The New Law and its Key Objectives
In alignment with European Union’s policies on green development, Greece, through the adoption of Law 5215/2025 introduces a comprehensive regulatory framework for the hydrogen market, establishing coherent provisions for the production of biomethane and hydrogen. The law defines both the licensing procedures for production plants and the injection of their production into the National Natural Gas System (ESFA) or the Natural Gas Distribution Systems, as well as the supply of the produced gases to end-users not connected to the System or Distribution Networks and their use as transport fuels.
The new legislation aims to fill a significant gap in the Greek energy market and to encourage investment in technologies that, until now, have been largely underutilized. Biomethane production, i.e. renewable methane, - derived from organic waste and biomass - utilizes materials that would otherwise end up in landfills, converting them into clean energy. This practice, already implemented in several European countries, substantially contributes to the circular economy and the reduction of greenhouse gas emissions.
Key Innovations & Licensing Procedure
At the same time, special emphasis is placed on the development of the hydrogen market, which is internationally regarded as the “fuel of the future”. Hydrogen can be used for electricity generation, industrial processes, or as a transportation fuel, providing a flexible solution for decarbonizing sectors that are difficult to be fully electrified. The new Law introduces rules for the safe and sustainable production, storage, and transportation of hydrogen, establishing a new category of networks, the Geographically Confined Hydrogen Networks (GCHNs). These Networks operate within restricted geographic areas (e.g., industrial parks, ports), promote energy autonomy, and are addressed to specific sets of users, without being connected to the national hydrogen system; such Networks are benefited from a simplified regulatory framework and are eligible for state support schemes, especially if they constitute part of regional decarbonization plans. GCHNs are particularly significant as they are an ideal solution for industrial clusters, ports, airports and islands, while allowing the use of hydrogen prior to the development of the national hydrogen system.
Specifically, the licensing procedure for hydrogen producers is conducted in two phases: first, a producer certificate is issued, and then a license is granted for the installation and operation of the plant. At the same time, financial support is provided through competitive procedures, with operating subsidies determined by decision of the competent Ministry, following a recommendation by the Regulatory Authority for Waste, Energy and Water (RAAEY), which also acts as the supervisory authority for the hydrogen market. An innovation of the Law is the procedure for the issuance of a hydrogen producer license, which is carried out through the digital submission to RAAEY of all technical, spatial planning, and environmental documentation, as well as of a declaration on the origin of the electricity used in the production process. The license is issued for 25 years and can be renewed for an additional 25-years period, with the overall licensing process considered to be fast, transparent, and investment-friendly, with projects expected to reach the construction and operational phase within 24-36 months on average, subject to clear deadlines for each stage.
The law regulates licensing procedures in detail, addresses matters relating to production and certification, and provides the legal basis for the future establishment of state support schemes - whether in the form of investment or operational aid - via the Hydrogen Bank, the RRF, or national programs. Interested parties will be able to participate in competitive procedures for flagship and integrated projects, thus enhancing investment incentives and reducing the projects’ risk.
Another important innovation is the certification process for the hydrogen produced, with the adoption of the Guarantees of Origin (GoOs) system, as already implemented in the electricity sector, certifying the origin and the “carbon footprint” of the produced hydrogen, ensuring its tradability and facilitating cross-border trade. GoOs are a prerequisite for the granting of state aid, while they also ensure compliance with EU’s renewable energy and decarbonization targets. The clear criteria set for the classification of the produced hydrogen as green or low carbon further enhance investment certainty in the international market.
According to Regulation (EU) 2023/1184, the certification of hydrogen as renewable depends on the source of the electricity used for its production. When electricity is derived directly from renewable energy sources, its certification is straightforward. If grid electricity is used, specific conditions must be met: the electricity must be derived from new, unsubsidized renewable installations (additionality condition), hydrogen production must be temporally aligned with renewable generation (temporal condition), and the hydrogen production plant must be in the same bidding zone as the renewable source (geographic correlation). Certification is provided by the Operator of Renewable Energy Sources and Guarantees of Origin (DAPEEP S.A.) through the Guarantees of Origin system and constitutes an essential condition for access to state subsidies and participation in renewable hydrogen offtake agreements.
Regulatory Gaps in the Law
However, the provisions of the Law regarding injection, transmission, and supply to end-consumers (both domestic and foreign), as well as issues concerning the system operators, are either vague or incomplete. This lack of clarity may be attributed to the fact that, in technical matters concerning hydrogen system operators, solutions and frameworks are ultimately defined by market needs and practice. It should be noted, however, that several provisions of the Law leave to the discretion of system operators the right either to refuse a connection, or to unilaterally decide on the temporary non-acceptance of gas volumes, or to request the producers to directly or indirectly participate in infrastructure and operational costs.
Overall Assessment and Future Perspectives
The new Law partially transposes Directive (EU) 2024/1788 on common rules for the internal markets in renewable gases, natural gas and hydrogen, aligning Greek legislation with European commitments on clean energy, energy security and economic competitiveness. By establishing a common set of rules, the Law promotes cross-border cooperation and facilitates investment, while providing a stable and predictable environment for businesses seeking to operate in these sectors.
The adoption of the new framework is expected to generate multiple benefits to the national economy. The production of renewable (green) hydrogen or low-carbon (blue) hydrogen is anticipated to increase utilization of renewable energy sources, promoting a green transition that is both socially equitable and environmentally sustainable. At the same time, it will foster innovation and encourage the development of new technologies, propelling domestic industry as well as small and medium-sized enterprises (SMEs).
Overall, Law 5215/2025 positions Greece on the map of the emerging green hydrogen economy. Through a transparent and flexible licensing procedure, the establishment of the geographically confined hydrogen networks (GCHNs), and the introduction of a Guarantees of Origin system (GoOs), Greece establishes a reliable and investment-friendly framework that reduces business risk and enhances transparency for consumers, producers, and investors alike. The Law provides access to a growing market, opportunities to leverage national and EU incentives, and participation in high value-added projects with international visibility, serving as a strategic development tool for stakeholders seeking to take a leading role in hydrogen production, trade and technological deployment in Greece. With the forthcoming issuance of secondary legislation that will detail its provisions, the Law will provide a coherent and comprehensive regulatory framework, aligned with EU standards. Given the country’s significant renewable energy potential and strategic geographic location, Greece is expected to become an attractive destination for producers and investors alike, in a rapidly growing market, thereby contributing to the green transition as well as to the attainment of Greece’s and the EU’s decarbonization objectives.
