Legal Framework and Strategic Mandate

In a decisive move from political declaration to enforceable legal action, the European Union has adopted Regulation (EU) 2026/261, setting out a structured framework for the gradual phase-out of natural gas imports from the Russian Federation. The Regulation operationalizes the strategic goals first outlined in the Versailles Declaration and the REPowerEU Plan, transforming the EU’s long-standing ambition to reduce energy dependence into legally binding obligations. This approach ensures that the Union’s energy policy is no longer a matter of voluntary political alignment but a coordinated, enforceable strategy that integrates energy security, market stability, and climate objectives.

Historical Dependencies and Geopolitical Imperatives

 The 2022 Russian invasion of Ukraine starkly exposed Europe’s structural energy vulnerabilities. For decades, the EU relied heavily on Russian pipeline gas under long-term contracts, a dependence that proved economically destabilizing and politically risky once gas supply became a tool of coercion. Previous disruptions, notably in 2006 and 2009, along with supply constraints following Russia’s annexation of Crimea in 2014, highlight a recurring pattern of market manipulation. The undercapacity of storage facilities and extreme price volatility in 2022 further confirmed that even residual Russian volumes pose systemic risks to inflation control, market stability, and social cohesion. Regulation 2026/261 addresses these vulnerabilities by codifying a phased elimination of Russian gas, signaling a structural shift in European energy governance.

Phased Elimination and Contractual Safeguards

The Regulation establishes a staggered phase-out schedule, carefully tailored according to delivery method and contract duration. Imports of Russian LNG under short-term contracts concluded before 17 June 2025 are prohibited from 25 April 2026, while short-term pipeline gas contracts signed before the same date face a ban starting 17 June 2026. Long-term contracts exceeding one year, concluded before 17 June 2025, are phased out more gradually: LNG imports cease from 1 January 2027, and pipeline gas imports from 30 September 2027. A narrowly defined safeguard allows the Commission to extend the final pipeline deadline until 1 November 2027 for a Member State demonstrating objective supply risks, ensuring continuity without compromising market integrity.

The transitional regime is deliberately restrictive. Only contracts concluded before 17 June 2025 benefit from the phased timetable, and amendments are permitted solely for operational, administrative, corporate, or quantity-reducing purposes. Any modification that increases volumes, extends delivery periods, or expands the economic scope of a contract is treated as a new agreement and falls immediately under the prohibition. This carefully calibrated mechanism prevents artificial restructuring aimed at circumventing deadlines, while allowing necessary technical adjustments during the wind-down period.

Authorization, Monitoring, and National Diversification

Beyond prohibitions, the Regulation introduces a comprehensive prior authorization system. From February 2026 onward, importers must secure authorization from national authorities before releasing gas for free circulation. Detailed documentation regarding origin, production location, contractual terms, and infrastructure bookings must be submitted, enabling effective traceability and enforcement. Customs authorities are empowered to refuse release where sufficient evidence is lacking, complementing the prohibition with a robust monitoring architecture designed to prevent re-routing, relabeling, or indirect participation through third countries.

Member States are also required to develop National Diversification Plans, detailing measures to ensure security of supply during and after the phase-out. These plans must address demand reduction strategies, integration of renewable gases such as biomethane and hydrogen, infrastructure adaptation, and alternative sourcing routes. The broader objective is not merely substitution but structural diversification, embedding the phase-out within a framework of energy solidarity and coordinated EU-wide action rather than fragmented national approaches.

You can read the article on Lexology here:

The EU Strategy for the Gradual Phase-Out of Russian Natural Gas and the Strategic Role of LNG Infrastructure

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“Europe’s New Energy Arteries: ACER’s Roadmap for the TEN-E Revision”

(Article drafted by Kosmas Karanikolas, Senior Associate, and Ioanna Toufexi, Associate, for Lexology on November 20, 2025)

Introduction: Europe’s Energy System in Transformation

The European Union is entering a new era of energy transformation. Electrification, green industry, hydrogen, and renewable energy sources are rapidly increasing the demand for stronger, smarter, and more interconnected grids.

Europe is confronted with a historic energy challenge. On one hand, it is committed to achieving climate neutrality; on the other, it must develop networks capable of supporting billions of new electric devices, millions of electric vehicles, data centers and an entirely new hydrogen economy.

The current legal framework governing Europe’s energy networks — particularly the TEN-E Regulation — is now widely viewed as complex, slow, and difficult to implement. For this reason, the European Commission is preparing a new European Grid Package for 2025.

In this context, ACER, the European Union Agency for the Cooperation of Energy Regulators, has published detailed proposals outlining how the existing framework should be revised.

The Issue: A Slow and Fragmented Planning Framework

ACER is clearly stated that today’s legal framework is excessively complex, burdened with consultations, steps, and procedures that delay the planning of critical infrastructure.

At present, building a high-voltage line or a hydrogen pipeline requires navigating a long chain of prerequisites: extensive scenario cycles, highly complex ten-year network development plans (TYNDPs), slow procedures for selecting Projects of Common Interest (PCIs), and a labyrinth of assessments and approvals.

The result is that planning is so delayed that projects often materialize only when the market has already moved on.

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“Bulgaria launches Second Tender for EU-funded 1,900 MWh Standalone Battery Storage Facilities (RESTORE 2)”

(Article drafted by Daniela Dzabarova, Senior Associate, and Desislava Dimitrova, Senior Associate, for Lexology on September 30, 2025)

Introduction

On 19 September 2025, the Bulgarian Ministry of Energy announced the commencement of the second tender under the National Infrastructure for Storage of Electricity from Renewable Sources – RESTORE 2 program (the “Procedure”). The Procedure is designed to provide financial support for the construction and commissioning of a standalone Battery Energy Storage System (BESS), financed under the EU’s Recovery and Resilience Facility. Under the first RESTORE procedure, 82 projects were approved, with total funding of BGN 1.149 billion.

Legal and Regulatory Framework

The Procedure is conducted in accordance with the state aid scheme approved by European Commission Decision SA.114306 (2024/N): State Aid Scheme for Supporting the Development of Standalone Energy Storage Facilities. It also aligns with Section 2.5.1, Point 77, Letter a), Subpoint (ii) of the European Commission Communication on the Temporary Framework for State Aid Measures to Support the Economy in the Context of the Crisis and Transition Related to the Aggression of Russia Against Ukraine (2023/C 101/03) and its subsequent amendments.

Procedure Objectives

The Procedure aims to provide funding for the construction and commissioning of at least 1,900 MWh of standalone Battery Energy Storage capacity. The storage facilities will be distributed across Bulgaria and connected either to the transmission network operated by TSO EAD or to the  distribution network, provided that they maintain a direct optical connection to TSO EAD’s SCADA/EMS telecommunication system.

You can read the article on Lexology here:

 Bulgaria launches Second Tender for EU-funded 1,900 MWh Standalone Battery Storage Facilities (RESTORE 2) – Lexology

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“A New Chapter in Green Energy: The New Law on Hydrogen Production in Greece”

(Article drafted by Ioanna Toufexi, Associate, and Mara Vasileiou, Associate, for Lexology on September 19, 2025)

The New Law and its Key Objectives

In alignment with European Union’s policies on green development, Greece, through the adoption of Law 5215/2025 introduces a comprehensive regulatory framework for the hydrogen market, establishing coherent provisions for the production of biomethane and hydrogen. The law defines both the licensing procedures for production plants and the injection of their production into the National Natural Gas System (ESFA) or the Natural Gas Distribution Systems, as well as the supply of the produced gases to end-users not connected to the System or Distribution Networks and their use as transport fuels.

“Νέο Κεφάλαιο στην Πράσινη Ενέργεια: Ο Νέος Νόμος για την παραγωγή υδρογόνου στην Ελλάδα”

Ο νέος νόμος και οι βασικοί στόχοι του

Η Ελλάδα, εναρμονιζόμενη με τις ενωσιακές πολιτικές για την πράσινη ανάπτυξη, με την υιοθέτηση του ν. 5215/2025, εισάγει ένα πλήρες ρυθμιστικό πλαίσιο για την αγορά υδρογόνου στη χώρα, θεσπίζοντας συνεκτικές ρυθμίσεις για την παραγωγή βιομεθανίου και υδρογόνου, οι οποίες καθορίζουν τόσο τη διαδικασία αδειοδότησης των μονάδων και την έγχυση της παραγωγής τους στο Εθνικό Σύστημα Φυσικού Αερίου (Ε.Σ.Φ.Α.) ή στα Δίκτυα Διανομής Φυσικού Αερίου (Δίκτυα Διανομής), όσο και τη διάθεση των παραγόμενων αερίων σε τελικούς πελάτες που δεν συνδέονται με το Σύστημα ή τα Δίκτυα Διανομής και τη χρήση τους ως καυσίμων κίνησης.

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A New Chapter in Green Energy: The New Law on Hydrogen Production in Greece

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“RAAEY’s Decision E-65/2025: A Regulatory Milestone for Greece’s Entry into the New Energy Storage Era”

(Article drafted by Ioanna Toufexi, Associate, and Andreas Papastathis, Partner, for Lexology on September 5, 2025)

The recent Decision E-65/2025 of the Greek Regulatory Authority for Waste, Energy, and Water (RAAEW) marks a decisive step in Greece’s energy transition, as it introduces for the first time a comprehensive methodology for calculating annual operational support for electricity storage projects starting operations from January 2026. This landmark decision not only completes the national regulatory framework for storage but also aligns fully with EU state aid rules, the CEEAG 2022 Guidelines, and Greece’s National Energy and Climate Plan.

By introducing the concept of “Reference Revenue” and linking support mechanisms to actual market performance, the framework ensures both the financial sustainability of storage investments and their active participation in the electricity market, particularly in balancing services. At the same time, it mitigates risks from market volatility, reduces curtailment of renewable production, and enhances system security.

While the methodology brings innovation and strong investment incentives, it also introduces new challenges, such as administrative complexity and compliance with performance benchmarks. Nevertheless, Decision E-65/2025 represents a regulatory milestone that balances investment stability with market discipline, paving the way for Greece’s entry into a new era of energy storage and renewable integration.

You can read the full article on Lexology: “RAAEY’S Decision E-65/2025: A Regulatory Milestone for Greece’s Entry into the New Energy Storage Era”

The article is available here: (pdf).

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Law 5215/2025: A Bold Reset for Landmark Investments in Renewable Energy, Innovation & Competitiveness

(Article drafted by Mara Vasileiou & Eva Kotzairaki, Associates for Lexology on July 24, 2025)

Greece has introduced Law 5215/2025, amending Law 4684/2021, to enhance the national framework for “Landmark Investments of Outstanding Significance.” The new legal framework is designed to attract large-scale strategic projects that contribute meaningfully to sustainable development, green and digital transition, technological innovation, and the competitiveness of the Greek economy.

Expanded Scope for Landmark Investments

The law broadens the definition of eligible investments, placing emphasis on:

• Renewable energy infrastructure, especially those combining power generation with renewable hydrogen production.
• Offshore wind farms, floating photovoltaic parks, and the circular economy.
• Strategic sectors such as critical raw materials, shipbuilding, and low-carbon technologies.

A key update is the shift from the term “green” to “renewable” hydrogen, reinforcing the legislative focus on renewable energy sources and expanding the scope for state aid.

Enhanced Incentive Mechanisms

Landmark investments may now benefit from a wide range of incentives under Articles 7–10 of Law 4864/2021, including:

• Spatial planning incentive (automatically granted for site preparation and related studies).
• Fast-track licensing procedures.
• Tax incentives, including:
  • Fixed corporate tax rate for 12 years.
  • Tax-exempt reserves (taxed only upon distribution).
  • Accelerated depreciation of up to 100% (with a cap at 40% depreciation rate).
• State aid covering up to 100% of R&D and employment-related expenses.

Flexible Timelines and Implementation Framework

Recognizing the long-term and complex nature of such investments, the law replaces the fixed December 31, 2025 deadline with project-specific timelines aligned with the funding instruments involved (e.g., RRF, NSRF 2021–2027). Investors must declare the intended completion date in their application, and failure to meet this deadline results in the revocation of incentives.

Inclusion of new projects under this framework is allowed until funding resources (from EU and national programs) are exhausted, provided budgetary constraints under the Public Investment Program and the Medium-Term Fiscal Strategy are respected.

Additional Support for Key Regions and Crisis Recovery

• In De-lignification Zones (DEZs), investments can receive up to 100% of the aid intensity permitted by EU Regulation 651/2014.
• Projects falling under the Temporary Crisis and Transition Framework (TCTF)—adopted following the Ukraine crisis—may also receive full state aid, regardless of location, subject to EU state aid rules.

Conclusion

Law 5215/2025 represents a significant legislative step toward making Greece a destination for high-impact, future-facing investments. By clarifying priority sectors, expanding the eligible investment scope, and offering robust financial and regulatory incentives, the law creates a compelling framework for strategic investors committed to sustainability, innovation, and long-term economic growth.

Read the full article here: Law 5215/2025: A Bold Reset for Landmark Investments in Renewable Energy, Innovation & Competitiveness – Lexology

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Data Centers: The Legal Imperative for Renewable Integration and Energy Storage

(Article drafted by Ioanna Toufexi, Associate, and Kosmas Karanikolas, Senior Associate for Lexology on July 18, 2025)

Introduction: Data centres, as core infrastructure of the digital economy, have grown rapidly due to cloud computing, AI, IoT, and big data, but they also pose significant environmental challenges. They currently consume around 3% of global electricity, with demand projected to increase sharply. In Greece, over 500 MW of large-scale data center projects are underway, necessitating integration with renewable energy sources (RES) and energy storage for sustainability and legal compliance.

EU and Greek Legal Framework: The EU’s Energy Efficiency Directive (EED) and Delegated Regulation (EU 2024/1364) mandate annual sustainability reporting for large data centres and set energy efficiency targets aligned with the EU Green Deal and taxonomy rules. The Climate Neutral Data Centre Pact encourages voluntary industry commitments. Greece has transposed these requirements into national laws, such as Law 5069/2023 and JMD 96038/2024, which establish operational thresholds and notification requirements for data centres. Law 4951/2022 created a digital platform (PSAPE) to fast-track licensing for RES and storage, supporting the integration of green energy into data infrastructure.

Renewable Energy Integration: To reduce their carbon footprint, data centres can incorporate on-site RES (e.g., solar PV, wind) or use corporate Power Purchase Agreements (PPAs) for off-site renewable supply. Greece has streamlined licensing through JMD ΥΠΕΝ/ΔΗΕ/124788/4301/2022, promoting private RES development and PPAs. Geographic advantages in regions like Attica and Central Greece allow proximity between data centres and renewable generation, minimizing losses and grid congestion.

Energy Storage Role: Since RES are intermittent, energy storage is vital for reliability. Greece has updated its legal framework (Law 4951/2022 and RAAEY Decision 1163/2022) to support storage integration and market participation. JMD 96038/2024 introduces detailed rules for hybrid RES-storage systems, enabling services like load shifting and peak shaving. These capabilities allow data centres to enhance grid stability, reduce costs, and generate revenue through flexibility services.

Conclusion: The integration of RES and energy storage in data centres is essential for meeting EU climate and regulatory goals. Greece, through progressive legislation and its National Plan for Energy and Climate (NECP), has positioned itself as an attractive hub for sustainable data infrastructure. Compliance with EU directives and regulations is not optional but a prerequisite for legal operation, competitiveness, and resilience in the digital economy.

Read the full article here: Green Data Centers: The Legal Imperative for Renewable Integration and Energy Storage – Lexology

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“The importance of the participation of electricity storage plants in the balancing system”

(Article drafted by Panagiota Maragkozoglou, Associate, and Andriani Kantilieraki, Senior Associate for Lexology on May 1, 2025)

Greece is rapidly expanding its renewable energy (RES) sector and sees electricity storage as essential to effectively integrate RES into the national energy system. While legislation (notably Law 4951/2022) has been enacted to support both standalone and RES-integrated storage projects, and competitive procedures for state aid have begun, actual operation of storage units remains limited to hydro-pump facilities. Efforts are underway to enable storage systems to participate in Greece’s electricity markets, particularly the Balancing Market. Key market operators—IPTO, HEE, and RAAEY—are collaborating to adjust regulatory codes and frameworks, with IPTO launching guidelines covering participation criteria, planning, system charges, and congestion management. Regulatory approval procedures, including public consultations, are ongoing to finalize these reforms and enable full integration of storage into the market.

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“Sustainable fuels in the aviation and maritime transport industry” (article about sustainable energy & fuels)

(article drafted by Panagiota Maragkozoglou, Associate and Kosmas Karanikolas, Senior Associate for Lexology in March 21,2025)

The article addresses the EU’s efforts, about sustainable energy & fuels, to reduce greenhouse gas emissions in aviation and maritime transport starting in 2025 through the ReFuelEU Aviation Regulation and the FuelEU Maritime Regulation. The Maritime Regulation targets ships over 5,000 gross tonnage, aiming for an 80% reduction in greenhouse gas emissions by 2050. Shipping companies must submit monitoring plans by August 2024 and annual “FuelEU reports.” Non-compliance results in fines, and insurance covering such fines is illegal. The Aviation Regulation requires aviation fuel supplied at EU airports to contain at least 2% sustainable aviation fuel (SAF) by 2025, rising to 70% by 2050, with synthetic aviation fuels making up a part of this blend. Reporting requirements and fines for non-compliance are also established.

The UK SAF Mandate follows a similar path, targeting 2% SAF use by 2025 and 22% by 2040, with a revenue certainty mechanism through a “contract for difference” model. Hydrogen is considered crucial for decarbonization, particularly green hydrogen derived from renewable sources. Greece is highlighted as a potential leader in green hydrogen production. The article concludes by emphasizing the importance of sustainable fuels and renewable hydrogen in achieving decarbonization goals under the Paris Agreement.

Access the full article about sustainable energy & fuels here:

Sustainable fuels in the aviation and maritime transport industry – Lexology

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RENEWABLE ENERGY GREECE

“ The Letters of Guarantee under the light of the Law  5151/2024”

(article by Panagiota Maragkozoglou – Associate and Andriani Kantilieraki – Senior Associate published on Lexology, January 29, 2025)

The new Greek law 5151/2024 introduces significant modifications to the legislative framework concerning letters of guarantee required for the development of Renewable Energy Sources (RES) projects, particularly for grid connection.

Key provisions include:

1. Return of Letters of Guarantee: RES and High-Efficiency Combined Heat and Power (HE CHP) plants can request the return of specific letters of guarantee if they have received a binding connection offer but have not been selected in competitive procedures or applied for an operational aid agreement by October 2024. Previously, returns were allowed under very limited conditions.
2. Reduction of Letters of Guarantee: RES and hybrid plants can replace their letters of guarantee with a reduced amount (30% reduction for plants ≥1 MW, 15% for plants <1 MW) if they have submitted them before October 31, 2024, or if applying afterward. Hybrid plants on non-interconnected islands must submit these guarantees upon accepting the connection offer.
3. Abolition of Exemptions: Plants with a maximum production capacity of up to 0.5 MW must now submit a producer’s certificate letter of guarantee, a requirement previously waived. Both existing and pending applications must comply within three months.

This law modernizes the framework, easing financial burdens for developers while maintaining regulatory oversight.

Read the full article Renewable Energy Greece- “The Letters of Guarantee under the light of the Law 5151/2024” here:

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