Overall assessment

Updated December 2022

The existing Law 4513/2018 that regulates the concept of ‘energy communities’ (ECs) already introduces some aspects of the RED II and IEMD provisions for RECs and CECs. However, the latter law was elaborated before the adoption of the EU provisions, so it is not fully compliant with them. The transposition process is still in progress.

Overall, several elements of a complete enabling framework for energy communities are missing, while the measure introduced for energy communities in the support scheme does take into account the specificities of energy communities, but does not have a permanent nature.

Detailed assessment

Assessment of obstacles and potential for development of ECs

Not addressed in the transposition.

Removal of unjustified regulatory & administrative barriers

Not addressed in the transposition.

DSO duties around cooperation with ECs and facilitation of energy sharing

Not mentioned in the 2018 Law. Several problems still exist with access to the grid for EC that want to develop virtual net metering (VNM) projects. The DSO do not reveal beforehand if they have the capacity for the project, so there are transparency issues. Moreover, in the context of the energy crisis, there was a measure introduced by the Ministry in order to help households and energy communities to reduce their prices. In more detail, the Ministry regulated that 10MW will be occupied for citizen and energy community renewable projects in areas with congested grid, so that it is guaranteed they have access to the grid. At the same time, the Ministry regulated that the DSO will decide how this measure will be implemented. The DSO broke down the 10MW to 10 KW projects and citizens and energy communities are only able to apply for 10KW. This is maybe enough for 1 or 2 households, but it is definitely not enough for energy communities, thus excluding them from access to such projects and the grid. Another barrier identified for the participation of energy communities with a citizen base to VNM projects is that, due to the current high electricity prices, more and more businesses and big industrial consumers develop energy communities in Greece in order to develop VNM projects and self-consume this energy. However, all these new energy communities that consist of businesses have funding, are faster, as they consist of professionals and occupy the grid, thus leaving no room for energy communities that are unique citizen initiatives that want to develop a VNM project. Therefore, the hijacking phenomenon of the concept of energy communities is very evident in Greece and constitutes a barrier for the unique citizen initiatives to participate in the market.

Fair, proportionate, and transparent registration & licensing procedures

Energy communities need to register to an Energy Community Registry which is established in the General Commercial Registry. With regards to licensing, the same regulations apply for ECs, as for the other market actors.

Incentives connected to network tariffs based on a CBA

Not addressed in the transposition.

Non-discriminatory treatment as market participant

Not addressed in the transposition.

Accessibility to low-income & vulnerable households

There are some mentions of the role of ECs in addressing energy poverty in the Law 4513/2018. It is mentioned as one of the objectives of ECs, while also it is possible for an EC to provide electricity for free to energy poor consumers in the context of virtual net metering projects, even if such consumers are not members to the EC.

Tools to access finance

Not addressed in the transposition.

Tools to access information

Not addressed in the transposition.

Regulatory capacity building for public authorities

Not addressed in the transposition.

NECP reporting on enabling frameworks

Not addressed in the transposition. Member States are required via the Governance Regulation (2018/1999) to report on their enabling frameworks for RECs by 15 March 2023.

Support Scheme adapted for RECs

Form of support for community production projects

According to Law 4579/2020 (article 160(3g)(3e)) and Law 4414/2016 (article 7(3a)), an energy community that has a Municipality as a member or an energy community with at least 60 members (50 of which are natural persons) can get a fixed tariff of 0.65 euros/MWh for 20 years without taking part in competitive procedures. This is not a permanent measure; it is dependent each time on a Ministerial decision.