GREECE Trends and Developments Contributed by: Evangelos (Evans) Courakis, Eleni Svoronou, Dimitra Rossopoulou, Maria Konstantina (Mariadina) Lili Kokkori and Evangelos Konitsas, Koutalidis Law Firm
Hellenic Energy Exchange (HEnEx). Within six months of operation, the platform has attracted 12 active participants who have begun submit- ting buy and sell offers. Although the platform currently functions as a matching tool (connect- ing supply and demand), early market signals show strong engagement and a push for deeper integration into Greece’s energy trading ecosys- tem. The platform accommodates various contract types, including pay-as-produced and base- load, with optional GoOs and tenors up to 15 years. It supports both physical and financial settlement, with fixed or indexed pricing, while maintaining offer anonymity until mutual interest is confirmed. Furthermore, legislative changes introduced in 2024 under Law 5095/2024 grant priority access to the grid for RES projects that conclude PPAs with industrial and agricultural offtakers, rein- forcing the role of PPAs in both commercial strategy and grid optimisation. Tolling agreements A notable trend in 2024–2025 has been the expansion of tolling agreements, particularly in the context of energy storage. These agree- ments allow plant owners or capacity holders to grant third parties the right to operate stor- age systems – such as standalone BESS – in exchange for a fixed or capacity-based fee. Tolling structures are emerging as a key enabler for financing BESS projects in the absence of subsidies, offering predictable revenue streams to the owner while transferring commercial risk (eg, arbitrage, balancing, ancillary services) to the offtaker. Several developers are already exploring tolling agreements to finance mer- chant BESS projects, particularly in areas with high curtailment risk. This model supports flex-
ible participation by energy traders or suppliers who seek access to storage infrastructure with- out direct ownership. Tolling is increasingly viewed as a cornerstone for the bankability of merchant storage pro- jects, with lenders focusing on factors such as the creditworthiness of the offtaker, the duration of the agreement relative to battery life, perfor- mance guarantees, and provisions for degrada- tion and augmentation. While the model is gain- ing traction, the regulatory framework around tolling agreements remains under development, but many stakeholders are still waiting for clearer rules on licensing obligations, taxation, eligibil- ity for flexibility services, and compliance with REMIT (the EU’s market transparency regulation) and capacity trading rules. As Greece scales up its storage capacity, tolling is expected to become a central pillar of its commercial model for grid-connected BESS. Hydrogen In a significant step towards shaping the future of renewable gases in Greece, the Ministry of Environment and Energy enacted a new law on 4 July 2025, establishing the country’s first comprehensive regulatory framework for the production and integration of biomethane and renewable or low-carbon hydrogen. The legis- lation outlines licensing procedures for produc- tion units, sets the groundwork for infrastructure development, and opens the door to potential operational support mechanisms aimed at attracting investment. The initiative aligns with the objectives of the updated NCEP and reflects Greece’s strategic focus on decarbonising its energy mix through the deployment of emerging clean technologies. The hydrogen sector, in particular, is entering a
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