Structuring the Future: Greece Enacts Landmark Hydrogen Legislation

With the enactment of Law 5215/2025, Greece has taken a pivotal step toward establishing a structured and regulated hydrogen economy. While the new legislation only partially transposes the provisions of Directive (EU) 2024/1788 on internal gas and hydrogen markets, it aligns national law more closely with the European Union’s framework for market decarbonisation. It also directly supports the ambitions of Greece’s National Energy and Climate Plan (ESEK), which outlines an aggressive trajectory for integrating renewables across sectors.

Hydrogen Typologies and Production Models

The law introduces specific classifications for hydrogen, drawing a clear line between renewable hydrogen—produced using electricity from renewable sources—and low-carbon hydrogen, whose production processes must comply with set carbon emissions thresholds. It also defines two main operational models for hydrogen production units: those that function independently of existing gas or hydrogen infrastructure, and those integrated into the transmission or distribution grid. This distinction will be essential for licensing, infrastructure planning, and policy support.

A Two-Stage Licensing Pathway

At the heart of the new legal regime lies a two-phase permitting structure, drawing from Greece’s experience with renewable energy project approvals. The first phase involves obtaining a hydrogen Producer Certificate, valid for up to 25 years and renewable for the same duration. The second phase encompasses all additional permits, beginning with environmental clearance and culminating in both installation and operational authorisations. For units connected to the grid, this phase also requires agreement on connection terms and execution of a binding connection contract with the relevant system operator.

Certification of Renewable Hydrogen Under EU Law

One of the most critical components of the framework is the determination of whether the electricity used in hydrogen production can be certified as renewable under Regulation (EU) 2023/1184. Grid-connected units must meet detailed criteria, including the level of renewable energy penetration in the unit’s location, the number of operational hours per year, and the carbon intensity of local electricity production. Where these primary benchmarks are not satisfied, electricity can still be considered renewable if three conditions are met: the project must add new renewable generation capacity (additionality), align electricity use with renewable generation on a time basis (temporal correlation), and locate both the hydrogen and renewable installations within the same market bidding zone (geographic correlation). Provided these criteria are fulfilled, the Renewable Energy Sources Operator & Guarantees of Origin (DAPEEP) can certify the resulting hydrogen accordingly. These guarantees are indispensable for establishing the provenance of renewable hydrogen and unlocking its commercial potential under both EU and global market standards.

Independent Hydrogen Networks: A New Infrastructure Paradigm

A defining feature of the new legal framework is its introduction of Geographically Confined Hydrogen Networks (GCHNs)—autonomous hydrogen infrastructures operating outside the national transmission system. These localised systems are designed to meet specific commercial or industrial demands while advancing broader public interest objectives such as energy security and regional resilience. GCHNs are subject to a dedicated regulatory process that begins with the issuance of a GCHN Licence by the Greek Regulatory Authority for Energy, Waste and Water (RAAEY). This licence grants the right to own and build a network and is available only to legal entities that meet requirements related to technical expertise, financial strength, competitive neutrality, demand coverage, and network efficiency. A separate licence is required for managing such networks. This GCHN Management Licence may be granted either to the holder of the initial infrastructure licence or to a vertically integrated company, provided that specific conditions are met. In cases where market competition may be distorted or multiple applicants target the same geographical area, the granting of these licences may be subject to public tender procedures. RAAEY is also tasked with conducting a review every seven years to assess the competitive, infrastructural, and market-wide impact of the GCHN licensing framework within Greece and across the European hydrogen market.

Future Rules and Network Code Requirements

Further operational details governing the development and use of GCHNs will be captured in a forthcoming Network Code to be issued by RAAEY. This code is expected to address a range of essential topics, including technical standards, access conditions, transport and infrastructure-use agreements, metering distribution, dispute resolution mechanisms, and general obligations related to system maintenance and performance.

Financing and Support Mechanisms

To catalyse early-stage hydrogen investments, the law enables the adoption of financial support schemes, whether through the national Public Investment Development Programme or via targeted operational or capital expenditure aid, subject to approval by the European Commission. While such mechanisms can play an important role in kickstarting market activity, the deployment of funding must be carefully evaluated to ensure balanced development across all segments of the hydrogen value chain. A narrowly focused or uneven incentive structure could hinder the formation of a sustainable and self-sufficient market.

From Legal Foundation to Market Execution

While this legislation represents a necessary and strategically timed intervention, its current form provides only the high-level scaffolding for Greece’s future hydrogen economy. The bulk of the regulatory detail remains to be fleshed out in secondary laws and delegated instruments. Crucial areas, including the integration of hydrogen as a storage vector for renewable energy, have yet to be addressed, leaving important gaps in the framework.

The pace and substance of follow-up legislation will determine how quickly the domestic market can move from blueprint to bankability. Greece’s success in scaling its hydrogen sector will hinge on its ability to simultaneously reinforce the supply and demand sides of the equation, unlock funding across all project phases, and deliver legal certainty to developers and investors alike. The road ahead requires both urgency and precision—but the foundation has now been laid.