Climate Law & Carbon Footprint

The law also defines obligations by activity type, introduces monitoring mechanisms, and connects all national measures with the National Energy and Climate Plan (NECP).

The law sets obligations for:

• Businesses with Environmental Permits (A1 & A2 category projects, Article 19)
• Listed companies, banks, insurers, large municipalities (>20,000 inhabitants), and public utilities (Article 20)
• New Environmental Impact Assessments (EIAs) submitted from 2024 onwards (Article 18)
• Corporate fleets & transport (Article 12 – zero-emission vehicles)

Applies to A1 & A2 category projects with Environmental Permits that are not covered by the EU ETS. Core obligation: establish a GHG inventory, set a 2030 reduction target, and submit verified annual reports.

Which project categories are covered?

Indicative groups (under Law 4014/2011):

• Group 4: Environmental infrastructure (wastewater plants, waste management units)
• Group 6: Hotels, tourism facilities, sports centers, buildings
• Group 7: Livestock/poultry farms
• Group 8: Aquaculture
• Group 9: Industry, chemicals, renewables, energy storage

Implementation steps:

 1) Baseline & Inventory

2019 as base year for existing operations; first full operational year for new entrants. Covers Scope 1 & 2 emissions under ISO 14064-1 or GHG Protocol.

2) Reduction Targets

Mandatory –30 % by 2030 (intensity-based, e.g. kg CO₂e per guest-night or per ton of product or per m2).

3) Mitigation Plan

Energy efficiency, fuel switching, renewable sourcing, process optimization, and circular initiatives

4) Reporting & Verification

Compliance Report submitted by 01 Jan 2026 via the Electronic Environmental Registry (ΗΠΜ); annual reports verified by accredited auditors (ISO 14064-3)

Penalties

• Late submission: €100 per day (up to 0.1 % of annual turnover).
• Non-achievement of target: up to 0.5 % of turnover, proportional to deviation.

Law 4936/2022 requires annual reporting of GHG emissions for high-impact organizations.

Who is obligated?

• Listed companies on the Athens Stock Exchange
• Banks, credit & financial institutions
• Insurance and pension funds
• A1/A2 category projects under Law 4014/2011 with Environmental Permits
• Municipalities >20,000 residents
• Public utilities (water, energy, telecom, transport)
• Medium/large companies in high-intensity sectors (logistics, retail, construction, food & beverages, etc.)

Annual Emissions Report

• Scope 1: direct emissions (fuels, boilers, vehicles)
• Scope 2: indirect emissions (electricity, district heating)
• Scope 3: optional
• Submission: by October 31 each year, via ΗΠΜ template (Excel)
• Verification: accredited third-party, ISO 14064-3