Law 4936/2022 — Articles 19 & 20 — GHG Reporting, Verification & Declaration
Law 4936/2022, published in the Government Gazette (ΦΕΚ A’ 105/27.05.2022), establishes Greece’s legislative framework for achieving climate neutrality by 2050 in line with the European Green Deal. Articles 19 and 20 create specific, enforceable obligations for installations and enterprises to measure, report and reduce their greenhouse gas (GHG) emissions.
The two articles address different categories of obligated entities and impose distinct requirements, timelines and penalties. Both require the engagement of an accredited independent verifier and submission of data to a publicly accessible electronic database managed by NECCA (Οργανισμός Φυσικού Περιβάλλοντος και Κλιματικής Αλλαγής — ΟΦΥΠΕΚΑ).
The obligation applies to Category A installations falling within the following Groups of the environmental classification ministerial decisions, provided they do not already participate in the EU ETS:
Waste treatment and disposal installations, landfills, composting, wastewater treatment facilities and similar environmental infrastructure.
Tourist installations and accommodation, urban development projects, buildings, sports and leisure facilities.
Intensive poultry and livestock farming operations of the scale classified under Category A environmental assessment.
Fish farming and aquaculture installations meeting the thresholds for Category A environmental classification.
Biomechanical activities, biogas installations and related biotechnology operations (per KYA 92108/1045/Φ.15/4.9.2020).
Article 20 applies to the following specific categories of legal persons. The obligation is defined by organisational type and sector, not by a generic size threshold.
Anonymous companies (AE) with shares or other securities listed on a regulated market in Greece.
Banks and credit institutions under Article 3 para. 1 of Law 4261/2014.
Insurance undertakings per Article 3 para. 1 case (a) of Law 4364/2016.
Investment companies per Article 4 para. 1 case (a) of Law 4514/2018.
Fixed and mobile telephone companies operating in Greece.
Water supply and sewage/wastewater management companies.
Express delivery and courier service companies.
Electricity and natural gas supply companies operating in Greece.
Retail chain store operators employing more than 500 employees.
Logistics service providers per Article 1 case (d) of Law 4302/2014.
Urban public transport companies providing scheduled passenger services.
Article 20 paragraph 3 specifies the exact methodologies to be used. Emissions must be calculated per the 2006 IPCC Guidelines for National Greenhouse Gas Inventories (as amended), covering direct and indirect emissions as defined in the GHG Protocol or ISO 14064-1:2018.
Emissions from sources owned or directly controlled by the reporting entity. As defined under the GHG Protocol “WORLD RESOURCES INSTITUTE” and ISO 14064-1:2018 Category 1.
Indirect GHG emissions arising from the consumption of purchased electricity, heat, steam or cooling. Defined as ISO 14064-1:2018 Category 2 and GHG Protocol Scope 2.
Article 20 paragraph 3 permits either of the following two internationally recognised frameworks, applied at Categories 1 and 2 (Scopes 1 and 2):
The foundational methodology, applied as amended. Provides the overarching framework for identifying, quantifying and reporting emission sources.
The GHG Protocol Corporate Accounting and Reporting Standard, widely used by private sector organisations globally for Scope 1 and Scope 2 reporting.
The ISO standard for quantification and reporting of GHG emissions at organisational level. Category 1 corresponds to Scope 1 and Category 2 to Scope 2 indirect energy emissions.
CO₂, CH₄, N₂O, HFCs, PFCs, SF₂ and NF₃ — all converted to tCO₂e using the most recent IPCC Global Warming Potential (GWP) values referenced in the national inventory.
Article 20: first reference year is 2022. Article 19: the reduction target is measured against the 2019 baseline, with 30% reduction required by 2030.
Both Articles 19 and 20 require that emission reports be reviewed and verified by an officially recognised independent verifier before submission. The verifier must be a natural or legal person recognised in accordance with Joint Ministerial Decision KYA Φ.01.2/56790/ΔΠΠ1828/31.5.2016 and meeting the minimum competence requirements of EU Implementing Regulation (EU) 600/2012 of the Commission (21 June 2012) on verification of GHG emission reports and accreditation of verifiers.
The verifier checks that all relevant Scope 1 and Scope 2 sources within the defined organisational and operational boundary have been identified and included.
Activity data (fuel consumption, energy purchased, process outputs) must be traceable to primary sources, invoices, meter readings or calibrated instruments. Data gaps and estimates must be documented and justified.
The verifier confirms that the correct IPCC/GHG Protocol or ISO 14064-1 methodology has been applied, and that the latest national GHG inventory emission factors have been used for energy conversion.
Upon satisfactory conclusion, the verifier issues a formal verification statement. This statement must accompany the GHG report when submitted to the NECCA database (Article 20) or the licensing environmental authority (Article 19).
When GHG emissions are quantified using direct measurement methods — rather than activity-data calculations — the accuracy and traceability of instruments is a central concern for the verifier.
Instruments such as continuous emission monitoring systems (CEMS), gas analysers (CO₂, CH₄, N₂O), flow meters and on-site fuel metering equipment must be calibrated at defined intervals by accredited laboratories (ESYD-accredited or equivalent EA-MLA member). Calibration certificates must demonstrate traceability to SI units and be available for inspection during verification.
Where technically feasible, MBO helps organisations design internal cross-verification protocols — for example, mass-balance cross-checks or duplicate measurement points — that can validate instrument readings without additional external laboratory costs. This approach is particularly applicable to fuel consumption and stationary combustion sources.
MBO provides a complete, end-to-end compliance service for both Article 19 (installations) and Article 20 (specific business sectors) — from initial assessment and emission calculations through to verified report submission.
We determine whether your organisation or installation is subject to Article 19, Article 20, or both — reviewing your sector, legal form, operational category and environmental licensing status.
We define the correct organisational and operational boundaries, identify all Scope 1 and Scope 2 emission sources, and select the most appropriate reporting framework (GHG Protocol or ISO 14064-1).
We design a structured data collection process, gather activity data and calculate emissions using IPCC-aligned methodologies and the national GHG inventory emission factors as required by the law.
We prepare a fully documented report covering all emission sources, methodologies, data quality assessments and uncertainty analysis — structured to meet verifier expectations under EU Regulation 600/2012.
Before the independent verifier engages, MBO reviews your report for gaps, inconsistencies or documentation deficiencies — reducing verifier queries and shortening the overall timeline.
We act as your representative during the independent verification, respond to verifier queries and help you select a suitable EU Regulation 600/2012-recognised body for your specific sector and scale.
We manage the complete submission of your verified report to the NECCA (ΟΦΥΠΕΚΑ) public database (Article 20) or to the licensing environmental authority (Article 19), ensuring all required fields are correctly populated by the statutory deadline.
A clear, structured process covering both Articles 19 and 20 of Law 4936/2022.
We determine which article applies to your organisation, review your environmental licensing status (for Art. 19) or legal form and sector (for Art. 20), and confirm the applicable reporting methodology and deadlines.
Definition of organisational and operational boundaries, identification of all Scope 1 and Scope 2 emission sources, selection of GHG Protocol or ISO 14064-1:2018 as the reporting framework, and assessment of data availability.
Structured collection of activity data (invoices, meter readings, production records). For direct measurement sources, we review calibration records and, where applicable, design internal cross-check protocols. Emissions are calculated using national GHG inventory emission factors.
Preparation of the full GHG report with methodology documentation, data quality assessment and uncertainty analysis. MBO then conducts an internal pre-verification review to identify and resolve any issues before the independent verifier is engaged.
The officially recognised verifier reviews the report and supporting evidence against EU Regulation 600/2012 requirements. MBO liaises on your behalf and responds to verifier queries. The verifier issues the formal verification statement upon satisfactory completion.
For Article 20: submission of the verified report and verification statement to the NECCA (ΟΦΥΠΕΚΑ) public electronic database. For Article 19: submission to the licensing environmental authority. Deadline management and confirmation receipt.
We archive all supporting documents, calibration certificates and submission confirmations. For Article 19, we also monitor progress against the 30% reduction target. We set up the annual data collection cycle to ensure next year’s reporting is more efficient and less demanding.
Law 4936/2022 specifies administrative sanctions for both late submission and failure to achieve the required emission reductions.
Contact MBO for an initial consultation. We will determine which article applies to your organisation, explain the requirements clearly and provide a tailored proposal covering all steps through to platform submission.
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