Dec 2025

News

Legal Snapshot: New Joint Ministerial Decisions on Articles 98, 99 (Golden Visa Financial Investments) and 100A (Start-Up Visa) of Immigration Code

As a continuation of Joint Ministerial Decision No. 214926/2025 (Government Gazette B 6014/11.11.2025), issued by the Ministry of Migration and Asylum in cooperation with the Ministry of Development, which revised the documentation and compliance requirements under Article 100 of the Immigration Code (Golden Visa), three new Joint Ministerial Decisions have now been published, providing clarified documentation standards, monitoring obligations and procedural guidance for investment-based residence permits. Collectively, these measures strengthen the legal certainty of the regime by offering clearer rules across four distinct investment pathways, for high-net-worth individuals and investors.

1. Joint Ministerial Decision No. 216169/2025 (Government Gazette B 6092/14.11.2025) – Corporate Investment (Article 98)

This Decision specifies the documentation, eligibility requirements and evidentiary standards for issuing the Golden Visa (Category B3) to investors or qualifying executives of Greek companies. It introduces explicit financial thresholds, such as major shareholders holding at least 33% and investing ≥€500.000, or investors in listed companies holding shares valued at €500.000 independently of percentage—and sets out the conditions for non-remunerated executives, including board members, legal representatives or managers, of companies with assets or turnover of at least €4 million. It also clarifies eligibility for executives of foreign companies whose Greek branches meet the same thresholds. The residence permit is valid for five years and renewable as long as the investment or corporate role continues.

2. Joint Ministerial Decision No. 216718/2025 (Government Gazette B 6217/20.11.2025) – Financial Investments (Article 99)

This Decision details the documentation, verification and ongoing monitoring requirements for all eligible financial investment categories, including capital injections into Greek companies, REICs (AEEAP) participation, Venture Capital and Private Equity vehicles (ΕΚΕΣ, ΑΚΕΣ), Alternative Investment Funds, government bonds, fixed-term deposit and listed securities. It introduces uniform assessment criteria, a clearer certification process and continuous oversight obligation, areas previously governed only by general principles. It also establishes rules on reporting material changes to the investment and provides explicit guidance on the number of residence permits that may be issued when investments are made through legal entities.

3. Joint Ministerial Decision No. 216761/2025 (Government Gazette B 6138/18.11.2025) – Investment in Greek Start-up Companies (Article 100A)

This Decision outlines the documentation, certification procedures and monitoring mechanisms for investments in Start-Ups registered on Elevate Greece. It sets out obligations for both investors and participating companies and clarifies how many residence permits may be issued in each investment scenario, whether the investor participates individually, through a legal entity or within a broader structure, providing predictability for those pursuing the start-up investment route.

Overall, these Joint Ministerial Decisions introduce clearer documentation requirements, defined verification processes and consistent procedural safeguards, enhancing transparency and administrative certainty for third-country nationals seeking residence in Greece through corporate, financial or start-up investments.

Contact our team at: gv@machas-partners.com for more information.