Hydrogen Law 5215/2025, forthcoming supplements to Energy Markets Law 4001/2011, and renewable hydrogen certification under RAAEY’s Decision Ε-186/2025
Introduction
Greece’s hydrogen regulatory system is entering a phase of finalisation. The adoption of Hydrogen Law 5215/2025 earlier this year provided the core legal foundation for hydrogen production, certification, and the establishment of local hydrogen networks (GCHN). Building on this framework, the Ministry of Environment and Energy has prepared a set of supplementary provisions to the Energy Markets Law 4001/2011, intended to integrate hydrogen into the country’s general energy legislation and to transpose the essential provisions of EU Directive 2024/1788 on common rules for the internal markets for renewable gas, natural gas, and hydrogen, and related elements of the EU Hydrogen and Decarbonised Gas Market Package.
These new provisions have now completed public consultation and have been formally submitted for voting before the Hellenic Parliament. Their adoption is widely expected within the coming days, marking a pivotal moment in the consolidation of Greece’s hydrogen framework.
In parallel, the Greek Energy Regulator’s (RAAEY) Decision Ε-186/2025, published on 29 July 2025, introduces the operational criteria for the certification of renewable hydrogen. While technically important, this decision must be read together with the imminent legislative supplements, which will determine how certification integrates into licensing, tariff-setting, and market access arrangements.
The Hydrogen Law as the foundational layer
Hydrogen Law 5215/2025 marked the first attempt to regulate hydrogen as an independent energy commodity, separate from the electricity and natural gas systems, by introducing the fundamental legal categories for the sector, including the Hydrogen Producer Certificate (HPC) and the definitions of renewable and low-carbon hydrogen. It further established the concept of local hydrogen networks, foreseeing the gradual development of decentralised hydrogen infrastructure.
However, the Law is deliberately framework-oriented. It anticipates a second legislative layer addressing network governance, tariffs, licensing, and market operation – all elements that stem from the Union-wide legal framework under EU Directive 2024/1788 and that are now incorporated into the forthcoming supplements to Energy Markets Law 4001/2011 that Parliament is expected to adopt shortly.
Supplementary provisions to Energy Markets Law 4001/2011: Completing transposition of EU Directive requirements
The supplements to Energy Markets Law 4001/2011 function both as national regulatory provisions and as the mechanism for transposing major elements of EU Directive 2024/1788 into Greek law. The Directive requires Member States to create a transparent, competitive, and interoperable hydrogen market, and the suggested legislative provisions reflect this objective.
Hydrogen transmission and distribution framework
The suggested provisions introduce the legal foundation for hydrogen transmission and distribution system operators, incorporating Directive-based rules on operator certification, network planning, non-discriminatory access, and unbundling. The legislative design mirrors the Directive’s recognition that hydrogen networks are, in the initial phase, likely to be regional, modular, and linked to industrial clusters.
Licensing of hydrogen supply activities
Following the Directive’s provisions on market opening and supplier obligations, the supplements introduce a new dedicated hydrogen supply licence. Suppliers will be subject to financial, organisational, and technical suitability requirements, as well as obligations relating to transparency, contractual fairness, and the provision of information to system operators and regulatory authorities.
Network access and tariffs
The supplements transpose the Directive’s rules on access to hydrogen networks, providing for regulated, transparent, and non-discriminatory access conditions. RAAEY will be tasked with issuing a tariff methodology in line with the Directive’s principles, ensuring cost-reflective, fair, and objective pricing.
The framework further anticipates the possibility of tariff differentiation based on the characteristics of the hydrogen – such as renewable origin – consistent with the Directive’s decarbonisation objectives.
Transparency, interoperability, and data obligations
Consistent with the Directive’s obligations, the suggested provisions introduce obligations relating to data availability, publication of technical information and network development plans, and cooperation between system operators and market participants. This includes requirements for interoperable data formats and timely information provision to ensure efficient connection, balancing, and system operation.
These rules underpin the future integration of Greek hydrogen infrastructure into a wider cross-border hydrogen market within the EU.
Renewable hydrogen certification under RAAEY’s Decision Ε-186/2025
RAAEY’s Decision Ε-186/2025 provides the operational detail necessary for producers to substantiate renewable status. It incorporates the methodology of EU Delegated Regulation 2023/1184, requiring evidence of additionality, temporal correlation, and geographical correlation for electricity inputs, together with robust monitoring and metering arrangements.
This decision’s importance is heightened by its interaction with the forthcoming supplementary provisions to Energy Markets Law 4001/2011. Certification is poised to become a key determinant of:
- Compliance with market participant obligations
- Eligibility criteria for hydrogen supply licences
- Access conditions to hydrogen networks
- Tariff treatment and network prioritisation
- Participation in GCHN infrastructure
- Alignment with national and EU financial support mechanisms
- Contractual requirements for renewable-only supply
Renewable certification thus becomes a fundamental prerequisite for participation in Greece’s fully regulated hydrogen market.
Implications for market participants
The convergence of the Hydrogen Law, the forthcoming supplements to the Energy Markets Law, and RAAEY’s Decision Ε-186/2025 signifies a structural transformation of Greece’s hydrogen market.
Producers must align project design, electricity sourcing strategies, and monitoring systems with both certification requirements and future network access conditions. Grid-connected projects, in particular, will need early validation of compliance with EU correlation rules.
Investors stand to benefit from the regulatory certainty expected once the supplements are adopted within the coming days. A defined supply licensing regime, clear network access principles, and forthcoming tariff structures will support more accurate risk assessments and bankability models.
Industrial off-takers will need to prepare for supply contracts that incorporate explicit certification obligations, reporting duties, and remedies for loss of renewable status.
Integrated energy groups should begin evaluating the impact of Directive-based unbundling rules on corporate structures, especially where production, supply, and network operations are conducted under a common ownership umbrella.
Outlook
With parliamentary adoption of the supplements expected within the coming days, Greece is poised to finalise a comprehensive hydrogen market framework that is fully aligned with the principles and requirements of EU Directive 2024/1788. This will enable Greece to move from the design phase to the operational phase of hydrogen market development.
Market participants should now complete the technical, contractual, and organisational measures required to ensure compliance with the obligations concerning system integrity, data availability, network access, and market conduct, thereby ensuring readiness for the regulatory framework that will crystallise soon.
As the new framework enters into force, attention will shift from legislative completion to implementation. Regulatory authorities, system operators, and market participants will begin applying the new licensing, access, and data-governance rules in practice, setting the conditions for the first wave of operational hydrogen projects and early network development initiatives.
Client Alert 2025-292
