Hydrogen Law 5215/2025: Greece’s New Legal Framework for Renewable & Low-Carbon Hydrogen

A Strategic Turning Point for Greece’s Clean Energy Transition

Greece has entered a decisive new phase in its energy transformation with the adoption of Law 5215/2025, which establishes a comprehensive legal framework for the organization, licensing, and operation of hydrogen production facilities. The new legislation, partially transposing EU Directive 2024/1788 on internal markets for renewable gases, natural gas, and hydrogen, positions Greece as one of the first EU Member States to define a detailed regulatory regime for renewable and low-carbon hydrogen.

This development represents more than a technical adjustment to EU energy policy: it is a strategic enabler for Greece’s National Energy and Climate Plan (NECP) and its broader ambition to become a regional hydrogen hub in Southeast Europe. By introducing structured procedures, investment incentives, and distinct operational standards, the law sets the foundation for a bankable and transparent hydrogen market capable of attracting both domestic and international investors.

A Dual-Track Licensing System with Predictable Timelines

At the heart of the new framework lies a two-phase licensing process, designed to accelerate project deployment while maintaining regulatory integrity.

• Phase I – Producer Certificate: Developers must first secure a Producer Certificate from the Regulatory Authority for Waste, Energy, and Water (RAWEW). The certificate, valid for up to 25 years and renewable for an equivalent period, serves as the legal cornerstone of a hydrogen project. It verifies the developer’s site control, energy sourcing, and corporate transparency.

• Phase II – Environmental, Installation, and Operation Licensing: Once the certificate is issued, the project advances through environmental assessment, connection approval, and final operating licensing. The law caps the entire authorization process at two years, extendable only once in exceptional circumstances.

This clear and time-bounded licensing architecture introduces a degree of regulatory certainty long absent in Greece’s energy infrastructure landscape, providing investors with a structured path from concept to operation.

Infrastructure and Cost Allocation: A Balanced Approach

The legislation distinguishes between grid-connected and standalone hydrogen facilities, offering flexible models for integration into Greece’s existing natural gas and energy systems.

A key innovation lies in the allocation of connection costs. Network operators bear the cost of measurement and control equipment and any required compression infrastructure, which are incorporated into their regulated asset base. Producers are responsible solely for the connection pipelines linking their facilities to the grid.

This balance ensures efficient cost distribution: producers contribute in proportion to their project footprint, while network operators recover strategic infrastructure investments through regulated tariffs, enabling systemic hydrogen infrastructure expansion across industrial regions.

Financial Support and State Aid Compliance

Recognizing the high capital intensity of hydrogen projects, Law 5215/2025 provides for investment and operational subsidies for renewable hydrogen production facilities, subject to European Commission approval under Articles 107 and 108 TFEU.

The forthcoming Joint Ministerial Decision, to be issued by the Ministers of National Economy & Finance and of Environment & Energy, will determine the exact eligibility criteria, subsidy levels, and funding procedures. While details remain pending, the inclusion of this mechanism signals strong government intent to mobilize public investment in line with EU State Aid and Green Deal frameworks, thereby improving the bankability of early-stage projects.

Ensuring Renewable Integrity: Compliance with EU Regulation 2023/1184

Hydrogen produced from renewable sources must meet the strict sustainability criteria set forth in EU Delegated Regulation 2023/1184. Producers must demonstrate that the electricity used originates from genuine renewable sources, satisfying the EU’s conditions on additionality, temporal correlation, and geographical correlation.

Compliance will be monitored through Guarantees of Origin (GoO) and verified by both the Regulatory Authority and the Renewable Energy Sources Directorate. This robust traceability framework ensures that Greek renewable hydrogen maintains full European certification equivalence, essential for future cross-border trading and export contracts.

Geographically Restricted Hydrogen Networks: Catalysts for Industrial Decarbonization

Law 5215/2025 also introduces the concept of Geographically Restricted Hydrogen Networks, localized hydrogen infrastructures serving specific industrial or commercial clusters.

These networks may operate under special regulatory conditions and limited unbundling requirements, enabling vertically integrated operators to supply hydrogen directly to industrial consumers within defined zones. This innovation supports industrial decarbonization, promotes energy autonomy, and encourages the formation of regional hydrogen valleys, a model already promoted under the EU’s “Hydrogen Valleys” initiative.

For developers and municipalities, this offers a unique opportunity to co-design closed-loop ecosystems where renewable hydrogen can power transport fleets, industrial furnaces, and local grids under a unified regulatory umbrella.

Opportunities and Challenges Ahead

Law 5215/2025 introduces a credible and investor-friendly framework, but the road to implementation remains complex. Key challenges include:

• Finalization of subsidy schemes and competitive tender procedures;

• Publication of network management codes and standardized access rules;

• Coordination between environmental permitting and state aid approvals; and

• Technical compliance with evolving EU certification and traceability standards.

Despite these uncertainties, early investors who can navigate the emerging regulatory ecosystem are likely to benefit from first-mover advantages, strategic positioning within Greece’s energy transition, and potential participation in EU-funded hydrogen infrastructure programs.

Tsamichas Law Firm: Your Legal Partner in Greece’s Hydrogen Transition

At Δικηγορικό γραφείο, we advise Greek and international clients across the entire energy and infrastructure value chain, combining deep regulatory expertise with transactional experience in project finance, public procurement, and EU environmental law.

Our team assists investors, developers, and industrial operators in:

• Structuring and licensing renewable and low-carbon hydrogen projects under Law 5215/2025;

• Conducting regulatory due diligence and securing Producer Certificates;

• Drafting and negotiating connection and offtake agreements;

• Navigating State Aid and EU funding frameworks; and

• Advising on sustainability compliance and certification procedures for renewable hydrogen.

With a strong understanding of Greece’s evolving energy law landscape and direct experience in strategic infrastructure and public-private partnerships, Tsamichas Law Firm stands ready to guide clients through the complexities and opportunities of Greece’s hydrogen marke