Distributes a software product, in Greece

Law 4994/2022, Arts. 19 to 21, 26(1) to (3) and (7) and 27, with Art. 69 of Law 5218/2025 · Read the law's page

• If a market surveillance authority has sufficient reason to believe that your product does not conform, cooperate fully with its evaluation (Art. 20(1)).
• If the authority finds that the product does not conform, take all the corrective measures it asks for within the period it sets, and withdraw the product from the market within a reasonable period if you did not take them in time (Art. 20(1); provisional measures follow under Art. 20(4)).
• Ensure that corrective measures are taken for all the products you placed on the market throughout the European Union (Art. 20(3)).
• Put an end to formal non-compliance when the authority requires it: a CE marking affixed in breach of the rules or missing, an EU declaration of conformity not drawn up or drawn up incorrectly, an unavailable or incomplete technical file, missing, incorrect or incomplete identification information under Art. 7(6) or Art. 9(4), or another unmet administrative requirement of Art. 7 or Art. 9 (Art. 21(1) and (2)).
• Make available to the authority, on its request, the copy of your Art. 14 assessment and the evidence behind it, so that it can review the assessment and the use of the Annex VI criteria (Art. 14(3) and Art. 19(4)).

Law 4994/2022, Arts. 3(1), 4(21), 5(1), 7 to 12, 14 to 18, 24, 25(2) and (3), 26(1) and (3) and 27(2) · Read the law's page

• If you place on the market a consumer general purpose computer hardware system or its operating system, a payment terminal, an automated cash machine, a ticketing machine, a ticket-checking machine or an interactive information self-service terminal that is intended specifically for the provision of services the Act covers (other than one installed as an integral part of a vehicle, aircraft, ship or rolling stock), consumer terminal equipment with interactive computing capability used for electronic communications services or for access to audiovisual media services, or an e-reader, make it meet the accessibility requirements of Sections I and II of Annex I, except that self-service terminals are excepted as to Section II (Art. 3(1) and Art. 5(1); implements Directive (EU) 2019/882, Art. 4(2)); Part B of the Act has applied since 28 June 2025 (Art. 46(2)).
• As manufacturer, design and manufacture the product in accordance with the applicable accessibility requirements, draw up the technical file under Annex IV, carry out the conformity assessment procedure of that Annex or have a third party carry it out, and, where conformity is shown, draw up the EU declaration of conformity and affix the CE marking (Art. 7(1) and (2)).
• Keep the technical file and the EU declaration of conformity for five years from the placing of the product on the market, ensure that series production stays in conformity, and give the product a type, batch or serial number, your name or trademark and a contact address in Greek, in braille or in another accessible format (Art. 7(3) to (6)).
• Supply the product with instructions and safety information in Greek that are clear, understandable and comprehensible and can be provided in an accessible format on the customer's request (Art. 7(7)).
• If you consider a product you placed on the market non-conforming, take corrective measures at once or withdraw it, inform the market surveillance authorities with details of the non-conformity and the measures taken, and keep a register of non-conforming products and related complaints; give the authority in Greek, on a reasoned request, all the information and documentation that show conformity, and cooperate with it (Art. 7(8) and (9)).
• As authorised representative, you cannot take over the manufacturer's obligations under Art. 7(1) or the drawing up of the technical file; the written mandate must allow at least keeping the EU declaration of conformity and the technical file at the authorities' disposal for five years, giving the authority the information and documentation that show conformity, and cooperating with it (Art. 8).
• As importer, place only conforming products on the market; before doing so, check that the manufacturer has carried out the conformity assessment procedure and drawn up the technical file, that the product bears the CE marking and comes with the required documents, and that the manufacturer has met Art. 7(5) and (6) (Art. 9(1) and (2)).
• As importer, do not place on the market a product you consider non-conforming until it conforms, and inform the manufacturer and the market surveillance authority (Art. 9(3)); show your name or trademark and a contact address in Greek, in braille or in another accessible format, and supply the instructions and safety information in Greek (Art. 9(4) and (5)).
• As importer, keep a copy of the EU declaration of conformity at the authority's disposal for five years and ensure that the technical file can be made available on request (Art. 9(7)); if you consider a product you placed on the market non-conforming, take corrective measures at once or withdraw it, inform the authority and keep a register of non-conforming products and complaints (Art. 9(8)); give the authority in Greek, on a reasoned request, the information and documentation that show conformity and cooperate with it (Art. 9(9)).
• As distributor, act with due care in relation to the Act's requirements and, before making a product available, verify that it bears the CE marking, comes with the required documents and with the instructions and safety information in Greek, and that the manufacturer and the importer have met Art. 7(5) and (6) and Art. 9(4) (Art. 10(1) and (2)).
• As distributor, do not make available a product you consider non-conforming until it conforms, and inform the manufacturer or importer and the market surveillance authority (Art. 10(3)); ensure that corrective measures or withdrawal follow where you consider that a product you made available does not conform, and give the authority the information and documentation that show conformity (Art. 10(5) and (6)).
• If you are an importer or distributor and place a product on the market under your own name or trademark, or modify a product already on the market in a way that may affect conformity, you carry the manufacturer's obligations under Art. 7 (Art. 11).
• Identify to the market surveillance authorities each operator that supplied you with a product and each operator you supplied with a product, and be able to do so for five years after the supply (Art. 12).
• The requirements apply only to the extent that compliance does not require a significant change that fundamentally alters the basic nature of the product and does not impose a disproportionate burden on you; make and document an assessment against the criteria of Annex VI, keep the results for five years from the last placing of the product on the market, and give the authority a copy on request (Art. 14(1) to (3)); this applies to every economic operator, whether manufacturer, authorised representative, importer or distributor (Art. 4(21)).
• A microenterprise in the products sector need not document its assessment but must give the authority, on request, the evidence relating to the assessment for the products on which it invoked Art. 14(1) (Art. 14(4)); a microenterprise is an enterprise with fewer than ten (10) employees and either an annual turnover not above EUR 2,000,000 or a total annual balance sheet not above EUR 2,000,000 (Art. 4(23)).
• Inform the market surveillance authority when you invoke Art. 14(1) for a particular product, except that a microenterprise need not (Art. 14(7)); you cannot invoke the disproportionate burden if you receive funding from sources other than your own resources that is provided to improve accessibility (Art. 14(6)).
• When you rely on the fundamental alteration or disproportionate burden exception for a product, state in the EU declaration of conformity which accessibility requirements fall under the exception; the declaration is drawn up or translated into Greek, follows the structure of Annex VII and is kept up to date (Art. 16(1) and (2)).
• As importer or distributor, make sure that, while a product is your responsibility, storage or transport conditions do not jeopardise its conformity with the accessibility requirements (Art. 9(6) and Art. 10(4)).
• Affix the CE marking visibly, legibly and indelibly to the product or its data plate, or to the packaging and the accompanying documents where the nature of the product does not allow it, before the product is placed on the market (Art. 18(1) and (2); general principles of Art. 30 of Regulation (EC) 765/2008, Art. 17); draw up one EU declaration of conformity where several Union acts require one (Art. 16(3)); by drawing it up the manufacturer takes responsibility for the product's conformity (Art. 16(4)).
• Do not apply an unfavourable discriminatory pricing policy, or any selective financial burden, against consumers whose access improves or is maximised as a result of your compliance with the Act (Art. 24).
• A product or service whose characteristics, elements or functions comply with the accessibility requirements of Annex I, in accordance with Section VI of that Annex, is presumed to meet the accessibility obligations of other Union acts, other than this Act, for those characteristics, elements or functions, unless those acts provide otherwise (Art. 25(2) and (3)).
• A product that conforms to harmonised standards or technical specifications whose references are published in the Official Journal of the European Union, or to parts of them, is presumed to meet the accessibility requirements to the extent those standards or specifications cover them (Art. 15).

Law 4994/2022, Arts. 3(2), (4) and (5), 4(23), 5(2) to (4), 6, 13, 14, 15, 24, 25(2) and (3), 26(4) to (6) and 28(1) and (3) · Read the law's page

• If you offer a service to consumers that the Act covers (an electronic communications service other than a machine-to-machine transmission service, a service giving access to audiovisual media services, a consumer banking service, an e-book service and its dedicated software, an e-commerce service, or the listed elements of air, bus, rail and waterborne passenger transport), make it meet the accessibility requirements of Sections III and IV of Annex I (Art. 5(2); implements Directive (EU) 2019/882, Art. 4(3)); Part B of the Act has applied since 28 June 2025 (Art. 46(2)).
• A microenterprise that provides services is exempt from the requirements of Art. 5(2) and from any obligation relating to compliance with them (Art. 5(4)); a microenterprise is an enterprise with fewer than ten (10) employees and either an annual turnover not above EUR 2,000,000 or a total annual balance sheet not above EUR 2,000,000 (Art. 4(23)).
• Design and provide the service in accordance with the accessibility requirements (Art. 13(1)).
• Draw up the information that Annex V requires and say how the service meets the applicable accessibility requirements, make it available to the public in written and oral form, including in a manner accessible to persons with disabilities, and keep it for as long as the service is in operation (Art. 13(2)(a)).
• Have procedures in place so that the provision of the service stays in conformity with the applicable accessibility requirements, and take due account of changes in the characteristics of the service, in the applicable requirements and in the harmonised standards or technical specifications on which conformity is declared (Art. 13(3)).
• If the service does not conform, take the corrective measures needed to bring it into conformity and inform the competent market surveillance authority at once, with details of the non-conformity and the measures taken (Art. 13(4)); on a reasoned request, give the authority all the information needed to show conformity and cooperate with it (Art. 13(5)).
• The requirements apply only to the extent that compliance does not require a significant change that fundamentally alters the basic nature of the service and does not impose a disproportionate burden on you; make and document an assessment against the criteria of Annex VI, keep the results for five years from the last provision of the service, give the authority a copy on request, and inform the authority responsible for checking the compliance of services when you invoke it (Art. 14(1) to (3) and (7)).
• Renew the disproportionate-burden assessment, for at least five years and for each category or type of service, when the service you offer changes or when the authorities that supervise the compliance of services request it (Art. 14(5)); you cannot invoke the disproportionate burden if you receive funding from sources other than your own resources that is provided to improve accessibility (Art. 14(6)).
• A service that conforms to harmonised standards or technical specifications whose references are published in the Official Journal of the European Union, or to parts of them, is presumed to meet the accessibility requirements to the extent those standards or specifications cover them (Art. 15).
• A service that meets the requirements on accessible information and information on accessibility in Regulations (EC) 261/2004, (EC) 1107/2006, (EC) 1371/2007, (EU) 1177/2010 and (EU) 181/2011 and the related acts issued under Presidential Decree 104/2010 is deemed to meet the corresponding requirements of the Act; meet in full the additional requirements the Act sets beyond them (Art. 6).
• A service whose characteristics, elements or functions comply with the accessibility requirements of Annex I, in accordance with Section VI of that Annex, is presumed to meet the accessibility obligations of other Union acts, other than this Act, for those characteristics, elements or functions, unless those acts provide otherwise (Art. 25(2) and (3)).
• Make the built environment that your clients use comply with the accessibility requirements of the urban planning legislation and of the legislation on accessibility in the land zone of ports (Art. 5(3)).
• Do not apply an unfavourable discriminatory pricing policy, or any selective financial burden, against consumers whose access improves or is maximised as a result of your compliance with the Act (Art. 24).
• Until 28 June 2030 you may keep providing services with products you lawfully used for similar services before that date; service contracts concluded before 28 June 2025 may continue without alteration until they expire, for at most five years from that date (Art. 28(1)); self-service terminals you lawfully used before 28 June 2025 may stay in use for similar services until the end of their economically useful life, for at most twenty years from the start of their use (Art. 28(3)).
• The Act does not cover pre-recorded time-based media or office file formats published up to 28 June 2025, online maps and mapping services that provide the necessary navigation information in an accessible digital way, third-party content that you neither fund, develop nor control, or archived website and app content that is not updated or published after 28 June 2025 (Art. 3(4)).

Law 5218/2025, Art. 68, inserting Art. 25A into Law 4994/2022 · Read the law's page

• Refrain from conduct that breaches the requirements of the Act, as economic operator handling products or as service provider; an association of persons under Art. 61 of the Civil Code that has a legitimate interest in representing persons with disabilities, or a public body entrusted with defending their collective interests or with ensuring compliance with the Act, can ask a court to stop that conduct and to secure the requirements by interim measures in a collective action (Art. 25A(1) of Law 4994/2022, inserted by Art. 68 of Law 5218/2025).

Ν. 4961/2022 (ΦΕΚ Α' 146/27.07.2022), Chapter Γ' of Part B, Arts. 32-42 · Read the law's page

• If you manufacture, import or distribute an Internet of Things device intended for operators of essential services, digital service providers or local government organizations in Greece, design it to reach an appropriate level of cybersecurity throughout its life cycle, with measures such as secure passwords, timely software updates from trusted sources, encryption of critical security data in transit and a vulnerability disclosure policy or procedure (Law 4961/2022, Article 32). Devices used by the National Intelligence Service and the Ministry of National Defence are outside the chapter.
• As a manufacturer, supply each such device with a declaration of conformity to the technical security specifications set by ministerial decision under Article 113, paragraph 12α, together with instructions for use and security information that end users can easily understand, keep the declaration, and give it to the National Cybersecurity Authority or the competent response team on request (Article 33(1) to (3)).
• As a manufacturer that learns a device does not comply with those specifications, inform the importer, the National Cybersecurity Authority and the competent response team immediately (Article 33(5)).
• As a manufacturer, keep for each device a procedure for handling an incident or vulnerability that a user finds, documenting its nature, giving detailed instructions for dealing with it and listing mitigation measures (Article 39).
• As an importer or distributor, check before supplying a device to an Internet of Things operator that it comes with the declaration of conformity, and stop supplying a device you know does not comply until it does, informing the manufacturer and, if it has already been supplied, the authority, the response team and the distributor or operators using it (Article 34).
• If you are an operator of essential services, a digital service provider or a local government organization using such devices, use them in accordance with the technical security specifications, appoint an Internet of Things Security Officer, keep a register of the devices you use and update it annually, suspend use of a device that presents a risk, and carry out a data protection impact assessment of the related processing (Articles 35, 37(2), 38 and 41(2)).

Ν. 2251/1994 (ΦΕΚ Α΄ 191), άρθρο 6 · Read the law's page

• Article 6 applies to a defective product, and its text does not say whether software supplied on its own is a product, so treat standalone software as an open question under Art. 6(2).
• If you manufacture a finished product, a raw material or a component, or put your name, trade mark or another distinguishing mark on a product, you answer for any damage a defect in it causes (Art. 6(1) and (2)).
• If you import a product for sale, leasing or another form of distribution in the course of your business, you answer as the producer (Art. 6(3)).
• If you supply a product and the producer is unknown, tell the consumer within a reasonable time who the producer is or who supplied the product to you, or you are treated as the producer (Art. 6(4)).
• Give the performance your product's specifications provide and the safety that can reasonably be expected, judged by all the circumstances, including its appearance, its expected use and when you put it into circulation (Art. 6(5)).
• Be ready to prove an Art. 6(8) defense: that you did not put the product into circulation, that the defect did not exist then, that you did not make it for distribution or distribute it in your professional activity, that the defect is due to mandatory rules of law, or that the state of scientific and technical knowledge then did not allow the defect to be discovered (Art. 6(8)).
• If you made only a component, be ready to prove that the defect is due to the design of the product it was incorporated into or to that product maker's instructions (Art. 6(9)).
• Do not rely on a contract term to limit or exclude your liability to the injured person, because such an agreement is void (Art. 6(12)).