GREECE Law and Practice Contributed by: Evangelos (Evans) Courakis, Evangelos Mylonas Tsoumas, Sofia Andreanoudi, Vassiliki Xynou and Ioanna Marouso Argyriou, Koutalidis Law Firm
1. Structure and Ownership of the Power Industry 1.1 Law Governing the Structure and Ownership of the Power Industry The energy industry in Greece comprises five major segments: generation, storage, transmis- sion, 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 pow- er plants, as well as many private companies, which have recently entered the market, mainly, in the renewable energy generation sector. Ener- gy 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 gov- erned by separate legislative acts, despite recent attempts to codify the framework. In particular, Law 4685/2020 modernised envi- ronmental legislation and streamlined the first phase of renewable energy sources (RES) pro- ject licensing, while Law 4951/2022 streamlined the second phase and introduced a new frame- work 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 regula- tion 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. In 2025, the legal framework was further enhanced. Law 5151/2024 exempts system operators (HEDNO and IPTO) from compensa- tion obligations to RES producers in cases of production curtailment, a move that has sparked controversy among RES associations. Moreo- ver, new incentives and a simplified licensing regime were introduced in early 2025 for the development of storage systems – particularly co-located battery storage at existing solar parks – targeting an additional 2 GW of storage capacity by 2030. Furthermore, new incentives for battery energy storage stations include state aid schemes to support the development of new battery energy storage stations, as well as prior- itisation in the granting of a grid connection offer by the transmission network operator. The new framework is primarily aimed at addressing grid congestion issues. Greece’s current regulatory structure on electric- ity transmission and distribution was essentially built upon Directive 2009/72/EC, part of the EU Third Energy Package, which introduced owner- ship 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 Ener- gy Law promoted the Independent Transmis- sion Operator model, ensuring the provision of transmission in the most economically optimal way by granting the asset owner full responsibil- ity for managing, operating and developing the transmission network. According to the Energy Law, network operators must be legally, opera- tionally and logistically independent from energy production and supply companies. The National
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