The Green Tank submitted comments on Greece’s national Social Climate Plan, which has been open for public consultation since July 4 and concludes on July 18. This Plan is the main strategy for designing measures and policies aimed at mitigating the socio-economic impacts of implementing the new Emissions Trading System for buildings and road transport (ETS2).

Effective planning is of critical importance, as it presents a key opportunity both to meaningfully support the most vulnerable social groups—by addressing energy and transport poverty—and to decarbonize the sectors covered by ETS2.

The Plan includes positive directions, focusing on investments that aim to reduce dependence on fossil fuels, recognizing their use as the primary driver of increased energy and transport vulnerability due to carbon pricing.

However, it also exhibits significant weaknesses and gaps that need to be addressed to ensure the effective implementation of ETS2. These are summarized as follows:

• Sole reliance on the Social Climate Fund for financing: The absence of complementary use of revenues from the Emissions Trading Systems (ETS1 and ETS2) raises concerns about the adequacy of available resources for the necessary investments.
• Expansion of the beneficiary base: While promoted as a positive measure, this may lead to fragmentation of resources without substantially alleviating the burden on the most vulnerable households.
• Methodological shortcomings: The Plan does not include an assessment of the socio-economic impacts of ETS2, a costing of the proposed measures, a clear implementation timeline, or specific targets with measurable milestones—all of which are required by Regulation (EU) 2023/955.
• Omission of provisions for energy communities: Despite being a crucial tool for a just energy transition, energy communities are entirely absent from the Plan.
• Limited and unaligned direct income support: The planned direct support is narrow in scope and not aligned with European guidelines.
• Deficient consultation process: Despite efforts, the process suffered from shortcomings in design, delays, limited representation of key stakeholders, and sudden changes to the working group without prior notice.

You can read the full text of our comments submitted to the public consultation (14.07.2025) in Greek here.

You can also read our full study “Recommendations for policies and measures to mitigate ETS2 implementation impacts in Greece” here.

This article first appeared on The Green Tank website on 15 July 2025.