The article was drafted by Alexandros Sarris, Senior Associate & Ioanna Toufexi, Associate for Lexology on July 6
On 20 May 2026, Greece’s Ministry of Environment and Energy published a draft Special Spatial Framework for Renewable Energy Sources (EChP-APE) for public consultation. The framework replaces the 2008 siting regime and introduces binding constraints that will reshape how photovoltaic projects are developed, valued, and transacted. With installed RES capacity at approximately 18 GW and a licensing pipeline exceeding 110 GW, the new rules create a regulatory filter that converts previously a private-law commodity—into a scarce, regulated asset.
What the Framework Does
The draft introduces two principal instruments for Photovoltaic projects (PV). First, exclusion zones prohibit new installations in Natura 2000 areas, forests, wetlands, protected areas, and archaeological zones. Second, a quantitative land-coverage cap of 1.5% per Regional Unit applies to new PV stations that have not yet obtained Environmental Terms Approval (AEPO). The framework exempts projects already in operation or in advanced permitting. Of the roughly 110 GW pipeline, approximately 70 GW are protected by transitional provisions, while around 37 GW—21 GW PV and 16 GW wind at early licensing stages—remain exposed to the new constraints.
Land as a Regulated Scarcity Asset
Irradiation and clear titles are no longer sufficient. A viable PV site must now satisfy spatial eligibility, Regional Unit capacity, environmental clearance, grid availability, and local acceptance criteria. Developers should restructure land agreements to include conditions precedent tied to spatial eligibility, cap headroom, AEPO issuance, and grid connection—with termination rights if any condition fails. Overpaying for land in Regional Units approaching the 1.5% threshold is a quantifiable bankability risk.
Permitting Status and M&A Valuation
The transitional architecture creates a valuation bifurcation. Projects with AEPO sit on the protected side: they face no re-screening, enjoy compressed timelines, and benefit from increasing scarcity value. In M&A terms, this translates into a premium reflecting reduced regulatory risk, enhanced bankability, and timeline certainty. Buyers acquire not just megawatts but regulatory optionality—the right to develop in conditions that new entrants cannot replicate.
The premium is not automatic. Acquirers should diligence whether protected status is legally robust; whether the site is in a sensitive area carrying Habitats Directive Article 6(3) or community-opposition risk; whether grid connection is credible; and whether the transitional classification will survive potential legislative amendment.
Large Groups vs. Small Producers
Vertically integrated companies benefit from mature pipelines protected by transitional provisions, internal GIS and legal capabilities, relocation flexibility, and capacity to acquire repriced portfolios. Their principal risks are reputational exposure from grandfathered projects in sensitive zones and stranded land in saturated Regional Units.
Smaller producers face disproportionate compliance costs and intensified competition for eligible land. Without reserved electrical space, priority mechanisms for energy communities, or simplified permitting for smaller installations, the framework risks accelerating market consolidation.
Grid Risk
The framework does not integrate grid capacity into spatial licensing. A project may satisfy every spatial criterion yet remain unfinanceable if it cannot secure a credible connection, faces structural curtailment, or requires co-located storage. Grid risk is now as material as permitting status to project valuation.
Practical Recommendations
PV businesses should: (1) map portfolios against exclusion zones and Regional Unit cap data; (2) classify projects by permitting status relative to the transitional line; (3) renegotiate land options to include spatial eligibility and cap-headroom conditions; (4) diligence grid connection and curtailment exposure; (5) develop a community-benefit strategy for projects above 500 kW; and (6) prepare for M&A repricing—as potential acquirers of distressed early-stage portfolios and as sellers of advanced-stage assets.
You can read the full article here: Greece’s Draft RES Spatial Framework: Why Photovoltaic Project Value Will Turn on Permitting, Land and Grid Risk – Lexology