Mika Lalaouni
Drakopoulus, Athens; Corporate Counsel Forum Liaison Officer, IBA Real Estate Section
mlalaouni@drakopoulos-law.com

Sophia Gofa
Drakopoulus, Athens
sgofa@drakopoulos-law.com

Introduction

For international private clients, family offices and real estate investors, Greece remains an established route to residence through real estate. The programme continues to offer a renewable five-year residence permit, Schengen access and no minimum-stay requirement.

That proposition is still attractive, but it is no longer a simple threshold exercise. Eligibility now turns on higher standard thresholds, a single-property rule, a minimum surface requirement for built property, targeted €250,000 exceptions and a stricter approach to short-term letting.

A property marketed as ‘Golden Visa eligible’ may still fail if it sits in the wrong price tier, is undersized, forms part of an aggregated structure, has not completed a qualifying change of use or is intended to operate in a way that conflicts with the rental restrictions.

The current framework

The current regime is a substantially tightened version of the existing programme. Article 64 of Law 5100/2024 amended Article 100 of the Migration Code (Law 5038/2023), restructuring the real estate route and replacing the earlier geography-based €250,000/€500,000 framework with higher standard thresholds and narrower reduced-threshold categories.

The transition has largely closed; new investments are now analysed under the amended rules, though some applications or renewals may still depend on preserved rights.

The standard acquisition route

Most acquisitions will fall within the standard route. The minimum investment is €800,000 in high-demand areas, such as the region of Attica, the regional unit of Thessaloniki and the regional units of Mykonos and Santorini and islands with a population exceeding 3,100, and is €400,000 elsewhere.

The investment must be made in a single property. Investors may no longer aggregate smaller units to reach the applicable threshold, which is a material change for those seeking exposure through multiple apartments, smaller units in the same building or a fragmented residential portfolio.

For built property, or property for which a building permit has been issued, the main areas must measure at least 120 square metres. Storage areas and parking spaces do not count towards that requirement, though their value may count towards the investment amount if acquired under the same deed, in the same building and as ancillary spaces.

Although there is no obligation to lease, the property may be let on a long-term basis, held for private use or retained as a passive asset.

The €250,000 categories

Two categories continue to qualify at the lower €250,000 threshold. Each is narrow, evidence-heavy and dependent on the legal status of the property.

A property whose main areas are converted from non-residential to residential use may qualify at €250,000, without the 120 square metre requirement. The change of use must be legally completed before the Golden Visa application is filed, must be after 5 April 2024 and must be evidenced by the prescribed engineer’s certificate. A property merely capable of conversion does not qualify.

The category extends beyond commercial-to-residential conversion to other non-residential uses, including professional or industrial uses, provided the statutory conditions are met. Where industrial property is involved, additional care is required, including as to the absence of industrial activity during the relevant five-year period. A property acquired under this route may not be used as the registered seat or branch of a company.

Commercially, this is one of the more interesting aspects of the regime. Greece holds a large number of office spaces, ground-floor commercial units and underused business premises. The conversion route may offer entry at a materially lower level than the standard thresholds. The exclusion risk, however, is real: planning, timing, technical certification and title due diligence must all be resolved before capital is committed.

The restoration or reconstruction of a listed building also qualifies at €250,000, again without a minimum surface requirement. This route can be attractive for investors interested in heritage assets or properties with architectural scarcity value. However, the conditions are strict: full restoration is a prerequisite for the first renewal after five years, the property may not be sold before restoration is complete and any transfer in breach is void. Failure to restore the building results in revocation of the residence permit and an administrative fine of €150,000.

The short-term rental restriction

Properties acquired for the grant or renewal of a Golden Visa may not be let on a short-term basis within the sharing-economy framework, nor subleased. Breach can lead to revocation of the permit and a €50,000 fine. The restriction is not retroactive and does not apply to properties acquired under the previous regime or completed within the transitional period.

In practical terms, the restriction captures Airbnb-type arrangements and other short-stay lettings falling within the statutory short-term rental regime, including stays of under 60 days where the statutory definition is met. It does not, however, prohibit long-term leasing nor require the owner to lease at all.

For investors, this means that a model built on short-term yield is now incompatible with the new Golden Visa real estate acquisition route. Long-term leasing remains available but presents a different investment profile: lower gross yield, more stable occupancy and a compliance obligation that must be maintained for the duration of the permit.

Due diligence has moved to the centre of the transaction

‘Golden Visa eligible’ is a marketing description, not a legal status. It carries no guarantees unless tested against the applicable law, title, planning position, technical characteristics of the property and the investor’s intended use.

Before committing, investors should consult with local advisors to verify the exact location tier, single-property status for Golden Visa purposes, compliance with the 120 square metre rule, proper documentation of ancillary spaces, timely and lawful completion of any change of use and compatibility of the proposed letting strategy with the rental restrictions.

The residence permit should be treated as part of the acquisition analysis, not as an administrative step taken after the real estate decision is made. In practice, that means aligning legal, planning, technical and immigration advice from the outset.

The next development: a portfolio route

Greece’s National Housing Strategy 2026–2035 (NHS) was approved by the Government Committee for Housing Policy on 23 July 2026, following a public consultation held between 18 June and 3 July 2026 by the Ministry of Social Cohesion and Family. The approval decision was subsequently published in the Government Gazette B’ 5200 on 17 August 2026.^[1] The NHS establishes the country’s housing-policy framework for the coming decade and includes, among its proposed measures, the creation of a specialised Golden Visa category allowing investors to qualify through a portfolio comprising more than one property, provided that the properties are committed exclusively to long-term residential letting within a prescribed period.

In this way, the investment is tied directly to increasing the available supply of housing and reducing the number of vacant or passive properties. The measure is designed to operate alongside policies for the activation of vacant homes, renovation and social or affordable letting, ensuring that the inflow of private capital is not confined to the passive holding of real estate but instead contributes to putting those properties to functional use for housing purposes.

The approval of the NHS marks an important policy development, but it does not by itself bring the proposed portfolio route into force. The existing Golden Visa regime continues to apply and, under its principal real-estate investment categories, the qualifying investment must generally be made in a single property. Introducing the new category will require specific legislation and, potentially, implementing decisions defining matters such as the applicable investment threshold, eligible properties, leasing period, monitoring arrangements and the consequences of non-compliance.

If implemented, the portfolio category would represent a significant departure from the current single-property model. Its policy objective is to channel foreign investment towards vacant or underused housing and increase the supply of homes available for long-term occupation. For investors, it could create a regulated residential income strategy offering diversification across properties, tenant profiles and locations, while linking residence rights to continuing compliance with the long-term letting requirements. It may appeal to family offices, private clients and real estate investors seeking both residence optionality and a managed Greek residential portfolio.

The measure should therefore now be described as forming part of the approved NHS, rather than as a consultation-stage recommendation. It is not, however, an operational investment route, and transactions should not yet be structured on the assumption that several properties may be aggregated for Golden Visa purposes. Investors already considering a long-term residential rental strategy should monitor the forthcoming legislative and regulatory steps closely.

Conclusion

The Greek Golden Visa remains a live and commercially relevant route for foreign investors seeking residence through direct real estate investment. It is, however, no longer a programme that can be analysed by threshold alone.

Eligibility now turns on the legal and technical character of the asset: location, single-property status, surface area, permitted use, change-of-use history, restoration obligations and rental restrictions. Therefore, careful due diligence is required, with immigration, real estate and planning advice integrated from the outset.

The portfolio category would move part of the programme towards an income-producing, long-term rental model and could suit investors seeking diversified exposure to Greek residential property. It forms part of the approved NHS but is not yet an operational Golden Visa route and remains worth tracking.^[2]