Hellenic Statistical Authority (ELSTAT)

Business Statistics Division

Registers and Big Enterprises Section

46 Pireos street, GR18510 PIRAEUS

The EuroGroups register (EGR) is the statistical business register of Eurostat and the EU Member States and European Free Trade Association (EFTA) countries for multinational enterprise groups. The purpose of the EGR is to offer to statistical users a tool for coordinating frame population, to derive consistent statistical output with an improved quality in measuring global activities of European enterprises part of multinational enterprise groups.

The EGR produces data in yearly cycles and covers microdata on the groups and their enterprises and legal units. The EGR aims to register all multinational enterprise groups that have enterprises in EU Member States or EFTA countries, including European and non-European groups.

The Member States, EFTA countries and Eurostat exchange data on multinational enterprise groups and on the units belonging to those groups for the purposes of the European framework for statistical business registers to ensure the quality of the multinational enterprise group’s information in the Union.

The EGR brings together microdata on multinational enterprise groups from the EU and the EFTA countries' national statistical institutes, in line with the requirements of the Regulation (EU) No 2152/2019, and from a commercial data source for data outside the EU and EFTA.

Classification systems and main code lists used in the EGR are as follows:

• Statistical classification of economic activities in the European Community (NACE Rev. 2);
• European System of Accounts (ESA 2010);
• List of 2-digit country codes (ISO 3166-1);
• List of legal forms of the legal units;
• Currency codes (ISO 4217).

The coverage of the data transmitted to the EGR is defined in the Regulation (EU) 2019/2152 on European business statistics.

For the purposes of the European framework for statistical business registers, the following economic activities are considered:

• any activity comprising the offer of goods and services on a given market;
• non-market services contributing to the GDP;
• direct and indirect holdings of active legal units.

Holding assets and/or liabilities are also considered an economic activity.

Global group head

The global group head (GGH) of an enterprise group is the parent legal unit that is not controlled either directly or indirectly by any other legal unit. The subsidiary legal units of a subsidiary legal unit are considered to be subsidiaries of the parent legal unit.

Global decision centre

The global decision centre (GDC) of an enterprise group is the unit where the enterprise group level’s strategic decisions are taken. A group may have several decision-making centres or several units dedicated to a particular internal function, for example accounting or human resources. However, the decisions about the group are made only in the GDC. The GDC may be the GGH or another legal unit under the GGH.

Ultimate Controlling Institutional unit

The ultimate controlling institutional unit (UCI) of a foreign affiliate means the institutional unit higher up a foreign affiliate’s chain of control that is not controlled by another institutional unit.

Activity of unit

A statistical unit is considered to have been active during the reference period, if in said period it either realized positive net turnover or produced outputs or had employees or performed investments. A legal unit can be legally or administratively active without any economic activity, when the inactive legal unit is part of an enterprise in combination with economically active legal units. Holding assets and/or liabilities shall also be regarded as an economic activity.

Number of employees

The number of persons who work for an employer and who have a contract of employment and receive compensation in the form of wages, salaries, fees, gratuities, piecework pay or remuneration in kind. The worker from a temporary employment agency is considered to be an employee of the temporary employment agency and not of the unit (customer) in which he works.

Number of employees and self -employed persons

The total number of persons who work in the enterprise, inclusive of working proprietors, partners and unpaid family workers, as well as persons who work outside the enterprise but they belong to it and they are paid by it (e.g. sales representatives, delivery personnel, repair and maintenance teams). The number of persons employed excludes manpower supplied to the enterprise by other enterprises, persons carrying out repair and maintenance work in the enquiry enterprise on behalf of other enterprises, as well as those on compulsory military service

Net turnover

Turnover comprises the totals invoiced by the enterprise during the reference period, which corresponds to market sales of goods or services supplied to third parties. Turnover includes all duties and taxes on the goods or services invoiced by the unit with the exception of the value added type taxes (VAT). Turnover also includes all other charges (transport, packaging, etc) passed on to the customer. Reduction in prices, rebates and discounts, as well as the value of returned packing must be deducted.

Total assets

The total assets refers to the sum of the balance sheet items at the end of the accounting period. It covers economic assets, which are divided into financial and non-financial assets.

Principal activity

The principal (or main) activity is the activity that contributes most to the total value added of a unit under consideration. Ideally, the principal activity of the unit should be determined with reference to the value added to the goods and services produced, by applying the top-down method. The top-down method follows a hierarchical principle: the classification of the unit at the lowest level of the classification must be consistent with the classification of the unit at higher levels. The principal activity so identified does not necessarily account for 50 % or more of the unit’s total value added.

In the European Union the classification of principal activity is determined by reference to NACE Rev. 2, first at the highest level of classification and then at more detailed levels (top-down method).

More information on statistical concepts and definitions relevant to the statistical business registers could be found in the EBS methodological manual for Statistical Business Registers (2021 edition).

The statistical units maintained in the EGR are defined in accordance with the Regulation (EEC) No 696/93 on the statistical units for the observation and analysis of the production system in the Community.

The EGR frame contains the following units: Legal units, Enterprises and Multinational enterprise groups.

Legal units include:

- legal persons whose existence is recognized by law independently of the individuals or institutions which may own them or are members of them,

- natural persons who are engaged in an economic activity in their own right.

The legal unit always forms, either by itself or sometimes in combination with other legal units, the legal basis for the statistical unit known as the 'enterprise'.

Enterprise

The enterprise is the smallest combination of legal units that is an organizational unit producing goods or services, which benefits from a certain degree of autonomy in decision-making, especially for the allocation of its current resources. An enterprise carries out one or more activities at one or more locations. An enterprise may be a sole legal unit.

Multinational enterprise group

A multinational enterprise group is an enterprise group that has at least two enterprises or legal units located in different countries.  In business statistics also term ‘global enterprise group’ is used.

The data transmitted to the EGR during the cycle is made of the following datasets.

1. The data set with information on all incorporated resident legal units for the EGR Identification Service.

ISRLE file including 284,685 population of resident legal units was sent to EGR for identification. The specific population consists of all resident legal units of the National Statistical Business Register. These legal units may be active or liquidated during the reference year.

2. The data set with information on foreign legal units for the EGR Identification Service.

ISNORLE file including 12,238 population of foreign legal units recorded in national statistical business register was sent to EGR for identification. The specific population consists of all non resident legal units having a relationship with a resident legal unit.

3. The data set with information on legal units.

LEU file including 10,122 resident legal units belonging to a global enterprise group was sent to EGR for processing. It consists of all resident legal units belonging to multinational or national enterprise groups.

4. The data set with information on relationships of ownership and control.

REL file including 10,664 relationships between legal units was sent to EGR for processing:

• two resident legal units (1,288 cases)
• one resident and one foreign legal unit (9,325 cases)
• two foreign legal units from non EU+EFTA countries (51 cases).

Relationships in the REL are:

• control relationships (>50%) (8,406 cases)
• minority relationships (<50%) (2,258 cases)

5. The data set with information on enterprises.

ENT file including 8,671 enterprises made of legal units sent in LEU files was sent to EGR for processing. It consists of all enterprises that occur from the profiling process and are part of an enterprise group.

6. The data set with information on links between enterprises and legal units.

LEL file including 10,122 links between enterprise (ENT) and legal units (LEU) was sent to EGR for processing. 

7. The data set with information on enterprise groups of which Greece is the GDC country for the EuroGroups Register.

GEG file including 598 groups' data was sent to the EGR for processing. The data referred to the enterprise groups having Global Decision Center in Greece.

The groups’ variables are updated after receiving the preliminary frame:

• GEG_NAME
• GEG_NACE_CODE_DIV
• GEG_NACE_CODE_DIV STA
• GEG_PERS_EMPL
• GEG_PERS_EMPL_STA
• GEG_TURNOV
• GEG_TURNOV_STA
• GEG_WEB
• GEG_GDC_LEID
• GEG_GGH_LEID

The Reference area of the EGR is the world, although the main interest is the area of EU and EFTA countries. Multinational enterprise groups active exclusively outside the EU and EFTA are not of interest to the EGR.

The EGR frames are available from reference year 2008 onwards. The Hellenic Statistical Authority (ELSTAT) transmits data on all phases of the compilation of EGR since reference year 2018.

Not applicable.

The economic variables on employment are recorded in absolute figures.

The net turnover for enterprises is recorded in EURO currency.

The net turnover and net total asset is recorded in millions in EURO currency.

The reference period for data sent to the EGR reflects the picture of 31 December of the given reference year.

Data initially transmitted to EGR during the EGR 2022 cycle for resident, foreign legal units, relationships and statistical unit "enterprise" refer to 2021. The relevant data are updated during the repair phase on the basis of the profiling procedure, and refer to 2022.

The economic variables (number of employees, turnover and economic activity) refer to the 2022 reference year.

The content of the national data sent to EGR is defined according the Regulation (EU) 2019/2152 on European business statistics.

Commission Implementing Regulation (EU) 2020/1197 of 30 July 2020 is laying down the technical specifications and arrangements pursuant to Regulation (EU) 2019/2152 of the European Parliament and of the Council on European business statistics.

The legal framework concerning the organization and operation of ELSTAT is detailed in the following link:

http://www.statistics.gr/en/legal-framework

The legal framework setting up the procedures for EGR data exchanges and access to confidential data for the purpose of the European framework for statistical business registers are defined in the Regulation (EU) 2019/2152 on European business statistics (Art.10). 

European legislation:

• Regulation (EC) No 223/2009 on European statistics;
• Regulation (EU) 2019/2152 on European business statistics (Art.10).

The national legislative measures or other formal procedures which prevent unauthorised disclosure of data that identify a person or economic entity either directly or indirectly include:

The issues concerning the observance of statistical confidentiality by the Hellenic Statistical Authority (ELSTAT) are arranged by articles 7, 8 and 9 of the Law 3832/2010 as in force, by Articles 8, 10 and 11(2) of the Regulation on Statistical Obligations of the agencies of the Hellenic Statistical System and by Articles 10 and 15 of the Regulation on the Operation and Administration of ELSTAT.

More precisely:

ELSTAT disseminates the statistics in compliance with the statistical principles of the European Statistics Code of Practice and in particular with the principle of statistical confidentiality.

https://www.statistics.gr/documents/20181/1609796/ELSTAT_Statistical_Confidentiality_Policy_EN.pdf/c79e5ac8-469c-433d-b4e6-8433319b21d2

Protection of personal data

ELSTAT abides by the commitments and obligations arising from the applicable EU and national legislation on the protection of the individual from the processing of personal data and the relevant decisions, guidelines and regulatory acts of the Hellenic Data Protection Authority.

Pursuant to the Regulation on the protection of natural persons with regard to the processing of personal data [Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation - GDPR)], ELSTAT implements the appropriate technical and organisational measures for ensuring adequate level of security against risks for the personal data it collects and has access to, in the context of carrying out its tasks, in order to meet the requirements of this Regulation and to protect these personal data from any unauthorised access or illegal processing.

The personal data collected by ELSTAT are used exclusively for purposes related to the conduct of surveys and the production of relevant statistics. Only ELSTAT has access to the data. The controller is the person appointed by law pursuant to the relevant provisions concerning the Legal Entities of Public Law and the Independent Authorities. The data are stored in the databases of ELSTAT for as long as required by the relevant legislation.

Legal basis of the processing: Article 6, para 1(c) and 1(d) of the General Data Protection Regulation (GDPR)

https://www.statistics.gr/el/privacy-info

EGR data are stored by the Commission (Eurostat) and by the national statistical authorities (NSAs) in the EU Member States and EFTA countries in a secure area with restricted and controlled access.

The transmission of the EGR data is done in an encrypted form and by electronic means via the Commission (Eurostat) single entry point for exchange of confidential data EDAMIS.

Rules applied for treating the data set to ensure statistical confidentiality and prevent unauthorised disclosure are defined according to the policy rules (see section 7.1).

ELSTAT protects and does not disseminate data it has obtained or it has access to, which enable the direct or indirect identification of the statistical units that have provided them by the disclosure of individual information directly received for statistical purposes or indirectly supplied from administrative or other sources. ELSTAT takes all appropriate preventive measures so as to render impossible the identification of individual statistical units by technical or other means that might reasonably be used by a third party. Statistical data that could potentially enable the identification of the statistical unit are disseminated by ELSTAT if and only if:

a) these data have been treated, as it is specifically set out in the Regulation on Statistical Obligations of the agencies of the Hellenic Statistical System (ELSS), in such a way that their dissemination does not prejudice statistical confidentiality or

b) the statistical unit has given its consent, without any reservations, for the disclosure of data.

The confidential data that are transmitted by ELSS agencies to ELSTAT are used exclusively for statistical purposes and the only persons who have the right to have access to these data are the personnel engaged in this task and appointed by an act of the President of ELSTAT.

ELSTAT may grant researchers conducting statistical analyses for scientific purposes access to data that enable the indirect identification of the statistical units concerned. The access is granted provided the following conditions are satisfied:

a) an appropriate request together with a detailed research proposal in conformity with current scientific standards have been submitted;

b) the research proposal indicates in sufficient detail the set of data to be accessed, the methods of analyzing them, and the time needed for the research;

c) a contract specifying the conditions for access, the obligations of the researchers, the measures for respecting the confidentiality of statistical data and the sanctions in case of breach of these obligations has been signed by the individual researcher, by his/her institution, or by the organization commissioning the research, as the case may be, and by ELSTAT.

Issues referring to the observance of statistical confidentiality are examined by the Statistical Confidentiality Committee (SCC) operating in ELSTAT. The responsibilities of this Committee are to make recommendations to the President of ELSTAT on:

•  the level of detail at which statistical data can be disseminated, so as the identification, either directly or indirectly, of the surveyed statistical unit is not possible;
• the anonymization criteria for the microdata provided to users;
•  the granting to researchers access to confidential data for scientific purposes.

The staff of ELSTAT, under any employment status, as well as the temporary survey workers who are employed for the collection of statistical data in statistical surveys conducted by ELSTAT, who acquire access by any means to confidential data, are bound by the principle of confidentiality and must use these data exclusively for the statistical purposes of ELSTAT. After the termination of their term of office, they are not allowed to use these data for any purpose.

Violation of data confidentiality and/or statistical confidentiality by any civil servant or employee of ELSTAT constitutes the disciplinary offence of violation of duty and may be punished with the penalty of final dismissal.

ELSTAT, by its decision, may impose a penalty amounting from ten thousand (10,000) up to two hundred thousand (200,000) euros to anyone who violates the confidentiality of data and/or statistical confidentiality. The penalty is always imposed after the hearing of the defense of the person liable for the breach, depending on the gravity and the repercussions of the violation. Any relapse constitutes an aggravating factor for the assessment of the administrative sanction.

Pursuant to the Regulation on the protection of natural persons with regard to the processing of personal data [Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (General Data Protection Regulation - GDPR)], ELSTAT implements the appropriate technical and organisational measures for ensuring adequate level of security against risks for the personal data it collects and has access to, in the context of carrying out its tasks, in order to meet the requirements of this Regulation and to protect these personal data from any unauthorised access or illegal processing.

The EGR final frame is made available to National Statistical Institutes in T+15 months.

The calendar is distributed to the press and is available to all interested parties free of charge. This calendar is also posted on the website of the ELSTAT (www.statistics.gr) under item “Press Releases Calendar”.

It should be noted that a relevant to EGR press release has not yet been disseminated.

Members of the European System of Central Banks (ESCB) have access to EGR data explicitly for the statistical purpose to ensure the quality of the multinational enterprises (MNE) information in Europe. A specific authorisation procedure is applied according to the register legislation.

EGR data are not accessible to the general public.

Accessing EGR data is further restricted to information of those MNE groups, when at least one legal unit of a MNE group is located in the territory of the country of that NSI or NCB. The EGR user thus can access country specific sub-population of the total EGR population via the EGR FATS and EGR IM user interfaces or by downloading EGR data via eDamis.

The EGR final frame is made available to NSIs and Members of the European System of Central Banks (ESCB) on an annual basis.

Not applicable.

Eurostat publishes an experimental statistics article on the Multinational enterprise groups and their structure.

The article presents some aggregated statistics based on the EGR data.

The EGR FATS and EGR IM user interfaces allow statistical users to consult and to download the EGR data via online applications. EGR FATS and EGR IM applications are accessible to all NSIs in the EU and EFTA countries and to the ESCB members.

The micro-data exchange of confidential data on multinational enterprise groups (MNE) and on the statistical units belonging to those groups takes place, exclusively for statistical purposes, between EU Member States and EFTA countries and the European Commission (Eurostat).

Where such exchange of confidential data is carried out to ensure the quality of the multinational enterprise groups' information in the Union and the exchange is explicitly authorised by the competent NSA which provides the data, national central banks may be part to the exchange of confidential data, exclusively for statistical purposes.

NSI exchanges information on MNEs with other Member States, for identification purposes and in order to ensure quality of the MNE information.

Not applicable.

• EuroGroups Register communication space (EGR wiki with restricted access)
• European business statistics methodological manual for statistical business registers – edition 2021

A quality report is sent to Eurostat on an annual basis, starting from reference year 2021.

Eurostat Data Quality Programme monitors the quality and compliance of the data transmitted by the countries to EGR using the instruments of the EBS quality framework.

At national level, the quality of the data sent to EGR is ensured as follows: 

• The compilation of the statistical data is made in accordance with the new European Regulation on Business Statistics, which entered into force on the 1st of January 2021 (Regulation (EU) 2019/2152 of the European Parliament and of the Council of 27th November 2019) and Commisson Implementing Regulation (EU) 2020/1197 of 30th July 2020, laying down technical specifications and arrangements pursuant to Regulation (EU) 2019/2152.
• The compilation of the relevant data is made on the basis of the methodological notes available in EGR wiki.
• The data are updated on the basis of the national and european profiling.

ELSTAT follows the recommendations on organisation and management of quality given in the Code of Practice for European Statistics (CoP) and the implementation guidelines given in the Quality Assurance Framework of the European Statistical System (QAF).

The quality assessment procedure includes:

• automatic validation procedures to check coherence between statistical units and their variables,
• data format and logical content of data,
• crosschecks with data from previous years,
• calculation of EGR - FATS quality indicators.

The EGR provides harmonised information on multinational enterprise groups and their enterprises in the EU and EFTA countries.

The statistical users can use EGR coordinated frame populations to derive consistent statistical output with an improved quality in measuring global activities of European enterprises that are part of multinational enterprise groups. Multinational enterprise groups' information is used for statistics related to globalisation, such as:

1. Statistics on Foreign Affiliates (FATS),
2. Foreign Direct Investment (FDI),
3. Gross National Income (GNI), etc.

The EGR country specific frames are used as a basis for European profiling of the largest and most complex multinational enterprise groups in the EU. EGR information may also be used for quality checks, as a secondary source or for deriving statistics on multinational enterprise groups, etc.

http://www.statistics.gr/en/user-satisfaction-survey

ELSTAT transmits data in all phases of the compilation of the EuroGroups Register (EGR), which are fully in line with the relevant EU Regulations.

The main issues regarding accuracy of the data are as follows:

• The non-identification via EGR-IS of foreign legal units belonging to multinational enterprise groups, whichs affects the final structure of the group.
• Employment data available from administrative sources during the compilation of EGR cycle refence year T, refer to T-1.

The actions taken to monitor and to improve accuracy of the data sent to EGR are the following: 

• Recording of the LEID number of foreing legal units identified in previous EGR cycles, so that the identification for the current year is focused in the foreign legal units not already identified. 
• Estimation of the employment data so as to relate to the reference year. ELSTAT gained access to monthly employment data from the Social Security Fund, which allowed the incorporation to EGR of employment information for referece year 2022 and the further improvement of the accuracy of the respective data. 
• Incorporation of information on the structure of the enterprise group and of the statistical unit enterprise from the national and european profiling.

Not applicable.

Not applicable.

The EGR process refers to a reference year T and is run yearly over a period of 11 months, between May T+1 and March T+2.

The EGR final frame is produced and released to its users at T+15 months.

There are no deviations from the timeliness of each yearly reference cycle.

ELSTAT transmitted the relevant files to Eurostat, in all phases of the EGR compilation, according to the schedule. More specifically:

• the resident and non-resident legal units were sent in T+5 months and T+10 respectively (ISRLE and NOISRLE file)
• the resident legal units which are part of MNEs were sent in T+11,5 (LEU file)
• the relationships of the resident legal units which are part of MNEs were sent in T+11,5 months (REL file)
  • These relationships can be: relationships between two resident legal units, relationships between one resident and one foreign legal unit, relationships between two foreign legal units from non EU+EFTA countries (e.g. LEU1 (RU)-LEU2(RU))
• the characteristics of the enterprises of the resident legal units which are part of MNEs were sent in T+11,5 months (ENT file)
• the one-to-one, one-to-many or many-to-one links between the enterprises and legal units were sent in T+11,5 months (LEL file)
• validation and update or repair of the group data took place during T+12 and T+14 months.

EGR is compiled in accordance with Regulation (EU) 2019/2152 on European business statistics and Commission Implementing Regulation (EU) 2020/1197 of 30 July 2020 which is laying down the technical specifications and arrangements pursuant to Regulation (EU) 2019/2152 of the European Parliament and of the Council on European business statistics. This ensures the comparability of the EGR data with the relevant data of other EU Member States. The common methodology applied at national level also ensures the comparability of data at regional level.

EGR data are comparable over time as they have been compiled on the basis of the same methodology and the same administrative sources and private provider.

Coherence of data sent to Eurostat with other data sources and statistical domains:

• Profiling results
• Statistical Business Register (SBR)

Data sent to EGR should be internally consistent. There is a set of standard quality checks that are routinely performed at national level before transmitting the data to Eurostat:

• Data transmitted to Eurostat on the structure of the enterprise group are compared to the results of the profiling process
• Data transmitted to Eurostat on the structure of the statistical unit "enterprise" are compared to the results of the profiling process
• Cross checks of the different files sent to Eurostat take place so that internal coherence is ensured.

EGR data are mainly compiled on the basis of administrative data and data from private provider. Therefore, no burden on enterprises is created.

The Revision Policy of ELSTAT is available at the following link: http://www.statistics.gr/documents/20181/a49dca9a-dacf-4b52-b5df-b156216cb354

Not applicable.

The sources used for the compilation of EGR 2021 data were the following:

• National Statistical Business Register (NSBR)
• Commercial Data Provider for the structure of the enterprise groups
• Foreign Direct Investment Survey data, from the National Bank of Greece, for the structure of the enterprise groups
• National profiling, for the structure both of enterprise groups and statistical unit "enterprise"
• Turnover data from administrative transaction files from the Independent Authority for Public Revenues (AADE)
• Employment data from the Social Security Fund (e-EFKA)
• Intra-flow transactions survey, for the compilation of the consolidated turnover of the statistical unit enterprise

The data used for the compilation of the EGR files are collected on an annual basis from the various data sources.

Data sent to EGR are collected from:

• National Statistical Business Register (NSBR)
• Commercial Data Source for the structure of the enterprises groups
• Foreign Direct Investment Survey data, from the National Bank of Greece, for the structure of the enterprise groups
• National profiling, for the structure both of enterprise groups and statistical unit "enterprise"
• Turnover data from administrative transaction files from the Independent Authority for Public Revenues (AADE)
• Employment data from the Social Security Fund (e-EFKA)
• Intra-flow transactions survey, for the compilation of the consolidated turnover of the statistical unit enterprise

The EGR data validation is based on the results of the national and european profiling and in the disseminated financial statements of the enterprise groups.

This procedure mainly takes place during repair phase of the structure of the groups by delivering relationships and data on enterprise groups to the EGR and also by pre-validating the EGR input file.

Estimation of employment at the level of Legal unit takes place, given that the respective information is not available from the data sources used. The final employment data at legal unit level are subsequently used for the calculation of employment for the statistical unit "enterprise".

Estimation of turnover at the level of the statistical unit enterprise is based on the consolidated data of the previous year (2021) and turnover data from administrative transaction files of the year 2022.

Not applicable.

Not applicable.