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

market with the EU electricity markets, neces- sitated the emergence of a new system close to the markets that already operated in other EU countries. Therefore, following the enactment of Laws 4425/2016 and 4512/2018 there are four individual markets at a wholesale level in place, namely: • the DAM where electricity products are being traded with the obligation of physical delivery within the subsequent 24 hours; • the intra-day market (IDM), where electric- ity products are being traded with physical delivery within the same day in order to cover any failures to fulfil order deliveries already concluded through the DAM; • the balancing market, where the imbalance between output and demand that cannot be met by intra-day transactions is corrected, in order for the system to maintain the uninter - rupted supply of energy at the expected qual- ity level; and • the forward market where future contracts are being traded through financial settlement, while members participating in the DAM are given the possibility of optional physical set- tlement of their monthly contracts (participa- tion in the forward market is optional). Law 4512/2018, as amended, expressly pro- vides for the establishment of the Hellenic Ener- gy Exchange, which operates the DAM, the IDM and the forward market, as Nominated Electricity Market Operator (NEMO) and provides trading services aiming at efficient price formation. The core function of a power exchange is its price formulation mechanism. The price formu- lation follows the rules governing a liberalised market, where supply meets demand. In the context of a power exchange, bids constitute an offer by market participants to the exchange

to sell a certain quantity of electricity in a certain price expressed in EUR/MWh. At the same time, demand by the participants to buy electricity co- forms – along with the expressed supply – the prices. In the DAM, a clearance process is being performed for every hour of the next day of the actual delivery. Namely, an equilibrium point is formed on an hourly basis. Such equilibrium points define the market clearing price (MCP) and the market clearing quantity. It should be noted that, in Greece, there are no specific provisions regulating the supply of electricity to energy intensive consumers such as heavy industries, data centres, etc. Never- theless, the matter was indirectly addressed by virtue of Article 30 of Law 5095/2024, which set out a priority framework for granting a grid con- nection offers for projects that have executed bilateral PPAs with certain energy-intensive con- sumers. 2.2 Electricity Imports and Exports The Greek electricity market, as part of the effort to establish a single integrated EU market, is structured on the pillar of the free market, where cross-border energy exchanges are permissible. Greece has several major transmission inter- connections that facilitate the flow of electricity across its borders. Within that context, the pri- mary interconnections are the following. • Bulgaria: two interconnection lines which allow for significant electricity exchanges between the two countries. The transmission capacity at the borders between the countries has been increased to 1,400 GW from Greece to Bulgaria and 1,700 GW from Bulgaria to Greece. • Turkey: interconnection line with transmission capacity of 600 MW (a new interconnection is

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