The decision, issued by the Ministry of Finance under reference A.1201/2025, replaces a regime dating back to 2016 and represents a comprehensive overhaul of how such exemptions are granted and monitored. The reform places particular emphasis on tighter supervision, clearer rules and the systematic use of digital controls.
The importance of the new framework is expected to be felt most strongly by Greece’s large, energy-intensive industrial producers. Companies such as Metlen, whose aluminium production at Aluminium of Greece depends almost entirely on electrolysis, as well as major metal processing groups like ElvalHalcor, rely heavily on electricity as a core production input. For these businesses, exemption from electricity excise duty is not simply a fiscal incentive but a key determinant of overall energy costs and international competitiveness.
A comparison between the old and the new regimes highlights a significant shift in policy approach over the past decade. When the previous framework was introduced in 2016, it reflected a different energy and fiscal landscape. At the time, the exemption was conceived primarily as a support mechanism for domestic industrial production, aimed at easing energy costs and helping preserve Greece’s manufacturing base. While the earlier system did include provisions for inspections and technical documentation, its application was relatively flexible, with less standardised procedures and a lighter administrative burden for companies.
By contrast, the new framework, which will be fully applied in 2026, is far more detailed and prescriptive. It clearly defines the purpose and scope of the exemption, the responsibilities of public authorities, the obligations of beneficiary companies and electricity suppliers, and the procedures for inspections and controls. In effect, the Greek state is turning what was once a relatively straightforward tax relief into a closely monitored administrative process, integrated into digital registries and structured information flows linking companies, customs authorities and energy providers.
The updated rules also reflect changes in how industrial electricity is produced and consumed. Over the past decade, self-generation and self-consumption have become far more common, driven by investments in photovoltaic systems, backup power plants and hybrid energy solutions. The new decision explicitly recognises cases where companies generate electricity exclusively for their own use without injecting power into the public grid, and it sets out clear procedures for exempting this consumption from excise duty. This provides greater tax clarity for companies that have invested in energy autonomy.
One of the most notable features of the new regime is the effort to strengthen legal certainty. A central registry of excise duty exemption beneficiaries is established, with each industrial installation registered separately and assigned a unique identification number. This marks a clear departure from the more fragmented monitoring of the past and is expected to reduce disputes with customs authorities, while giving companies greater predictability in their tax treatment.
The framework also introduces a formal and clearly defined appeals process. Companies that disagree with a decision by the competent authorities, whether over the rejection of an application or the percentage of electricity consumption deemed eligible for exemption, are now granted a specific time window to submit a documented objection and request a review. This provision enhances transparency and procedural safeguards compared with the previous system, where reconsideration often depended on the discretion and practices of individual offices.
At the same time, the new rules increase the compliance burden on businesses. Companies are still required to provide a financial guarantee equal to 5 per cent of the applicable excise duty, but the decision clarifies that this guarantee covers the full range of tax liabilities and must be adjusted annually. For large industrial consumers, this represents a meaningful commitment of liquidity. Responsibility is also more clearly placed on companies themselves, which must keep the authorities informed of any changes that could affect their exemption status, with the risk of back-tax assessments if they fail to do so.
The decision also provides for a transitional adjustment period for electricity suppliers and grid operators. A three-month deadline, running until March, has been set for suppliers and distributors to update their billing systems and documentation so that electricity consumption eligible for excise duty exemption is clearly distinguished from non-exempt consumption on customer invoices.
