The Order replaces Order 1849 / 2016, which generated numerous objections by businesses, together with the August 2018 legislative amendments, which made it compulsory for companies engaged in the wholesale or retail trade of energy products to hold deposits to obtain authorisation.

New provisions introduced by Order no. 3236/2018

Order 3236/2018 largely leaves unchanged the provisions of Order, no. 1849 / 2016 together with the August 2018 amendments. Although there is no change in the requirement for applicants for authorisation to hold deposits, exceptions have been introduced for the following:

• Companies which sell energy products based on fuel cards to end-users.
• Affiliates of authorized warehouse keepers, registered consignees or affiliates of companies which hold a wholesale certificate for energy products and who sell energy products only from the authorised locations of the companies with which they are affiliated.

Companies which hold certificates issued under the old Order must submit a new application for registration to the appropriate authority by 31 January 2019. From this date all previously issued certificates will become invalid.

Certificates issued to companies which carry out trading activities on the basis of ongoing public procurement contracts remain valid until the expiry of these contracts.