GREECE Law and Practice Contributed by: Anna Manda and Venetia Lazaratou, Karatzas & Partners
when considered necessary, contact third parties as part of its review process by sending written question - naires to third parties, such as competitors, customers and consumer organisations. These questionnaires should be replied to within at least five calendar days and there are fines in case of non-compliance and for providing inaccurate or misleading information (see also 3.6 Penalties/Consequences of Incomplete or Inaccurate Notification ). In the same manner, the HCC also typically sends written questionnaires to third parties regarding the sufficiency of the proposed commitments and their ability to eliminate the compe - tition concerns raised by the concentration. 7.3 Confidentiality HCC decisions are published both on the HCC web - site and the Greek Government Gazette. The HCC publishes the non-confidential versions of its deci - sions, meaning that the parties’ commercially sensi - tive information, including business secrets, are pro - tected from disclosure. 7.4 Co-Operation With Other Jurisdictions As a member of the European Competition Network, the HCC co-operates closely both with the EC and the national competition authorities in other EU member states regarding the enforcement of EU competition law. The HCC also participates in the International Competition Network. Over the past year, the HCC further enhanced its co-operation with other national competition authorities inside or outside the EU, by signing several memoranda of co-operation with the national competition authorities of North Macedonia, Cyprus, Albania, Italy, Turkey, Serbia, Austria, Hungar - ia, Morocco, South Africa, Israel, Egypt and Armenia. In order to share information with other jurisdictions, the HCC should seek relevant permission. 8. Appeals and Judicial Review 8.1 Access to Appeal and Judicial Review HCC decisions may be appealed before the Admin - istrative Court of Appeal of Athens. Neither the time - frame for filing the appeal nor its filing may suspend the enforcement of the HCC decision.
The judgment of the Administrative Court of Appeal of Athens may in turn be appealed before the Council of State (ie, the Supreme Administrative Court of Greece, which examines points of law and procedure only). 8.2 Typical Timeline for Appeals The timeline for filing an appeal against an HCC deci - sion is 60 calendar days from its publication or, in the absence thereof, of its notification to the parties. To the best of the authors’ knowledge, there are not any examples of successful appeals against HCC deci - sions to date. 8.3 Ability of Third Parties to Appeal Clearance Decisions Any third party that establishes a direct, personal and present legitimate interest regarding the clearance decision may appeal against the HCC decision before the Administrative Court of Appeal of Athens. The relevant timeframe for the appeal (60 calendar days) starts to run from the publication of the HCC decision in the Greek Government Gazette. To the best of the authors’ knowledge, there has not been any success - ful appeal against an HCC clearance decision. 9. Foreign Direct Investment/Subsidies Review 9.1 Legislation and Filing Requirements Greece introduced a foreign direct investment (FDI) screening regime in 2025, which comprises of Law 5202/2025 (the “Greek FDI Law”) and the Joint Min - isterial Decision No 64260/2025 (JMD), which clarifies the notification procedure and requirements. The Greek FDI Law came into force on 23 May 2025, but the mandatory notification process was initiated on 11 November 2025, when the JMD was published. FDIs are subject to a mandatory filing in Greece, pro - vided that the following conditions are cumulatively met: • there is a “foreign investor”: the Greek FDI regime classifies foreign investors as (i) non-EU (third- country) investors, (ii) EU investors ultimately controlled (directly or indirectly) by non-EU entities,
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