Greece reforms renewable energy permitting and spatial planning

This alert summarises the principal changes introduced by Law 5299/2026 and the new Special Spatial Planning Framework for Renewable Energy Sources (the new RES Spatial Framework).

Background

Greece's renewable energy source (RES) pipeline has grown substantially over recent years, driven by strong resource conditions, EU decarbonisation targets, and a broadly supportive permitting regime. That growth has, however, increasingly outpaced the capacity of the transmission and distribution networks to absorb new generation, and has placed sustained pressure on land available for development in a country with significant areas subject to environmental, archaeological, forestry, agricultural, and landscape protection. The Greek government has responded with two separate but related instruments: Law 5299/2026, which reforms the permitting process, and the new RES Spatial Framework, which governs where projects may be sited.

Law 5299/2026 (permitting). Law 5299/2026 transposes Directive (EU) 2023/2413, commonly known as RED III, and Commission Delegated Directive (EU) 2024/1405, and also partially transposes Directive (EU) 2024/1788, establishing common rules for the internal markets in renewable and natural gases and in hydrogen.

The law came into force on 5 May 2026 and introduced several key changes to the permitting process of renewable and energy storage projects. In particular, it designates Renewable Energy Acceleration Areas (REAAs) within which shortened, more predictable permitting timelines apply, sets statutory processing periods, revises grid connection procedures, and introduces new rules for the permitting of energy storage facilities and projects under repowering. The law is discussed in Section 1.

The RES Spatial Framework (siting). The new Special Spatial Planning Framework for Renewable Energy Sources was approved on 19 August 2026 by decision ΥΠΕΝ/ΔΝΕΠ/89998/3072/2026 (Government Gazette Vol. Δ no. 694) of the Minister of Environment and Energy (the Ministerial Decision). The framework sets the zoning, exclusion, and land-coverage rules against which individual project applications are assessed. Its scope extends beyond wind and solar, as the framework lays down technology-specific siting criteria for onshore and offshore wind farms, solar energy installations (including floating PV, both inland and at sea), small hydroelectric plants, biomass, biogas and biomethane, geothermal energy, and electricity storage. Excluded from its scope are, in particular, large hydroelectric plants and pumped storage, PV systems on rooftops and other built or artificial surfaces, wave and other forms of ocean energy, and renewable hydrogen production. The land-coverage caps apply to solar PV and onshore wind projects specifically. The framework received Cabinet-level endorsement and was presented as part of a broader spatial-planning reform covering industry and tourism as well as renewable energy. It is discussed, together with its transitional provisions, in Sections 2 and 3.

The previous Special Spatial Planning Framework for Renewable Energy Sources, which entered into force in late 2008, had largely served its purpose: at the time of its adoption, renewable energy capacity in the Greek system stood at little more than 1 GW, whereas installed RES capacity now exceeds 20 GW (excluding large hydro and cogeneration). However, the 2008 framework was not designed for today’s technology mix or development volumes, and its siting rules and environmental criteria had not kept pace with current planning standards, making wholesale replacement effectively unavoidable.

1. Law 5299/2026: Principal regulatory developments

Law 5299/2026 amends the Greek RES permitting regime in implementation of the revised EU renewable energy framework. From a transactional and financing perspective, the most significant changes concern permitting timelines, the treatment of projects within REAAs, grid connection procedures, and the permitting of energy storage systems and projects under repowering. REAAs are specific zones designated for the accelerated deployment of RES projects and associated infrastructure, located outside Natura 2000 areas and other environmentally sensitive zones and subject to a strategic environmental impact assessment. Permitting under the law does not, however, operate in isolation. The new RES Spatial Framework sets the zoning and land-use conditions within which the permitting process takes place: it defines acceleration areas by reference to Article 9 of Law 5299/2026, permits wind siting within REAAs designated under the law, and applies its exclusion areas across all of its area categories, including acceleration areas. A project that benefits from accelerated permitting must therefore still satisfy the framework’s siting rules, and the two instruments must be read together. Beyond the matters discussed in this alert, the law aligns national RES targets with the EU’s 42.5% target for 2030 and addresses market participation, power purchase agreements, guarantees of origin, self-consumption, and offshore wind.

Accelerated permitting procedures
Within REAAs, permitting and grid connection procedures generally may not exceed 12 months, measured from the initiating application through to the operation licence (the final key licence, which authorises the plant to operate). A shorter six-month period applies to certain repowering projects and smaller installations, while offshore developments are subject to separate provisions. REAA projects are also, in principle, exempt from environmental permitting: for Category A projects (those otherwise subject to the full environmental impact assessment regime), an exemption certificate may be issued within 30 days (20 days for repowering) where no significant environmental impact is expected. This addresses what has historically been one of the most significant sources of delay in the Greek permitting process.

Outside REAAs, the general processing period is two years, subject to shorter periods for specified project categories. Limited extensions are available of up to six months for general projects and three months for smaller or repowering projects. Repowering projects benefit from an accelerated regime both within and outside REAAs.

These statutory periods should not be read as a proxy for the timetable to commercial operation. The calculation excludes construction works, energisation, major network reinforcement, and judicial or administrative disputes, and exceptional extensions remain available in prescribed circumstances. The deadlines are also bilateral: they bind competent authorities and network operators, but they equally require developers to submit the required documentation within the prescribed periods.

 

Project category	Indicative statutory processing period
Within a REAA	Up to 12 months, from initiating application to operation licence
Smaller installations and certain repowering projects, within a REAA	Up to six months
Outside a REAA (general regime)	Up to two years, subject to shorter periods for specified categories
Repowering (within or outside a REAA)	Accelerated regime, shorter than the general periods above
Offshore developments	Subject to separate, dedicated provisions

Note: Figures are indicative and reflect the statutory outer limits. They exclude construction, energisation, network reinforcement, and dispute-related periods, and are subject to the extensions described above.
 
Key consideration
The reforms are expected to enhance procedural certainty but do not eliminate execution risk. Delays arising from grid reinforcement or legal challenge may continue to affect delivery timelines even where the statutory permitting periods are met.

Grid connection remains a critical constraint
Permitting timelines are, however, only part of the picture, because a project cannot materialise and, ultimately, come online without a deliverable grid connection. Article 14 of Law 5299/2026 amends the process for issuing final grid connection offers (the network operator’s binding technical and economic terms for connecting a project). It introduces tighter response deadlines for network operators and clearer rules on the information applicants must submit before an offer is processed. The stated aim is to reduce the administrative delay that has historically sat alongside, and often exceeded, delays caused by the queue for available network capacity.

The reforms do not, however, increase network capacity. Faster processing of an application does not create headroom on a constrained substation or line. In saturated areas, applicants may simply receive a capacity-based refusal, or an offer conditioned on costly reinforcement works, more quickly than under the previous regime. The quality and deliverability of a project’s grid connection will therefore continue to drive its value far more than the speed at which an offer is issued, and without substantial grid upgrades the new deadlines may prove largely declaratory.

In this context, the draft Ten-Year Network Development Plan 2027–2036 recently published for consultation by IPTO, the Greek electricity transmission system operator, envisages approximately €9 billion of investment, around 80% front-loaded to 2030, to integrate more than 10 GW of new renewable capacity by the mid-2030s through substation upgrades, new high-voltage corridors, and expanded cross-border interconnections, including the Great Sea Interconnector linking Greece and Cyprus. If delivered on schedule, these investments would materially improve the grid’s ability to absorb new generation. Until then, the gap between permitting acceleration and network readiness remains the central tension in the market.

Investors and lenders should therefore look beyond the procedural status of a connection application and examine:

• the technical feasibility of the connection and the specific substation or point of interconnection identified;
• the scope, cost allocation, and expected duration of any required network reinforcement works;
• realistic energisation timelines, benchmarked against the operator’s queue and published network development plans;
• any operational restrictions, including conditional or non-firm connection terms; and
• curtailment exposure under existing dispatch rules and under any enhanced curtailment regime introduced alongside the storage measures discussed below.

These factors are likely to remain among the principal drivers of project valuation and bankability and should form a core work stream in technical and legal due diligence irrespective of a project’s permitting status under Law 5299/2026.

Enhanced integration of energy storage
Grid constraints also explain the prominence of storage in the reforms. Law 5299/2026 introduces storage readiness obligations for new generation projects, a dedicated regime for pumped-storage development, and clarified rules on the ownership, representation, and market participation of standalone and co-located storage assets, including in balancing and ancillary services. It also enables small-scale and mobile systems, such as household batteries and electric vehicles, to participate in the electricity and balancing markets.

The policy objective is to make storage a central component of RES development in Greece. This reflects market conditions: curtailment on the existing solar and wind fleet has risen materially in recent years, and system operators have identified storage as a key tool for maintaining network stability as renewable penetration increases.

Storage is not, however, a substitute for robust grid access. It may reduce curtailment and allow output to be shifted away from periods of negative or depressed pricing, but project economics will still depend principally on the terms and quality of the underlying connection rights. Co-location and hybridisation strategies should therefore be assessed on their own commercial merits, and not treated as a general mitigant for a weak connection position.

Repowering
Law 5299/2026 also introduces accelerated permitting for qualifying repowering projects. Its stated aim is to support the renewal, technical upgrade, and life extension of Greece’s earlier-generation wind and solar assets, many of which have reached or passed the midpoint of their operating licences.

The faster procedure does not, however, mean that repowering is a straightforward continuation of the existing project. Projects meeting the relevant application trigger after 31 October 2024 may participate exclusively in the electricity market and may not qualify for operating support, such as a feed-in premium or contract for difference, for the renewed installation. This is a materially different risk and return profile from that of the legacy asset, which will often have benefited from a supported tariff for its original operating life.

Repowering should therefore be evaluated as a distinct investment, taking into account updated capital expenditure and equipment specifications; any new permitting, environmental, and spatial requirements for the upgraded installation; the connection terms to be used or reapplied for; merchant exposure in the absence of operating support; and curtailment risk over the revised project life. Spatial requirements are particularly relevant, because the new RES Spatial Framework discussed below governs where a renewed installation may be sited, subject to the transitional protections described in Section 3. Assumptions carried over from the legacy project’s economics should be treated with particular caution.

2. The new RES Spatial Framework

While Law 5299/2026 governs how projects are licensed, the new RES Spatial Framework governs where they may be located. It replaced the 2008 framework on 19 August 2026 and sets revised siting criteria, exclusion areas, and spatial compatibility rules, supported by detailed technical annexes and environmental conditions. Although the framework sets siting rules for almost all the main RES technologies, this section focuses on wind and solar PV, which together account for more than 95% of installed RES capacity in Greece. The article numbers cited below for the siting rules (Articles 5, 6, 8, and 16) refer to the framework itself, which is set out in Article First of the Ministerial Decision; the transitional provisions in Article Third belong to the Ministerial Decision itself.

We consider the framework at least as significant as Law 5299/2026. The law accelerates procedures, but it is the framework that determines, in considerably more detail than its 2008 predecessor, where projects may lawfully be developed. A project that benefits from faster permitting may still be constrained, or excluded, by the spatial rules.

Solar PV projects
Article 16 (1) caps land coverage by solar PV projects, with or without co-located storage, at 1.5% of the total area of each regional unit (an administrative area broadly corresponding to the former prefectures), using a standard footprint of 1.4 hectares per installed MW. The calculation is not a simple aggregate of all existing PV projects. It includes specified producer’s certificates (the first key licence in the RES permitting process) and special projects certificates (the equivalent first licence for certain specially regulated projects) lacking a complete grid-connection application at entry into force, certificates issued thereafter, and certain post-entry connection offers or agreements for exempt projects. The check is made at the producer’s certificate stage or, for small-scale exempt installations, when the competent operator issues the final grid connection offer or signs the grid connection agreement. In heavily developed regional units, the remaining headroom may become a binding constraint on new projects, which makes both a project’s permitting status and the available regional headroom commercially significant.

Article 16 (2) refers the siting of solar PV projects on high-productivity agricultural land to Article 56 of Law 2637/1998 and Joint Ministerial Decision ΥΠΕΝ/ΔΑΠΕΕΚ/104605/4389 (Government Gazette Vol. Β no. 5342/11.10.2022), while agrivoltaics fall under Law 4951/2022. Land classification and the applicable statutory restrictions therefore remain important diligence items. Article 16 (4) also requires certain adjacent solar PV projects to be assessed on the basis of their combined installed capacity when determining their environmental classification.

Key consideration
The 1.5% solar PV ceiling applies only to the categories and permitting checkpoints specified in Article 16 (1). The licensing and environmental status of each project must therefore be checked against the operative criteria and transitional provisions.

Wind projects
Onshore wind projects are subject to a more extensive set of siting rules than solar PV. Article 5 (A) lists areas in which wind projects are excluded in every area category, including UNESCO World Heritage sites and other major archaeological sites, nature protection zones and Ramsar wetlands, priority Natura 2000 habitats, landscapes of outstanding natural beauty, roadless areas, settlements, organised tourism zones, and municipal units (the local sub-divisions of a municipality) ranked in environmental impact categories A and B of the tourism spatial framework. Article 5 (A) (9) also excludes wind projects from all areas above 1,200 metres. The framework’s technical annexes, including the minimum distance tables in Annex II, apply alongside these exclusions. Offshore wind projects are subject to separate siting criteria under Article 9, which permits wind installations in the territorial sea and the exclusive economic zone in line with the National Offshore Wind Farm Development Programme, once adopted, and sets out marine exclusion areas; those criteria apply alongside the dedicated statutory regime for offshore wind.

Even where a site falls outside the exclusion areas, the framework caps the land area that wind projects may cover in each municipal unit. On the mainland, Article 6 (1) sets the cap at 8% in areas that were wind priority areas under the 2008 framework, 5% in former wind suitability areas, and 4% in several municipal units and on the island of Crete. Regional and local plans may, with municipal agreement, raise the 8% and 5% caps by 30% and 50% respectively (Article 6 (2)). Remaining headroom is checked against the records of the Regulatory Authority for Waste, Energy and Water (RAAEY) when a producer’s certificate is issued or amended (Article 5 (Ζ)), so available capacity in a given municipal unit is a diligence point in its own right. Site assessments should therefore be checked against the framework’s criteria and technical annexes.

Wind speed also matters. The siting of onshore wind projects is permitted in principle only in suitability areas, being municipal units with an average wind potential above 4 m/s (Article 4 (3)), but the framework allows two exceptions where RAAEY data show site wind speeds above 7.5 m/s: in special protection areas for birds, where the approved special environmental study also permits it (Article 5 (A) (6)), and in municipal units below the 4 m/s average, subject to a 1% land-coverage cap (Article 5 (ΣΤ)).

Islands are treated separately. Under Article 5 (A) (10), onshore wind projects are excluded on islands smaller than 300 km², unless they exclusively serve critical or public-benefit infrastructure (such as desalination plants) or are necessary for system security. On the larger islands, Article 8 caps wind land coverage at 4% of each municipal unit, with landscape integration assessed under Article 26 and Annex III. The 300 km² criterion is a central ground in the challenges to the Ministerial Decision, as discussed in Section 5.

On offshore wind, Law 5299/2026 also amends Law 4964/2022 to accelerate the strategy of the Hellenic Hydrocarbons and Energy Resources Management Company (HEREMA) for the centralised collection of data needed to mature offshore wind areas. Key implementation steps are the establishment of a special purpose company for this purpose and ministerial decisions on grid capacity reservation and the legal framework for the first competitive procedure.

3. Transitional arrangements

The general siting rules described above apply in full only to new projects. Article Three of the Ministerial Decision qualifies them with transitional protections for projects that had reached specified milestones when it entered into force on 19 August 2026. Projects lawfully operating at that date are maintained until they cease operation, and renewals of their licences follow the rules under which they were originally assessed. Valid installation licences (the licences authorising construction) may be implemented as issued within their period of validity under Article 19 of Law 4951/2022. Projects holding existing decisions approving environmental terms for high-impact category A projects, standard environmental commitments, which apply to lower-impact category B projects, or environmental-exemption certificates, as well as projects whose environmental impact assessment files had been confirmed as formally complete before entry into force, may obtain their remaining licences and be built under the previous spatial rules, subject to express exceptions (Article Three (2)–(9)).

The transitional regime is particularly relevant to modifications and repowering. Article Three (7) generally permits existing environmental approvals to be modified under the former rules, including to add energy storage systems. It excludes, however, relocations under Article 24 of Law 4951/2022 and changes exceeding 50% of the previously approved installation polygon (licensed project site) without an increase in installed capacity. Article Three (10) addresses radical renewal of projects within the protected categories. By contrast, projects holding only a producer’s certificate, special projects certificate, or electricity storage licence, without falling within any protected category, are reassessed for compatibility with the framework under Article Three (12). The scope of protection therefore depends on the precise permitting milestone a project had reached, not simply on whether it was already in development.

For acquisitions and financings, diligence should verify each project’s permitting and environmental status as at 19 August 2026, including documentary evidence of any formally complete environmental impact assessment submission. It should also confirm that any later amendments, site changes, or repowering remain within the transitional protection, and review pending permitting procedures against the timelines and procedural rules of Law 5299/2026.

4. Practical implications for transactions

These rules have direct consequences for acquisitions, financings, and joint ventures involving Greek renewable energy assets. In particular, they are likely to affect diligence scope, valuation, and transaction documentation in the following ways.

• Diligence scope: environmental permitting status and compliance with the new RES Spatial Framework should be treated as core diligence items alongside permitting status and connection terms, because they now determine whether a project remains developable at its proposed site.
• Valuation methodology: capacity-based or installed-MW benchmarks should be treated with caution where they do not reflect the quality of the grid connection, spatial compliance, and environmental permit maturity of the specific project. Two projects of the same size may carry very different risk profiles under the new rules.
• Conditionality: purchase agreements and financing documents for development-stage projects should address spatial compliance and land-coverage headroom (per regional unit for PV under Article 16 (1), and per municipal unit for wind under Articles 6 and 8) through express conditions precedent or specific representations, as general regulatory compliance language may not capture these risks.
• Transitional status: representations should confirm the permitting and environmental milestone reached by each project as at 19 August 2026, since both protection under Article Three and exposure to reassessment under Article Three (12) depend on it.
• Repowering assets: repowering candidates should be modelled on a stand-alone, unsupported market-price basis, with legacy tariff economics excluded from the base case, and their position under Article Three (7) and (10) should be confirmed.
• Storage and hybridisation: where storage is proposed as a mitigant for grid or curtailment risk, its contribution should be independently modelled, given that connection quality remains the main driver of project value.
• Reported challenges: for wind projects on the larger islands or in contested wind suitability areas whose value depends materially on the provisions targeted by the reported challenges, parties may wish to consider targeted risk allocation, such as specific indemnities or price adjustment mechanisms (see Section 5).

5. Litigation before the Council of State

According to press reports in early October 2026, the municipalities of Andros, Naxos and Small Cyclades, South Pelion, and Karystos, as well as the Regional Union of Municipalities of the South Aegean, have resolved to seek annulment of the Ministerial Decision before the Council of State (Greece’s supreme administrative court), and further challenges are being considered elsewhere. The grounds cited in those reports focus on the 300 km² island criterion, the scope of the minister’s statutory authorisation, consistency with other spatial plans, and the assessment of local carrying capacity.

Challenges of this kind are a familiar feature of major planning instruments in Greece. A strong initial reaction from local authorities does not in itself indicate that the Ministerial Decision will be annulled or that projects in the affected areas are unworkable, and any ruling may in any event be confined to specific provisions or areas. Investors and lenders should monitor whether petitions are lodged and how any proceedings develop, as part of standard diligence on projects in the contested areas, rather than treat them as a reason to pause activity.

6. Outlook for investors, developers, and financiers

Experience with the 2008 framework is instructive. It too met significant local opposition and legal challenge when it entered into force, yet it went on to underpin the growth of installed RES capacity in Greece from little more than 1 GW to over 20 GW. The Greek renewables sector has therefore already shown that it can absorb legal and political friction at the level of the planning framework and continue to develop.

Taken together, Law 5299/2026 and the new RES Spatial Framework provide shorter, more predictable permitting timelines and clearer siting rules, which should support project origination and transaction activity over the medium term. The outlook is not without constraints: grid capacity remains the principal practical bottleneck, and RAAEY’s implementation work and any clarifying measures will need to be followed closely. On balance, we regard the reforms as a constructive basis for continued investment, provided projects are assessed on their spatial compliance, permitting maturity, and grid connection quality.

We will continue to monitor any further implementing measures and the practical application of the framework by the competent permitting and environmental authorities. In the interim, we would be pleased to assist clients in assessing the impact of the reforms on specific projects, portfolios, or transactions.

Client Alert 2026-197