WINTER 2015 WINTER 201 5 ,Vtnt t')l li otinn .State bllio-tin At a regional level the European Social Charter provides only one quasi-judicial complaint mechanism for enforcing economic and social rights. 54 The European Social Charter offers only a right to lodge collective complaints and the European Committee of Social Rights (ECSR) issues only non-binding recommendations. However, the ECSR has in past years developed extensive case law stemming from collective complaints arising from the crisis and has confirmed that state shall guarantee the enjoyment of economic and social rights. 5 It noted in 2009 GeneralIntroduction to Conclusions that "the economic crisis should not have as a consequence the reduction of the protection of the rights recognized by the Charter. Hence, the governments are bound to take all necessary steps to ensure that the rights of the Charter are effectively guaranteed at a period of time when beneficiaries need protection the most. '56 Such pronouncement follows the principle of non-retrogression deriving from the CESCR. 57 The ECSR also dealt with the issue of socio-economic rights in times of crisis in decisions stemming from collective complaints. For instance, they noted in the case General Federation of Employees of the National Electric Power Corporation (GENOP-DEI)/ Confederation of Greek Civil Servants' Trade Unions (ADEDY) v. Greece, that spending cuts due to crisis "should not excessively destabilize the situation of those who enjoy the rights enshrined in the Charter., 58 It further noted "that a greater employment flexibility . . . should not result in depriving broad categories of employees, particularly those who have not had a stable job for long, of their fundamental rights in the field of labor law, protecting them from arbitrary decisions by their employers or from economic fluctuations." 59 Furthermore, the Committee continued that "doing away with such guarantees would not only force employees to shoulder an excessively large share of the consequences of the crisis but also accept pro-cyclical effects liable to make the crisis worse and to increase the burden on welfare systems. 6 ° In a similar decision against Greece, the Committee emphasized that that any spending cuts, "should not undermine the core framework of a national social security system or deny individuals the opportunity to enjoy the protection it offers against serious social and - See generally Olivier D. Schutter & Matthias Sant'ana, The European Committee of Social Rights (the ESCR), in G. de Beco (ed.), HUMAN RIGHTS MONITORING MECHANISMS OF THE COUNCIL OF EUROPE, 71-99 (Gauthier de Beco ed., 2013). 55See General Federation of Employees of the National Electric Power Corporation (GENOPDEI) / Confederation of Greek Civil Servants' Trade Unions (ADEDY) v. Greece, Complaint No. 65/2011; Federation of employed pensioners of Greece ((IKA -ETAM) v. Greece, Complaint No. 76/2012 56European Comm. of Social Rights [ECSR], European Social Charter, Conclusion XIX-2, at 13(2009). 57Comm. on Econ., Soc. and Cultural Rights, General Comment 3, The Nature of States Parties' Obligations (Fifth session, 1990), U.N. Doc. E/1991/23, annex IIat 86 (1991). 58 European Committee of Social Rights, Complaint No. 65/2011 General Federation of Employees of the National Electric Power Corporation (GENOP-DEI) / Confederation of Greek Civil 59 Servants' Trade Unions (ADEDY) v. Greece, 23 May 2012, para. 17. Id. at Para. 18. 60Id.