Prosumers

• Law No. 5037/2023
• Law No. 3468/2006
• Ministerial Decision 15084/382

There is no specific description of prosumers. However, the term of autonomous producer or self-producer can be deployed. Despite the fact that autonomous producers concern all RES technologies, there is practically a regulatory framework only for PV autonomous producers.

Until recently, the tools available for this purpose were net metering and virtual net metering. However, under the recent regulatory changes, energy self-production—whether by individual households, businesses, local government entities, collectively through energy communities, or jointly (e.g., apartment buildings)—is now facilitated through net billing and virtual net billing. With Law 5106/2024 and Law 5151/2024, changes were introduced both in the categories of self-producers eligible to utilize energy net metering and virtual net metering, as well as in the capacity limits per substation for the installation of self-production projects.

This regulation excludes Renewable Energy Communities (REC) and Citizens' Energy Communities (CEC) from the self-producers eligible to apply virtual net metering, as previously provided under Article 64 of Law 5037/2023. Consequently, the only regulatory tool now available to energy communities for energy offsetting is virtual net billing.

For Virtual Net Billing, self-consumers may receive compensation for surplus energy, provided that this activity is not their primary commercial or professional operation. They can either participate directly in the electricity market or receive compensation based on operational support, depending on the technology of their generation unit. The compensation rate for surplus energy injected into the grid is determined by the wholesale market price during the injection period. For Non-Interconnected Islands, surplus energy is compensated based on the Special Market Price (SMP) for RES and CHP technologies, published by DAPEEP and settled by HEDNO.

Consumption installations for offsetting are not electrically connected to the internal electrical installation of the generation unit, even if located on the same or adjacent premises. Generation units may be installed in any region of the country, regardless of the location of the consumption installations, provided both are within the same electrical system, either the Interconnected System or the respective system for Non-Interconnected Islands.

The capacity of each generation unit (in kWp) may reach up to 100% of the agreed consumption capacity (in kVA). Different limits apply for each island complex in the case of Non-Interconnected Islands.

• There are limitations with regard to the maximum capacity of a PV plant belonging to an autonomous producer. For the interconnected system (interconnected islands):
  • Households up to 20 kW, or up to 50% of the agreed power consumption if the plant is above 20 kW;
  • Small commercial entities up to 100% of the agreed power consumption for PV plants below 1 MW.
• For the non-interconnected islands:
  •  Households up to 10 kW (20 kW for Crete), or up to 50% of the agreed power consumption below a specific threshold defined for each island;
  • Small commercial entities up to 100% of the agreed power consumption below a specific threshold defined for each island (for example 500kW for Crete and Rhodes)
    (Ministerial Decision 15084/382).

The application of virtual net metering is now limited to beneficiaries of the "Photovoltaics on Rooftops" program and farmers for installations up to 30 kWp. All other categories of self-producers will adopt (virtual) net billing.

As of November 1, 2023, new applications for self-consumption stations using virtual net metering from Energy Communities under Law 4513/2018 are no longer accepted by the relevant Operator.

For the connection of RES projects owned by Energy Communities to the grid, the appropriate licensing is required from the Distribution Network Operator (HEDNO) or the System Operator (ADMIE), depending on the project's category. This licensing follows a priority system for issuing Final Connection Offers for RES and storage stations, managed by the respective Operator. The priority system is defined by a Ministerial Decision from the Minister of Environment and Energy. The current decision is Ministerial Decision ΥΠΕΝ/ΓΔΕ/84014/7123 (Government Gazette 4333/Β/12.08.2022).

For the sale of energy, the self-producer, as the owner of the RES or CHP stations operating in the Interconnected Network, participates directly in the electricity market.

The Operators to which the self-consumer’s supply points and RES or CHP station are connected provide the certified metering data to the supplier, the self-producer, and the Aggregator representing the RES or CHP station under the Signed Concurrent Netting Agreement as follows:

1. The absorbed energy from the consumption supply point for each Imbalance Settlement Period, adjusted to the System/Network boundaries, and
2. The injected and produced energy from the RES or CHP station for each Imbalance Settlement Period.

Based on the metering data received from the Operator, the Aggregator calculates the financial value of the surplus energy from the station for each Imbalance Settlement Period, using the revenue from market participation. Final settlement is conducted on a monthly basis.

In general, there are no limitations. However, regions with limited grid capacity may not connect autonomous producers. For non-interconnected islands, the maximum deployment limits are defined in Ministerial Decision 15084/382.

Virtual Net Billing

• Prosumers