Exclusive Interpretation of Greece’s New Policy Details by Globevisa’s In-house Lawyer Chrysoula Velopoulou

The detailed provisions of the Greek Golden Visa residency policy have finally been officially implemented. The content aligns closely with the earlier predictions made by Chrysoula Velopoulou, Globevisa’s in-house lawyer. In order to further confirm the specifics of the new Greek policy legislation, on April 9th at 11:00 a.m. local time, Chrysoula, the lawyer from Globevisa, and Lynette Ju, the head of Globevisa’s Greece office, personally visited the Greek Ministry of the Interior. They obtained first-hand analysis of the legislation from the immigration department.

Let’s first review Article 100 of Law No. 5038/2023 on Greek immigration, which was released on April 8th.

1. In the regions of Attica, Thessaloniki, Mykonos, Santorini, and islands with a population exceeding 3,100 residents, the minimum investment requirement is raised to €800,000, with a restriction of purchasing only one residential property exceeding 120 square meters.

2. Real estate prices in other areas increase by €400,000, also with a limitation of purchasing only one residential property exceeding 120 square meters.

3. For buildings currently serving different purposes and converted into residences (conversion must be completed before submitting the residency permit application) or investments in historic buildings awaiting restoration, the investment threshold remains at €250,000.

4. Further restrictions on the use of properties are imposed; all properties purchased for applying for the Golden Visa residency permit may not be used for short-term Airbnb rentals, even if rented out by third parties under sublease agreements. Violation of this regulation will result in the revocation of the residency permit and an independent administrative fine of €50,000 imposed on the property owner.

5.Properties cannot be used for commercial purposes or as branches of businesses.

Globevisa’s in-house lawyer Chrysoula at the Greek Ministry of the Interior

Following discussions with officials from the Ministry of the Interior regarding the updated legislation on April 8th, Globevisa’s in-house lawyer Chrysoula believes that there are still many areas of ambiguity in the published details of the law. One notable aspect concerns the residential conversion schemes under the “commercial to residential” category. What’s interesting about this scheme is that it’s not limited to specific regions. However, it remains unclear whether the €250,000 investment is required while the building is still in a commercial state or after the conversion into residential property is completed. Chrysoula’s analysis suggests it’s likely the former, meaning investors would need to initially invest €250,000 in a commercial building and then bear the additional costs of converting it into a residential property.

 Consequently, the total investment amount could far exceed €250,000, potentially rising to over €350,000 or even higher.

Furthermore, regarding the future restrictions on the use of properties for the Golden Visa residency, Chrysoula believes there is considerable controversy surrounding the definition of the Airbnb short-term rental model. Greece has long been renowned globally for its tourism industry, with hotel properties yielding higher returns than ordinary residential properties. Over the past decade, the majority of Golden Visa investors have tended to utilize their properties for short-term Airbnb rentals. This has directly resulted in either an increasing number of properties remaining vacant or local residents being unable to access them. Therefore, the aim of this new policy is to address the housing issues faced by local residents. Whether hotel-serviced apartment properties fall within this category requires further clarification through additional legislative interpretation. However, it is certain that hotel properties indeed possess higher investment return attributes compared to ordinary residential properties.

Finally, Chrysoula emphasizes that the Greek government exhibits a particularly humane approach in policy implementation. This entails providing a specific timeframe, within which, as long as the necessary procedures to secure the policy are completed, individuals will not be affected by subsequent policy changes.

Chrysoula photographed at the Greek Ministry of the Interior