Two legal regimes, not one
The same ministry buys under two different frameworks, depending on what it is buying.
| Regime | What it covers | What it means for a supplier |
|---|---|---|
| Law 4412/2016, the general law | Anything not military in character: food, fuel, clothing, cleaning, office IT, buildings, medical supplies | An ordinary tender in KIMDIS and ESIDIS, like any other public body. This is where most opportunities for non defence companies sit |
| Law 3978/2011, the defence law | Military equipment, sensitive material and related services, transposing Directive 2009/81/EC | Special rules: restricted procedures, information and supply security requirements, a limited field of bidders |
| Article 346 TFEU | Contracts touching essential national security interests | An exemption from EU rules. Not published in the usual way and often not visible at all |
The practical consequence: anyone selling food, services or commercial equipment to the armed forces operates in the world of Law 4412 and sees tenders as they would anywhere. Anyone selling weapon systems operates in an entirely different environment, where access precedes the notice.
Who buys
- The General Directorate for Defence Investments and Armaments of the ministry, which runs the major armament programmes and intergovernmental agreements.
- The General Staffs and their supply services: Army, Navy and Air Force, each with its own procurement directorates.
- Units and formations with devolved authority for small local needs, usually by direct award.
- Military hospitals such as 401 General Military Hospital, NIMTS and the Naval Hospital. They buy medical supplies on logic close to the national health system hospitals, but through their own procurement services.
- The armed forces share funds and other supervised bodies, which are separate legal entities running their own tenders.
The CPV codes of defence
- 35 Security, fire fighting, police and defence equipment. The defining defence code: weapon systems, ammunition, protective equipment, security vehicles.
- 15 Food and 55 Catering services. Feeding units is among the largest and most stable tender families in the sector, under Law 4412.
- 09 Fuels. Large volumes, often under framework agreements.
- 18 Clothing and footwear. Uniforms, boots, webbing. Traditionally a domain of Greek industry.
- 50 Repair and maintenance services. Maintenance of vehicles, vessels, aircraft and facilities. A large and continuous category.
- 33 Medical devices and pharmaceuticals for the military hospitals and medical service.
- 34 Transport equipment, 45 construction work for bases and infrastructure, 30 and 48 IT.
The specifics worth knowing
- Information security. Contracts under Law 3978/2011 often require personnel and facility clearance. Clearance cannot be obtained within a tender's deadlines, so it is a condition of entry rather than a document to be filed.
- Security of supply. Bidders are asked to commit that they can deliver and support the material under crisis conditions, often with guarantees of spare part availability over many years.
- Long cycle, long duration. Armament programmes are prepared over years and delivered across a decade. The commercial cycle does not begin with the notice.
- Unpublished contracts. Anything falling under Article 346 TFEU does not follow ordinary publicity. The absence of a tender from KIMDIS does not mean it did not happen.
- The non defence side is accessible. Food, clothing, fuel, cleaning, maintenance and IT are tendered normally in KIMDIS and ESIDIS. For most companies this is the real market.
Where tenders are published
Contracts under Law 4412/2016 are registered in KIMDIS and run in ESIDIS above 30,000 euro, exactly as for any other body. Contracts under Law 3978/2011 are published on TED when they exceed the thresholds of Directive 2009/81/EC, and the buying bodies keep their own notice pages. Decisions appear on Diavgeia, except where the content is classified.
The GOVADI platform tracks the defence ministry, the General Staffs, the military hospitals and the supervised bodies as separate contracting authorities, with emphasis on the Law 4412 contracts that are accessible to most companies: catering, fuel, clothing, maintenance and IT.
Frequently asked questions
Which law governs armed forces procurement in Greece?
It depends on the subject matter. Law 3978/2011, transposing Directive 2009/81/EC, covers military equipment and sensitive material. For everything else, such as food, fuel, clothing, cleaning and IT, the general Law 4412/2016 applies with the usual procedures.
What does Article 346 TFEU mean for a supplier?
It allows a member state to exempt contracts touching its essential security interests from EU rules. In practice some defence contracts are therefore not published in the usual way, so their absence from public registers does not mean they do not exist.
Can a company with no defence experience sell to the armed forces?
Yes, and that is where most of the opportunities are. Unit catering, fuel, clothing, cleaning, facility maintenance and IT are tendered under Law 4412/2016 and published normally in KIMDIS and ESIDIS.
What is security of supply in a defence tender?
It is the supplier commitment that it can deliver and support the material even under crisis or conflict conditions. It usually translates into guarantees of spare part availability over many years and undertakings about the production line.
Do I need a security clearance to take part?
For Law 3978/2011 contracts involving classified information, yes. Personnel and facility clearance takes time and cannot be obtained within a tender deadline, so it must already be in place. For Law 4412 contracts it is not required.