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Last updated: October 2026

Summary

What is the status of the transposition of Article 25(6) (EDD) and its implementation?  

According to the latest stakeholder update, Greece has not yet adopted the legislation needed to establish local heating and cooling plans in line with Article 25(6) of the recast Energy Efficiency Directive.

All municipalities are required to prepare Municipal Emission Reduction Plans under Article 16 of the National Climate Law (4936/2022). These focus on emissions from municipal buildings, equipment, infrastructure and activities. They can contribute to heating and cooling decarbonisation within municipal assets, but do not replace comprehensive heating and cooling planning across the municipal territory. Further regulatory changes and dedicated support remain necessary.

Detailed assessment

The legal framework and the obligations

The new requirement for municipal emissions reduction plans is insufficient to cover the provisions of the EED article 25.6.

Overview of the legal frameworks per governance level in Greece

National Greece’s main energy and climate objectives are enshrined in its National Climate Law adopted in 2022, and in its National Energy and Climate Plan, published in 2019. Greece has set a a target of 43% in 2030 for the share of renewable energy in the heating and cooling consumption, but without clear energy efficiency targets.
Local Article 16 of the National Climate Law (4936/2022) requires every municipality to prepare a Municipal Emission Reduction Plan. These plans inventory energy consumption and greenhouse gas emissions from municipal buildings, equipment, infrastructure and activities, and identify measures to reduce them.
Plans must be reviewed at least every five years, with annual progress reporting. Their focus on municipal operations does not provide comprehensive heating and cooling planning for residential, commercial and other buildings across the municipality.

The support framework

The financial, technical, and skills support available to local authorities is very limited.

There is no support framework in place to support the development of local heating and cooling plans in Greece, or for other energy-related planning documents drafted at the local level. Greek municipalities lack access to technical guidance and dedicated streams of funding for drafting such plans. Greek local authorities are today highly restricted in their capacity to carry out energy and climate related tasks due to substantial staff and skills shortages in their administrations, which today are almost exclusively outsourced to external contractors. Greek municipalities are also restricted by limited access to readily available and sufficiently detailed energy-related geodata. Substantial efforts will therefore be needed to provide Greek local administrations with technical and financial support mechanisms to develop local heating and cooling plans, to improve access to energy-related geodata, and to build staffing capacities.

Provided Support

Technical and organisational 1/5 There is no technical support regarding heating and cooling plans. Guidance and emission calculation tools are available for Municipal Emission Reduction plans. These can support measures concerning municipal buildings, but do not provide a comprehensive methodology for heating and cooling planning across the municipal territory.
Financial 1/5 There is no dedicated fund regarding heating and cooling projects or planning. More broadly, cities can access a new national program that supports climate and energy projects but does not provide any specific support for heating and cooling planning.
Staff & skills 1/5 There is a substantial lack of expertise and staff in Greek municipalities on climate and energy-related issues. Almost all municipal plans (SECAPs or municipal emissions reduction plans) are assigned to external consultants.
The recent National Climate Law makes it mandatory to have at least one energy officer in each Greek municipality. However, no additional budget is foreseen for the municipalities to develop a skills or staff strategy.
Access to data 1/5 Greek Municipalities lack access to energy-related geodata. Utilities are not obliged to cooperate with municipalities and the building information and RES potential data are not available. The municipal emissions’ reduction plan will mainly concern the collection and analysis of data on the energy consumption of publicly owned assets and buildings. This could work as an initial steppingstone for developing heating and cooling assessments but will be insufficient for the purpose of heating and cooling planning.