fisikon

National Legal and Regulatory Framework

Primary Legislation

The import, trade (supply), transmission and distribution of natural gas in Greece were initially regulated by L. 2364/1995 (Government Gazette Α’ 252/6.12.1995).

Subsequently, in order to comply with the obligations regarding the liberalization of the natural gas market which were imposed by the 2nd Energy Package of the European Union regarding the common set of rules of the internal gas market (Directive 2003/55/EC and ΕC Reg. 1775/2005), L. 3428/2005 (Government Gazette Α’ 313/27.12.2005)on “The Liberalization of the Natural Gas Market“ was issued, which integrated into national legislation the aforementioned provisions of the European Directives and Regulations.

Following the issuance of the 3rd energy package and in order to comply with its provisions (specifically, Directive 2009/73/EC and the EC Regulations 713/2009 & 715/2009), with the ultimate goal the further smooth completion of the internal natural gas market and the creation of equal access terms for all natural gas companies within the EU, the new energy law L. 4001/2011 (Government Gazette Α’ 179/22.8.2011) for the operation of Energy Markets for Electricity and Natural Gas was enacted, which replaced in its majority L. 3428/2005. Directive 2009/73/EC introduced the unbundling of the networks from the supply and generation activities with the adoption of three alternative models (ownership unbundling, ISO, ITO) since it was considered that the legal and operational unbundling foreseen in the previous, repealed Directive 2005/55/EC did not bring satisfying results as per the achievement of the above goal.  L. 4001/2011 initially provided only for the adoption of Ownership Unbundling.The Legislative Act of 16.12.2011 (Government Gazette Α’ 262/16.12.2011), foresaw the possibility of enactment of the Independent Transmission Operator model (ΙΤΟ) for the Transmission Systems owned by a Vertically Integrated Company on September 3rd 2009, as well as the option to choose, for the Vertically Integrated Companies wishing to do so, the Ownership Unbundling Model. The provisions of Law 4001/2011 regarding the Independent Transmission Operator were amended with L.4093/2012 (Government Gazette Α’ 222/12.11.2012), Legislative Act Government Gazette Α’229/19.11.12 and L.4111/2013 (Government Gazette Α’ 18/25.01.2013).  

L. 4336/2015(Government Gazette Α’ 94/14.8.2015), L.4337/2015 (Government Gazette A’ 129/17.10.2015), as well as L.4414/2016 (Government Gazette A’ 149/09.08.2016), article 55 of L.4423/2016 (Government Gazette Α’ 182/27.09.2016) and article 15 of L.4425/2016 (Government Gazette A’ 185/30.09.2016), amended L.4001/2001, in order to further liberalize the natural gas market in Greece via the restructuring of the natural gas distribution framework through the obligation of the Vertically Integrated Natural Gas Companies for legal and functional unbundling of their natural gas distribution activities from their supply activities and the widening of the definition of “Eligible” Customers. The abovementioned new provisions also include details concerning the implementation of the respective legal and functional unbundling.   

L. 4001/2011 was also amended, inter alia, by the following:  

  • Article 17 (13) of L. 4203/2013 (Government Gazette Α’ 235/1.11.2013) and in turn article 2(2) of L. 4336/2015 (Government Gazette Α’ 94/14.8.2015) amended article 73 of L. 4001/2011 concerning security of supply so as to comply with the European Regulation 994/2010. Furthermore, article 17 (12) of L. 4203/2013 amended article 2 (2) of L. 4001/2011 and then MD Δ1/Β/10233/2014 (Government Gazette Β’ 1684/24.06.2014) was issued by the same law further laying down the categories of Protected Natural Gas Consumers.
  • Article 55 (8) of L.4223/2013 (Government Gazette Α’ 287/31.12.2013), replaced article 85(4), second subparagraph, of L. 4001/2011, and extended the duration of the provisions of article 24 of L. 3175/2003 (related to Take or Pay charges) up to 31.12.2015.
  • By virtue of article 96 of L.4512/2018 (Government Gazette Α’ 5/17.1.2018) concerning the restructuring of the Greek energy market, new articles 117A, 117B, 117Γ, 117Δ, 117E, 118E were introduced to L.4001/2011, which contain detailed provisions on the operation of the Energy Exchange, while with par. 4-7 of article 64 of L.4546/2018 (see below) specific provisions were added to articles 117B and 117E concerning RAE’s approval of the budgeted operational expenses of the Energy Exchange and of the Clearing Entity (concerning the time period from their incorporation up until 31.12.2018).
  • By virtue of article 24 of L.4513/2018 (Government Gazette Α’ 9/23.1.2018), the main subsequent amendments are the following: a) the framework for the natural losses offsetting and self-consumption of the NNGS is defined, also adjusted in order to comply with the requirements of EU Regulation 312/2014 on Gas Balancing, b) the Electronic Trading Platform of natural gas is reinforced for the even more efficient operation of the secondary market (resale, release/transfer of capacity and storage), c) the provisions for security of supply are amended so that the fee owed to power producers which use natural gas as fuel and with an obligation for an alternative fuel also covers the cost differential between oil and natural gas for the trials prior to signing of an agreement with DESFA, while particularly for the winter period of 2017-2018 power producers also have the obligation to hold natural gas reserves on a floating tank based on terms to be specified in a RAE decision and d) minimum capital requirements are introduced for candidates and holders of supply licenses, Independent Natural Gas System, Operation of the Independent Natural Gas System, Distribution and Operation of the Distribution Network. Case β’of par.8 of the article in question was amended by article 40.2 of L.4546/2018 (see below) and demands henceforth that holders of Gas Supply Licenses, of ASFA Licenses, of ASFA Operation Licenses, of Distribution and Distribution Operation Licenses within nine (9) months from the entry into force of the Revised Licenses Regulation to submit to RAE an application for an amendment of their license accompanied by additional information which attests their compliance with the provisions of article 90 of L.4001/2011, as amended by L.4513/2018 and L. 4546/2018 and in force, so as not to have their license revoked.
  • By virtue of par.1 article 40 of L.4546/2018 (Government Gazette Α’ 101/12.06.2018): a) a new paragraph was added on the ASFA Operations License (article 77 of L.4001/2011), as well as a subparagraph regarding Distribution and Distribution Operation Licenses (par.1 of article 80Γ of L.4001/2011), which stipulate that the Licenses in question shall foresee the terms, the conditions and necessary measures to ensure the independence and the operational unbundling of the license holder, b) by virtue of article 81, par.1 of L.4001/2011 for the supply of natural gas it is foreseen that henceforth a Supply License is not required for gas sales to a Supplier or Wholesale Customer and that RAE will monitor the way in which the Supply activity will be performed by Wholesale Customers, c) article 84 of L.4001/2011 concerning resale was repealed. In addition, par.2 of article 47 of the law in question replaces the 1st subparagraph of par.2 of article 80B of L.4001/2011 and it is foreseen that the expansion works of the existing Distribution Networks which take place from 1.04.2017 onward from EDA Attica, Thessaloniki and Thessalia are under their exclusive ownership.
  • By virtue of article 53 of L.4602/2019 (Government Gazette Α’ 45/09.03.19) articles 80Δ, 80Ε, 80ΣΤ, 80Ζ, 80Η, 80Θ, 80Ι, 80ΙΑ, 80ΙΒ, 80ΙΓ and 80ΙΔ were added following article 80Γ of L. 4001/2011, which foresee the full ownership unbundling of companies which own a Natural Gas Distribution Network and exercise the responsibilities of operator of the network from the activities of generation or supply of natural gas or electricity or electricity trading. In addition, the article in question contains provisions for the corporate restructuring of DEPA S.A. into DEPA Commercial S.A. and DEPA Infrastructure S.A., as well as the sale of shares of the above companies to interested investors.
  • By virtue of Chapter Δ’ of L.4643/2019 (Government Gazette Α’ 193/03.12.19) provisions were introduced for the privatization of DEPA S.A., as well as other provisions relating to the natural gas market. Specifically, a.16 repeals articles 80ΙΑ, 80ΙΓ and 80ΙΔ of L. 4001/2011 and articles 80ΣΤ, 80Ζ, 80Η and 80Ι, are substituted with provisions for the restructuring of DEPA S.A. into DEPA Supply S.A., DEPA Infrastructure S.A. and DEPA International S.A., as well as the sale of HRADF’s total shares in DEPA Supply S.A. and DEPA Infrastructure S.A., excluding shares of DEPA International S.A..
  • By virtue of Chapter H’ (articles 72 & 73) of L.4685/2020 (Government Gazette Α’ 92/07.05.20) inter alia, a) the provisions of articles 176-177 were supplemented, in terms of natural gas infrastructure projects, to include East Med pipeline, b) the process for selection of Supplier of Last Resort for natural gas was redefined, and c) HHRM was restructured with the transfer of 65% of shares of DEPA International S.A., formerly owned by HRADF and the possibility for acquisition of the remaining 35% of shares owned by Hellenic Petroleum was foreseen.
  • By virtue of Law 4951/2022 (Government Gazette A' 129/4.7.2022), entitled: "Modernization of the licensing process for Renewable Energy Sources - Phase B, Licensing of electricity production and storage, framework for the development of Pilot Marine Floating Photovoltaic Plants and more specific provisions on energy and environmental protection", in Part C, provisions of Law 4001/2011 are amended regarding the licensing and exercise of electricity production and storage activities and incorporation of provisions of Directive (EU) 2019/944 on the production , the res aggregation and storage of electrical energy. In article 122, as a response to the energy crisis, the temporary mechanism for returning part of the revenues to the day-ahead electricity market is established. Pursuant to the said mechanism, with application from 1.7.2022 to 1.6.2023, part of the revenues to which participants in the next-day market are entitled from their participation in it is withheld by the clearing agency. Additionally, article 138 provides for the abolition of the readjustment clause in fluctuating electricity supply tariffs from 1.8.2022 to 1.7.2023 (par. 1) with the possibility of further extending the validity period. In article 139, articles 80F and 80G of Law 4001/2011 (A΄ 179), on the certification of the Undundled Natural Gas Distribution Network Operators and the existing holdings and rights, respectively, are repealed.
  • By virtue of Law 4964/2022 (Government Gazette A'150/30.07.2022) entitled "Provisions for the simplification of environmental licensing, establishment of a framework for the development of Offshore Wind Farms, dealing with the energy crisis, environmental protection and others provisions", in Part A, Chapter H (a. 65-80) provisions for the development framework of offshore wind farms are mentioned, and in chapter I (a. 81 - 94) there are provisions for dealing with the energy crisis. Also, in Chapter IA', in article 107, reference is made to the subject of the Adjustment Clause – Amendment of article 138 of Law 4951/2022 in which, among other things, it is stated that electricity suppliers announce on a monthly basis and in a prominent place on their website, until the twentieth day of the previous month, before the month of application, the fixed charges and electricity supply charges for the power and energy component and any discounts, which cannot be linked to the fluctuation of the wholesale market sizes applied to the supply tariffs.Finally, with article 181 of the said law, issues of subsidizing the consumption of natural gas and payment of subsidies are regulated within the framework of the temporary mechanism for returning part of the day ahead market revenues — Amendment of article 61 of Law 4839/2021.
  • By virtue of article 62 of Law 4986/2022 (Government Gazette A' 204/28.10.2022) entitled "Incorporation of Directive (EU) 2019/944 of the European Parliament and of the Council of June 5, 2019 regarding the common rules for the internal electricity market and the amendment of Directive 2012/27/EU and other urgent provisions.", a special contribution of €10 per thermal MWh in favor of the TEM is foreseen for power producers with natural gas fueled units and for the 1st implementation the reference month is set for November 2022. The revenue from the special levy is primarily allocated to support electricity consumers, in the context of dealing with increased energy costs, due to the energy crisis.
  • By virtue of article 40 of Law 4994/2022 (Government Gazette A' 215/18.11.2022) establishes a Temporary Mechanism for Returning Part of Retail Market Revenues, which imposes on Electricity Suppliers an extraordinary levy, based on their excess revenue from the activity in the domestic retail electricity market for the period of validity of par. 1 of article 138 of Law 4951/2022 (A' 129). Also, with article 41, a new provision is added to Law 4001/2021 (article 143Z) regarding the establishment of an Electricity Demand Reduction Service as an obligation of electricity consumers, cumulative load representation bodies, to limit the power they consume or represent during peak hours, at least by a certain quantity, with financial compensation.
  • Article 89 of Law 5027/2023 (Official Gazette A' 48/2.3.2023) replaces paragraph 2 of article 62 of Law 4986/2022 where paragraph 1 applies to natural gas consumed from March 1, 2023. It should be noted that the aforementioned Law includes regulations of the Ministry of Environment & Energy that amend provisions of laws 4994/2022 and 4986/2022 regarding the Temporary Mechanism for the Return of Part of the Revenues from Electricity Suppliers and the Amount of the special contribution per thermal MWh in favor of TEM. The last provision on a special levy on power generation companies is repealed by article 36 of Law 5086 /2024 (Government Gazette A' 183/14.02.2024)
  • By virtue of Law 5037/2023 (Government Gazette A’ 78 28.03.2023) entitled "Renaming the Energy Regulatory Authority to the Waste, Energy and Water Regulatory Authority and expanding its scope with responsibilities on water services and urban waste management, strengthening water policy - Modernization of legislation on the use and production of electricity from renewable sources through the integration of EU Directives 2018/2001 and 2019/944 - More specific provisions on renewable energies and the protection of the environment" in Chapter C (a.6-21) the Energy Regulatory Authority (RAE) is renamed to the Regulatory Authority for Waste, Energy and Water (RAEWW), expanding its scope with responsibilities over water services and municipal waste management. This Law also amends provisions of Law 4001/2011 regarding citizens' energy communities, and RES issues (RES access to Networks and infrastructures and monitoring of support regimes). Also, article 105 replaces article 92 of Law 4001/2011 on renewable gas access to natural gas networks and infrastructures, which explicitly refers to the flow of biomethane using natural gas distribution systems and networks. In article 146, there are provisions on "DEPA COMMERCIAL SA" staff issues. and its affiliated companies – Addition of par. 7 to article 80IB of Law 4001/2011, and with article 160 the issuance of new licenses for the production of electricity fueled by natural gas or petroleum products is now prohibited, while the possibility of converting licenses is given of electricity production in electricity storage permits - Amendment of article 132 of Law 4001/2011.
  • By virtue of article 17 of Law 5066/2023 (Government Gazette A' 188/14.11.2023) regulations are established in the supply of electricity and in particular with the addition of article 138A to law 4951/2022 a Special Electricity Supply Tariff is created by electricity suppliers of Energy for each category of Low Voltage customers, to which Electricity Suppliers must transfer Electricity Customers who were subject to the provisions of Article 138 for electricity consumption from January 1, 2024 to December 31, 2024.
  • Article 27 of Law 5069/2023 (Government Gazette A' 193/28.11.2023) abolishes the obligation to install a gas fuel network for every new building, while the preparation of a relevant study now becomes optional in derogation of the p.d. 420/1987 (A΄ 187). With article 58 of the said Law, paragraph 3 of article 61 of Law 4839/2021 on the granting of electricity and natural gas bill subsidies to consumers is amended, providing from the special account of para. 1 a subsidy for billable electricity consumption credited to the accounts of the beneficiaries as a discount from the electricity suppliers. Beneficiaries of the above subsidy may be all electricity consumers, regardless of voltage level.
  • By virtue of article 30 of Law 5095/2024 (Government Gazette A' 40/15.03.2024) entitled "Measures to reduce energy costs for the promotion of the primary and secondary sector" absolute priority of connection to the grid is given to RES projects whose production is channeled, through bilateral contracts, to energy-intensive industries and farmers.
  • Law 5106/2024 (Government Gazette A' 63/01.05.2024) includes provisions (articles 103-126) to strengthen energy security and promote RES. Articles 113-116 amend article 65 of Law 4964/2022 regarding offshore wind farms and the Renewable Energy Sources Fee, while Chapter C (articles 117-121) on the subject of "Framework for the Creation of Electric Space" the framework of production restrictions of RES and High-Efficiency Heat Cogeneration stations is determined - Addition of article 10A to law 4951/2022. Finally, articles 122-126 present additional provisions for the regulation of the electricity market (such as for the heating allowance on electricity from TEM, the Universal Electricity Service Provider, and the fight against power theft).

Secondary Legislation

1. Licensing

2. National Natural Gas Transmission System (NNGS) Operation

  • NNGS Code of Operation:

The first version of the NNGS Code of Operation was issued by virtue of M.D. Δ1/Α/5346/2010 (Government Gazette Β’ 379/1.4.2010).Pursuant to the abovementioned Code, the “Standard Natural Gas Transmission and LNG Facility Usage Agreements” were issued by virtue of RAE decision No. 611/2010 (Government Gazette Β’ 480/20.4.2010).

The first (1st) Revision of the NNGS Code entered into force on October 14, 2011 by virtue of RAE Decision 1096/2011 (Government Gazette Β’ 2227/14.10.2011). The revision aimed at supplementing – improving the provisions of the Code, as well as attempting its harmonization with the European Gas Target Model. As a result of this revision, RAE, with its decision No 126/2012 (Gov. Gaz. B’ 907/23.3.2012), approved the new Standard Natural Gas Transmission and LNG Facility Usage Agreements, which are compliant with the revised provisions of the Code.

The second (2nd) revision of the NNGS Operation Code (Government Gazette B’ 3131/9.12.13) was issued on December 9, 2013 so as to adjust mainly to the provisions of the Tariff Regulation of July 5, 2012 (see paragraph below), as well as to the provisions of European Regulation (EC) 994/2010 concerning measures to safeguard security of gas supply and the provisions of Regulation (EC) 715/2009 on the conditions for access to the natural gas transmission networks, as amended by Commission Decision 2012/490/EU concerning measures for congestion management. An unofficial (commissioned by DEPA) translation in the English language of the 2nd revision of the NNGS Code is available on our website. Based on the 2nd Code Revision, the revised Standard Natural Gas Transmission and LNG Facility Usage Agreements (RAE Decision 635/2013, Government Gazette B’ 3325/27.12.2013) were issued.

The 3rd Revision of the NNGS Code (RAE Decision 239/2017- Government Gazette B’ 1549/5.5.2017) was issued on May 5th 2017 and came in force on June 1st, 2017. The purpose of the revision in question is to include the provisions of European Regulations on Capacity Allocation (EU 984/2013), rules on Balancing (EU 312/2014) and on Interoperability and Data Exchange rules (EU 703/2015). Based on the 3rd Code Revision, the new Standard Framework Natural Gas Transmission and LNG Facility Usage Agreements (RAE Decision 257/2017 – Government Gazette B’ 1443/27.4.2017) were issued and are in force as of June 1st, 2017.

The 4th Revision of the NNGS Code (RAE Decision 123/2018- Government Gazette B’ 788/7.3.2018) comes in force July 1st 2018. The scope of the revision in question is the adaptation of the national regulatory framework to the European framework, following the enforcement of European Regulations (EU) No 459/2017 (on capacity allocation mechanisms in gas transmission systems and repealing Regulation (EU) No 984/2013), and (EU) No 1938/2017 (concerning measures to safeguard the security of gas supply and repealing Regulation (EU) No 994/2010). The main amendments concern the creation of a Virtual Trading Point, the Auction of within-day firm capacity products at Interconnection Points (including the Entry Point “Kipi”) and the operation of a Balancing Platform on which the TSO will conduct auctions of short-term standard products which are necessary for the balancing of the NNGS and on which Users shall also trade among themselves as well as with the TSO in order to balance their position.
Based on the 4th Code Revision, the new Standard Framework Natural Gas Transmission Usage Agreement (RAE Decision 507/2018 – Government Gazette B’ 2473/27.6.2018) – in force as of June 27, 2018, as well as the Balancing Manual (RAE Decision 546/2018 – Government Gazette B’ 2523/29.6.2018) – in force as of June 29,2018, were issued. In turn, by virtue of RAE Decision 821/2020 (Government Gazette Β’ 2056/30.05.2020) the Standard Framework Natural Gas Transmission and LNG Facility Usage Agreements were amended with the addition of new provisions, which are in force as of May 30, 2020. By virtue of RAE Decision 727/2020 (Government Gazette Β’ 1684/04.05.2020), the provision of the NNGS Code concerning the Revithoussa LNG Facility were amended, providing for additional flexibility to system users.

The 5th Revision of the NNGS Code (RAE Decision 1035/2020- Government Gazette B’ 2840/13.7.2018) entered into force on August 1st, 2020 except for provisions of articles 76, 76Α, 76Β και 76Γ of RAE Decision 727/2020 (Government Gazette Β’ 1684/04.05.2020) which will come in force September 1st 2020. The main amendments concern the introduction of three schemes of transmission capacity offer: a) Coupled Transmission Capacity, for which a pair of Coupled Entry and Exit Points of the NNGS is defined, b) Competing Transmission Capacity, which is offered for booking by the TSO at Capacity Competition Points (CCPs), which are defined as two or more Entry Points at which the TSO may dispose for booking to Transmission Users Competitive Transmission Capacities and c) Conditional Transmission Capacity. In the decision in question, a new article 15A is also added to the Tariff Regulation of the NNGS, which reflects the discount offered by the TSO for both the Conditional and Coupled Capacity. In addition, by virtue of the same Decision, the Balancing Manual of the NNGS is amended in relation to paragraphs of articles 3.2 (Μarginal buy price of gas and marginal sell price of gas) and 3.3 (Maximum and Lower Tolerance limit of Unit Price Offers).

The 6th Revision of the NNGS Code (RAE Decision 1433/2020 - Government Gazette Β΄4799 / 30.10.2020), was published on 30/10/2020, and the majority of its provisions entered into force on 1/1 /2021. The main amendments concern Chapter 11 of the Code regarding the Management of the LNG Facility and LNG services and specifically the adoption of a new format for the LNG Annual Planning process which is now carried out through an auction (LNG Auction), separate for each Year of LNG Planning. Also, a new article (A.110) was added to the Code related to the Transitional Arrangements for the Annual LNG Planning for year 2021. As a consequence, RAE Decision 1513/2020 (Government Gazette Β΄5094/ 18.11.2020) for the approval of the annual LNG planning parameters for the year 2021 was issued.

In addition, as a result of the 6th Revision, RAE Decision 1436/2020 (Government Gazette Β΄ 4803/ 30.10.2020) was issued approving the LNG Auction Manual which entered into force on 30/10/2020. This manual regulates every detail of the procedure and conditions for conducting LNG auctions, while determining the electronic background for LNG auctions, as the LNG Auction Exchange.

In turn, by virtue of RAE Decision 1435/2020 (Government Gazette Β’ 4802/30.10.2020) the Standard Contracts for the Transmission of Natural Gas and the Use of LNG Installation were amended in order for users to participate in an LNG Auction.

The 7th Revision of the NNGS Code (RAE Decision 735/2021 - Government Gazette B’ 4687/ 11.10.2021) which was published on 11/10 /2021, focuses on the access of third parties to the LNG Facility of Revithoussa and more specifically, among others, it provides for i) the introduction of a new product in the annual LNG Auction, and ii) the introduction of an additional cycle of re-declarations for the LNG Facility.

In addition, as a result of the 7th Revision, RAE Decision 736/2021 of September 30th, 2021, was published, approving the Amendment of the LNG Auction Manual. Subsequently, by virtue of RAE Decision 1060/2021 of 29.12.2021 (Government Gazette B' 37/10.1.2022) the 7th Revision of the Network Code was completed, with provisions for the development and operation of the Natural Gas Trading Platform in Greece , which is operated by the Hellenic Energy Exchange (HEnEx S.A) with the participation of the Transmission System Operator (DESFA). It is also provided that from the start of operation of the Trading Platform, the purchase and sale of Balancing Gas by the TSO, through Short-term Standardized Products, for the execution of Balancing Transactions is carried out exclusively on the said Trading Platform. At the same time, by virtue of RAE Decision 1061/2021 of 29.12.2021 (Government Gazette B' 49/12.1.2022) the Load Balancing Manual of the ESMFA was amended accordingly.

As a result of the 7th Revision and following relevant consultations, a series of Decisions concerning the Natural Gas Trading Platform was also published, namely: RAE Decision 60/2022 of 20.01.2022 (Government Gazette B' 454/7.2.2022)a which approves the operation of natural gas purchases under the "Hellenic Energy Exchange S.A." in accordance with the provisions of article 19 of Law 4425/2016 (A'185), RAE Decision 61/2022 of 20.01.2022 (Government Gazette B' 336/01.02.2022) which approves the Regulation of the Natural Gas Trading Platform Energy Exchange, in accordance with the provisions of article 19 of Law 4425/2016, as well as RAE Decision 62/2022 of 20.1.2022 (Government Gazette B 584/11.02.2022) where product specifications are approved of Natural Gas Trading of the Hellenic Energy Exchange, in accordance with the provisions of subsections 4.2.2 to 4.2.8 and 4.4.3.4 of the Natural Gas Trading Platform Regulation. The decision in question was amended by the 29.02.2024 E-49/2024 RAEWW Decision (Government Gazette B' 1610/11.03.2024). Also, RAE Decision 88/2022 of 27.01.2022 was published (Government Gazette B΄513/9.2.2022)α approving the anonymous company with the name "Energy Stock Exchange Clearing Company S.A." and the distinctive title "EnExClear S.A." as the Natural Gas Market Clearing Body (Natural Gas Trading Platform), in accordance with the provisions of article 19 of Law 4425/2016 (A' 185), and RAE Decision 89/2022 of 27.1.2022 (Government Gazette B ' 515/9.2.2022) where the Regulation for the settlement of Natural Gas Trading Transactions of the Energy Exchange is approved, in accordance with the provisions of article 19 of Law 4425/2016 (A' 185).

The 8th Revision of the Network Code (RAE Decision 645/2022 – Government Gazette B΄ 4269/11.08.2022) which was published on 11/08/2022, includes in Chapter 2A the provisions of RAE Decision 586/2022 (Government Gazette B' 3823/21.7.2022) regarding the amendment of the Code for the provision of Interruptible Transportation Services, as well as in the new Chapter 11A (articles 89A - 89K) the provisions of RAE Decision 590/2022 (Government Gazette B ' 4270/11.08.2022) regarding the provision of the Liquefied Natural Gas Truck Loading Service (LNG Service) at the Revythoussa LNG Terminal.

Also in relation to the LNG Service, by virtue of RAE Decision 591/2022 (Government Gazette B' 4321/12.08.2022) the Standard (LNG) Installation Framework Contract for Loading LNG Trucks is approved and by virtue of RAE Decision 592/2022 (Government Gazette B' 4344_16.8.2022), which determines the temporary tariff for the use of the (LNG) Truck Loading Station in Revythoussa, in accordance with paragraph 1 of article 15 and paragraph 5 of Article 88 of Law 4001/2011, for the years 2022 and 2023.

The 9th Revision of the Network Code ( RAEWW Decision Ε-143/2023 Government Gazette B' 5773/04.10.2023), which was published on 4.10.2023, amends provisions that refer to the procedure for conducting the Annual LNG Planning. Corresponding provisions are also amended in the NNGS ESFA Load Balancing Manual, by virtue of RAEWW Decision. Ε-145/2023 (Government Gazette B' 5771/4.10.2023).

As a result of the 9th Revision of the Network Code, the LNG Auctions Manual was amended in accordance with the 21.3.2024 RAEWW Decision 144/2023, (Government Gazette B' 5821/5.10.2023). By virtue of the 21.3.2024 RAEWW Decision E-146/2023 (Government Gazette B' 5828/5.10.2023), the Parameters of LNG Annual Planning for the Years 2024-2038 are approved. HenxeforthNow, the Annual LNG Planning is prepared every Year and covers each of the next 15 Years (instead of 5 years which was in force previously).

  • Tariff Regulation of Core Activities of the NNGS:

M.D.  4955/2006  (Government Gazette Β’ 360/27.3.2006) on the “Natural Gas Transmission and LNG Re-gasification Tariff“ was issued, which was amended by  MDs Δ1/23344/2006 (Government Gazette Β’ 1781/7.12.2006) and Δ1/5037/2007 (Government Gazette Β’ 379/20.3.2007), and  M.D.Δ1/Α/1110/9860/2010 (Government Gazette Β’ 747/31.5.2010) on the Amendment of the Natural Gas Transmission and LNG Re-gasification Tariff, which foresaw tariffs based on exit capacity charges-postage stamp, seized to be in force following the enforcement of the abovementioned NNGS Usage Tariffs, with the explicit exception of the provisions for the calculation of the Recoverable Difference, according to the provisions of article 22 of RAE’s decision No. 594/2012.

RAE’s decision No. 594/2012 (Government Gazette Β’ 2093/5.7.2012) approved the Tariff Regulation of Core Activities of the NNGS, by which a tariff system with independent entry-exit capacity charges was adopted, and RAE’s decision No 722/2012 (Government Gazette Β’ 2385/27.8.12) approved the NNGS Usage Tariffs. The tariff system in question was applicable from February 1, 2013 (replacing M.D. 4955/2006) until December 31, 2016.

The 1st Revision of the Tariff Regulation of the NNGS was approved by virtue of RAE Decision 339/2016 (Government Gazette B’ 3181/4.10.16), while by virtue of RAE Decision 352/2016 (Government Gazette B’ 3513/1.11.16)the corresponding NNGS Usage Tariffs were approved and were applicable from January 1, 2017. The provisions of the aforementioned 1st Revision of the Tariff Regulation are in accordance with the requirements of the framework that has developed according to the existing European Regulations EU 984/2013, EU 312/2014, and EU 703/2015 (see above).

RAE proceeded with the 2nd Revision of the Tariff Regulation of the NNGS with the main purpose being the completion and further improvement of the existing regulatory framework for the conformation of the NNGS Usage Tariffs in accordance with European Regulation (EU) 2017/460 (establishing a network code on harmonized transmission tariff structures for gas) in terms of the need to normalize the continuous variations of tariffs, and in particular the need to prevent extreme fluctuations in the future, but also due to the significant revenue over-recovery of the TSO for 2017. The revision in question was approved by virtue of RAE Decision 871/2017 (Government Gazette B’ 3720/20.10.2017), while by virtue of RAE Decision 997/2017 (Government Gazette B’ 4737/2017.29.12.2017 the revision of the NNGS Usage Tariffs was approved, in accordance with the 2nd Revision of the Tariff Regulation of the NNGS, which are applicable from May 1st, 2018. Subsequently, in July 2018 the 3rd Revision of the Tariff Regulation of the NNGS was issued, which contains intraday capacity products, capacity conversion service (to bundled capacity) and it does not affect the existing tariff usage decision (RAE Dec. 997/2017). The aforementioned revision was approved by virtue of RAE Dec. 644/2018 (Government Gazette Β’ 3000/25.07.2018)and corrective, as per the correction of faults, issue of Government Gazette Β’ 3892/07.09.2018), in force as of July 25th 2018.

In June 2019, RAE Dec. 540/2019 (Government Gazette Β’ 2436/20.06.2019) was published, which approved the Required Revenue for Transmission and LNG regasification and revised the NNGS Usage Tariffs as of September 1st 2019, in the context of the Regular Revision process foreseen in the Tariff Regulation.

By virtue of RAE Dec. 539/2019 (Government Gazette Β’ 2601/28.06.2019), the 4th Revision of the Tariff Regulation of the NNGS was approved, in accordance with the provisions of European Regulation (EU) 2017/460, which contains, inter alia, the conversion of the price reference methodology from postage stamp to Capacity Weighted Distance, the creation of a cluster entry point for Sidirokastro and Kipi, the development of two system exit clusters (North Zone and South Zone, from three already in place), the distinction between Transmission and Non-Transmission Regulated NNGS Services, as well as the distinction between Regulated LNG Services and Additional Regulated LNG Services, as well as the recovery of the Required Revenue for Transmission Services by 50% from Entry Points and 50% from Exit Points (from the existing 80/20 split between Exit and Entry Points. In turn, by virtue of RAE Dec. 566/2019 (Government Gazette Β’ 2724/2.07.2019), the revised NNGS Usage Tariffs were approved, in accordance with the 4th Revision of the Tariff Regulation, in force as of January 1st 2020.

Αs mentioned above, by virtue of RAE Dec. 1035/2020 (Government Gazette Β’ 2840/13.07.2020) the 4th Revision of the Tariff Regulation of the NNGS was amended with the addition of a new article (15A) referring to the Charge for the use of Conditional Transmission Capacity and Coupled Transmission Capacity, as a consequence of 5th Revision of the NNGS Code . Subsequently, RAE Dec. 1038/2020 (Government Gazette Β’ 3367/12.8.2020) approved the adjustment of NNGS Usage Tariffs in accordance with the amendment of the 4th Revision of the Tariff Regulation of the NNGS, in force as of January 1st, 2021.

RAE Decision 1434/2020 (Government Gazette B '4801/30.10.2020) approved the 5th Revision of the Tariff Regulation of the NNGS, effective from October 30th, 2020. The revision in question is a consequence of the 6th Revision of the NNGS Code, by which a new scheme was adopted for the LNG Annual Planning process.

RAEWW Decision E-59/2023 (Government Gazette B' 4192/29.6.2023) amended the Regulation on the Methodology of the Required Revenue and the Invoicing of the activities of the NNGS TSO - Sixth Revision, while by virtue of the of 22.6.2023 RAEWW Decision E-58/ 2023 of (Government Gazette B' 4335/7.7.2023) the Temporary Usage Tariff for the year 2023 was determined, with the start of application from 01.01.2023.

RAEWW Decision E-69/2023 (Government Gazette B' 7096/18.12.2023) approved the Allowed Revenue for the Regulatory Period 2024-2027, the Required Revenue for the year 2024 for the Transmission Service and the Basic LNG Installation Service, as well as the Adjustment of the NNGS Usage Tariff for the year 2024.

By virtue of RAEWW Decision E-152/2024 (Government Gazette B' 4909/27.08.2024) the Required Revenue for the year 2025 for the Transmission Service and the Basic LNG Installation Service, as well as the Adjustment of the NNGS Usage Tariff for the same year were approved.

3. Distribution Network Operation

4. Security of Supply

5. Climate Neutral Economy

The National Energy and Climate Plan formulates Greece’s policy on energy and climate change issues until 2030, taking into consideration the recommendations of the European Commission, as well as the UN goals for Sustainable Development, through the creation of road map with specific quantitative goals, priorities and policy measures for a broad spectrum of economic activities. The initial National Energy & Climate Plan, published in January 2019, foresees by 2030, 31% RES share in gross final energy consumption, 16,5% lignite share in electricity generation, reduction of greenhouse gasses by 32% compared to 1990 and improvement of energy efficiency in final energy consumption by 33%. However, new, more ambitious goals have been according to the ratification decision of the National Energy & Climate Plan (Gov. Gaz. Β’4893/31.12.2019) which foresees by 2030, at least 35% RES share in gross final energy consumption (with an average European target of 32%), 61% RES share participation in final electricity consumption and no lignite participation (delignitization) by 2028), reduction of greenhouse gasses by at least 42% compared to 1990 (in full agreement with the European target) and improvement of energy efficiency in final energy consumption by 38%.

a. Adjustment to Climate Change

Articles 42-45 of L.4414/2016 (Government Gazette A’ 149/9.8.2016) set the processes for creation and the minimum contents of National Strategy for the Adjustment to Climate Change, as well as the by Region Plans for Adjustment to Climate Change (its content was further specified by virtue of Ministerial Decision no. 11258/ Government Gazette B’ 873/16.3.2017). The National Strategy for the Adjustment to Climate Change sets the general goals and the means for the achievement of an effective strategy for the country’s adjustment to the framework set by the UN agreement, the Strategy of the EU and the European Directives for the Adjustment to Climate Change, also taking into consideration international experience. The necessary adjustment measures include a wide range of intervening actions which focus on the rational management of forests and waters, the maintaining of biodiversity, the adjustment of buildings and infrastructures to future extreme climate conditions, the protection of coastal regions from the rise of sea level. The creation of Regional Plans that follow focuses on the setting of ad hoc policy and priorities for measures on the basis of climate conditions and particular characteristics of every region.

By virtue of Law 4936/2022 (Government Gazette A' 105/27.05.2022) the National Climate Law is published, which establishes measures and policies for the country's adaptation to climate change and ensuring the decarbonization path by the year 2050. In particular, the following are established: a) measures and policies to strengthen adaptation to climate change at the lowest possible cost, b) intermediate targets for mitigating anthropogenic emissions for the years 2030 and 2040, c) indicators for monitoring progress towards achieving the relevant targets, d) procedures for evaluating and readjusting targets and taking additional measures, and e) measures to mitigate emissions from power generation, the building sector, transport and business. The creation of a carbon budgeting mechanism for the main sectors of the economy and the system of governance and participation for the undertaking of climate action is also foreseen.
b. RES and Greenhouse Gas Emissions

1. By virtue of L.4062/2012 (Government Gazette A’ 70/30.3.2012),Directive 2009/28/EC for the promotion of power generation from RES was incorporated into national legislation. Subsequently the provisions of Directive 2018/2001/EU, which repeals the aforementioned Directive were incorporated into national law by virtue of Law 5037/2023 (Government Gazette A'78/28.03.2023) see related section "Primary Legislation"), which modernizes the legislation on the use and production of electricity from renewable sources, including more specific provisions for the promotion of RES and the protection of the environment.

2. By virtue of Inter-ministerial Decision 48416/2037/E.103 (Government Gazette B’ 2516/7.11.2011) the compliance with the provisions of Directive 2009/31/EC is enacted, concerning the environmentally safe storage of CO2 in the geological formations within Greek territory, including the sea bed, the continental shelf and the subsoil. Also, by virtue of article 173 of Law 4964/2022 (Government Gazette A' 150/30.07.2022 - see also section "Primary Legislation"), provisions are provided for the storage of carbon dioxide by entities that hold the right or license for research and exploitation of hydrocarbons, as well as that for the activation of the rights of the entities to submit an application to the Hellenic Hydrocarbons and Energy Resources Management Company S.A. (HEREMA.).

3. By virtue of Inter-ministerial Decision 54409/2632 (Government Gazette B’ 1931 /27.12.2004) the compliance with the provisions of Directive 2003/87/EC is enacted, concerning the establishment of a greenhouse gas emission allowance trading scheme, Inter-ministerial Decision 181478/965/2017 (Government Gazette B' 3763/28.10.2017) amends and codifies Government Decree 54409/2632 with the main objective of integrating the rules of the European Emissions Trading System (ETS) of greenhouse gases and defining measures and processes aimed at limiting greenhouse gas emissions in a cost-effective and cost-effective manner.

Furthermore, Inter-ministerial Decision 105040/2297/2019 (Government Gazette B' 4315 /29.11.2019) amends Inter-ministerial decision 81478/965/2017 in compliance with Directive (EU) 2018/410, which in turn amended Directive 2003/87 /EC, with a view to enhancing cost-effective emission reductions and promoting low-carbon investments and Decision (EU) 2015/1814.

c. Energy Efficiency

Initially, in order for national legislation to comply with Directive 2006/32/EC  on energy end-use efficiency and energy services , L.3855/2010 (Government Gazette 95/23.6.2010) was issued enacting measures for the improvement of end-use energy efficiency, by which M.D. Δ5/Β/29891/2011 (Government Gazette 3254/30.12.2011) was issued enacting the obligations of energy distributors, distribution system operators and retail energy companies for the provision of information on final energy use. Subsequently, since the aforementioned Directive was repealed by Directive 2012/27/EE, the latter’s provisions were incorporated in national legislation by virtue of L.4342/2015 (Government Gazette 143/9.11.2015)By virtue of  L. 4342/2015M.D. 174063/28.03.2017 (Government Gazette B’ 1242/11.04.2017) was issued by which the Regulation for Operation of the Regime for Energy Efficiency Obligation was enacted.

Subsequently, by virtue of M.D ΥΠΕΝ/ΔΕΠΕΑ /102848/1035 (Government Gazette B' 4237/20.11.2019) the Regulation on the Operation of the Energy Efficiency Obligation Enforcement Regime is established, with a period of application of the regime from 1/1/2017 to 31/12/2020.

By virtue of M.D. ΥΠΕΝ/ΔΕΠΕΑ /24355/274 (Government Gazette B' 1125/4.4.2019) the Obliged Parties for the implementation of the Energy Efficiency Obligation Enforcement Regulation during the Reference Year 2019 are determined and the cumulative target for the year 2019 is distributed to the Obliged Parties, in accordance with the provisions of article 5 of the decree of the Ministry of Energy & Environment 174063/28.03.2017 "Regulation of the Operation of the Energy Performance Obligation Regime " (Β΄ 1242). Accordingly, by virtue of Ministerial Decisions ΥΠΕΝ/ΔΕΠΕΑ /17965/125 (Government Gazette B' 734/10.3.2020), ΥΠΕΝ/ΔΕΠΕΑ /73687/553/14.7.2022, ΥΠΕΝ/ΔΕΠΕΑ /41083/291/12.4.2023, as well as MD ΥΠΕΝ/ΔΕΠΕΑ/88074/1691/09.08.2024 the Obliged Parties for the implementation of the Energy Efficiency Obligation Enforcement Regulation are determined and the cumulative annual targets for reference years 2020, 2022, 2023 and 2024 are allocated to them.

Law 4843/2021_(Official Gazette A' 193/20.10.2021) incorporates Directive (EU) 2018/2002 of the European Parliament and of the Council of 11 December 2018 "on the amendment of Directive 2012/27/EU on energy efficiency", adaptation to Regulation 2018/1999/EU of the European Parliament and of the Council of 11 December 2018 on the governance of the Energy Union and Climate Action and to Delegated Regulation 2019/826/EU of the Commission, of March 4, 2019, "amending Annexes VIII and IX of Directive 2012/27/EU of the European Parliament and of the Council on the content of comprehensive assessments of efficient heating and cooling potential" and related regulations for energy efficiency in the building sector. Taking into consideration paragraph 1 of article 29 of the above law, as well as paragraph 6 of article 17 of Law 4936/2022 (A' 105) "National Climate Law" (see related sub-section "a. Adaptation to Climate Change" Ministerial Decision ΥΠΕΝ/ΔΕΠΕΑ/57295/426 (Government Gazette Β΄2898/8.6.2022) was issued, which establishes the Regulation for the Operation of the Energy Efficiency Obligation Enforcement Regime with a period of application of the regime from 1/1/2021 to 31/12/2030 .

By virtue of Inter-ministerial Decision ΥΠΕΝ/ΔΕΠΕΑ /68315/502 (Government Gazette B' 3424/2.07.2022) measures to improve energy efficiency and energy savings in buildings and facilities belonging to or used by Public Sector bodies are established. The aforementioned Inter-ministerial Decision is amended by Inter-ministerial Decision ΥΠΕΝ/ΔΕΠΕΑ /74248/559 (Government Gazette B' 3794/18.7.2022) and by Ministerial Decision ΥΠΕΝ/ΔΕΠΕΑ /68315/502 (Government Gazette B' 2692/9.5. 2024).

In addition, for reasons of harmonization of national legislation with Directive 2010/31/EU on the energy efficiency of buildings, Law 4122/2013 (Government Gazette A' 42/19.2.2013) was issued. Under the authorization of Law 4122/2013, the Inter-ministerial Decision of the Ministers of Finance and Environment & Energy ΥΠΕΝ/ΔΕΠΕΑ 178581 (Government Gazette B' 2367/12.07.2017) was issued, which establishes the Energy Performance of Buildings Regulation. The aforementioned Directive was amended by Directive (EU) 2018/844, which was incorporated into Greek legislation by Law 4685/2020 (Government Gazette A' 92/7.5.2020) entitled "Modernization of environmental legislation, integration of Directives 2018/844 and 2019/692 of the European Parliament and of the Council and other provisions".


6.Natural Gas Vehicles / CNG and LNG in Transport

a. By virtue of, the provisions of article 12 (Chapter A’) of L.4233/2014 (Government Gazette A’ 22/29.1.2014) introduced the possibility for the conversion of vehicle engines to dual fuel engines, i.e., for both conventional fuel and compressed natural gas (CNG). By virtue of above provision M.D. No. 10852/715/14/2014 (Government Gazette B’ 1466/05.06.2014) was issued setting the technical specifications for the special equipment necessary for  the use of CNG, as well as all the other terms and conditions for their inspection and safe operation.
Furthermore, M.D. No. 13935/930/2014 (Government Gazette B’ 674/18.3.2014), issued by virtue of article 45 of L. 2773/1999 as in force, set the competent authorities, the terms and conditions for the establishment and operation of CNG distribution and mixed liquid fuel stations.

Subsequently, by virtue of L.4439/2016 (Government Gazette A’ 222/30.11.2016), Directive 2014/94/EU on the deployment of alternative fuels infrastructure, including biomethane, was incorporated into Greek legislation enacting provisions regarding the simplification of the licensing procedure for refueling stations and other provisions relating to Fuel and Energy Supply stations, as well as the promotion of activities of vehicle repair shops related to alternative fuels.

Inter-ministerial Decision 77226/1 (Government Gazette B' 3824/31.10.2017), defines and specifies the required implementation details and technical specifications of the National Policy Framework for the development of the alternative fuel infrastructure market in the sector of transport and for the implementation of the relevant infrastructures.

Inter-ministerial Decision 93067/1083 (Government Gazette B' 5661/17.12.2018) defined the technical specifications, the competent bodies, the terms and conditions for the establishment and operation of natural gas stations with the installation of pressurized natural gas supply devices (refueling points) natural gas (CNG) in wheeled vehicles, such as, 1. pure compressed natural gas (CNG) stations or 2. mixed stations a. liquid fuels, LPG and compressed natural gas (CNG) or b. liquefied petroleum gas (LPG) and compressed natural gas (CNG) or c. liquid fuels and compressed natural gas (CNG). Subsequently, by virtue of Circular no. 166286/25.6.2021 of the Ministry of Infrastructure and Transport defines the minimum internal safety distances of pure or mixed CNG stations.

By virtue of MD. 12597/2022 (Government Gazette B` 259/ 28.1.2022) Inter-ministerial Decision of the Ministers of Environment and Energy and Infrastructure and Transport 93067/1083/20.11.2018 (Government Gazette Β΄ 5661/17.12.2018) is amended and is repealed by MD 11709/2024 (Official Gazette B' 402, 22.1.2024). This decision determines the terms, conditions, technical specifications and the procedure for issuing an establishment license and an operating license, for the installation and operation of pure or mixed gas stations for the storage and distribution of compressed natural gas/biomethane/Mixed natural gas - biomethane (CNG/CBG/ Bio-CNG) in wheeled vehicles, for public or private use. Also, the minimum safety distances of the characteristic elements of the installations of pure or mixed CNG/CBG/Bio-CNG stations are defined, b) the terms and conditions for the safe construction, operation, maintenance and inspection of the building and electromechanical installations of pure or mixed CNG/CBG/Bio-CNG stations, in order to distribute this gas as fuel for the movement of vehicles. c) the technical specifications of the building and electromechanical installations of pure or mixed CNG/CBG/Bio-CNG stations.

By virtue of MD 188543/2022 (Government Gazette B' 3368/1.7.2022) the terms, conditions and technical specifications for the installation of (LNG) supply devices (refueling points) in wheeled vehicles, in existing or licensed "Stations" Fuel and Energy Supply". The decision in question determines the procedure for issuing an operating license, for the installation and operation of pure or mixed LNG and/or L-CNG filling stations, for public or private use, including filling stations with equipment from a single operator, with a maximum storage capacity of 50 tons, as per the storage of liquefied natural gas.

Inter-ministerial Decision 118664 of the Ministry of Environment & Energy and the Ministry of Transport of 12.4.2023, (Government Gazette B' 2570/20.4.2023) determines the terms, conditions, technical specifications for the installation and operation of pure or mixed hydrogen stations in the gaseous phase for public or private use, including stations with single maximum storage unit equipment of 2.5 tons (tn), in terms of the availability of hydrogen for use in road transport. It is also provided that the mixed hydrogen filling stations, in addition to complying with the provisions of this decision, meet the terms and conditions of the respective provisions relating to the establishment and operation of liquid and/or alternative fuel filling stations in all areas that do not conflict with this decision.

Decision 378266 of the Minister of Transport, of 12.12.2023, (Government Gazette B' 7274/22.12.2023) determines the technical specifications and the conditions under which it becomes possible to drive vehicles with compressed natural gas (CNG) or liquefied natural gas (LNG), either as bi-fuel ) or as dual-fuel, as well as the terms and conditions of control and safe circulation of both converted and manufactured vehicles that use (CNG) or (LNG) for their propulsion. This Decision was amended by Decision of the Minister of Transport 100398 (Government Gazette B' 2475/26.04.2024).

b. By virtue of Presidential Decree 64/2019 (Gov. Gaz. Α’ 103/20.06.2019) the Regulation for the safe refueling of ships with LNG was enacted.

c. The harmonization of national legislation with Directive 2003/30/EC and the introduction of biofuels in the domestic market was enacted with the necessary amendment and completion of the regulatory framework for petroleum products, i.e. with L.3054/2002 (Government Gazette Α’ 230/2.10.02), L.3423/2005 (Government Gazette Α’ 304/13.12.05), L.3769/2009 (Government Gazette Α’ 105/1.7.09) and L.4062/2012 (Government Gazette Α’ 70/30.3.12).

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