Greece Golden Visa Circular 2026:: Rules Explained 2026
Circular 1/2026 (22 Apr 2026) activates Law 5100/2024. Documentation, property tiers, processing steps, and what changed for investors.
By Greek Invest Editorial · Updated June 17, 2026 · 9 min read
Quick answer: Circular 1/2026, issued 22 April 2026 by the Greek Ministry of Immigration, translates Law 5100/2024’s framework into step-by-step operational rules. It codifies property tier thresholds, the required documentation package, and processing sequencing that immigration offices must follow. Every investor who signed a preliminary contract or paid a deposit after the law’s enactment date is subject to these rules in full.
What Circular 1/2026 Is and Why It Matters
Greece’s Golden Visa programme has operated under three overlapping legal layers since mid-2024: the original 2013 framework, Law 5100/2024 that restructured the property tier system, and the long-awaited implementing circular that tells officials precisely how to execute the new rules. Circular 1/2026, signed by the Ministry of Immigration and published in the official government gazette on 22 April 2026, is that third layer.
Without an implementing circular, civil servants handling applications at regional immigration offices (the Aliens and Immigration Departments) had been relying on interim internal guidance that varied between Athens, Thessaloniki, and the island prefectures. Circular 1/2026 ends that inconsistency. It is now the single authoritative reference document for every case officer processing a Golden Visa application under Law 5100/2024.
For investors, this matters because the circular contains details that neither the law itself nor the explanatory memorandum fully specified. These include the exact form of the property classification certificate, the clock-start definition for the 15-day completeness check, how co-ownership applications are evaluated when two buyers jointly purchase a property above the threshold, and the evidentiary standard required to prove full payment in foreign currency.
Property Tier Classification Under the Circular
Law 5100/2024 introduced a tiered minimum investment structure. The circular operationalises these tiers by defining precisely how the purchase price is verified and how mixed-use or partially converted properties are classified.
The Three Active Tiers
| Tier | Minimum Investment | Applicable Zones |
|---|---|---|
| Tier 1 | €800,000 | Attica region, Thessaloniki, Mykonos, Santorini, islands over 3,100 residents |
| Tier 2 | €400,000 | All other mainland prefectures and islands not in Tier 1 |
| Tier 3 (conversion route) | €250,000 | Commercial-to-residential conversions and listed building restorations nationwide |
The circular adds clarification on two edge cases that caused significant confusion in 2025:
- A property located partly within an Attica municipality boundary and partly outside it is classified at the higher Tier 1 threshold. The rule follows the cadastral registration address, not the physical footprint.
- A new-build apartment within a mixed-use development (ground floor commercial, upper floors residential) is classified based on the residential unit’s own valuation, not the whole building’s value. The investor must obtain a separation certificate from a licensed civil engineer confirming the standalone valuation exceeds the applicable tier minimum.
The €250,000 Conversion Route
The third tier at €250,000 was introduced to incentivise regeneration. Circular 1/2026 tightens the eligibility criteria that the 2024 law left ambiguous:
- The commercial-to-residential conversion must be completed and inspected before the Golden Visa application is submitted, not at the time of purchase.
- A certified completion report (Certificate of Final Inspection by the local urban planning authority) is a mandatory document in the application file.
- Listed building restorations qualify at €250,000 regardless of location, but the investor must produce a signed restoration agreement with the Central Archaeological Council and evidence that at least 40 percent of the restoration cost has been disbursed before application.
Investors pursuing this route frequently work alongside the standard buy-side process. The guide on the Greece Golden Visa €250,000 conversion route covers the full workflow in detail.
Documentation Package: What the Circular Requires
Previous versions of the application checklist circulated informally and differed between prefectures. Circular 1/2026 establishes a single national list. Incomplete files will be rejected at the completeness stage and the 15-day review clock will not start.
Mandatory Documents: Property and Transaction
- Notarised final purchase contract (not a preliminary agreement) or, for off-plan properties, notarised evidence of full payment of the purchase price.
- Property registration certificate from the Hellenic Cadastre issued no more than 30 days before the application submission date.
- Property classification certificate from a licensed civil engineer confirming the property’s tier, its residential use designation, and the absence of outstanding urban planning violations (arbitrary constructions). This is a new requirement introduced by the circular and was not in prior informal checklists.
- Bank transfer documentation showing funds originated outside Greece. A SWIFT confirmation or correspondent bank statement is acceptable. Cash payments and transfers from Greek bank accounts of the investor are explicitly excluded.
- Proof of property insurance covering at least the municipal taxable value (ENFIA base), valid for the full residency permit duration.
Mandatory Documents: Investor Identity and Status
- Valid passport with at least 18 months’ remaining validity at the time of application.
- Recent criminal record certificate from the investor’s country of nationality and, if different, country of residence, apostilled and translated into Greek by a certified translator.
- Health insurance policy providing coverage within Greece for the investor and all family members included in the application.
- Completed and signed application form (new version published alongside the circular; the 2023 version is no longer accepted).
Co-Ownership Applications
Where two investors jointly purchase a single property to reach the tier threshold, Circular 1/2026 specifies that each investor must independently satisfy the minimum investment amount. A Tier 1 property worth €800,000 jointly purchased by two investors at €400,000 each does not qualify either investor under Tier 1. Each would need to demonstrate a qualifying solo investment.
This affects a significant number of applications that relied on a previous informal interpretation. Investors in this situation should review the property tiers guide and consult a licensed Greek lawyer before submitting.
Processing Stages: The Two-Phase Review
Circular 1/2026 formally splits the immigration office’s review into two sequential phases with defined time limits. This is a significant change from the previous single-queue system that had no statutory clock.
Phase 1: Completeness Check (15 calendar days)
Within 15 calendar days of the application file being lodged, the case officer must confirm that all mandatory documents are present, that translations are certified, that notarisations carry an apostille, and that the application form is the current version. If any document is missing or non-compliant, the file is returned in its entirety. The applicant receives a written deficiency notice listing every missing item. The 15-day clock does not restart when the corrected file is resubmitted, instead, Phase 1 repeats from day one for the resubmission.
Phase 2: Substantive Review (up to 60 calendar days)
Once Phase 1 is completed without deficiency, the case moves to substantive review. The case officer verifies the legal status of the property, confirms the tier classification certificate against cadastral records, checks criminal record certificates against national databases, and validates the health insurance policy. The circular sets a 60-day outer limit for this phase. If no decision is issued within 60 days, the application is deemed approved by administrative silence, a provision that existed in earlier law but was inconsistently applied. The circular confirms it applies to Law 5100/2024 applications in full.
Biometric Appointment
Biometric enrolment (fingerprints and digital photograph) must occur after Phase 2 approval is issued and before the physical residence permit card is produced. The circular sets a 30-day window from the approval decision for the investor to attend a biometric appointment at the issuing prefecture. Missing this window does not void the approval, but it delays card production and restarts the 30-day window only once.
For a full timeline with realistic waiting periods based on 2025 processing data, see the Greece Golden Visa application timeline guide.
The Short-Term Rental Prohibition: Operational Rules
One of the most commercially significant provisions of Law 5100/2024 was the prohibition on using a Golden Visa property for short-term rental (Airbnb-style platforms). Circular 1/2026 operationalises this by:
- Requiring a signed declaration from the investor at application stage that the property will not be offered on short-term rental platforms for the duration of the residency permit.
- Authorising the Ministry of Digital Governance to share platform registration data with the Ministry of Immigration on a quarterly basis for cross-checking.
- Specifying that confirmed short-term rental of the qualifying property triggers a formal revocation procedure, not merely a fine. The investor receives a 30-day notice to cease the rental and remove all platform listings. If the violation continues, the residency permit is revoked and a five-year ban on reapplication applies.
Long-term rental (12-month contracts registered with the tax authority) is explicitly permitted. Investors whose strategy depends on rental income should review the Greece Golden Visa no short-term rental guide before committing to a property.
Grandfathering: Who Is Under the Old Rules
The circular specifies a precise grandfathering cutoff. Applications governed by pre-Law 5100/2024 rules must satisfy all three conditions:
- A preliminary purchase agreement was signed and notarised before the law’s enactment date.
- A deposit of at least 10 percent of the purchase price was paid and documented by the enactment date.
- The final notarised purchase contract was completed and the full purchase price paid before 31 December 2025.
Investors who signed preliminary agreements before the law’s enactment but have not yet completed the final contract are not fully grandfathered under the circular’s interpretation. They are subject to the new tier thresholds if the final contract is executed after the cutoff. This is a narrower grandfathering window than many investors and lawyers assumed from the law’s text alone.
For investors purchasing in the Attica region or on major islands, the practical consequence is that the applicable threshold may be €800,000 rather than the €250,000 minimum some were expecting to rely on.
The 120 Square Meter Residential Use Rule
The circular cross-references and confirms the 120 square meter minimum residential floor area requirement that applies to qualifying properties in high-demand zones. This rule, which was introduced to prevent micro-apartment Golden Visa products from dominating the Athens market, is now a documented element of the completeness check. The property classification certificate must include the gross floor area of the residential unit, and any property below 120 square meters in a Tier 1 zone is flagged for additional scrutiny.
The Greece Golden Visa 120 square meter rule guide explains how this interacts with new-build, conversion, and resale transactions.
What the Circular Does Not Change
Circular 1/2026 is an implementing document, not a policy revision. Several elements of the programme remain unchanged:
- The five-year initial residence permit duration and the unlimited renewal cycle.
- The physical presence requirement: zero nights per year are required to maintain the permit (though citizenship naturalisation requires seven years of genuine residence).
- Family reunification eligibility: spouse or registered partner, minor children under 21, dependent parents of the main applicant and spouse, and dependent adult children under 24 who are full-time students all remain eligible as family members on a single application.
- The investment types beyond property: Greek company shares, Greek government bonds, bank deposits in Greek credit institutions, and investment funds focused on Greek assets remain valid qualifying instruments. The circular’s documentation requirements apply to property-route applications only.
For the broader context of buying property as a foreign national in Greece, including legal ownership structures, see the buying property in Greece as a foreigner guide.
Practical Implications for Investors in 2026
The publication of Circular 1/2026 removes a substantial source of operational uncertainty that had slowed applications processed through 2025. The two key practical changes investors should prepare for are:
The property classification certificate from a licensed engineer is a new cost and a new potential delay. In practice, obtaining this certificate takes between one and three weeks and costs between €500 and €1,500 depending on property complexity. Investors should factor this into their pre-submission timeline.
The Phase 1 completeness check is now strict and fully documented. Files returned in Phase 1 are not added to the back of the queue, they restart Phase 1 from scratch. A single missing apostille can add six to eight weeks to the total processing time. Having a Greek lawyer review the full document package before lodging the file is no longer a precaution; it is a practical necessity.
Investors looking at the full cost picture should also review the cost of buying property in Greece guide, which covers transfer taxes, notary fees, cadastral costs, and the engineering certificates now required under the circular.
Required documentation matrix
| Document | Issued by | Purpose in GV file |
|---|---|---|
| Property classification certificate | Licensed engineer | Confirms tier, residential use, 120m² usable area |
| Notarised purchase deed or preliminary | Notary | Proves price, ownership path, clean title chain |
| Proof of full payment | Greek bank | Matches contract value and tier threshold |
| AFM certificate | AADE | Tax ID for buyer and co-applicants |
| Insurance / utilities contract | Provider | Shows lawful residential occupation where required |
| Immigration application form | Ministry | Ties property bundle to residence permit request |
Frequently Asked Questions
Circular 1/2026 is the implementing ministerial circular published by the Greek Ministry of Immigration on 22 April 2026. It translates the provisions of Law 5100/2024 into step-by-step operational rules for immigration offices nationwide, covering documentation requirements, property tier classification, processing stages, and the short-term rental prohibition enforcement mechanism.
No. The three-tier structure from Law 5100/2024 remains intact: €800,000 in Attica and high-demand islands, €400,000 in all other zones, and €250,000 for commercial-to-residential conversions and listed building restorations. What the circular does is clarify how mixed-use buildings are classified and confirm that co-owners must each independently meet the applicable threshold.
The property classification certificate is a document issued by a licensed civil engineer confirming the property's tier classification, its residential use designation, its gross floor area, and the absence of unresolved urban planning violations. It is a mandatory document for all property-route Golden Visa applications under Law 5100/2024. Obtaining it typically takes one to three weeks and costs between €500 and €1,500.
Phase 1 (completeness check) must be completed within 15 calendar days of file lodging. Phase 2 (substantive review) has an outer limit of 60 calendar days. If no decision is issued within 60 days from the start of Phase 2, the application is deemed approved by administrative silence. Total processing from a complete file submission to permit card issuance is typically four to five months in 2026.
Only partially. The circular requires all three conditions for full grandfathering: a notarised preliminary contract signed before the law's enactment, a documented deposit of at least 10 percent paid by that date, and completion of the full notarised purchase contract with full payment before 31 December 2025. Investors who have signed a preliminary agreement but have not yet completed the final contract are subject to the new tier thresholds under the circular's interpretation.
Using the qualifying property for short-term rental is prohibited under Law 5100/2024 and the circular operationalises enforcement: the investor signs a declaration at application stage, platform data is cross-checked quarterly, and confirmed violations trigger a formal revocation procedure. You receive a 30-day notice to cease, and if the violation continues, the residence permit is revoked and a five-year reapplication ban applies. Long-term rental under a registered 12-month contract is explicitly permitted.
Joint purchase of a single property is permitted, but each co-investor must independently satisfy the applicable tier minimum. Two investors splitting the cost of an €800,000 Athens apartment at €400,000 each do not qualify under Tier 1 rules. Each would need to demonstrate a solo qualifying investment at or above the threshold for their chosen zone.
No. Circular 1/2026 specifically addresses the property acquisition route under Law 5100/2024. Greek company shares, government bonds, bank deposits in Greek credit institutions, and qualifying investment fund applications continue to follow the procedural rules applicable to those instruments. The documentation changes and processing stage structure described in the circular are property-route specific.
No. The circular does not alter the physical presence rules. Greece's Golden Visa has no minimum stay requirement for maintaining the residence permit. Investors may live anywhere in the world and the permit renews indefinitely provided the qualifying investment is maintained. Physical presence requirements only become relevant when applying for permanent residence after five years or citizenship after seven years of genuine habitual residence.
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