On 10/3/2026, the Hellenic Competition Commission (HCC) conducted unannounced inspections at the premises of undertakings active in the sectors for water supply, irrigation and sewage/wastewater management. These inspections were conducted as part of the HCC’s ex officio investigations into possible horizontal agreements or concerted practices, in particular concerning possible bid rigging and/or cartel facilitation in breach of Articles 1 of Law 3959/2011 and 101 of the Treaty on the Functioning of the European Union (TFEU). The dawn raid was realized with the assistance of officers from departments of the Hellenic Police.

Investigating cartel-type agreements and concerted practices between competitors is a strategic priority for the HCC, as they presumptively lead to higher prices, limited choice and quality of products and services, and reduced innovation to the detriment of consumer welfare.  Bid-rigging, practices, in particular, undermine the integrity of competitive processes, strain the state budget and drive down the quality of services provided.

It is noted that unannounced inspections take place at undertakings where evidence of anticompetitive practices in the markets concerned may be collected and they do not mean that the inspected undertakings have engaged in anti-competitive behavior, nor do they prejudge the outcome of the investigation itself.

Legal Framework

The HCC enforces Greek and EU antitrust rules according to national law 3959/2011 and Articles 101 and 102 TFEU:

• Article 1 of Law no. 3959/2011 and Article 101 of the TFEU prohibit anticompetitive agreements and decisions of associations of undertakings that prevent, restrict or distort competition.
• Article 1A of Law no. 3959/2011 prohibits unilateral practices that constitute an invitation to collude or future price announcements to competitors.
• Article 2 of Law no. 3959/2011 and Article 102 of the TFEU prohibit the abuse of a dominant position.

The HCC intervenes within its competence as an immediate priority where necessary and examines any relevant case that comes to its notice, upon submission of a complaint, application for leniency or anonymous information through the secure digital environment (whistleblowing) and will impose severe administrative sanctions on companies that apply anti-competitive practices, pursuant to the provisions of law 3959/2011 and articles 101/102 TFEU.

The HCC’s leniency programme

An undertaking's participation in a cartel, i.e. a secret agreement among competitors to restrict competition by inter alia fixing prices or production, allocating customers or market shares, or rigging bids, may lead to significant fines from the HCC, criminal sanctions, and its elimination from public tenders and concession contracts for three (3) years from the issuance of the HCC’s decision.

The HCC’s leniency program has significant advantages for undertakings, associations of undertakings and natural persons involved in cartels, as it offers:

• Immunity from fines or reductions in administrative fines,
• Immunity from, or reductions in, criminal fines, 
• Immunity from any kind of administrative sanctions.
• In addition, the undertakings are not barred from public tenders or concession contracts.

For more information on the HCC’s leniency program, please visit: https://www.epant.gr/en/legislation/leniency-programme.html or call +30 210 88 09 100.  

Further information on the HCC’s whistleblower tool is available on the HCC’s website, at: https://www.epant.gr/en/enimerosi/whistleblowing-system-for-citizens-business.html