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GREECE: An Introduction to Energy

Dimitrios Andriopoulos
Vangelis Mylonas Tsoumas
Pavlina Bozini
Koutalidis Law Firm Logo
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On 31 March 2021, the Greek Government set out a 57 billion euro national recovery plan entitled “Greece 2.0” (the “Plan”). As the Greek PM put it, the Plan shall “constitute the bridge leading Greece into the post-COVID era and the third decade of this century”. The Plan is grounded on four main pillars, the first – and perhaps most crucial – of which concerns the so called “green energy transition”. The Plan includes, inter alia: (i) extended “sustainable living” regime for households, businesses, public property and infrastructure; (ii) connection of Greek islands to the national grid; (iii) strategic gentrification of high developmental and environmental value; (iv) large investments in flood defence projects, coupled with reforms in the use of irrigation networks and installation of telemeters for leak detection and smart water management; (v) new national reforestation plan; (vi) biodiversity protection initiatives; and (vii) investments in energy storage.

The Plan also intends to facilitate investors in identifying which lands they may use for their investments – one of the traditional market risks in Greece – by announcing investments in the preparation of urban planning drawings providing valid and accurate snapshots of the land situation for 4/5 of the country.

Digital transition is also one of the key priorities outlined in the Plan and is expected to bolster green energy transition by reducing bureaucratic inefficiencies and even creating cross-sector collaboration opportunities for energy and TMT investors (eg powering of energy-heavy 5G networks and data centres / cloud services).

Coupled with the already successful Invest in Greece program for strategic investments (recently amended primarily in order to further simplify the licensing of strategic investments) Greece doubles down on its bet to reinvent itself as a desirable investment destination in the Balkan / Eastern Europe area with a strong focus on green projects.


RES projects 

New licensing framework 

The energy legal landscape saw massive change towards mid-2020 with the issuance of Law 4685/2020, which set out a brand-new production licensing framework aimed at accelerating and streamlining the licensing process and completely digitizing the licensing process in the RES industry. Prospective RES energy investors can now easily submit their applications for the issuance of a “producer’s licence” (technically a “certificate”) and all supporting documentation to the Regulatory Authority for Energy (“RAE”) via an electronic platform.

Improvements in the licensing of RES projects also came about by a 2020 Ministerial Decision compelling the Hellenic Electricity Distribution Network Operator (“HEDNO”) to prioritize grid connection offers for RES projects.

Tender procedure for FITs 

The feed-in-tariff (“FIT”) regime saw significant change in late 2020. In essence, from 2021 onwards – and with certain exceptions – no photovoltaic project may receive a feed-in premium, without first participating in (and “winning”) the relevant tender procedure. The exceptions relate primarily to certain photovoltaic projects by “Energy Communities” – a special type of investment vehicle – and certain photovoltaic projects in the area of Western Macedonia.

Imposition of special levy 

In late 2020 a one-off special levy was imposed mainly on RES electricity producers operating in the country before 2016 equal to 6% of total turnover for 2020.

Sustainable living 

In 2020 the “Save – Autonomize” (in Greek: “Exikonomo – Aftonomo”) program (the “Program”) was introduced. The Program provides incentives for energy upgrading and housing autonomy with the goal to reduce the energy needs of buildings and greenhouse gas emissions, save costs for citizens and achieve a cleaner environment.

As above mentioned the Greek government appears keen on further expanding on the Program in the post-COVID era.


In 2020 a new law (Law 4710/2020) for the promotion of electromobility in Greece was promulgated. The new law provides several incentives (eg tax benefits) to purchase electric vehicles and contains provisions for the deployment of the required electric vehicle infrastructure. Electric vehicle purchase is also subsidized by the state within the context of the recent “Moving Electrically” (in Greek: “Kinoume Ilektrika”) program.

Green public contracts 

In line with the European Commission’s suggestions, the Ministry of Environment and Energy endorsed an action plan for green public contracts. The plan involves the supply of environmentally sustainable products by the EU Member States in order for them to reduce the environmental impact that such procurements would otherwise entail.


In the past few years Greece has seen a surge of energy-related investments particularly in its booming RES sector. Greece’s unique geomorphological characteristics together with an ever evolving and – mostly – favourable legislative framework (also coupled with the availability of international investment protection through Greece’s vast network of Bilateral Investment Agreements and its participation in the Energy Charter Treaty) have enticed investors from all over the world to set up shop in the country. In the December 2020 cycle for applications for RES licensing alone, RAE received applications of 45.55 GW total capacity. Recent investor activity in the sector can be broken down in four main categories: renewables, oil & gas, energy storage and infrastructure and privatizations.


Some of the most notable examples of recent renewables investments include (i) the development of a 470 MW, ~500 million euro wind power plant in the north-central and southern parts of Evia (intra-EU joint venture between Greece’s Ellaktor and Portugal’s EDP); and (ii) a 2.5 billion euro investment in electrolytic hydrogen production through photovoltaic parks of 1.5 GW total capacity in Western Macedonia.

Oil & Gas 

Recent examples that come to mind in this regard are: (i) the 300–400 million euro “strategic investment” underground natural gas storage facility in Southern Kavala with an estimated throughput at 360 million Nm3; and (ii) the floating storage and regasification unit (“FSRU”) project in Alexandroupolis of total LNG storage capacity of up to 170,000 cubic metres and a natural gas sent out capacity that will exceed 5.5 billion cubic metres per year. The FSRU will be connected to the National Natural Gas System of Greece via a 28 km long pipeline, through which the regasified LNG will be transmitted to the markets of Greece, Bulgaria and the wider region, from Romania, Serbia and North Macedonia to Hungary, Moldova and Ukraine.

Energy storage 

The single largest investment in energy storage in Greece is currently the hydro pumped storage complex in Amfilochia project developed by Terna Energy, with an investment value of over 500 million euros. The project aims at maximizing RES penetration in the energy production mix.

Infrastructure & Privatizations 


Crete’s connection to the mainland constitutes one of the biggest energy infrastructure projects currently being constructed in the country, having a value of over 1 billion euros. The project includes two submarine HVDC cables, approximately 328 kilometres long, with a rated power of 1,000 MW in bipolar operation (2 x 500 MW), from Attica to Crete. The timely construction of the Crete–Athens electricity grid interconnection (currently envisaged for 2022) is required to prevent a looming energy shortage on the island.


On 15 December 2020 an Invitation for Expression of Interest for the sale of a 49% stake in the share capital of HEDNO was announced, initiating the official public tender procedure for the privatization of the Greek distributor for electricity. The procedure is currently ongoing.