Banking and Finance 2025

GREECE Law and Practice Contributed by: Ioannis Charalampopoulos, Daphne Kasimati, Afroditi Kazani and Ioanna Exarchou, Machas & Partners

the final decision in cases requiring an in-depth inves- tigation. The authorities have the power to approve, impose conditions, or prohibit the investment. Non- compliance with the notification requirement can lead to the reversal of the investment and administrative sanctions ranging from EUR5,000 to EUR100,000, or even up to twice the value of the investment in certain cases. For more information, see 8.4 Foreign Ownership . 8.6 Common Financing Sources and Typical Structures In the Greek market, projects are predominantly financed by local and international commercial banks, with bond loans being the most common structure. We have also witnessed projects involving the sig- nificant import of foreign equipment or technology, which rely on export credit agencies to provide guar- antees or lend directly. Multilateral institutions also play a crucial role by providing long-term financing, guarantees, and co-financing solutions for large-scale projects. Blended financings are also frequently seen in project finance deals. Multilaterals often combine their resources with governmental programmes (such as Greece’s Recovery and Resilience Facility) to de- risk investments and attract private investment. 8.7 Natural Resources Generally, there are no statutory limitations on the export of natural resources from Greece. Due to recent geopolitical tensions, the EU has imposed comprehensive export restrictions targeting specific countries. These sanctions include bans on the export of goods that might contribute to these countries’ mili- tary, technological, or industrial capabilities. Export prohibitions apply to dual-use goods, advanced tech- nology items, and certain energy sector equipment, aiming to curb the military and economic infrastruc- ture of sanctioned countries. 8.8 Environmental, Health and Safety Laws A series of legislative instruments governs the envi- ronmental regulatory framework in Greece. For instance, for projects in the energy and infrastructure sectors, Laws 4014/2011, 4685/2020, 4964/2022, and

5037/2023, as amended and currently in force, regu- late the environmental licensing process. In particu- lar, Law 3468/2006, as amended, regulates the pro- duction of electricity from renewable energy sources (“RES”), Law 4001/2011 on the operation of electricity and natural gas energy markets for the exploration, production and hydrocarbon transmission networks and Law 4014/2011, as recently amended, sets out the requirements for the environmental licensing of projects. Furthermore, the recent enactment of Law 5215/2025 established a comprehensive regula- tory framework for the production and integration of biomethane and hydrogen in Greece for the first time. Law 5215/2025 introduced Greece’s first compre- hensive framework for the production and integration of biomethane and hydrogen, marking a significant step towards diversifying the country’s clean energy mix. Greek banks and investors must also adhere to additional environmental standards, which are also incorporated as obligations in the project financing documentation. The regulatory body overseeing environmental laws is the Ministry of the Environment and Energy, which oversees these approvals. The most significant legal framework is Law 3850/2010, as amended and in force, along with Law 5053/2023 and specific legislative provisions, in compliance with EU law (primarily EU Directive 89/391/EEC) regarding the health and safety of workers in Greece. The pre- vention of workplace accidents, the implementation of preventive measures to ensure workplace safety, and equal treatment among workers are issues that fall within the scope of this legislation. Lenders and investors often require evidence of adherence to health and safety standards, such as documented risk assessments and health and safety plans, as part of due diligence processes. Additionally, Law 4808/2021 introduced innovative provisions, including the obliga- tion for businesses employing more than 20 people to adopt a policy for the prevention of violence and harassment in the workplace. The Hellenic Labour Inspectorate is responsible for the inspections and enforcement of such rules.

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