Cartels 2025

GREECE Law and Practice Contributed by: Anna Manda and Maria Kallidopoulou, Karatzas & Partners

by the HCC. The proportion of cases in which the courts reduced the fine varied significantly over the relevant period when the decision was adopted, ranging from 30% of the cases decid - ed in 2012–13 to 70% of the cases decided in 2016 (mainly owing to the financial crisis). 5.9 Timeline of Cartel Enforcement Process On average, a cartel enforcement proceed - ing, from the dawn raid to the conclusion of an appeal, may take from two to four years. The proceeding before the HCC, in particular, may take approximately two years (eg, dawn raid, issuance of the HCC’s decision). The procedure before the administrative courts in the event that the HCC’s decision is appealed may take approximately two additional years. Any legal or natural person who has suffered harm caused by a competition law infringement has the right to claim full compensation for the harm caused by the anti-competitive behaviour of an undertaking or an association of undertak - ings. With regard to what is covered under full compensation, see 4.7 Issuing Civil Complaints . As also mentioned in 4.7 Issuing Civil Com- plaints , there has been no civil court decision to date (April 2025) awarding damages for a com - 6. Civil Litigation 6.1 Private Rights of Action

theless, based on the general rules of civil proce - dure, more claimants can file collective actions. 6.3 Indirect Purchasers and “Passing On” Defences The Damages Law expressly provides that defendants may invoke the “passing-on” defence. More specifically, defendants in claims for antitrust damages can invoke as a defence the fact that the claimant passed on the whole or part of the overcharge resulting from the com - petition law infringement and thus the claimant is not entitled to full compensation. In this respect, the civil court may quantify the amount of the overcharge on the basis of probability (reduced standard of proof).

6.4 Evidence Obtained From Governmental Investigations/ Proceedings See 4.7 Issuing Civil Complaints . 6.5 Frequency of Completion of Litigation

Private antitrust litigation is still in an early stage in Greece, given that the relevant EU Damages Directive was transposed in 2018. As men - tioned in 4.7 Issuing Civil Complaints , there is no civil court decision to date (April 2025) award - ing damages for a competition law infringement. 6.6 Attorneys’ Fees Unsuccessful parties to court proceedings bear the legal costs associated with the court pro - ceedings, including the attorneys’ fees. 6.7 Costs/Fees See 6.6 Attorneys’ Fees . 6.8 Judicial Review or Appeal Decisions involving private civil litigation issued by the Athens Court of First Instance are subject

petition law infringement. 6.2 Collective Action

Neither the Damages Law nor the GCA include specific provisions on collective actions in com - petition law matters. In addition, collective con - sumer redress mechanisms are only applicable for violations of consumer law legislation. None -

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