In November 2022, the Hellenic Competition Commission (“HCC”) launched proceedings under Article 11 of Law 3959/2011 (regulatory intervention in an economic sector) to examine the petroleum products sector and, specifically, to assess whether effective competition existed at the three stages of production and distribution (refining, marketing and retail sales) in the Greek markets for 95-octane unleaded petrol, diesel and heating oil.
In August 2024, the HCC published its Initial Views Report on regulatory intervention in the petroleum products sector, which is available here.
The report analysed (a) the structure and conditions of competition at each stage of the sector’s supply chain (refining, marketing and retail sales), (b) the institutional framework governing the petroleum products market in Greece, (c) trends in prices, trade flows and profitability indicators at the refining and marketing stages, (d) how the products under review are priced and the factors that affected price levels during the reference period, and (e) the phenomenon of asymmetric price pass-through (‘rockets and feathers’). The HCC subsequently published its Second Views Report in July 2025, which is available here.
This report reassesses the lack of effective competition in light of the submissions received on the Initial Views Report. It finds that effective competition does not exist in the sector and proposes a package of measures deemed absolutely necessary, appropriate and proportionate to establish effective competition across the sector.
On 10 December 2025, the HCC Plenary unanimously adopted Decision No. 896/2025 on regulatory intervention in the petroleum products sector. The decision is regulatory in nature, having been issued under Article 11 of Law 3959/2011, insofar as it requires companies operating in the sector to stop including exclusivity clauses concerning fuel storage in fuel storage/service agreements at facilities owned by third-party companies. In all other respects, the decision is advisory in nature, having been issued under Article 23(4) of Law 3959/2011. The details are as follows:
Under its powers pursuant to Article 11 of Law 3959/2011, the HCC unanimously decided that fuel storage/service agreements at facilities owned by third-party companies must be amended so that they no longer include exclusivity clauses concerning fuel storage.
In addition, under its powers pursuant to Article 23(4) of Law 3959/2011, the HCC unanimously recommends:
- To strengthen the capacity to import fuel:
- the establishment of an Independent Central Stockholding Entity (ICSE), supervised by the Regulatory Authority for Waste, Energy and Water (RAAEY), to hold emergency stocks on behalf of the obligated parties for a set fee. The fee would be paid by all obligated parties in proportion to their total consumption in the previous year, rather than according to any imports they may have made.
- the establishment of formal recording, monitoring and oversight of petroleum storage facilities, including any shortfalls or unused capacity, in a single register, and the designation of the authority responsible for maintaining that register.
- To reduce price transparency and the risk of tacit collusion in refining, Ministerial Decision No. 3006/18.4.2007 (Government Gazette, Series B, No. 554) should be amended. It requires the sale prices of petroleum products intended for the domestic market to be notified electronically to marketing companies by 10:00 on the morning of the delivery date. The notification should instead be made individually to each marketing company, without publishing the prices, which are currently posted daily on the website of the (former) General Secretariat for Trade and Consumer Protection.
- To increase price transparency at the retail level, the competent ministry should introduce a digital app to provide consumers with real-time price information in a user-friendly format. It should show prices at filling stations in real time by product, station and geographical area, and display the nearest stations and their prices based on the user’s current location. The app would build on and complement the databases available at fuel.gr and the Price Observatory.
The full text of Decision 896/2025 is available on the HCC website here.