Finally, following a series of public consultations by RAE and years of work on the necessary amendments to Articles 39 and 42 of the Supply Code, both by the market and by the Ministry of Environment and Energy, we are now one step away from completing a critical institutional intervention to resolve the issue of overdue debts.
ESPEN has already submitted a specific proposal to amend Articles 39 and 42 of the Procurement Code, with the aim of addressing the issue in a balanced and functional manner. The proposal has been thoroughly reviewed by both the Secretary General and the Deputy Minister and has been forwarded in its final form to the Minister of Environment and Energy, with the only remaining step being his signature for the issuance of the relevant Decision and its entry into force.
The proposal provides for a mechanism allowing a request to be submitted to the previous supplier to disconnect the service, based on the principle of proportionality. This provision is not proposed indiscriminately. On the contrary, it is accompanied by clear safeguards: it applies only in cases of substantial debts, requires that all settlement options have been exhausted beforehand, and includes provisions ensuring that the consumer is not suddenly confronted with old outstanding debts.
In other words, this is an approach that seeks to strike a balance between consumer protection and the need to ensure that consistent payers are not systematically burdened by the costs arising from the market’s imperfect regulation.
The issue of energy costs
Electricity prices remain firmly at the center of public debate. This makes sense. Electricity is not just another commodity on the market. It is a basic necessity, absolutely essential for the daily lives of households, for the operation of businesses, and, ultimately, for the overall resilience of the economy. So when energy costs rise or remain high, the pressure is not abstract. It is immediate, tangible, and socially visible.
That is why access to affordable electricity is not merely a technical or commercial issue. It is a deeply political and social issue. And precisely for this reason, the discussion about why our country has this price level, what exactly influences it, and how the cost to the end consumer can be substantially reduced must take place in clear terms and without facile simplifications.
The Hellenic Association of Energy Suppliers (ESPEN), which represents the leading independent energy suppliers in the Greek market and participates institutionally in the dialogue with the government and regulatory authorities, consistently highlights a critical aspect of the discussion: the electricity supply market in Greece is a highly competitive market, offering consumers a wide range of choices and products.
This means that the problem does not lie where it is often sought. A significant portion of the costs ultimately incorporated into supply charges is not linked to a lack of competition. It is linked to structural weaknesses and unresolved issues in the institutional framework governing the market’s operation.
The Electricity Supply Code
A prime example is the Electricity Supply Code. Although it was adopted in 2013, it has not been substantially updated since then, despite the major changes that have taken place in the energy market in the meantime. The result is that critical aspects of the market remain inadequately regulated, with a prime example being the framework for switching suppliers and the management of related overdue debts.
This issue is neither minor nor technical; it has a direct economic impact. It imposes additional costs of hundreds of millions of euros on energy suppliers every year, reduces the scope for even more competitive prices, and ultimately shifts the burden onto compliant consumers. That is, precisely those who meet their obligations on time.
This is the point that is often lost in public debate: when the market operates with unresolved regulatory issues, the cost does not disappear. It is shifted somewhere else. And it is usually shifted to where it is easiest to absorb—into the total cost ultimately paid by the consumer.
Addressing distortions and on-bill financing
The need to address these distortions is becoming even more critical today, as the market is gradually transitioning into a new era of energy services. A prime example is on-bill financing, a new tool that can more directly link energy upgrades to cost savings for the consumer.
On-bill financing allows for the financing of energy upgrades at the consumer’s premises, along with the supply of appropriate equipment, with repayment made gradually through electricity bills. This tool is expected to serve as a key channel for utilizing €2.5 billion in funds from the Social Climate Fund’s new“Exoikonomo”program.
Its significance is not limited to financing. Suppliers are called upon to take on a much more complex role: not only to support energy upgrades, but also to provide consumption management and optimization services through the relevant equipment.
We are talking about technologies such as behind-the-meter batteries, heat pumps, price-responsive electrical appliances, and electric vehicle chargers. These are tools that can be leveraged to reduce supply costs for the consumer while simultaneously lowering the system’s overall operating costs, providing valuable flexibility services.
This is precisely the essence of the future: energy savings will not result solely from passive measures, but also from smarter, more active, and more technologically supported consumer participation in the market. However, this transition cannot take place amid institutional uncertainty.
This new model entails significant additional credit risk for suppliers. And this risk cannot be effectively addressed as long as the issue of overdue debts remains unresolved.
The need for rules that work
Updating the Procurement Code, as well as addressing other known distortions in the framework, can no longer be treated as just another administrative or regulatory pending issue. It is a necessary prerequisite for limiting structural surcharges currently embedded in supply charges, for developing new energy-saving and management tools, and, ultimately, for the electricity market to operate in a more efficient, sustainable, and affordable manner.
This is precisely why the discussion on reducing energy costs needs to be grounded in the right principles. Not through interventions in pricing or the commercial policies of a highly competitive market, such as the electricity supply market. Such approaches may sound simple or appealing at first glance, but they do not address the root of the problem.
A substantial reduction in costs requires something far more demanding but also far more effective: addressing those structural elements of energy and supply costs that currently remain essentially hidden within the“competitive component”of bills, without being under the control of suppliers and without constituting a real arena for competition.
If the goal is truly to see lower energy costs for households and businesses, then the answer does not lie in easy announcements. It lies in a more modern, more functional, and fairer institutional framework. Because at the end of the day, expensive electricity isn’t just a market issue. It’s also a matter of rules.
PRESENTATION