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Date: 10th December 2025
Examination of Allwyn’s acquisition of Novibet in plenary following SO recommending prohibition.
01/41
The Hellenic Competition Commission (the “HCC”) will convene in plenary on 12 January 2026 to assess the notified concentration concerning Allwyn’s acquisition of sole control over Novibet, following the issuance of the statement of objections (the “SO”).
According to the SO, the transaction may significantly restrict effective competition through horizontal unilateral effects in the affected markets of online betting and online casino games by strengthening Allwyn’s dominant position and removing competitive pressure in these markets. In particular, the SO underscores: (i) Allwyn’s high pre-transaction market share and the parties’ very high combined shares; (ii) the significant gap to the next competitor, with remaining competitors holding negligible shares; (iii) the parties’ closeness of competition on key parameters; (iv) the merged entity’s overwhelmingly larger customer base; and (v) high barriers to entry/expansion, limited potential competition and a lack of countervailing buyer power. The SO further considers Novibet as a significant competitive force, citing its aggressive pricing policy, high advertising expenses and its innovative award-winning “Hellenocentric” platform.
In this context, the SO proposes that the HCC prohibit the concentration.
Allwyn has proposed commitments with a view to addressing the aforementioned concerns.
HCC clears Generali Hellas’ acquisition of Euroclinic Athens.
02/41
The ΗCC has unconditionally approved the acquisition of sole control by Generali Hellas over Euroclinic Athens. The concentration involved vertical overlaps between the parties’ activities in the private health insurance market and the private healthcare (diagnostic centers) market. Considering the parties’ limited market shares, the HCC concluded that the transaction does not raise serious doubts as to its compatibility with the requirements for the effective functioning of competition in the relevant markets.
HCC greenlights Ellinika Galaktokomeia’s acquisition of Dodoni.
03/41
The HCC has unconditionally approved the acquisition of sole control over Dodoni by Ellinika Galaktokomeia. The concentration concerned the upstream markets for the supply of conventional and organic raw milk and a broad range of markets and sub-markets for final products, assessed at both national and regional level. The HCC found that the combined market shares and the incremental increase post-transaction are limited across almost all relevant markets, while in the region of Epirus – where Dodoni traditionally holds a strong position – raw milk producers retain significant bargaining power and the ability to switch to alternative buyers.
In this regard, the HCC concluded that the transaction is not expected to give rise to horizontal unilateral or coordinated effects and therefore does not raise serious doubts as to its compatibility with effective competition in the relevant markets.
HCC approves Ifantis’ acquisition of Nikas.
04/41
The HCC has unconditionally approved the acquisition of sole control over Nikas by Ifantis in the Greek cold-cuts sector. In particular, despite the parties’ notable combined market shares in certain retail segments, the HCC found that effective competitive constraints, namely (i) numerous competitors, (ii) volatile market shares, (iii) low barriers to entry and expansion, (iv) the absence of structural links, and (v) the significant bargaining power of supermarket chains, would continue to offset the competitive power of cold-cut suppliers and the effects of the concentration under examination.
In this context, the HCC held that the concentration is unlikely to give rise to horizontal unilateral or coordinated effects and does not raise serious doubts as to its compatibility with effective competition in the relevant markets.
HCC clears GEK TERNA’s acquisition of sole control of Egnatia Odos.
05/41
Τhe HCC approved the acquisition of sole control by GEK TERNA over the business activity of the Egnatia Odos motorway, covering its financing, operation, maintenance and exploitation. The HCC assessed the concentration in the markets for the grant of toll motorway concessions, transport infrastructure management, and related ancillary services, and concluded that it does not raise serious concerns as to its compatibility with competition rules in the relevant markets.
HCC accepts commitments by Public Retail on price protection clause raising potential resale price maintenance concerns.
06/41
The HCC has adopted a commitment decision concerning a price protection clause in Public Retail’s (“Public”) contracts with its suppliers in several product markets, including school bags, toys and large household appliances. The clause provided for retroactive compensation (e.g., via credit notes or discounts) to Public by its suppliers where Public reduced its retail prices in response to lower prices offered by competing retailers for the same suppliers’ products. In its preliminary assessment, the HCC considered that the clause could raise indirect resale price maintenance concerns, as it could pressure suppliers to maintain resale price levels within their retail network to avoid the financial burden of compensation and deter them from offering lower prices/terms to Public’s competitors. Accordingly, the clause could lead to artificial price alignment among retailers, restrict suppliers’ pricing freedom and prevent vigorous competition.
Public denied any infringement and stated the clause was never implemented, but committed to remove it and not reintroduce it.
The HCC adopted the decision without establishing an infringement, while warning that non-compliance may trigger fines.
Key takeaways for businesses:
HCC publishes key findings of its mapping study on veterinary medicines for sheep and goats.
07/41
The ΗCC published the key findings of its mapping study on competition conditions in the market for veterinary medicinal products (“VMPs”) for sheep and goats, focusing on vaccines, antibiotics/anti-inflammatories and antiparasitics, as part of its broader agri-food value chain strategy.
Key findings:
Regulatory and operational constraints:
HCC launches mapping study on competition in the agri-food value chain.
08/41
The HCC has launched a mapping study to assess competition conditions across the entire agri-food value chain, covering agricultural production, processing, wholesale and retail trade. The initiative complements earlier HCC mappings of specific products (e.g.milk, yoghurt, feta) and key inputs(animal feed and veterinary medicinal products), published in October 2025. Against the backdrop of rising food prices and recent inflation trends, the study aims to identify potential competition distortions and broader structural issues, while also taking into account wider economic factors affecting price formation. Findings are expected in Q3 2026.
HCC publishes Interim Report on its sector inquiry into bank deposits.
09/41
The HCC has published the Interim Report (the “Report”) of its sector inquiry into bank deposits, analysing market structure, supply and demand conditions, and the determinants of deposit interest rates in Greece (covering 2019-early 2025). The Report covers bank deposits, with particular emphasis on time deposits, while loans and mixed deposit–investment products are excluded from its scope.
The Report identifies the following concerns regarding factors influencing deposit rate formation: (i) the oligopolistic structure of the market and high barriers to entry; (ii) banks’ excess liquidity, which may reduce incentives to fully and swiftly pass through increases in ECB policy rates; and (iii) consumer inertia in searching for and switching providers.
The Report further notes that: (i) the deposit growth during the period mainly related to highly liquid, low-yield products; (ii) the pass-through of ECB policy rate increases to deposit rates has been limited, delayed and uneven; (iii) the opportunity cost of holding deposits remains high; and (iv) overall market conditions do not favour strong competition in deposit interest rates.
Finally, the HCC sets out its preliminary findings and proposals aimed at improving competition in the bank deposit market, including facilitating new entries and expansions, creating state-backed savings accounts, developing genuine savings products, and improving rate comparison tools.
Stakeholders are invited to submit their views by 16 February 2026 and/or participate in an online consultation in February 2026.
HCC conducts unannounced inspections in electricity generation and wholesale supply markets.
10/41
In the context of an ex officio investigation into the electricity generation and wholesale supply markets, the HCC carried out unannounced inspections at the premises of undertakings active in these markets. The HCC is examining alleged horizontal agreements/concerted practices, including price-fixing or the fixing of other trading conditions and/or the limitation or control of production/distribution, as well as a possible abuse of dominance by an undertaking through the imposition of unfair prices/conditions and/or the limitation of electricity generation/supply.
The investigation is being conducted with the assistance of the Regulatory Authority for Waste, Energy and Water (the “Regulatory Authority”), as part of a coordinated effort by the two independent authorities to investigate possible infringements within the framework of their distinct powers. In parallel, the Regulatory Authority has also launched its own ex officio investigation into potential breaches of the REMIT Regulation in the wholesale energy market.
HCC appoints Commissioner-Rapporteur in potential vertical restraints case in the pet food supply market under the Settlement Procedure.
11/41
The HCC has prioritised and assigned to a Commissioner-Rapporteur a case concerning potential anti-competitive vertical agreements in the pet food supply markets, under the Settlement Procedure. The case forms part of the HCC’s ex officio investigation into the import/production, wholesale and retail supply of pet food (dog and cat food). The HCC notes that parts of the case have already been assigned to a Commissioner-Rapporteur.
The European Commission seeks feedback on SAP commitments over alleged anticompetitive practices in on-premises ERP maintenance and support services.
12/41
The European Commission (the “Commission”) has invited all interested parties to submit their views on commitments offered by SAP to address suspected abusive conduct in the provision of its maintenance and support services for its on-premises ERP software. According to the Commission’s preliminary concerns, SAP may have engaged in certain abusive practices analysed in our September-October Flash Notes.
In order to alleviate the Commission’s concerns, SAP proposes a 10-year, worldwide package of commitments, including:
If adopted by the Commission, the commitments will apply globally, including in Greece.
Commission opens antitrust investigation into Red Bull over suspected abuse of dominance.
13/41
Τhe Commission opened a formal antitrust investigation to assess whether Red Bull may have developed a European Economic Area (“EEA”) -wide strategy – at least in the Netherlands – to restrict competition from energy drinks sold in cans larger than 250ml in the off-trade channel (e.g. supermarkets and petrol station shops). In particular, the Commission suspects that Red Bull may have engaged in two abusive practices: (i) granting monetary and non-monetary incentives to its off-trade customers to delist or disadvantage competing energy drinks (including reducing their visibility); and (ii) misusing its position as category manager at off-trade customers to achieve the alleged delisting or disadvantaging of competing energy drinks.
The Commission notes that this is its first formal investigation into a potential abuse involving the misuse of a category management position by a supplier.
Key takeaway for suppliers and retailers:
This investigation highlights increased regulatory scrutiny of category management arrangements in retail supply chains, particularly where such arrangements may be used to influence the assortment, placement or promotion of competing products. Given the limited decisional practice on alleged misuse of category management, the case is likely to shape future guidance and compliance expectations for retail supply chains across the EEA.
Commission opens antitrust investigation into alleged collusion between Deutsche Börse and NASDAQ in the financial derivatives market.
14/41
The Commission has opened an antitrust investigation into Deutsche Börse and NASDAQ over suspected collusion on the listing, trading and clearing of certain financial derivatives in the EEA. In particular, the Commission suspects that such entities may have entered into a non-compete arrangement, as well as other anti-competitive agreements/arrangements, including allocation of demand, price coordination and the exchange of commercially sensitive information.
The Commission frames the investigation as part of its efforts to safeguard a fair and open Single Market and promote a fully integrated Capital Markets Union.
Commission opens antitrust investigation into Google’s alleged abuse of dominance in AI content use.
15/41
The Commission has opened a formal antitrust investigation to assess whether Google has abused its dominant position by imposing unfair terms on publishers and content creators and/or granting itself privileged access to their content to train and power its generative artificial intelligence (“AI”) services.
In particular, the Commission is examining whether:
Commission opens antitrust investigation into Meta’s new policy regarding AI providers’ access to WhatsApp.
16/41
The Commission has opened a formal antitrust investigation to assess whether Meta’s new policy restricting AI providers from using the “WhatsApp Business Solution” where AI is the primary service may amount to an abuse of a dominant position. The Commission is concerned that such policy may block third-party AI providers from offering their services via WhatsApp in the EEA, while Meta’s own Meta AI would remain accessible to users on the platform.
The investigation covers the EEA except Italy, to avoid overlap with the Italian Competition Authority’s ongoing proceedings (including potential interim measures) concerning Meta’s conduct.
DG Competition Policy Brief rejects calls to extend LPP to in-house lawyers in competition law investigations.
17/41
As part of the evaluation of Council Regulation (EC) No 1/2003 (“Regulation 1/2003”), DG Competition officials published Competition Policy Brief No 1/2025 (the “Brief”) examining whether legal professional privilege (“LPP”) in the context of the Commission’s competition investigations should be extended to in-house lawyers. While the authors note that the Brief does not necessarily reflect the Commission’s official position, it provides a useful indication of DG COMP’s current policy thinking.
The Brief concludes that there is no reason to depart from established case-law: in Commission investigations, LPP is applied uniformly across the EU and covers only communications with (or advice from) independent, EU-qualified external lawyers, excluding in-house counsel.
It rejects key stakeholder arguments raised during the Regulation 1/2003 evaluation, particularly: (i) there is no predominant Member State trend towards recognising in-house LPP (only five Member States clearly recognise some form of in-house LPP, while the large majority do not), and it notes that Greek case-law has so far not upheld in-house LPP in competition law investigations; and (ii) the self-assessment regime under Regulation 1/2003 does not justify a change, as the Akzo judgments post-date Regulation 1/2003 and already rejected similar claims.
From an enforcement-policy perspective, the Brief argues that extending LPP to in-house lawyers would likely hamper investigations, citing: (a) abuse risks, given in-house lawyers’ integration within corporate structures—privilege could be used to conceal or even facilitate wrongdoing—and noting that significant evidence in real cases (including Teva Copaxone) was found in correspondence involving in-house counsel; and (b) complexity and administrative burden, since in-house lawyers often participate in internal exchanges beyond the provision of legal advice, making it difficult in practice to distinguish privileged legal advice from other communications, including purely commercial matters.
Key takeaways for businesses:
Εnsure documents are structured to benefit from the Commission’s narrow LPP approach at the time they are created, including by:
Intel saga: General Court reduces fine for naked restrictions.
18/41
In Case T-1129/23, the General Court largely upheld the Commission’s 2023 decision on Intel’s naked restrictions, but reduced the fine by approximately €140 million.
The case is a continuation of the long-running dispute stemming from the Commission’s 2009 abuse of dominance decision in the x86 microprocessors market, which was later annulled in part, leading the Commission to adopt a narrower decision in 2023 limited to practices not annulled. The General Court held that, since the existence of the anticompetitive naked restrictions had already been upheld by the EU Courts, the Commission was not required to re-establish jurisdiction or redefine a new infringement but merely to implement the earlier judgments by recalculating the fine based solely on the remaining conduct. The General Court also rejected Intel’s procedural complaints, including insufficient reasoning, the need for the issue of a new statement of objections and alleged infringements of the rights of defense, noting that the decision formed part of a procedural backdrop well known to Intel and that the Commission had sufficiently explained its fine-setting methodology.
However, exercising its unlimited jurisdiction, the General Court found that the fine had to be refined to better reflect the relatively limited number of computers affected and the 12-month gap separating certain practices.
Such decision underscores that, following a partial annulment, competition authorities must fairly redetermine a proportionate fine reflecting only the residual infringement.
Court of Justice of the European Union clarifies access to leniency statements and settlement submissions in criminal proceedings.
19/41
In Case C-2/23, (FL und KM Baugesellschaft m.b.H. & Co. KG et SAG) the Court of Justice of the European Union (the “CJEU”), in the context of a preliminary ruling, held that:
Key takeaway for businesses:
The judgment confirms that the leniency statements and settlement submissions remain strictly protected, thus supporting incentives to cooperate with the competition authorities, while annexes and supporting documentation may be transmitted and used in parallel proceedings subject to confidentiality and business secrets rules. In this context, companies should structure leniency statements and settlement submissions with a parallel-proceedings risk assessment, ensuring strict internal controls over the preparation and content of accompanying evidence.
CJEU clarifies when copyright royalties charged to hotels by collective management organisations may amount to abuse of dominance.
20/41
In Case C-161/24 (OSA z.s. v Úřad pro ochranu hospodářské soutěže), the CJEU set, inter alia, the conditions under which a collective management organisation’s (CMO) royalty-setting methodology may amount to an abuse of a dominant position. The Court held that a CMO’s failure to take hotel occupancy rates into account when calculating royalties may, depending on all relevant circumstances, contribute to a finding of abuse through the application of unfair prices subject to verifying whether the level of those royalties is excessive in light of the nature and scope of the use of the copyrighted works and the economic value generated by that use.
Key takeaway for hospitality sector:
Accommodation providers may challenge flat-rate royalty schemes imposed by CMOs that disregard actual occupancy, provided that a more accurate, occupancy-sensitive method of calculating royalties is feasible—having regard to the availability and reliability of occupancy data and existing technological tools—and can be implemented without entailing a disproportionate increase in the CMO’s administrative and monitoring costs.
CJEU clarifies scope of the essential facilities doctrine (Bronner criteria).
21/41
In Case C-245/24 (Lukoil Bulgaria/Lukoil Neftohim Burgas), the CJEU clarified when the Bronner criteria for abusive refusal of access apply to infrastructure originally developed by public authorities and later acquired by a dominant undertaking through privatisation, or operated pursuant to exclusive rights transferred by the public authorities. The CJEU held that Bronner remains applicable where the privatisation/transfer took place under conditions ensuring the competitive nature of the price and terms, and the dominant undertaking enjoys full decision-making autonomy over access to the infrastructure.
The CJEU also confirmed that where two companies within the same dominant undertaking are alleged to have pursued an overall strategy of refusing third-party access to facilities under their respective control and restricting trade, a competition authority may characterise the conduct as a single abuse under Article 102 TFEU. In such circumstances, the authority need not demonstrate separately that the Article 102 TFEU conditions are met for each type of conduct, provided it establishes those conditions for the overall abusive conduct.
CJEU guidance on margin squeeze and market definition under Article 102 TFEU
22/41
In Case C-260/24 (Lukoil Bulgaria), the CJEU clarified the requirements for establishing an abusive practice of margin squeeze under Article 102 TFEU. In particular, a competition authority must establish: (i) the existence of dominance on the upstream market; and (ii) the existence, on a downstream market linked to that upstream market, of pricing that is capable of producing exclusionary effects on competitors that are at least as efficient.
The CJEU also reiterated that only products showing a sufficient degree of substitutability may be included in the same relevant market for dominance assessment. Importantly, even where fuels are not functionally substitutable for end-consumer demand (diesel, petrol, LPG), the authority must assess whether competitive conditions and the structure of supply and demand justify treating some of them as belonging to the same upstream product market.
Commission’s investigation into potential DMA breach by Google.
23/41
The Commission has launched proceedings to assess whether Google complies with the Digital Markets Act (“DMA”) obligation to apply fair, reasonable and non-discriminatory conditions of access for publishers’ websites on Google Search. In particular, the Commission’s investigation suggests that Google’s “site reputation abuse” policy may demote publishers’ websites and content in its search results when they host content from commercial partners, thereby directly impacting a common and legitimate way for publishers to monetise their websites and content.
In case of infringement, the Commission may impose fines of up to 10% (up to 20% for repeated infringements) of worldwide turnover as well as other remedies.
Commission’s market investigations into cloud computing services under the DMA.
24/41
The Commission has opened three DMA market investigations into cloud computing. In particular, two investigations assess whether Amazon and Microsoft should be designated as gatekeepers for their cloud computing services. If such businesses are ultimately designated as gatekeepers, they would have six months to ensure full compliance with the DMA obligations.
The third investigation assesses whether the current DMA obligations sufficiently address practices in the cloud sector that may limit competitiveness or be unfair, such as tying and bundling of services and imbalanced contractual terms. This investigation will result in a final report, which may propose updates to the DMA obligations regarding cloud sector.
Commission’s conditional approval of ADNOC’s acquisition of Covestro under the Foreign Subsidies Regulation.
25/41
Further to our July/August Flash Notes on the Commission’s in-depth investigation of ADNOC’s acquisition of Covestro under the Foreign Subsidies Regulation, the Commission has conditionally approved the transaction, subject to full compliance with commitments offered by ADNOC. In particular, ADNOC committed to remove the unlimited State guarantee by amending its articles of association so as not to deviate from ordinary UAE insolvency law and to license Covestro’s sustainability-related patents to certain market participants on pre-defined, transparent terms.
The commitments apply for 10 years – with patent licensing commitments to remain in force beyond the commitment period, for the duration of any license agreement concluded during such period – and their implementation will be monitored by an independent trustee.
Commission opens in-depth foreign subsidies investigation into Nuctech’s threat detection systems.
26/41
The Commission has opened an in-depth investigation under the FSR into alleged foreign subsidies granted to Nuctech in relation to its production and sale of threat detection systems (TDS) and related services in the EU. Nuctech is headquartered in the People’s Republic of China (the “PRC”) and forms part of the Tsinghua Tongfang group which is indirectly controlled by the PRC.
The Commission’s preliminary view is that a number of measures granted by the PRC to Nuctech – including grants, preferential tax measures and preferential financing (loans)—may constitute foreign subsidies that improved Nuctech’s competitive position in the internal market, potentially enabling it to offer tender prices and conditions that rivals cannot reasonably match for the supply of large TDS and for the provision of TDS-related services.
Commission amends ETS State aid Guidelines to address increased carbon leakage risks.
27/41
The Commission adopted an amendment to the EU Emissions Trading System (“ETS”) State aid Guidelines to address the heightened risk of carbon leakage for additional energy-intensive industries, driven by persistently higher EU ETS emission costs. The amendment expands the list of eligible sectors and increases the aid intensity, aiming to support EU industrial competitiveness while preserving incentives to decarbonize.
Greek FDI screening regime becomes operational – publication of Joint Ministerial Decision No.64260/11.11.2025.
28/41
On 11 November 2025, Joint Ministerial Decision No. 64260/11.11.2025 (the “JMD”) (Government Gazette Issue B’ 6009/11.11.2025) of the Ministers of Foreign Affairs and Development was published, giving operational effect to the Foreign Direct Investment (“FDI”) control mechanism established by Law 5202/2025 (the “Law”). While the JMD does not provide any guidance on the interpretation or application of the substantive provisions of the Law, it gives operational effect to the Greek FDI control mechanism by regulating procedural matters, including the filing process, application content, supporting documentation and other formal requirements.
For further information about this development click here
Council and Parliament reach political agreement to strengthen EU FDI screening.
29/41
The Council Presidency and the European Parliament have reached a provisional political agreement to revise the EU FDI Screening Regulation, aiming to better identify and address security and public-order risks while keeping the EU open to investment.
Key points include:
The provisional agreement must now be endorsed by the Council and the European Parliament before formal adoption. The new rules will apply 18 months after entry into force.
Presentation of the Social Agreement signed between the Ministry of Labor and Social Security and the National Social Partners.
30/41
On November 26th, 2025 the Ministry of Labor and Social Insurance held a press conference to present the Social Agreement for Strengthening Collective Labor Agreements, signed by the Government and all National Social Partners.
This landmark agreement, concluded after seven months of tripartite consultation (from May to November 2025), marks the end of the memorandum-era limitations on collective bargaining and ushers in a new phase of social dialogue in Greece. It is the first time such a broad, tripartite consensus has been achieved, reflecting a shared commitment to reinforcing collective bargaining mechanisms.
The Social Agreement is structured around three main pillars:
I. Extension of Collective Labor Agreements
This pillar aims to expand the scope of protection by facilitating the extension of Collective Labor Agreements (CLAs). Key measures include:
II. Protection after CLA Expiry
This pillar ensures that employee protections continue beyond the expiry of a Collective Labor Agreement:
III. Dispute Resolution Procedures
This pillar focuses on improving the resolution of disputes between employees and employers by enhancing the role of the Organization for Mediation and Arbitration (O.ME.D.):
The draft Bill under the title “National Social Agreement for Strengthening Collective Labour Agreements”, introduced by the Ministry of Employment and Social Security, has been opened for public consultation until January 28th, 2026.
Revocation of Circular Nr.19/2025 on Social Contribution Exemptions.
31/41
According to General Document No 2039469/05-12-2025 issued by of e-EFKA, Circular No. 19/2025 has been officially revoked.
The revoked circular concerned the exemption from social security contributions on amounts related to:
as provided under the Individual Labour Code (P.D. 62/2025) for employees under full-time employment.
The issuance of new relevant guidelines is expected.
ERGANI II: New Ministerial Decision on Electronic Submission of Declaration.
32/41
The Ministry of Labor and Social Affairs has published a new decision in the Government Gazette (Issue B’ 6745 /16-12-2025) regarding ERGANI II system. The decision amends the previous act 40331/D1.13521/13-9-2019 (Issue B’ 3520), which set out the terms for the electronic submission of forms under the responsibility of the Labor Inspection Authority and the Employment Organization. The new ERGANI II Information System will be fully operational on 16 February 2026, completely replacing the existing ERGANI system, the operation of which is going to cease on the same date.
ERGANI II has been in pilot operation since April 2025, and, during the period from 16 December 2025 to 16 February 2026, it will operate in parallel with the existing system to allow businesses and professionals time to adapt.
EU Advances Major Sustainability Simplification with Omnibus I.
33/41
The European Parliament approved the Omnibus I package on November 13th, introducing significant simplifications to the Corporate Sustainability Reporting Directive (CRSD, EU 2022/2464), Corporate Sustainability Due Diligence Directive (CSDDD, EU 2024/1760) and Tax regulations. The reforms aim to reduce administrative burdens and strengthen business competitiveness in respond to long-standing requests from European industry.
Under the new CSRD framework, reporting obligations now apply only to large companies, with reduced disclosure content and optional sector-specific standards. Tax obligations will similarly apply only to companies already subject to the CSRD. As for the CSDDD, its scope is narrowed to very large companies, supported by a more targeted risk-based approach and fewer data demands from smaller value-chain partners, while climate transition plans are no longer mandatory.
The European Data Protection Supervisor Publishes New Guidance on AI Risk Management.
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The European Data Protection Supervisor (EDPS) has issued new guidance to assist EU institutions in identifying and mitigating data-protection risks arising from AI systems. Emphasizing accountability under the Regulation (EU) 2018/1725 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data (EUDPR), the EDPS highlights risks linked to complex AI supply chains and the need for institutions to demonstrate how these risks are addressed.
The guidance also focuses on key risk areas such as objectivity, accuracy, data minimization, security, and data-subject rights and outlines possible technical mitigation measures.
European Commission Launches AI content Labeling Code of Conduct
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The European Commission is developing a voluntary code of conduct to support the labeling of AI-generated content, including deepfakes. The initiative aims to enhance transparency, reduce the spread of misinformation, and guide both providers and users in disclosing AI involvement.
The code applies to text, images, video, and synthetic audio, with machine-readable formats for detection. These rules will complement existing frameworks governing high-risk and general-purpose AI systems and are expected to take effect in August 2026.
European Commission Launches AI Act Whistleblower Tool
36/41
A new secure platform now enables individuals to report suspected breaches of the EU AI Act anonymously. This tool is available in all EU languages and uses strong encryption to protect both data and the identity of whistleblowers.
The platform supports the early detection of risks to fundamental rights, safety, health and public trust. Whistleblowers can also receive updates on their submissions and communicate securely through the system.:
New Authority for Market Oversight and Consumer Protection.
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The Greek Ministry of Development has proposed the establishment of a new Independent Authority for Market Oversight and Consumer Protection. The Authority will consolidate key market-control and consumer-protection services, merging most of the Inter-Agency Market Inspection Unit, parts of the General Secretariat for Commerce, and the Consumer Advocate.
The main responsibilities will include combating illegal trade, enforcing consumer and market legislation, overseeing e-commerce and online search engines and coordinating inspection teams nationwide. The Authority will also handle consumer complaints, facilitate out-of-court dispute resolution, and conduct studies on market conditions.
A notable development is that the new Authority will have the power to bring representative actions on behalf of consumers – an ability previously reserved for a limited number of accredited consumer organizations.
Extension of the deadline for GEMI penalty framework until 31 January 2026.
38/41
On 31 December 2025, Joint Ministerial Decision No. 104666 (Government Gazette B’ 7204) was published, introducing amendments to the previously established regulatory framework under Joint Ministerial Decision No. 46982/2025, which governs administrative fines for non-compliant entities required to register with the General Commercial Registry (GEMI) and related matters.
Until 31 January 2026, obliged entities may:
As of 2 February 2026, administrative fines will begin to be imposed by the competent GEMI Services on non-compliant entities that are in breach of commercial publicity rules.
The 2025 Update to the OECD Model Tax Convention.
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In November 2025, the OECD Council approved the 2025 Update to the OECD Model Tax Convention on Income and Capital, along with relative changes in the observations, reservations, and positions made by OECD member and non-member states.
The 2025 Update, to be published within the next few months, incorporates significant changes with regard mainly, to how treaty countries’ tax authorities should interpret treaty provisions under article 5, regarding cross border remote work from home, the exploration and exploitation of extractible natural resources, and their impact on the creation of a business’ permanent establishment status.
Changes were further introduced to the Commentaries of articles 7, 9, 24, 25, and 26 aiming at clarifying implementation technical issues and providing a common basis of interpretation and certainty to both taxpayers and the tax authorities.
The 2025 Update, stemming from the need to regulate the 2019 pandemic work from home post effect, and bring into line the 2017 Model provisions with present conditions and requirements, is expected not only to guide tax authorities in future treaty negotiations but also to serve as interpretative guideline to currently applicable DTT provisions; as such it will prove of paramount importance for tax compliance, tax planning and dealing with controversies.
Under the 2025 Update, the analysis provided in the article 5 Commentaries, cross border remote work from home does not itself result in the foreign employer acquiring a business permanent established in the country the employee works.
Two criteria need be satisfied (cumulatively) for such a p.e. risk to materialize:
The 2025 Update includes five illustrative examples to facilitate a common understanding of the new interpretative rules.
Changes in the article 5 Commentaries further include an “alternative (optional)” provision regarding the acquisition of a permanent establishment status and taxation of profits deriving from the exploration and exploitation of extractible natural resources (oil, gas and minerals) and related activities, carried out offshore or offshore and onshore including specific onshore activities related to offshore works. Under the new optional provision, contracting states may agree on a lower permanent establishment threshold within any 12-month period, i.e. bilaterally agree on a shorter period than the standard p.e. thresholds; activities carried out during a period exceeding the threshold set, will result in the acquisition of the permanent establishment status of the enterprise carrying out said activities and taxation according to set rules.
Changes introduced to the Commentaries of articles 7, 9, 24, 25, and 26 clarify and provide mainly for:
It is worth noting that Greece recalled reservations made to article 5, regarding its right “to treat an enterprise as having a permanent establishment in Greece … … if scientific equipment or machinery is used in Greece for more than three months by the enterprise in the exploration or extraction of natural resources” and “to insert special provisions relating to offshore activities”, leaving thus space to the Greek tax authorities to get aligned with the OECD rules and proposals on the subject.
The implementation of the OECD rules and interpretative guidelines, as above, by the Greek tax authorities, will materially impact on the conduct of related activities in Greece; considering that Greece is evolving into a work from home hub, and further, major natural resources exploration and extraction projects are in place, guidelines are expected to shape Greece’s position in this new environment.
Law 5259/2025 on Public Benefit Assets and Foundations, Vacant Succession Inheritance Assets and Donations to Greek State.
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Law 5259/2025 replaces Law 4182/2013 and aims at introducing a new regime regarding the operation and taxation of public benefit organizations. Its scope of application is limited to public benefit foundations and assets granted to Greek state or to third parties and aimed to support public benefit purposes. Non-Greek foundations and trusts, as well as non-Greek legal persons and entities, operating under the laws of their place of establishment, and pursuing public benefit purposes in Greece are explicitly excluded from the scope of operation of Law 5259/2025.
Public benefit organizations are subject to new e-filing transparency processes, management audit and financial statements drafting requirements, while special procedural rules are provided for donations to Greek state.
As of January 1, 2026, zero tax is provided for, for income gained and inheritance and gifts received by public benefit organizations established and e-registered in Greece, as well as by public benefit legal persons established or to be established in another EU/EEA country and demonstrably pursuing charitable activities in Greece.
Council of State decision no 1243/2024 (ΣτΕ 1243/2024) re tax registry entries.
41/41
Greece’s Supreme Administrative Court held it is unlawful for a Tax Office to refuse correction of an erroneous Tax Register entry (tax representative wrongly registered as legal representative) on the grounds of “safeguarding of State interests” due to principal company’s debts and/ or the “inability” of the tax authorities’ software to register a tax representation status. Administrative registers must reflect the accurate legal status; technical constraints are not a lawful basis to deny rectification.
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