The extension of the deadline for the submission of environmental licensing documents for tourist accommodations until April 30, 2026, is requested by the Panhellenic Federation of Hoteliers (POX) in a letter to the Minister of Environment and Energy, Mr. Stavros Papastavrou.
POX points out that, despite legislative interventions in recent years aimed at simplifying and accelerating environmental licensing procedures, delays continue to be significant, resulting in the objective impossibility of timely completion of all files within 2025.
According to the current regulation, the final deadline for submitting the Environmental Terms Approval Decision (E.T.A.D.) or the declaration of inclusion in Standard Environmental Commitments (S.E.C.) has been set for October 31, 2025.
The Federation emphasizes that this specific deadline “proves insufficient,” as the services are unable to respond to the large volume of applications that have accumulated. As stated in the letter, environmental licensing procedures continue to be particularly time-consuming, while the large number of pending files makes it objectively impossible to complete all within 2025.
Furthermore, POX notes that the deadline coincides with the end of the tourist season, a period during which businesses face increased operational obligations and are unable to comply with complex administrative procedures. At the same time, the lack of sufficient specialized engineers in many tourist areas is noted, which further complicates the process.
Read the letter from POX:
We have repeatedly pointed out the significant delays that continue to be observed in the environmental licensing process of tourist accommodations.
Despite legislative initiatives undertaken with the aim of simplifying and accelerating the related procedures, the time required for their completion remains particularly long.
In this context, article 7A of Law 4276/2014 provides the following: “1. Tourist accommodations of paragraph 2 of article 1, which possess, by July 1, 2024, a Special Operating Permit (S.O.P.) or have notified the operation of their activity or have received operating approval for the activity, operate legally and no administrative sanctions or measures are imposed, even if the validity period of the Environmental Terms Approval Decision (E.T.A.D.) has expired, provided that a request for its issuance has been submitted by July 1, 2024. Administrative sanctions and measures from inspections carried out before July 1, 2024, are neither imposed nor confirmed and, if imposed, are revoked by the authority that imposed them, provided that the conditions of the first sentence are met. The previous sentence applies upon request of the tourist accommodation holder, submitted by August 31, 2025. 2. For tourist accommodations that had an S.O.P. or notification of activity operation or approval of activity operation, and due to expiration of the E.T.A.D., the S.O.P. has been revoked or the operation of the activity has been interrupted, the S.O.P. is reissued and operation of the activity is allowed, after a decision of the competent service, provided that by July 1, 2024, a request for issuance or extension of the E.T.A.D. or inclusion in Standard Environmental Commitments (S.E.C.) has been submitted to the competent service. 3. Special tourist infrastructure facilities of paragraph 3 of article 1, which possess, by July 1, 2024, an S.O.P. or have notified the operation of their activity or have received operating approval, operate legally even if the E.T.A.D. is missing or has expired or no declaration of inclusion in S.E.C. has been submitted, provided that a relevant request has been submitted to the competent service or is submitted by December 31, 2024. Facilities located in complex tourist accommodations or in Integrated Tourism Development Areas are excluded from the application of the first sentence. 4. For special tourist infrastructure facilities that had an S.O.P. or notification of operation or operating approval and due to lack of E.T.A.D. or approval of declaration of inclusion in S.E.C., the S.O.P. has been revoked or operation interrupted, the S.O.P. is reissued and operation allowed, after a decision of the competent service, if a request for issuance of the E.T.A.D. or declaration of inclusion in S.E.C. is submitted to the competent service by December 31, 2024. Facilities in complex tourist accommodations or in Integrated Tourism Development Areas are excluded from the application of the first sentence. 5. In cases of paragraphs 1 to 4, for the submission of the E.T.A.D. or the declaration of inclusion in S.E.C. to the service that issues the S.O.P. or the operating approval or receives the notification of operation, a deadline is set until October 31. After the ineffective expiration of the deadline of the first sentence, the S.O.P. or the operating approval is revoked or operation interrupted according to articles 3 and 4.”
However, the deadline of paragraph 5 of the aforementioned article, which stipulates that submission of the E.T.A.D. or the declaration of inclusion in S.E.C. must take place by October 31, 2025, proves insufficient.
Environmental licensing procedures continue to be particularly time-consuming, while the large number of applications submitted according to the above provision has led to a significant accumulation of pending matters in the competent services. This fact makes it objectively impossible to complete all files in time within 2025.
Moreover, the final date of October 31 coincides with the end of the tourist season, a period during which businesses find it extremely difficult to respond to demanding administrative procedures, such as the search and submission of additional supporting documents often requested by the services, considering also the lack of sufficient specialized engineers in tourist areas.
Given that the failure to complete the procedure on time results in automatic revocation of the Special Operating Permit (S.O.P.), it is proposed that the deadline of paragraph 5 of article 7A of Law 4276/2014 be extended until April 30, 2026.
The proposed extension is considered absolutely reasonable and necessary because it provides the required time for the completion of pending files by the competent services, prevents the artificial administrative “asphyxiation” that would be created by the simultaneous expiration of a large number of cases, ensures smooth transition to the new tourist season of 2026 without sudden revocations of S.O.P., and does not cause any administrative or other burden to the State, as it concerns exclusively cases where a request has already been submitted for issuance or renewal of the E.T.A.D. or inclusion in S.E.C.
We remain at your disposal for any clarification.
