Greece has enacted Law 5236/2025 transposing Directive (EU) 2022/2557 (CER Directive) to strengthen the resilience of essential service providers against physical, technological and hybrid risks.
1. Scope
The Law applies to critical entities, i.e. public and private operators in key sectors (energy, transport, finance, health, water, digital infrastructure, public administration, space and food supply), with infrastructure in Greece, whose disruption would significantly affect essential services.
Excluded from the Law’s scope are matters governed by Law 5160/2024 (NIS 2 on cybersecurity), activities related to national or public security, defense, or law enforcement, as well as cases where other EU acts already impose equivalent obligations.
2. Main Obligations
Critical entities must:
- carry out comprehensive risk assessments;
- adopt technical, organizational and security measures to ensure resilience;
- appoint a representative for compliance matters;
- conduct personnel screening where necessary; and
- report significant incidents promptly.
Entities providing essential services in six or more EU Member States may be designated as having European significance and are subject to additional coordination requirements.
3. Penalties
The General Secretariat for the Protection of Critical Entities (G.S.P.C.E.), established within the Ministry of Citizen Protection, monitors compliance and may impose substantial administrative fines depending on the gravity of non-compliance, reaching up to €10 million in the most serious cases.
4. Key Timelines
17 January 2026: National Strategy on the resilience of critical entities to be adopted by G.S.P.C.E.
17 July 2026: Designation of critical entities and creation of the official register by G.S.P.C.E.
Within one month of the above designation: Critical entities receive formal notification from G.S.P.C.E.
Within nine months of the above notification: Completion of the entity’s risk assessment.
Stay tuned for timely insights and expert updates from KG Law Firm on every development in this matter.