The Hellenic Competition Commission publishes the interim report of the sector inquiry in Coastal Shipping, launched in April 2025 (see press release here). The Interim Report presents the structure of the coastal shipping market, the determinants of supply and demand, the parameters of competition, the institutional framework, and the rules under which business strategies and market behavior are shaped.
The Interim Report is available (in Greek) here.
The Interim Report identifies inefficiencies and potential distortions in the operation of the market, which require further investigation. At the same time, by identifying concerns and formulating preliminary positions and proposals, it seeks to initiate an open and constructive dialogue with authorities and stakeholders, aiming to strengthen competition and find a balanced approach between the economic viability of market participants and the serving of the wider public interest. The HCC supports that the modernization of the institutional framework, the upgrading of port infrastructure, the redesign of the network, investment in a green fleet, and the establishment of a stable and transparent governance structure which constitute the necessary conditions for an efficient, competitive, and socially equitable coastal shipping sector in Greece.
The Competition Commission invites all interested parties to submit their views on the issues examined in the Interim Report by 14th of November 2025, either through written submissions or by participating in an online consultation to be held during the first half of November. The exact date of the consultation will be announced shortly.
The views of stakeholders will serve as a valuable guide for the preparation of the Final Report.
Written submissions should be sent to This email address is being protected from spambots. You need JavaScript enabled to view it. . Parties should identify confidential information contained therein and submit a non confidential version of their submissions.
The Sector Inquiry into Coastal Shipping is independent from ex officio investigations conducted by the HCC on potential infringements of Law 3959/2011 and Articles 101 and 102 of the Treaty on the Functioning of the European Union (TFEU). At the same time, the results of the present inquiry contribute to a better understanding of the sector and of the prevailing competitive conditions.
Key Findings of the Interim Report
▪ Conditions of Supply and Demand
Coastal shipping is a sector of strategic importance for the Greek economy and for social and territorial cohesion, as it ensures geographical continuity between the mainland and the islands and significantly supports the tourism product.
Demand mainly arises from the need for connections between islands and the mainland, as well as inter-island routes, covering the transport of passengers, vehicles, goods, and tourists. It is highly seasonal, peaking during the summer due to tourism. At the same time, there is a relatively inelastic core of demand from permanent island residents and freight transport, while tourism-related demand is more elastic and sensitive to price and service quality. Following the pandemic downturn, the market has recovered: in 2023, approximately 17.25 million passengers and 3.3 million vehicles were transported on domestic routes. On the supply side, around 299 vessels (247 conventional and 52 high-speed) and 216 companies operate. Despite the large number of operators, the market is concentrated: Attica Group and Seajets jointly control around 60% of passenger capacity. The fleet is relatively old (average age ~25 years, ~31 years for medium-to-long-distance routes), and the adoption of green technologies remains limited.
In terms of cost structure, fuel is the largest expense, followed by wages, maintenance, and insurance; larger companies benefit from economies of scale. The sector shows signs of recovery and further consolidation, with positive prospects depending on investment in technology and sustainability.
The system of coastal shipping balances two often conflicting objectives: on the one hand, its role as a public service of general interest, and on the other, the need for economic viability as a market activity. Achieving this balance is challenging due to the large number of small and remote islands and the strong seasonality of demand. Since the liberalization of the market in 2002 and its alignment with EU law, state intervention has been reduced, competition and service quality have formally improved, yet challenges remain in ensuring adequate and sustainable service for smaller or less touristic islands.
Pricing tends to reflect the perspective of the occasional visitor rather than that of regular users (residents, commuters, freight operators), as income levels and affordability are not always sufficiently taken into account. To offset this, the “Transport Equivalent” policy subsidizes island residents and businesses, aligning sea transport costs more closely with those of land transport.
▪ Institutional Framework
The framework governing route scheduling, though regulated, allows loopholes that may reduce competitive intensity, for example through procedures that align timetables following Ministry of Shipping invitations for “necessary time intervals.” This practice can facilitate communication among competitors and create a risk of anti-competitive coordination, as shown by HCC decisions (759/2021, 793/2022) concerning ferry routes (price/discount coordination, route allocation).
Additionally, sector associations’ representation in advisory bodies (such as the Council for Coastal Shipping) raises concerns about governance, transparency, equal treatment, and potential conflicts of interest. The report proposes modernizing the regulatory framework toward a “dynamic, responsive, and adaptive” model that treats regulation as a repeated game with evolving incentives, strikes a balance between rigid rules and freedom, and integrates learning from past experience. The goal is to create conditions of healthy competition and continuous market evolution rather than static and short-term incentives that may distort long-term economic balance.
▪ Port Infrastructure
Port infrastructure is a critical complementary link in the value chain. Long-standing deficiencies, especially in island ports, affect both supply and demand satisfaction, undermining efficiency. Priority areas include upgrading quays, docks, depths, and terminal facilities, enhancing safety, and improving passenger services. The report also recommends addressing fragmentation among port authorities, upgrading Port Organizations and Port Funds, and creating larger, better-equipped management entities (e.g., the Evia Ports Organization model). It also discusses the introduction of a “Sea Ports Time Slots” system, similar to aviation, where peak-hour berthing slots would be auctioned or allocated, helping to reduce congestion and simultaneous arrivals/departures — provided careful design ensures complementarity between port and service operations.
▪ Fleet and Green Transition
The current network has a “star-shaped” topology centered on Piraeus. Before 2002, this led to multiple island calls per route, lowering service quality and creating paradoxical dependence of neighboring islands on Piraeus. Although this central structure largely remains, studies show that a hub-and-spoke model with main nodes and regional inter-island routes would improve efficiency, provided it integrates into a multimodal island transport system. Fleet aging increases operating costs (repairs, fuel), which are passed on to prices. The green transition requires either fleet renewal with new vessels or major retrofits (anti-pollution and energy-efficiency technologies). While these investments may create funding gaps, they also open new fields of competition that will reshape capacity, service quality, locations, and pricing. Access to finance and entry of new players will be decisive factors.
▪ Supervisory Governance
The governance framework has undergone repeated restructurings, which may undermine stability and consistency. Although Law 4948/2022 attempted partial codification, fragmentation of responsibilities remains a challenge. The composition and functioning of the Coastal Shipping Council (SAS) also raise concerns about transparency and conflicts of interest. The report advocates for a single regulatory and supervisory authority to ensure smooth market operation, compliance, and strategic planning.
▪ Public Service Obligation (PSO) Contracts
PSO contracts are essential to ensure service during winter/low-demand periods and maintain territorial cohesion, but their cost has increased dramatically — from €10 million in 2001 to €150 million in 2025 (+1400%). The number of routes has risen to 75 (with further expansion expected by 2029), indicating both market shortcomings and inefficient use of exclusive contract arrangements. The current framework allows ad hoc or late route scheduling even on subsidized routes, effectively nullifying exclusivity and increasing public expenditure. The report calls for a comprehensive review of the PSO framework, including incentive structures, identification of truly “non-viable” routes, and improvement of tender procedures.
▪ Island Cohesion
To achieve economic, social, and territorial cohesion, the report stresses the need for a holistic multimodal island transport system that organically connects maritime and air transport (planes, and where feasible, seaplanes/helicopters). A central planning and implementation authority should ensure synergies, smooth interconnections, and the integration of a unified multimodal network that can reliably and affordably meet the needs of all island regions.