The Hellenic Competition Commission (“HCC”) carried out an unannounced on-site inspection on 20 October 2026 at companies that provide operation, repair, maintenance and upgrade services for water supply and sewerage networks and/or wastewater treatment plants, and supply related equipment.
The HCC is investigating possible collusion between competitors to rig public tenders (bid rigging), in breach of Article 1 of Law 3959/2011 on the “Protection of Free Competition”, as amended, and/or Article 101 of the Treaty on the Functioning of the European Union (TFEU).
Inspections are carried out at companies from which evidence of anti-competitive practices in the market under investigation may be gathered. They do not prejudge whether the companies have engaged in anti-competitive conduct or the outcome of the investigation.
The legal framework for inspections
As guardian of the proper functioning of the free market, the HCC is responsible for enforcing competition rules under Law 3959/2011 and Articles 101 and 102 TFEU.
Article 1 of Law 3959/2011 and Article 101 TFEU prohibit agreements between companies (agreements, decisions by associations or concerted practices) that have as their object or effect the restriction of competition.
Article 1A of Law 3959/2011 prohibits unilateral practices that amount to an invitation to enter into a prohibited agreement, as well as announcements to competitors of future intentions regarding the pricing of products and services.
Article 2 of Law 3959/2011 and Article 102 TFEU prohibit the abuse of a dominant position in the market.
Intervention and strict administrative sanctions
The HCC says that, within the scope of its powers, it will make intervention an immediate priority wherever necessary and examine every relevant case that comes to its attention, whether through a complaint, a leniency application, anonymous relevant information submitted via its secure digital platform (whistleblowing) or other means. It will impose the strictest administrative sanctions on companies that engage in anti-competitive practices under Law 3959/2011 and Articles 101 and 102 TFEU.
The Commission’s leniency programme
A finding that a company has participated in cartel agreements—that is, secret agreements between competitors to fix prices or quantities, allocate customers or market shares, or rig tenders—may result in significant fines imposed by the HCC, criminal penalties for the individuals responsible, and the exclusion of the companies involved from public tenders and concession contracts for three (3) years from the date the decision is issued.
Joining the HCC’s leniency programme offers significant advantages to companies, associations of companies and individuals involved in such agreements, including:
Full or partial exemption from administrative fines, or a reduction in them; the removal of criminal liability or reduced penalties for the individuals responsible; full exemption for the company from any kind of administrative sanction; and no exclusion of companies from public tenders or concession contracts.