The Green Tank submitted detailed comments and proposals on the “Long-term strategy for the renovation of the public and private building stock and its transformation into a carbon-free, highly energy-efficient building stock by 2050,” which was put out for public consultation in December 2025.
Overall, the strategy is assessed positively, as it moves in the direction of decarbonising the building sector and aligns with both European legislation and national strategy, as reflected in the revised National Energy and Climate Plan (NECP). Particularly positive is the consideration of combined interventions, such as energy savings, improvement of the building envelope, electrification of heating, and increased penetration of Renewable Energy Sources (RES), as well as the recognition of the need for multiple and complementary financing instruments.
However, The Green Tank points out that the strategy presents significant shortcomings and implementation risks for a successful and socially just transition of the building sector, which can be summarised as follows:
Resources and financing
- Insufficient oversight of financing mechanisms: A clear framework for monitoring and controlling the financing of measures is lacking, especially in third-party financing schemes (e.g. on-bill financing), creating risks of lack of transparency and excessive profit-making practices. An enhanced role for RAAEY and the involvement of consumer protection bodies are required.
- Risk of excluding vulnerable households from financing instruments: The emphasis on private financing (e.g. loans, pay-as-you-save schemes, energy performance contracts) may exclude low-income households with limited access to own capital or borrowing.
- Risk of loss of public funds due to implementation delays: Experience from programmes such as “Apollo,” where resources intended for vulnerable households were decommitted due to delays, highlights the need for better planning and timely implementation.
Social dimension and energy poverty
- Insufficient alignment with the Social Climate Plan and energy poverty policy:
The strategy does not adequately ensure that resources from the Social Climate Fund will be directed exclusively to energy-vulnerable households and SMEs that are disproportionately affected by ETS2. - Complete absence of policies for social housing: There is no reference whatsoever to social housing, despite its critical role in addressing energy poverty and the housing crisis, as well as its prioritisation at EU level.
- Underutilisation of energy communities as a transition tool: The strategy limits the use of energy communities mainly to tackle energy poverty, instead of leveraging them as a key tool for the overall decarbonisation of the building sector and the democratisation of energy.
- Insufficient social and geographical targeting of interventions: The design of interventions is based mainly on climate zones and years of construction, without adequately incorporating socioeconomic characteristics and regional inequalities in energy vulnerability.
Targeting and effectiveness of interventions
- Long-standing problems in “Exoikonomo”-type renovation programmes: High bureaucracy, delays, participation costs, engineers’ fees, and difficulties in accessing financing significantly limit citizen participation, especially among the most vulnerable groups.|
- Need to update individual measures in line with the current regulatory framework:
Certain provisions (e.g. regarding energy net metering in the public sector) are not aligned with recent legislation and require immediate updating.
Read the full comments submitted by The Green Tank to the public consultation [in Greek] here.
