Source: Circular No. 1/2026 (Protocol No. 72019/21.04.2026), General Secretariat of Migration Policy, Ministry of Migration and Asylum, Greece. Issued 22 April 2026 and distributed to all regional migration authorities, notaries and the Athens Bar Association.
The Greek Ministry of Migration and Asylum has issued Circular No. 1/2026, containing 23 binding clarifications on the implementation of Article 100 of Law 5038/2023 — the provision governing the Permanent Investor Residence Permit (Golden Visa, category B.5). This is the most comprehensive official guidance on the programme issued to date. Below we analyse the clarifications of greatest practical importance for international investors.
Key Clarifications
1 Single Property Rule — Universal Application
The requirement to invest in a single property applies to all four investment categories, including the €250,000 commercial-to-residential conversion and heritage restoration routes. An investor cannot combine multiple lower-value properties to reach the threshold.
2 Parking Spaces and Storage Rooms Count Towards Investment Value
Auxiliary spaces — parking bays and storage rooms — purchased simultaneously under the same notarial deed in the same building may be included in the total investment value. However, they do not count towards the 120 sqm floor area requirement.
Ministry example: Investor purchases a 60 sqm converted apartment (€248,000) plus a parking space (€8,000) and storage room in the same building. Total: €256,000. The application qualifies under the €250,000 threshold. The 120 sqm requirement does not apply to converted properties.
3 No Encumbrance Certificate Required at Application
Applicants for an initial Golden Visa are no longer required to submit a certificate of encumbrances and non-claims at the time of application. Migration authorities are instructed not to request it.
4 Land Registry Delays Will Not Block Permit Issuance
Due to significant delays in completing land registry registrations across Greece, a lawyer's certificate confirming that a registration request has been submitted is sufficient to proceed with the residence permit application. Full registration proof is required at renewal.
5 Change of Use Must Post-Date 5 April 2024
For the €250,000 commercial-to-residential conversion route, the change of use must have been completed after 5 April 2024 (entry into force of Law 5100/2024). A property that was residential before that date cannot be reclassified and back again to qualify.
6 The €250,000 Conversion Route Can Only Be Used Once Per Property
Once a property has been used to obtain a Golden Visa under the €250,000 route, a subsequent buyer of that same property cannot use the same threshold. The second buyer must satisfy the standard €400,000 or €800,000 threshold.
Ministry example: Investor A buys a converted apartment for €300,000 and obtains a Golden Visa. Investor B later buys the same property from Investor A for €300,000. Investor B cannot use the €250,000 rule — the property is now a standard residential unit. The €400,000 or €800,000 threshold applies.
7 Short-Term Rentals (Airbnb) Prohibited
Golden Visa properties cannot be rented out on a short-term basis through sharing economy platforms (Airbnb, VRBO and similar). Short-term rental is defined as any tenancy under 60 days where no services beyond accommodation are provided. Breach may result in permit revocation and administrative fines. Long-term residential rentals remain permitted.
8 Replacing the Investment: Mandatory Sequence
Investors who wish to replace their qualifying property with a different one must follow this exact sequence: (1) Purchase and complete the new investment first. (2) Notify the migration authority. (3) Only then sell the original property. If the investor sells first and buys later, there will be a gap — the permit will be partially revoked and a fresh application required.
9 Full Scope of Family Members Confirmed
Eligible family members include: spouse/registered partner (civil partnership valid whether concluded in Greece or abroad); children under 21 (extendable to 24); and parents of both spouses. Parents of the investor's spouse do not require the spouse to also hold a Golden Visa — they derive their entitlement directly from the investor.
10 Power of Attorney Requirements Updated
For investors outside Greece, a PoA must carry an Apostille or Greek consular certification. For investors present in Greece, a notarial PoA or KEP/gov.gr authorisation is sufficient. All lawyer-submitted applications must be filed through the "Olomeleia" portal — applications filed outside this portal will be archived without fee refund.
11 Russian and Belarusian Nationals — Suspension Continues
The suspension on new applications from nationals of Russia and Belarus remains fully in force across all investor permit categories, including applications made via the change-of-purpose procedure.
12 Golden Visa Does Not Permit Employment
The Permanent Investor Residence Permit does not grant access to the Greek labour market. Holders may own company shares and serve as non-executive board members only. They may not serve as legal representatives or executive directors, as these roles involve performing work.
Investment Threshold Reference Table
| Route | Location | Minimum | Notes |
|---|---|---|---|
| Residential real estate | Attica, Thessaloniki, Mykonos, Santorini, islands >3,100 | €800,000 | 1 property, min 120 sqm |
| Residential real estate | All other regions | €400,000 | 1 property, min 120 sqm |
| Commercial-to-residential conversion | Anywhere | €250,000 | 1 property, no sqm, used once |
| Heritage building restoration | Anywhere | €250,000 | 1 property, no sqm, used once |
| Qualifying mutual fund | Greece | €350,000 | Greek markets only |
| Fixed-term bank deposit | Greek bank | €500,000 | 12-month rolling |
| Company capital contribution | Greece | €500,000 | Min 5 employees |
Circular No. 1/2026 is the most authoritative statement yet of how the Golden Visa programme operates in practice. For investors, their advisors and legal representatives, it resolves questions that have caused uncertainty, delays and permit revocations across Greece over the past eighteen months.
This article is based on Circular No. 1/2026 (Protocol No. 72019/21.04.2026) of the General Secretariat of Migration Policy, Ministry of Migration and Asylum, Greece, dated 22 April 2026. It is provided for general information purposes and does not constitute legal advice. Investors should obtain independent legal advice before making any investment decision.