Property Eligibility, Investment Thresholds, the 120 sq.m. Rule, Change of Use, Short-Term Rentals, Resale, Inheritance and Family Rights
Greece’s Golden Visa programme has entered a new and considerably more demanding phase.
The programme remains one of Europe’s most attractive residence-by-investment frameworks. It offers qualifying non-EU investors a five-year renewable residence permit, the possibility of including eligible family members, and freedom of travel within the Schengen Area, without imposing a minimum annual physical-presence requirement in Greece.
However, the legal analysis can no longer stop at the headline investment amounts.
The decisive questions in 2026 are more technical:
· Does the property itself qualify?
· Does the 120 sq.m. requirement apply?
· Can storage rooms and parking spaces be included?
· When must a change of use have been completed?
· What happens when an industrial building is converted into residential property?
· Can the property be rented through a short-term rental platform?
· Can an investor sell and replace the qualifying property?
· What happens if the investor dies?
· Can the residence permit continue through inheritance?
· What evidence must be produced concerning the consideration and the movement of funds?
· What happens when the contractual value differs from the real economic substance of the transaction?
Circular No. 1/2026 of the Greek Ministry of Migration and Asylum, issued on 22 April 2026 under Protocol No. 72019/21.04.2026, provides an important interpretative framework for these questions. It must be read together with Article 100 of Law 5038/2023, as amended, the reforms introduced by Law 5100/2024, the relevant implementing decisions and the subsequent amendments to the Immigration Code. The result is not merely a revised list of documents.
It is a compliance system requiring the legal, technical, notarial, banking and migration aspects of the investment to be aligned before the transaction is completed.
1. The Current Real-Estate Investment Thresholds
The applicable minimum investment depends on the location and legal characteristics of the property.
€800,000 investment threshold
The minimum value is €800,000 for properties located in:
· the Region of Attica;
· the Regional Unit of Thessaloniki;
· Mykonos;
· Santorini; and
· Greek islands with a population exceeding the statutory threshold.
The investment must, in principle, be completed through the acquisition of one property.
Where the investment concerns developed property, or property for which a building permit has been issued, the property must generally include at least 120 sq.m. of main-use space.
€400,000 investment threshold
The minimum value is €400,000 in the remaining areas of Greece.
This route is also generally subject to:
acquisition of one property; and
a minimum of 120 sq.m. of main-use space for developed property or property covered by a building permit.
The legislation expressly provides that, in cases of acquisition of an undivided co-ownership share, the value of the investor’s share must itself meet the applicable €800,000 or €400,000 threshold.
€250,000 special investment routes
The reduced €250,000 threshold remains available for specific categories, principally:
property whose main-use spaces are lawfully converted into residential use; and
property comprising a listed building requiring restoration or reconstruction.
These are not geographical discounts.
They are special legal categories subject to their own technical, evidentiary and timing requirements.
The legal and technical file must demonstrate that the conversion has been completed and recognised under the applicable planning framework.
Key documents normally requiring review
Depending on the property, the review may include:
1. the original building permit;
2. the approved historical use;
3. planning approvals;
4. change-of-use documentation;
5. revised plans;
6. electronic building identity;
7. engineer’s certificates;
8. horizontal-property documentation;
9. cadastral entries;
10. evidence of completion; and
11. the final notarial description of the converted property.
Where an industrial building is involved, additional evidence may be needed to establish the absence of an operating industrial activity during the legally relevant period.
5. Listed Buildings and the Restoration Obligation
The €250,000 route is also available for the acquisition of property comprising a listed building requiring restoration or reconstruction.
The reduced entry threshold does not remove the restoration obligation.
Full restoration or reconstruction is an additional condition for the first renewal of the investor’s residence permit.
The legislation also imposes a severe restriction on early disposal: transfer of the property before full restoration or reconstruction has been completed is invalid. (Υπουργείο Μετανάστευσης και Ασύλου (https://migration.gov.gr/wpcontent/uploads/2024/10/9%CE%95%CE%B3%CE%BA%CF%8D%CE%BA%CE%BB%CE%B9%CE%BF%CF%82-Golden-24.9.2024-FINAL.pdf))
This is not a passive real-estate acquisition
An investor considering a listed building must evaluate:
the scope of the restoration;
approvals from competent planning and cultural authorities;
anticipated construction costs;
contractor capacity;
financing;
project timing;
evidentiary requirements for renewal; and
restrictions on transfer before completion.
The investment decision should therefore be based on the total legal and financial exposure, not only on the €250,000 acquisition price.
A low acquisition price combined with an uncertain restoration budget can produce materially greater risk than a standard acquisition under the €400,000 or €800,000 route.
6. Land and Construction Projects
Investment in undeveloped land or property requiring construction demands a different form of due diligence.
The existence of a plot with an attractive location does not establish that a qualifying project can lawfully be completed.
The legal and technical review should consider:
· buildability;
· planning classification;
· land-use restrictions;
· forestry status;
· archaeological restrictions;
· shoreline or coastal-zone limitations;
· cadastral boundaries;
· access to a recognised public road;
· permitted building coefficient;
· the status of any building permit;
· construction agreements; and
· the aggregate value of the land and qualifying construction obligations.
The contractual architecture must also demonstrate that the statutory investment has genuinely been made.
The Ministry’s 2026 approach places substantial emphasis on economic substance, payment traceability and the prevention of artificial arrangements.
7. Payment Traceability and the Real Economic Value of the Investment
A qualifying transaction is not established merely because the purchase deed states the statutory threshold.
The authorities may examine whether the declared investment corresponds to the real economic transaction and whether the consideration has been paid through legally accepted and traceable channels.
Particular risk arises where arrangements involve:
repayment of part of the consideration to the investor;
side agreements reducing the investor’s real economic contribution;
artificial inflation of the contractual price;
circular movement of funds;
developer-funded “rebates” concealed outside the deed;
guaranteed-return structures funded from the investor’s own purchase price; or
misleading representations concerning the actual minimum investment.
Circular No. 1/2026 expressly signals enhanced scrutiny of arrangements intended to circumvent the statutory investment requirements.
Such conduct may result not only in rejection or revocation of the residence permit, but also in referral to anti-money-laundering or prosecutorial authorities where appropriate.
A compliant file should establish
° the identity of the payer;
° the identity of the recipient;
° the banking route;
° the source of the funds where required;
° the exact amount paid;
° the contractual basis of each payment;
° the timing of the payments; and consistency between the deed, bank records, invoices and application file.
Payment design must therefore be reviewed before funds are transferred—not reconstructed after the transaction has closed.
8. Short-Term Rentals and Prohibited Use
Golden Visa property is subject not only to acquisition rules but also to restrictions concerning its subsequent use.
Short-term rental of qualifying property through digital platforms, including Airbnb-style arrangements, is prohibited under the current framework.
The prohibition cannot safely be avoided by appointing:
a property-management company;
a hotel operator;
an affiliated company;
a lessee;
a family member; or
another intermediary.
The investor remains exposed where the economic use of the property breaches the statutory restriction.
Long-term rental
Long-term residential leasing is conceptually distinct from short-term tourist accommodation and may remain permissible, subject to the applicable legal and tax framework and the particular category of the investment.
Every lease and management agreement should nevertheless be reviewed for:
duration;
permitted use;
subletting;
tourist exploitation;
platform registration;
hotel-style services;
guaranteed returns;
termination rights; and
responsibility for regulatory breaches.
The description given to an agreement is not decisive. The authorities may examine how the property is actually used.
9. Sale and Replacement of the Investment
A Golden Visa investor may wish to sell the qualifying property during the validity of the residence permit.
This requires careful sequencing.
The investor should not create a period during which the statutory investment no longer exists.
Where the investor intends to preserve the residence status through a replacement investment, the new qualifying investment should be completed before the existing property is transferred.
A sale-first, replacement-later structure can place the investor and dependent family members at risk of revocation or non-renewal.
Before any sale, the investor should verify
whether the current property may legally be transferred;
whether restoration obligations remain outstanding;
whether a replacement investment is required;
whether the replacement property falls under the current thresholds;
whether a new application or notification is needed;
whether family permits are affected; and
whether there will be any interruption in the qualifying investment.
Special caution applies to listed-building investments, because transfer before completion of the required restoration or reconstruction is expressly restricted.
10. Death, Inheritance and the Surviving Family
The death of the investor does not make the legal and migration consequences disappear.
The treatment of the residence status depends on:
° who inherits the qualifying property;
° whether the investment remains legally intact;
° whether the heir is an eligible family member;
° whether inheritance formalities have been completed;
° whether the property remains within the qualifying structure; and
° whether the relevant application or renewal is submitted with the necessary evidence.
Circular No. 1/2026 provides important guidance concerning succession and the position of surviving family members.
A surviving spouse inheriting the qualifying investment may, under the applicable conditions, preserve an investment-based residence position.
This is not automatic.
The succession file may require coordination between:
Greek inheritance law;
the law governing the deceased’s succession;
wills or intestate succession;
certificates of inheritance;
acceptance of inheritance;
tax declarations;
cadastral registration; and
the residence-permit procedure.
Estate planning should therefore form part of the Golden Visa strategy, particularly where the investment is intended to support several generations of a family.
11. Eligible Family Members
The Golden Visa framework permits qualifying family members to obtain dependent residence permits.
Depending on the family relationship and supporting documentation, this may include:
the investor’s spouse;
a registered partner, subject to recognition of the relationship;
unmarried children within the applicable age limits;
eligible children of the spouse or partner; and
eligible ascendants of the investor and the spouse or partner.
Particular attention is required where:
a child approaches the statutory age limit;
the child is between 18 and 21;
the relationship arises through a foreign civil partnership;
the family relationship has changed;
the parents are divorced;
custody or parental-responsibility questions exist; or
family members hold different nationalities.
The principal investor’s continued compliance remains central to the dependent permits.
A defect in the investment may consequently affect the residence status of the entire family.
12. The Investor’s Right to Reside—but Not to Take Ordinary Employment
The Golden Visa grants residence rights, but it should not be confused with a general employment permit.
The holder may reside in Greece and may engage in permitted investment or corporate activity, but the permit does not ordinarily provide unrestricted access to salaried employment.
Corporate participation, appointment to corporate bodies and receipt of returns on investment must be distinguished from dependent employment.
Investors intending to perform operational duties in a Greek company should obtain specific advice on:
the nature of their role;
management authority;
social-security treatment;
remuneration;
tax residence;
work-permit requirements; and
whether another immigration category is more appropriate.
13. Renewal Under the Updated Immigration Framework
Golden Visa permits are generally issued for five years and may be renewed for successive five-year periods while the statutory conditions remain satisfied.
Renewal is not automatic.
The investor must demonstrate that:
the qualifying investment continues to exist;
ownership or the relevant investment right has been maintained;
no prohibited use has occurred;
the statutory conditions remain satisfied; and
any category-specific obligations have been completed.
For listed-building investments, full restoration or reconstruction is an additional condition for the first renewal.
Law 5275/2026 also amended the general renewal timetable under the Immigration Code. Renewal applications are generally submitted within the two months preceding expiry. Late filing may be accepted for up to three months after expiry, subject to a fine of €100 for each month of delay, unless legally recognised exceptional circumstances apply.
Investors should not treat the late-filing period as an extension of the permit. Renewal planning should begin well before the residence card expires.
14. Financial Investment Routes Remain Available
The Greek residence-by-investment framework is not limited to real estate.
Separate investment routes may include, subject to the current statutory requirements:
- qualifying fixed-term deposits with Greek credit institutions;
- Greek government or corporate bonds;
- shares or capital contributions;
- qualifying mutual funds or alternative investment funds;
- egulated investment vehicles; and
- certain investments in eligible start-up companies.
These routes are governed by separate conditions, thresholds and documentary requirements.
They should not be merged conceptually with the real-estate provisions of Article 100.
For some investors, a financial route may offer:
greater liquidity;
less property-management exposure;
reduced construction risk;
easier diversification; or
a structure more closely aligned with their wider investment portfolio.
For others, banking onboarding, sanctions screening, source-of-funds review, investment volatility or minimum holding requirements may make the route less suitable.
The correct choice depends on the investor’s nationality, banking profile, risk tolerance, liquidity needs, tax position and long-term objectives.
15. The Due-Diligence Checklist Before Signing
A properly structured Golden Visa transaction should not begin with the residence-permit application.
It should begin with a legal eligibility review before the investor becomes contractually or financially committed.
Legal title review
° ownership and chain of title;
° mortgages, prenotations and seizures;
° claims and litigation;
° easements;
° cadastral registration;
° horizontal-property status;
° co-ownership restrictions;
° contractual transferability.
Planning and technical review
° lawful construction;
° approved use;
° main-use surface area;
° unauthorised alterations;
° building permit;
° electronic building identity;
° change-of-use compliance;
° listed-building status;
° restoration obligations;
° buildability in land acquisitions.
Golden Visa eligibility review
° applicable threshold;
° one-property requirement;
° 120 sq.m. requirement;
° special €250,000 category;
° timing of conversion;
° payment structure;
° intended use;
° family-member strategy;
° renewal implications.
Financial and banking review
° source of funds;
° transfer route;
° banking availability;
° sanctions and KYC exposure;
° currency-conversion risk;
° payment evidence;
° tax and transaction costs;
° consistency between the declared and actual consideration.
Contractual protection
The preliminary and final agreements should address:
- Golden Visa eligibility as a material condition;
- seller representations;
- delivery of technical documents;
- completion of change of use;
- restoration obligations;
- refund rights where eligibility fails;
- payment milestones;
- encumbrance removal;
- handover;
- permitted use;
- liability for inaccurate representations.
16. The Principal Risks for Each Participant
The investor
The investor risks:
- acquiring an ineligible property;
- paying before the conditions are satisfied;
- relying on inaccurate marketing;
- losing eligibility because of prohibited use;
- failing to maintain the investment;
- exposing family permits to revocation;
- entering a project with unquantified construction obligations.
The developer or seller
The developer or seller risks:
- misrepresenting eligibility;
- using non-compliant payment structures;
- failing to complete a promised change of use;
- delivering inconsistent technical records;
- promoting prohibited rental arrangements;
- exposing the transaction to civil, regulatory or criminal scrutiny.
The notary
The notarial file must accurately reflect:
- the property;
- the consideration;
- the payment method;
- the statutory declarations;
- the legal category of the investment; and
- the supporting documentation.
The engineer
The engineer’s analysis may determine:
lawful use;
main-use surface area;
completion of conversion;
existence of unauthorised construction;
listed-building obligations;
compliance of the electronic building identity.
The lawyer
The lawyer must coordinate the entire structure.
A migration application cannot cure:
defective title;
unlawful construction;
an incomplete change of use;
an artificial payment arrangement;
a prohibited rental model; or
a transaction that never qualified under the legislation.
17. Frequently Asked Questions
Can I buy two apartments whose combined price reaches the threshold?
Under the current principal real-estate routes, the minimum investment must generally be made in one property. Several unrelated apartments cannot ordinarily be combined to reach the threshold.
Can a storage room count toward the €400,000 or €800,000 investment?
It may form part of the same acquisition structure where the statutory conditions are met, including acquisition through the same deed and location in the same building.
It does not count toward the 120 sq.m. main-use requirement.
Does the 120 sq.m. rule apply to a change-of-use investment?
No. The special €250,000 change-of-use route is not subject to the 120 sq.m. requirement, but the conversion must satisfy its own legal and timing conditions.
Can the seller complete the change of use?
Yes. The conversion may be carried out by the seller or the investor, provided it complies with the law and is completed before submission of the residence-permit application.
Can I use the property for Airbnb?
Short-term rental of the qualifying Golden Visa property is prohibited.
Can I rent it on a long-term basis?
Long-term leasing may be possible, subject to the applicable rules and the terms of the particular investment. The lease should prohibit short-term subletting and other non-compliant use.
Can I sell the property after obtaining the permit?
A sale can affect the legal basis of the permit. A replacement investment should be structured and completed before disposal where the investor intends to maintain the residence status.
Can I sell a listed building before completing restoration?
The legislation imposes a specific restriction, and transfer before completion of the required restoration or reconstruction is invalid.
Does buying property automatically guarantee the Golden Visa?
No. Ownership, investment value, property eligibility, lawful use, payment evidence and the full application file must all satisfy the statutory requirements.
Must I live in Greece?
The Golden Visa does not generally impose a minimum annual residence requirement for renewal. Different physical-presence rules apply, however, if the investor later seeks long-term residence or citizenship.
Does the permit lead automatically to Greek citizenship?
No. Citizenship is governed by separate residence, integration and naturalisation requirements. Holding a Golden Visa without actual residence in Greece does not by itself establish entitlement to citizenship.
18. The Correct Strategy in 2026
The central lesson of the updated framework is simple:
The residence permit should not be used to test whether an investment was compliant after completion. Compliance must be designed into the transaction from the beginning.
A properly managed Golden Visa investment requires coordinated work between:
the investor;
the immigration lawyer;
the property lawyer;
the notary;
the engineer;
the bank;
the accountant;
the developer or seller; and
where appropriate, the investment adviser.
At Amoiridis Law Services®, we approach Golden Visa cases as integrated legal and investment-compliance projects.
Our work may include:
assessment of the most appropriate investment route;
property and title due diligence;
review of the 120 sq.m. requirement;
verification of change-of-use eligibility;
listed-building and restoration analysis;
review of banking and payment structures;
source-of-funds coordination;
contractual protection;
family-member planning;
submission and monitoring of residence applications;
renewal planning;
resale and replacement strategy;
inheritance and succession planning.
The Greek Golden Visa remains a powerful residence and investment-planning instrument.
But in 2026, successful implementation depends less on identifying a property advertised as “Golden Visa eligible” and more on proving—legally, technically and financially—that the entire investment satisfies the law.
This publication provides general legal information based on the Greek legal and administrative framework in force as of July 2026. It does not constitute individual legal, tax, financial or investment advice. The eligibility and appropriate structure of each investment must be assessed on the basis of its specific facts and supporting documents.
For any further information and clarifications please do not hesitate to contact our qualified legal team, ready to provide you with further personalized information tailored to your needs and your profile.
You can email us: or call/text us directly at: +306908351705 (WhatsApp/Viber)
Athens, July 2026
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