Understanding the Updated Greek Golden Visa: Latest Circular, Real-World Examples, and 2026 Investor Insights

On April 22, 2026, the Greek Ministry of Migration and Asylum issued Circular No. 1/2026, marking a pivotal update to the Greek Golden Visa scheme established under Article 100. This circular delivers crucial guidance addressing technical, procedural, and market-related challenges that have created uncertainty for government officials, legal professionals, developers, and investors over the last two years.

Drawing from the Ministry’s official Golden Visa regulations, along with existing implementation guidelines and clarifications, the newly released circular is set to enhance the efficiency of application reviews by providing clearer instructions. Simultaneously, it reinforces a strict stance towards compliance.

Any strategies aimed at evading legal requirements—such as those involving repayment of investment funds to applicants or artificially lowering the actual investment amounts—will be subject to examination by the relevant anti-money laundering authorities and prosecutors, which may lead to the withdrawal of residence permits from the investors involved.

The full text of Circular No. 1/2026 from the Ministry of Migration and Asylum on the Greek Golden Visa program follows:

1. General

As you are aware, paragraph 1 of Article 64 of Law 5100/2024 (Government Gazette A’ 49) amended the provisions of Article 100 of Law 5038/2023, which sets out the conditions for the granting / renewal of permanent investor residence permits (residence permit category “B.5”). In particular:

1.

The provisions of points (a) and (b) of paragraph 2 of Article 100 of Law 5038/2023 were amended as regards the minimum investment value required in order to secure eligibility for the granting of a permanent investor residence permit (“B.5”).

More specifically, for:
(a) the Region of Attica,
(b) the Regional Unit of Thessaloniki of the Region of Central Macedonia,
(c) the Regional Units of Mykonos and Thira of the Region of South Aegean, as well as
(d) islands with a population, according to the latest census, exceeding three thousand one hundred (3,100) inhabitants,

the minimum acquisition value of the real estate at the time of its acquisition, as well as the total contractual rent under the agreements referred to in point (d) of paragraph 1 of Article 100 of Law 5038/2023, are set at eight hundred thousand (800,000) euros.

For the remaining areas of the country, the minimum acquisition value of the real estate at the time of its acquisition, as well as the total contractual rent under the agreements referred to in point (d) of paragraph 1, are set at four hundred thousand (400,000) euros.

By virtue of these new provisions of Article 64 of Law 5100/2024 (Government Gazette A’ 49), in addition to the changes to the acquisition values, changes are also introduced both to the number of properties and to the minimum surface area. Thus, the restriction according to which the minimum investment value must relate to one single property is extended to all of the above cases.

Furthermore, a minimum surface area restriction is now introduced in points (a) and (b) of paragraph 2 of Article 100 of Law 5038/2023, in respect of built real estate or real estate for which a building permit has been issued, whereby the minimum surface area of the main areas must amount to at least one hundred and twenty (120) square metres.

The minimum surface area restriction does not apply in cases of undeveloped real estate or real estate for which no building permit has been issued (indicatively, a plot or parcel of land).

It is noted that, in the event of the acquisition of an undivided co-ownership share in a property, with the minimum acquisition value of each share being 400,000 or 800,000 euros, depending on the location of the property, by two or more investors (each investor’s investment amounting to 400,000 or 800,000 euros), the 120 sq.m. restriction relates to the property as a whole and not to each investor’s share separately.

Example 1: Two investors acquire, in undivided co-ownership (50% each), a residence with a main-area surface of 130 sq.m. and a value of EUR 1,600,000 in an area of Attica. Through this investment, both investors are eligible to fall within the scope of Article 100 of Law 5038/2023, since each has invested EUR 800,000 and the main areas of the property as a whole (and not per investor) exceed 120 sq.m.

Example 2: One investor acquires a residence with a main-area surface of 118 sq.m. and a value of EUR 1,000,000 in an area of Attica. At the same time, within the framework of the above investment, the investor purchases (under the same notarial deed and in the same apartment building) a parking space of 12 sq.m. and a storage room of 8 sq.m. The investor is not eligible to fall within the scope of Article 100 of Law 5038/2023, because although the financial investment criterion is met, the 120 sq.m. criterion is not met, since the main areas of the property amount to 118 sq.m., while the parking space and storage room are not regarded as main areas and are not counted towards the total surface area of the main areas.

2.

By virtue of point (c) of paragraph 2 of Article 100 of Law 5038/2023, as amended by Article 64 of Law 5100/2024, the possibility was introduced of making an investment through the purchase of real estate, provided that its main areas (through construction, conversion or urban planning regularisation) are changed from any other use (for example, indicatively, commercial, professional or other use) into residential use, with a minimum acquisition value, at the time of acquisition, of two hundred and fifty thousand (250,000) euros.

The investment must likewise be made in one single property, without any restrictions as to the surface area of the main areas (i.e. the 120 sq.m. threshold does not apply), and the change of use must have been completed before submission of the application for the granting of the permanent investor residence permit.

It is noted that, in the event that a third-country national purchases a property which, as regards its use, does not constitute a residence, and proceeds to carry out an investment involving a change of use, and such investment results in more than one property, i.e. apartments / residences, these fall under point (c) of paragraph 2 of Article 100, namely with a minimum investment value of EUR 250,000 for the purposes of eligibility for the permanent investor residence permit.

In that case, the original investor may likewise fall within the scope of point (c) of paragraph 2 of Article 100, provided that they continue to retain ownership of one of the resulting residential properties (apartments) arising from the change of use. It is noted that, in respect of the property which the investor retains in their ownership, they must demonstrate that its value amounts to at least EUR 250,000, applying by analogy the method of proof of minimum value included in Joint Ministerial Decision 214926/2025 and relating to antiparochi, namely: “valuation report of a sworn auditor from the register of certified valuers, who has been entered in the register and is active in the sector referred to in point (a) of subparagraph G.4 of paragraph G of Article One of Law 4152/2013, regarding the value of the property remaining in the ownership of the applicant, which must independently meet the applicable value requirement.”

In this context and by way of clarification, a table is attached as an Annex, setting out the minimum investment thresholds in force, as well as the corresponding previous transitional provisions, in relation to the time of completion of the investment and its applicable minimum amount.

At this point, it is clarified that the above change of use must have been completed after the entry into force of Article 64 of Law 5100/2024, which introduced the licensing possibility through ownership of a residence resulting from a change of use, i.e. from 05.04.2024 onwards, while the change of use may be carried out either by the purchaser or by the seller of the property (the investor’s transferor).

The above also covers cases of investment through the purchase of real estate consisting of new residential properties arising:
(a) either from interventions or additions vertically and/or by extension to existing properties whose use changes, as above, from any other use to residential use;
(b) or from the addition of new independent buildings intended for residential use on plots or parcels of land (whether standalone or resulting from the merger of adjoining plots) with pre-existing buildings whose use changes, as above, from any other use to residential use.

3.

By virtue of point (d) of paragraph 2 of Article 100 of Law 5038/2023, as amended by Article 64 of Law 5100/2024, the possibility is provided for investment through the purchase of real estate in cases where such real estate consists of a listed building or part of a listed building requiring restoration or reconstruction, or where a listed building is located thereon, with a minimum acquisition value at the time of acquisition of two hundred and fifty thousand (250,000) euros.

Likewise, as in point (c) of paragraph 2 of Article 100 of the Migration Code, the above cases under point (d) of Article 100 also include investments in properties arising from interventions or additions vertically and/or by extension to listed buildings requiring restoration or reconstruction, or from the addition of independent buildings on plots or parcels of land (standalone or resulting from the merger of adjoining plots) on which listed buildings requiring restoration or reconstruction already exist.

The investment must likewise be made in one single property, and in this case no restrictions apply as regards the surface area of the main areas (i.e. the 120 sq.m. threshold does not apply).

It is specifically noted that, in cases of third-country nationals holding a permanent investor residence permit who implemented an investment under point (d) of paragraph 2, an additional condition for the first renewal of their residence permit is the completion of the full restoration, prior to the submission of the renewal application, of the elements of the real estate, or their total reconstruction, irrespective of the cause to which the deterioration, collapse or demolition of the buildings or parts thereof is attributable.

It is further noted, in this respect, that where the co-owners are spouses or partners in a civil partnership, the right of residence is granted to both with one investment having an acquisition value at least equal to that specified in the cases of paragraph 2 of Article 100 of Law 5038/2023; however, a permanent investor residence permit is granted to one of the two co-owners, while the other spouse or civil partner is granted a residence permit as a family member.

The above approach is followed because each permanent investor residence permit must correspond to one investment. It is noted that in the event of the investor’s death, if the family member (spouse) acquires the property in full, on the basis of which the permits had been granted, they may convert their residence permit from family member status to investor residence permit on the basis of that investment. However, in the event that part of the property passes to other members of the investor’s family and, as a result, the real estate is no longer owned by one third-country national, a new investment meeting the applicable conditions must be made if the heir / heirs wish to fall within the scope of Article 100 of Law 5038/2023.

1. Special Clarifications

CLARIFICATION 1

With a view to the proper application of the provisions of Article 100 of Law 5038/2023, as currently in force, in all the above investments (cases a, b, c and d of paragraph 2 of Article 100 of Law 5038/2023), the investment must be made in one single property in order to qualify for the permanent investor residence permit.

CLARIFICATION 2

It is noted that, within the concept of one single property (for the purposes of determining the minimum value criterion, and not the minimum required surface area for the application of paragraph 2 of Article 100 of Law 5038/2023), there may be included, in all cases (a), (b), (c) and (d) of paragraph 2 of Article 100 of Law 5038/2023, other spaces (storage room(s) and/or parking space(s)), provided that cumulatively:
(a) they are purchased by the investor under the same sale and purchase deed as the main property,
(b) they are located in the same building, and
(c) they constitute ancillary-use spaces, either accessories to the main property (e.g. a pilotis parking space), or independent horizontal properties (e.g. an underground parking space and/or storage room(s)).

In that case, for the fulfilment of the 120 sq.m. requirement (where applicable), such spaces are not taken into account, since under the relevant provision the surface area of the main areas must amount to at least 120 sq.m. (where required). However, for the fulfilment of the minimum investment value (EUR 800,000 or EUR 400,000 or EUR 250,000, as applicable), the purchase price of the ancillary spaces may be counted towards the investment price, insofar as it concerns the acquisition of ancillary spaces (parking space(s) within the same property and storage space(s) within the same property).

Example: An investor has purchased a property (apartment) of sixty square metres (60 sq.m.) within an industrial building, the use of which was changed to residential after the entry into force of Law 5100/2024 (Government Gazette A’ 49), for a price of EUR 248,000. At the same time, under the same notarial deed, the investor purchases in the same building an underground parking space for EUR 8,000 (with its own Cadastral Code / KAEK) and one storage room (without its own KAEK). The above investment totals EUR 256,000 and fulfils, first, the investment amount requirement (above EUR 250,000, since it concerns a property resulting from a change of use) and, second, the one-property criterion, since for the purposes of migration legislation the parking space or storage room is not regarded as a distinct property.

CLARIFICATION 3

As you are aware, third-country nationals applying for the initial granting of a permanent investor residence permit under Article 100 of Law 5038/2023 (Government Gazette A’ 81) shall not be required to submit a certificate of encumbrances and non-claims on the property when submitting the required supporting documents, as such document is not included in the joint ministerial decisions governing the supporting documents for granting the permit (Joint Ministerial Decisions 95391/2024 and 214926/2025, issued in implementation of, respectively, Law 5038/2023 [paragraph 1, Article 176] and Law 5100/2024 [paragraph 2, Article 64]).

Consequently, your services should not request such document, since it is no longer included among the supporting documents required for granting the residence permit under Article 100 of Law 5038/2023, nor should they examine in any way the non-existence of encumbrances, as such a condition is no longer provided by law and the relevant ministerial decisions.

In this context, and with a view to uniform application of the provisions, especially in cases where applications submitted before the entry into force of Law 5038/2023 remain pending, it is emphasised that the above approach should also be applied by your services to applications for the initial granting of a permanent investor residence permit which were submitted before 31 March 2024, i.e. pursuant to Article 20B of Law 4251/2014 (Government Gazette A’ 80).

CLARIFICATION 4

With regard to the application of Section II of our document no. 265272/25.10.2024 entitled “Amendment of paragraph 2 of Article 36 of the Code of Lawyers, regarding the possibility of issuing certificates in respect of real estate”, we hereby inform you that, within the meaning of the lawyer’s certificate concerning registration, ownership, encumbrances and claims relating to the property, where the submitted certificate does not certify the fact of registration itself, but certifies the filing of the registration request (where registration has not yet been completed), the competent one-stop service, as applicable, may proceed normally with the issuance of the investor residence permit (Articles 94, 95 and 100, Law 5038/2023) without requesting further evidence. The same practice shall apply where the third-country national submits evidence regarding the filing of the application for registration of the sale and purchase deed.

In such cases, the applicant third-country national or their attorney-in-fact must submit, either within the validity period of the initial five-year permanent residence permit or upon submission of the application for renewal of the permanent investor residence permit, the required supplementary documents regarding completion of the registration of the property in question, either by means of a registration certificate issued by the competent Mortgage Registry or Cadastral Office, or by means of a corresponding lawyer’s certificate certifying the registration (see also the provisions of Joint Ministerial Decision 214926/2025).

The above practice is followed because, according to relevant information, very substantial delays are being observed in the completion of registration of real estate sale and purchase deeds, which, if translated into delays in the implementation of Article 100 of Law 5038/2023, would undermine the successful implementation to date of the provisions concerning migration through investment in real estate.

CLARIFICATION 5

Within the framework of the application of point (c) of paragraph 2 of Article 100 of Law 5038/2023, and in relation to the point in time at which the change of use of the property into residential use must occur in order for the property to fall within the above provisions, it is noted, for the proper application of the relevant provision, that the condition requiring completion of the change of use after the entry into force of Article 64 of Law 5100/2024 shall be evidenced by the date of issuance of the relevant required act, such as, indicatively, a building permit, approval of small-scale building works, file update or revision of a building permit, and shall also be deemed fulfilled in the case of works where the permit for change of use was issued before publication of the law, but is updated or revised for any reason after publication of the law, i.e. from 05.04.2024 onwards, as provided in Joint Ministerial Decision no. 214926/2025 (Government Gazette B’ 6014), entitled “Determination of the special supporting documents for the granting of the permanent investor residence permit under Article 100 of Law 5038/2023 ‘Migration Code’ (A’ 81), as well as the method of certifying fulfilment of points (c) and (d) of paragraph 2 of the same article.”

It is, however, underlined that in cases of properties which, at the commencement of the application of Law 5100/2024, already had residential use under the relevant urban planning provisions, it is not possible, through a subsequent change of use to another (non-residential) use and then a second change of use back to residential, for such properties to fall within point (c). Such properties may only fall within Article 100 under the new increased investment thresholds (EUR 800,000 or EUR 400,000), as well as the increased minimum main-area surface threshold of 120 sq.m. for built properties.

Likewise, in the case of properties (plots) for which a building permit has been issued for a use other than residential (e.g. offices), after the commencement of the application of Law 5100/2024, it is not possible to fall within point (c) of paragraph 2 of Article 100, because that provision requires a change of use of an existing property or project as at the commencement of the application of Law 5100/2024 and not of a future property. In such cases, falling within Article 100 is possible only under the new investment thresholds in points (a) and (b) of paragraph 2 of Article 100 of Law 5038/2023 (EUR 800,000 or EUR 400,000, one property and 120 sq.m.). In any event, a change of use is understood as relating to an existing property or project whose use is changed to residential, and not to a future property or project.

Within the framework of point (c) of paragraph 2 of Article 100 of Law 5038/2023, it is clarified that an investment is accepted where, in cases of investment through the purchase of real estate consisting of an industrial building or part of an industrial building, or where an industrial building is located thereon, the spaces of which may be converted into residences, provided that for at least the last five (5) years no industrial undertaking had been installed and operating there.

For the purposes of the above paragraph, it is noted that the concept of an industrial building does not include handicraft / workshop buildings; therefore, there is no obligation to verify fulfilment of the above conditions for such buildings, namely whether or not a handicraft / workshop activity had been installed and operating during the last five years.

At the same time, it is clarified that it is possible for a building with a use other than residential (e.g. an industrial building) to be converted into a mixed-use building, in which certain divided properties will be established with non-residential use (e.g. offices, shops) and certain divided properties with residential use. The residences resulting from such process are deemed properties resulting from a change of use, and the new owners may fall within point (c) of paragraph 2 of Article 100 of Law 5038/2023 (EUR 250,000), whereas the remaining divided properties with non-residential use must meet the conditions of either point (a) or point (b) of paragraph 2 of Article 100 (EUR 800,000 or EUR 400,000, as applicable).

Finally, it is noted that where, in the same building, the conditions of both point (c) (change of use) and point (d) (listed building) of paragraph 2 of Article 100 of Law 5038/2023 are met, namely where the property is a listed property with a non-residential use (e.g. office), which is both restored and converted into residential use, the applicant third-country national may choose under which of the two provisions to submit the application for an investor residence permit, taking into account the respective restrictions and obligations.

Example 1: After the commencement of the application of Law 5100/2024, an investor purchases in Attica, for EUR 300,000, a property which, at the commencement of the application of Law 5100/2024, was residential and was later subjected to a change of use (from residential to office), in order to subsequently undergo a further change of use back to residential and apply for the permanent investor residence permit. This case cannot fall within Article 100 (paragraph 2, point (c)), because the property had residential use at the commencement of the application of Law 5100/2024. Therefore, eligibility for the permanent investor residence permit would only be possible if the investment amounted to EUR 800,000 and the minimum surface area of the main areas was 120 sq.m.

Example 2: An investor purchases, off-plan in Attica, a property with a non-residential use for EUR 380,000, included in a building permit issued after the commencement of the application of Law 5100/2024 for the construction of offices. Subsequently, while construction works are ongoing, the development company amends the building permit in order to construct residences instead of offices. The company completes the construction of the residences and the investor submits an application for the permanent investor residence permit. The residence permit application is rejected, because a change of use of a property from another use to residential is not conceptually possible at the stage of issuance of the building permit, as the law requires a change of use of an existing / actual property. This case could only be licensed if the property met the criteria of point (a) or (b) of paragraph 2 of Article 100 of Law 5038/2023.

CLARIFICATION 6

Within the framework of the application of Article 100 of Law 5038/2023, questions have arisen regarding whether or not cases of third-country nationals may fall within the currently applicable provisions where such persons had either invested in real estate at lower investment levels than those currently applicable (e.g. EUR 250,000), but had never proceeded with filing an application for the granting of a permanent investor residence permit, or had obtained a permanent investor residence permit under the then-applicable investment levels, but failed to renew it (e.g. due to expiry of the deadlines).

It is noted that, for the above cases, in order to fall within Article 100 of Law 5038/2023 under the previous investment thresholds, the criteria examined by the competent authority are that the investment of the third-country national:
(a) was completed before the entry into force of the new financial criteria under Article 100 of Law 5038/2023, as applicable (as determined either by Article 91 of Law 5007/2022 – EUR 250,000 or EUR 500,000 – or by Article 64 of Law 5100/2024 – EUR 250,000 or EUR 400,000 or EUR 800,000),
(b) met the applicable investment amount criteria in force at the time of completion of the investment, and
(c) the consideration was paid in accordance with the currently applicable provisions, by producing in any case the corresponding notary’s certificate substantiating the method of payment of the consideration and the other relevant conditions.

It is further noted that, in the case of third-country national investors who lost the possibility of renewal and appear again for the granting of an initial investor residence permit, if they are unable to submit a notary’s certificate (e.g. because of the long time elapsed between the sale and purchase transaction and the request for issuance of the notary’s certificate), they may alternatively submit, instead of the certificate, the sale and purchase deed and the corresponding deed of payment / settlement, subject in all other respects to the requirements of Joint Ministerial Decision 214926/2025.

For the clarification of the above issue, the following examples are set out:

Example 1: A third-country national investor purchased real estate in 2017 for EUR 250,000 (according to the sale contract) and has never filed an application for the granting of a permanent investor residence permit. Today, they wish to fall within Article 100 of Law 5038/2023 on the basis of the purchase of that property, which met the investment amount requirement before the entry into force of the new investment threshold rules. In this context, that third-country national may fall within the scope of the permanent investor residence permit, because they had completed the investment before the entry into force of the new thresholds, provided that all other conditions are also met, especially as regards the method of payment of the consideration.

Example 2: A third-country national investor purchased a property in 2017 and obtained a permanent investor residence permit in 2017, which expired without renewal in 2022. Today, they wish to fall within Article 100 of Law 5038/2023 on the basis of the purchase of the same property through which they had initially been licensed, which met the investment amount requirements before the entry into force of the new provisions. That third-country national may fall within the scope of the permanent investor residence permit, because they had completed the investment before the entry into force of the new investment thresholds, provided that all other conditions are met, especially as regards the method of payment of the consideration.

6.

Within the framework of the application of paragraph 11 of Article 10 of Law 5038/2023, and in relation to the exceptional acceptance by your services of a power of attorney drawn before a competent foreign authority or a notary established abroad, for third-country nationals who meet the conditions for falling within Articles 96 to 100, and for the proper application of the said provision, it is noted that the relevant power of attorney document shall be drawn up, as regards its form and the authority issuing it, in accordance with the law of the country where it was executed, and shall be accepted by your services provided that it bears either an Apostille, if the country where it was executed has acceded to the Hague Convention, or the corresponding legalisation by the competent Greek consular authority.

Provided that the power of attorney document bears the above certifications, it is presumed that the foreign authority before which it was executed is competent to draw up such powers of attorney under the law of its country.

For example, in many jurisdictions, powers of attorney may also be executed before lawyers or other public officials. In such cases, the competent one-stop service may proceed normally with the issuance of the investor residence permit (Articles 94, 95, 99, 100 and 100A of Law 5038/2023) without seeking further evidence.

In this respect, and following numerous questions from one-stop services as well as third-country nationals regarding representation issues upon submission of the residence permit application (initial granting or renewal), the following are clarified:

(a) upon submission of an application for the initial granting of an investor residence permit, the application may be submitted either by the investor personally, provided that they have already entered and are present in the Greek territory at the time of submission of the application, or by their lawyer acting under a power of attorney.

In the case of submission by a lawyer under power of attorney, such authority is evidenced as follows:

1. i) where the third-country national investor has not entered Greek territory, by means of a power of attorney document executed before a Greek consular authority or before a competent foreign authority or a notary established abroad, bearing an Apostille [Hague Convention Apostille of 5 October 1961] or the corresponding legalisation by the competent Greek consular authority; or
2. ii) where the third-country national investor has entered Greek territory, by means of a notarial power of attorney or a simple authorisation signed and certified at a Citizens’ Service Centre (KEP) in Greece or through the state electronic services (gov.gr). It is noted that, where the authorisation has been executed through the state electronic services (gov.gr), it must be accompanied by evidence demonstrating that, at the time of execution of the electronic / digital authorisation, the applicant third-country national was present within Greek territory (e.g. tickets evidencing entry into Greece or an entry stamp on the travel document). In the case of a notarial power of attorney or an authorisation at a KEP, the presence of the third-country national in Greece is inferred from the certification of the document by the competent authority (notary or KEP officer).

If it is not possible to prove the presence of the third-country national in Greece in the case of an electronic authorisation executed through the state electronic services, the application shall be archived without refund of the fee, since the authority has already carried out the first review and processing of the application and the applicant may submit a new residence permit application through an authorised representative, provided that the applicable representation conditions are fully met.

(b) upon submission of an application for renewal of the investor’s residence permit, the application may be submitted either by the investor personally, provided that they have already entered and are present in the Greek territory at the time of submission of the renewal application, or by their lawyer acting under a power of attorney.

Where the application is submitted by a lawyer acting under a power of attorney, such authority is evidenced as follows:

1. i) where the third-country national investor has not yet entered Greek territory for submission of the renewal application, by means of a notarial power of attorney or simple authorisation executed and certified at a KEP in Greece or through the state electronic services (gov.gr), and which had been used either for the initial granting of the residence permit or had been executed significantly earlier than the renewal application, accompanied by a solemn declaration of the authorised lawyer stating that such power of attorney has not been revoked; or
2. ii) where the third-country national investor has entered Greek territory for submission of the renewal application, by means of a notarial power of attorney or simple authorisation executed and certified at a KEP in Greece or through the state electronic services (gov.gr). It is noted that, where the authorisation has been executed through the state electronic services (gov.gr), it must be accompanied by evidence demonstrating that, at the time of execution of the electronic / digital authorisation, the applicant was within Greek territory (e.g. tickets evidencing entry into Greece or an entry stamp on the travel document). In the case of a notarial power of attorney or an authorisation at a KEP, the presence of the third-country national in Greece is inferred from the certification of the document by the competent authority (notary or KEP officer); or

iii) where the third-country national investor has not yet entered Greek territory for submission of the renewal application and has changed their authorised representative, by means of a document executed before a Greek consular authority or before a competent foreign authority or a notary established abroad, bearing an Apostille [Hague Convention Apostille of 5 October 1961] or the corresponding legalisation by the competent Greek consular authority.

It is pointed out to authorised representatives who are lawyers that, in all the above cases of granting or renewal, the application submitted by the authorised lawyer must mandatorily be filed in the Migration Integrated Information System (OPS Migration) through the “Plenary” portal (“Olomeleia”), as the necessary authentication certifications are provided therefor in accordance with Ministerial Decision no. 118654/2024. Where the competent one-stop service establishes that a lawyer acting as authorised representative has filed a licensing application (initial or renewal) outside the “Olomeleia” portal, while using their personal contact and authentication details (email and mobile phone), the application shall be archived without refund of the fee, since the service has already proceeded with initial processing of the application, and the authorised lawyer must re-submit the application through the “Olomeleia” portal, subject in all other respects to Articles 2, 4 and 7 of Ministerial Decision no. 118654/2024.

CLARIFICATION 7

By virtue of Article 64 of Law 5100/2024, paragraph 7A was added to Article 100 of Law 5038/2023, providing that properties acquired in full ownership and possession by third-country nationals for the initial granting or renewal of an investor residence permit may not be leased short-term within the framework of the sharing economy, nor subleased.

In addition, it is noted that, according to the above provision, properties acquired under point (c) of paragraph 2 of Article 100 of Law 5038/2023 may not be used as the registered seat or branch of a business.

In the event of a breach of the above, as well as of the provisions of point (d) of paragraph 2 and paragraph 4 of Article 100 of the Migration Code (prohibition on transfer of listed properties prior to completion of their full restoration or total reconstruction), sanctions are provided for (revocation or non-renewal of the residence permit – administrative fines). However, it should be made clear that under the applicable provisions:

(a) the prohibition on leasing and subleasing properties acquired in full ownership and possession by third-country nationals for the initial granting or renewal of an investor residence permit relates exclusively to short-term leasing and subleasing within the framework of the sharing economy, in accordance with Article 111 of Law 4446/2016 (Government Gazette A’ 240) and the specific definitions contained therein: “Sharing economy means any model whereby digital platforms create an open market for the temporary use of goods or services often provided by private individuals. Digital platforms mean electronic, bilateral or multilateral marketplaces where two or more groups of users communicate via the internet with the intermediation of the platform manager in order to facilitate a transaction between them. Short-term letting means the letting or subletting of real estate, irrespective of whether it is posted on a digital platform in the context of the sharing economy or not, and irrespective of whether the agreement is concluded through the digital platform, for a specific duration of less than sixty (60) days, provided that no services are offered other than accommodation and the provision of bed linen.”

Therefore, the above prohibition does not cover, indicatively, long-term leases or subleases to tourism enterprises for professional use of the property under paragraph 2 of Article 1 of Law 4276/2014, provided that services other than accommodation and bed linen are also offered (e.g. where the property is a hotel), and provided that the specific property is not used as the seat or branch of a business, in cases concerning the purchase of real estate whose main areas were changed to residential use under point (c) of paragraph 2 of Article 100 of the Migration Code, in which case such use is prohibited by the second subparagraph of paragraph 7A of the same article.

(b) the above prohibition on short-term leasing and subleasing within the framework of the sharing economy does not cover properties acquired under the previously applicable provisions, nor properties for which the investment is completed within the transitional period of paragraph 4 of Article 64 of Law 5100/2024.

CLARIFICATION 8

Under points (a) and (b) of paragraph 2 of Article 100 of Law 5038/2023, a minimum surface area restriction of one hundred and twenty (120) square metres is introduced in cases concerning built real estate or property for which a building permit has been issued.

It is also noted that in the case of purchase of undeveloped property (plot) for which no building permit has been issued, no minimum required surface area is specified, since the 120 sq.m. restriction refers only to built surface.

However, if a building permit is subsequently issued, the property that will be erected (whether through antiparochi or by assigning construction to a contractor) and that remains in the ownership of the investor, in order to be linked to the residence permit under Article 100 of Law 5038/2023, must satisfy not only the requirements regarding the purchase price amount (points (a) and (b) of paragraph 2 of Article 100), but also the above restrictions of one single property and 120 sq.m. In particular, the following cases are distinguished:

(a) the investor erects on the plot, on the basis of which they obtained the permanent investor residence permit, one property (e.g. a detached house), retains the permanent residence permit, and merely notifies the one-stop service that issued the residence permit of the new supplementary investment on the property. The authority does not assess the manner in which the new investment was made (construction on the plot), and it is noted that the applicant will retain the permanent investor residence permit for as long as they retain the whole of the above property (the plot on the basis of which they were licensed and the property subsequently erected thereon after the permit had been issued); and

(b) where the investor erects on the plot, on the basis of which they obtained the permanent investor residence permit, more than one independent property and sells one or more of them, they are required, first, to immediately inform the competent one-stop service that issued the permanent investor residence permit of the sale of the independent property / properties, and second, to demonstrate to the competent one-stop service that the real estate they continue to retain has a value equal to the minimum investment thresholds, as determined in points (a) or (b) of paragraph 2 of Article 100 of Law 5038/2023 (EUR 800,000 or EUR 400,000 depending on the location of the real estate).

At the same time, according to point (b) of paragraph 1 of the above article, the right of investor residence is also granted to undivided co-owners of a property only where the share of each co-owner has a value at least equal to that specified in the cases of paragraph 2 of Article 100 of Law 5038/2023, except where the co-owners are spouses or partners who have entered into a civil partnership, in which case the right of residence is granted to both on the basis of one investment whose acquisition value is at least equal to that provided in the cases of paragraph 2 of the above article.

Accordingly, it is pointed out that, in the case of co-ownership of a property, co-owner spouses or civil partners are required jointly to satisfy only the minimum investment value; therefore, for the purposes of points (a) and (b) of paragraph 2 of Article 100 of Law 5038/2023, the undivided property acquired may have a minimum main-area surface of 120 sq.m., irrespective of the number of co-owners.

In connection with the above, it is noted that the restriction of investment in one single property now applies to all cases (a), (b), (c) and (d) of paragraph 2 of Article 100.

CLARIFICATION 9

Within the framework of the application of points (c) and (d) of paragraph 2 of Article 100 of Law 5038/2023, and in relation to investment through the purchase of property with a minimum acquisition value of two hundred and fifty thousand (250,000) euros and no minimum surface restriction, subject to the relevant conditions and for the proper application of the said provision, it is noted that, in the event of resale of such property to another third-country national after the first licensing under the favourable provisions of Law 5038/2023 (minimum consideration EUR 250,000), the right to obtain a residence permit is not granted to the new purchaser on the basis of the same minimum acquisition value, since a property resulting from a change of use or restoration of listed buildings may be used under these exceptional provisions only once. In any event, the favourable provisions concern a property which changes from another use to residential use and, therefore, once the property has already become a residence, the standard provisions as to the investment amount (i.e. EUR 400,000 or EUR 800,000) apply for its sale to another third-country national.

Example 1: A third-country national proceeds with an investment in a residence resulting from a change of use [point (c), paragraph 2], with a minimum consideration of EUR 250,000. They submit an application and obtain the permanent investor residence permit. Subsequently, another third-country national purchases that property from the above-mentioned third-country national for EUR 300,000 and wishes to apply for the granting of a permanent investor residence permit. In this case, since the residence right has already been granted once under that provision, the applicant cannot fall within point (c) of paragraph 2 of Article 100, because the sale concerns a residence-to-residence transaction; therefore, the criteria under points (a) or (b) of paragraph 2 of Article 100 must be met.

Example 2: A third-country national proceeds with an investment in a property that does not constitute a residence (e.g. a shop or office), which has resulted from restoration of a listed building [point (d), paragraph 2], with a minimum consideration of EUR 250,000. They submit an application and obtain the permanent investor residence permit. Subsequently, another third-country national purchases the above property from the first third-country national for EUR 300,000 and wishes to apply for the granting of a permanent investor residence permit on the basis of point (d) of paragraph 2 of Article 100. In this case, since the residence right has already been granted once under that provision, the applicant cannot again fall within point (d) of paragraph 2 of Article 100 and, therefore, the criteria under points (a) or (b) of paragraph 2 of Article 100 must be met. Alternatively, if the new owner changes its use to residential, the first owner’s residence permit is revoked (unless they have already made a new investment), and the new owner may obtain a residence permit under point (c) of paragraph 2 of Article 100, as this is the case where the sale of a residence resulting from a change of use may take place once.

Example 3: A third-country national invests in a non-residential property for EUR 250,000 (e.g. a shop or office) before the entry into force of the increased investment criteria of Law 5100/2024 and obtains the permanent investor residence permit. Subsequently, after the entry into force of the new provisions of Law 5038/2023 [points (c) and (d) of paragraph 2 of Article 100], the investor changes the use to residential and sells the property (residence) to another third-country national. In this case, the first owner’s residence permit is revoked (unless they have already made a new investment), and the second third-country national may obtain a residence permit under point (c) of paragraph 2 of Article 100, as this is the case where the sale of a residence resulting from a change of use may occur once.

Example 4: A third-country national invests in a non-residential property with a minimum surface area of 120 sq.m. for EUR 800,000 (e.g. a shop or office) after the entry into force of the increased investment criteria of Law 5100/2024 and obtains the permanent investor residence permit under point (a) of paragraph 2 of Article 100. Subsequently, the investor sells the property to another third-country national for EUR 700,000, and the latter changes its use to residential. In this case, the first owner’s residence permit is revoked (unless they have already made a new investment), and the new owner may obtain a residence permit under point (c) of paragraph 2 of Article 100, as this is the case where the sale of a residence resulting from a change of use may occur once.

CLARIFICATION 10

Within the framework of the application of paragraph 2 of Article 95 of Law 5038/2023, it is noted that all family members of an investor, regardless of degree and type of kinship, derive their right directly from the sponsoring person, namely that person’s children and the children of their spouse, as well as ascendants (their own parents and the parents of their spouse). Therefore, residence permits may be granted to the ascendants or unmarried children of the other spouse or civil partner, subject to the custody requirement referred to in point (c) of the above provision, without it being necessary for the other spouse or partner to apply for a residence permit as well. At the same time, and for the proper application of point (a) of the above provision, it is noted that a civil partnership may have been entered into either in Greece or before a foreign authority.

It is noted that the above approach also applies in cases where, for example, the other spouse / partner of the investor either does not wish to obtain a residence permit as a family member of the investor, or is subject to a special regime (e.g. is a citizen of an EU Member State, whereas their parents do not have that status and are third-country nationals). In all the above cases, if the investor and the spouse / civil partner cease to constitute a family (due to divorce or death of the spouse / partner), it follows that the parents of the family member spouse or partner lose the right of residence as family members of the investor, since the kinship link with the sponsoring investor has ceased.

CLARIFICATION 11

Within the framework of the implementation of Article 100 of Law 5038/2023, many cases have been recorded where investors seek either to modify the invested real estate or to replace it. The cases identified and the handling thereof by the one-stop services are as follows:

• A third-country national has purchased one property (built property) and has obtained the permanent investor residence permit. Subsequently, they proceed with improvement / renovation and/or extension works on the property with a view either to exploiting it through long-term lease or residing in it, without altering the ownership status thereof. The person continues, without impediment, to retain the permanent investor residence permit, while notifying the migration authority of the changes, especially where the changes affect the extent and therefore the value of the property.
• A third-country national has purchased one property (built property) and has obtained the permanent investor residence permit. They subsequently decide to replace the property with another property which will also satisfy the provisions of Article 100 of Law 5038/2023. In this case, in order to continue without interruption to retain the permanent investor residence permit, the third-country national must take the required steps in the following order:
  Step 1: before selling the existing investment property, they proceed with a new investment in another property which also fulfils the requirements of Article 100 of Law 5038/2023 (completion of the new investment); and
  Step 2: notification to the competent one-stop service, on the one hand of the acquisition of the new property, in order to verify that the new property fulfils the above requirements. Thereafter, the investor may dispose of the first property as they wish (e.g. sale).

In such case, if the competent one-stop service verifies that the new investment, which precedes in time the sale of the first investment, fulfils the conditions of Article 100 of Law 5038/2023, the third-country national retains the permanent investor residence permit without further formality, as the condition is met that the third-country national investor continuously retains suitable real estate throughout the validity period of the residence permit, without any interruption in the ownership of suitable property, and the competent authority updates the file of the third-country national with the details of the new property.

However, if the competent one-stop service establishes that the investor proceeded with a new investment satisfying the conditions of Article 100 of Law 5038/2023 after the disposal of the real estate on the basis of which the third-country national had obtained the permanent investor residence permit, the competent one-stop service shall proceed with partial revocation, and the third-country national shall, after re-entering the country, submit an application for the initial granting of a permanent investor residence permit on the basis of the new investment in real estate. This approach is adopted because the investor does not continuously retain in their ownership real estate meeting the conditions of Article 100 of Law 5038/2023, but, after first disposing of the real estate on the basis of which the investor residence permit had been granted, they automatically cease to meet the conditions of Article 100 and therefore must lose the residence permit.

• A third-country national has purchased an undeveloped property and has obtained the permanent investor residence permit. They then decide to build on it, either through a construction contract (self-funded construction investment) or through antiparochi.

In the case of construction of a residence through a construction contract (self-funded construction investment), the third-country national investor retains the residence permit without impediment, provided that they either retain the whole of the constructed residence (which must, however, satisfy the 120 sq.m. requirement and the minimum investment value under points (a) and (b) of paragraph 2 of Article 100 of Law 5038/2023, with the investment value resulting from the sum of the purchase price of the undeveloped property and the value of the construction contract), or retain a property within the erected building which satisfies the 120 sq.m. requirement and the minimum investment value under points (a) and (b) of paragraph 2 of Article 100 of Law 5038/2023 (see, in both cases, the Joint Ministerial Decision on the supporting documents under Article 100).

In the case of construction of a residence through antiparochi, the third-country national investor retains the residence permit without impediment, provided that they retain a property within the erected building which satisfies the 120 sq.m. requirement and the minimum investment value under points (a) or (b) of paragraph 2 of Article 100 of Law 5038/2023 (see, in both cases, the Joint Ministerial Decision on the supporting documents under Article 100).

If the third-country national cannot substantiate that the real estate resulting therefrom meets the conditions of points (a) or (b) of paragraph 2 of Article 100 of Law 5038/2023, the residence permit is revoked.

CLARIFICATION 12

Within the framework of the implementation of Article 100 of Law 5038/2023, many cases have been recorded in which investors seek to change the nationality under which they obtained their residence permit. Such cases are identified and addressed as follows:

• A third-country national is the holder of two different nationalities at the commencement of the investment process and the issuance of the permanent investor residence permit. The third-country national chooses one of the two nationalities and, with that nationality, proceeds with all required actions for issuance of the permanent investor residence permit, namely:
  (a) making the investment,
  (b) granting the required authorisations,
  (c) entering Greek territory, and
  (d) submitting the residence permit application and obtaining the permanent investor residence permit.

The third-country national must continue to be licensed under the nationality originally chosen and has no possibility of changing it. A change of nationality and reissuance of the residence permit is possible only if the third-country national provides evidence of loss of the first nationality by administrative act of the third country.

• A third-country national is the holder of one nationality at the commencement of the investment process and the issuance of the permanent investor residence permit. The third-country national, under that nationality, proceeds with all required actions for issuance of the permanent investor residence permit, namely:
  (a) making the investment,
  (b) granting the required authorisations,
  (c) entering Greek territory, and
  (d) submitting the residence permit application and obtaining the permanent investor residence permit.

Subsequently, during the validity of the permanent investor residence permit, the third-country national acquires a second third-country nationality (by producing not merely a new travel document, but also the decision granting the nationality by the new third country and the new travel document). Since acquisition of the new nationality constitutes an event occurring after issuance of the investor residence permit, the investor may, if they so wish, request reissuance of the residence permit due to the change in nationality, irrespective of whether they retain the first nationality.

CLARIFICATION 13

According to paragraph 3 of Article 12 of Law 5038/2023: “… Third-country nationals legally residing in the country with a final residence title or long-stay visa may move to any category of this Code …”. This provision grants, inter alia, to holders of a permanent investor residence permit, as well as to their family members, the possibility to submit an application for change of purpose (e.g. for a residence permit for employment).

If a third-country national holding a permanent investor residence permit applies to change category under Article 12 of Law 5038/2023, the competent authority must, before proceeding with the partial revocation of the investor residence permit or the residence permits of the family members, essentially assess whether the new conditions are fulfilled, and if it finds that the new conditions are met, request partial revocation from the authority which issued the investor residence permit (if this differs from the authority examining the new application, e.g. for a work permit). The purpose of the above approach, which should be followed in all cases of application of Article 12 of Law 5038/2023, is to ensure the lawfulness of the status of third-country nationals.

CLARIFICATION 14

As you are aware, under Article 95 of Law 5038/2023, a family member of a holder of a permanent investor residence permit (child) is licensed as a family member of an investor until the age of 21, while at age 21 they may fall within the autonomous residence permit as a “bridge” permit to another migration regime. On that basis, and with a view to ensuring the swift issuance of autonomous residence permits to family members of investors, it is pointed out that the competent authority for issuing the autonomous residence permit is the one-stop service which issued the last residence permit of the third-country national as a family member of an investor.

Consequently, if, for example, a residence permit for a family member up to the age of 21 was issued by the one-stop service of the Ministry of Migration and Asylum, that service is also competent to issue the autonomous residence permit.

It is noted that the exceptions regarding representation issues, as set out in Article 10 of Law 5038/2023 and in this circular, apply not only to investors and their family members, but also to family members of investors who submit an application for the granting of an autonomous residence permit (autonomous residence permit for the period from 21 to 24 years of age).

CLARIFICATION 15

Many cases have been observed where applications for investor family members (minor children), submitted after the application of the sponsoring person and/or the other spouse / partner, are transmitted through the Migration Integrated Information System to the one-stop service in the area where the property is located. At the same time, given the operation of the Biometric Data Collection Centres, which have now made biometric collection, especially in Attica and Thessaloniki, a very rapid process, by the time the one-stop service identifies that the application was submitted to a service different from that which licensed the sponsor, the minor child may already have provided the required biometric data.

With a view to safeguarding the best interests of the minor third-country national, the authority which received the child’s application, provided that:
(a) the required biometric data have been collected, and
(b) the sponsor’s residence permit has been issued by another one-stop service,

the second authority (i.e. the authority which received the child’s application) may issue the residence permit of the minor, since otherwise (transfer of the application to the other one-stop service) the minor would have to provide the required biometric data again.

CLARIFICATION 16

As you are aware, according to paragraph 3 of Article 2 of Joint Ministerial Decision 214926/2025, for the renewal of the permanent residence permit there must be submitted, on the one hand, proof that the real estate remains in the ownership and possession of the interested party, or that the prescribed leases remain in force [supporting document 3.a)], and, on the other hand, a copy of the investor’s real estate declaration (E9), except in cases concerning long-term agreements for integrated tourist resorts or timeshare leases [supporting document 3.d)].

With a view to simplifying procedures and explaining the above, it is noted that:
(a) in the case of investment in real estate, for the fulfilment of point 3.a), the applicant satisfies the relevant condition if they submit either a recent copy of the real estate declaration (E9), which they submit in any event, or a recent cadastral extract of the property; whereas
(b) in the case of investment in long-term agreements for integrated tourist resorts or in timeshare leases, the applicant shall submit proof that the prescribed leases remain in force (a recent certificate from the Mortgage Registry or the corresponding Cadastral Office confirming that there has been no change in the ownership status of the lease).

CLARIFICATION 17

Following questions from our consular authorities, as well as one-stop services, regarding the possibility of beneficiaries of international protection falling within Article 100 of Law 5038/2023, as well as more generally within the Migration Code, we draw your attention to our document no. 19522/30.1.2025, which clarifies the following:

According to points (e) and (z) of paragraph 3 of Article 3 of Law 5038/2023, beneficiaries of international protection, as well as beneficiaries of subsidiary protection, do not fall within the scope of the Migration Code, subject to specific exceptions expressly provided therein (e.g. access to long-term resident status, access to highly skilled employment, access to residence documentation due to marriage to a Greek citizen or citizen of an EU Member State, etc.).

Specifically, the relevant provision states:
“3. This Code shall not apply: {…}
(e) to beneficiaries of international protection, except applicants for the EU Blue Card under the conditions of Chapter B of Part B, as well as persons subject to long-term resident status under Part Θ, and to applicants for international protection within the meaning of the 1951 Geneva Convention relating to the Status of Refugees, ratified by Legislative Decree 3989/1959 (A’ 201), as amended by the New York Protocol of 31 January 1967, ratified by Emergency Law 389/1968 (A’ 125), and in accordance with the Code of legislation on the reception, international protection of third-country nationals and stateless persons and temporary protection in the event of a mass influx of displaced foreigners [Law 4939/2022 (A’ 111)], except point (c) of paragraph 1 of Article 161 of this Code, {…}
(z) to persons who have been granted subsidiary protection {…}.”

It is clarified that the above provisions excluding recognised beneficiaries of international or subsidiary protection from the scope of Law 5038/2023 apply exclusively in cases where such status has been granted by the competent Greek authorities under Law 4939/2022 (Government Gazette A’ 111).

Therefore, beneficiaries of international protection (asylum or subsidiary protection) whose status has been granted either by another EU Member State or by a third country fall within Law 5038/2023 (including Article 100) and are treated like all other foreign third-country nationals, provided that they meet the applicable entry and residence conditions and do not fall within the above exceptions.

As regards submission of the required supporting documents for the granting of the national entry visa and/or the corresponding residence permit under Law 5038/2023, it is pointed out that the applicant:
(a) as regards the travel document, shall submit that which has been issued to them in the context of the international protection status (TDV); and
(b) as regards the criminal record certificate (where they appear for the obtaining of a national visa), shall submit either a criminal record certificate from the country which granted them the status, or a criminal record certificate from the country of habitual residence, if different from the country granting the status, or, taking into account their status as a beneficiary of international protection, whatever they are in a position to submit due to their circumstances, such as, for example, a certificate under Article 25 of the Geneva Convention (ratified by Legislative Decree 3989/1959, Government Gazette A’ 201).

CLARIFICATION 18

Following questions from one-stop services as well as interested third-country nationals holding permanent investor residence permits, and taking into account the above reference no. 4, it is pointed out that the permanent investor residence permit (Article 100 of Law 5038/2023) does not confer a right of access to the labour market in Greece (neither dependent employment nor self-employment). Notwithstanding this restriction, holders of permanent investor residence permits may establish companies, i.e. may be shareholders or partners and exercise corporate rights (as shareholders or non-executive members of boards of directors), provided that they do not in any case perform work for the company.

It goes without saying that the above capacities which may be held by a third-country national who is a holder of a permanent investor residence permit do not include that of legal representative of a company, nor that of executive member of the board of directors.

CLARIFICATION 19

As regards issues concerning fulfilment by third-country nationals holding permanent investor residence permits of the obligation to maintain valid insurance coverage, i.e. either private insurance in Greece or insurance from the country of origin or habitual residence, expressly covering the holder in Greece with the minimum required coverage under Joint Ministerial Decision 133692/2024:

It is pointed out that, in accordance also with Circular 6, during the procedure for the granting or renewal of the permanent investor residence permit (Article 100, Law 5038/2023), as well as the residence permit for investments in intangible securities or fixed-term deposits (Article 99, Law 5038/2023), the applicant (or their representative) must submit valid insurance at the time of filing the residence permit application, in accordance with the above.

Consequently, where, at the time of the application for the granting or renewal of the residence permit, valid private insurance or evidence of adequate foreign insurance with express reference to coverage in Greece (either specifically referring to Greece or generally referring to worldwide coverage) has not been submitted, the authority shall immediately issue a request for submission of a supplementary supporting document (insurance) within a strict time limit of thirty (30) calendar days. This reduced period, compared to the Code of Administrative Procedure, is introduced exceptionally, because in practice the relevant condition must be met at the time of submission of the residence permit application and not at a later stage.

If such document is not submitted within the above strict deadline, the application shall be rejected, while allowing it to be submitted either in the context of an appeal / request for review (if the insurance had been issued in time but not submitted), or in the context of a new residence permit application (if it had not been issued before submission of the application).

CLARIFICATION 20

Following inquiries by third-country nationals as well as one-stop services regarding the possibility of properties, in all categories of points (a), (b), (c) and (d) of paragraph 2 of Article 100 of Law 5038/2023, falling within Article 100 where the process of connection to utility networks (especially electricity) has not yet been completed, the following are pointed out:

1. i) in cases (a) and (b) of paragraph 2 of Article 100 of Law 5038/2023, completion of the investment often occurs even before the construction of the property (e.g. off-plan purchase from a development company and full payment of the property with corresponding registration of the deeds and the deed of payment / settlement, if required). Therefore, no documentation is required proving connection of the property to utility networks;
2. ii) in case (c) of paragraph 2 of Article 100 of Law 5038/2023, which concerns property / properties resulting from a change of use to residential use, the change of use is certified by the engineer’s certificate pursuant to Joint Ministerial Decision 214926/2025, which certificate is based on the “review of the building permit or the approval of small-scale building works and/or file update and/or revision of the building permit (the relevant act is selected, such as building permit, file update or other)”. Therefore, completion of the change of use is related to and certified by the above and not by connection of the property to utility networks, which may be delayed for a substantial period and are not requested by the one-stop service for issuance of the permanent investor residence permit; and

iii) in case (d) of paragraph 2 of Article 100 of Law 5038/2023, which concerns property / properties resulting from restoration of a listed building, completion of the restoration is certified by the engineer upon renewal of the residence permit and, therefore, no equivalent document / supporting evidence is requested.

Accordingly, in all the above cases the one-stop services do not request evidence regarding the possible connection of the property to utility networks, but examine only the supporting documents provided for in Joint Ministerial Decision 214926/2025.

CLARIFICATION 21

For the purpose of clarifying issues relating to the common conditions / common supporting documents accompanying applications for initial residence permits and/or renewals (for all categories of residence permits submitted under Law 5038/2023 and Presidential Decree 106/2007), and taking into account that incorrect practices by applicants or their authorised representatives have been recorded, it is pointed out that in all cases of submission of an application (except in the case of persons lacking a passport) there must be submitted a “certified copy of a valid passport or travel document recognised by our country, together with the required valid national or uniform entry visa where such visa is required, subject to point (a) of Article 8 of Law 5038/2023”.

Whether the application is submitted electronically or in person (where so provided), the applicant, at the time of submission, shall submit a certified copy of the entirety of their valid passport or valid travel document, which in both cases must be recognised by our country.

Certification of the passport or travel document may be carried out by any public authority or by a lawyer acting under a power of attorney, subject in all other respects to the applicable provisions.

It is pointed out that, where the applicant or authorised representative submits either only part of the passport or a document lacking the certification required by law, the competent one-stop service shall request, through the supplementary documents procedure, the proper certified copy of the travel document or passport.

CLARIFICATION 22

It is recalled, so as to avoid any incorrect information, that the suspension of the submission and approval of new applications by citizens of the Russian Federation and Belarus continues to apply in respect of Articles 96 to 100A of Law 5038/2023, including family members and applications for approval / certification of investment, following the corresponding suspension of cases under Articles 16 and 20B of Law 4251/2014, in accordance with document no. 186958/1.4.2022 of the Minister of Migration and Asylum. The above suspension also applies to cases of applications for inclusion under the above articles through the change-of-purpose procedure pursuant to Article 12 of Law 5038/2026, as that procedure essentially constitutes a quasi-initial grant rather than a renewal of the residence permit.

CLARIFICATION 23

Finally, with a view to safeguarding the credibility and integrity of our country’s investment attraction programmes through migration, and especially that concerning the granting of the permanent investor residence permit due to investment in real estate (Article 100, Law 5038/2023), it is pointed out that our services are in close cooperation with the competent supervisory and law enforcement authorities.

In this context, where our service identifies or receives complaints regarding practices connected either with misleading advertising in Greece and/or in countries of origin vis-à-vis prospective investors, concerning the conditions for the granting of the permanent investor residence permit (e.g. amount of consideration, manner of payment of the consideration by the investor, rights conferred, prohibition on leasing through sharing-platform arrangements), or with unfair practices connected to the implementation of the investment (e.g. cases of unjustified / unsubstantiated transfer of funds before or after the investment), which lead to the obtaining of a residence permit with an investment substantially lower than the minimum amount required by law in the particular case, it shall refer the relevant complaints to:
(a) the competent tax authorities and/or law enforcement authorities, as applicable; and
(b) the Hellenic Anti-Money Laundering Authority, for their further actions.

Where such practices are established, which circumvent and run contrary to the provisions and restrictions of Article 100 of Law 5038/2023, it is noted that they result, in addition to the specific sanctions under Article 100 of Law 5038/2023, in revocation of the residence permits granted, in accordance with the applicable provisions.