From September 1st, 2024, significant changes have been implemented to the options for obtaining the Greek Golden Visa, following an initial announcement made in April 2024 regarding the amendment of the law. These updates reflect Greece’s ongoing efforts to adapt its residency-by-investment program to current market conditions and enhance its appeal to foreign investors.

Four types of real estate investment options:

• Real estate investments in Key Regions (Art.100§2.A Law 5038/2023): Investors must now make a minimum investment of 800,000 EUR in specific high-demand areas, including the Region of Attica, the Region of Thessaloniki, as well as ALL Greek islands with a population of over 3,100 inhabitants. This investment must be directed toward a single property with a minimum surface area of 120 square meters. These areas are known for their strategic economic importance and popularity among international buyers, which has led to an increase in the required investment threshold in these regions.

• Real estate investments in the rest of Greece (Art.100§2.B Law 5038/2023): For properties located outside of these high-demand areas, the minimum investment requirement is set at 400,000 EUR. This investment must also be directed toward a single property with a minimum surface area of 120 square meters. This option provides opportunities for those interested in more affordable areas across Greece, while still contributing to the country’s real estate sector through high-value investments.

• Investments in properties resulting from change of use – Commercial to Residential conversions (Art.100§2.C Law 5038/2023): In cases where the investor seeks to convert a commercial property (such as industrial buildings or other non-residential properties) into a property of residential use, the minimum investment required is 250,000 EUR. This applies regardless of the property’s location (it could even be in the centre of Athens), and there is no restriction on the surface area either (no minimum required). This option enables investors to contribute to urban renewal and transformation projects, particularly in areas where the conversion of commercial spaces into residential units can meet the growing demand for housing.

• Investments in properties resulting from the restoration of Listed Buildings (Art.100§2.D Law 5038/2023): A unique opportunity exists for those interested in properties of historical significance or special cultural interest. For buildings that are classified as listed (meaning they are under special protection due to their historical value), the minimum investment threshold remains at 250,000 EUR. This applies regardless of the property’s location or surface area, so it gives a variety of options, and allows investors to participate in the restoration or reconstruction of historically important structures, thereby contributing to the preservation of Greece’s cultural heritage.

Key pivotal points:

The Conversion Must be done after 05/04/2024

The amendments implemented in 2024 indicate that investors retain the option to invest in units at the previous threshold of 250,000 EUR, provided that the designated units have been repurposed from commercial to residential usage. As the program progresses, investors may invest in such ventures, as long as the conversion occurs after the 5th of April, 2024, which is when the Golden Visa Law was amended to include this option.

Investors Exception for Short – Term lease
While the new Golden Visa Law prohibits the short-term lease of properties via online platforms such as Airbnb for new investors, there are beneficial exceptions: Current Golden Visa holders are not affected by this prohibition, and their properties are still eligible for short-term rental through online platforms, such as Airbnb. Moreover, properties acquired prior to or during the current transitional period (namely, by investors who paid a 10% deposit by the 31st of August, 2024 and conclude this purchase by the 31st of December, 2024) will continue to be eligible for short-term rental through online platforms, such as Airbnb.

The ability to modify existing commercial units by adding additional ones
The addition of new floors to industrial buildings, or new buildings on plots with industrial structures converted to residential use, will also qualify for the 250,000 EUR investment threshold, with no restrictions on square footage. This same rule applies to listed/preserved buildings.

Short-Term Rental Opportunities for Apartments in Touristic Serviced Projects
Apartments in developments designated as touristic serviced apartments can be leased to property management companies under a commercial lease, which can then offer them for short-term rentals, as long as there are other services provided (e.g. cleaning services), and only if the property has not been converted from commercial to residential use.

Prohibitions and Fines of the New Golden Visa Law:

1) Horizontal restriction for all properties (Article 100 Par. 2.a/2.b/2.c/2.d):

Renting and subletting to sell the property on the short-term rental market (less than 60 days) is prohibited during the residence permit period. Violating the above prohibitions results in 1) the revocation of the residence permit and 2) the imposition of a fine of 50,000 EUR.

2) Properties resulting from a conversion of use (Article 100 Par. 2.c):

i) Leasing and subletting to place the property on the short-term rental market (less than 60 days) is prohibited.

ii) The commercial lease of the property to use it as a company headquarters or branch is prohibited.

Violating the above prohibitions results in 1) the revocation of the residence permit and 2) the imposition of a fine of 50,000 EUR, for each violation. Violation of multiple prohibitions may result in cumulative fines.

3) Properties resulting from the restoration of a listed building (Article 100 Par. 2.d):

i) Leasing and subletting to place the property on the short-term rental market (less than 60 days) is prohibited. Violating the above prohibition results in 1) the revocation of the residence permit and 2) the imposition of a fine of 50,000 EUR.

ii) The property resale is prohibited before the full completion of the restoration and rehabilitation of the listed building. Violating the above prohibition results in 1) the revocation of the residence permit and 2) the imposition of a fine of 150,000 EUR.

iii) The full completion of the restoration and rehabilitation of the listed building is additionally a condition for the first residence permit renewal (after 5 years). Failure to comply with the above condition results in 1) the revocation of the residence permit and 2) the imposition of a fine of 150,000 EUR.