Greece National Climate Law - CCUS Update

Greece’s National Climate Law 4936/2022 (45 articles) sets the country’s climate-neutrality-by-2050 framework: five-year sectoral carbon budgets, emission cuts across power, buildings, transport and industry, and monitoring indicators tied to the National Energy and Climate Plan under EU Governance Regulation 2018/1999. For CCS specifically, the operating regime is layered: Joint Ministerial Decision 48416/2011 transposed the EU CCS Directive 2009/31/EC (site selection and characterisation, exploration and storage permitting, monitoring and reporting, closure and post-closure duties, financial guarantees, transfer of responsibility), with HEREMA designated licensing authority for CO2 geological storage (Law 4920/2022). Law 4964/2022 Article 173 added a fast track letting hydrocarbon concession holders convert existing exploration data directly into storage exploration and then storage permits (notably the Prinos Complex off Kavala), though its 12-month application window has lapsed. In December 2025 Greece adopted Law 5261/2025, its first comprehensive CCS statute: state ownership of storage sites, exploration licences up to five years, mandatory plume monitoring with operator liability until strict handover conditions are met, a dedicated CCS account funded by per-tonne storage fees, and a carbon-contracts-for-difference support route. The 2022 record therefore reads as the framework-setting step in an active legislative sequence, not a finished regime.