EU energy communities policy tracker

Through the Technical Support Instrument, two stakeholder consultations were held, which were of high quality. Invitations were sent well in advance, with a clear agenda and contextualisation of the process, while surveys were also deployed to share available data and evaluate the proposed measures. Various stakeholders were invited (e.g., civil society, DSO, TSO, electricity and heat suppliers), but local authorities were not present at the meetings. Also, the procedure lacked representation from social representatives, directly working with vulnerable groups. Lastly, the consultations were by invite-only, failing to transparently and openly include broader segments of society. 

The general online consultation opened on a Friday night, remaining open for two weeks (which is the minimum length proposed by the Commission under the Better Regulation guidelines).

Various Ministries were involved during the drafting of the Plan, including the Finance, Infrastructure and Transportation, Environment and Energy, Social Cohesion and Family Affairs, Maritime and Islands Policy Ministries. The government departments handling the Recovery Facility and Cohesion Funds were also present during the consultations.

During the implementation phase, the following Ministries have been explicitly designated as "Implementation Bodies": the Ministry of Environment and Energy; • the Ministry of Social Cohesion and Family; • the Ministry of Education, Religious Affairs, and Sports; • the Ministry of Development; and • the Ministry of Infrastructure and Transportation.

The two targeted stakeholder consultations that occurred during the winter and spring of 2025 gave stakeholders the opportunity to propose measures proactively, before a first list was drafted.

On the implementation, the Plan will include the "organisation of road shows, info days and Local Stakeholder Forums in collaboration with local and regional authorities, with a cumulative total of 20 high impact, national-scale events over six years, to be delivered by Q2 2032". 

However, 1) the national scale of the purported events might not be the most accessible format for regional/rural stakeholders, and 2) the number of events (20) lacks ambition, considering the urgency to communicate to the general public the importance of ETS2 (and the SCF). 

The invitations for the stakeholder consultations were sent well in advance, giving enough time for participants to prepare. Post-consultations surveys were sent to allow for stakeholders to provide additional input. However, the short consultation period for the broad online consultation (less than weeks in working days) right before the summer holidays, constrained broad public participation.

While stakeholders from the energy and environment sectors were well represented in the consultations (NGOs, energy suppliers, DSO, TSO), key social stakeholders and/or representative organisations were missing, including advocates for the houseless, migrants/refugees, young people, and people with disabilities.

Many of the civil society proposals tabled during the targeted stakeholder consultations were not taken into account in the draft Plan. This includes proposals around supporting energy communities, and deep renovations of buildings prioritising worst performing buildings.

This issue to set up a permanent monitoring committee to ensure transparency in the Plan's implementation was brought up repeatedly by civil society during the targeted stakeholder consultations. It is currently not foreseen in the Plan, nor has it been communicated by the Ministry of Environment and Energy.

Law 5294/08.04.2026 (Government Gazette 58/A') established the Coordinating Authority for the Social Climate Fund (CA-SCF), but this is largely focused on the technocratic compliance of the Plan, rather than offering meaningful space for stakeholder inclusion and oversight. 

While efforts were made to include local authorities (targeted surveys were sent by e-mail, and the national network of municipalities was invited to the targeted stakeholder consultations), they did not actively partake in the consultations. Civil society representatives made specific calls for 'open day'-like events to be organised in partnership with various municipalities across the country, informing the general public about the effects of ETS2 and opportunities from the SCF, but ultimately these were not taken up.

The report on which the Greek SCP is based on explicitly adopts the definition of energy poverty from the Energy Efficiency Directive (EED) (Directive (EU) 2023/1791)

The Plan across its various investments looks at economic KPIs for vulnerability, but also social (e.g., gender, age, students, and people with disabilities) as well as geography (households in outermost or particularly cold areas). 

Investment 50 foresees the creation of 13 One stop shops (€17.8 mil.), one per Region, that will provide free guidance and advisory support to vulnerable households and microenterprises. Support is provided for a switch to clean heating and cooling technologies, clean transportation, building renovations and ultimately navigating the funding application process.

Unlike in the draft version of the Plan, the final Plan does not utilise existing existing chambers of commerce and local community centers, that can help microenterprises and vulnerable households respectively access relevant information. Opting instead for new tenders awarded to private/public entities. No reference is made to utilising social economy actors (like energy communities) as stakeholders when staffing the OSS. Moreover, the regional dimension of the OSS is too macro-level to provide the (hyper) local support needed for vulnerable households. 

Positively, Investment 52 foresees the issuance of Energy Performance Certificates (€32.3 mil.), providing fully subsidised issuance of 190,500 EPCs for vulnerable households, so that they can seamlessly participate in housing renovation programs.

Various measures in the transport component (e.g., M5.1, M5.4) are also meant to facilitate the access of people with disabilities to clean transport solutions (e.g., with specifically retrofitted buses and taxis). However, it should be noted that many of the transportation investments are focused on the country's two main urban centers (Athens and Thessaloniki) effectively sidelining rural and semi-urban areas, where the issue of transport poverty is significantly higher (due to less urban density and less public transport options). 

However, the Plan does not explain if and how municipalities and civil society (e.g., energy communities) could help co-manage the OSS. It also fails to employ trained professionals to directly visit vulnerable households in their homes, ensuring greater capillarity and on-the-ground impa

Households with older, inefficient boilers can still be eligible for the efficiency interventions, such as procurement of heat pumps. 

For Investment 7 on micro-enterprises the following safeguard is added: whenever the building is rented (and not owned) there has to be a 7 year lease agreement in place. If the lease is terminated earlier, the owner still has to lease it to a vulnerable micro-enterprise for the remaining of the duration. 

For Investment 32 on energy efficiency for private residencies, in cases where the vulnerable households are renting, a tenancy agreement of at least 7 years will be required, which if terminated, will result in the grant having to be returned to the State. 

However, the Plan stops short of enforcing stricter measures such as rent controls/caps. 

Investment 10 aims to create a social housing building stock with a €487.5 mil., that consists of the construction of 2,350 new A+ energy-class units (the number is a significant upgrade from the initial 100). National budget will be mobilised to improve public transport access to these sites. An additional sub-investment focuses on the renovation of existing public buildings to create an additional 450 social housing units.

The investment is complemented by a specific reform which will establish the detailed legal and administrative framework necessary for the implementation of the social housing scheme in Greece, including beneficiary eligibility and prioritisation, tenancy conditions, the methodology for determining and administering social rents, governance arrangements, and safeguards ensuring that the housing stock remains dedicated to social and affordable housing purposes over the long term.

Investment 2 targets the renovation of 15 public student residences (€226.6 mil.),  across 10 Universities, providing residence for 5,930 students. The investment is also accompanied with a holistic reform of the regulatory framework for public student residences in the country, which will establish a unified, legally binding framework of horizontal and equitable admission criteria for public student residences across all universities, taking into account social and income-based criteria. 

The lion's share of the Buildings Component (€1,748 mil.) goes to energy efficiency upgrades of residential buildings. A wide range of interventions is eligible for financing, from comprehensive building renovations (shell insulation, replacement of window frames) to targeted equipment replacements (heat pumps, solar water heaters, photovoltaics for self-consumption), aiming to achieve an upgrade of at least three energy performance classes compared to the initial EPC classification. Only worst performing buildings (C or lower) are eligible for this investment. 

This investment is also accompanied by a reform, Registry of Energy Support Beneficiaries and Energy Support Beneficiary (ESB) Card, that aims to facilitate vulnerable households to participate in support measures and energy-efficiency funding schemes. An additional reform to the Energy Efficiency Obligation regime, will leverage the private sector (particularly electricity and gas suppliers) to help vulnerable households access renovations through on-bill financing. 

Heating and cooling investments are folded under the broader 'Buildings' envelope and relate to the replacement of fossil-based boilers with heat pumps, solar water heaters, and the installation of rooftop solar for self-consumption. These measures are addressed both to vulnerable households and micro-enterprises. 

Collective approaches to heating and cooling, such as through energy communities, are not taken into account. 

The Plan foresees no investments or reforms for energy communities, which is a significant gap, as citizen-led energy communities are currently not supported by any other public financing program in Greece.

Investment 1 will strengthen the fleet of urban buses in Athens and Thessaloniki (€129 mil.) - the two biggest cities, through the procurement of 211 new zero emission buses, to strengthen lines that serve mainly areas with increased vulnerability in the transport sector (e.g. Western Attica and Western Thessaloniki). A municipal bus fleet will also be developed for Athens (€11.8 mil.). 

Additionally, the metro of Athens will be supported with €262 mil. both for new trains and the upgrade of existing ones. 

Significant questions are raised on the additionally of these measures, since particularly the Metro upgrade, is non targeted and seems to be replacing a regular national budgetary expenditure. 

Demand responsive transport routes will be developed in both sub-urban areas of Athens and Thessaloniki, as well as rural areas (nationally). 

Investment 60 introduces an electric vehicle social leasing scheme, (€165.3 mil.), subsidizing the leasing of zero emission vehicles for 15,000 transport-vulnerable households. In addition, the investment will support the purchase and installation of private EV charging points. This investment is complemented by a roll out of public EV chargers, prioritising areas with low EV penetration and higher levels of poverty. 

An investment of €396 million (Investment 4) will support up to 9350 vulnerable microenterprises with financial incentives to renovate their buildings, switch to more efficient heating & cooling technologies, and install PVs for self-consumption. Additional incentives will be provided to micro-enterprises in disadvantaged and rural areas, as well as in areas with a particularly cold climate. Smart meters and building management systems will be deployed to monitor energy use and optimize performance. A primary energy savings target of at least 30% compared to the pre-investment situation is put in place, which is medium in ambition.

Investment 90 will support vulnerable 15,550 micro-enterprises for buying or leasing zero emission vehicles (€373,7 mil.), such as cars, light/medium vans, and two-wheelers. The investment provides specialised support for micro-enterprises in the logistics sector to purchase or lease heavy vehicles (trucks). Also, this investment provides dedicated funding to taxi drivers, supporting the purchase of 3,200 zero-emission taxis, including also 200 vehicles accessible to persons with disabilities.

There are various investments in the greek Plan that pave the way for the continued use of fossil fuels.

'Low emission vehicles' are frequently mentioned in all of the investments of the transport component. 

Direct income support takes up the remaining 7% of the budget (€324.807.106) support for vulnerable households using fossil fuels for heating, which is an indirect fossil fuel subsidy.

Heating subsidies that will be provided to vulnerable households are framed as 'temporary' and 'bridging' measures, until more structural measures kick in (e.g., housing renovations, public transport, switching to electric vehicles, with priority support from the dedicated One Stop Shops). A clear timeline is set for the reduction of the subsidy from 2028-2032. 

Eligible households will be required to register in the Energy Support Registry (ESR). 

The Implementation and Coordination Body of the Greek Plan is explicitly tasked with "Ensuring alignment of the operation of the Social Climate Plan with national policy initiatives and ensuring coherence and complementarity between the national Social Climate Plan and the Action Plan on the European Pillar of Social Rights, cohesion policy programmes, the Recovery and Resilience Plan, the National Building Renovation Plan, the revised National Energy and Climate Plan, the Just Transition Plan, the Action Plan to Combat Energy Poverty, and the National Climate Law". 

The Greek Plan explicitly references linkages with the:

• National Energy and Climate Plan, 
• National Building Renovation Plan (emphasising the prioritisation of worst performing buildings), 
• Sustainable Urban Mobility Plans, 
• Recovery and Resilience Facility (mentioning that reforms and investments will be scaled further), 
• Cohesion programs
• Territorial Just Transition programs (highlighting them as particularly exposed to the impacts of ETS2)
• the European Pillar of Social Rights

There is no reference to mobilising broader ETS2 (or ETS1) revenues for the purposes of the Plan. The NECP outlines significant investment needs for the decarbonisation of buildings (€13.5 billion) and for the transport sector (€44 billion) up to 2030. Therefore, the funds committed for these sectors from the Social Climate Plan (~€2.91 billion for buildings and €1.46 billion for transport), only covers a small fraction of the real investment needs.