Customs administrations generate a vast amount of data every single day. From declarations and controls to audits, seizures and facilitation programmes, our institutions are rich in operational information. For Greek Customs, as for many other Customs administrations, the primary challenge lies in transforming these datasets into meaningful intelligence that supports innovation, accountability and informed decision-making. The WCO Performance Measurement Mechanism (PMM) provides an international framework that helps Customs administrations identify what truly matters, benchmark themselves globally and pinpoint areas for improvement.

This article explores the experience of the Greek Customs administration implementing the WCO PMM during its first full reporting cycle. It reflects on the institutional context of Greek Customs, the motivations for joining the PMM, the practical challenges encountered, the analytical value of the results obtained, and the lessons learned for embedding performance measurement into long-term governance and reform agendas. Rather than focusing solely on scores, the Greek experience demonstrates how the PMM can act as a catalyst for organizational learning, strategic dialogue and data-driven Customs modernization.

The General Directorate of Customs & Excise Duties (Greek Customs) is a key pillar among the eleven General Directorates within the structure of the Independent Authority for Public Revenue (IAPR). IAPR’s mission is to safeguard public revenue by promoting tax compliance and combating tax evasion and smuggling, while providing high-quality services to citizens and businesses. To fulfil this mandate, the IAPR exercises a broad range of organizational and operational powers, including the determination, assessment and collection of tax, customs and other public revenues, as well as the identification and prevention of tax evasion, smuggling, tax fraud, illegal trade and the shadow economy.

The IAPR is also responsible for implementing tax and customs legislation, enhancing the effectiveness and efficiency of its services, while improving public revenue collectability through strategic and operational planning, target-setting and performance measurement. Its remit also extends to protecting public health, the environment and consumer interests, while supporting fair market functioning and competitiveness, the provision of e-services to citizens, businesses and public-sector bodies, the development of its IT and e-governance strategy and the identification of risks related to corruption, inefficiency or non-compliance within its services. The IAPR further prepares and executes its own budget and procurement programme to ensure the smooth operation of its activities.

Within this institutional framework, the General Directorate of Customs & Excise Duties comprises four Central Directorates, three Regional Customs Directorates, 88 Customs Offices, and a network of specialized audit, investigation and mobile enforcement units. Staffed by approximately 2,360 Customs officers who serve across the country, with a balanced gender distribution. This organizational scale and diversity require robust coordination mechanisms, clear strategic priorities and reliable performance information to ensure consistent service delivery and effective enforcement.

Performance management is already deeply embedded in the IAPR’s governance model. A multiannual Strategic Plan, complemented by an Annual Business Plan, defines key objectives, reform initiatives and measurable indicators. Performance is monitored through monthly reporting tools, quarterly reviews, structured internal reporting to senior management and an Annual Performance Report. At the same time, the IAPR is investing in an integrated information system designed to digitize and enhance performance management across all IAPR domains.

This existing performance culture provided a solid foundation for engaging with the WCO PMM, while also highlighting the opportunity to align national indicators with international methodologies and end-to-end performance concepts.

Participation in the WCO PMM was a strategic choice aligned with several reform agendas. The IAPR Strategic Plan 2020-2024, currently followed by the new Plan for 2025–2029, IAPR’s Strategic Plan against corruption for the years 2022-2025 as well as the broader vision of “Tax Administration 3.0” all emphasize the principle of measuring what matters, treating performance measurement not merely as a reporting obligation, but as an essential management tool for transparency, accountability and continuous improvement.

For Greek Customs, the PMM offered three distinct added values.

1. Global Benchmarking: It enabled global benchmarking beyond national or regional reference points, allowing Greek Customs to compare their performance with that of other WCO Members using a common language and methodology.
2. Strategic Alignment: It supported alignment with international standards and the Sustainable Development Goals (SDGs), strengthening the international relevance of national performance narratives.
3. Holistic Insights: It complemented existing EU-level and national performance frameworks by introducing indicators focused on outcomes, effectiveness and end-to-end processes.

The readiness of Greek Customs to engage with the PMM was further reinforced by prior experience with EU Customs Union Performance (CUP), monitoring the maturity of internal performance practices. Greece was among the 62 WCO Members that successfully submitted sufficient data in PMM Version 1, confirming both institutional commitment and operational capacity. 

The implementation of the PMM required structured coordination across multiple services within IAPR. Two National Contact Points (Customs International Relations Directorate and Customs Procedures Directorate) coordinated data collection, interpretation and validation within a demanding 30-day reporting window.

Inputs were required from several Customs Directorates, operational units and horizontal services, reflecting the cross-cutting nature of PMM indicators. This process highlighted both the strengths of existing cooperation mechanisms and the areas where data ownership, documentation and standardization could be improved. Importantly, the PMM exercise acted as a practical stress test for internal coordination and data maturity arrangements.

As with many first-time participants, Greek Customs faced challenges related to data availability and standardization. Certain PMM indicators were not systematically measured within existing national frameworks, requiring ad hoc data extraction and manual calculations. Differences in definitions and measurement approaches necessitated careful interpretation to ensure consistency with WCO guidance.

Standardization constraints also played a substantial role. Although Greece has made significant progress in Customs IT systems, not all required data could be retrieved automatically. Manual extraction and verification increased the workload on individuals and teams under time pressure, underscoring the vital need for more automated and standardized data pipelines.

At the same time, certain PMM indicators could only be partially covered due to national specificities. These included non-availability of required disaggregation (i.e. by mode of transport in several enforcement KPIs), or institutional responsibilities extending beyond Customs, such as measurement of the “effectiveness of controls on foodstuffs and consumer goods”. Rather than viewing these gaps as shortcomings, Greek Customs treated them as analytical signals pointing to areas where performance measurement boundaries and inter-agency cooperation require further attention.

One of the most valuable outcomes of participating in the PMM was the opportunity to systematically compare PMM Key Performance Indicators (KPIs) with existing national performance metrics. Several PMM KPIs were already reflected, either directly or indirectly, within IAPR’s national performance framework, particularly in the enforcement domain.

National indicators monitor, among other metrics, the percentage of import and export controls, the volume of seizures, post-clearance audits conducted, violation detection rates and the proportion of staff dedicated to enforcement activities. These indicators are vital for operational oversight, ensuring compliance with nationally defined targets.

The PMM, by contrast, introduces a performance logic centered on effectiveness, outcomes and international comparability. Bringing both perspectives together allowed Greek Customs to distinguish between operational activity levels and strategic performance results, enhancing the analytical depth of performance discussions.

The Authorized Economic Operator (AEO) programme serves as a prime example of the complementary value between national and PMM indicators. National performance indicators track the total number of AEO certificate holders, a figure that has shown steady growth in Greece over recent years. This metric is essential for monitoring programme uptake and administrative output.

PMM KPIs, however, go a step further by measuring the variation in the number of AEOs and the share of trade the conduct. These indicators capture the economic relevance and facilitation impact of the programme. During the 2022 PMM cycle, Greek Customs observed positive trends consistent with national data, while gaining new insights into how AEOs contribute to trade flows and overall competitiveness.

This combined analytical approach addresses two distinct but equally important questions: how many AEOs does Greece have, and how effectively do they contribute to trade facilitation. The PMM thus supported a more strategic assessment of programme performance, moving beyond mere administrative growth.

A second illustrative case focuses on clearance and release times. National performance indicators track the percentage of declarations cleared within one hour, with targets exceeding 70% for both imports and exports. These indicators reflect service delivery standards strictly within the scope of Customs control.

PMM KPIs, by contrast, measure actual time performance in minutes for the physical release of goods, capturing the entire end-to-end process across the supply chain. When comparing the two datasets, Greek Customs observed significant differences, particularly regarding imports. While national targets were largely met, PMM results revealed longer average release times influenced by factors beyond the immediate Customs sphere  — such as terminal operations, logistics processes and inspections by other authorities.

This comparison reinforced a critical lesson: effective trade facilitation requires end-to-end measurement and shared accountability. PMM indicators enabled evidence-based dialogue with stakeholders and highlighted systemic bottlenecks that would otherwise remain invisible through Customs-centric metrics.

One of the most tangible impacts of the PMM exercise was the quality of the internal dialogue it stimulated, particularly regarding enforcement performance. While Greek Customs already monitor a broad set of national enforcement indicators, PMM KPIs introduced a different perspective, shifting the focus from activity volumes to effectiveness, outcomes and proportionality.

Discussions based, for instance, on the correlation between the controls intensity and their results. PMM indicators on inspection rates and detection outcomes encouraged a more nuanced analysis of risk management practices: Are controls sufficiently targeted? Do higher control rates yield into proportionally higher detection of violations? How effectively do post-clearance audits contribute to compliance?

These questions led to constructive exchanges among data contributors, operational units, risk management teams and operational planners. Rather than reinforcing a culture of rigid quantitative control targets, PMM supported a gradual shift towards quality-based enforcement assessment, aligned with risk-based principles and trade facilitation objectives.

In parallel, PMM data highlighted areas where performance is influenced by factors beyond Customs’ direct control, such as inter-agency inspections or logistics processes. This reinforced the understanding that enforcement performance should be assessed within the broader border management ecosystem, providing a solid basis for informed discussions with partner authorities.

The comparison between national indicators and PMM KPIs allowed Greek Customs to identify concrete areas for improvement. Within the enforcement domain, the need for a more systematic linkage between risk analysis, control selection and post-control outcomes became evident. PMM results have encouraged the further refinement of feedback loops between frontline controls and strategic risk profiling.

In the area of trade facilitation, discrepancies between national clearance standards and PMM end-to-end release times highlighted bottlenecks located outside the Customs IT environment. These findings are currently informing discussions on stakeholder engagement, process mapping and enhanced cooperation with terminal operators and other authorities.

From a governance perspective, PMM also exposed gaps in data standardization and documentation. Some indicators required significant manual effort, revealing the importance of embedding performance requirements into system design rather, than treating them as ad hoc reporting exercises.

Preparation for the first PMM cycle required early planning, clear role allocation and robust internal communication. Greek Customs established a dedicated coordination core, led by the designated National Contact Points, supported by focal points within key Directorates. This structure ensured both horizontal oversight and the necessary sector-specific expertise.

A mapping exercise was conducted to identify data owners for each PMM KPI and to assess data availability, quality and extraction methods. Where indicators were not directly aligned with existing national metrics, methodological notes were prepared to document assumptions, calculation methods and limitations. This proved essential for ensuring consistency and building institutional memory.

Time constraints were addressed through strict prioritization and clear timelines. Regular internal check-ins during the data collection period allowed potential issues to be identified early and resolved collaboratively, significantly reducing last-minute pressure.

Several challenges emerged during implementation. The most significant related to data fragmentation and the absence of automated reporting for certain indicators. Greek Customs addressed this by consolidating data from multiple sources and validating results through cross-checks with operational units.

Interpretation challenges were mitigated through close adherence to WCO methodological guidance and peer exchange. When ambiguities arose, they were documented transparently rather than adjusted to fit expectations, thereby reinforcing the integrity and reliability of the results.

Resource constraints were managed through strong senior management support, which recognized PMM participation as a strategic priority rather than an additional reporting exercise. This endorsement was critical in mobilizing cooperation across all services and ensuring the project’s success.

Based on the first PMM cycle, several lessons may be of value to other Customs administrations considering participation. Early preparation and clear governance arrangements are essential. Assigning data ownership and documenting methodologies reduces pressure and improves data quality.

Equally important is the mindset adopted towards the results. PMM is most valuable when utilized as a diagnostic and learning tool, rather than a mere performance ranking exercise. Variances and gaps should be explored analytically, as they often reveal systemic issues or latent opportunities for reform.

Finally, integration matters. The real impact of PMM emerges when its results are embedded into national planning, reform design and stakeholder dialogue. When combined with existing national indicators, PMM provides a powerful, credible and internationally aligned performance narrative.

Moving forward, the IAPR is committed to addressing deeper data standardization and system design gaps. We aim to institutionalize permanent mechanisms for PMM data collection, validation and reporting, while formalizing clear data ownership across Directorates, and leveraging PMM results in strategic communications, including Sustainable Development Goal (SDG) reporting.

Peer learning has also emerged as a significant opportunity for knowledge transfer. PMM results provide a concrete basis for identifying high-performing peers and seeking targeted support, knowledge exchange and capacity building. In this sense, PMM is not a one-off reporting exercise, but a dynamic platform for continuous institutional learning.

The experience of Greek Customs demonstrates that the true value of the WCO Performance Measurement Mechanism resides not in achieving “perfect scores”, but in gaining a deeper institutional understanding. By integrating national performance indicators with PMM KPIs, Customs administrations can construct a more accurate and credible narrative of their performance, grounded in both national realities and global benchmarks.

In alignment with the WCO Strategic Plan 2025–2028 theme of serving data-driven Customs for a connected world, PMM supports evidence-based reform, fiscal transparency and modern public service delivery. By sharing experiences openly, Customs administrations contribute collectively to a global culture of performance, mutual learning and trust across the Customs community.

In December 2025, the WCO launched the self-assessment phase of the second cycle of the Performance Measurement Mechanism and WCO Members are now invited to submit their data through the PMM Platform. Greek Customs had already commenced preparations for this cycle. Administrations that have not participated in the first cycle are strongly encouraged to nominate a national coordinator to manage access to the PMM online platform.

Greek Customs remain an active participant in the Performance Measurement Mechanism Project Team set up by the WCO to maintain and develop the mechanism. We are honored to chair the next meeting of the Project Team at the end of 2026, and we look forward to welcoming many more administrations to join us in this collective effort to shape the future of Customs performance.

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