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

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On 26 February 2025, the European Commission presented the “Omnibus I” package of proposals, aimed at reducing the administrative burden on businesses, strengthening the competitiveness of the European economy, and simplifying sustainability obligations without abandoning the core objectives of the European Green Deal. Proposal COM(2025) 81 is central to the reform, as it amends the Corporate Sustainability Reporting Directive, the Corporate Sustainability Due Diligence Directive (CSRD and CSDDD) and related legislation. For Greek businesses, the package should be read less as a withdrawal from ESG and more as a shift toward a more proportionate, workable and commercially relevant sustainability framework.

Why does the Omnibus matter for Greek businesses?

Experience with the CSRD and CSDDD has shown that sustainability compliance can be costly, complex and resource-intensive, particularly for smaller and mid-sized undertakings. In markets such as Greece, where many businesses operate as suppliers, borrowers, sponsors, contractors or investee companies within larger European value chains, the challenge has not only been formal legal compliance, but also the indirect flow-down of ESG information requests from banks, customers, investors and public or private procurement processes.

According to the Commission, the Omnibus package is expected to deliver administrative relief of more than EUR 6 billion per year, as obligations are concentrated on businesses considered to have the greatest environmental and social impact. In practice, however, the benefit for Greek companies is likely to be relative rather than absolute: lenders, strategic customers, international groups and institutional investors are expected to continue requesting reliable ESG information through financing arrangements, supply-chain policies, investment processes and contractual undertakings.

Key proposed changes to the CSRD

The most significant change concerns the reporting framework applicable to undertakings. The proposed Directive provides that sustainability reporting obligations will apply to undertakings with more than 1,000 employees, provided they also meet the relevant financial criteria. Following the alignment of national laws, the Commission estimates that approximately 80% of companies that were expected to fall within the mandatory CSRD reporting regime will be exempted. The Omnibus proposal also provides that undertakings within the scope of the CSRD should not be able to require companies outside the Directive’s scope to provide sustainability information beyond what is set out in a simplified voluntary reporting standard.

Equally important is the simplification of the European Sustainability Reporting Standards (ESRS), with the aim of focusing on core sustainability indicators and improving proportionality without undermining the quality and comparability of disclosed information. This is particularly relevant for Greek small and medium-sized enterprises, which may not be directly in scope but may still need to respond to ESG questionnaires, onboarding requirements and tender or financing requests from larger counterparties.

The simplification also extends to the EU Taxonomy Regulation, a key tool for assessing the environmental sustainability of economic activities, including through the introduction of materiality criteria. For the Greek market, this remains relevant for bankability and investment appetite in sectors such as energy, infrastructure, real estate, transport, tourism and manufacturing, where access to financing and institutional capital increasingly depends on credible sustainability data.

Proposed recalibration of the CSDDD

The Omnibus proposal provides for the postponement of the Directive’s first application until 2028, a stronger focus of due diligence on direct business partners, the review of indirect business relationships where there are indications of heightened risk, the reduction of the frequency of risk assessments from an annual to a five-year basis, and the narrowing of certain requirements relating to stakeholder engagement and value-chain monitoring. The direction of travel is to move due diligence away from a continuous, highly expansive exercise and toward a more targeted, risk-based and manageable compliance system.

What should Greek businesses do now?

For many companies, the Omnibus represents welcome relief in terms of cost and administrative burden. The practical message for the Greek market, however, is that ESG will remain relevant where it affects financing, procurement, supply-chain access, corporate governance, M&A readiness and investor confidence. Companies should therefore focus on a proportionate ESG baseline: identify which information is actually requested by banks, customers, investors and tendering authorities; assess whether the group or its key counterparties remain in scope; and maintain a practical dataset that can be used consistently across commercial relationships.

This approach is particularly important in transactions and financing. A Greek target, borrower, sponsor or supplier that can provide concise, reliable and decision-useful ESG information is likely to be better placed in due diligence, credit approval, procurement evaluation and negotiations with international counterparties, even where it is not itself subject to full mandatory reporting.

You can read the article on Lexology here: “The EU “Omnibus I” Package: Practical Implications for the Greek Market” – Lexology

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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.

You can read the whole article on Lexology here:

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”

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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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