Repowering renewable power projects in Greece: Regulatory evolution and a growing investment opportunity

How regulatory developments are shaping the next phase of renewables growth

Introduction: A critical juncture for Greece’s energy transition

Greece’s renewable energy sector is approaching a pivotal stage. A significant share of early wind farms and several first-generation solar photovoltaic parks are reaching the end of their useful life cycle, making repowering an increasingly material issue for investors. As these assets mature, repowering decisions become strategic rather than optional, directly affecting asset value preservation, reinvestment planning, and long-term returns.

While repowering – referred to in Greece as a “radical overhaul” or “radical renewal” involving the full replacement of key equipment – offers a cost-effective pathway to extend asset life and enhance performance, its investment potential depends heavily on regulatory clarity. Greece’s current legal framework, although formally defined, remains partially misaligned with EU law, introducing uncertainty that can delay project execution, complicate financing, and ultimately slow the pace of decarbonisation.

The Greek legal framework for repowering

Greek law formally recognises “radical renewal” or “radical overhaul” (ριζική ανανέωση in Greek) of renewable energy projects, a concept that corresponds, in functional and economic terms, to repowering as understood at the EU and market level. For the purposes of this briefing, the term repowering is used to describe projects that meet the statutory criteria for radical renewal or overhaul under Greek law.

The core technical definition of repowering is set out in Ministerial Decision ΥΠΕΝ/ΔΑΠΕΕΚ/114746/4230/2020, as amended and in force (the Producer’s Certificates Regulation), which was issued pursuant to the enabling provisions of Law 4685/2020. The Regulation defines repowering through technology-specific minimum replacement thresholds, requiring the full replacement of key generating equipment (e.g., all turbines for wind projects, all modules and inverters for solar photovoltaic projects, and the principal electromechanical systems for other renewable energy sources and high-efficiency cogeneration technologies). Partial upgrades that fall below these thresholds do not qualify as repowering and are assessed under separate permitting pathways.

The same Regulation governs the renewal of the project’s core authorisation, namely the Producer’s Certificate (or Certificate of Special Projects as applicable). Producer’s Certificates may be renewed for up to twenty-five (25) additional years, with renewals granted in successive five-year periods. Where a renewal application concerns a repowering project, a modified Producer’s Certificate is issued that extends the validity of the existing authorisation by twenty-five (25) years from its original expiry date and expressly refers to the approved repowering. The legal identity of the project is thus preserved, while the framework introduces an implementation safeguard by providing for automatic revocation of the modified certificate if the repowered station is not brought into operation within five (5) years.

Spatial flexibility in the context of repowering is limited. Relocation of the project to a new site is not permitted, although repositioning of equipment within the originally licensed project site (also referred to as the “polygon”) is allowed, and a controlled expansion of the polygon may be approved, subject to compliance with statutory siting criteria. For wind projects, the Regulation also allows for a reduction in installed capacity and number of turbines, subject to a proportional reassessment of availability and production criteria.

Law 4685/2020 itself does not regulate repowering as a distinct legal category. Its relevance is primarily institutional and procedural: it establishes the Producer’s Certificate licensing process, sets out general licensing and environmental permitting principles, and empowers the issuance of secondary regulation – most notably the Producer’s Certificates Regulation – that substantively defines repowering. As such, any facilitation of repowering under Greek law derives from implementing acts and administrative practice rather than directly from the primary provisions of Law 4685/2020.

Substantive repowering-specific provisions are instead introduced by Law 4951/2022, as amended and in force. Article 42 expressly recognises the right of renewable energy and high-efficiency cogeneration projects to undergo repowering and links the treatment of such projects to the Producer’s Certificates Regulation. For projects exempt from the Producer’s Certificate regime, Article 42 establishes a dedicated procedure for obtaining new grid connection terms from the competent grid operator in the context of repowering.

Article 42 further provides for priority examination and an accelerated timeline for the issuance of new grid connection terms, provided that cumulative conditions are met. These include, in particular, that any increase in the repowered project’s maximum installed capacity does not exceed fifteen per cent (15%) and that the modified technical characteristics do not impose a greater burden on the grid compared to the original configuration. Where these conditions are not met, grid connection is assessed under the general rules applicable to new or materially modified projects. The law also explicitly allows the co-location of energy storage with repowered projects, subject to the relevant licence or certificate amendments. In addition, Article 42 provides for priority examination of applications for the issuance of an Installation Licence in the context of repowering, provided that no renewed documentation of land-use rights is required; however, this facilitation does not extend to the imposition of binding decision deadlines and therefore does not eliminate execution risk across the permitting life cycle.

Finally, Law 4951/2022 introduces a decisive rule on revenue treatment. Projects that apply for repowering from 31 October 2024 onwards are required to participate exclusively in the electricity market and are not eligible for operating aid throughout the operating life of the repowered plant. Repowering applications submitted prior to that date remain governed by the support framework applicable at the time of submission.

Overall, the Greek legal framework for repowering is technically detailed and legally coherent, but also fragmented. Repowering is enabled and defined primarily through secondary regulation and targeted statutory interventions rather than through a single, consolidated primary-law regime, leaving key aspects of implementation dependent on administrative practice rather than explicit legislative design.

Against this regulatory backdrop – where repowering is clearly enabled in law but implemented through a layered and partially discretionary framework – the strategic and financial implications for investors and lenders are determined by how these rules operate in practice, particularly in terms of revenue certainty, permitting execution, and risk allocation.

Strategic and financial implications

Repowering in Greece presents a differentiated risk and return profile that investors and lenders must assess in light of the specific legal and regulatory structure described above. While repowering is clearly enabled in law and supported by detailed technical rules, its economic viability depends on how revenue treatment, permitting execution, grid access, and administrative discretion interact in practice.

A primary determinant of bankability is the applicable revenue regime. Repowering projects that retain access to pre-existing operating support benefit from predictable cash flows and greater revenue visibility, which in turn support longer financing tenors and more favourable debt terms. In such cases, repowering operates as a value-preserving investment, extending asset life while improving efficiency and output within an established risk profile.

By contrast, repowering projects that are required to run without operating support – particularly those applying from 31 October 2024 onwards under Law 4951/2022 – are exposed to wholesale electricity market volatility throughout their operational life. While merchant operation is not uncommon in mature renewable markets, it materially affects project economics by increasing revenue uncertainty, tightening debt sizing constraints, and shifting risk allocation towards equity. As a result, these projects tend to be assessed less as extensions of legacy assets and more as new merchant investments.

Beyond revenue considerations, administrative execution risk remains a key factor. Although the legal framework provides for renewal of the Producer’s Certificate and, in certain cases, priority treatment for grid connection, it does not impose binding, end-to-end timelines across the full permitting life cycle of repowering projects. Environmental review requirements in particular remain subject to administrative discretion, and the potential application of full environmental impact assessments can extend approval timelines beyond those typically assumed in financial models.

This execution risk is likely to be accentuated by the anticipated revision of Greece’s spatial planning framework for renewable energy. Many existing projects were developed lawfully under earlier spatial planning regimes, and the manner in which repowering applications will be assessed under the forthcoming framework – particularly in the absence of explicit transitional or grandfathering provisions – introduces an additional layer of forward-looking uncertainty. This issue is increasingly relevant for site-specific due diligence and long-term investment planning.

Grid access considerations further shape project feasibility and timing. The legal framework provides for priority examination and accelerated treatment of grid connection requests in the context of repowering, subject to clearly defined conditions, including limits on capacity increases and technical impact on the grid. Where these conditions are not met, projects may be subject to general grid availability assessments and queuing mechanisms, with potential implications for construction schedules and the timing of efficiency gains. Careful calibration of the technical scope of repowering therefore remains an important strategic consideration.

Finally, strict technical compliance is a prerequisite for regulatory certainty. The replacement thresholds and siting constraints that define repowering under Greek law are not merely formal requirements; they determine eligibility for licence renewal, grid connection treatment, and continued operation. Deviations from these requirements risk reclassification of the project or exposure to more onerous permitting pathways, with direct financial consequences.

Overall, repowering in Greece offers a credible pathway to extend the life and performance of existing renewable assets, but its investment profile is shaped less by technical feasibility than by regulatory execution. While the Greek framework provides a clear legal basis for repowering, the absence of binding permitting timelines, repowering-specific environmental assessment rules, and operational spatial planning tools means that outcomes continue to depend heavily on administrative practice. These characteristics stand in contrast to the implementation model envisaged under RED III (Directive (EU) 2023/2413), which places emphasis on proportionate permitting, incremental impact assessment, and enforceable acceleration mechanisms. As a result, the strategic and financial considerations outlined above cannot be fully separated from the broader question of how effectively Greece translates RED III objectives into practical, time-bound procedures – an issue examined in the following section.

RED III and the Greek repowering framework: Alignment in principle, gaps in delivery

By enabling the modernisation of existing renewable energy assets, repowering allows European Union Member States (EU MSs) to increase renewable output without additional land take, reduce permitting friction, and maximise the use of existing grid infrastructure. Recognising this, RED III establishes a clear EU benchmark aimed at accelerating repowering through proportionate permitting, limited environmental reassessment, and binding administrative timelines.

Against this benchmark, Greece is broadly aligned at the level of conceptual recognition and technical definition, but alignment weakens materially at the level of delivery mechanisms and procedural guarantees.

RED III treats repowering as a distinct regulatory category, warranting differentiated and simplified treatment compared to new projects. It requires that permitting procedures be proportionate to the incremental impacts of the modification, that existing sites and grid connections be reused wherever technically feasible, and that administrative decision-making be subject to shortened and binding timelines. These requirements are designed to ensure that repowering functions as an acceleration tool rather than being absorbed into standard development processes.

Greek law recognises repowering as a distinct concept and defines it with a high degree of technical specificity. However, as outlined in section 2 above, this recognition is achieved primarily through secondary regulation and targeted statutory provisions rather than through a consolidated primary-law regime. As a result, while repowering is legally enabled, it is not embedded as a fully autonomous permitting track with clearly differentiated procedural consequences.

In particular, Greek law does not establish an explicit rule limiting environmental assessment to the incremental impacts of repowering. Although general principles of proportionality exist within the environmental permitting framework, their application to repowering remains dependent on administrative discretion rather than on a binding, repowering-specific standard, as envisaged under RED III. In practice, repowering projects may therefore still be subject to full environmental reassessment, undermining the Directive’s acceleration objective.

Similarly, while certain elements of priority treatment exist – notably in relation to grid connection and the examination of installation licence applications under Article 42 of Law 4951/2022 – Greek law does not provide for binding, end-to-end timelines covering the full permitting life cycle of repowering projects.

The treatment of spatial planning further illustrates this divergence. RED III places strong emphasis on the reuse of existing sites and on the designation of Renewable Acceleration Areas (RAAs) to enable streamlined permitting. In Greece, RAAs have not yet been designated or operationalised, and existing national spatial planning concepts have not been formally aligned with the RED III framework. As a result, repowering projects remain exposed to evolving spatial planning rules without the legal certainty or presumptions envisaged by the Directive.

Finally, Greece’s decision to impose mandatory merchant-only operation on repowered projects from 31 October 2024 onwards represents a national policy choice rather than a requirement under RED III. While RED III is neutral on revenue support, its core objective is to remove non-economic barriers to repowering. The Greek approach, by contrast, combines procedural complexity with a stricter revenue regime, which may dampen investment incentives even where technical and system-level benefits are clear.

In sum, Greece aligns with RED III at the level of conceptual recognition and technical definition of repowering, but falls short in translating this alignment into a coherent, accelerated, and predictable permitting regime. The gap is not one of legal permissibility but of regulatory design: repowering is enabled, yet not structurally prioritised in the manner envisaged by EU law. Bridging this gap will be critical if repowering is to fulfil its role as a core instrument of Greece’s energy transition rather than remaining a technically available but procedurally constrained option.

Greece in a European context: Repowering frameworks compared

To place Greece’s repowering framework in context, the table below compares how selected EU MSs have structured and implemented their repowering regimes, highlighting differences in regulatory design, permitting certainty, and investor readiness.

Country	Repowering approach (legal base)	Indicative predictability (market practice)	Support retention (general rule)	Renewable Acceleration Areas (RAAs): mapping and identification	Takeaway
Germany	Repowering is handled under the Federal Emissions Control Act (BImSchG), which provides an established permitting route for material modifications, including turbine replacement. Repowering is explicitly recognised in planning and permitting practice.	Relatively high predictability in EU terms, supported by statutory procedures and recent permitting reforms; litigation risk remains, but is well understood by the market.	No automatic continuation of legacy support; repowered projects generally move to new market-based or auction-based remuneration, depending on eligibility.	Most advanced among EU MSs. Existing wind priority areas with prior : Strategic Environmental Assessment (SEA) are widely expected to qualify as RAAs; further areas are being designated via regional planning.	Germany combines legal clarity with mature administrative practice, explaining why most EU repowering activity is concentrated there (as consistently noted by WindEurope).
Italy	No dedicated repowering regime. Treatment depends on whether changes are considered “substantial”; substantial repowering typically triggers the Single Authorisation (Autorizzazione Unica) procedure.	Moderate predictability; timelines depend heavily on how authorities classify the modification and on regional implementation.	Legacy incentives are not automatically preserved; materially modified projects must qualify under the support framework in force at the time of repowering.	In progress but incomplete. RAA mapping is expected to build on regional “suitable areas” and national mapping exercises; no comprehensive terrestrial RAAs formally designated yet.	Italy offers legal pathways but remains procedurally complex; benefits of acceleration areas are still largely prospective.
France	Repowering assessed under the Environmental Authorisation regime; “substantial” changes require full re-authorisation, similar to a new project.	Legally certain but potentially slow; predictability depends on early classification by authorities and can involve long lead times.	New support possible, but generally through fresh awards, not continuation of legacy tariffs.	Decentralised approach. Municipal “acceleration zones” (ZAERs) are being identified and validated at regional level; offshore zones exist, but RAA equivalence is not yet explicit.	France provides legal certainty but limited speed; repowering is feasible mainly for developers able to absorb longer timelines.
Spain	Repowering is recognised in law but often intersects with multiple permitting, grid, and environmental procedures, creating layered approval requirements.	Lower predictability in practice, despite EU-level simplification objectives; sequencing of approvals is a key risk factor.	Legacy remuneration rarely preserved; material changes usually imply new regulatory treatment.	Fragmented and non-coordinated. Several mapping tools exist, but no consolidated RAA designation process; offshore priority areas may serve as RAAs, but are not formally confirmed.	Spain illustrates the implementation gap highlighted by WindEurope: high technical potential, limited repowering delivery.
Portugal	Repowering is generally treated as a new licensing process where changes are material, including renewed environmental assessment.	Moderate to low certainty, especially where full environmental reassessment is triggered.	No automatic support continuity; repowered assets rely on merchant exposure, power purchase agreements , or new support mechanisms if available.	Mapping underway. Potential onshore RAAs identified and expected to undergo SEA; offshore spatial plan approved, but RAA linkage remains unclear.	Portugal shows administrative progress in spatial planning, but limited regulatory differentiation for repowering so far.
Greece	Repowering is legally recognised and often defined as a “radical overhaul” or “radical renewal” (i.e., full replacement of key equipment). In practice, it is frequently treated close to a new project, with limited procedural differentiation.	Formally defined but weakly streamlined. Absence of a genuinely simplified, time-bound repowering pathway creates permitting and scheduling risk.	Limited continuity. Legacy support is not automatically preserved; post-31 October 2024 repowered projects are explicitly market-only.	No RAAs designated yet. RED III only partially transposed. Existing national concepts (e.g., “Areas of First Choice”) have not yet been aligned or confirmed as RAAs.	Greece has a clear legal definition of repowering but lacks the operational acceleration and spatial tools seen in leading markets.

The comparative analysis makes clear that the challenges identified in Greece are not unique to the Greek market. While Greece’s repowering framework is technically well defined, procedural uncertainty, discretionary environmental review, and the post-2024 shift to market-only remuneration reduce its attractiveness for investors and lenders. However, similar structural constraints are evident across most EU MSs. With the notable exception of Germany, repowering is still largely treated as equivalent to new development, leading to prolonged permitting timelines and regulatory uncertainty. As a result, the acceleration effects envisaged under RED III have yet to materialise in practice across much of Europe. The concerns expressed by Greek power producers therefore reflect a wider EU-level implementation gap, rather than a country-specific deficiency.

Navigating the repowering landscape: Strategic considerations for investors, lenders, and policymakers

For investors and lenders, the Greek repowering framework presents both opportunity and challenge. Strategic selectivity is essential. Projects that retain access to pre-2024 operational support should be identified and prioritised, as they offer the highest degree of revenue predictability and bankability. Repowering projects subject to mandatory merchant-only operation from 31 October 2024 onwards remain viable, but require more conservative financial structuring, robust sensitivity analysis, and careful management of market exposure to ensure long-term financial resilience.

Administrative execution remains a critical factor. Timely submission of renewal applications – ideally well in advance of the expiry of the Producer’s Certificate – can reduce the risk of procedural delays and support access to priority treatment where available, including in relation to grid connection terms and installation licensing. Equally important is a detailed understanding of the applicable technical thresholds and project-site (polygon) constraints. Compliance with these requirements is non-negotiable for eligibility, licence renewal, and regulatory certainty; any deviation risks reclassification, delay, or loss of procedural facilitation.

Risk mitigation extends beyond formal permitting. Anticipating the potential scope of discretionary environmental review, planning for procedural contingencies, and incorporating flexible design elements – such as the co-location of energy storage where permitted – can strengthen both operational performance and revenue stability. Investors and lenders are therefore well advised to stress-test financing structures against merchant-only exposure, permitting delays, and evolving market conditions.

Policymakers, meanwhile, play a pivotal role. Ensuring that repowering procedures are predictable, proportionate, and aligned with RED III objectives – particularly through binding timelines, incremental environmental assessment, and effective spatial planning tools – is not merely a regulatory exercise. It is central to unlocking the full potential of Greece’s existing renewable fleet, attracting long-term investment, and accelerating deployment in line with national and EU decarbonisation goals.

In short, navigating Greece’s repowering landscape requires a combination of proactive regulatory engagement, meticulous project planning, and strategic foresight. Those who act early and structure projects in line with the practical operation of the framework are best positioned to capture both economic value and system-level benefits.

Conclusion

Repowering stands at the intersection of opportunity and regulatory constraint in Greece’s renewable energy sector. It offers a cost-effective and high-impact pathway to extend the life of existing renewable assets, enhance efficiency, and accelerate decarbonisation, making it a critical component of the country’s energy transition. The modernisation of wind farms, solar parks, and high-efficiency cogeneration units can unlock significant output gains, enable the integration of storage, and reinforce system flexibility – benefits that are particularly valuable as Greece pursues ambitious EU climate and energy targets.

At the same time, the full potential of repowering is constrained by structural gaps in the regulatory framework. While Greece has clearly codified the technical definition of repowering and introduced targeted facilitation measures, binding permitting timelines, repowering-specific environmental assessment rules, and fully operational spatial planning tools remain largely absent. Compared with leading EU markets, procedural uncertainty, reliance on administrative discretion, and the post-2024 shift to mandatory merchant-only operation increase financial and execution risk, with implications for investment pace and financing conditions.

For investors and lenders, this environment demands disciplined project selection, early regulatory engagement, and conservative financial assumptions. For policymakers, the challenge is equally clear: to translate technical eligibility into a predictable, accelerated, and EU-aligned implementation framework that reduces uncertainty and strengthens investor confidence. Doing so would allow repowering to function as the acceleration tool envisaged under RED III, rather than as a technically available but procedurally constrained option.

Ultimately, repowering is not merely a technical upgrade; it is a strategic imperative. The effectiveness of Greece’s energy transition will depend in part on whether regulatory design evolves to fully support the reinvestment of capital in existing renewable assets. Those stakeholders who anticipate these dynamics and engage proactively – both at project and policy level – will be best placed to capture the dual benefits of enhanced asset performance and meaningful contributions to Greece’s clean energy future.

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