Greece enacts first hydrogen law, establishing national hydrogen market framework

On 4 July 2025, the long-awaited law 5215/2025 (Government Gazette A’ 116/2025) (the Law) was published. The Law lays down the country’s first dedicated legal framework for the production, transport, storage, distribution, and commercialization of renewable and low-carbon hydrogen. The Law represents a landmark step in the decarbonisation of the Greek economy and aims to facilitate investment in hydrogen infrastructure and renewable gases.

Importantly, Law 5215/2025 partially transposes Directive (EU) 2024/1788),¹ and integrates elements of the Commission's Delegated Regulation (EU) 2023/1184² concerning the certification of renewable hydrogen. It's a cornerstone in Greece’s alignment with the EU Hydrogen Strategy and the European Green Deal, but also with the revised National Energy and Climate Plan 2024-2030 (ESEK) which sets an ambitious framework of objectives for the uptake of renewable energy.

 

A licensing framework for hydrogen producers

Under the new framework, the Hydrogen Producer Certificate (HPC) is the first mandatory step for developing hydrogen production units in Greece. The process is already in force and fully digital, with applications submitted through the Regulatory Authority's for Energy, Waste and Water (RAAEY) platform. The HPC is issued for 25 years, renewable once for the same duration.

Applications must include technical, spatial and environmental details, along with a declaration on the electricity source – either a specific renewable plant (with location) or supply via the grid. Once submitted, applications are published within five business days, followed by a 15-day objection period and a 10-day response window. HPCs are issued within 30 days from the lapse of these periods. Amendments to the HPC are required if there's a reduction of installed capacity, maximum production capacity, and maximum hourly production capacity for hydrogen (kWhth) or there's an increase of those parameters by more than 50% or the energy supply method changes.

Within six months of receiving the HPC, developers must initiate the environmental licensing process. If the project is designed to inject hydrogen into the gas or hydrogen networks, a grid connection agreement with the competent operator must be concluded within 36 months. Off-grid projects must instead sign a contract for the construction and operation of a Hydrogen Control and Measurement Unit.

Finally, building permits, water use permits, installation and operation permits must be obtained to allow construction and commercial operation. These are issued under the general licensing rules on renewable projects under law 3982/2011.

On average a project would need 24 to 36 months to reach the ready-to-build status.

 

Certification as renewable hydrogen: Strict EU-based criteria

Pursuant to the Commission's Delegated Regulation (EU) 2023/1184, as incorporated into Greek law, hydrogen is certified as renewable depending on the electricity source used during production.

When the electricity is supplied directly from a renewable plant, and both the installation and connection are identified in the application, no further proof is needed.

If electricity is sourced from the grid, additional elements must be demonstrated – including the origin of the electricity, its renewable share, and the unit’s operating profile. Failing this, hydrogen may still qualify as renewable if the following conditions are cumulatively met:

• Additionality: the electricity must be generated from unsubsidised, new renewable plants.
• Temporal correlation: hydrogen must be produced during the same period the electricity is generated.
• Geographic correlation: the hydrogen and power plants must be located in the same bidding zone.

Certification is granted by DAPEEP via the Guarantees of Origin scheme and is key to accessing public funding and participating in renewable hydrogen offtake agreements.

 

Geographically Confined Hydrogen Networks

A distinguishing characteristic of the Law is the introduction of Geographically Confined Hydrogen Networks (GCHN) as a new category of licensed hydrogen infrastructure. These networks operate within a limited geographic area (such as an industrial zone), serve a defined group of users and public interest objectives, and are not connected to the national hydrogen grid.

A GCHN license is issued by RAAEY and can only be granted to legal persons. While subject to safety and technical requirements, GCHN benefit from a simplified regulatory framework and can be eligible for state support, especially when integrated into regional decarbonisation plans.

 

Guarantees of Origin and Incentives

A central feature of the new regime is the introduction of a national Guarantee of Origin (GoO) system for hydrogen. This will allow producers to certify the origin and carbon intensity of their product and trade that certification in line with EU rules. GoOs are also a prerequisite for subsidy access and will play a key role in cross-border trade and compliance with renewable energy targets. The Law introduces a formal basis for state support to hydrogen projects equipped with an HPC, in line with the EU’s Clean Industrial Deal State Aid Framework. Certified producers can benefit from investment aid and operational subsidies subject to the European Commission's prior approval. Public funding might also be available through national schemes and EU mechanisms such as the Hydrogen Bank or Greece’s Recovery and Resilience Facility, with additional support awarded via competitive procedures for flagship or integrated projects.

 

Next steps and implementation timeline

While the core licensing and certification rules are already in force, secondary legislation is expected over the coming months to clarify technical specifications, tariffs, and network access rules. In the meantime, RAAEY can begin receiving and evaluating applications under the new regime.

The new hydrogen law represents a significant regulatory milestone, bringing Greece in line with the EU’s low-carbon strategy. Investors, developers, and energy companies planning to engage in hydrogen production or infrastructure development should:

• assess whether their projects qualify as renewable or low-carbon;
• prepare for certification and public consultation procedures; and
• monitor secondary legislation and forthcoming tenders for infrastructure licenses and public support schemes.

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¹ Directive (EU) 2024/1788 of the European Parliament and of the Council of 13 June 2024 on common rules for the internal markets for renewable gas, natural gas and hydrogen, amending Directive (EU) 2023/1791 and repealing Directive 2009/73/EC (OJ L, 2024/1788, 15.7.2024, p. 1-107).
² Commission's Delegated Regulation (EU) 2023/1184 of 10 February 2023 supplementing Directive (EU) 2028/2001 of the European Parliament and of the Council by establishing a Union methodology setting out detailed rules for the production of renewable liquid and gaseous transport fuels of non-biological origin (OJ L 157, 20.6.2023, p. 11–19).