Understanding the new Golden Visa Law Νο. 5100/2024: Key Points and Implications6 February 2025

I. A New Approach to the Golden Visa Program

The updated law marks a clear shift in how Greece manages its Golden Visa program. The aim is to attract high-quality foreign investment whilst ensuring that all investments meet strict regulatory standards. Under the new rules, third country nationals can obtain a permanent residence permit—commonly known as a Golden Visa—if they meet specific investment and property requirements.

Key changes include:

• Single-Property Investment: Investors must channel their investment into a single property. This requirement helps prevent fragmented or piecemeal investments, ensuring that each project meets the set financial and spatial standards; and
• Minimum Investment Amounts:
  • in high-demand regions such as Attica, the Thessaloniki area of Central Macedonia, popular Aegean islands (including Mykonos and Thira) and islands with over 3,100 inhabitants, the minimum investment is set at €800,000; and
  • in all other areas of Greece, the required minimum investment drops to €400,000.

These thresholds are designed to attract substantial investments that contribute to the local economy while maintaining clarity and fairness in the application process.

II. Investment Options and Property Requirements

The law not only sets financial benchmarks but also specifies the types of property transactions that qualify for the Golden Visa. These include:

• direct purchases and long-term leases: Investors can secure their Golden Visa either by purchasing real estate outright or through long-term leasing agreements. For lease arrangements, the total rent must be equivalent to the required investment amount; and
• property size conditions:
  • for properties that are built or have an issued building permit, the main living area must be at least 120 square meters. This rule is intended to ensure that the properties acquired are suitable for genuine long-term residence and are not simply small or inadequate units;
  • for properties not subject to this construction requirement (such as plots of land or undeveloped property), the size requirement does not apply.

A unique provision allows for a reduced investment threshold of €250,000 when a property originally intended for industrial or non-residential use is converted into a residence. In these cases, the change of use must be fully completed before the investor submits their application for the Golden Visa. This flexibility also extends to properties classified as “heritage” or “preservable” buildings that are scheduled for renovation or complete reconstruction.

III. Restrictions and Oversight Measures

One of the most important aspects of the new legislation is its focus on ensuring that investments serve their intended purpose. The law includes several restrictions designed to maintain the integrity of the Golden Visa program:

• short-term rental ban: Properties acquired through the Golden Visa scheme cannot be rented out on a short-term basis through platforms like Airbnb. The prohibition applies specifically to rentals in the sharing economy, preventing investors from exploiting the program for quick, short-term profits; and
• business use restrictions: In cases where the investment involves a property that is converted from an industrial or non-residential building, the property must not be used as the headquarters or branch office of a business. Violations of these rules can lead to revocation of the Golden Visa and the imposition of substantial administrative fines.

These measures reflect the government’s commitment to ensuring that the Golden Visa program remains focussed on long-term residential stability rather than serving as a shortcut for commercial exploitation.

IV. Transitional Arrangements and Key Deadline

The new Golden Visa law introduces a set of transitional arrangements designed to accommodate ongoing and pending transactions under the previous legal regime. Importantly, the law clarifies that Golden Visas issued under earlier frameworks-whether granted under Article 20 par. B of the Law No. 4251/2014, the specific conditions of Article 92 of Law No. 5007/2022, or the pre-existing requirements before the enactment of the new law-will remain in force and are not subject to the new restrictions or prohibitions imposed on investments made under the revised system, such as the short-term rental ban.

However, for new applications, the law establishes clear deadline and payment conditions. Transactions conducted from 1 September 2024 onward must comply fully with the new regime, including the requirement that the total purchase price or contractual rent be fully paid before the application is submitted.

This approach provides continuity for existing visa holders, ensuring that they are not adversely affected by the enhanced restrictions and new investment requirements imposed on future applicants.

V. Practical Considerations for Investors and Legal Advisors

For both investors and legal practitioners, the updated Golden Visa law necessitates careful attention to detail. It is essential that all aspects of the investment—from property selection and financial transactions to compliance with spatial and use-related requirements—are thoroughly documented and aligned with the new legal standards.

Legal advisors must be well-versed in both real estate and immigration law to guide their clients through this complex process. Ensuring that payment methods, contractual details, and property specifications comply with the new rules will be critical for a successful Golden Visa application. With the increased emphasis on detailed oversight—including the need for notarized documents and precise payment records—both investors and their legal teams must exercise extra caution in their preparations.

Conclusion

The new Golden Visa law represents a major update to Greece’s immigration and investment policies. By setting clear financial thresholds, specifying property requirements, and introducing strict restrictions on the use of acquired real estate, the law seeks to create a balanced framework that supports economic growth while protecting national interests. For investors, this means that while the opportunity to obtain permanent residence through real estate investment remains open, it comes with enhanced responsibilities and compliance requirements. Legal practitioners, in turn, must be prepared to navigate these changes, ensuring that every application meets the rigorous standards set by the new legislation.

This comprehensive approach not only aims to attract high-quality, long-term investments but also safeguards the integrity and sustainability of the Golden Visa program in Greece. Should you require further guidance or personalised legal advice regarding your Golden Visa application, please do not hesitate to contact our team of experts at the Athens office of Watson Farley & Williams.