Power Generation, Transmission & Distribution 2024 Comparisons

The energy industry in Greece comprises five major segments: generation, storage, transmission, distribution and supply. 

Power generation in Greece constitutes an open market. The main players involved in power generation include the state-controlled Public Power Corporation S.A. (PPC), which is the main electricity producer in the country, operating a large part of the lignite and hydroelectric power plants, as well as many private companies, which have recently entered the market, mainly, in the renewable energy generation sector. Energy storage, still developing but rapidly growing, uses technologies like batteries and pumped storage to balance supply and demand and has been designated by the Greek government as a key countermeasure against grid congestion.

Energy project development in Greece is governed by separate legislative acts, despite recent attempts to codify the framework. In particular, Law 4685/2020 modernised environmental legislation and streamlined the first phase of renewable energy sources (RES) project licensing, while Law 4951/2022 streamlined the second phase and introduced a new framework for energy communities, storage projects and citizen participation. Law 3468/2006, the initial framework for RES licensing, despite being partially abolished by Laws 4685/2020 and 4951/2022, remains in force with respect to provisions on self-producers and the regulation of guarantees of origin. Notable legislation also includes Law 4414/2016, which sets out the operating support schemes for RES and CHP projects and Law 4643/2019, which facilitated the commencement of operation of the Hellenic Energy Exchange S.A. (HEnEx) and promoted energy market liberalisation.

Greece’s current regulatory structure on electricity transmission and distribution was essentially built upon Directive 2009/72/EC, part of the EU Third Energy Package, which introduced ownership and operational unbundling requirements in the electricity sector for all member states (the “Electricity Unbundling Directive”). This Directive was incorporated into Greek legislation through Law 4001/2011 (the “Energy Law”). The Energy Law promoted the Independent Transmission Operator model, ensuring the provision of transmission in the most economically optimal way by granting the asset owner full responsibility for managing, operating and developing the transmission network. According to the Energy Law, network operators must be legally, operationally and logistically independent from energy production and supply companies. The National Electricity Transmission System is managed by the Independent Power Transmission System Operator S.A. (IPTO), while electricity is distributed to final consumers through the network managed by the Hellenic Electricity Distribution Network Operator S.A. (HEDNO). The framework is supplemented by secondary acts like the Electricity Transmission System Management Code and the Hellenic Electricity Distribution Network Management Code, which regulate the operation, management, user connections and quality of the transmission and distribution networks.

Greece’s electricity supply sector has been liberalised, allowing many private suppliers to enter the market along with PPC. It is mainly regulated by the Electricity Supplier’s Code which focuses on ensuring consumer protection. 

Lastly, a central role for regulating all above segments of the energy market in Greece is reserved for the Regulatory Authority for Waste, Energy and Water (RAWEW). Its regulations and administrative decisions cover a wide range of issues, from generation, storage and supply licences to tariff regulation, state-aid auctions and market monitoring. RAWEW is also the certifying authority and supervisor for distribution and transmission operators in Greece. RAWEW is entrusted with the hard task of ensuring compliance with the regulatory framework and is empowered to impose sanctions on all players throughout the energy sector.

The power industry in Greece involves both state-owned and investor-owned entities responsible for generating, transmitting, distributing and selling electricity.

PPC is the main state-controlled electricity producer, and, before the enactment of the Energy Law, it also held the monopoly in transmission and distribution activities. The issuance of the Energy Law meant the separation of PPC’s transmission and distribution activities and the creation of two separate entities, IPTO and HEDNO. HEDNO operates, maintains and develops the Hellenic Electricity Distribution Network nationwide. IPTO, on the other hand, manages and operates the high-voltage transmission network, ensuring reliable electricity transmission. 

It should be noted that HEDNO and IPTO are not fully state-owned. IPTO’s shareholding structure is as follows: 51% of the company’s shares is held by ADMIE Holding S.A. (state-controlled), 24% is held by the State Grid Corporation of China, and 25% is held by DES ADMIE S.A. (state-owned). HEDNO is owned by PPC (state-controlled) at 51% and at 49% by Macquarie Asset Management Group. Notably, both IPTO and HEDNO are strictly bound by the current EU and national framework to act in a transparent manner and offer equal treatment to all market participants and their compliance to unbundling provisions is certified by RAWEW. 

Lastly, private entities have developed a significant and active role in the development of Greece’s power industry, owning a large part of the country’s power generation facilities with some of them also holding affiliates engaged in the electricity supply sector. There is obviously a trend towards revisiting the traditional state-owned enterprises system towards individual (national or international) enterprises, however the field is currently under development and this, along with market volatility, is certainly expected to reshape the market in the years to come.

In general, there are no specific benefits reserved for foreign investments in the energy sector in Greece. As a signatory of the Energy Charter Treaty (ECT), Greece guarantees non-discriminatory treatment to investors, offers compensation for expropriation and other losses, and ensures the free movement of capital. However, the EU has decided to exit the ECT, with withdrawal taking effect in one year’s time. In this context, when eventually ratified, an inter se agreement among EU member states aims to invalidate the sunset clause for intra-EU investments, meaning that such protections will no longer apply to intra-EU investors using the ECT. Nevertheless, these protections will still be in place for investors from non-EU countries, as Greece has also signed bilateral investment treaties (BITs) with several countries.

Moreover, foreign investments in certain special and innovative electricity projects may fulfil the eligibility criteria to be designated as “strategic investments”. Such characterisation comes with certain benefits such as the potential to stabilise tax rates for up to 12 years or obtain tax exemptions, expedition of the licensing process and provision of financial aid. 

While there are no specific restrictions on foreign direct investments for energy projects in Greece, third-country investors (ie, investors from non-EU and non-European Free Trade Area countries) wishing to engage in energy transmission services must satisfy certain conditions. In such cases, RAWEW must issue a decision on whether the acquisition could jeopardise public safety or the country’s energy supply and may deny the certification of the transmission operator. RAWEW must also obtain a relevant opinion from the European Commission and notify it of its final decision on the certification. 

One should also note that there are special restrictions on all foreign direct investments that involve assets in borderland areas of Greece. These restrictions effectively prohibit the purchase of land or other in rem rights by third-country residents in such areas without a special permit from the Ministry of National Defence. Such permission is granted after a national security check. The above restrictions could be applicable to acquisitions of energy generation projects located in borderland areas. 

The sale and purchase of assets in the electricity industry are not subject to specific restrictions, but there are a few key considerations to make when acquiring or selling a power industry asset in Greece. 

In particular, compliance with Law 4601/2019 shall be reassured. This Law governs corporate transformations in Greece. The Law does not impose specific restrictions on transactions in the power industry but focuses on modernising and simplifying the legal framework for mergers, demergers, conversions and other corporate restructuring processes. Additionally, it necessitates compliance with other existing tax regulations.

The acquisition of energy-related projects requires compliance with certain permit-related obligations. More specifically, a potential acquisition would need to be notified to the authorities that issued the project’s licences. Sometimes, such notification might require an update or amendment to the respective licence, which is, however, a simple process in most cases. An exception applies for special projects where RAWEW performs an audit on the owner’s financial status. 

Lastly, in some cases, the Law does not allow for energy projects to be transferred, for example if such projects have received state aid. Depending on the case, such restriction might no longer be applicable when such assets reach a certain maturity stage (eg, RES projects that have received operational state aid through an auction, which may be transferred after their electrification). 

The Ministry of Environment and Energy is essentially formulating the scenery in the energy sector in Greece by exercising its legislative initiative and its powers to issue secondary acts. Additionally, a large part of Greece’s energy sector framework, mainly with respect to network operation, fair competition, market participation and state aid, was shaped by the EU legislator. 

Nevertheless, RAWEW is the central authority that oversees and administers the electricity supply and the transmission and development of distribution facilities to ensure system reliability and adequacy of supply. Established as an independent administrative authority, RAWEW is responsible for a wide range of functions and powers. These include ensuring the adequacy of electricity supply by monitoring supply and demand, consumer protection, project licensing and overseeing the planning and development of generation and storage facilities as well as achieving compatibility with national and EU energy goals. RAWEW also has audit and sanctioning powers and plays a significant role in assembling and reforming the regulatory framework in Greece’s energy sector. Notably, RAWEW certifies and supervises:

• IPTO, the entity responsible for the management and maintenance of Greece’s high-voltage transmission network, ensuring the stability and reliability of electricity transmission across the country; and
• HEDNO, the entity that oversees the distribution network operation and development.

It approves the IPTO’s annual Ten-Year Network Development Program (TYNDP) and issues regulations and guidelines for the electricity market’s smooth operation, ensuring transparency and adherence to regulatory requirements by energy companies. Furthermore, RAWEW approves the Electricity Transmission System Management Code, which sets out the rules for the operation and management of the Electricity Transmission System, ensuring the stability and reliability of the system, and the Hellenic Electricity Distribution Network Management Code, which regulates the operation and management of the distribution network, including provisions on the connection of users and the quality of the energy supplied. 

There is also a role for the EU Agency for the Cooperation of Energy Regulators (ACER), established by Regulation (EC) No 713/2009, which facilitates the co-operation of national regulatory authorities (NRAs) at EU level and co-ordinates the activities of electricity and gas transmission system operators (TSOs). 

Lastly, the European Network of Transmission System Operators for Electricity (ENTSO-E) develops and implements common operational rules and standards, collaborates on the development of transmission infrastructure, and publishes reports assessing system adequacy and forecasting demand and supply at EU level, while the EU DSO Entity aims at developing network codes and guidelines, strengthening the cooperation between TSOs and distribution system operators (DSOs) and sharing pertinent best practices.

The main recent changes in Greece’s regulatory framework could be summarised as follows. 

• Energy communities: Law 5037/2023 essentially abolished the previous concept of energy communities under Law 4513/2018 which allowed for their transformation into profit seeking companies and established two new types of energy communities, namely Renewable Energy Communities and Citizens’ Energy Communities, which both have non-profit orientations.
• Self-consumption scheme: Law 5037/2023 introduced significant changes to self-consumption provisions, aligning national legislation with Directive (EU) 2018/2001. It grants consumers the right to produce, consume, store and sell renewable energy without intermediaries. It also mandates that consumers installing renewable energy systems can receive compensation reflecting the market value and long-term benefits of the energy they inject. The Law abolished net-metering for most consumers, in view of replacing it with net-billing. 
• Curtailments: Law 5106/2024 expanded the possibility for the operator to proceed with technical curtailments (first introduced in 2022) in order to address disruptions in production-demand balance and network stability. The Law abolished the previously applicable 5% threshold for such curtailments but obliges operators to minimise their use and fairly allocate them between producers. 
• RES auctions: Law 5106/2024 introduced the possibility for projects to enter into tenders for feed in premia after 1 May 2024 to be subjected to curtailments and/or mandatory BESS unit installation. This change highlights the regulator’s turn towards BESS projects to address grid saturation issues.
• Super priority PPAs: Law 5095/2024 introduced measures to reduce energy costs and promoted the agricultural and energy-intensive industrial sectors by granting absolute priority for grid connection offers to RES energy projects that have a PPA with agricultural electricity connection holders or energy-intensive industrial consumers.
• Merchant price cap abolishment: in light of the energy crisis, from 1 July 2022 until the end of 2023, the Greek wholesale electricity market was capped at merchant price, affecting the producers’ revenues generated by the sale of electricity produced by certain sources, including RES. Nevertheless, the producers’ need to remove the restrictions on their strategy to submit bids in the day-ahead and intra-day markets led to the abolishment of the above-mentioned price cap from 1 January 2024. 

One of the main focuses for Greece’s energy sector is developing sufficient capacity for energy storage systems, including batteries and pumped hydro storage. According to the National Energy and Climate Plan (NECP), battery storage capacity is expected to reach 4 GW by 2030. In late 2022, a new framework was established to support battery energy storage stations (BESS) providing investment and operational support through three tenders totalling 1,000 MW. The first tender, announced in June 2023, awarded 411.79 MW, and the second tender, announced in November 2023, awarded 299.77 MW. The third tender is yet to be announced. Additionally, the Ministry of Environment and Energy plans to support 1,700 MW of standalone storage capacity over the next two years, with new tenders and projects integrated with battery storage.

Moreover, the Greek government is prioritising the development of offshore wind farms, aiming for the first projects to be operational by 2030. To facilitate this, a detailed regulatory framework is currently being established. The IPTO’s plan includes reserving 2 GW of electrical capacity for offshore wind parks in Thrace, Crete, the Cyclades, Attica, and the Dodecanese. Pilot projects totalling 600 MW have already started near Alexandroupolis. In 2027, Greece is exploring the potential to launch its first tender for these wind farms, with Eastern Crete as a primary location. 

Lastly, Greece is advancing its hydrogen strategy, aiming to integrate hydrogen as a key component of its future energy mix. This includes plans for formulating a framework for hydrogen production, storage and utilisation in various sectors, contributing to the decarbonisation goals and enhancing energy security.

Greece’s power industry has seen significant developments, particularly in the rapid expansion of renewable energy sources such as wind and solar power, driven mainly by the country’s favourable geographical conditions. At the same time, Greece is investing in interconnections with neighbouring countries, such as the EuroAsia Interconnector, which remains on EU’s list of projects of common interest, enhancing energy security. The effort to decarbonise is also crucial, with the gradual phase-out of lignite-fired power plants and the transition to natural gas and renewables set as a priority.

However, due to the high penetration of RES during recent years, the issue of grid saturation came to the surface. Addressing this saturation involves – apart from grid development – the promotion of energy storage projects, such as pumped hydro storage and battery systems, to balance supply and demand. 

Greece is also exploring the potential of offshore wind farms, geothermal energy and its water resources for further development of sustainable energy sources. Moreover, the adoption of smart grids and the modernisation of the regulatory framework are viewed as the next steps for enhancing the system’s stability and efficiency. 

Lastly, Greece is also exploring the possibility of modernising its framework for hydrogen. Despite challenges like economic constraints and regulatory hurdles, the energy industry in Greece is evolving dynamically, aligning with global trends toward sustainable development and energy transition.

The adoption of the EU Target Model, as well as the new energy regulatory framework put into force under Commission Regulation (EU) 2015/1222 regarding market coupling within the EU, introduced material changes to the Greek wholesale electricity market structure. The key aspect of the domestic wholesale electricity market restructuring was the abolishment of the “mandatory pool” model, based on which the day-ahead market (DAM) was structured. According to this “mandatory pool” system, the electricity transactions performed by the participants were exclusively related to the DAM. Physical bilateral transactions between the participants were not allowed, and the system marginal price (SMP) was the price at which the electricity market was cleared. More specifically, the SMP was determined through the combination of the price and quantity supply submitted by the electricity producers and the hourly electricity demand formed by the consumers daily. The model’s main drawback, which was its inability to achieve the coupling of the Greek day-ahead market with the EU electricity markets, necessitated the emergence of a new system close to the markets that already operated in other EU countries. Therefore, following the enactment of Laws 4425/2016 and 4512/2018 there are four individual markets at a wholesale level in place, namely: 

• the DAM where electricity products are being traded with the obligation of physical delivery within the subsequent 24 hours;
• the intra-day market (IDM), where electricity products are being traded with physical delivery within the same day in order to cover any failures to fulfil order deliveries already concluded through the DAM;
• the balancing market, where the imbalance between output and demand that cannot be met by intra-day transactions is corrected, in order for the system to maintain the uninterrupted supply of energy at the expected quality level; and
• the forward market where future contracts are being traded through financial settlement, while members participating in the DAM are given the possibility of optional physical settlement of their monthly contracts (participation in the forward market is optional). 

Law 4512/2018, as amended, expressly provides for the establishment of the Hellenic Energy Exchange, which operates the DAM, the IDM and the forward market, as Nominated Electricity Market Operator (NEMO) and provides trading services aiming at efficient price formation.

The core function of a power exchange is its price formulation mechanism. The price formulation follows the rules governing a liberalised market, where supply meets demand. In the context of a power exchange, bids constitute an offer by market participants to the exchange to sell a certain quantity of electricity in a certain price expressed in EUR/MWh. At the same time, demand by the participants to buy electricity co-forms ‒ along with the expressed supply ‒ the prices. In the DAM, a clearance process is being performed for every hour of the next day of the actual delivery. Namely, an equilibrium point is formed on an hourly basis. Such equilibrium points define the market clearing price (MCP) and the market clearing quantity. 

The Greek electricity market, as part of the effort to establish a single integrated EU market, is structured on the pillar of the free market, where cross-border energy exchanges are permissible. Greece has several major transmission interconnections that facilitate the flow of electricity across its borders. Within that context, the primary interconnections are the following. 

• Bulgaria: two interconnection lines which allow for significant electricity exchanges between the two countries. The transmission capacity at the borders between the countries has been increased to 1,400 MW from Greece to Bulgaria and 1,700 MW from Bulgaria to Greece.
• Turkey: interconnection line with transmission capacity of 600 MW (a new interconnection is expected to increase the capacity by 600 MW in both directions).
• Italy: Greece is connected to Italy via a submarine power cable known as the Italy-Greece HVDC Interconnector, which has a capacity of 500 MW. This line connects the Greek mainland to the Italian power grid. 
• North Macedonia: two interconnection lines with transmission capacity of 500-600 MW each. 
• Albania: two interconnection lines with total transmission capacity of approximately 1,000 MW. 

These interconnections are crucial for balancing supply and demand and integrating renewable energy sources. Greece’s participation in the ENTSO-E further facilitates cross-border electricity trading, promoting reliability.

Electricity supply mix in 2023 saw significant contributions from renewable energy sources, reflecting the country’s commitment to increasing its green energy capacity generated by RES. According to data supplied by the IPTO, the supply mix for 2023 was formed as follows.

• Wind, solar and hydropower: combined, these sources accounted for 57% of Greece’s electricity production. This marked a significant increase from previous years, driven by substantial investments in wind farms, solar panels and hydroelectric plants. The output from these renewable sources increased by 8.5% compared to 2022.

• Natural gas: natural gas remained a major component of the energy mix, exceeding 30%. Despite the global energy crisis and fluctuations in natural gas prices, it continued to play a crucial role in Greece’s electricity generation due to its reliability and capacity to provide a steady power supply.
• Lignite: although lignite has been phasing out, it still contributed to the energy mix by 10% approximately, especially as a measure to ensure energy security amidst fluctuating natural gas supplies. The country plans to completely phase out lignite-fired power plants by 2028.

Market concentration limits in the electricity supply sector are governed by a combination of national laws and EU regulations designed to promote competition and prevent the formation of monopolies. The principal laws governing market concentration limits could be summarised as follows.

• The Energy Law is the fundamental law that regulates the Greek electricity market, implementing the EU’s Third Energy Package. It aims to enhance competition, ensure fair access to the electricity network and protect consumer rights.
• Law 4389/2016 is also known as the “Greek Public Sector Reform Law,” which is primarily focused on broader economic and administrative reforms in Greece. However, it also contains provisions that impact the electricity market, specifically regarding market concentration and the operation of the energy sector. 

At the same time, Law 4389/2016, as amended, includes measures to ensure the unbundling of activities within PPC, Greece’s dominant electricity provider. These provisions aimed to separate production, transmission and distribution activities and enhance market transparency and competition. It set the framework for the privatisation of state-owned assets in the energy sector, encouraging private-sector participation, aimed to reduce the market share of PPC in the supply market to 50% or less until 2019. The above-mentioned Law reinforces the role of the RAWEW in monitoring and regulating the electricity market. It grants RAWEW additional powers to ensure compliance with competition laws and market rules. If an entity is found to exceed permissible market concentration or engage in anti-competitive behaviour the following apply.

• Fines and penalties: significant financial penalties can be imposed, which can be up to 10% of the entity’s annual turnover.
• Structural remedies: RAWEW may require divestiture or other structural changes to restore competitive market conditions.
• Regulatory actions: RAWEW can impose specific regulatory measures, such as capacity restrictions, to mitigate market dominance.

According to the provisions of Law 4001/2011, as amended, RAWEW is entrusted with the responsibility of energy market surveillance to detect anti-competitive behaviour. 

Within that context, RAWEW oversees the electricity and natural gas markets, ensuring compliance with market regulations, promoting competition and protecting consumers by monitoring market activities, conducting audits and investigating potential breaches of market rules. Upon detecting potential anti-competitive behaviour, RAWEW can launch formal investigations and impose sanctions. These investigations may involve data collection, interviews and co-operation with other national and international regulatory bodies. If a violation is confirmed, RAWEW can impose a range of sanctions, from fines and penalties to structural remedies such as the divestiture of assets or the imposition of operational changes.

The determination of anti-competitive behaviour entails substantial financial penalties, potentially reaching up to 10% of the offending entity’s annual turnover. Further to this, structural remedies, such as orders to divest certain assets or business units to reduce market dominance and restore competitive conditions are likely to be imposed.

Lastly, the Hellenic Competition Commission is entrusted with monitoring overall compliance with applicable general competition laws and is competent to launch pertinent investigations and make use of a plethora of sanctions statutorily available to the same.

The principal Greek laws, governing the construction and operation of generation facilities, include the following.

• Law 4685/2020 (as amended and in force) modernised environmental legislation and streamlined Phase A of RES project licensing, by regulating the first licensing step for generation projects, namely the producer’s certificate or the special project’s certificate (depending on the project). Phase A also includes the obtention of an Environmental Permit in accordance with Greek Law 4014/2011, in conjunction with Ministerial Decision 1958/2012 (as amended and in force) on the classification of activities into environmental categories and subcategories. 
• Law 4951/2022 (as amended and in force) streamlined Phase B of the licensing process, by setting the main rules and procedures for grid connection, the installation licence for project construction purposes and operation licence obtainment. It is important to note that the Law also provides a framework for the prioritisation of projects regarding the evaluation of grid connection applications (supplemented with relevant secondary acts) and the imposition of curtailments by the operators. Said Law also comprises the major regulatory framework for projects exempted from the obligation to receive a producer’s certificate, an installation licence or an operation licence. 
• Law 4495/2017 (as amended and in force) established a comprehensive framework for the management, regulation and legal validation of construction and buildings. The Law regulates the building permits that generation facilities must obtain in order to proceed with construction works. 

The main steps of the licensing process for generation facilities can be summarised as follows. 

• First, applicants must obtain a producer's certificate or special works certificate (depending on the nature of the project) from RAWEW. 
• Subsequently, the project must acquire an environmental permit. The process for the issuance of such permit is greatly dependent on a project’s environmental classification. In particular, the framework distinguishes between Category A projects (ie, projects with potentially significant environmental impact requiring environmental impact assessment studies) and Category B projects (ie, projects with potentially lesser environmental impact). Category A projects require the issuance of an environmental terms approval (ETA), which follows a stricter administrative process, including the drafting of an environmental impact assessment study and the issuance of opinions from various administrative authorities and stakeholders. In contrast, Category B projects are subject to standard environmental commitments (SEC), which is a simpler and standardised process. 
• Following the environmental permit, the producer may apply for a grid connection offer (GCO) from the competent operator. At this point, it is important to note that grid connection applications are examined in accordance with a detailed prioritisation framework. 
• Upon acceptance of the GCO, the producer proceeds with obtaining an installation licence. The installation licence requires that the producer has secured the land related to the installation polygon, allowing it to apply for the respective building permits necessary to begin the project’s construction. At the same time, the producer proceeds with executing a final grid connection agreement (GCA) with the competent operator. 
• The final licensing step before the generation facility’s operation is obtaining an operation licence.

One should note that the process above is the usual licensing process for generation facilities in Greece. There are deviations for special project categories or smaller scale projects.

In Greece, the installation, construction and operation of a generation facility require compliance with the environmental terms set out in the project’s environmental permit, adherence to technical and safety standards, as well as maintaining the validity of all necessary permits and licences from the relevant authorities. The generation facility owner must also have lawful use of the land plots where the project is located. 

Maintaining the permits might entail certain amendments or renewals during the project’s lifecycle. The renewal and the amendment process for each permit could be summarised as follows. 

• The producer’s certificate and the special projects certificate are valid for an initial period of 25 years. Law 4685/2020 and the RES Licensing Regulation allow for the renewal of the certificates every five years and for a maximum of 25 additional years under certain conditions. Amendments are generally allowed, albeit major amendments may only be requested at specific timeframes. 
• Environmental permits, either ETA or SEC, are valid for 15 years and require the submission of a renewal file at least two months before expiry, with the environmental authority reviewing the file within 15 working days. The complexity of the renewal process for the ETA depends on whether modifications to the project characteristics or compliance with new regulations necessitate changes in the ETA. A modification of the project might require an amendment to the ETA and the imposition of stricter environmental terms and the complexity of the process for such amendment depends on the scale and the expected impact of the modification. 
• GCA between the project developer and the network operator have an indefinite duration, thus there is no need for renewal, except if there are changes in the project that require an amendment of either the GCA or the initial grid connection offer.
• The installation licence is essentially replaced by the operation licence, but a modification of the project might require the issuance of a new installation licence. 
• An operation licence is valid for 20 years and can be renewed for an equal term upon application at least three months before expiry. However, the Law foresees that such application for renewal must be accompanied by a valid power purchase agreement (PPA). The terms of the operation licence are more or less standard and remain the same. 

Article 4 paragraph 7 of Law 4951/2022 explicitly characterises RES projects as beneficial to the public interest and specifically allows for project owners to utilise land expropriation to ensure their operation. This provision aims to simplify expropriation procedures for such projects by satisfying the first two requirements for land expropriation set out in the Greek Constitution, namely the definition of such projects as projects of public utility and the need for a specific legislative provision. 

The expropriation shall take place in accordance with Law 2882/2001 and its costs shall be borne by the project owner. The compensation to be paid to the landowners is determined through a court decision. However, the owners of generation facilities can only pursue expropriation after exhausting all other legal alternatives. In the specific case of photovoltaic stations, expropriation of land is restricted to no more than 2% of the total land plot that may be expropriated. The 2% limitation also applies to forests and forestry lands.

Decommissioning a generation facility involves various regulatory and procedural steps governed by national legislation and EU directives. Owners must obtain the necessary decommissioning permit from RAWEW and inform the authorities involved in their licensing process as to their decommissioning plans. Additionally, within the framework of environmental licensing, operators prepare an environmental impact assessment to ensure that decommissioning activities comply with environmental protection standards and complete restoration. In this context, an ETA or SEC is issued. The aim is to implement measures in accordance with safety standards for the safe dismantling of the facility.

The entity responsible for the operation, maintenance and development of the Greek Electricity Transmission System is IPTO, established in accordance with the Energy Law and in compliance with the Electricity Unbundling Directive. Exceptionally, the Non-Interconnected Islands electricity transmission system management falls under the competence of HEDNO and not IPTO. 

The terms and conditions of IPTO’s operation and the construction of transmission facilities are regulated by the Management Code for the Greek Electricity Transmission System, which is scrutinised and approved by RAWEW. Users, such as independent producers and eligible customers, connect to the system through specific installations extending from their premises to the existing grid. These projects, termed “system expansion projects” under the management code, require an implementation agreement between IPTO and the user to allocate responsibilities. Costs for these projects, including land expropriation, are solely the responsibility of the applicant. Once completed, ownership of equipment and associated civil works transfers to IPTO. The extension projects for the connection of producers and consumers may be implemented either by the respective producer or consumer, or by IPTO. In any case, IPTO shall be responsible for the control and the supervision of the construction and location of the extension works.

As far as projects connecting to the grid, the framework and, in particular, Law 4951/2022, as amended and in force, provide that such projects would have to obtain a GCO from either IPTO or HEDNO (depending on whether the voltage is high, medium or low). Grid connection lines always belong to the operator and not the owner of the connected station. Substations, however, may be owned by the RES station owner, who is nevertheless obliged to facilitate the connection of other RES station owners to the substation. 

The regulatory process for obtaining all necessary approvals to construct and operate a transmission line and associated facilities involves several critical steps and considerations. The Energy Law foresees that IPTO must annually submit the TYNDP to RAWEW. This plan ensures system adequacy and supply security, detailing major infrastructure projects, ongoing and new investments, with feasibility studies and timelines. It considers demand response, energy storage and other alternatives to system expansion. 

According to the Electricity Transmission Management Code, extension projects of the Distribution Network, as well as the substation development projects are implemented by IPTO, which undertakes the licensing of such projects, such as obtaining environmental permits and any building permits, pursuant to the Greek legislation (Laws 4014/2011 and 4495/2017, respectively). 

The environmental licensing process for transmission lines or other transmission network works depends on the environmental categorisation of such activities. Works expected to have a significant environmental impact are required to submit an environmental impact assessment. The assessment of the environmental impact depends on the scope and the characteristics of the requested project, the size of the works required and its impact on the environment. In the case of transmission lines, this would mostly depend on the length of the lines, the nature of the area where the lines are to be installed and whether a substation would be required. It is noted that new substations for specific projects, as well as the transmission lines to be installed for the connection of such projects to the grid, are included in the environmental assessment required for the issuance of the projects’ environmental permit. Lastly, IPTO’s TYNDP is also accompanied by a strategic environmental impact assessment, which needs to be approved by the Ministry of Environment and Energy.

The ETA for the installation of transmission lines usually requires that the works are executed with the minimal environmental impact possible. This includes measures to protect natural habitats, such as avoiding protected areas and using alternatives to minimise disturbances. Additionally, the works must adhere to regulations on pollution control, noise and waste management. The terms also emphasise the importance of maintaining biodiversity, with specific actions like mapping and safeguarding bird habitats, restoring vegetation and ensuring that construction activities do not harm local ecosystems. Continuous monitoring and compliance with environmental standards are mandated throughout the project’s lifecycle. 

The process for amendments to the issued environmental permit depends on whether the changes substantially impact the environment. For non-substantial changes, which typically include improvements like cleaner fuels or better waste management, the authority will review and decide within ten working days. If the changes are deemed substantial, the procedure is lengthier and more rigorous, requiring the submission of a new Environmental Impact Assessment Study. For minor adjustments that do not significantly alter the project, a notification would most likely be sufficient, albeit the authority has 15 working days to assess the matter and request a full modification process if deemed necessary.

Transmission and distribution operators in Greece usually secure the rights to install transmission lines, through an easement, which is either contractually agreed or imposed against landowners via expropriation. In particular, the applicable law provides that infrastructure like transmission networks, substations and roads are considered projects of public utility. Thus, if securing an easement on private property is necessary for these projects to be implemented, then such property may be expropriated in accordance with the usual expropriation process (Law 2882/2001). The entity benefiting from the expropriation bears the costs and must compensate the landowner for any damages or loss of use resulting from the construction activities.

For public forestry areas, the applicable law grants transmission and distribution operators the right to relocate or modify existing electricity networks without needing approval, requiring only notification to the forestry authority. Forestry authority approval is required for new installations, except for underground networks in forests, which only require a notification to the authorities. Operators must, nevertheless, submit and implement vegetation restoration plans for disturbed areas. 

Private forest land may be accessed by operators without the forest owner’s consent, though they must compensate the latter for any damages. Additionally, the law provides for compulsory expropriation in the case of installation of electricity transmission and distribution networks in such areas without the need to obtain a forest intervention permit.

The provision of transmission services in Greece is a natural monopoly reserved only for IPTO due to the very high infrastructure costs. Therefore, the Energy Law foresees only a single transmission operator. The overall organisation of the management of energy transmission activities, along with the Electricity Unbundling Directive and the Energy Law, also reflected in IPTO’s Articles of Association ensure its substantial independence.

The framework foresees that IPTO shall receive the Greek Electricity Transmission System’s required revenue in return for its services. The required revenue is determined via a RAWEW decision for each calendar year. The required revenue is recovered through system usage charges, which are determined based on the general principles provided for in the Electricity Transmission System Management Code and the methodology included in the system usage charges manual.

Pursuant to the Energy Law, RAWEW decides, after consulting the competent electricity network operators and applying transparent criteria, the methodology for the calculation of tariffs for non-competitive activities, in such a way that such tariffs are non-discriminatory and reflect the cost of the services provided. The methodologies and the tariffs for non-competitive activities are published on RAWEW’s and the competent operator’s website. RAWEW must take into account the need to establish short and long-term incentives for transmission system operators and distribution network operators in order to improve the efficiency of transmission systems and distribution networks, including through the use of flexibility services, to promote the development of the energy market, security of supply, improvement of the quality of services, the use of electricity generated from RES, with corresponding investments in the development of transmission systems and distribution networks.

Under the Electricity Unbundling Directive as incorporated in the Energy Law, transmission system operators (TSOs) must provide fair and equal access to the network for all market participants, preventing any preferential treatment. TSOs must operate independently from generation and supply activities to avoid conflicts of interest, ensuring transparency and efficiency in network operations. The TSO may deny access to the system only due to the exhaustion of the system’s capacity and such decision must be specifically justified based on objective, technical and economic criteria. In the event of a denial of access, the TSO is required to provide information regarding the necessary measures to reinforce the system, in exchange for a fee that reflects the cost of providing these reinforcements.

Under the Electricity Transmission System Management Code, IPTO may enter into a contract with any natural or legal person registered in IPTO’s register who accepts all the provisions of the said Code (Article 1.4 of the Code). 

The operator transaction agreement (in Greek “Σύμβαση Συναλλαγών Διαχειριστή”) is deemed to have been concluded by the parties upon registration in the operator register (in Greek “Μητρώο Διαχειριστή”) and is not subject to any other formality. Any amendment to this Code shall automatically govern the concluded transaction agreement in force, without any action.

The entity responsible for the for the operation, maintenance and development of the Hellenic Electricity Distribution Network is HEDNO, which was established in accordance with the Energy Law and in compliance with the Electricity Unbundling Directive. However, there are also provisions allowing for the existence of other DSOs, albeit only in closed networks. Exceptionally, HEDNO is also responsible for the management of the electricity transmission systems for the Non-Interconnected Islands. 

The terms and conditions of HEDNO’s operation and the construction of distribution facilities is regulated by the Management Code for the Hellenic Electricity Distribution Network, which is scrutinised and approved by RAWEW.

The framework and, in particular, Law 4951/2022, as amended and in force, provide that all energy generation projects would have to execute a GCA with either IPTO or HEDNO (depending on whether the voltage is high, medium or low). At the request of an interested producer and, only in cases explicitly permitted under the applicable framework, the expansion projects of the medium voltage grid may be designed and constructed by them. Network development projects to connect power generation stations are planned, designed and implemented by HEDNO. 

HEDNO holds the licence for the management of the Hellenic Electricity Distribution Network and the licence for the ownership of the Hellenic Electricity Distribution Network covering all further extensions of the latter. With respect to such extensions, HEDNO must obtain the respective permits, such as environmental permits and building permits, pursuant to the Greek legislation (Laws 4014/2011 and 4495/2017, respectively). The environmental licensing process for distribution lines would mostly depend on the length of the lines, the nature of the area where the lines are to be installed and whether a substation would be required. It is noted that new substations for specific projects, as well as the distribution lines to be installed for the connection of such projects to the grid, are included in the environmental assessment required for the issuance of the projects’ environmental permit. 

The ETA for the distribution lines project usually requires that the project is executed with the minimal environmental impact possible. This includes measures to protect natural habitats, such as avoiding protected areas and using alternatives to minimise disturbances. Additionally, the project must adhere to regulations on pollution control, noise and waste management. The terms also emphasise the importance of maintaining biodiversity, with specific actions like mapping and safeguarding bird habitats, restoring vegetation and ensuring that construction activities do not harm local ecosystems. Continuous monitoring and compliance with environmental standards are mandated throughout the project’s lifecycle. 

The process for amendments in the issued environmental permit depends on whether the changes substantially impact the environment. For non-substantial changes, which typically include improvements like cleaner fuels or better waste management, the authority will review and decide within ten working days. If the changes are deemed substantial, a new Environmental Impact Study is required, following rigorous procedures. For minor adjustments that do not significantly alter the project, a notification is sufficient, but the authority has 15 working days to request a full modification process if necessary.

Transmission and distribution operators in Greece usually secure the rights to install distribution lines, through an easement, which is either contractually agreed or imposed against landowners via expropriation. In particular, the law provides that infrastructure like distribution networks, substations and roads are considered projects of public utility. Thus, if securing an easement on private property is necessary for these projects to be implemented, then such property may be expropriated in accordance with the usual expropriation process (Law 2882/2001). The entity benefiting from the expropriation bears the costs and must compensate the landowner for any damages or loss of use resulting from the construction activities.

With regard to public forestry areas, the applicable law grants transmission and distribution operators the right to relocate or modify existing electricity networks without needing approval, requiring only notification to the forestry authority. Forestry authority approval is required for new installations, except for underground networks in forests, which only require a notification to the authorities. Operators must, nevertheless, submit and implement vegetation restoration plans for disturbed areas. 

Private forest land may be accessed by operators without the forest owner’s consent, though they must compensate the latter for any damages. Additionally, the applicable law provides for compulsory expropriation in the case of installation of electricity transmission and distribution networks in such areas without the need to obtain a forest intervention permit.

The National Distribution Network Management activity is a natural monopoly supervised and regulated by RAWEW. Nevertheless, the Energy Law foresees the existence of other closed distribution system operators (CDSOs) operating independently. These CDSOs manage local networks, often within specific industrial or commercial zones, providing electricity distribution services similar to those offered by HEDNO but on a much smaller scale. 

The Energy Law mandates that all DSOs must be independent in terms of legal form, organisation, and decision-making from other activities not related to electricity distribution. This includes specific criteria such as ensuring that management does not participate in the daily operations of production, transmission or supply, and that the DSO has the necessary resources and decision-making power. A compliance programme must be established and monitored by a compliance officer, who ensures adherence to confidentiality and impartiality standards. RAWEW supervises all DSOs and is empowered to impose penalties for non-compliance.

The framework foresees that HEDNO shall receive the Greek Electricity Distribution System’s connection charges. The connection charges are determined via a RAWEW decision on the basis of some basic principles, such as:

• The power of the connection requested by the consumer and the distance of its property from the existing operational facilities of the Grid,
• For the determination of the Charges, account shall be taken of Network Facilities in operation. Network installations that are planned to be built or are under construction, or have already been built but are not operational, or substation sites that are not yet operational, shall not be considered, even if these installations are for the supply of electricity to another User who has already paid the Connection Charges.
• Consumer charges for connection to the Network may differ depending on the type of Network facilities installed in a certain area of the country. For this reason the methodology includes parameters depending on the area of the consumer’s installations. 

In 2021 the network usage charges manual provided for in Hellenic Electricity Distribution Network Management Code was established.

The producers’ Connection Charges for the composition of the connection of their installations to the Network shall be determined on the basis of the Network works required for the connection.