The Association of Small and Medium-sized Photovoltaic Producers of Greece, for installations up to 500 kW (SYFOEL) has taken formal action at European level, recently filing two official complaints with the European Commission concerning the operation of Greece’s electricity market and the country’s compliance with European Union law.
The complaints are accompanied by a detailed 45-page legal memorandum and, according to the association, highlight the impact of extensive generation curtailments affecting renewable energy sources (RES), zero and negative electricity prices, and gaps in essential energy infrastructure. SYFOEL argues that these conditions place particular pressure on small and medium-sized solar power producers, while it is also preparing collective legal action at national level to seek compensation.
Two complaints to the European Commission
SYFOEL said it had completed and filed two official complaints with the European Commission: one on behalf of the association and one on behalf of its members. According to the text of its announcement, the complaints bear reference number ID 94530. They ask the Commission to investigate whether Greece is complying with fundamental provisions of European Union law concerning the electricity market and the promotion of renewable energy sources.
The association is asking the Commission to examine actions and omissions by the Greek authorities, assess the market situation and, if it finds any infringements, initiate the procedures provided for.
Renewable generation curtailments in focus
A key issue raised in the complaints is the curtailment of electricity generation from renewable energy sources, which SYFOEL says is hitting small and medium-sized solar power producers hardest. The association argues that the frequency and scale of the curtailments cannot be seen simply as an unavoidable consequence of the energy transition, but links them to longstanding delays in developing the necessary infrastructure.
As the announcement points out, while the development of renewable energy sources was actively promoted and attracted significant private investment, energy storage infrastructure, electrification and other measures needed to integrate rising output smoothly did not advance at the required pace.
Zero and negative prices put producers under pressure
Another issue highlighted in the complaints is the emergence of zero and negative prices in the electricity market. According to SYFOEL, the combination of these prices and mandatory generation curtailments puts producers under significant financial pressure, affecting their revenues and the viability of their investments.
The association argues that curtailments, which under its interpretation of European law should be used only as a last resort and in exceptional circumstances, have become a recurring feature of the market. In its view, the cost of structural weaknesses in the system is being borne largely by producers.
European regulations and directives cited
In its 45-page legal memorandum, SYFOEL cites European legislation governing the operation of the electricity market. This includes:
Regulation (EU) 2019/943 on the internal market for electricity, Regulation (EU) 2018/1999 on the governance of the Energy Union, and the RED II Directive and RED III Directive on promoting the use of energy from renewable sources.
According to the association, these provisions are linked to the need for a predictable investment environment, transparent and non-discriminatory market access, the efficient operation of the system and limits on curtailments. The provisions form part of its legal argument, while the filing of the complaints does not in itself mean that the European Commission has found an infringement.
45-page legal memorandum seeks formal investigation
The complaints are accompanied by a detailed memorandum and supporting evidence documenting conditions in the Greek market. SYFOEL is asking the European Commission to assess the actions and omissions of the Greek authorities as a whole and initiate the procedures provided for. The aim is to restore the proper application of the law, strengthen legal certainty and ensure conditions for sustainable operation.
Collective compensation claims nearing final stages
SYFOEL also said that preparations for collective legal action at national level, aimed at seeking compensation, are at an advanced stage. It did not, however, provide a specific filing timetable, the amount being claimed or details of the eligibility criteria for taking part.
Giorgos Tsiantoulis: “We have fulfilled our commitment to SYFOEL members”
SYFOEL president Giorgos Tsiantoulis expressed his satisfaction, saying:
“We have fulfilled our commitment to SYFOEL members”.
He said that filing the complaints provides an opportunity to raise at European level the problems faced by solar power producers. Mr Tsiantoulis also referred to preparations for collective legal action at national level, noting that the move forms part of efforts to protect small and medium-sized producers’ investments and strengthen legal certainty.
What comes next
The next stage involves the European Commission’s examination of the complaints; there has been no indication that it has formally found an infringement. Developments at national level are also being closely watched, as they concern both the financial viability of investments and the rules governing the market.