Photovoltaics – Renewable Energies

Yes. The investment is open to all interested parties wishing to invest on Greek territory, regardless of nationality – both European and international investors.

Fundamentally. The fixed feed-in tariffs still in force in 2013 (in some cases up to €500/MWh) have been abolished for new projects. The market has matured: large projects today are financed through competitive auctions (market premiums) or, increasingly, through private power purchase agreements (PPAs) with industry. Installed capacity has also grown massively – from around 900 MW (2013) to now more than 13 GW of renewable energy. The central challenge today no longer lies in the level of remuneration, but in securing a grid connection (see Section 3).

The relevant laws are Law No. 4685/2020 (“Phase A” – modernisation of environmental law), Law No. 4951/2022 (“Phase B” – modernisation of renewable energy permitting), Law No. 4964/2022 and Law No. 5037/2023. These have replaced and/or supplemented the earlier provisions of Laws No. 4093/2012, 3851/2010 and 3468/2006.

Primarily the installed capacity of the installation. The decisive threshold today is 1 megawatt (MW) – raised by Law No. 4685/2020 from the previous 500 kW.

A significantly simplified procedure applies to this category. Not required are:

• a producer certificate (exceptions apply for grid-congested areas or non-interconnected islands),
• a separate installation and operating licence,
• a full environmental impact assessment (Category B generally suffices),
• a classic building permit.
Required, however, are a permit for small-scale works, a binding grid connection offer together with a grid connection agreement with the distribution system operator DEDDIE, and an agreement on the sale or operating aid support of the electricity generated with DAPEEP.

Stricter, digitalised rules apply to larger installations. Required in particular are:
• the producer certificate (Βεβαίωση Παραγωγού) from RAAEY,
• an environmental permit – standard conditions (ΠΠΔ) for 1–10 MW, a full environmental impact assessment (ΑΕΠΟ) above 10 MW,
• an installation permit and an operating licence,
• a grid connection agreement with DEDDIE or ADMIE,
• an operating aid agreement with DAPEEP following successful participation in a RAAEY tender.

The renewable energy producer certificate (Βεβαίωση Παραγωγού ΑΠΕ) has, since Law No. 4685/2020, replaced the former, lengthy production licence. It is issued by RAAEY (formerly RAE) via the digital information system PSAPE, is valid for 25 years with the possibility of extension, and is only required for installations over 1 MW. A building permit must be obtained within 30 months of issue, failing which the certificate automatically lapses.

Projects are divided into three categories: Category A1 (high environmental impact – full environmental impact assessment and AEPO by the Ministry of Environment, YPEN), Category A2 (medium impact – AEPO by the competent decentralised administration), and Category B (low impact – mere electronic subjection to standard conditions, no AEPO required). PV installations up to 1 MW generally fall under Category B, provided they are not located in sensitive areas such as Natura 2000 zones or forest land. Ground-mounted installations up to 500 kW and rooftop installations receive an exemption certificate within 20 days.

As a rule, no. For most photovoltaic projects, a permit for small-scale works (ΕΕΜΚ) under Article 29 of Law No. 4495/2017, issued by the competent building authority (ΥΔΟΜ), is sufficient. A full building permit is only required exceptionally, for example for certain tracker systems or additional structures.

The overall duration has been significantly shortened compared with the past (in some cases 36 to 60 months); the Greek Ministry of Environment puts the core process at around 14 months. Individual statutory deadlines: determination of the grid connection point 20 days, review of RAAEY criteria 2 months, environmental permit or PPD classification around 4 months, installation permit 15 to 30 days, operating licence 20 days. In practice, however, the actual overall duration of a project depends significantly on the availability of a grid connection (see the following section).

DEDDIE is responsible for the distribution network (the former network operations of DEI/PPC), and ADMIE for the transmission network. Statutory deadlines for concluding the grid connection agreement are 3 months (installations without a producer certificate, up to 1 MW) or 6 months (installations with a producer certificate) from submission of complete documents. The network operator must complete the actual connection works, depending on complexity, within 12 to 24 months of contract signature.

Upon acceptance of the final grid connection offer, a letter of guarantee must be submitted to the competent network operator. Acceptance itself must take place within 2 months, failing which the offer automatically lapses. The guarantee must run for at least 2 years and be extended until commissioning. The amounts are staggered by capacity (indicative values): up to 1 MW €60,000 per MW, 1 to 10 MW €30,000 per MW, 10 to 100 MW €20,000 per MW, over 100 MW €10,000 per MW – on the grid connection agreement taking effect, the amount is reduced to a quarter. Photovoltaic installations on buildings are exempt from this obligation regardless of capacity. As the amounts may have been adjusted by more recent ministerial decisions, we recommend a current check with DEDDIE, ADMIE or RAAEY.

The greatest practical obstacle for new projects at present is no longer the permitting procedure itself, but the limited capacity of the Greek electricity grid to absorb further installations. Photovoltaic and wind installations with a capacity of around 15 GW are already installed, final grid connection offers already exist for a further approximately 15 GW, and applications for a further approximately 50 GW are pending before RAAEY – against actual grid capacity of currently only around 19 GW. The network operator therefore prioritises the award of final grid connection offers according to criteria such as total capacity, location, existing storage capacity and existing power purchase agreements. Construction should on no account begin without a secured grid connection offer.

If the final grid connection offer is not accepted within 2 months, it automatically lapses by operation of law. If the guarantee is not extended at least three working days before expiry, or if the grid connection agreement does not take effect in time, the letter of guarantee is forfeited in favour of the special account for renewable energy administered by DAPEEP.

Since Law No. 4414/2016, no longer through fixed feed-in tariffs, but through operating aid agreements (ΣΛΕ) in the form of a sliding market premium (Contract for Difference): the producer sells the electricity on the market and additionally receives the difference between a competitively determined reference price and the market price. Reference prices from more recent auctions (2023–2025) for photovoltaics were generally between €40 and €65/MWh. The contract term is generally 20 years from commissioning. Alternatively, producers may market their electricity directly through bilateral power purchase agreements (PPAs) with large consumers, entirely without state support.

For smaller installations, particularly rooftop installations, net billing has meanwhile become the central model and has largely replaced the earlier net metering (legal basis: Law No. 4513/2018, as amended by Law No. 5037/2023). Under this system, the electricity generated is offset financially – rather than purely by quantity – against consumption, often combined with state support programmes and battery storage. Virtual net metering extends this offsetting to several consumption points of the same operator.

No. Historical price tables – including the figures of up to €500/MWh sometimes cited – no longer apply to new projects. Only installations still operating under the old power purchase agreements (ΣΠΕ under Law No. 3468/2006 or 4093/2012) continue to enjoy protection of legitimate expectations under the original conditions. For such existing installations, we recommend an individual legal review.

For classic PV parks feeding fully into the grid without storage, generally no longer – their support is provided exclusively through the competitive RAAEY tenders (see Section 4). Direct grants under Development Law No. 4887/2022 or the ESPA 2021–2027 funding programme, however, are provided for PV installations with integrated battery storage, commercial net-billing self-consumption installations, energy communities and innovative projects.

Large enterprises: €1,000,000. Medium-sized enterprises: €500,000. Small enterprises: €250,000. Micro-enterprises: €100,000. In all cases, the investor's own contribution must be at least 25% of the eligible costs.

The aid rates depend on location and company size and can reach up to 70–75% in “just transition” areas (e.g. Western Macedonia); small and medium-sized enterprises receive an additional bonus of 10 to 20%. The types of aid available include: exemption from income tax on undistributed profits, a direct grant (mainly for SMEs), a subsidy toward leasing instalments for new equipment, and a subsidy toward the wage costs of newly created jobs.

For installations up to 1 MW, generally not – the exception is a transfer to a legal entity whose entire company capital belongs to the previous operator. As an indirect alternative, a transfer of shares in the operating company may be considered; however, we tend to advise against this before grid connection, as DAPEEP has meanwhile abandoned its previously more generous approval practice and there is a significant risk of refusal. We recommend either prior approval from the competent authority or carrying out the transfer only after grid connection and commissioning. Farmers are additionally subject to a five-year transfer ban from the date the permit is granted; the only exception is succession by inheritance.

Yes. Particularly on land of high agricultural productivity, strict spatial-planning and agricultural-protection restrictions apply, including regional area quotas, exclusion zones and special permit requirements. The percentages permissible in any given case must be checked against the currently applicable rules for the region concerned.

Yes, a significantly simpler regime applies to rooftop installations than to ground-mounted installations – among other things, the letter-of-guarantee obligation does not apply, regardless of installed capacity. The exact procedure depends on whether the installation serves self-consumption under net billing or full grid feed-in.

No. Offshore installations are subject to their own, more specific permitting and spatial-planning regime, with separate spatial-planning, environmental and competitive allocation procedures, the details of which are laid down by special ministerial decisions.

Part of the revenue from renewable energy installations is returned to the municipalities in which the projects are built – among other things, to directly reduce the electricity costs of local households, and in favour of the Green Fund for environmental measures. Self-suppliers and certain smaller installation categories are exempt from this levy.

No. The temporary suspension of new and pending applications for production licences and grid connection offers imposed by ministerial decision in August 2012 was lifted long ago. Today, the much faster digital procedure described above applies, under Laws No. 4685/2020, 4951/2022 and 5037/2023.

No. This extraordinary crisis surcharge of 25 to 30% (depending on the date of commissioning) applied exclusively to revenue from the period between 1 July 2012 and 30 June 2014 and has definitively expired. The separate special levy on windfall profits from the 2022/2023 energy crisis (Law No. 4986/2022, implementing EU Regulation 2022/1854) likewise applied only to the period September 2022 to June 2023 and has since ended as well. The two measures are unrelated to one another.