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Draft — internal Mitos pilot specification

Ref: Mitos 344883 · Law 4495/2017 · e-Adeies platform

Professional Chamber / Municipal Authority · Greece

Technical Chamber of Greece (TEE) / Municipal Building Services (YDOM)

Building Permit Issuance with Pre-approval (e-Adeies)

DRAFTIGSL L3v1

Institutional framework

Institution

The building permit with pre-approval is the administrative procedure through which an authorised engineer submits a complete dossier via the TEE (Technical Chamber of Greece) e-Adeies platform and obtains an automatically-issued building permit under Greek Law 4495/2017. It applies to building permit Categories 1, 2, and 3 where preliminary approval (Προέγκριση) is mandatory or voluntarily obtained.

The procedure is governed principally by Law 4495/2017 (Building and Urban Planning Act), particularly Articles 33, 35, 36, 38, and 40. It is operationally mediated by the TEE e-Adeies information system.

Structural signature

This procedure is structurally distinctive within the Greek e-government corpus: the core institutional decision — the building permit itself — is fully automated. No human official exercises discretionary judgment on whether to issue the permit. The automated system issues the permit number within 3 working days of a complete dossier submission, and the permit is published online immediately. Construction may begin from that moment.

This places the institutional weight of the procedure on two different acts:

  1. The engineer's professional attestation (CP-1): the authorised engineer, by submitting the dossier under statutory declarations of assignment and supervision, creates professional liability and triggers the automated decision. The engineer's act is the real gatekeeping act.
  2. The automated system decision (CP-2): the TEE system performs the issuance — a software-mediated binding administrative act.

A third act — the post-issuance levy and budget check (CP-3) — follows within 3 days of issuance and is performed by the local YDOM; this check is also transitioning toward automation.

Institutional structure

Two distinct institutional actors appear:

  • TEE (Technical Chamber of Greece): operates the e-Adeies platform; its information system issues the permit number automatically.
  • YDOM (Υπηρεσία Δόμησης): the municipal Building Service. Issues the underlying pre-approval (in a prior procedure), and conducts the post-issuance levy check. Also the filing body for any hierarchical appeal.

A third upstream actor exists off-procedure: YDOM (or the Ministry of Development for strategic investments) must have issued the pre-approval (Mitos 893653) before this procedure can begin.

Prerequisite: pre-approval (Mitos 893653)

Before any submission can be made under this procedure, the applicant must hold a valid preliminary approval of the building permit (Προέγκριση οικοδομικής άδειας) issued under the separate prior procedure Mitos 893653. This prerequisite is hard and blocking — no submission is possible without it. Pre-approval is obtained from YDOM (or the Ministry of Development for strategic investment cases) under Art. 35–36 N.4495/17.

This cross-procedure dependency is the strongest of its kind encountered in the Mitos pilot corpus.

Normative structure

The procedure passes through three commitment points:

  1. The dossier must be submitted by an authorised engineer bearing active TEE credentials, accompanied by statutory declarations of professional assignment, assumption, and supervision of studies.
  2. The TEE system automatically issues the building permit number and publishes it online; construction may begin immediately. Permit is valid for 4 years from issuance.
  3. YDOM reviews the required contributions and project budget within 3 days of issuance. This is currently a manual check, transitioning to automated.

Recourse

A hierarchical appeal (Ιεραρχική Προσφυγή) is available within 30 days of notification or knowledge of any YDOM act (CP-2 or CP-3), filed with the YDOM that issued the act and reviewed by the Regional Councils for Urban Planning Issues and Disputes (ΠΕ.ΣΥ.ΠΟ.Θ.Α.) under Art. 26 N.4495/2017.

Governing principles (0)

Protocol topology

Commitment points (3)

ATTEST#1AAuthorised Engineer (holder of active TEE/My TEE credentials)

Engineer Professional Attestation and Dossier Submission

The authorised engineer submits the application — including statutory declarations of assignment, assumption, and supervision of studies — together with the full dossier of technical studies and supporting documents via the TEE e-Adeies electronic platform. Submission automatically triggers permit issuance. A hard blocking prerequisite (pre-approval, Mitos 893653) must have been obtained before this step.

Good practice

Title of ownership and cadastral certificate or extract (κτηματογραφικό απόσπασμα).Αρχιτεκτονική μελέτη (μελέτη παθητικής πυροπροστασίας και προσβασιμότητας ΑΜΕΑ συμπεριλαμβάνεται).Στατική μελέτη.Μελέτη χρονικού προγραμματισμού εκτέλεσης του έργου.Μελέτη υδραυλικών εγκαταστάσεων και αποχετεύσεων.Σ.Α.Υ./Φ.Α.Υ. κατά π.δ. 305/1996.Σχέδιο Διαχείρισης Αποβλήτων με αντίγραφο σύμβασης ΑΕΚΚ ή έγκριση ΑΣΕΔ.Αιτιολογική έκθεση.Αποδεικτικά κατάθεσης εισφορών ιδιοκτήτη.Αντίγραφο απόδειξης παροχής υπηρεσιών ή τιμολόγιο αμοιβής και Φόρου Εισοδήματος Μηχανικών.

Possible outcomes

SUBMITTEDREJECTED INCOMPLETE

Authority

Model: INDIVIDUAL
Automation: SEMI_AUTOMATED
Roles:
  • Authorised Engineer (holder of active TEE/My TEE credentials)

Legal basis

  • Art. 38 §6 N.4495/2017
  • Art. 40 N.4495/2017
  • Mitos 344883 steps 1–3
DECIDE#2TTEE e-Adeies Information System

Automatic Building Permit Issuance

The TEE e-Adeies system automatically issues the building permit number within 3 working days of dossier submission. The permit number is published online immediately upon issuance. Construction works may commence from the moment of publication. The permit is valid for 4 years from issuance.

Possible outcomes

PERMIT ISSUED

Authority

Model: AUTOMATED
Automation: FULLY_AUTOMATED
Roles:
  • TEE e-Adeies Information System

Legal basis

  • Art. 38 §6a N.4495/2017
  • Mitos 344883 step 4

Disagree?

  • YDOM (filing) / PESYPOTHEA (review)

    Window: P30D

DECIDE#3MMunicipal Building Service (Υπηρεσία Δόμησης — Υ.ΔΟΜ.) of competent municipality

Post-Issuance Levy and Budget Determination (YDOM)

Within 3 days of permit issuance, the competent YDOM reviews the required contributions and deductions to the State, municipality, and e-EFKA, including a project budget check (Art. 38 §6 N.4495/17). This check is currently performed manually by YDOM officials but will be replaced by automated system verification once the information system capability is activated (transitional provision).

Possible outcomes

LEVIES CONFIRMEDDISCREPANCY NOTED

Authority

Model: INDIVIDUAL
Automation: TRANSITIONING_TO_AUTOMATED
Roles:
  • Municipal Building Service (Υπηρεσία Δόμησης — Υ.ΔΟΜ.) of competent municipality

Legal basis

  • Art. 38 §6 N.4495/2017
  • Mitos 344883 step 5

Disagree?

  • YDOM (filing) / PESYPOTHEA (review)

    Window: P30D

Temporal constraints (4)

TypeDurationReferenceOn Expiry
?
?
?
?

Glossary

Historical context

The rendered specification follows the internal structure visible in the Mitos administrative record for service 344883 (extraction date: 2026-05-02, ICSL extraction v0.2). That record exposes the complete building permit issuance chain: engineer submission with statutory declarations, fully automated permit issuance, and post-issuance levy check.

This is modeled as a three-CP protocol rather than a flat service transaction. The engineer's professional attestation, the automated issuance decision, and the YDOM levy check are treated as separate commitment points because each carries a distinct institutional function, authority, and downstream consequence.

The cross-procedure dependency on pre-approval (Mitos 893653) is preserved explicitly as a blocking external dependency node in the topology, reflecting its significance as the primary condition for entry into this procedure.

Open questions

  • CP-2 automated check scope (amb_001): The exact nature of the TEE system's automated checks is not described in the source. If only completeness (not regulatory compliance) is checked, the substantive gatekeeping function may be effectively delegated to the engineer's attestation at CP-1.
  • CP-3 discrepancy outcome (amb_002): The source does not describe what happens when YDOM finds a levy/budget discrepancy. Whether this produces a suspension, a correction notice, or a purely accounting consequence is unknown from the source. CP-3 is retained on institutional-function grounds at confidence 0.72.
  • CP-1 ATTEST boundary (amb_003): The ATTEST classification for the engineer's submission is a considered inference from the professional liability nature of the statutory declarations. If ICSL extraction Rule 2 is tightened, this CP might be reclassified as a precondition, reducing the CP count to 2.
  • AUTOMATED authority model / TRANSITIONING_TO_AUTOMATED automation level: Both are non-standard ICSL values introduced as candidate spec pressures (csp_001, csp_002). The former captures a genuinely automated administrative decision-maker; the latter captures a transitional state.
  • Deadline unit precision: The 3-working-day deadline for permit issuance uses ISO P3D, which does not distinguish working days from calendar days. This is a known candidate spec pressure (csp_003).