GREECE Trends and Developments Contributed by: Claire Pavlou, Katerina Tzamalouka and Angeliki Papadaki, Kyriakides Georgopoulos Law Firm
Cybersecurity In the cybersecurity domain, Law 5160/2024 trans - posed the NIS2 Directive into Greek law, significantly expanding the scope of entities subject to cybersecu - rity obligations and introducing more stringent incident reporting, risk management, and governance require - ments. Financial sector entities face the additional layer of the Digital Operational Resilience Act (DORA), which imposes prescriptive requirements in relation to Information and Communication Technology (ICT) risk management, third-party provider oversight, and operational resilience testing. For many companies, the combined effect of NIS2 and DORA represents a substantial increase in the technical and organisation - al resources required for cybersecurity compliance. Legal advisers should be prepared to support clients in mapping their obligations, reviewing contracts with critical ICT third-party providers, and adapting internal governance frameworks accordingly. Digital regulation In the domain of digital regulation, Regulation (EU) 2024/1689 – the Artificial Intelligence Act – entered into force on 1 August 2024 and is being implement - ed on a phased basis, with prohibitions on certain AI practices applying from February 2025 and obliga - tions for high-risk AI systems taking effect progres - sively through 2026 and 2027. The AI Act establishes a risk-based classification framework for AI systems deployed or made available in the EU, imposing grad - uated compliance obligations ranging from transpar - ency requirements for limited-risk systems to compre - hensive conformity assessments, risk management, and human oversight obligations for high-risk systems. Companies operating in Greece that develop, deploy, or distribute AI systems should undertake a thorough classification exercise to determine whether their sys - tems fall within the scope of the Regulation and, if so, which tier of obligations applies. Early engagement with the compliance requirements is strongly advis - able, given the complexity of the conformity assess - ment procedures and the significant penalties – up to EUR35 million or 7% of global annual turnover – for non-compliance. Taxation Tax law has also evolved considerably. Greece adopt - ed the OECD’s Pillar Two global minimum tax rules
tions across the regulatory and corporate landscape. In furtherance of this objective, the Athens Stock Exchange (now Euronext Athens) has developed a dedicated ESG Reporting Guide, which, while princi - pally directed at Greek-listed companies, serves as a practical reference tool for non-listed entities seeking to adopt or enhance their own ESG reporting prac - tices on a voluntary basis. In addition, Greece is required to transpose Directive (EU) 2024/1760 – the Corporate Sustainability Due Diligence Directive (CSDDD) – into national law. The transposition deadline has been extended to 26 July 2028 by virtue of Directive (EU) 2026/470, affording Greek legislators and in-scope companies additional time to prepare for a regime that will require covered undertakings to identify and address adverse human rights and environmental impacts arising from their own operations, those of their subsidiaries, and those occurring across their chain of activities. The Directive is intended to promote a sustainable and responsible corporate culture, and its eventual implementation will impose significant due diligence, reporting, and reme - diation obligations on companies meeting the appli - cable size and activity thresholds. Businesses that anticipate falling within scope would be well advised to begin mapping their value chains and assessing their existing due diligence processes in advance of formal transposition, in order to mitigate the compli - ance burden when the obligations take effect. In a related development reinforcing Greece’s com - mitment to the green transition, the European Com - mission granted approval in February 2026 to a Greek state aid scheme valued at EUR400 million, designed to incentivise investment in clean technology manu - facturing in furtherance of the objectives underpinning the Clean Industrial Deal and the broader transition to a net-zero economy. The scheme was authorised pursuant to the Clean Industrial Deal State Aid Frame - work (CISAF) and will deliver support to eligible under - takings through a combination of direct grants and tax incentives. The programme is open to companies operating in Greece and will remain in effect until 31 December 2030, providing a sustained and structured incentive framework for businesses seeking to estab - lish or expand clean technology manufacturing opera - tions in the country.
433 CHAMBERS.COM
Powered by FlippingBook