GREECE Law and Practice Contributed by: Paris Tzoumas, Vivian Efthymiou and Dimitrios Mekakas, Zepos & Yannopoulos
Credit institutions, like other financial sector par - ticipants, are therefore required to adjust their business models and develop plans to align their balance sheets with this transition to the sustain - able economy, as well as to monitor and comply with the ESG legislative developments. As of 2024, credit institutions have to disclose their green asset ratio as an indication of their degree of alignment with the EU Taxonomy. Regular climate stress tests are expected to take place on the basis of guidelines on institu - tions’ ESG risks stress testing. In January 2024, the ECB announced plans to enhance its cli - mate initiatives during 2024 and 2025. Under its 2024-2025 climate and nature plan, the ECB will concentrate on addressing nature-related risks, implementing a greener monetary policy, and assessing the implications and challenges asso - ciated with transitioning to a green economy, which includes evaluating investment require - ments and transition costs. This strategic focus aims to strengthen the ECB’s role in promoting sustainability within the financial system. As mentioned in 11. Horizon Scanning , one of the most significant legislative initiatives is the EU banking package implementing the Basel III framework, which will, among other things, ensure the EU’s transition to climate neutrality. In June 2023, the EU also published the proposal for a regulation on the transparency and integrity of ESG rating activities. National Level In general, Greece follows the path adopted by the EU, since the majority of EU provisions are adopted in the form of regulations which are directly applicable throughout the EU. In the same way, in 2021, the BoG established the Climate Change and Sustainability Centre (CCSC) to build on the work initiated by the
previous Climate Change Impacts Study Com - mittee (CCISC). The focus of the BoG is turning towards the compliance of credit institutions with the ESG principles and requirements, tak - ing into account the reports and guidelines of EU regulators. The implementation of relevant directives, such as the Corporate Sustainability Reporting Directive, is expected to happen soon in Greece. In investment services, the Bank of Greece Executive Committee Act 234/3/23.9.2024 updates the national legal provisions trans - posed by Commission Delegated Directive (EU) 2017/593 on the safeguarding of financial instru - ments and funds belonging to clients, product governance obligations and the rules applicable to the provision or reception of fees, commis - sions or any monetary or non-monetary benefits, as amended by Commission Delegated Directive (EU) 2021/1269 with respect to the integration of sustainability factors into product governance obligations. In addition, Greece’s first climate law (Law 4936/2022) was enacted in May 2022 by the Hellenic parliament, with the aim of establish - ing a coherent framework for improving climate resilience in Greece. Under the new law, a long list of undertakings, including credit institutions, is bound by carbon reporting obligations. The reports will be uploaded to a publicly accessible electronic database operated by the Organisa - tion of Natural Environment and Climate Change (with 2022 as a reference year).
10. DORA 10.1 DORA Requirements
In December 2022, Regulation (EU) 2022/2554 (Digital Operational Resilience Act, DORA) was
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