<!-- Appendix J — from "After the EU's Golden Passports", Kestrel Private, 6 August 2026. Canonical: https://kestrelprivate.com/research/after-the-golden-passports -->

# Appendix J — Implementation Timeline

This appendix is the working form of Chapter 17. It restates the implementation sequence as three instruments a professional can use directly: a stage-by-stage timeline (Table J.1), a statement of which workstreams may run concurrently and which must not (Table J.2), and the recurring calendar that begins once the position exists (Table J.3). Every row carries the section of the report it derives from, and nothing appears here that is not established there. Durations are marked **[V]** where an official processing standard or statutory time limit exists and **[I]** where the figure is practice, published by a programme channel or reported by secondary sources and therefore indicative only. No timetable in this appendix is a commitment. Government processing times are outside the control of any adviser, and the outcome of every application — citizenship, residence, banking and tax — rests with the respective government or institution alone (§18.9). Where the body of the report qualifies a point as requiring confirmation at the date of application, the qualification is repeated here and travels with the row wherever the appendix is used, including in isolation.

**Actor key.** C = the client and family. K = Kestrel Private, acting as coordination only and not as legal, tax, immigration or investment advice (§18.1). P = the locally admitted regulated professional (Greek immigration counsel, property lawyer, notary, engineer, accountant or tax representative; on the citizenship side the programme's designated application channel and licensed agent). G = a government authority, registry or regulated institution.

## J.1 Stage-by-stage timeline

| # | Stage | What happens | Who acts | Documents in play | Indicative duration | What can stall it | Section |
|---|---|---|---|---|---|---|---|
| 1 | Initial strategy assessment | Structured assessment of nationalities held by each family member, countries of residence and tax residence, objectives, funding available and its origin, and time horizon | C provides facts; K assesses | None filed; internal assessment record; written engagement terms (fixed professional engagement fee agreed in writing before work begins) | No fixed duration **[I]**; no government engaged | Incomplete facts — an undisclosed nationality, an unresolved residence history, an unclear funding source | §17.1 |
| 2 | Rights and objectives mapping | Each objective is mapped to the single instrument that would provide it, and the objectives the structure cannot meet are identified | K; C decides | Objectives schedule (Appendix A consolidates) | No fixed duration **[I]** | Objectives the structure does not provide (EU citizenship, unrestricted EU employment, guaranteed banking or tax results) surfacing late | §17.2, §1.7, §13.14 |
| 3 | Suitability decision | Documented suitability view under the Chapter 13 criteria, including the decline criteria; the correct output may be a recommendation not to proceed or to proceed with fewer components | K recommends; C decides | Suitability record | No fixed duration **[I]** | A negative suitability view; the decision binds no government | §17.3, §13.12–§13.14 |
| 4 | Source-of-funds pre-clearance | The source-of-wealth and source-of-funds file is assembled before anything is filed anywhere, because every later gate consumes the same file | C produces records; K coordinates assembly and consistency-checking; P opines where needed | Evidence classes of Chapter 15 (Appendix F is the checklist); bank documentation; declaration of lawful origin of funds | Weeks where affairs are already audited, substantially longer where historical documentation must be reconstructed — a general observation, not a verified figure **[I]** | The deferral triggers at §15.14; an application that would fail here should be deferred, not filed and refused | §17.4, §15.14 |
| 5 | Family eligibility confirmation | Each family member is tested against two distinct family rules — Article 95(2) of Law 5038/2023 on the residence side, and the decree's dependant definition by reference to Lei n.º 7/2022 on the citizenship side | K coordinates; P advises; C evidences | Birth, marriage and dependency evidence; police clearances; consent and custody documents; translations and legalisation | No fixed duration **[I]** | Documentary gaps; the São Toméan dependant-definition uncertainty, which requires an applicant-specific legal explanation before a family application is priced or filed; the three-nationality position of each member | §17.5, §16.7–§16.10, §13.2 |
| 6 | Property selection | The client selects, with the client's own advisers, against Chapter 8's investment tests; the property must pass the property-without-immigration test on its own merits | C decides; K coordinates | Marketing particulars; preliminary planning and title information | No fixed duration **[I]**; should not conclude before stage 7 has begun on the shortlisted property | Marketed stock failing the immigration gates on inspection; asking prices reflecting the statutory floor rather than the district market | §17.6, §8.3, §8.7, §8.15 |
| 7 | Property legal and technical due diligence | Lawyer and engineer work in parallel: title searched for at least 20 years with encumbrances; building-legality certificate; change-of-use technical report in the prescribed form naming the qualifying planning acts | C instructs and pays; K coordinates scope and completeness; P reports in writing | Title and encumbrance certificates (KAEK-based or legacy person-based indexes); building-legality certificate under Article 83 of Law 4495/2017; change-of-use technical report; Electronic Building Identity; energy performance certificate | Property-specific and unverified as a market figure **[I]**; no published tariff market — written quotations required | Planning defects; unregularised works; registry backlogs; any indication that the conversion is paper-only rather than an actual completed change of use | §17.7, §14.4, §10.8 |
| 8 | Tax and structural assessment | Holding form fixed (personal ownership is the reference case; acquisition through a legal person admitted only where the applicant holds 100% of it); the property's acquisition-tax position confirmed; home-country interaction and death-tax exposure reviewed; funds-flow plan fixed | P advises in each relevant jurisdiction; K coordinates; C decides | Tax advice; entity documents where used; funds-flow plan (remitting accounts, names, currency-conversion arrangements) | No fixed duration **[I]**; must complete before contracts are signed | Structures that would create Greek corporate tax residence or that fail the 100%-ownership evidence rule; unresolved home-country positions | §17.8, §9.12, §10.6, §10.9, §14.13 |
| 9 | Engagement of local regulated professionals | The professional bench is engaged before any filing; every regulated act is performed by the locally admitted professional | K coordinates scope, sequence and completeness; P engaged; C instructs | Engagement letters; written fee quotations; powers of attorney drawn before a Greek consular authority or a foreign notary and apostilled or consular-legalised | No fixed duration **[I]**; should not be compressed | Document legalisation logistics; conflicts checks; a defective power of attorney invalidates steps taken under it | §17.9, §18.1 |
| 10 | Property reservation and acquisition | Sequence: tax number, funds, deed, registration. Full price paid before the residence application, only through the statutory channels; transfer tax declared and paid before the deed; deed registered | C (or attorney under power of attorney); P (lawyer, notary); G (tax authority, registry); banks | Tax number (AFM) and tax-representative designation; reservation or pre-contract instrument reviewed by the lawyer; crossed bank cheque, credit transfer or card payment through a provider operating in Greece; notarial deed recording all payment details; registration application or lawyer's certificate | No official standard exists for a private conveyance **[I]**; driven by due diligence, funds transfer and registry practice | Objective-value complications in the tax declaration; the seller's own certificates; registry backlog; funds arriving by a non-qualifying route, which cannot support the permit | §17.10, §14.17 |
| 11 | Residence application — filing | Digital-only filing through the immigration portal, capable of being made by proxy before the applicant has entered Greece | P files; C funds; G receives | Passport (entry evidence where the applicant has entered; not required on the proxy route); notarial certificate; registration proof or attestation/lawyer's certificate; 100%-ownership evidence where an entity is used; engineer's technical report; private insurance policy; E9 copy; electronic fee €2,000 plus €16 card (€2,016 total for the main applicant), €150 per family permit, minors exempt from the permit fee | Same-day filing once the file is complete **[I]** | Incomplete technical or notarial documents; insurance policies that do not meet the applied minimums | §17.11 |
| 12 | Certificate of submission | On a complete filing the applicant receives the certificate of submission (the "blue receipt"), valid until the decision; it certifies lawful residence and its holder temporarily enjoys the rights flowing from the requested permit | G issues | Certificate of submission | Issued on complete filing; valid until decision **[V]** | Whether the certificate supports short-stay circulation in other Schengen states is not documented in any official source located; travel planning should assume that Schengen mobility begins with the card, not the receipt | §17.11 |
| 13 | Biometrics — the one compulsory visit | On the proxy route the applicant and each family member must enter Greece and submit biometric data — both index fingerprints to passport specifications, collected only in Greece — with the outstanding insurance document | C attends; G collects | Passport used for entry; insurance policy; summons | Exclusive 12-month period from filing (Article 10 §11 of Law 5038/2023) **[V]**; optional national-visa entry route carries a €180 consular fee | Summons logistics for large families; two failures to appear at the summoned date cause rejection; the window does not pause for any other workstream | §17.11, §14.17 |
| 14 | Residence decision | The Ministry decides; refusal is subject to administrative appeal | G decides; P follows up | Decision; appeal where required (fee €50) | Official completion standard of 50 days running from file completion **[V]** — on the proxy route the file completes only when biometrics are given, so this is never an end-to-end time. Official counterweight: 10,032 investor applications pending as at March 2026, including 3,399 filed in 2024 **[V]**. No reliable end-to-end figure can be stated | The caseload tail; documentary deficiencies. Appeal within two months, decided within 30 days **[V]** | §17.11, §14.6 |
| 15 | Card collection | The card may be collected by proxy for the investor categories against a certified copy of the passport, so no second visit is required for collection | P collects; C authorises | Certified passport copy; power of attorney | No official standard **[I]** | Reissue or correction requirements | §17.11, §17.15 |
| 16 | Citizenship — preparation and submission | Electronic submission via the responsible unit's platform on the official form in Portuguese or English, through the programme's designated application channel; promotion of the programme must be licensed | C signs; P (licensed agent) submits; K coordinates | Certified passport copies; criminal-record certificates issued within the last three months from countries of nationality and of residence of the last five years; proof of residence; medical certificate; declaration of lawful origin of funds with supporting bank documentation; certified translations; apostilled or consular-authenticated foreign documents; proof of payment of the US$5,000 due-diligence and processing fee (non-refundable after submission); due-diligence report from a recognised entity | No fixed duration for preparation **[I]** | Document currency (the three-month criminal-record rule); legalisation; the nationality cap and the reported April 2026 holds | §17.12, §17.5 |
| 17 | Admission and preliminary appreciation | The unit admits only complete files and makes a preliminary appreciation, with power to request additional elements | G | Admission record; requests for further elements | 15 days (Decree-Law 07/2025, Art. 10) **[V]** | Incomplete files are not admitted; requests for further elements restart practical timing | §17.12 |
| 18 | Due diligence and review | Independent external entities engaged by the unit perform due diligence on all applicants and criminally-imputable dependants; interviews may be required in person or by video; a consultative Review Committee chaired by a Public Prosecutor's representative verifies compliance | G and its appointed entities; C attends interviews | Due-diligence reports; interview record | No statutory limit stated for this phase **[I]** | Precautionary suspension of the file on serious concerns; interview scheduling | §17.12 |
| 19 | Public Prosecutor consideration | The completed file goes to the Ministério Público for a prior visto | G | File; visto | 30 days under the Nationality Law (Decree-Law 07/2025, Art. 11; Lei n.º 7/2022, Art. 10) **[V]** | Refusal of the visto causes the process to lapse | §17.12, §14.5 |
| 20 | Citizenship decision | After the visto, or Public-Prosecutor silence, the unit's Director decides with legal reasoning | G | Reasoned decision | 15 days from the visto (Decree-Law 07/2025, Art. 14) **[V]**. Programme-channel and industry figures for the whole citizenship process — approximately 1.5 to 3 months to decision, average 2.5 months in the first cohort — are published or reported figures, not independently audited, and carry limited predictive weight given the programme's short operating history **[I]** | The unresolved articulation between grant by Government decree on the justice minister's favourable opinion (Lei n.º 7/2022, Art. 12) and approval by the Director's despacho (Decree-Law 07/2025, Art. 14) requires an applicant-specific legal explanation; no reading should be assumed | §17.12, §6.12, §14.5 |
| 21 | Contribution deposit | Delivery of the approval certificate is conditional on deposit of the contribution into the National Transformation Fund's exclusive account: US$90,000 single applicant, US$95,000 family of two to four members, US$5,000 per additional qualifying dependant | C pays; G receives | Approval certificate; deposit evidence | 90 days from approval, failing which the process lapses (Decree-Law 07/2025, Art. 14; Anexo I) **[V]** | Funds transfer and correspondent-banking friction; the contribution is non-refundable and the decree contains no express refund clause for any post-deposit scenario | §17.12, §6.7, §14.15 |
| 22 | Oath and registration | The applicant swears the oath of fidelity before a public official in São Tomé and Príncipe or, where abroad, before the competent diplomatic or consular agent; the decree imposes no travel, visit or residence requirement. The file then passes to the central registry for transcription | C swears; G registers | Oath record; registry transcription | Transcription within five days of the oath, per the decree as stated at §17.12 **[V]** | Consular scheduling | §17.12 |
| 23 | Banking application | Banking starts early, in parallel with stage 6, and its outcome is never assumed: an institution that cannot complete customer due diligence must not establish the relationship, and nothing obliges any bank to accept a customer | C applies; P supports; G (the bank) decides | Passport or passports; tax number; address and activity evidence; the source-of-funds file of stage 4 | No official standard exists; weeks to months should be planned for, without commitment — a planning observation, not a verified figure **[I]** | Risk-based refusal; requests for original-identity documents where a citizenship-by-investment document is presented; from 10 July 2027 the EU Anti-Money-Laundering Regulation carries the same refusal obligation and expressly requires collection of all nationalities held | §17.13, §9.4–§9.5, §14.9 |
| 24 | Tax-residence implementation | Applies only where the client contemplates genuine relocation to Greece and separately qualifies; for the non-relocating reference client there is nothing to implement and the default position is no Greek tax residence | P (Greek tax counsel); C decides | Elective-regime application; evidence of transfer of qualifying funds into a Greek bank account | Investor-regime application by 31 March of the tax year; non-Greek tax residence in seven of the eight preceding years; €500,000 qualifying investment completed within three years — reported pending gazette-text confirmation and requiring confirmation at the date of application **[I]** | The €250,000 reference property is half the investor-regime investment threshold, and the regime's investment-condition waiver attaches to a different permit category, not to the property permit used in this structure | §17.14, §9.6, §9.7 |
| 25 | Approval and document issuance — Greece | The decision issues the five-year permit as a stand-alone electronic card; collection may be by proxy. The card, not the certificate of submission, is the document that carries the short-stay Schengen mobility arising from Article 21 of the Convention Implementing the Schengen Agreement | G issues; P or C collects | Residence card; collection authority | Five-year validity **[V]**. A 2026 law is reported to run card validity from issuance rather than the application date; the gazette text had not been read at the date of this report and the point requires confirmation, as it affects the renewal diary **[I]** | Card production and collection logistics; identity-data corrections | §17.15, §7.10 |
| 26 | Approval and document issuance — São Tomé and Príncipe | After the oath and registration the citizenship documents issue: certificate of registration, national identity card and passport | G issues; P coordinates | Certificate of registration; national identity card; passport | The programme channel states that the passport currently follows approval by about three months **[I]**. The channel publishes an aggregate charge of US$750 per applicant for the three documents; the gazetted fee schedule contains no document fees, so the amount requires confirmation at the date of application **[I]**. The passport's validity period is not published in any official source located and requires confirmation at the date of application | Identity-card enrolment (reported possible remotely by video verification since April 2026; previously in person in São Tomé, Lisbon or Brussels); the reported hold on passport issuance to adult dependent children, with no lifting located as at 2 August 2026. The six-month judicial-opposition window runs from the declaration of acquisition of nationality (registration), not from document issuance, and is therefore already running when the documents issue — approval is not the end of legal exposure | §17.15, §17.12, §14.15 |
| 27 | Post-approval compliance begins | The position created is maintained, not merely held: standing property and use conditions, migration-registry declarations, and the first Greek tax obligations | C; P; G | See Table J.3 | Continuous from issuance **[V]** | Failure to make the first E9 declaration is the commonest failure of foreign owners; declaration duties on change of nationality and passport details carry fines | §17.16, §17.17 |

Caption to Table J.1: The sequence assumes the reference case — a non-EU-national applicant acquiring one €250,000 change-of-use property in personal ownership, filing the Greek application by proxy before entering Greece, and applying for São Toméan citizenship in parallel, with no relocation to Greece. Fees stated are those in Chapter 10 and Chapter 17: Greek electronic fee €2,000 plus €16 card = €2,016 for the main applicant; €150 per family permit; €450 for a child's three-year independent permit at 21; €50 administrative-appeal fee; €180 optional national-visa consular fee; €100 permit reissue fee. Citizenship-side figures: US$5,000 due-diligence and processing fee; contribution US$90,000 (single) / US$95,000 (family of two to four) / US$5,000 per additional qualifying dependant; US$750 per-applicant document charge published by the programme channel and requiring confirmation. **[V]** durations derive from Law 5038/2023 (consolidated), the official administrative record at mitos.gov.gr, the Ministry of Migration and Asylum's March 2026 bulletin, Decree-Law 07/2025 and Lei n.º 7/2022. **[I]** durations derive from the programme channel's published material, industry reporting of programme-supplied data, or stated planning observations, and are not verified. No duration is guaranteed and government processing times are outside any adviser's control. Derived from §17.1–§17.16, with risk cross-references to §14.4–§14.9, §14.15 and §14.17.

## J.2 Parallel and sequential workstreams

The two components are legally unconnected. They are administered by two states, on two timetables, with different points at which conditions crystallise, and nothing coordinates them but the client's own planning (§14.17). The table records what that permits and what it forbids.

| Workstreams | Relationship | Reason | Section |
|---|---|---|---|
| Citizenship application (stages 16–22) and residence application (stages 11–15) | May run concurrently | The applications are legally unconnected and neither is a condition of the other; the citizenship application runs in parallel through its own channel | §17.12, §14.17 |
| Banking application (stage 23) and property selection (stage 6) | May run concurrently; banking should start early | The statutory purchase-payment channels can be satisfied by credit transfer from existing foreign accounts, so the acquisition does not fail for want of a Greek account, but a Greek account is commonly needed afterwards for utilities, insurance, tax and rent receipts | §17.13 |
| Legal and technical due diligence (stage 7) | Internally concurrent | Lawyer and engineer work in parallel on the selected property and produce separate documents doing different work; a property may pass one and fail the other | §17.7, §14.4 |
| Family eligibility confirmation (stage 5) and source-of-funds pre-clearance (stage 4) | May run concurrently | Both are documentary assemblies with independent lead times, and both precede any filing | §17.4, §17.5 |
| Tax and structural assessment (stage 8) and due diligence (stage 7) | May run concurrently | Both inform the same decision to contract; neither depends on the other's output | §17.7, §17.8 |
| Suitability decision (stage 3) → any engagement of professionals or governments | Must be sequential | No cost should be incurred before the suitability view is documented, and the correct output may be a recommendation not to proceed | §17.3, §13.14 |
| Source-of-funds pre-clearance (stage 4) → any filing anywhere | Must be sequential | Every later gate consumes the same file, and an application that would fail this step should be deferred, not filed and refused | §17.4, §15.14 |
| Due diligence (stage 7) → reservation payment and acquisition (stage 10) | Must be sequential | No reservation payment should be made before due diligence is complete, and any reservation instrument should be reviewed by the lawyer first; reservation practice is unregulated by the permit legislation | §17.7, §17.10 |
| Tax and structural assessment (stage 8) → signature of contracts (stage 10) | Must be sequential | The holding form, the acquisition-tax position and the funds-flow plan are fixed before contracts are signed | §17.8 |
| Powers of attorney legalised (stage 9) → any act by proxy (stages 10, 11, 15) | Must be sequential | A defective power of attorney invalidates the steps taken under it | §17.9 |
| Completion of the change of use → filing of the residence application (stage 11) | Must be sequential | The statutory text requires the change of use to be completed before the application; the official administrative record adds that completion must fall after 5 April 2024 and before submission | §17.6, §17.10, §17.11 |
| Full payment of the price and execution of the deed (stage 10) → filing (stage 11) | Must be sequential | The whole price must be paid before the application, only through the statutory channels; the notarial deed records the payment details on which the file relies | §17.10, §17.11 |
| Citizenship stages 17 → 19 → 20 → 21 → 22 | Must be sequential in the decree's own order | The decree's sequence is admission, visto, decision, deposit, oath. "Approval in principle" is the channel's vocabulary and is not a stage of the decree | §17.12 |
| Approval (stage 20) → contribution deposit (stage 21) | Must be sequential, and is time-limited | The contribution is payable only after approval, within 90 days, failing which the process lapses | §17.12, §6.7 |
| The 12-month biometric window (stage 13) and everything else | Must not be assumed to accommodate the other workstream | The exclusive 12-month period does not pause for a citizenship application, a passport reissue or a change of personal circumstances, and two failures to appear cause rejection | §14.17, §17.11 |
| Issue of the São Tomé passport (stage 26) and the residence file (stages 11–15) | Must not be treated as independent | The permit is in practice a nationality-bearing document recording the nationality of the passport against which the application was made; a permit issued against the original passport paired with a new São Tomé passport may fail identity matching at a border applying the strictest documented national standard. Whether Greece re-keys the permit to a newly acquired second nationality while the original subsists is unpublished and requires Greek-counsel confirmation at the date of application | §14.17, §17.16 |
| The two components' commitment patterns | Opposite, and must not be planned on a common assumption | On the residence side more than €250,000 is irrevocably committed before any residence decision exists; on the citizenship side the processing fee is non-refundable after submission but the contribution is payable only after approval. A file sitting between the fixing points of one component is exposed to change in the other | §14.17, §14.2 |

Caption to Table J.2: The relationships are those established at §17.1–§17.16 and analysed as risk at §14.17; stage numbers refer to Table J.1. Mitigation, as stated at §14.17, is a single sequencing plan fixing the order of the two applications, the compulsory-visit window and the passport position before either file is opened (§5.9, §17.1), with travel on the matching original passport pending Greek counsel's advice on declaration and reissue. What cannot be mitigated is that two sovereign administrations run two independent timetables and neither is obliged to accommodate the other.

## J.3 Renewal and monitoring calendar

| When it falls due | Obligation | Action and documents | Consequence of default | Section |
|---|---|---|---|---|
| Standing, for the life of the permit | Qualifying property retention | Retain full ownership and possession of the property; long-term letting only | Sale revokes the permit; short-term letting or sub-letting carries revocation and a €50,000 administrative fine | §17.16, §17.17, §7.12 |
| Standing, for the life of the permit | Change-of-use conditions | Principal spaces remain residential; the property is not used as the seat or branch of a business | Revocation; fines attach to the corresponding breaches | §17.16, §17.17 |
| Standing, from acquisition of São Toméan nationality | Nationality cap | No acquisition of a fourth nationality without accepting immediate loss of São Toméan nationality | Loss by operation of law | §17.16, §17.17 |
| Once, six months from the declaration of acquisition of nationality | São Tomé judicial-opposition window | Diarise opening and expiry; retain counsel availability; the opposition has no suspensive effect on the acquisition | Opposition, if instituted and successful, can end in loss of nationality | §17.12, §17.15, §14.15 |
| Annually, per family member | Private health insurance | Policy meeting the applied coverage minimums — fixed under the predecessor Code and still applied in practice, requiring confirmation at the date of application; foreign policies qualify only with an express clause covering the period of residence in Greece | Residence condition unmet at renewal | §17.17, §17.11 |
| Annually; for 2026, lump sum by 31 March or 12 monthly instalments, dates restated each year | ENFIA (annual property tax) | Assessment via the tax portal; payment may be made remotely | Interest and enforcement; unpaid ENFIA blocks a future sale | §17.17 |
| By 31 January of the year following any change | E9 property declaration | Update the property statement on acquisition, disposal or alteration | Penalties; the first-year omission is the commonest failure of foreign owners | §17.16, §17.17 |
| Annually where Greek-source income arises; filing window 15 March to 15 July of the following year | Greek income-tax return | Return filed through an accountant or tax representative | Penalties; loss of the deemed-expense deduction position | §17.17 |
| On each new lease | Letting events | Lease declaration to the tax administration; energy performance certificate for the new tenancy; from 1 April 2026, rent into a landlord bank account declared to the tax administration (reported); three-year minimum term on primary-residence leases (reported) | Loss of the 5% deemed-expense deduction (reported); unmarketable tenancy documents | §17.17 |
| Within two months of the event | Change of nationality, including acquisition of São Toméan citizenship | Declaration through the migration registry; Greek-counsel advice on whether and how the permit is re-keyed, no published rule existing | €100 fine, €200 on repetition; unresolved permit-to-passport pairing | §17.16, §17.17, §14.17 |
| At latest by the next permit renewal or reissue application | Passport renewal, any nationality held | Declaration through the migration registry; permit reissue where needed (€100) | €100 fine, €200 on repetition; identity mismatch at borders | §17.16, §17.17 |
| Every five years; file within the two months before expiry; late filing possible up to three months after expiry at €100 for each month of delay | Greek permit renewal | Proof the property remains in the holder's ownership and possession; the definitive registration certificate where deferred at first issuance; fresh insurance policy; €2,000 electronic fee plus €16 card; E9 copy; solemn declarations that there is no short-term letting or sub-letting, that the principal spaces remain residential and that the property is not a company seat or branch | Beyond the grace window the application is barred absent proven force majeure | §17.17 |
| Expected at each five-year renewal — requires confirmation at the date of application | Renewal biometrics | Appearance in Greece for fingerprint capture for the new card | After two failures to appear on summons, rejection | §17.17, §17.11 |
| With the sponsor's five-year cycle; on a child reaching 21 | Family permits | Renew family permits with the sponsor's cycle; a child reaching 21 receives a three-year independent permit (€450) | Family members' residence lapses simultaneously with the sponsor's | §17.17, §17.5 |
| Validity not published in any official source located — requires confirmation at the date of application | São Tomé passport renewal | Renewal through the issuing migration and frontiers service | Travel-document gap on the citizenship side | §17.15, §17.17 |
| From issuance, subject to confirmation | Greek card-validity basis | A 2026 law is reported to run the five-year card validity from issuance rather than the application date; the gazette text had not been read at the date of this report, and the point governs where the renewal date falls | A renewal diary keyed to the wrong date | §17.15, §17.17 |

Caption to Table J.3: The calendar assumes a single applicant, with family rows as noted, holding the €250,000 change-of-use permit, the property either long-let or held vacant, and no relocation to Greece. Greek tax dates reflect the 2026 filing calendar and are restated annually. Fee figures: permit renewal €2,000 plus €16 card = €2,016; child's independent permit at 21 €450; permit reissue €100; late-renewal fine €100 for each month of delay; short-term-letting fine €50,000. All fees and dates require confirmation at the date of application. Derived from §17.16 and §17.17, with §7.12 on disposal, §14.15 on post-approval risk and §14.17 on the passport-and-permit pairing. Underlying instruments named in the body: Law 5038/2023 (consolidated) Articles 11, 19–20, 95, 100 and 171; Joint Ministerial Decision 214926/2025; KYA οικ. 53821/2014 as applied in practice, its formal survival unresolved; Decree-Law 07/2025 and Lei n.º 7/2022. Nothing in this calendar guarantees renewal, retention of status or any administrative outcome.
