees imposed on ships at the island’s port.

During the audit, it was found that:

(a) no indirect waste fee had been imposed on permanently moored or transiting passenger ships and cargo ships, and

(b) the imposition of an indirect fee for the reception of oil residues and waste lubricating oils had been omitted for specific categories of transiting vessels (tourist ships, cruise ships, tankers), despite the provisions of current legislation.

Proposals – Recommendations:

The NTA recommended that:

  • the Board of Directors of the Local Government Legal Entity under Public Law (NPDD) to reconsider its decision regarding the calculation and approval of the ship waste fee system, as well as the Ship Waste Management Plan, in compliance with the law and Decision No. 1329/2025 of the Fifth Section of the Council of State.
  • the General Secretariat for Shipping and Ports of the Ministry of Maritime Affairs and Insular Policy take into account the findings of the audit report when approving the waste fee system and, within the scope of its responsibilities, to issue guidelines for the proper enforcement of ship waste fees, following the decision of the Council of State.

Following the recommendations issued by the NTA, the Board of Directors of the Municipal Port Fund of the First-Degree Local Government Authority issued a new decision establishing the ship waste fee system and revised the Ship Waste Reception and Management Plan.

The audit report was forwarded:

  • To the Secretary of the Decentralized Administration for the initiation of disciplinary proceedings against the President, Vice President, and regular members of the Board of Directors of the Legal Entity under Public Law (NPDD).
  • To the Athens Appeals Prosecutor for a criminal assessment of the report’s findings.

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