Climate Law (Law 4936/2022)
I. Climate Law
Climate change is now one of the most important pillars of environmental policy and sustainable development at both the European and international levels. Through the European Climate Law (2021), the European Union has established the framework for achieving climate neutrality by 2050, while also setting binding targets for the substantial reduction of greenhouse gas emissions over the coming decades.
In Greece, the National Climate Law (Law 4936/2022) constitutes the main institutional framework for the country’s transition to a more sustainable and low-emission development model. The Law introduces measures and obligations aimed at the gradual reduction of the environmental footprint of activities in both the public and private sectors, while also enhancing transparency and the monitoring of greenhouse gas emissions.
More specifically, the Law establishes requirements regarding the recording, monitoring, verification, and disclosure of emissions data, applicable to:
- businesses (Article 20),
- installations subject to environmental permitting (Article 19),
- as well as First-Level Local Government Organizations / Municipalities (Article 16).
The verification of the relevant reports and inventories is carried out by accredited verification bodies, in accordance with the requirements of Regulation (EU) No 600/2012 and the applicable accreditation framework for the National Climate Law, with a relevant reference in the scope of accreditation of their certificates for Articles 20, 19, and 16 of the National Climate Law.
II. Article 20 - ORGANIZATIONS
By 31 October each year, companies subject to Article 20 of the National Climate Law are required to submit a verified Carbon Footprint Report for the preceding calendar year through the electronic platform of the Natural Environment and Climate Change Agency (O.FY.PE.K.A.): https://climaregistry.necca.gov.gr.
Obligated companies:
- Listed public limited companies
- Credit institutions
- Insurance companies
- Investment firms
- Fixed and mobile telecommunications companies
- Water supply and sewerage companies
- Courier companies
- Electricity and natural gas supply companies
- Retail chains employing more than 500 employees
- Logistics service providers
- Urban public transport service companies
*Small and very small enterprises are exempted.
Emissions Calculation
Emissions are calculated in accordance with:
- the “2006 IPCC Guidelines for National Greenhouse Gas Inventories”, or
- ISO 14064-1:2018 (Categories 1 and 2), or
- the GHG Protocol of the World Resources Institute.
The reports include:
- Direct greenhouse gas emissions
- Indirect emissions from energy consumption
For the conversion of final energy consumption into equivalent carbon dioxide (CO₂) emissions, the emission factors included in the most recent national emissions inventory are used, as published annually by the Ministry of Environment and Energy.
III. Article 19 – Facilities Subject to Environmental Permitting
Category A facilities and activities, as defined in Article 1 of Law 4014/2011 and not falling under the European Union Emissions Trading System (EU ETS), are required to proceed with a gradual reduction of greenhouse gas emissions, aiming to achieve a 30% reduction by 2030 compared to the 2019 baseline emission levels.
Scope of Application
Article 19 applies to the following groups of activities:
- Environmental infrastructure systems (Group 4)
- Tourism facilities and urban redevelopment projects, including buildings, sports, and recreational facilities (Group 6)
- Livestock and poultry farming installations (Group 7)
- Aquaculture facilities (Group 8)
- Industrial and related installations (Group 9)
Obligations of Operators
Operators of the above activities were required to submit a Compliance Report to the competent environmental authority by 1 January 2026, describing the manner in which the emission reduction target will be achieved. The report serves as an amendment dossier for the Environmental Terms Approval Decision (AEPO).
From 2026 onwards, obligated operators shall submit annual verified emissions reports through the O.FY.PE.K.A. platform: https://climaregistry.necca.gov.gr. For the 2025 reporting year, the first submission must be completed by 31 October 2026.
IV. Article 16 – First-Level Local Government Organizations (Municipalities)
According to Article 16 of the National Climate Law (Law No. 4936/2022), first-level local government bodies are required to develop Municipal Emissions Reduction Plans (DHSME) with the aim of systematically recording, monitoring, and reducing their carbon footprint.
The Municipal Emissions Reduction Plan is consistent with the National Energy and Climate Plan and is revised at least every five years. It is based on a detailed inventory of energy consumption and greenhouse gas emissions, with 2019 as the baseline year, and covers municipal infrastructure and activities such as:
- municipal buildings and public facilities,
- sports and cultural infrastructure,
- street lighting and lighting of public spaces,
- water supply, sewerage, and irrigation systems,
- as well as the municipal vehicle fleet.
Under the Law, municipalities are required to achieve specific greenhouse gas emission reduction targets: 10% by 2025 and 30% by 2030, compared to the 2019 baseline year.
To prepare the Municipal Emissions Reduction Plan, a Carbon Footprint Emissions Report must be drafted for Scope 1 and 2 emissions, in accordance with internationally recognized methodologies, such as the IPCC Guidelines and the ISO 14064-1:2018 standard.
The Emissions Report is submitted for verification by an accredited body, in accordance with the applicable regulatory framework of the National Climate Law. The process includes both the initial verification of the emissions inventory for the 2019 reporting year and the annual recurring verifications required to monitor the implementation and progress of the plan.
The submission of the Municipal Emissions Reduction Plans and related reports is carried out via the OFYPEKA electronic platform: https://climaregistry.necca.gov.gr , while their preparation and updating is a basic prerequisite for the participation of local authorities in funding programs related to energy efficiency, sustainable development, and climate adaptation.
V. EMICERT SERVICES
EMICERT provides comprehensive verification and technical support services to ensure compliance with the requirements of the National Climate Law (Law 4936/2022) regarding Articles 16, 19, and 20.
As an accredited verification body, EMICERT has many years of experience in verifying greenhouse gas emissions within the framework of:
- EU ETS 1 & EU ETS 2
- CBAM
- ISO 14064-1
- ISO 14064-2
- ISO 14067
- Νationaland European climate change compliance schemes
At the same time, EMICERT supports its clients throughout the reporting process on the OFYPEKA electronic platform, ensuring proper and timely compliance with regulatory requirements.
