GREECE GOLDEN VISA PROGRAM: LEGAL FRAMEWORK AND COSTS (2025-2026)

M. Sami Akbeniz
Jan 5
16 min read

1. Executive Summary and Strategic Overview

Greece's "Investor Permanent Residency" (known as the Golden Visa) has become one of Europe's most popular investment-based residency programs since its inception in 2013. The program has injected over €5.5 billion in foreign direct investment into the Greek economy, particularly through the real estate sector. However, 2024 and 2025 mark a turning point in the program's history. The Greek government has transformed the program from a mere capital attraction tool into a sophisticated social policy instrument aimed at alleviating the country's chronic housing crisis and promoting urban transformation.

This report presents an up-to-date, comprehensive, and technical analysis prepared in light of the Immigration Law No. 5038/2023 and the radically amending Law No. 5100/2024, as well as the Joint Ministerial Decision No. 214926/2025 of November 2025. The main finding of the report is that the Greek Golden Visa program has not ended, but has "transformed." The traditional "buy an apartment in the city center, create an Airbnb" model has been replaced by a strategy of "converting commercial properties into residential properties" or "investing in rural/developing regions."

For Turkish investors in particular, beyond geographical proximity and cultural similarities, the need for Euro-based asset diversification and visa-free access to the Schengen area makes Greece a primary target. However, the new regulations, including the "short-term rental ban" (Airbnb ban) and regional thresholds of up to €800,000, necessitate a much more thorough legal and technical due diligence process for investors.

2. Legal Basis of the Program and Current Legislative Framework

The Greek Golden Visa program is based not on a single law, but on a series of complementary legal regulations that are updated over time. The key texts that investors and legal professionals should refer to are as follows:

2.1 Fundamental Laws and Articles

Law No. 4251/2014 (Former Immigration Law): This law laid the initial foundations for the program, regulating the right to a 5-year residence permit with a €250,000 investment (Article 20B). Many of the practices in effect today originate from this law, although it has been largely updated.
Law No. 5038/2023 (New Immigration and Social Integration Law): Forms the backbone of the existing legal framework. Specifically , Article 100 regulates the conditions, application procedures, and renewal requirements for "Investor Permanent Residence Permit" ( B.5 visa). This law modernized the system by repealing the 2014 law.
Law No. 5100/2024 (Article 64): This is the most critical regulation that came into force on April 5, 2024, and changed the rules of the game. With this law, investment thresholds were regionally differentiated (Tiered Investment Zones), a "single property" requirement was introduced, a minimum square meter requirement (120 m²) was set, and most importantly, an exceptional path of €250,000 was opened for the conversion of commercial properties to residential properties .
Joint Ministerial Decision (JMD) No. 214926/2025 (November 11, 2025): This decision clarifies the technical details, particularly for transformation projects and historical monument restorations. It standardizes the format of technical reports that engineers must prepare, how to prove the "non-industrial use" condition, and which documents notaries must request during title transfers .

2.2 Purpose of the Legislation and "Housing Crisis" Strategy

The government's primary motivation for the legal changes is "to bring idle stocks back into the economy and increase the housing supply." According to official data and reports from the Athens University of Economics and Business (AUEB), more than 2.2 million homes are vacant or idle throughout Greece. In the Attica region alone (including Athens), approximately 500,000 properties are unused.

In response to foreign investors buying up ready-to-buy homes in central Athens, driving up prices and exacerbating housing problems for locals, the government adopted the following strategy:

Price Increase: Raising the threshold for purchasing ready-to-buy properties to €800,000 in sought-after areas (Athens, Thessaloniki, Mykonos, Santorini, etc.) to attract foreign investors to the luxury segment.
Conversion Incentive: To encourage the conversion of idle commercial (office, shop, warehouse) or industrial properties into residential properties, the threshold is set at €250,000. This aims to create a new supply of housing to the market instead of depleting the existing housing stock . 8

2.3. Analysis of "2.2 Million Vacant Homes"

The data frequently cited in the media and industry reports, "There are over 2.2 million vacant homes in Greece," is accurate, but it is a misleading indicator for Golden Visa investors .

Source and Nature of Data: According to analyses by AUEB and the Eteron Institute, approximately 2.27 million homes nationwide are classified as "empty" or "abandoned." However, a large portion of this figure consists of secondary residences (summer houses), abandoned rural homes, and properties fragmented through inheritance that are legally unsaleable. 3
Regional Distribution: Approximately 500,000 of these residences are located in the Attica region (including Athens). However, since these properties already have "residential" permits, they do not fall under the discounted Golden Visa category of €250,000 under the new law. An investor wishing to purchase a vacant apartment in central Athens would have to pay €800,000 if the area is in a "high demand " zone (which is the case for all of Athens) .
Conclusion: The 2.2 million stock is not a "pool" for investors, but an indicator of a "crisis" that the government is trying to resolve. This is not the data that investors should focus on.

2.4. Real Opportunity: Statistical Analysis of Idle Commercial Property Stock

The main potential for investors lies in commercial properties that can be accessed through "Change of Use" at levels starting from €250,000 . While there is no central national database for these properties, sectoral research and "louketa" reports reveal the volume of stock awaiting conversion.

2.4.1. Retail and Store Stock Vacancy Rates

In Greece, the economic crisis between 2010 and 2018 and the digitalization of retail created a huge void in ground-floor retail spaces in central Athens. While these properties are too small or inefficient for modern retail, they are ideal for residential conversion (loft apartments).

Vacancy Rates in Central Athens: Studies show that commercial property vacancy rates in Athens' central commercial axes (around Kypseli, Exarchia, Patission, Omonia) vary between 25% and 50% depending on the area . 7
District-Based Commercial Idle Inventory Data:
Kypseli: In Kypseli, one of Athens' most densely populated and historic districts, the closure rate of shops on the main shopping streets (Drosopoulou, Aghias Zonis, etc.) reached 40% during the crisis. 7 Many of these shops are still derelict and are a primary target for conversion into residential buildings.
Exarchia and Neapoli: In this area alone, according to 2013 data, more than 460 vacant ground-floor commercial spaces were identified, representing approximately 43% of the total stock. 7
Piraeus: Although the vacancy rate on the main streets of the port city of Piraeus is around 16%, there is a "hidden" underutilized stock, particularly in former office buildings where the shipping industry has relocated. 7

2.4.2. The "Dual" Structure and Transformation Potential in the Office Market

The Athens office market is sharply divided. While there is high demand for sustainable, modern (Grade A) office space (less than 5% vacancy), there is a significant surplus of older office stock (Grade B and C) built between 1970 and 1990.

Volume Awaiting Conversion: Many older apartment buildings (polykatoikia) were previously used as offices but are now vacant due to substandard conditions. According to industry projections, the conversion of such commercial properties alone is expected to add between 3,000 and 5,000 new residential units to the Athenian market within the next three years ( by 2027).
Current Stock: There are approximately 1,000 to 2,000 converted units currently about to enter the market . While this figure may seem small compared to the "2 million vacant homes" data, it represents the real "golden" stock accessible to Golden Visa investors, backed by legal incentives .

In summary: The investor's target is not the problematic 2 million-unit housing complex, but the tens of thousands of derelict shops and former office floors in central Athens. These properties are strategically important because of their central location in the city (near the metro) and their eligibility for the €250,000 exemption.

However, for investors willing to allocate this budget, a viable strategy is to purchase multiple affordable and vacant properties, renovate them, rent them out, and apply for a Golden Visa by reaching the €800,000 investment threshold in total.

2.3 Transitional Provisions and Extension of Time (Grandfathering)

Legislators have provided transition periods to ensure that sudden changes do not undermine ongoing investments. According to the latest regulation:

Investors who pay a deposit of at least 10% of the property price and sign a preliminary agreement (notarized or private contract) by August 31, 2024 , can benefit from the old limits (€250,000 or €500,000 depending on the region).
The deadline for these investors to complete their purchases has been extended to February 28, 2025 (and in some cases , until April 2025) due to a recent amendment. Those who fail to complete the title transfer by this date will be subject to new higher limits (400k/800k).

3. Investment Thresholds and Regional Map

As of 2025, the Greek Golden Visa program is divided into three different categories instead of a single investment amount. One of these three paths must be chosen according to the investor's budget and risk tolerance.

3.1 Zone A: €800,000 (High Demand Zones)

This category covers areas where the real estate market is at its busiest and housing prices are at their highest.

Scope:
The entire Attica Administrative Region (Athens city center, northern and southern suburbs, Piraeus port and surrounding areas).
Thessaloniki Regional Unit.
Mykonos and Santorini islands.
All other islands with a population of over 3,100 (e.g., Crete, Rhodes, Corfu, Paros, Naxos, etc.). 3
Conditions:
Minimum Investment: 800,000 Euros .
Single Property Rule: The investment amount must be paid for a single property. It is forbidden to reach this amount by purchasing multiple small apartments (e.g., two apartments worth €400,000 each).
Square Meter Requirement: The net usable area of the main property must be at least 120 m² .

3.2 Zone B: €400,000 (Other Zones)

It covers all Greek territory except for "Region A" listed above.

Scope: Peloponnese, Halkidiki, Thrace, Epirus region, and small islands with a population under 3,100.
Conditions:
Minimum investment: €400,000 .
The Single Property Rule: Investment should be made in a single property.
Square Meter Requirement: The property must be at least 120 m² .

3.3 Zone C: €250,000 (Conversion and Restoration Exemption)

This category includes "value creation" projects that the government wants to encourage, and they are location-independent . This means that even if the property is in the heart of Athens (Kolonaki, Syntagma) or in Mykonos, the threshold is €250,000 for properties meeting the following conditions.

Category 1: Commercial -> Residential Conversion (Change of Use):
The property must be registered as "commercial" (office, shop, warehouse, workshop, etc.) in its original license.
Legally converting the property into a residential property (Change of Use permit) after the purchase and before applying for a residence permit.
Important: If the property is an industrial building, proof that no industrial activity has been carried out in it for the past 5 years (via electricity disconnection records or tax records) is required .
Category 2: Restoration of Historic Buildings (Listed Buildings):
The property is registered by the state as a "listed building" requiring protection.
For the residence permit to be renewed at the end of the first 5 years, the restoration must be completed.
Advantages:
Minimum investment: €250,000 .
No Square Meter Limit: The 120 m² requirement does not apply in this category. You can convert a 50 m² office into a residence and purchase it.
No regional restrictions: Valid throughout Greece.

4. Who is Eligible? Family Coverage and Rights

The Greek program is one of the most generous in Europe regarding "Extended Family" reunification.

4.1 Rights Holders

In addition to the main applicant, the following family members can also obtain a residence permit through the same investment:

Spouse: A legally married spouse or a partner with whom a "Cohabitation Agreement" has been signed before a notary in Greece (including same-sex partners). 11
Children: Unmarried children under the age of 21.
Detail: Children's cards are not cancelled when they turn 21, but they can extend them until they are 24 by proving they are students. After the age of 24, they lose their rights unless they make an independent investment. 12
Parents: The primary investor's parents AND the spouse's parents. There is no age limit for parents, and they do not need to prove that they are financially dependent on the investor. 12

4.2 Rights and Limitations

Validity Period: Cards are issued for 5 years and are renewed for life in 5-year periods as long as ownership is maintained.
Residency Requirement: There is NO requirement to live in Greece . There is no need to even enter or exit the country to renew the card (a single visit for biometrics is sufficient).
Travel/Schengen: Cardholders can travel visa-free for 90 days within a 180-day period in the 29-country Schengen area. This card is not a "travel visa" but an EU residence permit, therefore they are treated like EU citizens at border crossings.
Right to Work: The Golden Visa does not grant permission to work as a salaried employee . However, investors can establish companies in Greece, become shareholders, and serve as Board Members (CEOs). In this way, they can earn commercial income (dividends). 12
Education and Health: Children can access Greek state schools and universities on the same terms as Greek citizens. Access to the state healthcare system requires either private health insurance or social security contributions.

4.3 Property and Residence Relationship

Sale: When the property is sold, the Golden Visa is cancelled. However, if you sell the property to another Golden Visa applicant, the right is transferred to them.
Transfer: It is possible to transfer property to children. If a parent transfers property to a child over the age of 21, the child becomes the "Primary Investor," while the parents retain their residency status by switching to "Dependent Parent" status.
Joint Ownership: If a property is valued at €800,000 (or the relevant threshold) and two people are purchasing it jointly, each person's share must meet the threshold (i.e., a total of €1.6M). The only exception is spouses; spouses can jointly purchase an €800,000 property and both receive a Golden Visa.

5. Application Timeline: Step-by-Step Process (Practical Flow)

The time it takes for an investor to "make a decision" and "put the card in their pocket" is, on average, 4-9 months. The process varies depending on the density of the area (Athens central offices are busier, while peripheral offices like Piraeus or Pallini may be faster).

Step 1: Preparation and Property Selection (1-2 Months)

Property Selection: The investor (or their representative) selects the property.
Legal Review (Due Diligence): The lawyer examines the property's title deeds, mortgages, liens, encumbrances, and zoning status. (This stage is very critical).
Tax Number (AFM): An AFM number is obtained from the Greek tax authorities for the investor (takes 1 day).
Bank Account: (Optional but recommended) An account is opened in Greece for money transfers. (Difficulties for Turkish citizens are explained below).

Step 2: Purchase and Payment (1 Month)

Preliminary Agreement: 10% deposit required.
Full Payment: The full sale price must be paid before or at the time of signing the final contract in the presence of a notary. Payment must be made via bank transfer (wire transfer, check, POS) and the source of the funds (white money) must be transparent.
Title Transfer (Notary): The sales contract is signed in the presence of a notary.
Land Registry: The contract is registered with the Land Registry Office and a "Registration Certificate" is obtained. Applications cannot be submitted without this document.

Step 3: Golden Visa Application (1-2 Weeks)

Online Application: The lawyer uploads all documents (Title Deed, Insurance, Passport, Family Documents, Photographs) to the Immigration Ministry's online platform.
Blue Paper: The system automatically generates a "Temporary Residence Permit" (Blue Paper) as soon as the application is submitted.
Function: With this document, the investor can legally stay in Greece and enter and exit the country without a visa. However, it does not grant the right to travel to other Schengen countries. 12

Step 4: Biometrics and Card Printing (3-8 Months)

Appointment: The lawyer schedules an appointment for fingerprinting (biometrics). Due to high demand in Athens, this appointment may be scheduled months after the application is submitted.
Visit to Greece: The investor and their family will travel to Greece on the appointment day to provide fingerprints.
Card Printing: After biometrics, the file is reviewed, approved, and the card is printed.
Delivery: The cards are given to the lawyer, who can then send them to the investor via courier.

Critical Risk Point: The passport must not expire between the application and card issuance. Also, attention must be paid to the age limit for children.

6. Real Estate Purchase Procedure and Technical Details

In Greece, unlike in Türkiye, the real estate purchase process is centered around notaries and lawyers. The land registry office is merely the registration authority; the "behind-the-scenes" aspects of the transaction are handled by lawyers and notaries.

6.1 The Attorney's Duty (Due Diligence)

This is the most vital part of the purchase. The lawyer oversees the following:

Chain of Ownership: Whether all changes of ownership of the property in the last 20 years have been legal.
Liabilities: Mortgage, seizure, easement, tax debt, third-party claims (Bari - Mortgage Registry check).
Engineering Inspection: Checking whether the actual condition of the property is consistent with the permit project (checking for illegal constructions). In Greece, the sale of properties with illegal additions (and those not legalized) is prohibited. 13

6.2 The Notary's Duties

A notary is a public official who, on behalf of the state, verifies the legality of a transaction.

He prepares the sales contract.
It confirms that all taxes (Transfer Tax) have been paid.
The engineering department checks the "Energy Performance Certificate" and the "Legal Compliance Certificate".
The buyer and seller's identities and payment receipts are included in the contract.
He forwards the transaction to the Land Registry Office.

6.3 Additional Procedures in Commercial -> Residential Conversion

If the investment is for a transformation project at the €250,000 threshold, the following documents must also be included in the Notary and Ministry files:

Engineer's Technical Report: A standard report documenting that the property's intended use has been changed from "commercial" to "residential," that the necessary permits have been obtained (Small Scale or Full Construction Permit), and that the process was completed after April 5, 2024 .
Industrial History Document: If it is an old factory/workshop, proof that industrial electricity has been disconnected for the last 5 years or that no industrial activity has been reported to the tax office.

7. Costs: Item-by-Item Analysis of the €250,000 Conversion Project

The table below shows the estimated total cost for an investor purchasing a commercial-to-residential property worth €250,000 . (Assuming VAT is suspended until the end of 2025 and a 3.09% Transfer Tax is paid). 14

Table 1: Initial Investment Cost Table (2025)

Expenditure Item	Rate / Explanation	Amount (€)	Payment Time
Property Sale Price	Investment Amount	€250,000	At the Signing of the Contract
Property Transfer Tax (FMA)	3.09% (based on price)	€7,725	Pre-contract
Notary Fees	~1 % (+24% VAT)	~€3,100	At the Signing of the Contract
Land Registry Fee	~0.8% (+VAT)	~€2,000	Post-contract
Attorney's Fee	~1.0% + 3.000 € (+24% VAT)	~€6,820	Throughout the Process
State GV Application Fee	Main Applicant	€2,000	At the Time of Application
Family Members Fee	Per person (over 18 years old)	€150	At the Time of Application
Card Printing Fee	Per person	€16	Card Printing
Health insurance	Per capita/annual (Average)	~150 €	Before Application
Translation/Apostille	Depending on the volume of documents	~500 - 1,000 €	Preparation Phase
TOTAL ADDITIONAL COSTS	(Excluding property cost)	~22,500 - 23,000 €
TOTAL		~272,500 - 273,000 €

Note: If construction costs for property conversion are to be paid separately, and this cost is not included in the "Property Price," it will not count towards the Golden Visa threshold. This table is based on a "Turnkey" sales scenario of €250,000.

Regular Annual Expenses (& Income)

ENFIA (Property Tax): Approximately €300–500 per year
Accounting Services: €100–200 per year (for tax filing)
Common Charges (Building Maintenance Fees): €30–100 per month depending on property type
Guaranteed Rental Income: €7,500/year × 3 years = €22,500
- After income tax: €19,125 net
- Excluding property tax and accounting costs
Self-managed Properties (Non-guaranteed): Rental yield may reach 4–5% annually

Annual Rental Income and Expense AnalysisFor a property valued at €250,000 – assuming a 3% guaranteed rental yield

Item	Amount (€)	Description
Annual gross rental income	7,500	Based on 3% rental yield
Income tax (15%)	-1,125	For income up to €12,000
ENFIA (property tax)	-400 (approx.)	Estimated average
Accounting service fee	-100	Annual accounting cost

Total annual expenses	-1,625
Annual net rental income	5,875	Net income after tax and expenses

8. Commercial to Residential Conversion: The New Market Reality (Data & Analysis)

The government's goal of "bringing idle properties back into the economy" has found a real response in the market.

8.1 Stock and Capacity

Official statistics show that there are over 2 million vacant properties across Greece, some of which are derelict former office stock, ground-floor shops, and small workshops in Athens. Ground and semi-ground floors of buildings constructed in the 1960s and 70s in central Athens (Kypseli, Patission, Metaxourgeio) have been vacated due to the rise of e-commerce. This stock is an ideal source for the €250,000 Golden Visa .

8.2 Significant Impact and Figures

Application Statistics: In 2024, 9,289 new Golden Visa applications were submitted (a record level). This represents a 10% increase compared to 2023. The number of pending applications is approaching 50,000 .
Conversion Trend: According to market observations, because the €800,000 threshold is considered too high, the vast majority of investors (in the 60-70% range) are turning to conversion projects priced at €250,000. This leads to a rapid depletion of idle stock and an artificial increase in the prices of such "project" properties. 17

9. Banking and Special Circumstances for Turkish Citizens

The biggest operational challenge for Turkish investors is the process of opening a bank account in Greece.

9.1 Challenges and AML (Anti-Money Laundering) Controls

Greek banks are exercising extra "enhanced due diligence" towards customers with Turkish passports due to the EU's strict AML directives and Turkey's past fluctuations on the FATF (Financial Action Task Force) list. 18

9.2 Practical Process

Physical Presence Requirement: Many banks (Eurobank, Piraeus, etc.) require the investor to be physically present at the branch for signature verification when opening an account. While opening an account with a power of attorney is theoretically possible, in practice, banks' compliance departments scrutinize power of attorney documents very strictly and may reject them. 20
Required Documents (All Apostilled and Translated):
Passport.
Proof of residence address in Türkiye (Latest electricity/water bill or Population Registration Certificate).
Tax Identification Number (TIN) document.
Proof of Income (Critical): Payslip, tax return, or dividend statement. The bank wants to see definitively that the money coming to Greece is legal income that has been "declared and taxed".
Phone bill (proof of mobile phone ownership). 20
Duration: Account opening and compliance verification may take 1-3 weeks after document submission.

10. Rental Restrictions and Risk of Loss: The Airbnb Ban

The most significant restriction introduced by Law No. 5100/2024 is the ban on short-term rentals (Airbnb) .

Rule: Properties acquired under the Golden Visa program (especially those in the conversion category and those acquired after the new law came into effect) CANNOT be rented out for short-term (less than 60 days) through platforms such as Airbnb and Booking.com .
Penalty: Violation of this rule will result in the cancellation of the residence permit and an administrative fine of € 50,000 .
Impact on Investors: Investors should now focus on the lower but more stable long-term rental (3 years and above) model, rather than the Airbnb model which promises "high returns." Long-term rental yields in Athens range from 3% to 5% gross .

11. Market and Policy Risk: "Will the Government Back Down?"

11.1 Past Experiences

Although Greece frequently changes the program rules (a 500k increase in 2023, an 800k increase in 2024), it has always adhered to the principle of "grandfathering ." The rights of investors who have already applied or paid a deposit have not been retroactively revoked.

11.2 Possible Scenarios

Program Cancellation: The EU Commission continues to pressure against the "Golden Visa" programs (Spain and Portugal examples). Although this program is vital for the Greek economy (40-50% of FDI), there is a risk that in the long term (3-5 years) the program will be completely closed or transformed into just a "grant/investment fund" model.
Existing Files: Files for which applications have been submitted are secure. Those who have received their cards can renew them as long as they do not sell the property.
Strategy: A "wait-and-see" approach is currently risky. As thresholds are constantly rising, it is recommended that prospective investors quickly assess the current "transition period" or "€250,000 conversion exemption" windows.

12. Conclusion and Recommendations

The Greek Golden Visa program, as of 2025, is a structure stuck between "opportunity" and "technical details".

Opportunity: The €250,000 conversion route continues to offer the most affordable residency in Europe. Acquiring property and residency at this price is still very attractive, especially in a metropolis like Athens.
Attention: This route requires far more complex technical and legal processes (engineering report, change of use, industrial background check) than purchasing a standard apartment.
Recommendation: It is essential for investors to work not only with real estate agents focused solely on "sales," but also with "engineer-lawyer" teams who are knowledgeable about the technical and legal aspects of the process and experienced in transformation projects. Furthermore, due to the Airbnb ban, it is necessary to realize expected returns and focus on long-term rentals.