GREECE Law and Practice Contributed by: Anna Manda and Venetia Lazaratou, Karatzas & Partners
1. Legislation and Enforcing Authorities 1.1 Merger Control Legislation The relevant Greek merger control provisions are enshrined in Law 3959/2011 (the “Greek Competition Act”), as currently in force. In addition to these provi - sions, the Hellenic Competition Commission (HCC) has issued Decision No 780/2022, which clarifies the requirements of the long and short notification forms (the “HCC Guidelines”), as well as Decision 779/2022, which determines the content of the remedies form. In 2024, the HCC amended its procedural and opera - tional regulation. In interpreting and applying the Greek merger control legislation, the HCC takes also into account all the relevant EU legislation, notices and guidelines, as well as the EU case law. 1.2 Legislation Relating to Particular Sectors The Greek Competition Act applies in principle to all transactions (including foreign-to-foreign transac - tions) and to all sectors, and the HCC is the com - petent authority to implement the Greek competition rules, apart from the transactions relating to electronic communications, and postal services, for the review of which the Hellenic Telecommunications and Post Commission (EETT) is the competent authority. Mass Media Sector Concentrations relating to informative media (eg, tele - vision, radio, papers and magazines) are governed by both the Greek Competition Act and Law 3592/2007, as amended by Law 5212/2025. On the other hand, as regards concentrations relating to entertainment (ie, non-informative) media, only the Greek Competi - tion Act applies. With respect to FDI filing requirements see 9.1 Legis- The HCC is the competent authority for the enforce - ment of the relevant legislation applicable to merger control, as well as for the review of the notified con - centrations. The HCC is an independent authority with administrative and economic autonomy, which is supervised by the Minister of Development. lation and Filing Requirements . 1.3 Enforcement Authorities
For the review of mergers involving undertakings active in the markets of electronic communications and postal services, the EETT is the relevant compe - tent authority. Decisions issued by the HCC and EETT are subject to judicial review by the Greek administrative courts.
2. Jurisdiction 2.1 Notification
In case the respective thresholds described in 2.5 Jurisdictional Thresholds are met, a notification to the HCC, prior to the implementation of the transac - tion is compulsory (see also response to 2.14 Excep- tions to Suspensive Effect on derogations from the suspensive effect of the implementation of a notifiable concentration). There is no exception as to the man - datory nature of the filing requirement. The notification shall be submitted after the signing of the relevant binding agreement, the acquisition of controlling inter - est, or the announcement of a public bid that confers control on a lasting basis. Following the latest amend - ment to the Greek Competition Act, the 30-calendar- day deadline for submitting a notification to the HCC after the signing of the relevant binding agreement, the acquisition of controlling interest, or the announce - ment of a public bid, has been abolished. 2.2 Failure to Notify The HCC can impose administrative fines of at least EUR30,000 and up to 10% of the aggregate national turnover of the undertakings responsible for the filing, for failure to notify. The Greek Competition Act explic - itly states that the fine imposed must be calculated on the basis of the economic power of the undertak - ings involved, the number of the affected markets, the competitive conditions therein and the potential effect of the contemplated concentration on competition. The executives of the undertakings concerned are personally and jointly liable for the payment of all fines imposed against the undertakings by the HCC. In addition, the HCC may also impose administrative fines on the executives themselves for failure to com - ply with the merger control rules, which range from EUR200,000 to EUR2 million.
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