The Audit Office has expressed significant reservations in its Special Report on the “Digital Citizen” project, implemented by the Deputy Ministry of Research, Innovation and Digital Policy.
Project background and contractor selection
The application was developed as part of an intergovernmental collaboration with Greece’s Ministry of Digital Governance, under Article 39(4) of Directive 2014/24/EU. However, implementation was awarded directly to the same private contractor that developed Greece’s “gov.gr wallet,” through a negotiated procedure without an open tender.
The Audit Office questions whether this approach fully ensures transparency and equal treatment of economic operators, noting the potential for a preferential position for the existing contractor.
Work commenced before contract signing
The report emphasises that technical work for the Digital Citizen project began in March 2024, prior to the signing of the Memorandum of Cooperation (June 2024) and the Contract (October 2024).
The initial technical plan envisaged five months of implementation, yet the project took around eight months to become operational in December 2024. The contractual schedule, however, stipulated just two months, creating the impression of a predetermined project trajectory.
Legal basis change
Three days before signing the contract, the legal basis was changed from Article 12(4) to Article 39(4) of Directive 2014/24/EU. Despite this change, the implementation still proceeded with the same contractor through a negotiated procedure, which, according to EU Court of Justice case law, is allowed only under strict conditions and as an exception.
Cost and financial oversight
The contract totals €1.7 million, with €1.5 million contributed by Cyprus and €200,000 by Greece. At the time of signing, there was no detailed cost assessment or preliminary pricing for the €1.5 million portion. The absence of comparative cost data makes evaluating the economic efficiency of the agreement difficult.
The final project cost exceeds the contract, covering project management, system interconnections, promotional campaigns, and technical equipment.
Hosting and technical oversight
The application is hosted on the same cloud infrastructure as the Greek platform, without documented evaluation of alternative hosting options. Technical supervision is carried out by Greece, with the Deputy Ministry receiving inspection results, limiting direct oversight over a critical national digital infrastructure.
Strategic planning and European integration
The Audit Office raises questions regarding strategic planning in light of the mandatory European Digital Wallet implementation. It remains uncertain whether the Digital Citizen project will serve as a genuine stepping stone towards the EU solution or require redesign with additional costs and resources.
The Special Report concludes with recommendations to strengthen transparency, document costs, and rigorously adhere to public procurement principles.
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