Partner Athens
"These targets also favour the maintenance of subsidies and incentives for EVs and the balanced development of an adequate network of publicly accessible charging points."
In Greece, e-mobility is governed by Law 4710/2020 “On the promotion of e-mobility” (the “EV Law”), which introduced a unified and thorough regulatory framework for the market that had previously been regulated in a partial and fragmented way. Provisions setting particular e-mobility targets were also included in the National Climate Law 4936/2022 (the “National Climate Law”). In addition, two Ministerial Decisions provide for the general “E-moving”¹ initiative: (a) Ministerial Decision No. ΥΠΕΝ/ΕΣΠΑΕΝ/77472/520/2020 on the “E-moving” (the “MD 2020”) and (b) Ministerial Decision No. ΥΠΕΝ/ΑΤΗ/70517/238/2022 on the “E-moving – Round B”² (the “MD 2022”), whereas further subsidy schemes are implemented to specific cases.
This legislative framework is intended to allow Greece to reach the targets of the National Plan for Energy and Climate (the “NECP”),³ which sets an ultimate target that EVs should represent at least 30% of all newly registered vehicles by 2030. The updated NECP draft, which was uploaded on the European Commission’s website on 6 November 2023,⁴ includes an EV penetration target down to 30% (baseline scenario), which can be extended to 50% (optimistic scenario) of the country’s fleet for 2030. These targets also favour the maintenance of subsidies and incentives for EVs and the balanced development of an adequate network of publicly accessible charging points.⁵
The National Climate Law
The National Climate Law includes the following measures for the promotion of Zero-Emission Vehicles (“ZEVs”) and Zero- and Low-Emission Vehicles (“ZLEVs”):
- as of 1 January 2030 (unless otherwise stipulated by EU legislation), registrations for ICE passenger and LCV cars shall be allowed only for ZEVs;
- as of 1 January 2026, new taxis in Athens and Thessaloniki Prefectures must be ZEVs;
- as of 1 January 2026, at least a third of the new vehicles registered for leasing purposes in Athens and Thessaloniki Prefectures must be ZEVs; and
- as of 1 January 2024, at least a quarter of new company cars (purchased or leased) must be ZLEVs (0-50grCO2/km). The total number shall be calculated cumulatively on an annual basis.
The EV Law
The EV Law, as amended, aims to increase the use of ZLEVs, to develop Greece’s charging infrastructure and to formulate the regulatory framework of the e-mobility market by introducing financial and tax incentives. It also includes provisions on the organisation and operation of the market, the relations between market players and their obligations, spatial and urban planning for the development of charging infrastructure and other technical issues.
Tax incentives for the acquisition and use of e-vehicles and the development of charging points
The EV Law includes a range of tax benefits for the acquisition or leasing of electric vehicles or plug-in hybrid vehicles, further increased for islands. Tax benefits include higher tax deductions for vehicles used for business or provided to employees, increased depreciation rates and tax allowances for the installation of public or employee-only charging points. Among others, it provides for the following:
"Since 2020, secondary legislation consisting in MD 2020 and MD 2022 has established and regulated the general 'E-moving' initiative."
- incentives for e-mobility product manufacturing – the Law includes incentives for the installation and operation of investments for the manufacture of products related to the e-mobility market. Firstly, it accelerates the procedure for the installation and operation of such units by granting absolute priority in the licensing procedure before public authorities. Further, units located in the West Macedonia and Arcadia regions, where lignite facilities are currently concentrated, enjoy additional incentives. The income tax rate applicable to such units is reduced by five percentage points for the first five profitable years and the depreciation rate of fixed assets is increased.
- build-out of charging infrastructure – the EV Law includes provisions to promote the rapid development of a charging network across Greece. In particular, all municipal authorities must produce EV charging plans providing for sufficient charging points in publicly accessible areas; these may be implemented through open tenders. Further, special ranks and charging points must be created for exclusive use by taxi drivers driving purely electric or hybrid electric vehicles. All new or renovated buildings should install suitable cabling to allow for the creation of charging points, and in purely commercial buildings there must be at least one charging point per 20 parking spaces. Provisions simplifying the procedure for the installation of domestic chargers are introduced and obligations to create a minimum number of charging points are imposed for state-owned and governmental buildings.
- organisation and operation of the market – the EV Law aims to promote a contemporary, complete and transparent market model for the development of the market to assist Greece in meeting its goals for rapid growth of clean transportation and decarbonisation of the energy mix. In brief:
• the basic terms of operation and the roles are determined for electric vehicle charging infrastructure providers (“EVCIPs” and in Greek “ΦΕΥΦΗΟ”), e-mobility services providers (“ESPs” and in Greek “ΠΥΗ”), processor of e-mobility transactions (“PEMTs” and in Greek “ΦΔΣ”) and aggregators of electricity for electric vehicles (“Aggregators” and in Greek “ΦΟΣΕΦΗΟ”);
• HEDNO (the electricity distribution network operator) must enable the connection of charging points in the distribution network without discrimination amongst the businesses that develop and operate charging points;
• the Registry of E-Mobility Infrastructure and Market Participants is created, containing information on market participants and publicly accessible charging points.⁶ The Registry is intended to ensure market transparency and online access to real-time information in respect of charging networks, costs, navigation and booking of charging points; and
• charging prices are unregulated but should be determined on a transparent basis.
As of 27 June 2023, the supervision of the organisation and operation of the e-mobility market – initially assigned to the Ministry of Environment and Energy in cooperation with the Regulatory Authority for Energy – has been assigned to the Ministry of Infrastructure and Transport, in cooperation with the renamed Regulatory Authority for Waste, Energy and Water.⁷
The “E-moving” initiative
Since 2020, secondary legislation consisting in MD 2020 and MD 2022 has established and regulated the general “E-moving” initiative, which has provided significant incentives to consumers and professionals for the acquisition of EVs or plug-in hybrid vehicles, as well as for the purchase and installation of EV charging infrastructure. The purpose of E-moving is to promote e-mobility and facilitate the penetration of EVs in the Greek market in order to reduce gas emissions and fulfil the targets of the NECP. Round A was introduced by MD 2020⁸ and ended on 31 December 2021 (payments to be completed by 30 November 2023), while Round B was introduced by MD 2022 and started on 28 July 2022.
E-moving – Round B initiative provides subsidies of a total public expenditure of €50m in the form of an environmental bonus for the purchase or lease of EVs, subsidy for the purchase of a “smart” EV chargers and subsidy through old vehicle replacement.
"There are also additional environmental bonuses for disabled individuals, families with at least three dependent children, and young people under 29 years of age."
| Subsidy category | Individuals (not for business purposes) | Businesses |
|---|---|---|
| Purchase or lease of EV vehicle | 30% of RPBT,⁹ with a maximum of €8,000 | 30% of RPBT, with a maximum of €8,000 per EV for up to 20 vehicles |
| 20% of RPBT, with a maximum of €6,000 per EV for more than 20 vehicles | ||
| In each case, if the legal entity has business activity on an island, there is an extra bonus of €4,000 per EV | ||
| Purchase of two or three-wheeled vehicles categories L1e – L4e | 30% of the purchase price before VAT, with a maximum of €1,300 | 30% of the purchase price before VAT, with a maximum of €1,300 per vehicle, up to 10 vehicles |
| Purchase of two or three-wheeled vehicles categories L5 – L7 (microcars) | 40% of the purchase price before VAT, with a maximum of €3,000 | 40% of the purchase price before VAT, with a maximum of €3,000 per vehicle, up to 10 vehicles |
| Electric bicycle | 40% of the purchase price before VAT, with a maximum of €800 | 40% of the purchase price before VAT, with a maximum of €800 per electric bicycle, up to 10 electric bicycles |
| Incentives for replacing existing vehicles | €1,000 for cars and €400 for two-wheel/three-wheel vehicles (excluding bikes) of categories L1e – L7e | |
| Purchase of smart domestic EV charger | subsidy of up to €500 | subsidy of up to €400 |
There are also additional environmental bonuses for disabled individuals, families with at least three dependent children, and young people under 29 years of age.
Applications to participate in the initiative are submitted to the e-platform kinoumeilektrika2.ypen.gr. Each application should be accompanied by the required documentation, as indicated in the relevant Annexes of the MD 2022.
Applicants must include a formal offer from the vendor of the specific vehicle they wish to purchase in their applications. Except for legal entities, each applicant may apply only for one vehicle.
The MD 2022 provides an explicit description of the application process, of the objection process if an application is rejected, of the payment process and the obligations of the participants.
The initiative ran until 31 December 2023.
Further subsidy schemes
In addition to the “E-moving” initiative, the following subsidy schemes have been implemented:
"Whilst there is an upwards trend in EV registrations, they still only represent a very small percentage of the vehicle market."
- “Antonis Tritsis”: a Special Development Programme for Municipalities, which, among others, includes 100% funding for the purchase of up to 10 municipal fleet EVs (passenger, vans, small trucks, buses, two-wheelers etc.);¹⁰
- “e-Astypalea”: this scheme provides for the subsidisation of the purchase or lease of EVs by the residents and businesses of Astypalea with the simultaneous replacement of old vehicles, which is optional (except for taxis, for which it is mandatory).¹¹ The total budget of the scheme amounts to €9m and it is implemented in the framework of the “Smart and Sustainable Island” project;
- “Green Taxis”: an RRF funded €39.94m subsidy scheme involving the replacement of approximately 2000 old taxis (Euro 5 and older) with EVs, mandatory replacement and scrappage.¹²;
- “Charge Everywhere”: an RRF funded €79.79m subsidy scheme involving the procurement and installation of public charging points in municipalities and at important points of interest (motorways, ports, airports etc.).¹³;
- “Produc-e Green”: an RRF funded €199.7m subsidy scheme involving the manufacturing of units with R&D departments for innovative products/services in area of sustainable mobility, such as recycling EV batteries with reuse of raw materials (lithium, cobalt), EV manufacturing/assembling, chargers etc;¹⁴ and
- “Procurement of 220 Electric Buses – Green Public Transport”: an RRF funded €136.04m programme involving the replacement of 220 old buses with electric ones in Athens and Thessaloniki.¹⁵
Market data
Based on the European Automobile Manufacturers’ Association press release of 1 February 2023, the Greek market saw a 30% increase in Battery Electric Vehicle (“BEV”) unit registrations and a 15% increase in Plug-in Hybrid Electric Vehicle (“PHEV”) unit registrations in 2022. Whilst there is an upwards trend in EV registrations, they still only represent a very small percentage of the vehicle market. In particular, the market share of BEVs and PHEVs represented only 2.7% and 5.2% of total new vehicle registrations in 2022, respectively.¹⁶
As stated in the proposal for the revised NECP, the country’s fleet of EVs is approximately 25,000 at present and is expected to increase to 85,000 in 2025 and over 750,000 by 2030.¹⁷ According to the press, there has also been a significant increase in the number of charging points around the country in the last years, from 58 in 2019 to approximately 3,600 in 2023.¹⁸
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footnotes
[1] Government Gazette B 3323/07.08.2020.
[2] Government Gazette B 3981/27.07.2022.
[3] Government Gazette B 4893/31.12.2019.
[4] https://commission.europa.eu/publications/greece-draft-updated-necp-2021-2030_en
[5] https://energypress.gr/news/anatheorimeno-esek-aiolika-95-gw-fotoboltaika-134-gw-apothikeysi-53-gw-fysiko-aerio-77-gw-kai
[6] https://electrokinisi.yme.gov.gr (activated on 06.06.2022).
[7] Article 9 para. 1 of Presidential Decree 77/2023, Government Gazette A 130/27.06.2023.
[8] Please refer to WFW article dated 30 September 2020 entitled Recent developments in Greece’s e-mobility -market.
[9] Ministerial Decision No. 22766/2020, Government Gazette B 1386/14.04.2020, as amended.
[10] Ministerial Decision No. ΥΠΕΝ/ΑΤΗ/78654/257/2021, Government Gazette B 3961/30.08.2021; e-astypalea.gov.gr
[11] Ministerial Decision No. ΥΠΕΝ/ΑΤΗ/137582/646/2022, Government Gazette B 6789/28.12.2022; prasinataxi.gov.gr
[12] Ministerial Decision No. ΥΠΕΝ/ΑΤΗ/49144/468/2023, Government Gazette B 2966/05.05.2023; fortizopantou.gov.gr
[13] Ministerial Decision No. ΥΠΕΝ/ΥΔΕΝ/52385/774/2023, Government Gazette B 3156/12.05.2023; producegreen.gov.gr
[14] https://greece20.gov.gr/wp-content/uploads/2022/08/427.Promitheia-202-Ilektrika-Leoforeia_16924_5181142.pdf
[15] https://www.acea.auto/fuel-pc/fuel-types-of-new-cars-battery-electric-12-1-hybrid-22-6-and-petrol-36-4-market-share-full-year-2022/
[16] https://energypress.eu/electric-vehicle-penetration-lowered-in-revised-necp/
[17] https://energypress.gr/news/staikoyras-tha-synehistoyn-ta-kinitra-gia-tin-ilektrokinisi-19000-aitiseis-os-tora-ston-b
[18] https://energypress.gr/news/staikoyras-tha-synehistoyn-ta-kinitra-gia-tin-ilektrokinisi-19000-aitiseis-os-tora-ston-b
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