Carbon Footprint Assessments
National Climate Law 4936/2022 introduces new obligations for key business sectors, municipalities, and the majority of projects/activities.
Each year, these entities are required to calculate their carbon footprint and set realistic emission-reduction targets in order to achieve the intermediate milestones of Law 4936/2022 and, ultimately, climate neutrality by 2050.
Article 19 – Projects & Activities
According to Article 19 of Law 4936/2022, the following groups of projects or activities are required to assess their carbon footprint, provided they are classified as Category A1 or A2 under Law 4014/2011 and are subject to the issuance of an Environmental Terms Approval Decision (ETA/AEPO):
Group 4 – Environmental infrastructure systems (e.g. wastewater treatment plants, landfills, sanitary landfills)
Group 6 – Tourism facilities and urban development projects, building sector, sports and recreational facilities
Group 7 – Poultry and livestock farming facilities
Group 8 – Aquaculture
Group 9 – Industrial, manufacturing, and related activities
Entities subject to Article 19 of Law 4936/2022 are required to:
Upload a Compliance Report to the Electronic Environmental Registry (EER), including the emissions reduction target.
Upload an Annual Verified Emissions Report to the EER.
Article 20 – Businesses
According to Article 20 of Law 4936/2022, the obligation to submit a Verified Carbon Footprint Report applies to specific categories of businesses, such as:
- Listed companies
- Credit institutions (banks)
- Insurance and investment companies
- Telecommunications companies
- Water supply and wastewater management companies
- Courier and express delivery companies
- Electricity and natural gas supply companies
- Retail chains employing more than 500 employees
- Logistics and supply chain service providers
- Urban transport service providers
Obligated businesses must prepare and submit an Annual Verified Carbon Footprint Report to OFYPEKA by 31 October each year.
Article 16 – Municipalities
According to Article 16 of Law 4936/2022, municipalities are required to prepare Municipal Emissions Reduction Plans (MERPs), which constitute a key instrument for the local implementation of the National Climate Policy.
MERPs include:
- An inventory of energy consumption and emissions for municipal buildings and facilities, street lighting and public spaces, municipal water supply, wastewater and irrigation facilities, and the municipal vehicle fleet.
- Integration of the Building Energy Efficiency Plan, in accordance with Article 7(12) of Law 4342/2015 (Government Gazette A’ 143).
- Definition of targets for reducing net emissions by 10% by 2025 and 30% by 2030, compared to the 2019 baseline year.
- Five-year revision of the Plans and annual monitoring through a Technical Progress Report, which may be prepared by the Municipality’s Energy Manager or an external body.
The preparation of a MERP is a prerequisite for funding energy-saving projects and climate change mitigation actions.
Our company supports municipalities at all stages: from data collection and emissions calculation to the drafting, monitoring, and submission of the Plans to OFYPEKA (NECCA).
For more information please do not hesitate to Contact us

