- Data Journalists reveal photographs from a confidential 2021 report by OPEKEPE inspectors.
- A free-for-all at 1,700 meters in Rhodope, Florina, Kastoria, and Heraklion, Crete
By Vaggelis Triantis
Today, Data Journalists published photographic evidence of the fraud scheme uncovered within OPEKEPE. The scheme involved subsidy applications submitted by alleged farmers for the cultivation of wild olive trees. The images, captured via Google Earth, show specific plots of land across various regions of Greece for which farmers submitted subsidy claims in 2020. These photos are included in a confidential briefing document compiled by OPEKEPE inspectors in 2021 following a spot check of applications submitted by so-called wild olive cultivators. The inspectors were startled by what they found: the alleged wild olive groves were located in areas such as Rhodope, Florina, Kastoria, and Heraklion in Crete—at altitudes exceeding 900 meters. The only problem? Wild olives don’t grow at such elevations. In some of the plots declared as olive groves, the inspectors observed “dense vegetation with tall trees,” such as beech, clearly identifying the land as forested. In Kastoria, one particular case revealed that the area claimed for wild olive cultivation was officially designated as reforestation land. In their report, the inspectors recommended nullifying or freezing the declared plots entirely. They also advised requiring the alleged farmers to submit additional documentation. But let’s start from the beginning.
The 2021 confidential report by OPEKEPE inspectors
In 2021, OPEKEPE’s Directorate of Technical Audits compiled a confidential report on “declared agricultural plots with wild olive varieties” tied to subsidy applications submitted in 2020. The inspectors conducted a sample audit of these applications, which requested EU subsidies for cultivating wild olive trees.
In the report, now published by Data Journalists, the inspectors began by explaining what the wild olive (oleaster) is. They described it as a “long-living, evergreen shrub of considerable size or a small tree” and one of the dominant species found in Mediterranean shrublands. The inspectors further explained that the wild olive, along with the carob tree (Ceratonia siliqua), is a characteristic species of sclerophyllous vegetation, which is typical of the maquis biome in the central Mediterranean climate zone and thrives at altitudes up to 600 meters.
The inspectors noted that the Central Mediterranean vegetation zone, where wild olives naturally thrive, “appears as a more or less continuous strip along the western, southeastern, and eastern coasts of Greece; on the Ionian and Aegean islands; in the southern and eastern coastal areas of Halkidiki; and in scattered patches along the coasts of Macedonia and Thrace.”
Regarding the agricultural parcels declared as wild olive groves by farmers included in the audit sample, the inspectors identified several irregularities. One key finding was that the declarations had been submitted primarily by online users and involved large areas, mostly within eligible reference parcels categorized as pastures, though typically with an eligibility coefficient of zero. The inspectors also observed that, in many cases, these same plots were not declared as wild olive groves in 2021, which raises further suspicion about the legitimacy of the 2020 subsidy claims.
Photographic proof of the fraud
Inspectors made another critical discovery: they identified “wild olive declarations made outside the Central Mediterranean vegetation zone”, that is, in regions where wild olives cannot grow. The Google Earth images included in the report are striking. They show plots of land in various parts of northern Greece located above 900 meters in elevation, where “the declared areas were covered with dense vegetation consisting of tall forest trees, such as oak and beech.”
A telling example is a declaration for wild olive cultivation in Kastoria, located at an elevation of 1,200 meters. The satellite image clearly shows a reforested area in that case, as noted in the report.
Another image shows a declared wild olive grove in Rhodope at an elevation of 1,300 meters. In another case, farmers claimed to be cultivating wild olives in Florina at an elevation of 1,200 meters, well above the elevation at which wild olives can survive.
The most extreme case was in Heraklion, Crete, where an application was submitted for wild olive cultivation in a high-altitude area “at the boundary of the forest or alpine zone,” over 1,700 meters above sea level, an altitude at which fir trees are far more common than wild olive trees.
“Nullify or freeze these parcels”
In the confidential report, OPEKEPE inspectors provided a detailed explanation of their findings. They acknowledged that wild olive trees might be present in some of the reported cases, either as naturally occurring plants scattered across the land, as part of the maquis sclerophyllous vegetation, or as remnants of abandoned olive groves (e.g., after natural disasters such as fire or frost).
However, they stressed that “the photointerpretation of isolated wild olive trees or shrubs, common in these cases, is extremely difficult and requires specialized equipment and expertise. Furthermore, it is not relevant to the eligibility criteria of the Land Parcel Identification System (LPIS).”
The inspectors also noted that “even in the event of an on-site inspection, in most cases it would merely confirm the presence of scattered trees amid forest or other non-agricultural vegetation.” For this reason, the inspectors emphasized that “in such cases, the beneficiary must prove that genuine agricultural activity is being carried out in accordance with national regulations, something that is clearly not fulfilled in the case of isolated and scattered trees.”
The inspectors also noted that, since most of the declared “wild olive” areas are classified as public forest land, beneficiaries must present a certificate confirming their legal right to cultivate forest species in the event of an appeal.
The inspectors formally recommended the nullification or administrative freeze of these parcels pending documentation. “Based on the above,” the report states, “we propose nullifying the declared parcels or freezing them, which would require the beneficiaries to submit the aforementioned certificate from the relevant Forestry Departments. We kindly request your approval on this matter.”
The core trick behind the technical solution
The wild olive declarations in areas where the plant cannot grow were just one of many schemes devised to funnel illegal subsidies. The linchpin of the fraud was the implementation of the “technical solution,” officially referred to as the allocation of eligible pastureland. First introduced in 2014, this “technical solution” had been stretched far beyond its original scope by 2019, creating the perfect loophole for systemic abuse. Let’s go back to the beginning.
On December 12, 2014, Minister of Rural Development Giorgos Karasmanis issued a decision outlining the application of the Technical Solution for OPEKEPE-administered subsidies. According to Data Journalists’ reporting, this decision was prompted by the enforcement of an EU-mandated action plan on pastureland. This plan led to the removal of approximately 9.5 million stremmas (950,000 hectares) of pastureland from Greece’s pool of eligible agricultural land.
The action plan resulted from repeated audits by the European Commission between 2009 and 2012 that focused on Greece’s direct subsidy system. After multiple visits, Commission officials concluded that Greece was not complying with EU pastureland regulations. The root of the issue was that the EU’s definition of pastureland did not account for the characteristics of the Mediterranean landscape; rather, it applied criteria suited to the terrain of Northern Europe. Consequently, significant portions of Greek pastureland were disqualified, resulting in substantial fines for Greece and compelling the country to implement a corrective action plan to update the mapping system used for declaring pastureland.
The Karasmanis ministerial decision, which introduced the so-called “technical solution,” included specific provisions known to EU authorities. According to a confidential briefing submitted to the European Public Prosecutor’s Office by a former OPEKEPE executive, the decision included allocating pastureland among regional units for transhumant livestock farmers; not allowing the transfer of pasture rights from one island region to another island or mainland region; and setting a maximum allocation limit of 330 stremmas per farmer.
The amendment that opened the floodgates
In January 2015, Giorgos Karasmanis signed a new ministerial decision introducing a revised version of the national allocation of public pastureland, commonly referred to as the “technical solution.” Decision 104/21.1.2015 applied to the direct payment scheme. According to its provisions, the minimum agricultural activity required for pastureland eligibility was defined as maintaining livestock at a density of 0.7 livestock units (LU) per hectare.
Then, in May 2015, the Ministry of Rural Development’s new political leadership signed Decision 873/20-5-2015, which included several significant changes. The new decision had no time limit for implementation, divided the country into nine spatial zones for allocation purposes – separately for mainland and island regions – and maintained a restriction prohibiting the transfer of allocation surpluses between islands or from islands to the mainland. In other words, pastureland could not be reassigned from one island region to another island or to the mainland, or vice versa.
In June 2015, Evangelos Apostolou, the Minister of Rural Development at the time, amended Decision 104 concerning the direct subsidy regime. According to the revised terms, pastureland in good agricultural condition no longer required the presence of livestock to qualify for subsidies. The only requirement was annual trimming of the grass to ensure it did not exceed 70 centimeters in height. This amendment opened the door to mass applications for subsidies from the National Reserve, which triggered large-scale fraud. The European Public Prosecutor’s Office (EPPO) is currently investigating the full extent of the fraud.
According to a briefing submitted to EPPO, the centralized pastureland allocation system remained relatively “disciplined” in 2014 and 2015. However, 2016 marked the first unauthorized transfer: a small-scale borrowing of pastureland between mainland and island regions, which violated the original decision. By 2017, things began to shift dramatically. According to Data Journalists, that year saw the beginning of a significant artificial increase in declared livestock because the allocation process was now based on Livestock Units (LU) with no upper limit. It was also in 2017 that the first National Reserve was allocated to pastureland that had no animals. According to the same confidential memo, the trend continued into 2018, with the artificial inflation of livestock numbers reportedly escalating.
Starting in 2019, the situation spiraled beyond any oversight. That year, there was a sharp rise in the number of pastureland parcels without animals that received subsidies from the National Reserve, as well as a dramatic increase in the reported number of livestock. The result was the systematic and unauthorized transfer of pastureland from mainland Greece to island regions, circumventing all regulatory constraints.
In 2020, the issue intensified. The amount of pastureland without livestock increased once again, and the number of declared animals – real or not – rose further. This led to even larger unauthorized transfers of pastureland between mainland Greece and its islands.
In 2021, declaring wild olive trees in areas where the species cannot grow was introduced as a way to claim National Reserve subsidies. The first attempt at containment was made in 2022 through the gov.gr platform, but it was only a temporary measure. From 2023 to 2024, organized misappropriation of subsidies from legitimate farmers expanded to include various payments under the new Common Agricultural Policy (CAP) for 2023 – 2027, particularly eco-schemes.
