Greek Legal Framework for Investment Incentives

The current Greek legal framework for investment incentives is governed by the new Development Law (Αναπτυξιακός Νόμος) 4887/2022, which has been aligned with the current EU directives (General Block Exemption Regulation – GBER).

The focus has shifted from “soft energy” toward “green transition” and “digital transformation”. In addition, the amount of the subsidy may no longer increase where costs are restructured, and work may strictly only commence after the application has been filed.

Note: Since Greek investment law is supplemented by ministerial decisions and specific calls for proposals (proclamations) for different economic sectors, the exact percentages (e.g. for advance payments or extensions) may vary slightly depending on the specific funding programme within Law 4887/2022.
Support for Electricity Generation from Renewable Energy Sources (Current Legal Framework)
Renewable Energy Sources – Support for Electricity Generation from RES in Greece (updated in line with Law 4887/2022 and current European programmes).

Support for Electricity Generation from Renewable Sources in Greece

The following article provides information on the current framework for the inclusion of investment projects in the new Development Law (Law 4887/2022), as well as on other funding instruments (NSRF/ESPA 2021–2027, Recovery and Resilience Facility – Greece 2.0) in the RES sector (wind power, photovoltaics, biomass, geothermal energy and storage systems).

Important Notice (2026):

The provisions of the old Law 3299/04 have been repealed. Under current legislation, classic photovoltaic parks that feed all of their energy into the grid (without batteries) are no longer supported by direct state grants. Their support instead takes the form of competitive procedures (tenders held by the regulatory authority RAAEY) securing an operating aid (Feed-in Premium). Direct grants under the Development Law or ESPA are primarily intended for PV installations with integrated storage (batteries), self-consumption systems (net billing) for businesses, energy communities and innovative projects.

Basic Elements of Inclusion under Law 4887/2022

1.1. Aid Rates and Zones (Regional Aid Map 2022–2027)

The aid rates depend on the size of the company and its location. Areas falling under the Just Transition Plan (e.g. Western Macedonia) benefit from the highest rates, which can reach up to 70–75%. Small and medium-sized enterprises (SMEs) generally receive a bonus of 10% to 20% compared with large enterprises.\

1.2. Minimum Total Budget for Investment Projects (Law 4887/2022)

For inclusion in the Development Law, the minimum investment amount is set as follows: large enterprises – €1,000,000; medium-sized enterprises – €500,000; small enterprises – €250,000; micro-enterprises – €100,000.

Definition of company size (in accordance with Recommendation 2003/361/EC): Micro-enterprise – fewer than 10 employees and turnover or balance sheet total up to €2 million. Small enterprise – fewer than 50 employees and turnover or balance sheet total up to €10 million. Medium-sized enterprise – fewer than 250 employees and turnover up to €50 million or balance sheet total up to €43 million. Large enterprise – exceeds the criteria for a medium-sized enterprise.

1.3. Types of Aid

Investment projects may receive the following forms of support: (a) tax exemption – exemption from income tax on undistributed profits (advantageous for profitable companies); (b) grant – a sum of money provided free of charge by the state to cover part of the costs (under the current law, mainly awarded to SMEs); (c) leasing subsidy (finance leasing) – covering part of the leasing instalments for the acquisition of new equipment; (d) subsidy for the cost of employment created – covering part of the wage costs for new jobs.

1.4. Investor’s Own Contribution

The investor’s own contribution (excluding state aid) must be no less than 25% of the eligible costs. For newly established companies, the paid-up share/company capital is treated as the own contribution. For existing companies, the own contribution may be covered either by a capital increase through new cash contributions or by the use of taxed reserves (provided these are not distributed for a certain period after completion of the investment).

Requirements, Expenses and Assessment Criteria (Updated under Law 4887/2022)

Requirements, Restrictions and Conditions for the Investment Loan

Where the investment project proposed for support also involves the use of a loan, the loan must: have a term of at least four (4) years; take the form of a bank loan or a bond (overdraft facilities are excluded); be raised exclusively for the implementation of the investment project, which must be expressly stated in the corresponding loan agreement; and have been approved by the bank (at least as a preliminary approval/letter of intent) at the time the application for support is submitted, with a clear indication of the amount, term, interest rate, grace period and security. The loan may also be raised in a foreign currency.
General Information on Eligible and Non-Eligible

Expenses (under Law 4887/2022)

Eligible expenses:
• Intangible assets and consultancy fees: supported exclusively for small and medium-sized enterprises (SMEs). The aid rate for consultancy fees may not exceed 50% of those fees and is subject to caps relative to the total budget.
• Tangible assets: construction of buildings, purchase and installation of new, modern machinery, automation systems, software.
• Purchase of land: eligible mainly for SMEs and only up to 10% of the total eligible investment costs.
Non-eligible expenses:
• Operating costs.
• Purchase of passenger cars (up to 6 seats) and office furniture (unless part of a special initial fit-out).
• Investments aimed merely at replacing existing machinery and equipment without expanding or changing the production process.
• Construction on land not owned by the investor: as a rule not supported. Exception: for investments in electricity generation from RES on land not owned by the entity, support is permitted provided that use of the land has been granted or leased for a period of at least twenty (20) years. The lease agreement must be duly registered with the competent land registry/cadastral office.

Basic Criteria for the Inclusion of Investment Projects (Assessment Criteria via the OPSKE System)

Proposals are now assessed under a strict points system:

Assessment of the investment entity: financial capacity, liquidity, the ability to cover the own contribution (at least 25%), and the experience of the shareholders are examined.
Economic-technical assessment and viability: the completeness of the business plan, the profit outlook and the degree of technological innovation are assessed.

Contribution to the objectives of the Development Law (ESG criteria): increase in employment (creation of new annual work units), location of the investment (e.g. preference for areas under the Just Transition Plan), and contribution to environmental protection, energy saving and the circular economy.

Assessment Criteria for Investments:

• The introduction of environmentally friendly technologies and the promotion of the green transition (e.g. energy efficiency, circular economy).
• The digital transformation of the company (Industry 4.0).
• The international competitiveness of the products and services, and in particular the company’s export orientation and the increase of exports.
• The innovation and quality of the products manufactured and services provided.
• The contribution of the investment to regional development, social cohesion and the creation or preservation of jobs.

Restructuring of Eligible Investment Costs

Upon certification of the completion and commencement of productive operation of the investment, a restructuring of the eligible expenses is permitted at the investor’s request. This restructuring may, however, in no case lead to an increase in the originally approved grant amount. Changes between expense categories are permitted, within certain limits (generally up to 10–15%), without prior approval, provided the character of the investment is not distorted.

Completion Deadline – Possibility of Extension

The deadline set in the approval decision for completion of the investment (generally up to 3 years) may be extended. Under Law 4887/2022, the extension may not exceed one third (1/3) of the original deadline (generally 1 additional year), provided that: (a) the application is submitted before expiry of the original deadline; and (b) a minimum percentage of the approved project (generally 25% or 50%, depending on the scheme) has been implemented and certified. In cases of proven force majeure, the deadline may be extended by a period corresponding to the delay caused by the event, without the prior implementation of a percentage of the project being required, provided the event occurred within the approved deadline.

Commencement of Implementation of Investment Projects

Work on the investment project may only commence after the application for inclusion in Development Law 4887/2022 has been submitted (on account of the incentive-effect rule). Expenses incurred before the date the application is filed (with the exception of certain preliminary studies, where provided for) are not eligible and will be rejected. Commencement of implementation prior to publication of the approval decision is undertaken solely at the investor’s own risk and does not bind the assessment committee or the administration as regards the final inclusion of the investment.
Requirements and Restrictions for the Support of Equipment Leasing
Support for finance leasing for the acquisition of new, modern machinery and equipment is granted on condition that the leasing agreement contains the mandatory clause on the purchase of the equipment and the transfer of ownership to the company upon expiry of the leasing agreement. The term of the agreement may not exceed the duration of the long-term obligation to maintain the investment (generally 3–5 years).

Payment of the Investment Grant

The grant amount is paid in instalments as follows: part of the grant (generally 25% to 50%) may be paid after the implementation and certification of a corresponding percentage of the physical and financial subject-matter of the investment by the competent inspection body. The remaining balance of the grant is paid after certification of the completion and commencement of productive operation of the investment. An advance payment is possible (in certain support schemes up to 100% of the grant amount, though usually a lower percentage), provided that a letter of guarantee (bank guarantee) for the same amount, plus a surcharge (generally 10%), is submitted by a bank lawfully operating in Greece or in an EU member state.