Security Alert
Greece has introduced new law 5215/2025 (OJ A’/116/04.07.2025) regulating inter alia the organisation of the hydrogen production market and the operation of geographically confined hydrogen networks (the “Law”). This legislation represents a significant step towards establishing a competitive hydrogen economy capable of meeting both industrial demands and broader climate goals.
Although the new Law only partially transposes Directive (EU) 2024/1788 (on common rules for the internal markets for renewable gas, natural gas and hydrogen), it brings national legislation closer to the EU’s hydrogen market design and decarbonisation objectives, and to the implementation of the targets set in Greece’s National Energy and Climate Plan (ESEK) which sets ambitious mid- and long-term goals for renewable energy adoption.
Hydrogen Types and Categories of Production Units
The Law addresses the production of specific categories of hydrogen, covering both renewable hydrogen (produced using renewable energy) and low‐carbon hydrogen (produced by use of technologies meeting defined CO₂ emission thresholds).
The Law also distinguishes between two categories of hydrogen production units:
off‐grid units (not connected to a natural gas or hydrogen transmission or distribution network); and
grid‐connected units.
Market entry and Licensing
A two-phase licensing process lies at the core of the new Law drawing on the permitting approach already applied to RES projects in Greece:
Phase A: obtaining a hydrogen Producer Certificate, valid for up to 25 years (and renewable for an equal period).
Phase B: securing the required environmental permit, followed by other permits and approvals (such as the construction approval and the water use permit) up to the issuance of the installation approval and the operation approval. For on-grid units, this phase also involves securing grid connection terms and signing a binding connection agreement with the competent operator.
Counting Electricity as Renewable in Hydrogen Production
Hydrogen will qualify as renewable, provided that specific criteria of Regulation (EU) 2023/1184 for counting electric power used for hydrogen production as renewable are met.
For on-grid units, such criteria include the geographical zone of the production unit, the average proportion of renewable electricity produced in that zone, the total production hours of the hydrogen unit, the emission intensity of the electricity in that zone.
If these criteria are not satisfied, the electricity may still be classified as renewable if:
Additionality is ensured, meaning that hydrogen is produced from new dedicated renewable energy capacity.
Temporal Correlation is achieved, ensuring that hydrogen production and renewable energy generation coincide in time.
Geographic Correlation is maintained, meaning that the renewable energy generation and the hydrogen production plants are located in the same bidding zone (in Europe currently defined by national borders).
When these conditions are met, the national guarantees of origin (GOs) issuing body (DAPEEP)1 may issue GOs for the hydrogen produced – an essential certification for verifying and monetising renewable hydrogen under EU and international standards.
Geographically Confined Hydrogen Networks
A distinctive feature of the new Law is the introduction of Geographically Confined Hydrogen Networks (GCHNs), namely of dedicated hydrogen systems operating independently from the national grid. Designed to serve localised industrial or commercial needs, these standalone networks aim to serve public interest objectives and enhance security of supply at both national and European level. GCHNs are subject to a distinct licensing procedure, mainly involving:
GCHN Licence which is issued by the Greek Regulatory Authority for Energy, Waste and Water (RAAEY) granting the right to own and construct a GCHN. Only legal persons are eligible for obtaining a GCHN Licence subject to meeting specific criteria (such as technical and financial capacity of the applicant, assurance of free competition and third-party access, the demand served, the economic efficiency and reliability of the network).
GCHN Management Licence which is granted by RAAEY to the holder of the GCHN Licence or to a vertically integrated company, subject to specific restrictions.
According to the Law public tenders may be required for the granting GCHN licences (for example in cases where applications could negatively affect free competition or multiple applications concern the same geographical area). The regulator, RAAEY will conduct a 7-year review to assess the impact of GCHN licences on free competition, as well as on the development and operation of the Greek and the EU hydrogen market, and on relevant hydrogen infrastructures.
Additional obligations and requirements for GCHN operators (pertaining to the development, operation and maintenance of GCHNs, including, indicatively, technical and qualitative specifications, access arrangements, hydrogen transport or facility use contracts, distribution of metered quantities to users, dispute resolution etc.) will be regulated in a dedicated GCHN Network Code, to be issued in the future by RAAEY.
Investment and Incentives
To encourage an early-stage hydrogen market development, the Law permits the adoption of investment or operational aid schemes subject to European Commission approval, or deployment through Greece’s Public Investment Development Programme.
Although investor support schemes are undoubtedly important, careful evaluation of the relevant funding options will be crucial to ensure balanced growth across all components of the hydrogen value chain and to foster a sustainable hydrogen economy.
Outlook for Greece’s Hydrogen Market
Greece’s new legal framework marks a pivotal first step in establishing a domestic hydrogen market in line with the objectives of ΕSΕΚ, leveraging the country’s abundant renewable resources and strategic location for large-scale hydrogen production and export. However, the Law only provides overarching guidance. Critical details will be addressed in secondary legislation and further laws will need to be adopted to ensure full harmonisation with Directive (EU) 2024/1788 and to introduce complementary measures, such as a framework supporting hydrogen-based solutions for renewable energy storage, an aspect not yet covered by the Law.
Consequently, significant work remains to move from the current high-level policy vision to a practical, investor-ready environment. Swiftly issuing the necessary laws and regulations, with a focus on strengthening both the supply and the demand sides (including securing financing across the entire hydrogen value chain), will be key to determining how rapidly Greece’s hydrogen market scales and becomes competitive.
[1] Renewable Energy Sources Operator & Guarantees of Origin S.A.