Power Generation, Transmission and Distribution 2025

GREECE Law and Practice Contributed by: Evangelos (Evans) Courakis, Evangelos Mylonas Tsoumas, Sofia Andreanoudi, Vassiliki Xynou and Ioanna Marouso Argyriou, Koutalidis Law Firm

Electricity Transmission System is managed by the Independent Power Transmission System Operator S.A. (IPTO), while electricity is distrib- uted 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 Elec- tricity Transmission System Management Code and the Hellenic Electricity Distribution Network Management Code, which regulate the opera- tion, management, user connections and quality of the transmission and distribution networks. Greece’s electricity supply sector has been liber- alised, 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 seg- ments of the energy market in Greece is reserved for the Regulatory Authority for Waste, Energy and Water (RAWEW). Its regulations and admin- istrative 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 author- ity and supervisor for distribution and transmis- sion 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. 1.2 Principal State-Owned or Investor- Owned Entities The power industry in Greece involves both state-owned and investor-owned entities responsible for generating, transmitting, distrib- uting and selling electricity.

PPC is the main state-controlled electricity pro- ducer, 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 devel- ops the Hellenic Electricity Distribution Network nationwide. IPTO, on the other hand, manages and operates the high-voltage transmission net- work, 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 sig- nificant 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.

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