Greece Tightens Golden Visa Fraud Controls: Directive 1/2026 and Clarified Thresholds

Greece is stepping up oversight of Golden Visa fraud schemes—particularly fake real-estate purchase listings and so-called “investment” transactions that do not meet the legal requirements. The trigger is a circular directive 1/2026 (31 pages) signed by Konstantina Papakosta, the General Secretary for Migration Policy.

The document is addressed to one-stop services nationwide: when misleading advertising and fictitious investment operations are identified, the case materials must be forwarded to the tax authority (AADE) and to the Greek AML/financial enforcement unit: the Hellenic Anti-Money Laundering Authority.

The anti-fraud section takes up only the last two pages. However, the remaining 29 pages are just as important for practitioners: they address 22 procedural issues that previously led to different interpretations across regions.

The fraud problem

After the September 2024 increase in Golden Visa thresholds, the number of advertisements offering “suitable” property prices surged on social media and overseas platforms. The commonly promoted range was €180,000–€230,000. Formally, these properties are presented as compliant with the program.

As described by Greek outlet Mononews, the typical setup works like this: the buyer pays the full amount under the documents (e.g., €800,000 for Athens), and then part of the money is returned through so-called prepaid lease agreements, furniture payments, or other methods that are not supported by transparent financial records.

Attorney Alexandros Varnavas (Varnavas Law Firm), who prepared an unofficial English-language translation of the circular, notes that similar advertising has been recorded for the past year. In his view, authorities have long been checking contracts where hidden refunds were used to bypass minimum requirements, but now investigative pressure appears tougher.

Clarification 23 does not list what exactly should automatically trigger a review. Instead, it states that if the ministry identifies such practices or receives complaints, it will forward the materials to AADE and the AML authority. If violations are confirmed, sanctions apply under Article 100 of Law 5038/2023, including revocation of the permit.

At the same time, Mononews reports that Migration Minister Thanos Plevris allegedly compiled a dossier on companies that may be involved. This is information attributed to the media—not a direct statement from the circular itself or from the ministry.

Varnavas stresses that any Golden Visa investment advertising below €250,000 (the current real-estate threshold) should be treated as a clear “red flag”. He also adds that engaging a specialist lawyer can no longer be considered optional: compliance criteria apply not only to the amount, but also to the property itself—especially when the property’s use category changes or when dealing with buildings with protected status (e.g., listed or protected structures).

Not everyone in the market sees the tightening as a threat. President of Mercan Greece Theodoros Kioutsoukis calls the measures overdue and argues that investments must be real, transparent, and fully traceable. He believes coordination between the ministry, tax authorities, and AML bodies does not undermine the program—it protects it. For institutional developers, regulation could even become a business opportunity.

Threshold requirements: what is actually set out

The thresholds themselves are not new: all of them were established by Article 64 of Law 5100/2024 in September 2024. The circular merely reaffirms them as guidance for the one-stop services.

For Attica, as well as the regional units of Thessaloniki, Mykonos, and Tira (Santorini), and for islands with a population of more than 3,100, the minimum is €800,000 for a single property with at least 120 sq. m of residential/primary area.

In all other regions, the minimum is €400,000 under the same area and property-type conditions.

A separate €250,000 route remains for two categories: properties converted from non-residential to residential use, and buildings with protected status that require restoration. For these options, no minimum area requirement is specified.

One property—once

Law 5100/2024 introduced the requirement to purchase a single property, but practice left questions about whether it applied to all investment categories. The circular confirms: yes. Multi-property portfolios under any of the four routes are no longer considered.

Additional spaces (e.g., a parking space and a storage room) purchased under the same agreement/act and within the same building may be included in the minimum price, but do not count toward the 120 sq. m requirement.

An example is given: an investor buys a 60 sq. m apartment in a building that was previously industrial and has been converted into residential use for €248,000, and also buys an underground parking space for €8,000 under the same agreement. Total: €256,000. This may fall under the €250,000 route for change of use, because the parking space is not treated as a separate property for immigration-legislation purposes.

At the same time, properties that involve a change of use or are part of protected buildings can be used for a Golden Visa only once under the €250,000 threshold. If the first permit holder sells the residence to a third-country national, the new buyer must meet the standard thresholds of €400,000 or €800,000. In other words, the “favored” threshold is considered “spent” once the conversion is completed and the first permit is granted.

Change of use: where the circular becomes more specific

The €250,000 route for change of use was introduced by Law 5100/2024, but details were interpreted differently across regional offices. The circular clarifies several points.

1) The change of use must occur after 5 April 2024, when Law 5100/2024 entered into force. Properties that were already residential on that date cannot be “switched” to commercial and back again to requalify under €250,000.

2) For projects that are “under construction,” a similar principle applies: if an office-use permit is initially issued on paper and later amended to residential units, it is not considered an actual change of use of an existing property. What counts is the real functional change of the building, not a “re-labeling” of plans.

3) Industrial buildings may qualify if no industrial activity has been carried out for at least five years. Workshop and craft-production buildings are exempt from the waiting period.

4) Mixed scenarios are also possible: if part of a former factory becomes offices and part becomes apartments, then only the residential units fall under €250,000. The commercial parts must meet the standard thresholds.

5) The conversion can be carried out either by the buyer or by the seller—an important detail from clarification 5. In practice, this gives developers flexibility: they can prepare the property for conversion before selling individual units to Golden Visa applicants.

Transitional cases for those who invested earlier

Clarification 6 addresses a question that remained unclear for several months. Investors who bought a property under the former €250,000 threshold but never applied for a residence permit can still submit an application—provided three conditions are met:

the investment was completed before the new financial criteria took effect; the property met the thresholds applicable at the time; and payment was made in line with the requirements (in particular, notarized proof of the payment method is required).

The same logic applies to those whose permits expired without renewal: they may re-enter the program under the thresholds that applied at the time of purchase, if they can document exactly how payment was made.

“Airbnb ban”: the restrictions are narrower than many expected

Law 5100/2024 restricted short-term rentals on Golden Visa properties, but the wording left room for interpretation. The circular clarifies that the ban is already tighter than many assumed.

It applies only to rentals of less than 60 days where no additional services are offered other than accommodation and bed linen.

Long-term leasing to tourism companies that operate in a hotel-style format (and provide a broader set of services) remains possible.

The ban also does not apply to properties purchased under the old thresholds or during the transition period.

For properties with a change of use, there is an additional limitation: they cannot be used as a legal address or a branch of a business.

Replacing the property without losing the permit

If an investor wants to replace a “qualifying” asset, the rule is: the new property must be purchased before selling the old one.

The one-stop service checks the replacement, and only then can the investor dispose of the original property.

If the investor sells first and buys later, the one-stop service partially revokes the permit. In that case, the investor must return to Greece and file a new initial application.

Procedural fixes: what has been simplified

A number of clarifications aim to remove bureaucratic delays that slowed down application processing:

1) Certificates regarding encumbrances are no longer required for initial applications. One-stop services should not request them—even if the application was filed before 31 March 2024 under the old law.

2) If registration of title in the Mortgage Registry or in the Cadastre Service is delayed, the permit may be issued based on evidence that the registration application has already been submitted. Final documents can be provided during the validity period of the permit (up to five years) or upon renewal.

3) Proof of connection to utility networks (electricity, water) is not required in any category. For purchases during the construction phase, the property is often considered complete before construction begins. For conversions to another use category, the key factor is the engineering assessment on the change of use—not whether electricity is already “switched on.”

Attorney Varnavas expects these procedural clarifications to improve application quality and possibly speed up processing. In his view, more uniform checks by one-stop services reduce ambiguity and make outcomes more predictable—and overall, he describes the impact on investors as largely positive.

Work, sanctions, insurance, and the Olomeleia portal

Golden Visa holders still may not work in Greece. They may own shares and sit on company boards as non-executive members, but they cannot be legal representatives or executive directors.

The restriction for applicants from Russia and Belarus remains. It now explicitly also covers applications submitted under a change in the purpose of stay (see Article 12 of Law 5038/2023).

Individuals who received international protection in another EU member state or in a third country (not in Greece) may apply for a Golden Visa on the same basis as third-country nationals.

All applications submitted through a lawyer must go through the Olomeleia portal. If an application is filed outside the system using a lawyer’s personal credentials, it will be archived without any refund of the lawyer’s service fees.

At the time of filing, the applicant must have valid insurance. If not, the authority grants 30 calendar days to provide it. If the deadline passes, the application will be rejected.

Numbers that explain the tightening

Demand for Golden Visa remains high. According to Greek media, in 2025 authorities approved 8,879 permits—about 96% more than in 2024 (4,535).

As of February 2026, Chinese nationals account for 48.1% of all initial permits granted to investors (10,593). Next come Turkish nationals at 16.3% (3,578). The top 10 also includes Lebanon, Iran, the UK, Israel, the United States, Egypt, Armenia, and Serbia.

As reported by Mononews, more than €5 billion has flowed into Greek real estate through the program. With such volumes, schemes involving inflated declared prices and “workarounds” for returning money create strong incentives—while at the same time the government has a reason to show that enforcement is being strengthened.

The key question is whether this will translate into systematic checks across all suspicious cases, or whether the circular will mainly function as a deterrent. That will determine how much market practices actually change.

In the view of Migration Minister Kioutsoukis, the direction is clear: stricter rules “strengthen trust in the market” and protect bona fide investors.

Attorney Varnavas believes the new requirements also align Greece with the broader EU expectations for “migration through investment” programs, enhancing Golden Visa’s international reputation as one of the eight European programs that are still in operation.

If you’re considering Greece Golden Visa, it’s crucial to understand how authorities are tightening scrutiny over deals and listings. Directive 1/2026 strengthens anti-fraud procedures and clarifies which transactions may be treated as non-genuine, so choosing the right property, verifying paperwork, and keeping the transaction structure transparent are key. The team at Digital Nomad will help you assess risks, prepare the right documentation, and organize the process in line with legal requirements.

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