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Δημόσια Διαβούλευση του Κανονισμού Τιμολόγησης, του Κώδικα Κατανομής Χωρητικότητας και των κατευθυντηρίων οδηγιών για δημόσιες διεθνείς διαγωνιστικές

Η Ρυθμιστική Αρχή Αποβλήτων, Ενέργειας και Υδάτων λαμβάνοντας υπόψιν την Οδηγία 2009/31/ΕΚ, και τις αρμοδιότητές της σύμφωνα με τις διατάξεις του νόμου «Ρυθμίσεις για τη δέσμευση, χρήση, μεταφορά και αποθήκευση διοξειδίου του άνθρακα – Ενσωμάτωση της Οδηγίας 2009/31/ΕΚ του Ευρωπαϊκού Κοινοβουλίου και του Συμβουλίου της 23ης Απριλίου 2009 σχετικά με την αποθήκευση διοξειδίου του άνθρακα σε γεωλογικούς σχηματισμούς και για την τροποποίηση της οδηγίας 85/337/ΕΟΚ του Συμβουλίου, των οδηγιών του Ευρωπαϊκού Κοινοβουλίου και του Συμβουλίου 2000/60/ΕΚ, 2001/80/ΕΚ, 2004/35/ΕΚ, 2006/12/ΕΚ και 2008/1/ΕΚ και του κανονισμού (ΕΚ) 1013/2006 (L 140)», όπως ψηφίστηκε από την Βουλή των Ελλήνων στις 11.12.2025 (υπό δημοσίευση ΚΑΔ 71927), θέτει σε δημόσια διαβούλευση τις ακόλουθες εισηγήσεις της Ελληνικής Διαχειριστικής Εταιρίας Υδρογονανθράκων και Ενεργειακών Πόρων Α.Ε. (Ε.Δ.Ε.Υ.Ε.Π. Α.Ε.), αρμόδιας αρχής «CCS». :

  1. Κώδικας Κατανομής Χωρητικότητας τόπου αποθήκευσης διοξειδίου του άνθρακα.
  2. Κανονισμός Τιμολόγησης τόπου αποθήκευσης διοξειδίου του άνθρακα “Prinos CO2 Storage”.
  3. Κατευθυντήριες οδηγίες για δημόσιες διεθνείς διαγωνιστικές διαδικασίες δημοπράτησης χωρητικότητας αποθήκευσης τόπου αποθήκευσης διοξειδίου του άνθρακα “Prinos CO2 Storage”. Περαιτέρω, για τον σκοπό της ενημέρωσης, παρατίθεται οι απόψεις του φορέα εκμετάλλευσης του τόπου αποθήκευσης διοξειδίου του άνθρακα “Prinos CO2 Storage”, αναφορικά με τον κανονισμό τιμολόγησης και τις Κατευθυντήριες οδηγίες, όπως αυτές διαβιβάστηκαν στην ΡΑΑΕΥ από την ΕΔΕΥΕΠ ΑΕ. Η δημόσια διαβούλευση θα διαρκέσει έως την Τετάρτη 17 Δεκεμβρίου
  4. Οι ενδιαφερόμενοι καλούνται να υποβάλουν τις απόψεις τους στη ΡΑΑΕΥ με ηλεκτρονική επιστολή στη διεύθυνση info@raaey.gr ή εγγράφως. Η ΡAΑΕY θα δημοσιοποιήσει κατάλογο των συμμετεχόντων στη διαβούλευση, με εξαίρεση την περίπτωση κατά την οποία ο αποστολέας αιτείται τη μη δημοσιοποίηση των στοιχείων ή/και των απόψεών του. ΑΚΡΙΒΕΣ ΑΝΤΙΓΡΑΦΟ Ε∆ΕΥΕΠ 12/12/2025 Α. Π.: Εισερχ. 31827 Ηµ/νία Αποστολής: 12/12/2025 EnEarth Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology CONTENTS 1 INTRODUCTION AND STRUCTURE 7 1.1 1.2 Introduction Structure 7 7 2 DEFINITIONS 8 3 GUIDING PRINCIPLES 11 3.1 3.2 Purpose and Scope Guiding Principles 11 11 4 STRUCTURE OF TARIFFS 12 4.1 4.2 4.3 4.4 Purpose and Scope Tariffs Structure and Components LCO₂ Handling Tariff Summary Injection & Storage Tariff Summary 12 12 13 13 5 CAPACITY BOOKING PRINCIPLES & PROCESS 14 5.1 5.2 5.3 5.4 5.5 5.6 Purpose and Scope Standard Capacity Product Short Term Capacity Product LCO2 Users Back-to-Back Booking Requirement Capacity Booking Process Summary Capacity Register 14 14 14 14 14 15 6 QUALIFYING COSTS 15 6.1 6.2 Purpose and Scope Core Cost Components 15 15 7 SETTING PRE FID COST ALLOWANCES 16 7.1 7.2 7.3 7.4 7.5 Purpose and Scope Pre-FID Capex Cost Schedule Pre-FID Opex Cost Schedule Pre-FID Variable Opex Cost Schedule WACC 16 17 17 17 18 8 SETTING COST ALLOWANCES AT FID 18 8.1 8.2 8.3 8.4 8.5 8.6 Purpose and Scope FID Capex Cost Schedule FID Opex Cost Schedule FID Variable Opex Cost Schedule FID WACC COD delays 18 18 19 19 19 20 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 9 SETTING POST COD COST ALLOWANCES 21 9.1 9.2 9.3 9.4 9.5 Purpose and Scope Post COD Capex Cost Schedule Post COD Opex Cost Schedule Variable or pass through Opex Post COD WACC 21 21 21 21 21 10 MONITORING OF COSTS 22 10.1 Purpose and Scope 22 10.2 Monitoring of cost elements 22 11 CAPACITY TARIFF COMPONENT CALCULATION 22 11.1 11.2 11.3 11.4 11.5 11.6 Purpose and Scope Capacity Tariff and Booked Capacity Capacity Tariff Calculation Mechanics Nominal Terms Cost and Revenues included in the Capacity Tariff calculations Capacity Tariff payments adjustment for Availability 22 22 22 24 24 25 12 VARIABLE CHARGE COMPONENT CALCULATION 25 12.1 12.2 12.3 Purpose and Scope Variable Charge Calculation Mechanics Actual Cost Reconciliation 25 25 26 13 ADDITIONAL TARIFF PREMIUM CHARGES 26 13.1 13.2 13.3 Purpose and Scope Users Allocated by Regulated Allocation Process Users Allocated by all Other Processes 26 26 26 14 TARIFF INDEXATION 26 14.1 14.2 14.3 14.4 14.5 Purpose and Scope Annual Indexation Adjustment or Replacement of Indices Extraordinary Adjustments Notification and Effective Date 26 26 27 27 27 15 ENDURING POST COD TARIFF REVIEW 27 15.1 15.2 15.3 15.4 15.5 15.6 Purpose and Scope Tariff Review Triggered by Under-Subscription Tariff Review Triggered to Support System Capacity Expansion Extraordinary Tariff Review Approval and Implementation of Revised Tariffs Dispute Resolution 27 28 28 28 29 29 16 OVERCOMPENSATION MECHANISM 29 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 16.1 16.2 Purpose and Scope Summary of Decision 29 30 17 BILLING, CREDIT AND PAYMENT 30 17.1 17.2 17.3 17.4 17.5 Purpose and Scope Invoicing and Billing Procedures Payment Terms Remedies in Case of Default Disputed Invoices 30 30 31 31 31 17.6 Currency, Taxes, and Withholding 32 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 1 INTRODUCTION AND STRUCTURE 1.1 Introduction 1.1.1 This document describes the principles, procedures, and methodologies governing the determination, calculation, and application of tariffs applicable to the use of The System, including but not limited to the terminal facilities, onshore buffer storage facility, and the offshore injection and storage system. It has been prepared in accordance with the relevant legislative framework, including The Law of the Ministry of Environment and Energy on the arrangements for the capture, use, transport, and storage of carbon dioxide, as well as the transposition of Directive 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide, and amendments to related directives and regulations currently under consultation. 1.1.2 The provisions are intended to ensure that all Users are subject to a transparent, equitable, and cost-reflective tariff regime, in alignment with the guiding principles prescribed by the applicable legal framework. 1.2 Structure 1.2.1 The code comprises the following sections: I. Section 1: Introduction and Structure; II. Section 2: Definitions; III. Section 3: Guiding Principles; IV. Section 4: Structure of Tariffs; V. Section 5: Capacity Booking Principles & Process; VI. Section 6: Qualifying Costs; VII. Section 7: Setting Pre FID Cost Allowances; VIII. Section 8: Setting Cost Allowances at FID; IX. Section 9: Setting Post COD Cost Allowances; X. Section 10: Monitoring of Costs; XI. Section 11: Capacity Tariff Component Calculation; XII. Section 12: Variable Charge Component Calculation; XIII. Section 13: Additional Tariff Premium Charges; XIV. Section 14: Tariff Indexation; XV. Section 15: Enduring Post COD Tariff Review; XVI. Section 16: Overcompensation Mechanism; XVII. Section 17: Billing, Credit and Payment. 5 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 2 DEFINITIONS 2.1.1 In this document, unless the context otherwise requires, capitalised terms shall have the meanings given to them below: Booked Capacity means the quantity of capacity (expressed in tonnes of CO₂ per annum) reserved by a User as described in their Standard Storage Agreement. Capacity Allocation Code means the framework for allocating User capacity on the system as defined in Article 27 of The Law. Capacity Booking Process means the procedures and steps for Users to reserve, confirm, and maintain Booked Capacity on The System, as set out in the Market Test Notice & Guidelines and the Capacity Allocation Code. Capex has the meaning given to it in Section
  5. Capex Cost Schedule means a schedule that details all Capex for The System over the Development, Construction, Commissioning, Operation and Post-Injection Periods. This schedule itemises qualifying costs in accordance with standard accounting practices, as outlined in Section 6 and may include projected and actual capital costs incurred throughout the project lifecycle. COD means the Commercial Operations Date, being the date on which The System is declared operational and available for use by Users, as confirmed by The System Operator. Commissioning Period means the time period during which The System Operator undertakes all necessary testing, verification, and preparatory activities to ensure The System is fully operational and compliant with all technical and regulatory requirements. Construction Period means the time period commencing from the FID, during which The System Operator undertakes the construction and commissioning of The System and ending on COD. Cost Schedule means a schedule setting out the relevant costs across the relevant time period. For example a schedule of Capex or Opex incorporating qualifying costs as set out in Section 6 following normal accounting practices. Final Investment Decision (FID) means the formal decision by The System Operator to proceed with the construction and commissioning of The System. The detailed conditions for an FID will be defined by EnEarth Greece and shall be communicated to The Users during Storage Agreement negotiations. Firm Long-Term Capacity means capacity reserved by a User for a continuous period of fifteen

(15)years, as the standard product offered by The System Operator under this methodology. Grant means financial support received from Greek, EU or other bodies to support the development and construction and operation of The System. 6 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology Injection & Storage Capacity Tariff Component means a charge (in € per tonne) of CO₂ Booked Capacity, covering all costs associated with offshore transport, injection, and permanent storage including all costs incurred by The System Operator during Operating Period and the Post-Injection Period Injection & Storage Tariff means a charge per tonne of CO₂ booked, covering all costs associated with offshore transport, injection, and permanent storage. It is comprised of the Injection & Storage Capacity Tariff and the Injection & Storage Variable Charge. Injection & Storage Variable Charge Component means certain costs, including but not limited to electricity consumption, EU Emissions Allowances (EUAs), taxes, the Special Fee for Local Communities or other regulatory levies, which are charged to Users at cost as incurred and are not included in the base Tariff. LCO2 means carbon dioxide at cryogenic temperatures and in liquid form. LCO2 Handling Capacity Tariff Component means a charge (in € per tonne) of CO₂ Booked Capacity and supplied in liquid CO2 form, covering all costs associated with the Onshore LCO2 Terminal including receiving and unloading vessels. LCO₂ Handling Tariff means a charge per tonne of CO₂ booked and supplied in liquid CO2 form, covering all costs associated with receiving and unloading liquid CO2 vessels including treatment of vapour return if any, the onshore buffer storage, CO2 handling, and injection facilities. It is comprised of the LCO2 Handling Capacity Tariff and the LCO2 Handling Variable Charge. LCO2 Handling Variable Charge Component means certain costs, including but not limited to electricity consumption, EU Emissions Allowances, special taxes or other regulatory levies imposed by the State or Local Authorities, which are charged to Users at cost as incurred and are not included in the LCO₂ Handling Capacity Tariff Component. Market Test Notice & Guidelines means the framework establishing the rules, principles and procedures for assessing market interest and reserving CO2 injection and storage capacity with The System, with the minimum content of the guidelines detailed in Annex V of The Law. Onshore LCO2 Terminal means the onshore facilities for receiving, unloading, conditioning and transferring liquid CO2, including indicatively but not exclusively the associated storage, handling systems, utilities and ancillary equipment for safe operation of The System. Operating Period means a period of 15 Years after The System Commercial Operations Date (COD) Opex Cost Schedule means a schedule detailing the projected and actual Opex associated with The System over the Construction, Commissioning, Operation and Post-Injection Periods. This schedule incorporates all qualifying Opex costs, as set out in Section 6, and follows normal accounting practices. This schedule does not include items that are detailed in the Variable Opex Cost Schedule. 7 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology Pass-Through Costs means costs incurred by The System Operator which are directly attributable to a User’s use of The System and are charged to The User at cost, including but not limited to electricity consumption, EU Emissions Allowances (EUAs). Post-Closure Costs has the meaning given to it in Section 6 and are required to meet the obligations of The Directive. Post-Injection Period means the period after the Operating Period but before transfer of ownership to the Competent Authority. Reference Index means the inflation index designated under this methodology for annual tariff indexation, as further specified in Section
  1. Special CCS Account means the account described in Article 39 of The Law. Special Fee for Local Communities – means The Fee described in Article 12 of The Law. Standard Storage Agreement – means a contract which describes, amongst other items, The Users Booked Capacity on the system and the users rights to access the capacity. The agreement is between The User and The System Operator. Storage Code means the Code on the Management of the Storage Facility as described in The Law. The Storage Code are the rules and conditions agreed between The Users and The System Operator as described which ensure the safe and efficient operation of The System. Storage Permit means the decision of The Competent Authority as per The Law and Directive 2009/31/EC System Availability means the extent to which the System is functionally capable of accepting, injecting, and storing Carbon Dioxide at a rate consistent with the sum of all Users’ nominated Capacity over a given period. System Capacity means the maximum throughput of The System, either as built or planned at COD, to accept, inject, and store carbon dioxide. This is determined with consideration for system integrity and operational needs and is measured in tonnes per year. Tariff Component means the Capacity Tariff Calculated using the methodology in Section 11 or the Variable Charge Component described in Section
  2. Tariff Type means either the LCO₂ Handling Tariff or Injection & Storage Tariff. The Competent Authority means HEREMA. The Directive means the directive 2009/31/EC of the European Parliament and of the council of 23 April 2009 on the geological storage of carbon dioxide and amending Council Directive 85/337/EEC, European Parliament and Council Directives 2000/60/EC, 2001/80/EC, 2004/35/EC, 2006/12/EC, 2008/1/EC and Regulation (EC) No 1013/2006 8 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology The Law means Arrangements for carbon capture, use, transport and storage - Incorporation of the Directive 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide and amending Directive 85/337/EEC Council Directives 2000/60/EC, 2001/80/EC of the European Parliament and of the Council EC, 2004/35/EC, 2006/12/EC and 2008/1/EC and Regulation (EC) No 1013/2006 (L 140) The Regulator means RAAEY. The System means the integrated onshore and offshore infrastructure of the Prinos CO2 Storage Project, which includes the jetty and unloading arms for LCO2, the onshore equipment and associated buffer and handling facilities, the offshore transport pipeline and subsea equipment, the Prinos storage reservoirs with injection wells and associated subsurface formations necessary. The System Operator – The company responsible for operating The System, EnEarth Greece S.A.. The User - Any person or legal entity that has entered into a Standard Storage Agreement with The System Operator, granting the right to use The System. The User Base - The collective group of Users that have Standard Storage Agreements with The System Operator. Variable Opex Cost Schedule means a schedule detailing the projected and actual variable operating expenses associated with The System throughout the Construction, Commissioning, Operation, and PostInjection Periods. This schedule specifically incorporates all qualifying variable operating costs, as set out in Section 6, and adheres to normal accounting practices. It does not include items that are covered within the Opex Cost Schedule. WACC means the Weighted Average Cost of Capital. 3 GUIDING PRINCIPLES 3.1 Purpose and Scope 3.1.1 This Section sets out the principles, definitions, and methodology for the determination, calculation, and application of tariffs for the use of The System. 3.2 Guiding Principles 3.2.1 The principles are aligned with The Law of Ministry of Environment and Energy "Arrangements for the capture, use, transport and storage of carbon dioxide - Transposition of Directive 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide" and for the amendment the directive 85/337/EEC of Council, of Directives 2000/60/EC, 2001/80/EC, 2004/35/EC, 2006/12/EC and 2008/1/EC of the European Parliament and of the Council and Regulation (EC) 1013/2006 (L 140). 9 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 3.2.2 In line with The Law described in above the guiding principles for the tariff methodology are as follows: a. Cost-Reflectivity: Tariffs shall be set to recover the full, efficient, and prudent costs of providing the services to the Users described in the Standard Storage Agreement, including all relevant cost components as set out in Section
  3. b. Transparency: The methodology, cost components, and tariff calculations shall be published and made available to all Users. The System Operator shall provide, upon reasonable request, such information as is necessary to enable Users to understand the basis of their individual tariff determination. c. Non-Discrimination: Tariffs and access terms shall be applied equally to all Users booking the same standard product, with no undue preference or discrimination between Users. d. Regulatory Compliance: The tariff methodology and its application shall comply with all applicable legal requirements. 4 STRUCTURE OF TARIFFS 4.1 Purpose and Scope 4.1.1 This section describes the general structure of the Tariffs and the components that are combined to create a Tariff applicable to a User of The System. 4.2 Tariffs Structure and Components 4.2.1 In order to accommodate the requirements of individual Users, two distinct Tariff Types are described: a. LCO₂ Handling Tariff. b. Injection & Storage Tariff. 4.2.2 Both the LCO2 Handling Tariff and the Injection & Storage Tariff are the sum of the following two components that are bespoke for each Tariff Type: a. Capacity Tariff Component - calculated using the methodology in Section 11 and the relevant Cost Schedules. b. Variable Charge Component - calculated using the methodology in Section 12 and the relevant Cost Schedules. 4.2.3 User’s tariffs are calculated according to the provisions in this document based on the specific Tariff Type they require. 10 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 4.3 LCO₂ Handling Tariff Summary 4.3.1 The LCO₂ Handling Tariff is comprised of the following components: a. LCO₂ Handling Capacity Tariff Component: a charge (in €) per tonne of CO₂ booked and supplied in liquid CO2 form, covering all costs associated with the Onshore LCO2 Terminal including receiving and unloading vessels. b. LCO₂ Handling Variable Charge Component: certain costs, including but not limited to electricity consumption, EU Emissions Allowances (EUAs), special taxes or other regulatory levies imposed by the State or Local Authorities, which are charged to Users at cost as incurred and are not included in the LCO₂ Handling Capacity Tariff Component. 4.3.2 No volumetric or throughput-based charges shall apply, except in respect of LCO₂ Handling Variable Charge Component as set out in paragraph above. 4.3.3 The System Operator shall only receive liquid CO2 compliant to the CO2 specifications as defined in the Storage Permit as well as in the Storage Code. 4.3.4 The LCO₂ Handling Tariff does not include any penalties due to late ship arrival, variations in delivered quantities. Any penalties related to late arrival or mismatches in deliveries of CO2 shall be defined in the Storage Code. 4.4 Injection & Storage Tariff Summary 4.4.1 The Injection & Storage Tariff is comprised of the following components: a. Injection & Storage Capacity Tariff Component: a charge (in € per tonne) of CO₂ booked, covering all costs associated with offshore transport, injection, and permanent storage including all costs incurred by The System Operator during Operating Period and the Post-Injection Period; b. Injection & Storage Variable Charge Component: certain costs, including but not limited to electricity consumption, EU Emissions Allowances (EUAs), taxes, the Special Fee for Local Communities or other regulatory levies, which are charged to Users at cost as incurred and are not included in the base Tariff. 4.4.2 No volumetric or throughput-based charges shall apply, except in respect of Injection & Storage Variable Charge Component as set out in paragraph above. 11 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 5 CAPACITY BOOKING PRINCIPLES & PROCESS 5.1 Purpose and Scope 5.1.1 This Section summarises the rules and procedures for the booking of capacity in The System which are set out in other documents. 5.2 Standard Capacity Product 5.2.1 The standard capacity product offered by The System Operator is Firm Long-Term Capacity, being the right to inject and store carbon dioxide for a period of fifteen
(15)years from the Commercial Operations Date (COD) of The System. 5.2.2 All capacity is booked on “ship-or-pay” basis, such that Users pay for their Booked Capacity irrespective of actual utilisation. 5.3 5.3.1 Short Term Capacity Product The System Operator may offer short-term contracts. Such contracts may be marketed with a premium or adjustment to reflect the additional flexibility and operational complexity associated with short-term access. 5.3.2 For the avoidance of doubt The System Operator shall only construct System Capacity that is booked in the long term so that short term capacity is not expected to be available other than potential capacity returned to The System Operator by User. In such a case The User that has returned capacity shall remain financially responsible as per the terms and conditions of their contract. 5.4 LCO2 Users Back-to-Back Booking Requirement 5.4.1 Users may only book LCO₂ Handling Capacity if, and to the extent that, they simultaneously book an equivalent quantity of Injection & Storage Capacity for the same period (the “Back-to-Back Booking Requirement”). 5.4.2 For the avoidance of doubt, Users may not hold LCO₂ Handling Capacity without holding the same quantity of Injection & Storage Tariff Capacity. 5.5 5.5.1 Capacity Booking Process Summary Capacity shall be allocated subject to technical availability and compliance with the capacity allocation process described in Article 27 of The Law through the implementation of the Capacity Allocation Code, namely: a. Regulated allocation process for users. b. Capacity allocated via public international tender procedures. 12 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology c. 5.5.2 Short term capacity allocated by The System Operator. Only users that have been allocated capacity on the system via the process listed above will have the right to enter into a Standard Storage Agreement with The System Operator. 5.6 Capacity Register 5.6.1 The System Operator shall maintain an up-to-date capacity register. 6 QUALIFYING COSTS 6.1 Purpose and Scope 6.1.1 This section sets out the framework for classifying all development, construction, operational, and post-injection costs that will be considered in either of the capacity tariff or variable charge calculations. 6.1.2 This section will describe what is included in the Cost Schedules used in the section 11 & 12 to create Capex, Opex, and Variable Opex Cost Schedules. 6.2 6.2.1 Core Cost Components The Cost Schedules used in section 11 and 12 together indicatively comprise all the following cost components which are organised in a typical fashion for information. 6.2.2 For the purposes of the Capacity Tariff and Variable Charge calculations each component is allocated to a Cost Schedule, either Capex, Opex or Variable Opex. The allocation is determined in accordance with International Standards and good industry practice. a. Devex, including indicatively but not exclusively the following: allowance for all Permitting, FEED, Subsurface, drilling and other type of studies as required for the development of The System to allow FID to be taken. The Devex allowance will include efficient owner management and engineering costs for a project of this scale. b. Capex, including indicatively but not exclusively the following: Allowance for all capital expenditure incurred during construction and commissioning including onshore jetty and tankage systems, pipelines, pumps, drilling and equipment for injection wells, brine producer wells, monitoring systems, ESP pumps and any other items required. c. Maintenance Capex, including indicatively but not exclusively the following: Allowance to replace major items of equipment as Capex during the operation phase of the project such as ESPs and costs linked to assuring the integrity of The System and any other capital expenditure for the maintenance of the System. 13 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology d. Fixed Opex, including indicatively but not exclusively the following: Personnel costs, operation and maintenance costs, parent company costs, monitoring, HSE, and environmental regulatory compliance. e. Variable Opex, including indicatively but not exclusively the following: Electricity, Equipment, replacement, spare parts and Special Fee for Local Communities. f. Closure and Post-Closure Costs, including indicatively but not exclusively ABEX as well as all costs that occur after decommissioning and abandonment of The System is complete. This includes indicatively but not exclusively post-closure monitoring, corrective measures if any and all other obligations of The System, as required by Legal Requirements or Competent Authorities including those set out in the Directive. g. ABEX, including indicatively but not exclusively the following: the costs associated with the safe cessation of operations, decommissioning, and site remediation of The System. Including costs associated with the closure, sealing of the storage site, plug and abandonment of CO2 injection and water producing facilities developed for the purposes of The System. h. Insurance Cost, including indicatively but not exclusively the following: Insurance costs which cover construction, operation, operational, environmental and long-term CO2 containment risks. i. Regulatory & Finance Costs: All costs that are not included in the items above, but The System Operator is required to pay including indicatively but not exclusively interest, finance costs and fees, taxes, levies, and storage license obligations such items as Financial Security and Financial Contribution as per the Directive and The Law. 6.2.3 The System Operator shall maintain records of all cost components in line with normal accounting practices. 7 SETTING PRE FID COST ALLOWANCES 7.1 Purpose and Scope 7.1.1 The Tariffs paid by Users will be estimated at the Pre-FID stage based on preliminary design and budget assumptions, updated at FID to reflect construction costs negotiated as part of the FID decision, and updated Post-COD upon completion of construction and confirmation of actual costs. 7.1.2 As part of the Pre-FID Capacity Booking Process the sum of the system Booked Capacity may differ from the System Operators initial projections. It may be necessary to adjust the Tariff Components during the Pre-FID period based on the results of the economic viability assessment described in the Capacity Booking Process because the Booked Capacity projection strongly influences the Tariff Component calculation and the outcome of the assessment. The results of this would be communicated in writing to the relevant parties. 14 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 7.1.3 The cost allowances set by this section should cover all reasonable costs that would be incurred by The System Operator to plan, construct and operate the system but are based on Ex-Ante cost estimates with reasoned provisions for risk included in the estimate. 7.1.4 The costs outlined in the section will be published in The System Cost Schedule for the purposes of calculating the Tariff using the methodology outlined in Section 11 and for scrutiny under the provisions in Section
  1. 7.2 7.2.1 Pre-FID Capex Cost Schedule A Capex Cost Schedule will be created based on Pre-FID design documents and associated costing prepared in line with best practice and accounting rules. Section 6 describes the qualifying costs that are included in the Capex Cost Schedule. The Cost Schedule will be provided alongside an estimate of the accuracy of the Cost Schedule and shall include but not limited to provisions for: a. Technical Risks b. Currency Exchange Risks c. 7.2.2 Risks linked to the uncertainty of the User Base of The System The Capex Cost Schedule will be net of any Grants received or predicted to be utilised by The System Operator during Construction, Commissioning or Operation. 7.3 7.3.1 Pre-FID Opex Cost Schedule An Opex Cost Schedule based on the end of FEED stage operating philosophy for The System, management and parent company costs and regulation linked costs. Section 6 describes the qualifying costs that are included in the Opex Cost Schedule. The Cost Schedule will be provided alongside an estimate of the accuracy of the Cost Schedule and shall include but not limited to provisions for: a. Technical Risks b. Regulatory Risks c. 7.3.2 Risks linked to the uncertainty of the User Base of The System The Opex Cost Schedule will be net of any Grants received or predicted to be utilised by the project during Construction, Commissioning, Operation or Post-Injection Periods. 7.4 Pre-FID Variable Opex Cost Schedule 7.4.1 A Variable Opex Cost Schedule will be created based on the end of FEED stage operating philosophy for the System, forecast costs for power and EUAs, and forecast System throughput. Section 6 15 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology describes the qualifying costs that are included in the Variable Opex Cost Schedule. This Cost Schedule will be used to provide an estimate of the Variable Charge Components that covers the Pass-Through Costs. This Cost Schedule is indicative and actual costs will be used charged to the System Users as per clause
  2. 7.5 WACC 7.5.1 The WACC should reflect the specific risk profile of The System and be calculated using a transparent methodology appropriate for the Pre-FID stage of the project. The WACC floor value, the lowest value of WACC required to enable the project to progress towards FID for this project is described in the state aid decision A.108267 (2024/N). 8 SETTING COST ALLOWANCES AT FID 8.1 Purpose and Scope 8.1.1 The main objective of establishing cost allowances at FID is to set a tariff based on the costs that have a tighter accuracy range, reflecting the market engagement completed and allow stakeholders and the Users FID to occur across the chain at the same time. The following approach is based on this principle. 8.1.2 The costs outlined in the section will be published in a sequence of Cost Schedules created for the purposes of calculating the Tariff using the methodology outlined in Section 11 and for scrutiny under the provisions in Section
  3. For the avoidance of doubt, the Tariff shall be recalculated post COD 8.2 FID Capex Cost Schedule 8.2.1 At FID project Capex costs are largely fixed with the majority of construction prices known and risk priced and allocated between the System Operator and construction contractors. 8.2.2 At an appropriate time, when the major construction contracts are ready to be awarded, the forecasted Capex Cost Schedule to build The System will be stated. The FID Capex Cost Schedule will include the following items in addition to the forecasted cost to construct the system: a. Aggregated contingency allocated to the System Operator set in line with the terms across all major construction and drilling contracts b. An appropriate additional risk allocation set in line with the System Operator company policy 8.2.3 The Capex Cost Schedule will be net of any Grants received or predicted to be utilised by the project during Construction, Commissioning, Operation, Closure and Post-Injection Periods. 16 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 8.3 8.3.1 FID Opex Cost Schedule An Opex Cost Schedule will be created based on operating philosophy developed to support the FID decision for The System Operator and parent company costs and regulation linked costs. The Cost Schedule will be provided alongside an estimate of the accuracy and shall include but not limited to provisions for: a. Technical Risks b. Regulatory Risks c. 8.3.2 Risks linked to the uncertainty of the User Base of The System The Opex Cost Schedule will be net of any Grants received or predicted to be utilised by the project during Construction, Commissioning, Operation or Post-Injection Periods. 8.4 8.4.1 FID Variable Opex Cost Schedule A Variable Opex Cost Schedule will be created based on the end of FEED stage operating philosophy for the System, forecast costs for power and EUAs, and forecast System throughput. This Cost Schedule will be used to provide an estimate of the Variable Charge that covers the Pass-Through Costs. This Cost Schedule is indicative and actual costs will be used charged to the System Users as per clause
  4. 8.4.2 The System Operator may seek a long term Renewable Power Purchase Agreement (PPA) to meet part of its electricity requirements. 8.4.3 Electricity cost forecasts shall account for the nature of PPA agreements secured by The System Operator with additional requirements to be met from the national and/or European energy market. Electricity procurement for the system will be in line with normal and efficient purchasing approaches for Electricity with 8.5 8.5.1 FID WACC AT FID the project WACC will be fixed for the duration of System Operation. The WACC should reflect the specific risks of The System and be calculated using a transparent methodology. 8.5.2 Illustrative considerations and method to calculate The System WACC are provide in the following formula: 𝑊𝐴𝐶𝐶 = 𝐷 𝐸 ∗ 𝑅𝐷 ∗ (1 ― 𝑇) + ∗ 𝑅𝐸 𝐷+𝐸 𝐷+𝐸 And 𝑅𝐸 = 𝑅𝑓 + 𝛽 ∗ 𝐸[𝑅𝑚] ― 𝑅𝑓 + 𝑆𝑃 17 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology Where: 𝑅𝑓 Risk-Free Rate: Based on long-term government bond yields as published by the Bank of Greece. 𝐸[𝑅𝑚] ― 𝑅𝑓 Market Risk Premium (MRP): Derived from recognized financial benchmarks. 𝛽 Beta: Reflecting the non-diversifiable risk of CCS infrastructure compared to peers. 𝑆𝑃 Size Premium: Accounting for project scale and market position. 𝑅𝐷 Cost of Debt: Based on actual or notional debt yields, adjusted for credit risk. 𝑅𝐸 Cost of Equity; Determined using the CAPM formula 𝑇 Tax Rate: In line with national corporate tax legislation. 𝐷 Gearing Assumptions: Debt-to-equity ratio reflecting efficient financing structure. 𝐷+𝐸 𝑊𝐴𝐶𝐶 – Weighted Average Cost of Capital 8.5.3 The Market Risk Premium (MRP) applied in the calculation of the cost of equity shall include an appropriate adjustment for innovation, regulatory, and commercial uncertainty. This adjustment is necessary to capture risks associated with immature technology, evolving policy frameworks, and market adoption challenges. 8.5.4 The cost of debt shall incorporate a technology margin premium to compensate lenders for the heightened risk profile of CCS projects. This premium should reflect the limited operational track record of CCS systems, the higher perceived probability of technical failure compared to mature assets, the lower recovery value in the event of default, and the more conservative lending practices typically applied to novel technologies, including more conservative financial ratios such as higher Debt Service Coverage Ratios (DSCR) or loan life cover ratio. 8.5.5 These provisions ensure that the Weighted Average Cost of Capital (WACC) calculation remains consistent with prudent risk management and regulatory oversight for early-stage technologies. 8.6 COD delays 8.6.1 COD delay and any associated cost such as liquidated damages are a contractual matter. 18 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 9 SETTING POST COD COST ALLOWANCES 9.1 Purpose and Scope 9.1.1 The purpose of the Post COD allowance is to determine a final tariff and include any qualifying cost increase or contingencies in the tariff calculation. 9.1.2 The costs outlined in the section will be published in The System Cost Schedule for the purposes of calculating the Tariff using the methodology outlined in Section 11 and for scrutiny under the provisions in Section
  5. 9.2 Post COD Capex Cost Schedule 9.2.1 At an appropriate time after COD when the final Capex costs are known, the tariff for the operating period can be calculated. Upwards movement in the Capex Cost Schedule from the predicted cost at FID will be included in The System Post COD Capex Cost Schedule with the adjustment hierarchy noted below: a. Contingencies shall be applied first. b. Any remaining cost overruns that would alter the Tariff will be agreed with The Regulator. 9.2.2 The Post COD Capex Cost Schedule will be net of any Grants received or predicted to be utilised by the project during the Construction, Commissioning, Operation or Post-Injection Periods. 9.3 Post COD Opex Cost Schedule 9.3.1 An Opex Cost Schedule will be created based on the actual costs that The System Operator is committed to on a rolling basis in line with the tariff billing cycle. 9.4 Variable or pass through Opex 9.4.1 The System Operator will update inputs used to estimate pass-through costs at COD, including projected energy consumption and CO₂ leakage allowances. 9.5 Post COD WACC 9.5.1 Post COD the project WACC will be the FID WACC described in Section
  6. 9.5.2 The System Operator retains the right to increase the post-COD WACC in case of substantial change in equity and financial markets and duly substantiated. Such change shall be subject to the approval of the Regulator. 19 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 10 MONITORING OF COSTS 10.1 Purpose and Scope 10.1.1 The purpose of this section is to set out how the costs described in Sections 7, 8 and 9 will be monitored and audited to comply with the guiding principles set out in Section
  7. 10.2 Monitoring of cost elements 10.2.1 The monitoring framework under The Regulator ensures transparency, compliance, and accurate cost recovery throughout The System lifecycle. 11 CAPACITY TARIFF COMPONENT CALCULATION 11.1 Purpose and Scope 11.1.1 The purpose of the Capacity Tariff calculation is to ensure that The System Operator can recover the fixed costs for development, construction, operation, and abandonment of The System including Post-Closure Costs, at the Weighted Average Cost of Capital (WACC) from the Users. 11.1.2 The Capacity Tariff is calculated in Euros per tonne of booked capacity and the same calculation mechanics are used to calculate the Capacity Tariff component for both Tariff Types. 11.2 11.2.1 Capacity Tariff and Booked Capacity The Capacity Tariffs are determined based on each User's proportion of The System's total Booked Capacity. This approach ensures that cost recovery for constructing and operating The System is allocated equitably between The Users according to each User's Booked Capacity, while enabling The System Operator to recover all incurred costs. The Capacity Tariffs will be stated in Euros per tonne. 11.3 11.3.1 Capacity Tariff Calculation Mechanics The System Capacity Tariff shall be calculated such that for the aggregate of the Capacity Tariffs of The System net post-tax cashflow results in a project Net Present Value (NPV), calculated at the WACC, is equal to zero. For this purpose, all projected net revenues from the Capacity Tariff over the Operating Period shall be discounted at the WACC. This ensures that the revenue generated by the Capacity Tariffs recovers the total allowed costs after tax, including a return commensurate with the WACC. 11.3.2 The relevant Cost Schedules for the Tariff Type and Tariff Component are a key input to this calculation and are created following the instructions in Sections 7, 8 and 9 noting the provisions in 11.
  8. 11.3.3 The NPV relationship between the WACC, revenue and costs, can be stated as per Formula
  9. 20 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 𝑂𝐿 𝑅𝑡 ― 𝐶𝑜𝑝,𝑡 (1 ― 𝜏) + 𝜏 ⋅ 𝐷 𝑒 𝑝𝑡 ― 𝐶𝑐𝑎𝑝,𝑡 =0 (1 + 𝑊𝐴𝐶𝐶)𝑡 𝑡=1 Formula 1 - Recoverable Revenue Formula Where, OL: The System Development, Construction, Operation and Post-Injection Period in years, For the avoidance of doubt, this includes the Closure and post-Closure periods. R: Revenue, Ccap: capital costs from the Cost Schedules less Grants, Cop: Opex from the Cost Schedules less costs allocated to the charge in Section 12, Dep: Annual Depreciation Allowance, τ: Corporate Tax Rate, t: Time period in years. 11.3.4 The Capacity Tariff can be derived from Formula
  10. 𝑂𝐿 𝑇𝑡 = ∑𝑡=1 𝐶𝑜𝑝,𝑡(1 ― τ) + 𝐶𝑐𝑎𝑝,𝑡 ― τ ⋅ 𝐷𝑒𝑝𝑡 (1 + 𝑊𝐴𝐶𝐶)𝑡 ⋅ (1 + 𝐼𝑁𝐹)𝑡 (1 ― τ) 𝑂𝐿 ∑𝑡=1 (1 + 𝑊𝐴𝐶𝐶)t Formula 2 - Capacity Tariff Formula Where, Q: total booked System Capacity, T: Capacity Tariff in Euros per tonne, OL: The System Development, Construction, Operation and Post-Injection Period in years, For the avoidance of doubt, this includes the Closure and post-Closure periods., 21 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology Dep: Annual Depreciation Allowance, INF: Inflation rate (initially forecast during tariff calculation then during the Operation Period replaced by the tariff indexation in Section 14) τ: Corporate Tax Rate, Ccap: capital costs from the Cost Schedules less Grants, Cop: Opex from the Cost Schedules less costs allocated to the charge in Section 12, t: Time period in years. The above is a summary formula of a calculation that will be conducted in a detailed financial model as reviewed by The System Operator and The Regulator. 11.4 11.4.1 Nominal Terms All costs and revenues shall be calculated and presented in nominal terms, meaning they reflect actual monetary values at the time of payment, inclusive of inflation adjustments. 11.4.2 For the purposes of the calculation mechanics, The Capacity Tariff shall be established in Euros per tonne in real terms based on the target Final Investment Decision (FID) date and a forecast inflation rate during the Operation Period, and subsequently indexed by the agreed inflation factor for the duration of the regime for each phase of the project, Pre-FID, FID and Post COD. 11.5 Cost and Revenues included in the Capacity Tariff calculations 11.5.1 The cash flow is calculated based on the Capacity Tariff revenues, net of the relevant grants received, adjusted Cost Schedule and tax rates forecast. 11.5.2 All cost as per the Cost Schedule except Pass-Through Costs are included in this calculation. 11.5.3 The Pass-Through Costs and associated revenues are excluded from this calculation. 11.5.4 The decommissioning costs which The System Operator are obliged to pay as part of The System Storage Permit following the payment schedule agreed with The Authority and are assumed to occur immediately after The Operating Period ends. 11.5.5 Certain costs associated with CO₂ storage infrastructure will survive beyond the Operating Period, even after tariff-setting obligations have expired. These include but are not limited to: a. Decommissioning costs for dismantling and restoring infrastructure. 22 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology b. Monitoring and verification costs during the post-closure phase to ensure permanent containment. c. Corrective measures and environmental remediation, if required. d. Financial contributions to the Special CCS Account for long-term liability coverage. e. Financial Contribution as per article 20 of The Directive 11.6 Capacity Tariff payments adjustment for Availability 11.6.1 If the actual CO₂ volume processed is less than the sum of users Booked Capacity for the billing period and caused by a lack of availability of The System, then Capacity Tariff payments will be reduced in a proportionate manner based on the circumstances, unless agreed otherwise. 12 VARIABLE CHARGE COMPONENT CALCULATION 12.1 Purpose and Scope 12.1.1 The purpose of the Variable Charge calculation is to provide an estimate to Users of the Pass-Though cost of the System during the Construction, Commissioning, Operation and Post-Injection Period. 12.1.2 The Variable Charges will be calculated in Euros per tonne of throughput and the Variable Charge component calculation mechanics are used to calculate the Variable Charge component for both Tariff Types 12.2 Variable Charge Calculation Mechanics 12.2.1 The Variable Charges will be calculated so that all Pass-Through Costs are recovered from the System Users on a regular basis throughout the Construction, Commissioning, Operation and Post-Injection Period. 12.2.2 The calculation allows for an estimation of the Pass-Through Costs based on forecast prices, and operational requirements. These forecast costs are divided by a forecast System utilisation to generate an indicative forecast Variable Charge. 12.2.3 The Variable Charge will be billed to the Users based on their share of CO2 injected and stored. 12.2.4 A Variable Charge will be calculated for both LCO₂ Handling, and Injection & Storage. 12.2.5 An additional Variable Charge may be charged to Users who deliver compressed CO2 volumes. 12.2.6 The forecast Variable Charges shall be established in real terms at the point of the Final Investment Decision (FID), however, these charges are not fixed at that level due to the variation in PassThrough Costs such as energy price. 23 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 12.3 12.3.1 Actual Cost Reconciliation On a regular basis throughout the Operating Period a process of reconciliation will take place to trueup any difference between the forecast Pass-Through Costs and the audited actual Pass-Through Costs. 13 ADDITIONAL TARIFF PREMIUM CHARGES 13.1 Purpose and Scope 13.1.1 The Capacity Allocation Code contains provisions for The Regulator to allocate domestic Users to the system and also allow System Capacity to be sold by The System Operator via Market Test Notice & Guidelines. 13.1.2 The section describes how additional premiums are added to the calculated tariffs. 13.2 Users Allocated by Regulated Allocation Process 13.2.1 The additional tariff premium charges for User’s allocated Booked Capacity via the regulated allocation process set out in the Capacity Allocation Code will be equal to Zero Euros per tonne. 13.3 Users Allocated by all Other Processes 13.3.1 The additional tariff premium charges for User’s allocated Booked Capacity via any other process set out in the Capacity Allocation Code will be greater than Zero Euros per tonne in the event that demand for storage exceeds supply and capacity allocation takes place through a competitive bidding process. 13.3.2 The additional tariff premium will be added to the respective User’s calculated Tariff Types. The value of the additional tariff premium charges are a contractual matter between the User and the System Operator. 14 TARIFF INDEXATION 14.1 Purpose and Scope 14.1.1 This Section sets out the rules and procedures for the escalation and adjustment of Tariffs calculated by this methodology. 14.2 Annual Indexation 14.2.1 The Capacity Tariffs shall be adjusted annually to reflect changes in inflation. For this purpose, inflation shall be measured by either the Greek Harmonised Index of Consumer Prices (HICP), as published by Eurostat and the Hellenic Statistical Authority (ELSTAT), or the Harmonised Index of 24 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology Consumer Prices for the European Union (EU HICP), as published by Eurostat. The selected index shall be applied consistently in accordance with the methodology set out in this regulation. 14.2.2 The System Operator will publish the adjusted Tariffs for each calendar year no later than 15 December of the preceding year, together with the values of the Reference Index used in the calculation. 14.3 Adjustment or Replacement of Indices 14.3.1 Should the Reference Index be discontinued, cease publication, or undergo substantial changes that, in the reasonable judgment of The System Operator, render it unsuitable for the purposes outlined in this Section, The System Operator shall, after consulting with The Regulator, impose an alternative index that best represents general inflation trends in Greece. 14.4 Extraordinary Adjustments 14.4.1 In the event of a material change in law, regulation, or taxation, or other extraordinary event (including but not limited to force majeure, material changes in the cost base, User default or the introduction of new regulatory requirements) that has a material impact on the costs incurred by The System Operator in providing The System service, The System Operator may request an extraordinary adjustment to the Tariffs. 14.4.2 The System Operator shall inform the Users and, where required, seek approval from the Regulator before implementing any extraordinary adjustment to the Tariffs. 14.4.3 Any extraordinary adjustment to the Tariffs shall be calculated to ensure that The System Operator is held whole for efficient, prudent costs, and that Users are not charged for costs outside the agreed scope of the Tariff methodology. 14.5 Notification and Effective Date 14.5.1 The System Operator shall notify all Users in writing of any adjustment to the Tariffs pursuant to this Section, specifying the effective date of the adjustment, which shall not be earlier than 30 days from the date of notification, unless otherwise agreed with the Users or required by law. 14.5.2 Adjusted Tariffs shall apply to all invoices issued for services provided on or after the effective date of the adjustment. 15 ENDURING POST COD TARIFF REVIEW 15.1 Purpose and Scope 15.1.1 This Section sets out the rules and procedures for the review and revision of Tariffs applicable to the use of The System during its Operating Period. 25 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 15.2 15.2.1 Tariff Review Triggered by Under-Subscription If, at any time, the aggregate booked capacity falls below the System Capacity (or any material segment thereof), The System Operator may initiate a Tariff review to ensure that the full, efficient costs of The System are recovered. 15.2.2 In such circumstances, The System Operator shall: a. notify all Users in writing of the intention to review the Tariffs; b. The System Operator shall provide details of any under-subscription, including its impact on cost recovery and any shortfalls, in a similar manner to the periodic reporting obligations set out in this methodology to The Regulator; c. 15.2.3 consult with The Regulator, on the proposed approach to Tariff revision. Any revised Tariffs resulting from a review under this paragraph shall be calculated to ensure that The System Operator is held whole for its costs, and that Users are not charged for costs outside the agreed scope of the Tariff methodology. 15.3 15.3.1 Tariff Review Triggered to Support System Capacity Expansion If The System Operator proposes or undertakes an expansion of The System Capacity, a review of Tariffs shall be initiated to assess the implications for both prospective Users and The Users. The System Operator shall first test the economic viability of a capacity expansion, considering existing Booked Capacity, technical feasibility and financial considerations. Upon confirmation of expansion economic viability, The System Operator shall calculate revised Tariffs to ensure recovery of the full, efficient costs associated with the expanded capacity. 15.3.2 Tariff calculation post-expansion shall be conducted in accordance with the principles of this document, ensuring that prospective Users are subject to Tariffs reflecting the cost of access to the expanded capacity. Any changes to Tariffs arising from a capacity expansion shall be notified to all Users in writing. The System Operator will consult with The Regulator and Users on the proposed tariff changes and provide detailed justification as part of the review process. 15.4 Extraordinary Tariff Review 15.4.1 In addition to the tariff review mechanisms outlined above, the circumstances when an extraordinary tariff review can be triggered are listed below: a. force majeure events; b. material changes in law, regulation, or taxation; c. unforeseen capital or operating costs; 26 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology d. significant changes in the regulatory or legal environment; e. forced closure of the system due external events not within the control of The System operator f. User default, or any other circumstance in which the user is unable to fulfil their financial obligations under the Storage Agreement g. any other event which materially affects the cost base or capacity utilisation, 15.4.2 The results of the Extraordinary Tariff review can, if necessary, result in the extension, revision or annulment of all related contracts if agreed by all parties and the Regulator. 15.4.3 Any request for an extraordinary review shall be made in writing, setting out the nature of the event, the impact on costs or capacity, and the proposed adjustment to the Tariffs. 15.4.4 The System Operator shall consult the Competent Authority and Regulator, prior to implementing any changes to the Tariffs as a result of an extraordinary review. 15.5 Approval and Implementation of Revised Tariffs 15.5.1 All revised Tariffs, whether resulting from under-subscription, or extraordinary review, shall be subject to approval by the Regulator, where required by law or regulation. 15.5.2 The System Operator shall notify all Users in writing of any revised Tariffs, specifying the effective date of the adjustment. 15.5.3 Revised Tariffs shall apply to all invoices issued for services provided on or after the effective date of the adjustment. 15.6 Dispute Resolution 15.6.1 Any dispute arising in connection with a Tariff review, or the implementation of revised Tariffs shall be resolved in accordance with the dispute resolution procedures set out in Law. 16 OVERCOMPENSATION MECHANISM 16.1 Purpose and Scope 16.1.1 The section sets out how overcompensation of the System Operator will be defined and how revenue would be adjusted in the event of overcompensation. 16.1.2 EU Commission document SA.108267 (2024/N) describes and accepts the mechanisms and justification for the overcompensation mechanism. This section summarises but does not replace the process and decisions made in SA.108267 (2024/N). 27 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 16.2 16.2.1 Summary of Decision The tariff framework includes a mechanism to prevent overcompensation. Above a defined return threshold, The System Operator shall pay a royalty to the State. 16.2.2 The royalty shall be calculated as a percentage (Royalty Rate) applied to the net income from operations, commencing only after the break-even point has been reached. 16.2.3 Break-even occurs when cumulative revenues exceed cumulative capital, operating, and financial expenses. 16.2.4 Royalty rates shall be set based on approved thresholds and market conditions. Once approved, these rates cannot be modified during the Operating Period. 17 BILLING, CREDIT AND PAYMENT 17.1 Purpose and Scope 17.1.1 This Section sets out the rules and procedures for invoicing, billing, financial security, payment terms, and remedies in case of default, applicable to all Users and The System Operator in respect of The System. 17.2 Invoicing and Billing Procedures 17.2.1 The System Operator shall issue invoices to each User for: a. the LCO₂ Handling Capacity Tariff and/or Injection & Storage Capacity Tariff, calculated on the basis of the User’s Booked Capacity and the applicable Tariffs in force; b. the LCO₂ Handling Variable Charge and/or Injection & Storage Variable Charge, calculated on the basis of the User’s Booked Capacity or actual usage, as applicable. 17.2.2 Invoices for capacity-based charges shall be issued monthly in advance, unless otherwise agreed in writing. 17.2.3 Invoices for Pass-Through Costs shall be issued monthly in arrears, based on actual costs incurred and allocated to each User. 17.2.4 Each invoice shall specify: a. the period to which the invoice relates; b. the calculation of charges and any applicable indexation or adjustments; c. details of Pass-Through Costs and supporting evidence as required under Section 4; 28 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology d. the due date for payment; e. the bank account details for payment. 17.2.5 Invoices shall be issued in Euro (€), unless otherwise agreed in writing. 17.3 Payment Terms 17.3.1 All invoices issued by The System Operator shall be payable by the User within thirty
(30)days of the invoice date, unless otherwise agreed in writing. 17.3.2 Payments shall be made by wire transfer in immediately available funds to the bank account specified in the invoice. 17.3.3 All payments shall be made in full, free and clear of any deduction, set-off, counterclaim, or withholding, except as required by law. 17.3.4 Late payments shall accrue interest, calculated from the due date until the date of actual payment. 17.4 Remedies in Case of Default 17.4.1 If a User fails to pay any amount due under an invoice by the due date, The System Operator may: a. draw on any financial security provided by the User to satisfy the outstanding amount; b. require the User to provide additional security; c. suspend the provision of services under the Standard Storage Agreement in accordance with its terms and conditions, after giving written notice and allowing all applicable cure periods to be exhausted; d. terminate the Standard Storage Agreement in accordance with its terms, after giving written notice and a reasonable opportunity to cure the default. 17.4.2 The exercise of any remedy under this Section shall be without prejudice to any other rights or remedies available to The System Operator under law, regulation, or contract. 17.4.3 The User shall indemnify The System Operator for all reasonable costs, expenses, and losses incurred as a result of the User’s default, including legal fees and costs of enforcement. 17.5 17.5.1 Disputed Invoices If a User disputes any amount invoiced, the User shall notify The System Operator in writing, setting out the reasons for the dispute, no later than the due date for payment. 29 Tariff Methodology Development for the Prinos CO2 Storage Draft Tariff Methodology 17.5.2 17.5.3 The User shall pay the undisputed portion of the invoice by the due date. The Parties shall use reasonable endeavours to resolve any dispute promptly and in good faith. If the dispute is not resolved within thirty
(30)days, the parties should enter a process of mediation to resolve the issue with a backstop of further 30 days of mediation before using provisions in Law to resolve the dispute. 17.5.4 Any adjustment required as a result of the resolution of a dispute shall be made by way of a credit or debit in the next invoice. 17.6 Currency, Taxes, and Withholding 17.6.1 All amounts payable under this methodology are exclusive of value added tax (VAT) or any similar tax, which shall be payable by the User in addition to the amounts due. 17.6.2 If any deduction or withholding is required by law, the User shall pay such additional amounts as are necessary to ensure that The System Operator receives the full amount due, net of any deduction or withholding. 30 ΑΚΡΙΒΕΣ ΑΝΤΙΓΡΑΦΟ Ε∆ΕΥΕΠ 12/12/2025 Α. Π.: Εισερχ. 31825 Ηµ/νία Αποστολής: 12/12/2025 Market Test Notice & Guidelines Market Test for the Reservation of Injection and Storage Capacity in the Prinos CO2 Storage Facility
  1. Introduction 1.1 Purpose This Market Test Notice & Guidelines (the Notice) establishes the rules, principles and procedures governing the Market Test to be conducted by EnEarth Greece Single Member S.A. (the Storage Operator or EnEarth) for the reservation of long-term firm injection and storage capacity that will be allocated under the Storage Agreement (the Firm Injection and Storage Capacity or Firm Capacity) in the Prinos CO₂ Storage Facility (the Facility or Project). It sets out the stages of the process, the submissions required by all interested parties, the information and documentation to be provided by the Storage Operator, and the rules applicable to evaluation, allocation and contracting capacity. This Notice has been prepared as a public process document suitable for review by the competent authorities in accordance with the applicable regulatory framework. This Notice addresses the allocation of injection and storage capacity offered for the purposes of this Market Test. 1.2 Project overview The Facility constitutes an integrated offshore CO₂ storage system, comprising: • • A marine import terminal and associated handling chain for liquid CO₂ (LCO₂), designed to receive approximately 2.8 million tonnes per annum (MTPA) from jetty to manifold; and The associated injection and geological storage system, from manifold to reservoir, configured for an aggregate injection and storage capacity of approximately 2.8 MTPA. The technical configuration is designed to provide a reliable, scalable and safe service for the reception, injection, and permanent geological storage of CO₂. Interfaces, operating parameters, and associated arrangements may be further refined as engineering and permitting activities progress, without prejudice to the core principles established in this document. 1 1.3 Strategic context The Facility is the first offshore CO₂ storage project in Greece and one of the earliest expected to become operational in the wider Mediterranean region on or before
  2. It leverages existing offshore infrastructure and proven subsurface knowledge within the Prinos concession area in Kavala, thereby reducing delivery risk and enabling an accelerated timetable for permanent geological storage. The Project supports the decarbonisation of hard-to-abate industries in Greece and neighbouring EU member states, facilitates cross-border flows of captured CO₂, and contributes to an integrated European CO₂ transport and storage network. In doing so, it aligns with European Union policy objectives for industrial decarbonisation and net-zero manufacturing. At European Union level, the Project is included in the 1st and 2nd PCI/PMI Union list and has received public financial support through the national Recovery and Resilience Facility (RRF) and the Connecting Europe Facility (CEF), underscoring its role as a regional decarbonisation hub and enabler of EU net-zero industrial objectives. These elements underpin the Facility’s ability to offer long-term storage services at scale—approximately 2.8 MTPA at full configuration—in an open, transparent and non-discriminatory basis consistent with EU law. 1.4 Legal footing The Market Test will be conducted in accordance with: • • • Directive 2009/31/EC on the geological storage of CO₂ (CCS Directive), together with any relevant EU guidance documents issued thereunder; The corresponding provisions of Greek law, applicable to the geological storage of CO₂ (CCS Law); and The applicable competition and State aid framework, including the European Commission’s State aid decision SA.108267 (2024/N) for the Facility, as may be amended from time to time. The Market Test shall be implemented in an open, transparent, and non-discriminatory manner, consistent with the principles of fair competition and equal treatment of market participants. Where applicable, the Storage Operator shall incorporate and expressly reference in the relevant stage notice any ministerial decisions or regulatory instruments relating to: • • • Third-party access (TPA); Capacity allocation methodologies; and Regulated capacity shares. 2 1.5 Process principles The Market Test will be conducted in accordance with the following key principles: • • • • • Confidentiality: All non-public information exchanged during the process shall be protected under a Confidentiality Agreement, executed with each participant prior to access to any restricted data. Integrity of Submissions: Each participant shall confirm the completeness, accuracy, and veracity of the information provided, as well as the absence of exclusion grounds (including sanctions, anti-corruption, anti-money-laundering, and competition-law infringements). Authorisation of Representatives: Each submission must be signed by a duly authorised representative, supported by corporate documentation evidencing authorisation. Openness, Transparency and Non-Discrimination: The process will feature clearly defined timelines, written clarifications, a rectification period for minor formal defects, and a complaints procedure, ensuring consistent treatment of all participants. Proportionality and Due Diligence: The Storage Operator shall perform appropriate eligibility and compliance checks, including verification of identity, ownership, and integrity criteria, proportionate to the nature of the participation, its internal policies and applicable legal requirements.
  3. Structure of the Market Test 2.1 Overview The Market Test will be conducted through two sequential stages. Participation in Stage 1 (Non-Binding) is a prerequisite for admission to Stage 2 (Binding). All dates, deadlines, and procedural requirements will be specified in the individual notice to be issued for each stage of the process. 3 Binding/ non- Stage binding Description Non- Binding
(1)
(2)Stage 1: Registration and Non‑Binding Capacity Request (open)
(3)
(4)
(5)
(6)Binding Public launch and publication of the Notification Document. Execution of Confidentiality Agreement to obtain access to non‑public materials. Submission of Registration and Non‑Binding Capacity Request (including: capturing project description, timelines, expected volumes by source, transport concept, evidence of financial standing). Submission of confirmation on truthfulness/completeness; absence of exclusion grounds) together with corporate proof of authority. Written clarifications, completeness check and short rectification period for minor defects. Outcome: announcement of admitted participants (no right to capacity granted). Stage 1:
(1)Structured Cooperation under a Joint
(2)Development Agreement Execution of the Joint Development Agreement (JDA) between the Storage Operator and each admitted participant, to facilitate structured cooperation and to enable bilateral interface alignment. The JDA does not confer capacity rights. Stage 2:
(1)Binding
(2)Allocation and Contracting
(3)(restricted stage)
(4)Publication of a Tender Notice for the binding phase. Submission and evaluation of Binding Offers/Requests for Injection and Storage Capacity. Capacity allocation and post‑award execution of Storage Agreements; failure to contract/maintain guarantees will result in forfeiture and/or reallocation of the awarded capacity. Record‑keeping/audit trail maintained by the Storage Operator; aggregated and anonymized results to be published after completion of the process. 2.2 Stage 1 — Registration and Non-Binding Capacity Request (open phase) 2.2.1 Purpose The purpose of Stage 1 is to publicly launch the Market Test, to register all interested parties, and to collect non-binding information on prospective CO₂ capture projects, their expected injection volumes, and related transportation requirements, to support structured planning and technical/commercial alignment ahead of the binding stage. 4 Participation in Stage 1 is open to all entities developing CO₂ capture or aggregation projects. A fee of 10,000 EUR is payable by each interested party wishing to participate in Stage 1. The Participation Fee is intended to cover the administrative costs of EnEarth for performing the market test and must be paid together with the submission of the Registration and NonBinding Capacity Request, according to the procedure and timeline defined in the Notification document. For the avoidance of doubt, participation in Stage 1 does not confer any right or expectation to capacity allocation. Likewise, participation in the Market Test is without prejudice to any future allocation under a regulated capacity allocation mechanism. Entities that may subsequently be awarded capacity under a regulated procedure shall remain eligible to participate in the Market Test, including the binding stage, for any additional capacity they may seek beyond the regulated allocation. This ensures that the Market Test remains accessible to all relevant market participants and enables broad engagement and transparency ahead of the allocation of Firm Injection and Storage Capacity. 2.2.2 Public announcement and Notification Document EnEarth will:
  1. a)Publicly announce the launch of Stage 1; and
  2. b)Publish a Notification Document setting out, inter alia: • • • • • • • the key characteristics of the Project, its current development status, and indicative implementation timelines; the overall timeline and step-by-step process of the Market Test; detailed instructions for participation in Stage 1 (including submission process, templates, file formats and naming conventions, opening and closing deadlines); the list of mandatory supporting documents to be submitted by interested parties; the procedure and response timeframes for handling clarification requests; the evaluation process for Stage 1 submissions and the applicable exclusion criteria; and the complaints handling procedure. The public announcement and the Notification Document will be disseminated through: (
  3. i)EnEarth’s official website; (
  4. ii)the official website of the CCS Authority; and (iii) at least one nationally or EU-wide widely-circulated medium, including energy or industry press. Publication dates, links and evidence of publication shall be recorded by EnEarth and made available to the competent authorities upon request. 5 2.2.3 Technical and commercial documentation made available in Stage 1 For orientation purposes, without establishing any right or expectation of capacity allocation, EnEarth will make the following materials available to all registered participants in a transparent and non-discriminatory manner: • • • the applicable CO₂ stream specifications, including indicative delivery pressure and temperature envelopes; the standard Joint Development Agreement; and the Heads of Terms of the Prinos CO₂ Storage Management Code. Access to the material shall be subject to execution of a Confidentiality Agreement. 2.2.4 Submissions required from interested parties Each interested party shall submit a Registration and Non-Binding Capacity Request, duly signed by an authorised representative, including at a minimum: • • • • • CO₂ capture project information, including site, process, and a brief project description; Project timeline and milestones, indicating the envisaged dates for final investment decision, construction, and commencement of CO₂ capturing; Expected CO₂ quantities by source, specifying the process type and identifying whether the emissions are biogenic, or other; Transportation requirements, including intended delivery mode (e.g. shipment of liquid CO₂) and any known interface considerations; and Evidence of financial standing, such as audited financial statements, credit rating reports, or other recognised proof of creditworthiness. 2.2.5 Mandatory supporting instruments To uphold confidentiality, integrity, and authority throughout the process, each submission shall be accompanied, inter alia, by the following mandatory instruments:
  5. a)Confidentiality Agreement, executed between EnEarth and the participant prior to access to non-public information.
  6. b)Solemn Declaration, confirming the truthfulness and completeness of the information submitted and declaring the absence of exclusion grounds (including sanctions, anti-corruption, anti-money-laundering, and competition-law infringements). Any false statement or concealment of material facts shall constitute grounds for immediate exclusion from the process and revocation of subsequent participation. 6
  7. c)Corporate Proof of Authorisation, provision of documentary evidence that the signatory is duly authorised to act for the submitting entity (e.g. corporate registry extract, board resolution, or equivalent instrument).
  8. d)Proof of payment of the participation fee. The above list of supporting instruments is indicative. The Storage Operator reserves the right to revise, amend, or supplement such instruments as appropriate. The Notification Document will specify their precise form, content, and execution requirements. Failure to submit the mandatory supporting instruments specified above, and as will further be detailed in the Notification Document, will result in the exclusion of the interested party from the process. 2.2.6 Submission mechanics All submissions shall: • Comply with the templates, formats, and file-naming conventions set out in the Notification Document; • Be delivered by the deadline specified therein; and • Reference all dates and times in Athens local time (EET), unless otherwise indicated. 2.2.7 Completeness review and outcome EnEarth will review each submission to verify completeness, accuracy, and procedural compliance. Applicants will be notified accordingly and, where appropriate, granted a short rectification period to remedy minor formal defects. For the avoidance of doubt, any material technical or financial deficiencies shall not be subject to remedy. Following completion of the review, EnEarth will issue a formal announcement of the Stage 1 outcome, identifying the entities admitted as participants, subject always to confidentiality undertakings and applicable law. Participation in Stage 1 does not create any right or expectation to capacity allocation. 2.3 Structured Cooperation under a Joint Development Agreement (restricted substage within Stage 1) 2.3.1 Purpose The purpose of this Stage 1 sub-stage is to establish a framework for structured cooperation between EnEarth and each admitted participant, through the execution of a Joint Development Agreement. 7 The Joint Development Agreement (JDA) establishes progressive, clearly demarcated steps, covering information exchange, interface alignment, eligibility and compliance confirmations, and readiness sign-off, with the objective of achieving technical and commercial alignment in preparation for the submission of a Binding Request for Capacity in Stage 2. For the avoidance of doubt, participation in the JDA sub-stage does not confer any obligation to participation in the binding stage of the Market Test nor does create any right or expectation to capacity allocation. 2.3.2 Entry into the JDA Admission to this sub-stage requires: • Successful completion of the Stage 1 completeness review; and • Execution of the Joint Development Agreement by an authorized signatory. Each Participant shall designate its Joint Development Working Group representatives and single point of contact within five
(5)business days after signature. 2.3.3 Information provided by EnEarth upon execution of the Joint Development Agreement Upon execution of the JDA, EnEarth will grant to the relevant Stage 1 participants access (through a secure data room) to the following documents and materials:
  1. Prinos CO₂ Storage Management Code, defining the operational interface, service parameters and rules;
  2. Standard Storage Agreement, namely, a draft long-term contract for Firm Injection and Storage Capacity;
  3. Prinos CO₂ Tariff Methodology (publicly available). The Tariff Methodology in section 11 includes the calculation of the LCO2 handling tariff and the injection and storage tariff. The injection and storage tariff is the reference tariff as referred to in par.2 of Article 27 of the CCS law. In section 13 of the Tariff Methodology, it is stated that a premium is added on the injection and storage tariff in case a bidding process takes place.
  4. Technical Project Documentation, namely project schedule and development milestones, engineering and operational briefs, entry envelopes, metering and scheduling concepts, and other relevant technical specifications. 2.3.4 Information provided by Participants upon execution of the Joint Development Agreement 8 Each participant shall provide at least the following information required under the Joint Development Agreement: • • • • • • • • technical data and characteristics of the CO₂ stream, including expected variability; forecast annual quantities with monthly injection profiles, proposed shipment schedule and indicative delivery windows; project schedules (Gantt) and development milestones, updated as the project evolves; permitting roadmap and status including copies of submitted/approved permits; and comments and feedback on consultation drafts shared by the Storage Operator. evidence of project maturity (including engineering studies/FEED status, permit submissions and timeline to FID/COD); evidence of financial standing and financing plan/credit support appropriate to the requested capacity and consistent with the development timeline; confirmation of compliance with confidentiality, competition law, anti-corruption, anti-money-laundering and sanctions requirements EnEarth and the JDA participants shall ensure that throughout the timeline defined in the JDA, the parties will update the documents and information exchanged as required, and at least on a quarterly basis. 2.4 Stage 2 — Binding Allocation and Contracting (restricted stage) 2.4.1 Purpose The purpose of Stage 2 is to receive and evaluate Binding Requests for Capacity and to allocate Firm Injection and Storage Capacity in accordance with Stage 2 Notice and any relevant instruments issued by the competent authorities. 2.4.2 Eligibility and admission Participation in Stage 2 is restricted to participants that have executed the Joint Development Agreement. Each participant shall submit, together with its Binding Request for Capacity, a Participation Guarantee in an acceptable form. The amount, acceptable issuers and detailed terms (including template wording) will be specified in the Stage 2 Notice. All confidentiality undertakings and competition-law compliance safeguards established in previous stages shall continue to apply in full. 2.4.3 Stage 2 Notice — information provided by the Storage Operator 9 The Stage 2 Notice, issued to eligible participants, will set out the following details in a transparent and non-discriminatory manner: a) The submission calendar (including opening/closing dates, deadlines and format requirements); b) Registration and submission instructions, including templates and communication channels; c) Firm Storage Capacity with a standard term of fifteen
(15)years and earliest start date corresponding to the Commercial Operation Date (COD) of the Facility and the corresponding LCO2 handling tariff and injection and storage tariff (pre-FID level) ;
  1. d)Participation guarantee requirements (form, minimum amount, issuer criteria, and timing for submission);
  2. e)The detailed rules for the implementation of the applicable allocation framework as defined in the Capacity Allocation Code and required by Article 27 of the CCS law.
  3. f)Annual technical injection and storage capacity on offer taking into account the injection and storage capacity in the storage permit and the portion of the capacity to be allocated through the regulated procedure as per Capacity Allocation Code.
  4. g)The post-award contracting timetable, including deadlines for signature of the Storage Agreement and delivery of contract guarantees required at contracting (form, amount basis, issuer criteria, validity and template wording to be specified in the Stage 2 Notice). 2.4.4 Submissions required from participants Each participant shall submit a Binding Request for Capacity, duly signed by an authorised representative, including at a minimum:
  5. a)The requested annual capacity (expressed in tonnes of CO₂ per year);
  6. b)The proposed start date, which shall not be earlier than the Commercial Operation Date of the Storage Facility; and
  7. c)The Participation Guarantee in the form and under the terms specified in the Stage 2 Notice. 2.4.5 Economic Viability Assessment (EVA) Following the evaluation of the Binding Requests, EnEarth will run an Economic Viability Assessment (EVA) using the LCO2 handling tariff and the injection and storage tariff 10 calculated according to section 7 of the Tariff Methodology (pre-FID) and communicated to the participants during the JDA process. The EVA considers the Net Present Value (NPV), calculated with the applicable WACC, of costs and expected revenues due to the capacity allocation in the regulated and non-regulated part of Prinos CO2 and as per the Capacity Allocation Code and the Tariff Methodology. In case that capacity requests (registered demand) are less than the capacity on offer but the EVA is non-negative, EnEarth will invite the participants to countersign the Storage Agreement in accordance with paragraph 2.4.6. In case that the EVA is negative, then EnEarth will: • • • inform the participants, and investigate whether a technical solution meeting only the registered demand could result in a non-negative EVA, and re-calculate the LCO2 handling tariff and the injection and storage tariff required to meet the capacity on offer and in parallel results to a non-negative EVA. If a non-negative EVA is identified with a link to a plausible technical solution and the new tariffs are accepted by participants, then EnEarth shall invite the participants to countersign the Storage Agreement in accordance with paragraph 2.4.6. Else, if no agreement is reached, EnEarth will declare the procedure unsuccessful, in which case no capacity is allocated and participation guarantees are returned in accordance with Stage 2 Notice. In case the new proposal is accepted by some but not all of the participants, the procedure outlined above (information, technical solution and tariff recalculation) shall need to be reapplied. 2.4.6 Outcome and next steps EnEarth shall notify the allocation results in writing to all participants. Participants awarded capacity (the Allocated Participants) will then be invited to proceed, within the timeframe specified in the Stage 2 Notice, to the execution of the Storage Agreement under the separate post-award contracting process (including the provision of the contract guarantee specified therein). Failure to execute the Storage Agreements within the prescribed period or to maintain the required guarantees may result in forfeiture of the participation guarantee, loss of allocation and re-allocation of the corresponding capacity in accordance with the published rules. 2.4.7 Record-keeping and transparency EnEarth shall maintain a complete and verifiable audit trail of all Stage 2 submissions, evaluations, and outcomes. 11 For transparency purposes, aggregated and anonymised results may be published, subject always to the confidentiality undertakings and applicable data-protection and competitionlaw requirements. 2.5 Core elements of the Storage Agreement The allocation of Firm Injection and Storage Capacity resulting from the Binding Stage of the Market Test shall be implemented through the execution of a Storage Agreement between EnEarth and the relevant participant. The Storage Agreement constitutes the overarching contractual framework governing the provision of LCO2 handling, injection and permanent geological storage services and incorporates, by reference, the applicable Prinos CO₂ Storage Management Code, which set out the uniform technical and operational rules applicable to all users of the facility. The Storage Agreement shall specify, at a minimum, the following core elements, taking also into account the Capacity Allocation Code: • • • • • • • • • • • • identification of the parties and authorised representatives; scope of services; conditions precedent and commencement of contractual obligations; starting date, ending date and duration of the contracted services (the starting date is expected to be the Commercial Operation Date of Prinos CO2); annual injection and storage capacity reserved; annual LCO2 capacity reserved and indicative number of cargoes; tariff and payment arrangements, in accordance with the applicable Tariff Methodology; financial guarantees; compliance with applicable laws, confidentiality and data protection; force majeure and change in law provisions; suspension and termination rights; and governing law and dispute resolution. 3. Publication, communications and clarifications 3.1 Publication Each stage of the Market Test shall be initiated through a public announcement, namely: • • for Stage 1, the announcement will be according to subsection 2.2.2 and for Stage 2, participants shall be informed in writing. 12 3.2 Communications All communications between participants and EnEarth shall be conducted through the official channel specified in each stage notice. The Storage Operator shall share with the competent authorities all information arising from the Market Test, in accordance with the applicable CCS law. 3.3 Clarifications Questions and requests for clarification must be submitted within the deadlines specified in the relevant Notification Document. Responses deemed to be of general interest may be shared in anonymised form with all participants, ensuring equal access to information. 3.4 Complaints Complaints shall be submitted within the deadline stated in the respective Notification and Notice Documents. EnEarth shall acknowledge receipt of each complaint and provide a reasoned written decision within a reasonable period following submission. 3.5 Data Protection All personal data processed within the context of the Market Test shall be handled in compliance with applicable data-protection legislation, including Regulation (EU) 2016/679 (GDPR) and the relevant Greek implementing legislation, as amended and in force. Stage-specific privacy information shall be provided in the respective notice. The data room and communications platform shall conform to appropriate informationsecurity standards, such as ISO/IEC 27001-equivalent controls, ensuring confidentiality, integrity, and traceability of data exchanges. 4. Participation rules 4.1 Language Submissions shall be in English or accompanied by an official English translation; the English version prevails in case of discrepancy. 4.2 Submission channel and format 13 Each stage notice shall specify the submission channel (email or secure portal), together with the applicable templates, file-format requirements, and naming conventions. Late or materially non-conforming submissions may be rejected. 4.3 Integrity and compliance Participants shall comply at all times with all applicable competition, anti-corruption, antimoney-laundering, and sanctions laws and regulations. EnEarth may conduct know-yourcustomer (KYC) and sanctions checks at any stage of the process. Any conflict of interest shall be disclosed promptly and managed in accordance with the applicable framework. Where appropriate and proportionate, the Storage Operator may require self-cleaning measures or remedial undertakings to address identified integrity concerns. Any concealment or misrepresentation of material facts constitutes grounds for exclusion from the process. 4.4 Confidentiality Access to any non-public information or materials shall require the prior execution of a Confidentiality Agreement. The Storage Operator shall implement robust informationbarrier measures to prevent unauthorised disclosure, including access controls, need-toknow restrictions, and secure communication channels for bilateral exchanges. 4.5 Amendments and exclusions EnEarth reserves the right to amend, postpone, suspend, or terminate any stage of the Market Test for legitimate reasons. EnEarth may also exclude participants for misrepresentation, breach of law or process, or failure to meet eligibility or integrity requirements, without liability towards the affected participants. Any material amendment to this process shall be communicated publicly, subject to confidentiality restrictions, and applied on a non-discriminatory basis, with appropriate adjustment of deadlines where necessary. 4.6 Governing law and jurisdiction This Notice shall be governed by and construed in accordance with Greek law. Any dispute arising out of or in connection with this Notice shall first be subject to amicable resolution between the Storage Operator and the relevant participant. In case of failure, and subject to the establishment of an independent dispute settlement committee at the Ministry of Environment and Energy according to CCS Law and applicable regulatory regime, disputes shall be finally settled by arbitration under the Rules of Arbitration of the International Chamber of Commerce (ICC). The seat of arbitration shall be Athens, Greece, 14 and the proceedings shall be conducted in English. The tribunal shall consist of three
(3)arbitrators, with each party appointing one arbitrator and the two appointed arbitrators jointly appointing the third. Failing such appointment(s) within thirty
(30)days, the ICC Court shall make the necessary appointment(s). The arbitral award shall be final and binding on both the Storage Operator and the relevant participant. 15

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