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Expanding Financial Statement Review for SMEs: A Parliamentary Proposal Under Scrutiny

In a significant development, the Hellenic Parliament is considering a proposal that would extend the option of financial statement review – instead of a full audit – to a larger cohort of businesses. Currently, from 2023 onward, companies with an annual turnover of up to €200,000 are subject to a review of their financial statements by a certified auditor or audit firm rather than undergoing a full audit, which requires audited financial accounts.

Proposal Details And Expansion Of Thresholds

The proposal, introduced by DISI, seeks to extend this regime to companies with an annual turnover of up to €900,000. The rationale behind the measure is to ease the administrative burden on smaller enterprises and multi-company groups that often struggle to comply with the rigorous demands of international financial reporting standards.

Tax Authority Concerns And Revenue Implications

However, the proposal has met with resistance from the Tax Department. During a recent debate in the Parliamentary Commerce Committee, the Tax Commissioner, Sotiris Markidis, warned that raising the threshold to €900,000 would result in approximately 66% of companies being subject only to a financial statement review. He argued that as the ceiling increases, the state stands to lose significant revenue – citing a potential revenue risk of €0.5 billion.

Industry Reactions And Comparative Analysis

Markidis further cautioned that the streamlined review process lacks the detail of a full audit, potentially facilitating tax evasion among small enterprises – a concern that has precedent in the market. Representatives from the Small and Medium Enterprises Association (SELK) and the Banks Association have argued that the measure should target only very small companies. Additionally, a spokesperson for the Central Bank has recommended against the proposal in its current form, suggesting instead a hybrid review system for businesses with turnovers up to €900,000.

Establishment Of A Financial Reporting Standards Council

In a related legislative effort, the Commerce Committee also reviewed a second proposal by DISI, which would establish a Council for the Determination of Financial Reporting Standards. This council would be responsible for setting, monitoring, and evaluating the financial reporting standards applied by small companies, aiming to reduce administrative burdens while ensuring compliance with international practices.

Future Directions And Administrative Considerations

Industry insiders, including SELK and banking representatives, maintain that the measure should only encompass the very smallest enterprises. Meanwhile, the Tax Department and other stakeholders continue to emphasize the potential fiscal risks associated with broadening the turnover threshold. Furthermore, a representative from the Central Bank noted that the new financial standards council should ideally operate independently of the Ministry of Energy and the Department of Company Registrations, suggesting a reassignment of its oversight to either the Ministry of Finance or SEM’s regulatory framework. The final decision now rests with the council of the respective associations.

EU Investigates Booking.com Over Fake Listings And Advertising Transparency

The European Commission has opened an in-depth investigation into whether Booking.com complied with the EU’s Digital Services Act (DSA), focusing on fraudulent property listings, phishing scams and the transparency of paid search results.

Regulators will assess whether the platform adequately identified and mitigated consumer risks, including financial losses caused by fake accommodation offers and deceptive messages.

Fake Listings And Consumer Protection

As part of the investigation, the Commission will examine whether Booking.com took sufficient steps to address listings for non-existent properties, impersonation fraud and accommodation offers that may not meet applicable requirements. It will also assess the platform’s safeguards for removing fraudulent or non-compliant listings.

Phishing Risks And Guest Data

Another area of scrutiny concerns the risks associated with sharing reservation and guest data with accommodation providers, as well as the design of Booking.com’s messaging tools.

Weak safeguards could allow scammers to exploit these channels to obtain personal information or trick customers into making fraudulent payments.

Paid Search Results Under Scrutiny

A further focus is whether Booking.com clearly identifies paid-for search results. Accommodation providers can pay higher commissions to improve their rankings, but EU rules require users to recognise advertisements and understand who paid for them, why they are being shown and how advertising preferences can be adjusted.

Potential DSA Violations

If confirmed, the suspected failures could breach Articles 34 and 35 of the DSA, which require very large online platforms to assess and mitigate systemic risks. The investigation may also concern Article 26(1), which sets out transparency requirements for online advertising.

According to the Commission, the investigation will be treated as a priority. Possible next steps include requests for further information, interviews and inspections. The Commission may also impose interim measures, issue a non-compliance decision or accept commitments from Booking.com.

Opening proceedings does not prejudge the outcome. However, during the investigation, the Commission will directly supervise the suspected advertising-transparency issue under Article 26(1), rather than leaving it to national authorities.

Wider Implications For Online Marketplaces

The investigation follows the Commission’s review of Booking.com’s risk assessment and transparency reports, alongside its responses to formal information requests issued on September 23, 2025, and May 26, 2026. The Commission is working with the Dutch Authority for Consumers and Markets, the country’s Digital Services Coordinator.

Booking.com was designated a Very Large Online Platform under EU law on April 25, 2023. The case will test whether the company’s safeguards for consumer protection, security and advertising transparency meet the requirements imposed on major online platforms.

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