The applicability of Article 19 is not determined by the type or legal form of the company, but by the specific installation or activity and its environmental classification.
An installation falls under Article 19 when all of the following conditions are met:
✓ It is classified under environmental category A1 or A2 and holds an Environmental Approval Decision (AEPO).
✓ Its main activity falls under one of Groups 4, 6, 7, 8 or 9 of the environmental classification.
✓ It is not covered by the European Union Emissions Trading System (EU ETS).

The main categories of activities subject to Article 19 include:
Group 4 – Environmental infrastructure: waste management facilities, landfills, waste management facilities, recycling and composting units, wastewater treatment plants and biological treatment facilities, as well as sludge management facilities.
Group 6 – Tourism, buildings, urban development, sports and recreation: large hotels and tourist resorts, campsites, hospitals, clinics, educational complexes, shopping centres, large supermarkets, sports and cultural centres, theatres, museums and recreational facilities.
Group 7 – Livestock and poultry farming facilities: large pig farms, poultry farms, cattle farms, sheep and goat farms, as well as other organised animal-breeding facilities.
Group 8 – Aquaculture: fish farms, mussel farms, land-based aquaculture units, fish hatcheries and other facilities for the production of aquatic organisms.
Group 9 – Industrial and manufacturing facilities: food and beverage industries, slaughterhouses, dairy industries, cheese-making facilities, textile industries, wood and paper industries, chemical industries, production of plastics, metals, construction materials, concrete, machinery and batteries, as well as desalination facilities and fuel or chemical storage facilities.

Applicability under Article 20 is assessed at the level of the legal entity and its tax identification number.
Among others, Article 20 applies to:
• listed public limited companies, namely sociétés anonymes whose shares or other transferable securities are listed on a regulated market in Greece;
• credit institutions, including banks and cooperative banks;
• insurance companies, excluding individual insurance agents or brokers;
• licensed investment firms, such as investment services companies;
• fixed and mobile telecommunications providers;
• water supply and wastewater companies, such as EYDAP, EYATH and Municipal Water and Sewerage Companies (DEYAs), provided that they do not fall under the small enterprise exemption;
• courier and express delivery companies;
• electricity and natural gas supply companies, namely companies supplying energy or natural gas to customers;
• retail chains with more than 500 employees, including large supermarket, clothing, electrical goods, cosmetics and home goods chains;
• logistics and third-party logistics (3PL) companies providing at least one of the following services to third parties: transport, freight forwarding or storage;
• urban public transport companies, including bus, metro, tram and other urban transport operators.

• Submission of an application and review of competence, capacity and impartiality.
• Confirmation of the applicable verification scope and conclusion of an agreement.
• Review of the emissions report, methodology, calculations and supporting evidence.
• Risk assessment, sample-based data review, and on-site and remote verification activities.
• Communication and assessment of findings.
• Independent review and issuance of the Verification Statement.

COSMOCERT S.A., a member of the FoodChain ID Group, is an accredited Validation and Verification Body, holding Accreditation Certificate No. 1401-01, and a recognised conformity assessment body for carrying out the validation and verification activities provided for under the National Climate Law (Law 4936/2022, Government Gazette A’ 105).
In accordance with the framework established by Joint Ministerial Decision F.01.2/56790/ΔΠΠ 1828/31-05-2016 (Government Gazette B’ 1897), under Reference No. 79998 dated 22 September 2026, COSMOCERT provides independent validation and verification services for greenhouse gas emissions, emissions reduction projects and obligations arising from the applicable European and national regulatory framework.