Climate Law 4936/2022: Compliance Guide to the Emissions Monitoring & Reduction System
Greece’s Climate Law 4936/2022 requires specific installations and enterprises to measure, verify, and reduce greenhouse gas (GHG) emissions. Based on international standards (ISO 14064-1:2018, the GHG Protocol, and the IPCC Guidelines), obligated entities must submit an annual emissions report and (where applicable) achieve reductions. QLC undertakes the full design, implementation, and verification preparation of the System.
The Emissions Monitoring & Reduction System is based on:
Greek Climate Law 4936/2022 (Gov. Gazette 105A/27.05.2022), especially Articles 19 & 20.
International frameworks: ISO 14064-1:2018, GHG Protocol (Scope 1 & Scope 2; optionally Scope 3) and IPCC Guidelines.
Who the Law Applies To
Article 19 – Category A Installations (outside the EU ETS)
Covers installations under Law 4014/2011 that do not fall under the EU Emissions Trading System and belong indicatively to the following groups:
Group 4: Environmental infrastructure systems
Group 6: Tourism facilities, urban development, buildings, sports & leisure
Group 7: Poultry/livestock installations
Group 8: Aquaculture
Group 9: Industrial activities & related installations
Target obligation: ≥30% emissions reduction by 2030 vs. 2019, normalized to an appropriate product/work unit.
Article 20 – Large Enterprises
Applies to legal entities that do not fall under the SME Recommendation 2003/361/EC (indicative examples: listed companies, banks/insurers, telecommunications, utilities, courier & logistics, large retail chains, urban transport operators).
Obligations:
Calculate the corporate carbon footprint (Scope 1 & Scope 2).
Submit an annual emissions report with external verification by an accredited body.
Deadline: 31 October each year. (Exception: the report for year 2025 may be submitted by 01/01/2026.)
No quantitative reduction target is set, but systematic monitoring & reporting are mandatory.
According to available figures, 277 companies submitted a carbon footprint report for 2023, reporting 20.62 million tCO₂e and a ~26% reduction vs. 2022—evidence that a structured measurement and control system delivers tangible results.
How the System Is Implemented — Compliance Steps
Baseline assessment: collect energy and operational data.
Map emission sources: classify Scope 1 (direct) and Scope 2 (energy-related indirect).
Calculations: apply IPCC/GHG Protocol emission factors and conversions.
Intensity indicators: set KPIs per unit of product/service for continuous tracking.
Reduction plan (where required): technical & organizational actions, responsibilities, timeline.
Procedures & controls: documented data collection, processing, and QA/QC.
Internal audit: confirm completeness & accuracy prior to external verification.
Third-Party Verification by Accredited Bodies
External verification involves on-site checks at companies/installations to ensure data integrity and includes:
Review of data and calculations
Issuance of a verification statement
Business Benefits
Legal compliance & avoidance of fines
Lower energy costs via evidence-based efficiency actions
Stronger ESG profile & environmental accountability
Competitive edge in public tenders and funded programs
Credibility with customers, partners & investors
QLC goes beyond minimum legal compliance co-designing an Emissions Monitoring & Reduction System that turns a statutory obligation into a competitive and sustainable advantage. Want to see how prepared your organization is? Ask QLC for a compliance diagnosis and action timeline. Get in touch with us.