GREECE Trends and Developments Contributed by: Victoria Mertikopoulou, Ifigeneia Argyri and Maria Paziotopoulou, Kyriakides Georgopoulos Law Firm
Recent Evolution of Cartel Enforcement in Greece This article outlines recent Greek trends and developments in cartel enforcement, highlight - ing key sectors under investigation and nota - ble cartel cases, while emphasising the diverse enforcement actions and tools employed in Greece. In terms of enforcement, 2024 was a period of intensive activity for the Hellenic Competi - tion Commission (HCC), consolidating its role among the leading competition authorities inter - nationally. The HCC continues to prioritise cartel cases, especially bid rigging, as well as vertical restraints concerning resale price maintenance (RPMs) and internet minimum advertised prices (iMAPs) ‒ a trend that is expected to continue throughout the rest of 2025. In parallel, the HCC undertook multi-layered soft and hard enforcement actions in key markets for Greek consumers, with a view to responding to concerns arising from the inflationary pres - sures and combating price hikes, especially in terms of basic consumer goods. Indicatively, the authority deployed both its traditional and new toolbox, initiated ex officio investigations ( “dawn raids” ), engaged in market mapping studies (as introduced in 2022), regulatory interventions, and sector inquiries to assess competitive con - ditions in critical sectors for Greek consumers (eg, the food and fuel sector). The HCC also monitors prices through its Data Analytics and Economic Intelligence platform, a real-time data collection system aimed at ena - bling the HCC to filter out abusive, anti-com - petitive behaviours. At the same time, the HCC proactively participated in various co-operation initiatives with other national competition author -
ities, as well as EU and international bodies ‒ strengthening its presence in international fora. Sectors under investigation The HCC’s enforcement strategy for 2024 was marked by a significant number of high-profile dawn raids. The authority intensified its inves - tigations in multiple key sectors of the Greek economy, responding to geopolitical and other challenges ‒ such as the energy and cost-of-liv - ing crises ‒ and establishing its place as one of the most vigilant national competition authorities in the EU with regard to on-premise inspections. Notably, the HCC conducted seven dawn raids at 55 undertakings active in the following key sectors of the economy: • IT and related services; • organisation of educational trips for public and private schools; • ferry services; • smart water meter systems for local water supply networks;
• urban waste management; • pet food/companion animals; • coffee;
• chocolate; and • infant nutrition.
In the first quarter of 2025, the HCC carried out dawn raids in undertakings and associations of undertakings active in the provision of mari - time transport services for passengers, vehicles and trucks ‒ a key sector of the Greek economy for the connection of mainland Greece with its island network. In the second quarter of 2025, the HCC seems to be continuing its intensified enforcement; in April 2025, it conducted a dawn raid at the premises of an undertaking in the rail transport sector following a complaint related to an alleged abuse of dominant position.
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