Legal framework for PV systems in Greece

Note:

The legal framework currently in force is shaped mainly by the provisions of Laws No. 4685/2020, No. 4964/2022 and No. 5037/2023, which have replaced and/or supplemented the earlier provisions of Laws No. 4093/2012, 3851/2010, 3468/2006 and related legislation.

National Targets – Revised NECP 2024–2030

Under the revised National Energy and Climate Plan (NECP 2024–2030) and the objectives of European Directive 2023/2413 (RED III), the national targets include:

• A share of renewable energy in gross final energy consumption of at least 35% by 2030
• A share of renewable energy in gross electricity consumption of at least 80% by 2030
• Installed photovoltaic capacity of over 13 GW by 2030
• Integration of energy storage as an integral part of the energy system
• At least 42% renewable energy in final energy consumption for heating and cooling by 2030
• At least 29% renewable energy in final energy consumption in the transport sector by 2030

Permitting Procedure under Current Law

1.1 Distinction by Installed Capacity

Under Law No. 4685/2020, the permitting procedure differs according to installed capacity:

1.2 Installations with a Capacity of over 1 MW

Production Licence

Installations with an installed capacity of over 1 MW require a production licence, issued by RAE on the basis of the following criteria:

• National security and public health
• Energy efficiency and project maturity
• Technical maturity of the installation
• Compliance with national spatial planning
• Environmental protection

The permitting procedure is carried out digitally via the information system for renewable energy (PSAPE).

Individual Procedural Steps

• Determination of the connection point: by RAE in cooperation with ADMIE or DEDDIE within 20 days of the application.
• Review of criteria: by RAE within 2 months of submission of complete documents. The application is deemed complete if no additional documents are requested within 30 days.
• Publication of the decision: on the RAE website. An objection may be raised within 15 days. This is reviewed within 20 days – if this period elapses without a decision, the objection is deemed rejected.
• Register: all decisions are entered in RAE’s electronic register for renewable energy.
• Financing: the financing parties are reviewed by RAE and noted in the licence, provided they meet the requirements.

Duration of the Production Licence

It is issued for 25 years, with the possibility of extension for the same period.

A building permit must be issued within 30 months, failing which the production licence automatically lapses.

Amendment of Licence Details

An application for amendment is decided within 60 days. An increase in capacity of up to 10% requires only a notification, not an amendment.

Transfer of the Production Licence

A transfer is permitted with RAE’s approval, provided the statutory criteria are met. The deadline for the building permit is not extended by the transfer.

1.3 Installations with a Capacity of up to 1 MW

Exemption from the Production Licence – Renewable Energy Producer Certificate

Under Law No. 4685/2020, operators of photovoltaic installations with a capacity of up to 1 MW are exempt from the obligation to obtain a production licence. Instead, a renewable energy producer certificate is issued via PSAPE.

The exemption applies to all installations operated by the same operator on a given plot of land. In this case, remuneration is calculated on the basis of the total capacity of all installations, not per individual installation.

The competent body for the allocation of project rights and the grid connection is DEDDIE S.A. The application and the required documents are submitted there. After the connection conditions have been granted, the applicable fee is paid and the connection agreement is then signed.

Note: in areas where energy generation is “saturated” or restricted, installations in this category are given priority in the assessment.

Transferability of Installations up to 1 MW

Special restrictions on transferability apply to installations up to 1 MW:

• The installations may not be sold before commissioning, except in the case of a transfer to a legal entity whose entire company capital belongs to the transferor.
• After the transfer, DEDDIE is obliged to take all necessary steps to connect the installation, provided there is no technical ground for refusal.

Transfer of Company Shares:

The transfer of shares in the operating company to a third party constitutes an alternative, indirect form of transfer of ownership.

The following should, however, be noted:

• Transferring shares before the installation is connected and commissioned carries a significant risk of refusal by the competent body. The view that a transfer before connection is permissible has meanwhile also been abandoned by DAPEEP S.A. itself.

It is therefore expressly recommended:

• to obtain prior approval from the competent body before any transfer, or
• to carry out the transfer only after the installation has been connected and commissioned.

In the event of a transfer prior to connection, the tax ID (AFM) of the operating company may not change. DEDDIE is competent until connection; DAPEEP S.A. thereafter, following connection and commissioning.

Special Rule for Farmers:

Permits issued to farmers may not be transferred for five years from the date of issue. The sole exception is succession by inheritance.

Permitting Exemptions for Installations up to 1 MW

The permitting procedure for photovoltaic installations up to 1 MW has been considerably simplified and accelerated by Law No. 4685/2020. In particular:

• No production licence, building permit or operating licence is required.
• No prior environmental assessment opinion is required.
• Responsibility for the permit lies with DEDDIE, which considerably shortens the administrative process.

Environmental Assessment:

For ground-mounted photovoltaic installations up to 500 kW, as well as for installations on buildings, no environmental impact study is required. Instead, an exemption certificate is issued by the competent region within 20 days.

When the certificate is issued, in addition to capacity, it is also checked whether the land falls within a NATURA 2000 area or lies less than 150 metres from another approved agricultural holding.

For ground-mounted installations over 500 kW and up to 1 MW, the environmental review takes place under a simplified procedure pursuant to Law No. 4685/2020.

Building Permit / Small-Scale Works Permit

For all photovoltaic projects, regardless of category, a building permit or a permit for small-scale works from the competent building authority (YDOM) is required.

Caution: the requirements for issuing these permits change regularly through ministerial decisions. It is recommended to check the applicable legal position before filing the application. The exact procedure depends on the specific technical characteristics of the installation.

Grid Connection Agreement

Key milestones for completing the permitting procedure and commissioning are:

• Conclusion of a grid connection agreement with DEDDIE (for the distribution network) or ADMIE (for the transmission system)
• Conclusion of an operating aid agreement (SLE) with DAPEEP S.A.

These agreements are mandatory for all of the project categories described above.

Security

In certain cases, a security must be provided before or upon signature of the grid connection agreement:

• For installations that do not require a production licence, an exclusive connection deadline is set in the agreement. Failure to meet it results in forfeiture of the security.
• The amount of the security is €150/kW, under Ministerial Decision YA PE/F1/oik.24839/25.11.2010 and any subsequent amendments.

Note:

The exact amount and conditions of the security may have been amended by more recent ministerial decisions. A check with DEDDIE or RAE is required.

Exceptions:

Agreements signed before the relevant provisions entered into force, as well as projects held by holders of a production licence.

The security is refunded after commissioning, evidenced by a corresponding certificate.

In addition, a bank or credit institution’s financing commitment must be submitted.

Conclusion and Signature of the Agreement

The grid connection agreement with DEDDIE is concluded:

• at the operator’s request
• after payment of the connection fee
• where required, after payment of the security and submission of the financing commitment

Deadlines for Concluding the Agreement:

Obligations of the Network Operator

The network operator is obliged to complete the connection works within the following periods:

In exceptional cases, an extension of the above deadlines may be granted.

Building Permit

Installation Permit

Competent body: the competent region or the Secretary-General of the Decentralised Administration. It is issued within 15 days of completion of the review (30 days from the application).

Required Documents:

• Grid connection offer
• Decision approving the environmental terms (AEPO)
• Forestry authority permit (where required)
• Further permits relating to land use

Grid Connection Offer

Issued by ADMIE or DEDDIE within 4 months of the application. It becomes legally effective upon issue of the AEPO or the corresponding exemption certificate.

Environmental Permit – AEPO

Carried out electronically via the Electronic Environmental Register (HPM). It is issued within 4 months of submission of complete documents. Validity: 10 years, with the possibility of extension provided the application is filed 6 months before expiry.

Consulted bodies: heritage authorities, civil aviation authority, forestry authority, agriculture authority, army general staff, Greek National Tourism Organisation (EOT).

Duration of the Installation Permit

Valid for 2 years, with the possibility of extension for the same period.

Operating Licence

Issued within a preclusive deadline of 20 days. It is valid for 20 years for photovoltaic installations, with the possibility of extension.

Transfer of the Installation (after Grid Connection)

Possible at any time after the grid connection. The new owner assumes the rights and obligations toward DAPEEP S.A. RAE issues the corresponding decision on the transfer of the production licence and the operating licence. Alternatively, a transfer of company shares is also possible.

Electronic Register for Renewable Energy (RES Register)

Maintained by RAE via PSAPE and comprising:

• Production licences and renewable energy producer certificates
• Installation and operating licences
• Operating aid agreements (SLE)
• Every amendment or transfer

Agreement on the Sale of the Electricity Generated – Current System

Transition from Guaranteed Prices to Competitive Procedures

Important update: the fixed feed-in tariff system described in the original text on the basis of Law No. 4093/2012 has been abolished for new installations. The prices given in the table (€180/MWh, etc.) no longer apply to new projects. This system was replaced by Law No. 4414/2016 and further developed by Laws No. 4685/2020 and No. 4964/2022.

The support system currently in force works as follows:

1. a) Operating Aid Agreements (SLE) – Contract for Difference (CfD)

• They have replaced the earlier power purchase agreements (SPE).
• They are based on a variable premium (sliding premium): the producer receives the difference between the reference price, determined by auction, and the market price (wholesale electricity price).
• The competent contracting body is DAPEEP S.A.

1. b) Competitive Procedures (Auctions)

• Conducted by RAE, either technology-specific or mixed.
• They set the reference price for each successful installation.
• Indicative values from more recent auctions (2023–2025) for photovoltaics ranged between €40–65/MWh, depending on year and category.

Note: the exact reference prices are determined exclusively by the auction results. Current information can be found at www.rae.gr.

Term of the Operating Aid Agreement

The SLE is concluded for a period of 20 years from the date the installation is commissioned. An extension is possible by mutual written agreement, provided the production licence remains valid.

Transitional Arrangements – Old SPE

For installations that were subject to the old system of guaranteed prices (SPE under Law No. 3468/2006 and No. 4093/2012) and remain in operation, the following applies:

• The original contractual terms remain valid, provided the contractual obligations are complied with.
• Administration is carried out by DAPEEP S.A.
• Transitional arrangements on price adjustments or changes to the terms may apply.

For installations under the old regime, an immediate legal review of their current situation is recommended.

Energy Balancing (Net Metering / Virtual Net Metering)

For smaller installations (mainly private and commercial), the balancing system applies as an alternative.

11. The Agreement on the Sale of the Electricity Generated

Term of the Agreement

The agreement with the competent administrator or market operator on the sale of the electricity generated is concluded, depending on the applicable support scheme and the connection method of the project, for a period of twenty (20) years, unless the applicable legal framework, the auction notice or the model agreement provides otherwise.

An extension or renewal of the agreement is only possible where expressly provided for by the applicable regulatory framework, or on the basis of a written agreement between the parties, provided the installation continues to meet the legal and technical requirements then in force.

Remuneration Rules and Price Determination

For photovoltaic projects in Greece, the former general system of a guaranteed feed-in price has largely been replaced by the support framework currently in force, as shaped by subsequent amendments to Greek energy law. Under the current system, remuneration is generally determined in one of the following ways:

• through participation in competitive procedures/auctions and the award of a reference price or operating aid,
• through sale of the energy generated on the wholesale market, with or without additional support,
• through self-generation, energy balancing or virtual energy balancing systems, where permitted,
• through special transitional or preferential arrangements for installations lawfully subject to older regimes.

For projects that had already concluded an effective agreement, or had filed a complete application, under the former legal framework, the applicable remuneration continues to be governed by the transitional provisions and the principle of protection of acquired rights, subject to the specific conditions and deadlines of the relevant laws and ministerial decisions.

Consequently, historical tables of guaranteed prices that applied to older photovoltaic projects are today to be regarded only as transitional or legacy arrangements and cannot be used as a basis for new projects, unless the project expressly falls under a favourable transitional arrangement.

Remuneration Rules Applicable to New Photovoltaic Projects

For new photovoltaic projects, remuneration no longer follows the old fixed system of a guaranteed feed-in price. Instead, it is determined by the applicable regulatory framework and generally depends on:

• participation in tender procedures,
• inclusion in an operating aid scheme,
• the application of special rules for self-generation or energy communities,
• any special transitional provisions for projects that have already become permit-ready.

The exact remuneration depends on the size of the project, the type of connection, whether it is an interconnected system or a non-interconnected island network, and whether the project participates in an auction or is subject to a special support scheme.

12. Further Important Changes and Innovations

Offshore Installations

Offshore renewable energy installations are now handled under a more orderly and modern permitting regime. Their development is subject to special spatial-planning, environmental and permitting conditions and, where required, competitive allocation procedures.

The competent authorities and the individual permitting steps are laid down by special legislation and the ministerial decisions currently in force for offshore renewable energy installations.

Redistribution of the Special Renewable Energy Levy

The special renewable energy levy remains an important instrument of Greek energy law; however, its distribution and administration are governed by the legal and regulatory framework currently in force. Part of the revenue is passed on to the local communities and municipalities in which the renewable energy projects are built, while the remainder is allocated, in accordance with applicable law, to special accounts or funds for public purposes.

The purpose of the arrangement remains to strengthen local acceptance of renewable energy projects and to compensate the municipalities hosting such installations. The exact percentages and conditions of application must be checked against the rules in force in each case.

Special Rules for Agricultural Land

Additional restrictions and special spatial-planning requirements apply to photovoltaic installations on agricultural land, in particular land of high productivity. The permissibility of projects depends on the applicable spatial-planning and agricultural-protection provisions, as well as any quotas, exclusion zones or special permit requirements.

A fixed historical percentage should not be cited unless it expressly continues to apply to the project category and region concerned.

Rooftop Installations

A different and generally simpler regime applies to photovoltaic installations on rooftops than to ground-mounted installations. Depending on the technical characteristics and intended use, simplified permitting procedures, exemptions from certain permits, or special self-generation rules may apply.

The exact procedure depends on whether the system is connected to a building, whether it serves self-consumption or grid feed-in, and whether it is subject to the applicable balancing or electricity sale regime.

13. Summary

In summary, the current Greek legal framework for photovoltaic installations has moved away from the old model of fixed, guaranteed feed-in remuneration and has transitioned to a more modern system based on:

• simplification of the permitting procedure for smaller installations,
• digitalisation and acceleration of permits,
• remuneration through the market and competitive procedures,
• special rules for self-generation, rooftop installations and energy communities,
• stricter but orderly environmental and spatial control,
• adaptation of the support framework with the aim of aligning with European law and the energy transition.

KPAG Kosmidis & Partner / June 2026 / All information on these pages is provided without guarantee or liability.