Our Energy Law Briefing Special Edition provides an overview of the Special BESS Grid Connection Scheme:
A. Introduction
B. Project Grouping
C. Eligibility Requirements
D. Anti-Concentration Rules
E. Development and Operational Requirements
F. Penalties
G. Application Process
H. Financial Robustness
A. Introduction
1. Earlier this month, following a delay of more than one year, a
critical development for the Greek energy market took place. The
Ministry of Environment and Energy introduced a special grid
connection priority framework for merchant storage projects, which
had initially been anticipated by Law 5151/20241.
2. Based on a new Ministerial Decision2, standalone
Battery Energy Storage Systems (BESS) projects
that have not been awarded investment aid or operating support
through the tender procedures of the Regulatory Authority for
Energy, Waste and Water (RAEWW) will enjoy special
benefits in the race for Final Grid Connection Offers
(FGCOs) (the Special BESS Grid Connection
Scheme).
3. The Special BESS Grid Connection Scheme applies to BESS projects
set to be connected both to the Transmission System operated by
IPTO and to the Distribution Network operated by HEDNO.
4. The Special BESS Grid Connection Scheme did not directly amend
the Grid Connection Priority Framework and the Industrial and
Agricultural PPA Grid Connection Priority Framework introduced in
2022 and 2024 respectively. However it does affect the existing
order of priority by effectively granting merchant BESS projects a
significant head-start compared to other categories.
5. Applications for eligible projects will be evaluated by the Grid
Operator (IPTO or HEDNO) in parallel with:
a. projects falling under the Industrial and Agricultural PPA Grid
Connection Priority Framework;
b. hybrid projects located in non-interconnected islands and Crete;
and
c. storage projects that have already secured operating support
through the RAEWW tender processes.
6. This new Ministerial Decision defines project groups, capacity
limits, eligibility criteria, anti-concentration and prioritization
rules, regulates the application process and technical
requirements, and sets penalties imposed for non-compliance.
7. After the evaluation of applications based on the set criteria
and process, a Ministerial Decision is expected to establish the
selection order of eligible merchant BESS projects favored by the
fast-track scheme.
B. Project Grouping
1. Eligible BESS projects fall into two main categories of ESMIE
and EDDIE Project Groups.
2. ESMIE Project Groups include eligible projects with a capacity
of >10MW connected to the Transmission System:
3. EDDIE Project Groups: Eligible projects with capacity ≤10MW connected to the Distribution Network:
C. Eligibility Requirements
1. To qualify for the Special BESS Grid Connection Scheme, merchant
BESS projects must meet specific criteria, including:
a. a complete application for an FGCO must have been submitted
after 4 July 2022;
b. the project owner must have secured external financing (or at
least pre-approval) or demonstrate sufficient equity to fully fund
the development of the BESS project at the time of submission of
the application; the reference amount of the construction cost is
€200/kWh;
c. the BESS project has a maximum injection capacity of at least
0.5 MW and a usable storage duration of at least two hours;
d. an FGCO has been issued for the BESS project, whether as a
standalone system, an addition to an RES project sharing a common
connection point, or through the conversion of conventional power
plants or fossil fuel generation licenses into storage
projects;
e. the investor must demonstrate that they have robust land rights
over the project site; and
f. the BESS project must meet several technical and operational
requirements, while the investor must take out at least the minimum
insurance policies and ensure proper decommissioning and equipment
recycling.
D. Anti-Concentration Measures
1. The new Ministerial Decision limits the capacity per investor
that can benefit under the Special BESS Grid Connection Scheme to
discourage market concentration. Each project owner may directly or
indirectly hold standalone BESS projects to be connected to
the:
a. Transmission System with an aggregate capacity of < 250 MW;
and
b. Distribution Network with an aggregate capacity < 50
MW.
Additionally a cumulative market cap of 500 MW per project owner
applies to all BESS projects (standalone or
RES-combined6) until 2029.
2. In addition to the above general caps, for projects qualifying
under groups:
a. ESMIE Α1 and ESMIE Α3, a special limit of 100 MW of
BESS projects has been set; and
b. ESMIE Α2 and EDDIE D investors can directly or indirectly
connect up to 50 MW of BESS projects.
E. Financial Robustness
1. The application must be accompanied by a letter of guarantee
with a minimum validity of two years (the Application
Bond), calculated as follows:
2. Upon issuance of the FGCO, the Application Bond must be replaced with a letter of guarantee for the performance of the project of the same amounts (the Performance Bond). The Performance Bond is reduced to half of the initial amount after three years of operation and is returned to the interested party after 6 years.
F. Development and Operational
Requirements
1. BESS projects securing grid connection under the Special BESS
Grid Connection Scheme must submit a Declaration of Readiness
within 18 months of FGCO acceptance and will be subject to
curtailment measures.
G. Penalties
1. If a project fails to comply with the Special BESS Grid
Connection Scheme requirements, including timely electrification,
the Application Bond or the Performance Bond will be
forfeited.
2. The relevant Grid Operator will also suspend the project's
grid connection until full compliance is achieved.
H. Application Deadlines
1. To qualify under the Special BESS Grid Connection Scheme,
project owners must submit an application within the following
deadlines:
Footnotes
1 The special framework for the grid connection of merchant storage projects was established by virtue of Article 41 of Law 5151/2024, which amended Law 4685/2020 by adding new Article 11D.
2 ΥΠΕΝ/ΓΔΕ/28255/1143/2025, Government Gazette B' 1248/13.3.2025.
3 IPTO will evaluate the applications for each Project Group in the following order: a) ESMIE B, b) ESMIE C, c) ESMIE A1, d) ESMIE A2 and e) ESMIE A3.
4 Refers to Ultra-High Voltage Centers or Substations that are either currently operating, under construction, or those with a Grid Connection Agreement in place.
5 The project's maximum capacity must not exceed the business's peak annual consumption, as recorded in 2024 or the most recent full calendar year.
6 Excluding RES projects with integrated BESS that cannot absorb power from the grid.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
