Greece's competition authority – the Epitropi Antagonismou (Hellenic Competition Commission) – has significantly intensified its enforcement activity. Dawn raids, cartel investigations, and merger notification reviews are occurring at a pace not seen in previous years. International companies with Greek market exposure face real financial risk if their compliance programmes have not kept pace.
The Hellenic Competition Commission has escalated enforcement under Greece's competition legislation, targeting cartel conduct, market dominance abuses, and procedural failures in merger notification. Financial penalties can reach a meaningful share of a company's annual Greek turnover. Companies operating in Greece should review their compliance status immediately.
This alert sets out what has changed, which businesses are most exposed, and the concrete steps that international companies should take now.
What has changed – the enforcement shift and its scope
Greece's competition legislation aligns closely with EU competition rules. The Hellenic Competition Commission has broad powers to investigate suspected cartel conduct, penalise abuse of market dominance, and scrutinise concentrations that meet national turnover thresholds.
Three developments mark the current enforcement environment. First, the Commission has issued a series of decisions finding infringements across the retail, energy, construction, and digital sectors. Fines imposed on companies found to have participated in cartel arrangements have reached levels that can materially affect a business. Second, the Commission has deployed unannounced inspection powers – dawn raids – with greater frequency. Companies that are unprepared procedurally face compounding exposure: substantive penalties for the underlying infringement, and additional consequences for failure to cooperate effectively. Third, merger notification timelines are being enforced strictly. A transaction that crosses the statutory thresholds and proceeds without prior clearance can be declared void under Greek competition legislation.
The Commission has also signalled ongoing attention to digital markets and platform conduct. Companies that hold positions of market dominance – whether through traditional market share or through control of data and infrastructure – are subject to heightened scrutiny.
For international companies, the risk is not always obvious. A global distribution arrangement, a regional pricing policy, or an acquisition of a local Greek business can each trigger Greek competition rules. The fact that decision-making occurs outside Greece does not remove liability.
For advice on managing your exposure under Greek competition legislation, contact us at info@ferrazwhitmore.com.
Who is affected – threshold criteria and business categories
The following categories of business carry the highest exposure under current Greek enforcement conditions.
- Companies with significant market share in any Greek product or geographic market – the concept of market dominance applies where a business can behave independently of competitive pressure.
- Businesses party to distribution agreements, pricing arrangements, or information-sharing practices with Greek competitors or trading partners – even informal conduct can constitute a cartel under competition legislation.
- Groups completing acquisitions of Greek businesses where the combined turnover of the parties meets the statutory notification thresholds.
- International companies with Greek subsidiaries that participate in regional or global commercial arrangements – local subsidiaries can be held liable for conduct directed from a parent.
The leniency programme available under Greek competition legislation offers meaningful penalty reductions for companies that self-report cartel involvement before the Commission opens a formal investigation. The first company to report and cooperate fully may receive full immunity. Later applicants receive graduated reductions. This mechanism is underused by international companies – partly because of unfamiliarity with the Greek process, and partly because of mistaken assumptions about timing.
Companies in the retail, energy, and construction sectors should treat this alert as directly relevant. The Commission's published enforcement priorities name these sectors explicitly.
For a tailored assessment of your company's position under Greek competition rules, reach out to info@ferrazwhitmore.com.
What to do now – immediate actions and compliance steps
International companies should take the following steps without delay.
- Audit existing commercial arrangements – review distribution contracts, pricing policies, and information-sharing practices with Greek counterparts. Identify any conduct that could be characterised as coordinated behaviour restricting competition.
- Check merger notification obligations – if your group has completed or is planning any acquisition in Greece, verify whether the transaction meets the statutory thresholds. Failure to notify is a standalone infringement under Greek competition legislation.
- Prepare a dawn raid protocol – designate the personnel who will manage an unannounced inspection, ensure they know their rights and obligations, and confirm that legal counsel can be reached on short notice. Companies without a protocol in place are at a systematic disadvantage during inspections.
- Assess leniency eligibility – if there is any uncertainty about past or ongoing conduct that could constitute a cartel, seek specialist advice on leniency programme timing before the Commission takes its own investigative steps.
- Document compliance measures – the existence of a functioning internal compliance programme is treated as a mitigating factor in penalty calculations. Document the programme's scope, training records, and governance structure.
Companies facing corporate disputes in Greece that arise from or overlap with competition investigations should be aware that the two proceedings can run in parallel. Coordination between litigation strategy and competition defence is essential from the outset.
Our dedicated competition law practice in Greece covers the full range of enforcement scenarios – from dawn raid response and leniency applications to merger clearance and dominance defence. For related enforcement trends in neighbouring markets, our alert on competition enforcement in Portugal provides a useful comparative reference.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our competition law practice supports international companies facing enforcement actions, merger notification requirements, and cartel investigations in Greece and across the EU. Our attorneys combine Portuguese civil law grounding with English common law methodology – a dual perspective that proves particularly effective in cross-border competition matters where the conduct under scrutiny spans multiple legal systems. The firm's litigation and competition teams have experience before the Hellenic Competition Commission and in related administrative and civil proceedings. As an international law firm advising clients who need a lawyer in Greece with cross-border experience, we deliver results-oriented counsel to in-house legal teams, institutional investors, and multinational businesses. To discuss how Greek competition legislation applies to your situation, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.