Για λόγους έγκαιρης ενημέρωσης της αγοράς, η ΡΑΑΕΥ δημοσιοποιεί τις Αποφάσεις Ε-28/2026, Ε-29/2026 και Ε-2026 με τις οποίες εγκρίθηκαν ο Κώδικας Κατανομής Χωρητικότητας, ο Κανονισμός Τιμολόγησης και ο

Article 35

of the Law 5261/2025, which allows CO2 Storage within a Pilot Storage Site by a Storage Operator and specifies the conditions for carrying out the Storage. b CO2 Storage or Storage: the injection accompanied by permanent CO2 storage in underground geological formations. c Initially Estimated Annual Storage Capacity: the estimated annual storage capacity of the Pilot Storage Site, which is based on the Storage Permit, or on studies of an independent expert (Competent Person Report – CPR) that has been approved by the CCS Competent Authority. d Initially Estimated Total Storage Capacity: the estimated total storage capacity of the Pilot Storage Site, which is based on the Storage Permit, or on studies of an independent verifier (Competent Person Report – CPR) that has been approved by the CCS Competent Authority. a Short-Term Contract: the binding contract between an Eligible User,

Article 6

, and the Storage Operator, with which any additional capacity of the Pilot Storage Site is allocated, as per the Article 6 par.1 of the present Code, and whose minimum content is defined in Article 9 of the present Code. b Potential User of the Pilot Storage Site or Potential User: the natural or legal person requesting access to the Pilot Storage Site for Storage of quantities of CO2 resulting from capture, until the final assessment of their eligibility,

Article 4, Article 5, and Article 6 of the present Code.

Specifically for the case of regulated access, Potential User is defined as natural or legal person whose each installation or installations, for the CO2 emissions of which access is requested, has resulted in annual verified emissions greater than or equal to 150,000 tonnes of CO2 on average over the years 2022 – 2023 – 2024, as confirmed by the registry of the European Emissions Trading System. c National Energy and Climate Plan (NECP): the revised NECP, as ratified by Decision No. 3/2024 of the Government Economic Policy Council (Government Gazette 6983/Β/19-12-2024), as applicable. d Eligible User: the Potential User who is assessed as eligible for access to the Pilot Storage Site, either in a regulated manner, according to the criteria set out in Article 4, or through public international competitive procedures,

Article 5and in the decisions in par. 3 of Article 27 of the Law, or through Short

Term Contracts,

Article 6

, and for which the signing of the Access Contract with the Storage Operator is pending. e Annual Emissions Report: the annual report prepared and submitted by each obligated company whose activities fall within the scope of Directive 2003/87/EC, within the framework of the Emissions Trading System, in which the annual emissions resulting from the operation of each of its installations are recorded, and which is validated by an accredited verifier,

Directive 2003/87/EC and the Implementing Regulation (EU) 2018/

1. f CO2 Pilot Storage Site Tariff Regulation: the administrative act of RAAEY regulating issues related to the pricing of the Pilot CO2 Storage Site, in accordance with Article 40 par. 40 sub. c of Law 5261/
2. g Competent Person Report (CPR): the study prepared by an independent certified verifier with sufficient and appropriate experience, and which constitutes an independent, technical and documented assessment of the Initially Estimated Total Storage Capacity and the Initially Estimated Annual Storage Capacity, based on digital simulation of the behavior of the underground reservoir of the Pilot Storage Site and stochastic probability analysis. h New Storage Capacity: any capacity that arises in addition to the Initially Estimated Annual Storage Capacity as a result of new investments, additional to the initial investment plan for the construction and operation of the Pilot Storage Site, and as documented by studies of an independent verifier, which have been approved by the CCS Competent Authority. i Law: the Law 5261/2025 (Government Gazette 231/A/12.12.2025) regarding "Arrangements for the capture, use, transport and storage of carbon dioxide Integration 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 amending Council Directive 85/337/EEC, 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)" j Injection Period: the duration of CO2 injection into the Pilot Storage Site, including a ramp-up period, during which the Initially Estimated Annual Storage Capacity is made available to the market by the Storage Operator for booking by Potential Users. k Pilot Storage Site: the Storage Site in Prinos, for which a procedure for issuing a Storage Permit is in progress or has been completed pursuant to article 173 of Law 4964/2022 (Government Gazette A' 150), on the Storage of carbon dioxide by entities holding a right or permit to explore and exploit hydrocarbons. l Access Contract: the binding contract concluded by the Storage Operator with the Eligible Users which imprints the capacity of the Pilot Storage Site allocated to the latter ones, in accordance with the procedures described in Article 4, the Article 5and the Article
3. m Transfer Contract: the binding contract between a User of the Pilot Storage Site who has concluded an Access Contract, and a new Eligible User or existing User, by which the capacity provided for in the Access Contract is transferred in part or in full. n Regulated Access Contract: the binding contract between an Eligible User,

Article 4

, and the Storage Operator, which indicates the capacity of the Pilot Storage Site allocated, in accordance with the provisions of Article 4 par.1 of the present Code, the minimum content of which is defined in Article 9 of the present Code. o Access Contract through public international competitive procedures: the binding contract between an Eligible User and the Storage Operator, which indicates the capacity of the Pilot Storage Site allocated, as per Article 5 par.1 of the present Code, the minimum content of which is defined in Article 9 of the present Code. p Emissions Trading System (ETS): the European Union's system for limiting and trading greenhouse gas emission allowances, which operates according to the “cap-and-trade” system, setting a maximum limit on total emissions and allowing the issuance, transfer, return and cancellation of emission rights,

Ministerial Decision no. ΥΠΕΝ/ΔΚΑΠΑ/86227/2245/2024 (Government Gazette 4674/B’ 09.08.2024), as amended and in force. q Storage Operator: the natural or legal person who holds a Storage Permit and operates the CO2 Pilot Storage Site in Prinos. r Pilot Storage Site User or User: the Eligible User who has entered into an Access Contract with the Storage Operator

Article 4, Article 5 and Article 6 of the present Code.

Article 3 Access to the Storage Site 1 Potential Users' access to the Pilot Storage Site is carried out based on the principles of non-discrimination, transparency and fair and open access. 2 Potential Users' access to the Pilot Storage Site is carried out at a percentage of the Initially Estimated Annual Storage Capacity in a regulated manner, and at a percentage of the Initially Estimated Annual Storage Capacity through public international competitive procedures, in accordance with Article 27 of the Law and the provisions of Article 4 and the Article 5 of the present Code. 3 The Initially Estimated Total Storage Capacity of the Pilot Storage Site, is a value chosen by the Storage Operator between P50 and P75 of the total capacity of the Pilot Storage Site, according to a digital simulation of the behavior of the underground reservoir of the Pilot Storage Site and a stochastic probability analysis, as provided in par. 5 of this Article. 4 The Initially Estimated Annual Storage Capacity of the Pilot Storage Site, which is approved by the CCS Competent Authority, is calculated as the annual storage capacity, which results from the optimal utilization of the Initially Estimated Total Storage Capacity during the operation of the Pilot Storage Site, taking into account all the following relevant operational constraints: a Injection wells (Injectors): 5 ≤ Injection wells ≤ 8 b Water production wells (Producers): 8 ≤ Water production wells ≤ 10 c CO2 production: ≤ 1.0 % of the total injected CO2 quantity d Total oil production (as a by-product of water production): ≤ 1 million barrels during the total operating period of the Pilot Storage Site e Average daily oil production (as a by-product of water production): ≤ 200 barrels/day calculated over a period of 5 consecutive years f Injection Period for at least 15 (fifteen) years. 5 The Initially Estimated Total Storage Capacity and the Initially Estimated Annual Storage Capacity are certified by a signed Competent Person Report (CPR), which is submitted by the Storage Operator to the CCS Competent Authority for approval no later than 60 (sixty) calendar days from the issuance of this Code. The Storage Operator shall submit to the CCS Competent Authority a revised CPR study within 3 (three) months from the completion of the first drilling of the Pilot Storage Site, and in any case, the revised CPR study should be submitted before the capacity allocation procedures described in Article 4, par. 4 and Article 5, par. 2, sub. b hereof, and thereafter upon the Storage Operator's initiative or a relevant request from the CCS Competent Authority for the submission of a revised CPR study, provided that the available data regarding the operation of the reservoir indicate so. The CCS Competent Authority may assign the assessment of the CPR study to an independent expert with relevant experience in such studies, especially in cases of questioning the results of the study in question. In this case, the decision of the independent expert is binding. 6 The Initially Estimated Annual Storage Capacity is made available in its entirety by the Storage Operator for booking by Potential Users for a period of at least fifteen

Article 6hereof and Article 27 par.

2 bb of the Law. The relevant tariffs are formed as provided for in the CO2 Pilot Storage Site Tariff Regulation. The increase in storage capacity in accordance with the provisions of this paragraph may not affect the tariffs allocated to existing Users, in accordance with the provisions of par. 6 of this Article. 8 The New Storage Capacity (beyond the Initially Estimated Annual Storage Capacity and any additional storage capacity as per par. 7) that may arise as a result of new investments, additional to the initial investment plan for the construction and operation of the Pilot Storage Site, is made available by the Storage Operator to Potential Users through additional public international competitive procedures implemented via market test,

Article 5par.

2hereof. The relevant tariffs are set as provided for in the CO2 Pilot Storage Site Tariff Regulation. The increase in storage capacity in accordance with the provisions of this paragraph may not affect the tariffs allocated to existing Users, in accordance with the provisions of par. 6 of this Article, in a way that would make the Users worse off compared to the situation prior to the New Storage Capacity. 9 Natural or legal persons that produce emissions resulting from economic activities that do not comply with the Do No Significant Harm (DNSH) principle,

Regulation (EU) 2019/2088 and Regulation (EU) 2020/852, may not occupy capacity, as derived from the regulated and non-regulated parts, cumulatively greater than N1 MTPA capacity, where N is the Initially Estimated Annual Storage Capacity. For the assessment of this criterion, Potential Users submit a report to the CCS Competent Authority regarding compliance with the Do No Significant Harm principle which is assessed for its correctness, both for access in a regulated manner and for access through public international competitive procedures. The CCS Competent Authority shall approve or reject the said report and the result on compliance or noncompliance with the Do No Significant Harm Principle, with justification. In case of rejection, the CCS Competent Authority may request its re-submission by the respective Potential User within a specific deadline. 10 The part of the Initially Estimated Annual Storage Capacity which may not be occupied by natural or legal persons producing emissions originating from economic activities that do not comply with the principle of Do No Significant Harm, according to the provisions of par.9, that is 1 MTPA, is distributed in proportion to the percentages mentioned in Article 4 par.1 to the regulated access and Article 5 par.1 to access through a public international competitive process and is taken into account in any capacity allocation procedures. Article 4 Regulated Access 1 Potential Users' access to the Pilot Storage Site is carried out at a capacity equal to 50% (fifty percent) of the Initially Estimated Annual Storage Capacity of the Pilot Storage Site in a regulated manner. 2 Regulated access is carried out with equal capacity allocation to Eligible Users until the exhaustion of the available quantity of par.1, subject to the provisions set out in Article 3 par.9 and

1. 3 Regulated access to the Pilot Storage Site is available to natural or legal persons whose the relevant installation or each of the relevant installations has led to annual verified emissions greater than or equal to 150,000 tonnes of CO2 on average over the years 2022 – 2023 – 2024, as published in the registry of the European Emissions Trading System (EU ETS). 4 In order to determine the Eligible Users, the CCS Competent Authority issues an open call for expressions of interest, which specifies the exact duration of the Regulated Access Contract, and the required supporting documents to be submitted by the interested Potential Users, and which include at least the elements specified in Annex I of this Code, on the basis of which the interested Potential Users are evaluated as to their eligibility, based on at least the criteria of par.
2. The quantity of the Initially Estimated Annual Storage Capacity to be allocated is based on the most recent CPR study, as it has been accepted by the CCS Competent Authority, based on the provisions of Article 3 par. 5 of the current Code, and in any case before the capacity allocation procedures described in Article 4, par. 4 and Article 5, par. 2, sub. b hereof. 5 Within the framework of the procedure of par.4, when expressing interest, the interested Potential Users also apply for the requested annual quantity of CO2 for injection and permanent Storage, which cannot exceed the average of the verified emissions of the last three years of the facility for the emissions of which the interest in Storage is expressed, as published in the registry of the European Emissions Trading System (ETS – EU ETS). 6 After completing the procedure of par. 4 hereof, the Eligible Users must sign a Joint Development Agreement (JDA) with the Storage Operator, with the aim of creating a framework for structured cooperation and information exchange. The content of the JDA is proposed by the Storage Operator and approved by the RAAEY upon issuance of a relevant opinion by the Competent CCS Authority in the context of the procedure of the non-binding phase of the public tender procedure pursuant to Article 5 and in accordance with the provisions of the guidelines of subpar. ba) of par. b) of par. 2 of article 27 of the Law. 7 The eligibility of Potential Users of par.3 for access to the percentage of the Initially Estimated Annual Storage Capacity allocated in a regulated manner is evaluated by the CCS Competent Authority based on the following criteria, which must be met cumulatively and which may be further specified in the relevant invitation: a The Potential User must have a CO2 capture project under design, with the ability of completion and commencement of commercial operation by December 31, 2030, b The planned CO2 capture projects must have a positive contribution to the national target of reducing greenhouse gas emissions produced within the Greek territory, as set out in the approved National Energy and Climate Plan (NECP), c A high level of financial solvency, which will be proven at least by providing a financial guarantee,

Annex I. 8 If, during the evaluation of the Potential Users, the quantity resulting from the equal distribution of the quantity of par.1 and corresponds to each Eligible User, exceeds the amount of storage capacity requested by each Eligible User in the context of the expression of interest of par.4, the difference is redistributed equally to the remaining Eligible Users. This process is repeated until the quantity of par.1 allocated per Eligible User is not be greater than that requested by each Eligible User. 9 Following completion of the evaluation of the submitted data of the interested Potential Users and the determination of the Eligible Users for access to the capacity allocated in a regulated manner, the CCS Competent Authority issues a decision and publishes the results of the evaluation and capacity allocation on its website. 10 After the evaluation process of the interested Potential Users has been completed, the Eligible Users must, within 30 days of their notification, provide a letter of guarantee from a credit institution operating in a member state of the EU or a member state of the European Economic Area, and whose credit rating is at least BBBor equivalent from a recognized rating agency (S&P, Moody's or Fitch). The letter of guarantee must be valid until the signing of the final Access Contracts with the Storage Operator and will be calculated based on the following mathematical formula: allocated quantity according to par.8 * duration of Regulated Access Contract * 50 €/tonne CO2 * 5% In the casethe final Regulated Access Contract with the Storage Operator is not signed, due to the fault of the Eligible User, the said letter of guarantee will be forfeited in favor of the Greek State and the quantity released will be redistributed equally to the remaining Eligible Users. 11 The Storage Operator concludes Regulated Access Contract with each Eligible User, according to the provisions of Article 9 of this Code. Regulated Access Contracts must be signed up to 30 days after the completion of the public international competitive procedure. If the deadline expires due to the fault of the Eligible User, the capacity is reallocated to the remaining Eligible Users. 12 The duration of the Regulated Access Contract is at least fifteen years (15 years). 13 Within the framework of the Regulated Access Contract, Eligible Users must pay a financial guarantee, in accordance with the provisions of Article 10 of the present Code. 14 The rights and obligations arising from the Regulated Access Contracts may be transferred,

Article 27par.

2 sub. a of the Law and

Article 7of this Code.

15 The reference price of the Regulated Access Contracts is determined at the stage before the final investment decision (pre-FID) is taken by the Storage Operator,

Section 7

of the CO2 Pilot Storage Site Tariff Regulation, and is communicated to Potential Users by RAAEY’s decision approving the regulatory documents of the market test,

Article 27par.

3 of the Law. 16 In the event of non-utilization of the reserved capacity through the Regulated Access Contract by a User, the unused capacity returns to the Storage Operator, who owes to make the necessary efforts to reallocate it to other Users, existing or Potential and Eligible ones. If the unused capacity is not reallocated or is partially reallocated, a mandatory injection penalty clause (store-or-pay) is activated. The details of the application of this paragraph are specified in the Storage Site Management Code. Article 5 Access through public international competitive procedures 1 Potential Users' access to the Pilot Storage Site is carried out at a rate of 50% (fifty percent) of the Initially Estimated Annual Storage Capacity of the Pilot Storage Site through auction via a public international tender. 2 The auction of the quantity referred to in par.1 of this Article, is implemented by the Storage Operator through a market test, which is carried out in two phases: a Phase of non-binding expression of interest b Phase of submission of binding offers 3 The details and terms of the market test, as well as the evaluation criteria of the Eligible Users for access through the market test, as well as any other procedural details for conducting the tender are defined in the guidelines of the market test and the other regulatory documents of the market test (such as in particular announcements and notices) that are approved by RAAEY, upon recommendation of the CCS Competent Authority and after taking into account the views of the Storage Operator. 4 The quantity of the Initially Estimated Annual Storage Capacity to be allocated through auction will be based on the most recent CPR study, as it has been accepted by the CCS Competent Authority, based on the provisions of Article 3 par. 5 of the current Code, and in any case before the capacity allocation procedures described in Article 4, par. 4 and Article 5, par. 2, sub. b hereof 5 The duration of the Access Contract through public international competitive procedures is at least five years (5 years). 6 The rights and obligations arising from the Access Contracts through public international competitive procedures may be transferred,

Article 27par.

2 sub. ba of the Law and

Article 7of this Code.

7 On the date of the signing of the Access Contract through public international competitive procedures, Users must submit to the Storage Operator a financial guarantee, in accordance with the provisions of Article 10 of the present Code. 8 In the event of non-utilization of the reserved capacity through the Access Contract through public international competitive procedures by a User, the unused capacity returns to the Storage Operator, who shall make the necessary efforts to reallocate it to other Users, existing or Potential and Eligible ones. If the unused capacity is not reallocated or is partially reallocated, a mandatory injection penalty clause (store-orpay) is activated. The deadline within which the User declares that he does not intend to use the reserved capacity, the deadline within which the Storage Operator makes the capacity available again, as well as any other details are specified in the Storage Site Management Code. 9 Upon completion of the provision of the Initially Estimated Annual Storage Capacity in a regulated manner and through a public international tender in accordance with Article 4 and par.1 of this Article respectively, any unallocated capacity may be made available by the Storage Operator through additional public international tenders until the Initial Estimated Annual Storage Capacity is exhausted. Article 6 Access through Short-Term Contracts 1 In the event that additional storage capacity according to Article 3 par. 7 arises, the Storage Operator shall make available the additional storage capacity, through ShortTerm Contracts. 2 The conclusion of Short-Term Contracts is based on the 5-year rolling injection program prepared by the Storage Operator at the beginning of each year. 3 For the conclusion of Short-Term Contracts, the Storage Operator issues an open international invitation published on its website,

Article 27par.2, sub.bb of the Law.

The terms of participation, the criteria and the procedure for Potential Users of Short-Term Access will be defined within the invitation, which is approved by RAAEY. 4 Upon acceptance of the respective offer by the Storage Operator, the Short-Term Contract is concluded between the Storage Operator and the interested User, which shall not have a duration exceeding 5 years and to which the exact amount and type of the financial guarantee for the period of validity of the Short-Term Contract is defined, as per Article 10 of the present Code. 5 The rights and obligation arising from Short-Term Contracts may be transferred,

Article 7of this Code.

Article 7 Transfer 1 A User may transfer, in part or in full, rights and obligations deriving from an Access Contract concluded with the Storage Operator, in accordance with the terms of this Article and those set out in Article 4, Article 5 and Article

1. 2 The transfer is permitted provided that the following conditions apply cumulatively: a The safe and uninterrupted operation of the Storage Site is not hindered, b In the case of transfer of capacity under a Regulated Access Contract, the eligibility of the new holder of the capacity being transferred has been examined and confirmed, in accordance with the provisions of par. 6 hereof, no later than 30 days before the final transfer, c The duration and the quantity of the transferred capacity do not exceed the specified duration and quantity of the Access Contract being transferred, and d A written consent of the Storage Operator is provided for the transfer of capacity of the Access Contract through public international competitive procedures and the Short-Term Contract, as well as confirmation of the eligibility of the new holder by the CCS Competent Authority in the case of transfer of capacity of a Regulated Access Contract in accordance with par. 6 hereof. In order to provide the consent, the Storage Operator examines compliance with sub-cases a and c, as well as the financial solvency of the new candidate holder based on the ability to submit a financial guarantee for the respective capacity to be transferred to it, in accordance with Article 10 par. 5 hereof, and any other elements of financial solvency that were taken into account when concluding the initial Access Contract that is being transferred. 3 A Transfer Contract shall be concluded between the holder of the capacity being transferred and the new holder in accordance with the provisions of Article
2. A nonconfidential version of the Transfer Contract shall be attached to the original Access Contract and shall constitute an integral part thereof. 4 Without prejudice to the provisions of par. 5 of this Article, the transfer of capacity under an Access Contract before the expiry of 5 (five) years from the commercial operation date (COD) of the Pilot Storage Site is permitted provided that it does not result to the acquisition of direct financial benefit for the initial capacity holder. To verify the condition of the previous paragraph, the full, confidential version of the Transfer Contract is transmitted to RAAEY. 5 Storage capacity under a Regulated Access Contract may not be transferred before 18 months have passed since the commercial operation date (COD) of the Pilot Storage Site. 6 In the case of transfer of capacity of a Regulated Access Contract, before the finalization of the transfer, no later than 30 days before the transfer, the initial holder of the capacity being transferred shall submit to the CCS Competent Authority the necessary supporting documents for the assessment of eligibility of the new prospective holder, as specified in Article 4 par.
3. The supporting documents to be submitted include at least those specified in Annex I of the present Code. The Competent CCS Authority may request additional information and supporting documents. The approval or rejection of the transfer application must be issued by the CCS Competent Authority within 10 days from the sending of the documentation listed in Annex I or the additional elements of the previous quotation. In case of rejection of the request for transfer of capacity of a Regulated Access Contract by the CCS Competent Authority, the latter shall provide a reasoned opinion of the rejection. 7 The new holder replaces the initial User in the obligations towards the Storage Operator for the part of the capacity transferred to them. In particular, regarding the financial guarantee, Article 10 par. 5 of this Code shall apply. 8 The validity of the Transfer Contract begins from the date of its notification to the Storage Operator and completion of the procedure for complying with the conditions of par.
4. Article 8 Access Contracts 1 For the access of the Users to the Pilot Storage Site and the provision of Storage services, the signing of an Access Contract between the Storage Operator and each User is required, which stipulates the rights and obligations of the parties as well as the allocated annual capacity to be stored and the agreed unit price. 2 The Access Contract is drawn up in writing, in accordance with the standard Access Contract that is approved by RAAEY as an Annex of the Storage Site Management Code. The minimum content of the Access Contract is defined in Article 9 of the present Code. Article 9 1 Minimum content of Access Contracts The Access Contract specifies, at a minimum, the following: a Name, VAT number and legal form of the User with whom the Access Contract is concluded. b The services offered within the framework of the Access Contract. c The capacity of the Pilot Storage Site, expressed in tonnes of CO2/year, committed by the User. d The effective date and duration of the Access Contract. e The price of the access service to the Pilot Storage Site, expressed in €/tonne CO
5. f The rights and obligations of the Storage Operator of the Pilot Storage Site and the User. g The limits of the contractual liability of the parties. h The formula and methodology for calculating the financial guarantee, in accordance with the provisions of Article 10 of the present Code. i The process of invoicing by the Storage Operator and payment by the User. j Cases of force majeure, termination or cancellation of the Access Contract. k The dispute resolution process and the applicable law. l The process of amending the Access Contract and adjusting its terms. m The terms and conditions of transfer of the Access Contract. 2 The Transfer Contract the following should be specified at a minimum: a Initial Contract details, that is at minimum the Contract number, the date of its conclusion, and the type of Contract (Regulated Access Contract, Access Contract through public international competitive procedures or Short-term Access Contract). b The amount of capacity of the initial Contract transferred to the new holder through the Transfer Contract expressed in tonnes of CO2/year and the agreed contractual duration. c The financial price of the transfer and the method of payment thereof by the new holder of the Contract to the initial holder thereof (confidential term). d The process of issuing a relevant storage certificate, in accordance with Article 17 par. 3 of the Law, of the quantity of capacity that was transferred and ultimately utilized for CO2 Storage by the new owner. Article 10 Financial Guarantee 1 The type of financial guarantee required to be submitted to the Storage Operator,

Article 9

, regardless of the type of Access to the Pilot Storage Site, takes the form of a letter of guarantee issued by a credit institution operating in a member state of the EU or in a member state of the European Economic Area, and whose credit rating is at least BBB- or equivalent from a recognized rating agency (S&P, Moody's or Fitch). 2 In the event that the credit institution issuing the letter of guarantee fails to maintain the acceptable level of credit rating after issuance and until the end of its validity, within ten days from the occurrence of the case, the User must secure an equal guarantee to replace the existing one from a credit institution that meets the criteria of par.1 of this Article. In the event that the replacement of the letter of guarantee within the specified timeframe is not possible, the User must deposit an equivalent amount of cash collateral until the said guarantee is replaced, in accordance with the provisions of par.1 of this Article. 3 For Regulated Access Contracts and Access Contracts through public international competitive procedures, in accordance with the provisions of Article 9 of this Code, the unit price of the financial guarantee and any additional terms that may apply to it, are defined in the aforementioned Contracts. 4 For participation in the selection procedures for access to the Pilot Storage Site, a financial guarantee is deposited which: (

1. i)for regulated access is specified in Article 4, par. 4 of this Code, (
2. ii)for public international tenders is specified in the guidelines of par. 3 of Αrticle 27 of the Law and (iii) for the open international invitation for the conclusion of Short-term Contracts is set at €2/tonne CO2. 5 In the event of a transfer of capacity pursuant to Article 7, the financial guarantee of the original User is reduced by the part corresponding to the transferred capacity and the new holder deposits a respective financial guarantee corresponding to the transferred capacity. Article 11 1 Final Provisions After the completion of the non-binding phase of the market test, the percentages of allocation of the Initially Estimated Annual Storage Capacity of the Pilot Storage Site, which are allocated through Regulated Access (Article 4, par. 1 hereof) and through Public International Competitive Procedures (Article 5, par. 1 hereof), may be modified, based on the actual data and in particular the most recent CPR study that has been accepted by the CCS Competent Authority and the interest that has been expressed for regulated access and access through the competitive procedure. Article 12 Dispute Resolution 1 In order to resolve any dispute arising from the application of the provisions of this Code, the parties shall make reasonable efforts to resolve it promptly and in good faith. 2 In cases of disputes regarding the access procedure and the access conditions provided for in this Code, the party raising the dispute shall send a notice of dispute to the other party in which it adequately and reasonably describes the subject of the dispute. 3 If it is not possible to resolve the said dispute through bilateral agreement within 30 (thirty) calendar days from the service of the notice of dispute, the contracting parties shall address to the Settlement Committee for Access to Transmission Networks and CO₂ Storage Sites (Settlement Committee) established at RAAEY,

Article 28of the Law.

4 If a compromise is not possible through the Settlement Committee, the latter issues a conclusion with its assessment of the case, and the parties may either resort to RAAEY through arbitration, in accordance with the provisions of Article 37 of Law 4001/2011 and RAAEY’s Arbitration Regulation, or resort to the Courts. The conclusion of the Settlement Committee is taken into account and evaluated freely. 5 The Courts of Athens are designated as exclusively competent for the resolution of any dispute arising from the application of the provisions of this Code. Annex I Minimum Supporting Documents for the consideration of eligibility for regulated access 1 When Potential Users express interest in regulated access, the following documents shall be submitted in order to assess the eligibility criteria defined in Article 4 par.

1. a A Report assessing the compliance with the principle of Do No Significant Harm. b Annual Emissions Reports for the last three years validated by an accredited verifier, as submitted by the Potential User within the framework of the ETS and confirmed by the ETS registry. c A detailed business plan for the capture project, which includes, among other things, a detailed implementation schedule for the project, which indicates the ability to complete the CO2 capture project and starting its commercial operation by December 31,
2. d A technical report signed by an independent expert describing clearly and in detail the estimated annual amount of CO2 to be captured. e Offers or equipment supply contracts accompanied by technical brochures of the selected CO2 capture equipment, which clearly describe the technical characteristics and annual CO2 capture capacity of the equipment, as well as a detailed delivery schedule for the equipment. f Proof of legal seat/location of facilities where the capture equipment will be placed (e.g. GEMI Certificate). g Financial participation guarantee, amounting to €30,000, by a credit institution operating in a member state of the EU or in a member state of the European Economic Area, and whose credit rating is at least BBB- or equivalent from a recognized rating agency (S&P, Moody's or Fitch), valid from the submission of the expression of interest by the interested Potential Users until the date of presentation of the letter of guarantee specified in Article 4 par.10 for Eligible Users, or until the date of completion of the evaluation process of interested users and notification of ineligibility for ultimately ineligible Users. Πειραιώς 132 118 54 Αθήνα Τηλ.: 210-3727400 E-mail: info@raaey.gr Web: www.raaey.gr ΑΠΟΦΑΣΗ ΤΟΥ ΚΛΑΔΟΥ ΕΝΕΡΓΕΙΑΣ ΤΗΣ ΡΑΑΕΥ ΥΠ’ ΑΡΙΘΜ. Ε-29/2025 Κανονισμός Τιμολόγησης του Πιλοτικού Τόπου Αποθήκευσης διοξειδίου του άνθρακα του Πρίνου σύμφωνα με το άρθρο 40 παρ. 10 περ. (γ) του ν. 5261/2025 Ο Κλάδος Ενέργειας της Ρυθμιστικής Αρχής Αποβλήτων, Ενέργειας και Υδάτων Κατά την τακτική συνεδρίαση της Σύνθεσης του Κλάδου, στην έδρα της Αρχής, την 12η Φεβρουαρίου 2026, και Λαμβάνοντας υπόψη:
3. Το ν. 4001/2011 «Για τη λειτουργία Ενεργειακών Αγορών Ηλεκτρισμού και Φυσικού Αερίου, για Έρευνα, Παραγωγή και δίκτυα μεταφοράς Υδρογονανθράκων και άλλες ρυθμίσεις.» (ΦΕΚ Α’ 179/22.08.2011), όπως ισχύει.
4. Το ν. 5037/2023 «Μετονομασία της Ρυθμιστικής Αρχής Ενέργειας σε Ρυθμιστική Αρχή Αποβλήτων, Ενέργειας και Υδάτων και διεύρυνση του αντικειμένου της με αρμοδιότητες επί των υπηρεσιών ύδατος και της διαχείρισης αστικών αποβλήτων, ενίσχυση της υδατικής πολιτικής - Εκσυγχρονισμός της νομοθεσίας για τη χρήση και παραγωγή ηλεκτρικής ενέργειας από ανανεώσιμες πηγές μέσω της ενσωμάτωσης των Οδηγιών ΕΕ 2018/2001 και 2019/944 - Ειδικότερες διατάξεις για τις ανανεώσιμες πηγές ενέργειες και την προστασία του περιβάλλοντος» (Α΄ 78), και ιδίως τα άρθρα 1-23 του νόμου αυτού.
5. Την Οδηγία 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) αριθ. 1013/2006
6. Τις διατάξεις του ν.5261/2025 (ΦΕΚ Α’ 231/12.12.2025) «Ρυθμίσεις για τη δέσμευση, χρήση, μεταφορά και αποθήκευση διοξειδίου του άνθρακα - Ενσωμάτωση της Οδηγίας 2009/31/ΕΚ του Ευρωπαϊκού 1 Κοινοβουλίου και του Συμβουλίου της 23ης Απριλίου 2009 σχετικά με την αποθήκευση διοξειδίου του άνθρακα σε γεωλογικούς σχηματισμούς … » (εφεξής, ο «Νόμος») και ιδίως τα άρθρα 27, 35 και
8. Τις διατάξεις του άρθρου 173 του ν. 4964/2022 «Διατάξεις για την απλοποίηση της περιβαλλοντικής αδειοδότησης, θέσπιση πλαισίου για την ανάπτυξη των Υπεράκτιων Αιολικών Πάρκων, την αντιμετώπιση της ενεργειακής κρίσης, την προστασία του περιβάλλοντος και λοιπές διατάξεις.» (ΦΕΚ Α’ 150/2022).
9. Την υπ’ αριθ. πρωτ. ΕΔΕΥΕΠ 22781/01.07.2024 αίτηση της εταιρείας EnEarth Greece Μονοπρόσωπη Α.Ε. (εφεξής EnEarth) προς την Ελληνική Διαχειριστική Εταιρεία Υδρογονανθράκων και Ενεργειακών Πόρων Α.Ε. (ΕΔΕΥΕΠ) για χορήγηση Άδειας Αποθήκευσης για τον Πιλοτικό Τόπο Αποθήκευσης CO2 στον Πρίνο.
10. Την υπ’ αριθ. πρωτ. ΥΠΕΝ/ΔΙΠΑ/97416/6779/07.11.2025 Άδεια Έγκρισης Περιβαλλοντικών Επιπτώσεων (ΑΕΠΟ) του Έργου: Μονάδα Αποθήκευσης CO2 στον Πρίνο (ΑΔΑ: Ρ3I74653Π8-ΤΙ6).
11. Την εγκριτική απόφαση της Ευρωπαϊκής Επιτροπής C