ETCS Exception in Greece 2026: What Railway Operators and Manufacturers Must Review

Key data

Railway operators and rolling stock manufacturers operating in Greece or destined for that country face an exceptional regulatory situation: the European Commission has granted Greece a formal exemption from installing the European Train Control System (ETCS) on board its vehicles, as required by the Implementing Regulation (EU) 2023/1695.

This exception, set out in the Implementing Decision (EU) 2026/2189, has effect from 24 September 2026. The measure is not a minor change: it directly affects cross-border interoperability and requires any company with railway activity in the Greek market to review its technical and commercial strategy.

What does this regulation establish?

ETCS (European Train Control System) is the European technical standard for railway safety and control. Its installation on board vehicles is a mandatory requirement under Implementing Regulation (EU) 2023/1695, which implements the Directive (EU) 2016/797 on the interoperability of the EU railway system.

Decision 2026/2189 establishes a specific exception for Greece: its affected railway vehicles are temporarily exempted from complying with that installation requirement. In practice, this means that:

• Greek vehicles covered by the exception may operate without ETCS on board within Greek territory.
• The exemption is based on the article of Directive (EU) 2016/797 that allows Member States to request exceptions to technical interoperability requirements.
• The exception does not automatically exempt those vehicles from complying with ETCS if they operate in other EU Member States, where the standard remains mandatory.

Economic and operational impact

Installing ETCS on board a railway vehicle represents a significant technical investment: it involves on-board hardware, certified software, integration with signalling systems and homologation processes. The exception granted to Greece has direct operational and economic consequences for industry stakeholders:

• Greek railway operators: vehicles covered by the exception avoid the cost and timeline of ETCS installation, at least temporarily. This may represent short-term financial relief, but creates uncertainty about medium-term planning.
• Rolling stock manufacturers: vehicle supply projects for the Greek market may be affected in their technical specifications and contracts. A vehicle designed without ETCS for Greece will not be interoperable on the rest of the European network.
• International operators: cross-border services entering or leaving Greece must verify that their vehicles meet ETCS requirements to operate outside Greek territory, as the exception does not cover them in other countries.
• Interoperability: the exemption temporarily reduces the interoperability of the Greek railway network with the rest of the EU, which may limit the expansion of cross-border services and integration into European corridors.

Who does it affect?

• Railway operators with activity in Greece: both Greek national operators and international operators operating through Greek territory.
• Rolling stock manufacturers: companies that supply or plan to supply railway vehicles to the Greek market, as the technical specifications of their products may be altered.
• Greek railway authorities: responsible for managing the application of the exception and ensuring the operational safety of exempted vehicles.
• Railway maintenance and certification companies: that must adapt their homologation and maintenance processes to vehicles without ETCS on board.
• Cross-border corridor operators: especially those connecting Greece with other EU countries or the Balkans, where technical interoperability is critical.

Practical example

A European rolling stock manufacturer has a contract to supply locomotives to a Greek railway operator. Without the exception, those locomotives would have to incorporate the ETCS system on board in accordance with Regulation (EU) 2023/1695, with the associated cost and homologation timelines.

With Decision 2026/2189 in force, the manufacturer and the Greek operator must evaluate two scenarios: (1) supply vehicles without ETCS, taking advantage of the exception to reduce costs and timelines in the Greek market, accepting that those vehicles will not be able to operate freely in other Member States; or (2) maintain ETCS installation to preserve European interoperability and future operational flexibility, even though the exception makes it technically unnecessary in Greece for now.

The decision has contractual, technical and strategic implications that must be analyzed before signing or modifying any supply or maintenance contract linked to the Greek market.

What should companies do now?

1. Identify affected vehicles: review which vehicles in your fleet or supply portfolio operate or are intended to operate in Greece and whether they are covered by the exception in Decision 2026/2189.
2. Assess the impact on existing contracts: analyze whether supply, maintenance or operation contracts in Greece include clauses on ETCS compliance and whether the exception modifies contractual obligations.
3. Verify requirements for cross-border operation: confirm that vehicles operating outside Greece maintain ETCS compliance, as the exception only applies within Greek territory.
4. Consult with the Greek railway authority: obtain clarity on the exact scope and duration of the exception, as well as on the operating procedures applicable to exempted vehicles.
5. Update technical and financial planning: review investment plans for ETCS installation on affected vehicles, taking into account that the exception is temporary and that the requirement for full compliance may be reactivated.
6. Monitor regulations: follow the evolution of Decision 2026/2189 and any subsequent amendments, given that exceptions of this type usually have defined validity periods or review conditions.

Official source

Consult full regulation at official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026D2189