What Does Circular 1/2026 Mean for the Greek Golden Visa?
Greek Golden Visa: What Circular No. 1/2026 Means for Investors, Developers and Their Advisors
May 1st, 2026.
For more than two years, investors, developers, lawyers and one-stop service officers have been navigating the new Greek Golden Visa framework under Article 100 of Law 5038/2023 (as amended by Law 5100/2024) with more questions than answers. Which properties qualify under the €250,000, €400,000 and €800,000 tiers? How is the 120 sq.m. threshold measured when parking spaces and storage rooms are thrown in? What happens to a residence permit if the investor replaces the property, changes nationality, or inherits part of the real estate?
On 22 April 2026, the Greek Ministry of Migration and Asylum issued Circular No. 1/2026, a long-awaited interpretative document that addresses precisely these questions – together with a clear warning to the market that circumvention schemes will no longer be tolerated.
Below, we unpack the key points of the Circular and what they mean in practice for clients considering, renewing, or restructuring a Golden Visa investment in Greece.
THE HEADLINE MESSAGE: ENFORCEMENT IS TIGHTENING
Before getting into the technical detail, it is worth noting the tone of the Circular. Alongside the welcome clarifications, the Ministry is signalling unambiguously that:
– practices involving the return of funds to the investor after the transaction;
– artificial reduction of the real investment amount; and
– misleading advertising to prospective investors abroad regarding the true conditions of the programme,
may trigger referrals to the Hellenic Anti-Money Laundering Authority, the tax authorities and law enforcement, and ultimately lead to revocation of residence permits. For serious investors and reputable advisers, this is actually good news: it reinforces the credibility of the programme and levels the playing field.
The three investment tiers, clarified
Minimum investment value depends on the location and nature of the property.
€800,000
for real estate in the Region of Attica, the Regional Unit of Thessaloniki, the
islands of Mykonos and Thira, and islands with more than 3,100 inhabitants.
€400,000
for real estate in all remaining areas of Greece.
€250,000
for two special categories: (i) properties whose use is converted into
residential; and (ii) listed buildings requiring restoration or reconstruction.
Two structural restrictions
The 120 sq.m. threshold does not apply to undeveloped land without a building permit, nor to the two €250,000 categories.
One property
The investment must be made in one single property.
120 sq.m. minimum
For built properties in the €800,000 and €400,000 tiers.
1. How the 120 sq.m. rule really works
The Circular gives two practical examples that every investor should understand:
Two co-investors, one property. If two investors buy a 130 sq.m. apartment in Attica for €1.6 million in 50/50 undivided co-ownership, both qualify. The 120 sq.m. threshold is measured on the property as a whole, not per investor’s share.
Parking and storage do not count. An investor buying a 118 sq.m. apartment for €1 million in Attica, plus a 12 sq.m. parking space and an 8 sq.m. storage room under the same deed, does not qualify. The main areas remain below 120 sq.m., and ancillary spaces are not added to the main-area surface.
However – and this is a key practical point – ancillary spaces such as parking and storage can be counted towards the minimum investment value, provided they are purchased under the same deed, are located in the same building, and are either accessories to the main property or independent horizontal properties within it.
2. The €250,000 “change of use” route: narrower than many assume
The €250,000 change-of-use option has been one of the most attractive, and most misunderstood, features of the new regime. Circular 1/2026 closes several loopholes.
What qualifies: Properties genuinely converted from a non-residential use (e.g. commercial, office, industrial) into residential use. Properties resulting from vertical additions or extensions to existing non-residential buildings whose use is changed to residential. New independent residential buildings added to plots where existing non-residential buildings change use to residential.
What does not qualify: Properties that were already residential at the commencement of Law 5100/2024 (5 April 2024), were converted to another use, and are now being converted back to residential. This cannot be used to “refresh” a residence into a €250,000 investment. Future properties: if a building permit is issued for offices after 5 April 2024 and then amended mid-construction to build residences instead, the change-of-use route is not available. The law requires a change of use of an existing property, not a paper exercise at permit level. Handicraft or workshop buildings: the five-year non-operation rule for industrial buildings does not apply to these, because they are not treated as industrial buildings at all. The change of use may be carried out either by the purchaser or by the seller, but it must be completed before the application for the permanent investor residence permit is submitted. The date of issuance of the relevant act (building permit, small-scale works approval, permit update or revision) determines whether the work falls after 5 April 2024.
A practical industrial-to-mixed-use scenario An old industrial building is converted into a mixed-use property. Some of the resulting horizontal properties are residences; others are offices or shops. Under the Circular: The residences qualify under the €250,000 change-of-use rule. The non-residential units must meet the standard €400,000 or €800,000 threshold (as applicable by location) and the 120 sq.m. main-area rule.
The “once only” rule for €250,000 properties: A property that has already benefited once from the €250,000 change-of-use or listed-building route cannot be used again under that same route by a subsequent third-country national buyer. Once a change-of-use residence has been created and granted a Golden Visa, any onward sale to another third-country national investor must meet the €400,000 or €800,000 threshold. The favourable regime is a one-shot benefit attached to the conversion, not to the property in perpetuity.
3. Listed buildings: the restoration condition
Under the €250,000 listed-buildings route, the investor must not only purchase the listed property but also ensure full restoration or total reconstruction is completed before the first renewal of the residence permit -regardless of the reason for the building’s deterioration.
Interestingly, where a property satisfies both the change-of-use and listed-building criteria (for example, a listed former office being restored and converted to residential), the investor may choose under which of the two provisions to apply, taking into account the respective restrictions – not least the restoration obligation under the listed-buildings route.
4. Registration delays: a welcome pragmatic fix
A recurring practical problem in Greek real estate is the delay in registration of sale and purchase deeds with the Mortgage Registry or Cadastral Office, which had been holding up permit issuance. The Circular now confirms that one-stop services may proceed with the issuance of the investor residence permit where the lawyer’s certificate certifies the filing of the registration request (rather than the completed registration itself), or where evidence of the filing has been submitted. The completed registration must then be evidenced either within the validity of the five-year permit or at renewal stage. The Circular explicitly acknowledges that, without this flexibility, registration delays would undermine the successful implementation of the programme.
5. Encumbrance certificates: no longer required
Another practical simplification: one-stop services are now instructed not to request a certificate of encumbrances and non-claims on the property at the initial application stage. This supporting document is not included in the governing Joint Ministerial Decisions (95391/2024 and 214926/2025) and is not, as a matter of law, a condition for granting the permit. This clarification also applies to any applications still pending that were originally filed under the prior regime (Article 20B of Law 4251/2014, i.e. before 31 March 2024).
6. Powers of attorney and representation: detailed rules
The Circular consolidates the rules on how applications may be filed by lawyers acting under power of attorney, distinguishing between initial grant and renewal scenarios:
For the initial grant: If the investor is not in Greece, the POA must be executed before a Greek consular authority or before a competent foreign authority / foreign notary, bearing an Apostille (or consular legalisation for non-Hague Convention countries). If the investor is in Greece, a notarial POA or a simple authorisation via a Citizens’ Service Centre (KEP) or via gov.gr is sufficient. If the POA is electronic (gov.gr), the applicant must also provide evidence of presence in Greece (flight tickets or entry stamp).
For renewals: A previously used POA may be relied upon provided the lawyer files a solemn declaration that it has not been revoked. If the investor has changed their authorised representative and is not in Greece, an Apostille/legalised POA is required.
An important procedural point: applications by lawyers must be filed through the “Olomeleia” (Plenary) portal of the Migration Integrated Information System (OPS Migration), using the authentication certifications provided for under Ministerial Decision 118654/2024. Applications f iled outside that portal – using a lawyer’s personal email and phone – will be archived without refund of the fee.
7. What investors cannot do with the property
Two prohibitions are clarified:
Short-term rental via sharing-economy platforms is banned. This includes Airbnb-style arrangements, as defined in Article 111 of Law 4446/2016 (duration under 60 days, no services beyond accommodation and bed linen).
Properties acquired under the €250,000 change-of-use route may not be used as the registered seat or branch of a business.
Critically, however: Long-term leases are permitted. Leases to tourism enterprises (e.g. hotel operation) that provide services beyond accommodation and bed linen are permitted, provided the seat-of-business prohibition does not apply. The short-term prohibition does not retroactively apply to properties acquired under prior law, nor to those completed within the transitional period of Article 64(4) of Law 5100/2024
8. Replacing, renovating or extending the invested property
One of the most useful sections of the Circular sets out how the Ministry treats changes to the invested real estate:
– Renovation or extension without changing ownership – no impact on the permit, subject only to notifying the authority.
– Replacing the property with another qualifying property – the investor must first acquire the new property, then notify the authority, and only then sell the original. If the sequence is reversed (sale first, new purchase later), the authority will proceed with partial revocation, and the investor will need to re-enter Greece and apply afresh.
– Building on an undeveloped plot – the resulting property (whether through self-funded construction or antiparochi) must, depending on category, satisfy the 120 sq.m. rule and the minimum investment value of €400,000 / €800,000.
The principle underlying all of these rules is consistent: the investor must continuously retain qualifying real estate throughout the validity of the residence permit, without interruption.
9. Grandfathering: old investments, new applications
What about third-country nationals who invested years ago at lower thresholds but never applied – or whose earlier permit lapsed? The Circular confirms that such investors may still fall under Article 100 of Law 5038/2023 at the thresholds applicable when the investment was completed, provided:
– the investment was completed before the entry into force of the new thresholds;
– it met the investment-amount criteria then in force; and
– the consideration was paid in accordance with currently applicable provisions, evidenced
by a notary’s certificate (or, where a long period has elapsed, by the sale contract and the
corresponding deed of payment / settlement).
This is a meaningful opening for long-standing owners who had previously sat outside the
regime.
Several further clarifications are worth flagging:
10. Family members, nationality, and autonomous residence
Family members
derive their right directly from the sponsoring investor, including the
children and parents of the investor’s spouse or civil partner – even where that spouse / partner does not themselves apply
Co-owner spouses and civil partners
are treated as a single investment: one investor
permit is issued, the other spouse receives a family-member permit, and the 120 sq.m. rule
is measured at property level regardless of the number of co-owners.
Dual nationals
must stick with the nationality under which the investment and the permit were originally processed. A change is possible only if the original nationality is lost by
administrative act of the third country. Subsequently acquired nationalities, however,
may be reflected through reissuance of the permit
Autonomous residence permits
for children aged 21–24 are issued by the same one-stop service that issued the last family-member permit
No access to the Greek labour market
but holders of investment permits may establish
companies and act as shareholders or non-executive board members – provided they do
not perform work for the company and do not act as legal representatives or executive
directors.
11. Insurance, passports, and supporting documents
Finally, a few procedural points that frequently trip up otherwise well-prepared applications:
Valid insurance
(either private Greek insurance or adequate foreign insurance expressly covering Greece under Joint Ministerial Decision 133692/2024) must be in place at the time of application. If absent, the authority will issue a strict 30-day supplementary document request, after which the application will be rejected.
Passports
must be submitted in full and properly certified, either by a public authority or
by the authorised lawyer. Partial or uncertified copies will trigger a supplementary
documents request.
Utility connections are not required
as a supporting document at the initial application stage in any of the four investment categories.
12. Russian and Belarusian applicants: suspension continues
The Circular confirms that the suspension of new applications from citizens of the Russian Federation and Belarus under Articles 96 to 100A of Law 5038/2023 remains in place, in line with the Minister’s document of 1 April 2022. The suspension also extends to family members, investment certification applications, and change-of-purpose applications under Article 12.
Key takeaways for investors and their advisers
Circular 1/2026 will not rewrite the Golden Visa playbook, but it does something arguably more
valuable: it removes ambiguity on the points that had been causing the most friction in practice.
For investors, the practical implications are clear:
01
Structure the investment carefully.
The 120 sq.m. rule, the one-property restriction, and the “once only” benefit attached to change-of-use properties are not negotiable.
02
Beware of shortcuts.
Arrangements involving fund returns, artificial reductions of the purchase price, or misleading advertising now carry a serious risk of AML referral and permit revocation.
03
Document everything.
Notary certificates, proof of payment, engineer’s certificates for change of use, and renewal evidence of full restoration for listed buildings are all critical.
04
Plan transitions in advance.
The ordering of steps – particularly when replacing the invested property – can be the difference between a
seamless renewal and a forced re-application from abroad.
Get in touch
At Kanellos & Associates, we advise Greek and international clients across the full life-cycle of Golden Visa investments – from due diligence on properties and developers, through change-of-use and listed-building structuring, to family-member applications, renewals, and contested cases. If you would like to discuss how Circular 1/2026 affects a current or planned investment, please get in touch with our team.
This article is provided for general information only and does not constitute legal advice. Specific circumstances should be discussed with qualified Greek counsel.
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