Laws, Regulations and Codes

A. Legal Framework

The import and supply of natural gas in Greece and the development of its distribution network was initially regulated by Law 2364/1995 (Government Gazette Α’ 252/6.12.1995). According to Law 3428/2005 (Government Gazette Α’ 313/27.12.2005)on the “Liberalization of the Natural Gas Market”, incorporates into national Law the provisions of the European Directives and Regulations on common rules in the internal gas market (Directive 2003/55/EC and EC1775/2005 -2nd energy package).

Subsequently, the new energy Law 4001/2011 (Government Gazette A’ 179/22.8.2011) on the energy markets for electricity and natural gas was adopted, which mostly replaced Law 3428/2005 in order to harmonize national legislation with the provisions of the “3rd energy package”, as defined by Directive 2009/73/EC and Regulations (EC) 713/2009 and 715/2009. The Law 4001/2011, has undergone numerous amendments and is now in force as follows:

https://www.kodiko.gr/nomothesia/document/121622/nomos-4001-2011

In compliance with the provisions of Art. 90 par. 1 of Law 4001/2011, the Licensing Regulation was approved by the Minister of Environment and Energy (Government Gazette B’ 3430/17.8.2018) and subsequently in compliance with the Art. 80C par. 1 of the same Law, RAE issued the Natural Gas Distribution License (Government Gazette B’5904/31.12.2018) and the Natural Gas Distribution Network Management License (Government Gazette B’5923/31.12.2018) ) for EDA ATTIKIS S.A, the Natural Gas Distribution License (OGG Β’ 5922/31.12.2018) and the Natural Gas Distribution Network Management License (OGG Β’ 5916/31.12.2018) for EDA THESS, as well as the Natural Gas Distribution License (OGG Β΄ 5905/31.12.2018) and the Natural Gas Distribution Network Management License (OGG Β’ 5903/31.12.2018) for DEDA.

Following the corporate transformation of DEPA S.A. (partial demerger of the infrastructure sector), the above Licenses were amended as follows in order to reflect the change in the shareholding composition of the companies:

On 30/09/2023, the merger by absorption of EDA ATTICA S.A. and EDA Thessaloniki-Thessaly S.A. by DEDA was completed. The merger was carried out in accordance with the provisions of Law 4601/2019 (OGG A’ 44/09.03.2019).

Based on the above, the Distribution Licenses and Distribution Network Management Licenses of EDA ATTIKIS and EDA THESS were automatically transferred to DEDA, under the same terms and conditions.

Furthermore, on February 14^th, 2024, the name of “DEDA” was changed to “enaon EDA HELLENIC GAS DISTRIBUTION COMPANY Sole-Shareholder Societe Anonyme” with the distinctive title “enaon EDA”.

B. REGULATORY FRAMEWORK

Distribution Network Management Code

Following the provisions of paragraph 8 of Art. 80 of Law 4011/2011, the Natural Gas Distribution Network Management Code (Government Gazette B’ 487/20.02.17), which was amended by virtue of Decree No. 702/2017, 298/2018, 642/2018 and 420/2021 decisions of RAE The latter amendment (RAE Decision 420/2021 – Government Gazette B’ 3726/12.08.2021), expanded the scope of the Code to include all Distribution Network Operators.

Tariff Regulation of Basic Distribution Activity

By OGGB’3067/26.09.2016, the Tariff Regulation of Basic Distribution Activity was issued.

Subsequently, the Tariff Regulation was amended by Government Gazette B’3727/12.08.2021 in order to broaden its scope to include all Distribution Network Operators.

However, with Government Gazette B 3358/30.06.2022 the 2^nd revision of the Tariff Regulation was amended, in order to incorporate the provisions of par. 8 of article 88 of Law 4001/2011 for the Emerging Natural Gas Areas, which stipulates the possibility of recovering the under-recovery of the Required Revenue from the tariffs of other Natural Gas Distribution Networks, whose Management Licences belong to the same legal entity.

Metering Regulation

By OGG B’ 4818/24.12.2019, the Gas Distribution Network Metering Regulation was issued. Subsequently, with Government Gazette B’ 2794/30.06.2021 the Metering Regulation was amended, in order to expand its scope to include all Distribution Network Operators.

Remote Distribution Networks & Compressed Natural Gas CNG

By RAE Decision 643/2018 (OGG B’ 3334/10.08.2018), the framework for the development of Remote Distribution Networks using Compressed/Liquified Natural Gas was established.

By RAE Decision 822/2018 (OGG B’ 4298/27.09.2018), the terms and criteria of the tender for the CNG Virtual Pipeline Services were approved.

By RAE Decision 821/2018 (OGG B’ 4298/27.09.2018), the maximum price per kWh for the Compressed Natural Gas Virtual Pipeline service for the year 2018 was determined in accordance with the decision of RAE 643/2018.

By Decision of the Ministry of the Environment and Energy, the Technical Regulation of Decompression Facilities of Compressed Natural Gas and Auxiliary Devices was issued (OGG B’ 1809/21.05.2018).

By Decision of the Ministry of the Environment and Energy, the Technical Regulation of Land LNG Gasification Units was issued (OGG Β’ 3148/12.05.2023).

OGG B’ 5661 / 17.12.2018 set out the technical specifications, competent bodies, terms and conditions for the establishment and operation of service stations with installation of supply devices (refueling points) for compressed natural gas (CNG) in wheeled vehicles, such as: 1. service stations pure compressed natural gas (CNG) or 2. mixed service stations a. liquid fuels, liquified petroleum gas (LPG) and compressed natural gas (CNG) or b. liquefied petroleum gas (LPG) and compressed natural gas (CNG) or c. liquified petroleum gas and compressed natural gas (CNG), activities not related to the management of natural gas distribution networks. In this context, those who wish to invest in the compression, transport, and supply of compressed natural gas (CNG) can operate freely.

By RAE Decision 443/2019 (OGG B’ 2945/16.07.2019), the RAE Decision 822/2018 on the tender for the CNG Virtual Pipeline Service was amended.

By RAE Decision 442/2019 (OGG Β’ 2972/19.07.2019), the maximum price per kWh for the CNG service for the year 2018 was determined.

By RAE Decision 1427/2020 (OGG Β’ 4920/09.11.2020), the maximum price as of 01.11.2020 per kWh for the Compressed Natural Gas Virtual Pipeline service was determined in accordance with the decision of RAE 643/2018.

By RAE Decision 633/2021 (OGG B’ 4271/16.09.2021), the RAE Decision 643/2018 on the framework for the development of Remote Distribution Networks using Compressed/Liquefied Natural Gas was amended.

By RAEWW Decision E-128A/2023 (OGG B’ 7018/13.12.2023), the terms and criteria of the tender for the LNG Virtual Pipeline Services were approved.

By RAEWW Decision E-128B/2023 (OGG Β’ 7100/18.12.2023), the maximum price per kWh for the Liquified Natural Gas Virtual Pipeline service was approved.

By RAEWW Decision E-129/2024 (OGG B’ Β’4265/19.07.2024), the framework for supplying Remote Distribution Networks by ODYFA Network User using Liquefied Natural Gas, was established.

Development Program 2024 – 2028

Approval of the Development Plan (OGG B’ 6152/7.11.2024) of Enaon EDA’s Distribution Networks for the period 2024 – 2028.

Development Program 2025 – 2029

Approval of the Development Plan (OGG B’ 2042/28.4.2025) of Enaon EDA’s Distribution Networks for the period 2025 – 2029.

Typical Consumption Curves

The methodology for determining the typical consumption characteristics and creating typical consumption curves for non-hourly metered end customers, pursuant to Article 21 of the Natural Gas Distribution Networks Management Code, was approved by RAE Decision 125/2018, which was amended by RAE Decision 750/2020 (Government Gazette B’ 2045/30.05.2020)

Standard Connection Contract

By Government Gazette B’ 1788/11.05.2020 the Standard Contract for Connection to the Distribution Network was issued.

C. OTHER LEGISLATION

Security of Supply

Under Regulation (EU) 2017/1938 concerning measures to safeguard the security of gas supply and repealing Regulation (EU) No 994/2010 and in the context of the provisions of Law 4001/2011, RAEWW establishes an Emergency Plan and a Preventive Action Plan to guarantee, continued supply to protected customers (as defined in OGG B’ 1684 /24.6.2014).

The updated Emergency Plan came into force with OGG B’201/19.01.2023 integrating the provisions of the Preventive Action Plan (OGG B’5534/26.10.2022).

Subsequently, the National Emergency Plan was further revised by OGG B’6453/13.11.2023 while the Preventive Action Plan was correspondingly updated by OGGΒ’6440/10.11.2023.

Energy Efficiency

Pursuant to the provisions of Directive 2018/2002/EU of the European Parliament and of the Council on energy efficiency as incorporated by Law 4843/2021 (A’ 193) and the National Climate Law 4936/2022 (A’ 105), the Regulation on the Operation of the Energy Efficiency Obligation Regime for the period 2021-2030 (OGG B’2898/2022), was amended, according to which the Distribution Network Operators are obliged to implement specific energy saving actions in end-use.

Reduction of Methane Emissions in the Energy Sector

Regulation (EU) 2024/1787 on the reduction of methane emissions from the energy sector introduces new EU rules on the monitoring, reporting and verification of methane emissions, as well as a transparency mechanism on methane emission intensity. The regulation imposes an immediate ban on venting and flaring practices (with certain exceptions) as well as related requirements on the detection and repair of leaks.