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

# Appendix Q — What the Reference Position Enables in Practice

This appendix carries the sourced detail behind §19.10. It answers the question a family actually asks — what can we do, and on what condition — at the level of the instrument that creates each capability, so that any line can be traced to a text and tested against it. Sections Q.1 to Q.6 set out the position under the residence component; Q.7 sets out the position under the citizenship component; Q.8 records what could not be established, and what would establish it.

Three disciplines govern the appendix and are stated here rather than repeated in every cell. First, the two limbs are kept separate. Every capability in Q.1 to Q.6 is a capability of the Greek investor residence permit under Article 100 of Law 5038/2023 and of nothing else; the citizenship component contributes none of them. The single exception is the choice of succession law at Q6.7, where the effect is a property of Regulation (EU) No 650/2012 itself and is stated exactly that narrowly. Second, nothing in this appendix is a European citizenship right or a step towards one. Short-stay mobility in the other Schengen states arises from the Greek permit alone; nationals of São Tomé and Príncipe are listed in Annex I of Regulation (EU) 2018/1806 and require a visa to cross the external border (§6.9, §19.4). The comparison against EU citizenship as it was is drawn at Table 19.1 and §19.8 and is not restated here. Third, freedom from presence and presence-dependent benefits cannot both be taken: the permit imposes no minimum stay, and the driving-licence exchange at Q4.7, the long-term-residence routes at §19.3 and the survivor's position at Q8.2 all turn on actual presence. Wherever a presence condition applies, it is stated in the same sentence as the capability it conditions.

The report's standard applies without exception. Every line below is either cited to a primary or official source or expressly identified as requiring confirmation, and there is no third category. Where a proposition reached only *requires confirmation*, it does not appear as a capability at all: it appears in Q.8. Where a verified capability carries an unresolved question, the pointer to Q.8 travels with it in the same cell. Q.8 is not an afterthought to this appendix; it is the reason the rest of it can be relied on. Figures are the published schedules at the date stated and are annual or periodic; none is fixed.

---

## Q.1 Living

| Ref | What the family wants to do | What the position provides, and on what condition | Instrument |
|---|---|---|---|
| Q1.1 | Live in Greece on their own schedule | A permit valid for five years and renewable for equal periods, with no minimum stay and no maximum absence: periods of absence from the country are not an obstacle to renewal of the residence permit. The same wording governs the whole family class. | Law 5038/2023, Art. 100(4), as replaced by Art. 64(1) of Law 5100/2024, ΦΕΚ Α΄ 49/05.04.2024; Art. 95(1) |
| Q1.2 | Live anywhere in Greece, not only where the property sits | Third-country nationals residing lawfully in the country have freedom of movement and establishment throughout the territory; the permit does not tie the family to the region in which the property is located. | Law 5038/2023, Art. 18(1) |
| Q1.3 | Cover the whole household on one investment | Spouse or registered cohabitation partner; unmarried common children under 21; unmarried children of either partner under 21 where custody is lawfully held; and the direct ascendants of both spouses or partners. Article 95 states no express age or dependency condition for direct ascendants, and the term includes grandparents in the direct ascending line, subject to documentary proof of the complete civil-status chain. This is the absence of a statutory condition from a defined eligible category and not an argument from silence; it does not remove the documentary requirements or the administrative scrutiny that apply to every applicant. Each member applies separately and must meet the general conditions of Art. 8. The family permits expire at the same moment as the investor's, and a permit is revoked or not renewed once the granting conditions cease. | Law 5038/2023, Arts. 95(2)(α)–(δ), 95(3), 8 |
| Q1.4 | Avoid the two-year wait that normally precedes family reunification | Art. 95(2) operates by derogation from Art. 84(1), which otherwise requires two years' lawful residence before family members may be applied for. The derogation removes the waiting period; it removes no other condition. | Law 5038/2023, Arts. 95(2), 84(1) |
| Q1.5 | Add family members in stages, around school terms and work | Dependent members may enter Greek territory together with the investor or enter at a later time; children of six and over enter only to give biometric data, and children under six need not enter Greece at all. Applicants and family members have an exclusive twelve-month period from filing to enter and give biometrics, and fingerprints are compulsory from age six. | Ministry of Migration and Asylum, Secretary-General for Migration Policy, ref. 265272/Σ.133411, 25 October 2024, section I; Law 5038/2023, Arts. 10(11), 14(6) |
| Q1.6 | Keep a child in status past the 21st birthday | A child included under Art. 95(2)(β) or (γ) receives an autonomous residence permit for three years, the sole obligation being production of the previous family-reunification permit. A child who receives that autonomous permit on reaching 21 has immediate access to dependent employment and to studies at any level under Art. 90(7). The provision reaches dependent employment and studies and does not extend to unrestricted self-employment. | Law 5038/2023, Art. 95(2), final sentence; Art. 90(7) |
| Q1.7 | Work in Greece on this permit | No. The residence permits granted under this article do not establish a right of access to any form of employment. Letting the property is expressly permitted and is not employment. Nor does a family member acquire an employment entitlement merely through an Article 100 investor-family permit: Art. 89 grants family members access to employment equally with the sponsor, and the investor sponsor has no employment right under Art. 100(9). Employment would therefore require an independently qualifying status unless the competent authority confirms a different interpretation. | Law 5038/2023, Arts. 100(9), 100(7), 89 — the confirmation note is retained at Q8.1 |
| Q1.8 | Move onto a different Greek permit later without leaving the country | A right to apply, not a right to obtain. A holder of a definitive residence title, which the investor permit is, may move to any category of the Code and is exempt from the obligation to leave the country in order to apply for the entry visa provided for; the applicant must already be residing in Greek territory, any more specific prohibition is preserved, and the target category's conditions must be met in full. The exception operates on holders of type Ι.5 and Ι.7 titles. | Law 5038/2023, Arts. 12(1), 12(3), 4(ιστ), 163(5) and (7) |
| Q1.9 | Vote, or be assisted by another member state's embassy abroad | Neither. The permit is a Greek national residence title and confers no political rights and no consular status. | Law 5038/2023, Art. 100 (no electoral or consular capacity created); §19.8 |

*Assumptions: the reference case is a single third-country-national main applicant holding the €250,000 change-of-use permit under Art. 100(2)(γ), with family members admitted under Art. 95(2); status stated as at 2 August 2026. Article 100 is cited throughout as replaced by Art. 64 of Law 5100/2024 and never as enacted in 2023; the unconsolidated April 2023 text published by the Ministry still carries the superseded thresholds and contains no paragraph 7Α. Derived from Law 5038/2023 and Law 5100/2024 and cross-referenced to §7.9, §16.3 to §16.6 and §19.3.*

## Q.2 Schooling

| Ref | What the family wants to do | What the position provides, and on what condition | Instrument |
|---|---|---|---|
| Q2.1 | Put the children into Greek state school | Minor third-country nationals residing in Greek territory are subject to compulsory school attendance on the same footing as Greek nationals, and those attending any level have unrestricted access to the activities of the school community. The trigger is residence in Greece rather than the permit category, and it is a duty as well as an entitlement. | Law 5038/2023, Art. 18(7), ΦΕΚ Α΄ 81/01.04.2023, pp. 4125–4126 — see Q8.4 |
| Q2.2 | Enrol without an immigration assessment at the school gate | The documents required are the corresponding documents provided for Greek nationals. Enrolment on incomplete documentation is an exception reserved to protection beneficiaries, asylum applicants and persons whose residence has not been regularised; a lawfully resident family produces the ordinary set. Placement of a pupil arriving from a school abroad is determined by the competent education authorities under the ordinary school-placement rules; those rules were not retrieved for this report and the placement outcome should be confirmed with the school before a move. | Law 5038/2023, Art. 18(8) |
| Q2.3 | Choose an international school instead | Admission is contractual and set by each school; the published 2026–27 schedules are at Table Q-1. | Schools' published 2026–27 fee schedules — see Table Q-1 |
| Q2.4 | Know the schools are regulated | Private and foreign schools operate under the Ministry of Education, which publishes registers of active private schools (*Ενεργά Ιδιωτικά σχολεία*) and of foreign schools (*Πίνακας ξένων σχολείων*). This establishes supervision and the recognition of leaving certificates; it confers no right of entry on any particular child. | Greek Ministry of Education, Private Education section, minedu.gov.gr |
| Q2.5 | Go on to a Greek public university after Greek secondary school | Third-country nationals who have graduated from secondary education in Greece have access to tertiary education under the same terms and conditions as Greek nationals, subject to more specific provisions. This is equality of treatment and not an easier route: the same Panhellenic examinations, sat in Greek, and the same fee position as a Greek national. | Law 5038/2023, Art. 18(9) — see Q8.6, Q8.8 |
| Q2.6 | Know what an English-taught place at a Greek public university costs | Two published figures. The National and Kapodistrian University of Athens states that tuition fees for the academic year 2026-2027 for EU and non-EU citizens are €17,000 for the English-language MD; its BA in Archaeology, History and Literature of Ancient Greece is €6,000 a year in two instalments. The MD fee is expressly identical for EU and non-EU applicants, so there is no EU discount at source. | NKUA, medicen.uoa.gr/tuition-fees/ and baag.uoa.gr/admission-fees/ — see Q8.7 on eligibility |
| Q2.7 | Study elsewhere in the EU on home-fee terms | No such entitlement follows from the Greek permit, and none could be sourced. EU law does not harmonise tuition, and residence-based fee tests in other member states look to residence there or to EEA nationality. A second-member-state residence right arises only through EU long-term resident status, on that state's own conditions. | Directive 2003/109/EC, Art. 14(2)(b) — see Q8.10; the report does not state that a Greek permit produces EU-rate fees elsewhere |

*Assumptions: children resident in Greece with the family; state-school entitlement runs on residence, not on the permit category. Placement at Q2.2 is the rule for a pupil arriving from a school abroad and is a placement rule, not an admission guarantee to a particular school; the competent education director determines the class and the school. The university figures are the two institutions' published 2026–27 schedules and are annual. Derived from Law 5038/2023, Art. 18, ,  and the cited institutional publications; cross-referenced to §19.3.*

### Table Q-1 — Published 2026–27 international-school schedules

| School | Annual tuition band | Separately itemised charges |
|---|---|---|
| ACS Athens | €9,050 Pre-School; €11,393 Kindergarten; €13,782 Grades 1–5; €14,898 Grades 6–8; €16,348 Grades 9–12 | Registration €221 or €963; two-year IB Diploma €1,400 |
| St Catherine's British School | €9,950 Nursery, rising through €13,630 / €14,670 / €14,830 / €15,390 / €16,620 to €17,320 Years 12–13 | Application €200; registration €1,500; development fee €2,000 (€500 Years 12–13); reservation deposit €2,500 |
| Byron College | €8,580 EYFS; €10,860 KS1; €11,230 KS2; €12,480 KS3; €13,150 KS4; €14,300 Sixth Form | Registration €1,000 or €1,700; admission test €150 for Years 4–12 |
| International School of Athens | €8,700 to €15,000 by band | Registration €600 or €1,700; transport €2,100–€2,800 |
| Pinewood, Thessaloniki | €6,990 to €14,300 by band | Capital levy €3,000 for new Grades 1–12 entrants; transport €1,100; boarding €11,900 |

*Assumes the schools' own published schedules for the 2026–27 academic year, verified from each school's pages; amounts are annual and are subject to each school's revision. The four Athens schools cluster at €13,000–€17,500 at secondary level, and Byron College's sixth form sits roughly €700 to €3,000 below the others. The charges in the third column are itemised by the schools separately from tuition; ACS Athens does not state that its divisional totals are inclusive of them, and this report does not say that they are. Admission is contractual: none of these schedules confers a right of entry, and international schooling is nationality-blind and available on the same terms without the permit.*

## Q.3 Healthcare

| Ref | What the family wants to do | What the position provides, and on what condition | Instrument |
|---|---|---|---|
| Q3.1 | Be covered from the first day | Full sickness insurance covering the totality of the risks covered for Greek nationals is a general condition of the right of residence rather than a filing formality. Because the permit carries no labour-market access, the family falls in the residual class directed to private insurers unless there is health cover in Greece provided by a foreign body. A lapse is a defect in the residence title itself. The risks such a policy must cover are fixed by joint ministerial decision; the decision in force, and the minimum sums it prescribes, were not identified for this report and must be confirmed before a policy is bound. | Law 5038/2023, Arts. 8(ε), 100(9) |
| Q3.2 | Keep the permit at renewal | A live policy is required at renewal as well as at grant: an insurance contract from a private insurance body covering all health and safety risks at initial grant, and an insurance policy in the same terms at renewal. | Ministry of Migration and Asylum, migration.gov.gr golden-visa page — cited only as evidence of administrative practice; it is drafted under the predecessor statute and states the earlier threshold |
| Q3.3 | Use Greek public hospitals | Not on this permit alone. The statutory route gives third-country nationals holding lawful residence documents, and their spouse and minor or dependent children, free access to Public Health Structures where they are neither directly nor indirectly insured — but the access is conditional on holding an AMKA and is verified through ΗΔΙΚΑ, and an Article 100 permit does not by itself provide a non-working holder with an AMKA. The competent institution's eligibility position is that third-country nationals holding residence permits without labour-market access, including investor-property permit holders covered by private insurance, are not entitled to AMKA on that basis, and Art. 100(9) expressly provides no access to work. A separate qualifying basis — an insured family relationship, or another status — may produce one; the permit itself does not. Public-health access dependent on an active AMKA is therefore not an operative benefit of the permit, and compliant private medical insurance remains the relevant practical basis of cover. Where an AMKA exists on another basis, a person holding private health insurance may use the route only for a health problem requiring immediate hospital or continuous medical-pharmaceutical care, or for pregnancy, that the policy does not cover, and beneficiaries within the scheme cannot be required to sign any acknowledgement of debt. | Law 4368/2016, Arts. 33(1), 33(2)(α), 33(3), 33(5); JMD Α3(γ)/ΓΠ/οικ.25132/4.4.2016, Art. 1(1) and 1(3), ΦΕΚ Β΄ 908/04.04.2016; Law 5038/2023, Art. 100(9); the competent institution, AMKA eligibility table — see Q8.11, Q8.12, Q8.14 |
| Q3.4 | Be admitted in an emergency regardless of paperwork | Hospitals, therapeutic institutions and clinics are expressly exempt from the general prohibition on serving third-country nationals who cannot show lawful entry and residence, where the person is admitted on an emergency basis, for childbirth, or is a minor child. This removes a documentation bar; it is not a payment rule, and for a lawfully resident family the bar does not arise. Charging follows the policy and the ordinary rules. | Law 5038/2023, Arts. 21(1), 21(2)(α) |
| Q3.5 | Be covered when travelling elsewhere in Europe | The private policy's territorial scope governs and should be read before it is bought. No Greek or EU instrument attaches healthcare entitlement outside Greece to the holding of a Greek permit. The European Health Insurance Card is issued by the competent institution to insured persons and their family members; coordination extends to third-country nationals only where they are legally resident and in a situation not confined within a single member state. | Regulation (EC) No 883/2004, Arts. 1(c), 19(1); Regulation (EC) No 987/2009, Art. 25(1); Decision No S1 of 12 June 2009; Regulation (EU) No 1231/2010, Art. 1 — see Q8.13 |

*Assumptions: a privately insured family holding lawful residence documents, with no employment and therefore no contributory insurance in Greece. European Commission guidance (Your Europe, unplanned healthcare during temporary stays) states that a third-country national holding an EHIC cannot use it in Denmark, Iceland, Liechtenstein, Norway or Switzerland; Regulation (EU) No 1231/2010 is silent as to those states, and the point rests on that guidance rather than on the Regulation. Neither an EHIC nor an AMKA nor membership of the Greek public health system follows from the permit, and this report does not say otherwise: the private policy is the cover, and the four published minima at Q3.1 are a floor and not a specification of an adequate policy. Derived from Law 5038/2023 and Law 4368/2016; the insurance condition as a continuing obligation is in Chapter 19's schedule of principal conditions and in the renewal and monitoring calendar at §17.17.*

## Q.4 Money and banking

| Ref | What the family wants to do | What the position provides, and on what condition | Instrument |
|---|---|---|---|
| Q4.1 | Open a Greek bank account | A legal entitlement rather than a commercial favour. Consumers legally resident in the Union have the right to open and use a payment account with basic features at credit institutions established in Greece, and that right applies irrespective of the consumer's place of residence. Legal residence in the Union is defined as a right to reside in a member state by virtue of Union or national law, and the Article 100 permit is such a right. Greece did not take the "genuine interest" option, and all credit institutions offering consumer payment services must offer basic accounts. | Law 4465/2017, Arts. 16(1)–(2), ΦΕΚ Α΄ 47/04.04.2017, transposing Directive 2014/92/EU, Art. 2(2) |
| Q4.2 | Not be turned away for being non-EU | Credit institutions shall not discriminate against consumers legally resident in the Union by reason of their nationality or place of residence, and the conditions for opening and maintaining a basic account may not entail any kind of discriminatory treatment. A decision is due within ten business days, and any refusal must be written, free of charge, reasoned, and signposted to the competent authority and to alternative dispute resolution. Anti-money-laundering refusal grounds are unaffected. | Law 4465/2017, Arts. 15, 16(3), 16(7) (Directive 2014/92/EU, Art. 15) |
| Q4.3 | Use the account normally | The basic account must carry cash deposits and withdrawals in the Union at the counter and at ATMs, direct debits, card payment transactions including online payments, and credit transfers including standing orders, at least in euro, with an unlimited number of transactions and a reasonable-fee cap that expressly excludes credit-card transactions. This is a floor and not a ceiling: it carries no entitlement to an overdraft, a credit card, a mortgage or a private-banking relationship. | Law 4465/2017, Art. 17(1)(α)–(δ), 17(2), 17(3), 17(4) |
| Q4.4 | Use the Greek IBAN anywhere in the euro area | A payee or payer in the Union may not require that a euro account be held in any particular member state, with reachability an obligation on payment service providers. | Regulation (EU) No 260/2012, Arts. 3, 9(1)–(2), consolidated text as at 8 April 2024 |
| Q4.5 | Seek basic banking in another member state | The Directive imposes the obligation on every member state, expressed irrespective of the consumer's place of residence; the transferable asset is the residence status and not the Greek IBAN. What each state's own transposition delivers is a separate question — another state may require proof of genuine interest, must refuse on AML grounds, may refuse where an equivalent account is already held there, and may legislate further grounds. Only Greece's transposition was examined for this report. | Directive 2014/92/EU, Arts. 15, 16(2), recital 34 — see Q8.15 |
| Q4.6 | Get a Greek tax number | Free, remote and delegable. The procedure covers any natural person, domestic or foreign, tax resident of Greece or abroad; supporting document 9 for a third-country national is a copy of a valid residence permit; the process cost is 0.00; identification is by myAADElive video call or in person at a tax office; and the application may be submitted by an authorised representative holding their own AFM and certified AADE credentials on a special power of attorney with certified signature. The AFM issues together with the κλειδάριθμος and the AADE e-service codes. An AFM is a tax-administration identifier and is not the same as being a Greek tax resident. | National Register of Administrative Procedures, *Απόδοση ΑΦΜ & Κλειδαρίθμου σε φυσικά πρόσωπα*, mitos.gov.gr pageid 21039 — see Q8.16; §9.6 |
| Q4.7 | Drive | Two distinct positions, and they cannot both be taken. Licences issued by the United States, Canada, Australia, the United Kingdom and Gibraltar may be used in Greece for mopeds, motorcycles, tricycles, quadricycles and passenger cars throughout the holder's stay, temporary or normal. Separately, licences from the USA, Canada, Australia, Japan, South Africa and South Korea convert to the Greek equivalent without theoretical and practical examination — South Korea limited to categories A and B, South Africa new plastic format only, provisional licences excluded — at a stated €118 for one category and up to 30 days from receipt of the file. Conversion requires normal residence in Greece, at least 185 days in each calendar year, declared on oath, and the exchanged licence carries code 70, which removes the guarantee of mutual recognition elsewhere in the Union. Vienna Convention licences are valid only while the holder is not normally resident in Greece. | Ministry of Infrastructure and Transport circular Δ30/Α3/76710 of 13 May 2026, applying Art. 98§3(ζ) of Law 5209/2025 (ΚΟΚ, Α΄ 100), Διαύγεια ΑΔΑ 68ΧΨ465ΧΘΞ-ΘΟΡ; JMD 24058/2653/2004, Art. 1, ΦΕΚ Β΄ 1119/23.07.2004; Directive 2006/126/EC, Arts. 11(6), 12; Law 1599/1986, Art. 8 |
| Q4.8 | Buy the property without first opening a Greek account | The statute regulates the payment method and the seller's account, not the buyer's. Payment must be made in full by crossed bank cheque into a payment account of the payee held at a credit institution operating in Greece, by credit transfer, or through a POS installed by a payment service provider operating in Greece; payment may be made by a spouse or a relative by blood or affinity to the second degree; and the notary records the payer's payment-account numbers, address, identity-document number and date and place of birth. Art. 100(6) requires a copy of the investor's Ε9 property declaration on acquisition by transfer, which presupposes an AFM. | Law 5038/2023, Arts. 100(5) and 100(6), as replaced by Art. 64(1) of Law 5100/2024; Law 4537/2018, Art. 4(24) |

*Assumptions: a non-resident third-country-national consumer opening a basic payment account in his own name; the €118 licence figure is the Ministry's stated charge and embeds a doctors' fee that the Ministry's own procedure sheet says tracks the prevailing consultation rate. The sworn declaration of normal residence carries a criminal penalty for a knowingly false statement, and the licence-exchange benefit is therefore unavailable to a family relying on the permit's freedom from presence. Nothing here is a guarantee that any particular institution will open any particular account or extend any particular facility (§9.5). Derived from Law 4465/2017, Regulation (EU) No 260/2012 and the cited procedure records; cross-referenced to §9.4, §9.5, §17.10 and §19.6.*

## Q.5 Mobility in detail

| Ref | What the family wants to do | What the position provides, and on what condition | Instrument |
|---|---|---|---|
| Q5.1 | Travel across the rest of Schengen without a visa | On the permit together with a valid travel document, for up to 90 days in any 180-day period in the other Schengen states, conditional on the entry conditions of Art. 6(1)(a), (c) and (e) of the Borders Code and on the holder not being the subject of a national alert. It is short-stay movement only, with no right to reside, work or establish. The area comprises 29 countries. | Convention implementing the Schengen Agreement, Art. 21(1), as replaced by Regulation (EU) No 265/2010, Art. 1(2), and further amended by Regulation (EU) No 610/2013, Art. 2(3); Regulation (EU) 2016/399, Art. 6(1) — see Q8.17; §19.4 |
| Q5.2 | Fly in without a consular appointment | At an external border the permit substitutes for a Schengen visa: a visa-national must hold a visa except where they hold a valid residence permit or a valid long-stay visa. The remaining Art. 6(1) conditions still apply, and admission remains a border-guard decision. | Regulation (EU) 2016/399, Art. 6(1)(b) |
| Q5.3 | Live in Greece and still have the full 90 days | Periods authorised under a residence permit are excluded from the calculation of duration of stay, so time in Greece does not erode the allowance. The 90/180 is a single pooled quota across all the other Schengen states together and not a per-country allowance. | Regulation (EU) 2016/399, Art. 6(2) |
| Q5.4 | Cross borders without being enrolled in the Entry/Exit System | Holders of residence permits within Art. 2(16) of the Borders Code are outside the EES, subject to the provision's own carve-out for the categories covered by its points (a) and (b); the Commission's guidance states that travellers in these categories show the identity document or passport together with the long-stay visa or residence permit and that border checks remain as usual. The EES became fully operational on 10 April 2026. Greek stamping is optional and depends on national law. The EES does apply where entry for a short stay is refused. | Regulation (EU) 2017/2226, Arts. 2(2), 2(3)(c); European Commission, *Smart borders*; consolidated Schengen Borders Code, Art. 11(1) — see Q8.17 |
| Q5.5 | Turn a consular visa application into an online one for Türkiye | For Indian, Pakistani and Afghan nationals only: ordinary passport holders with a valid Schengen visa or residence permit may obtain single-entry e-Visas via the official portal, single entry, one month. This is the one third-country visa facilitation attributable to the permit that could be verified from an official source, and it benefits only nationals of the listed countries. | Republic of Türkiye, Ministry of Foreign Affairs, *Visa Information For Foreigners*; evisa.gov.tr |
| Q5.6 | Enter Cyprus | Cyprus applies Art. 2(1)(c) of Decision No 565/2014/EU, under which holders of residence permits issued by Schengen member states require no Cyprus short-stay visa for stays of up to 90 days in any 180-day period, counted against a separate Cyprus budget; the recognition runs one way only, and the concession expressly does not apply to citizens of Türkiye and Azerbaijan unless they are family members of an EU citizen. Cyprus is not part of the area without internal border controls. | Decision No 565/2014/EU, Arts. 1, 2(1)(c), 5; §19.4 and §7.10 carry the full treatment |
| Q5.7 | Enter the United States or Canada more easily | No facilitation from either limb, on primary law. United States Visa Waiver Program eligibility turns on being a national of, and presenting a passport issued by, a designated country; residence is nowhere a ground. Canada's temporary-resident-visa exemptions contain no EU or Schengen residence-permit ground, and the residence-based exemption is confined to United States nationals and United States lawful permanent residents. | 8 U.S.C. § 1187(a)(2); Immigration and Refugee Protection Regulations, SOR/2002-227, s. 190(1)(c) — see Q8.19 |
| Q5.8 | Enter or transit the United Kingdom | The Greek card is not a route into the United Kingdom. GOV.UK's transit-visa guidance lists five documents that remove the need for a transit visa — an ETA, an EU Settlement Scheme family permit, a Home Office travel document, a Standard Visitor visa and a Marriage Visitor visa — and no EEA or Swiss residence permit is among them. United Kingdom travel is planned and applied for separately. | GOV.UK, *Transit visa* guidance; UK Immigration Rules Appendix Visitor — see Q8.18, which is why this report asserts nothing either way about airside transit |
| Q5.9 | Travel on the São Toméan passport | Not in Europe, at any point. Nationals of São Tomé and Príncipe are listed in Annex I of Regulation (EU) 2018/1806 and require a visa to cross the external borders; the United Kingdom lists São Tomé and Príncipe as a visa national and the United States has not designated it for the Visa Waiver Program. Verified visa-free or equivalent access is to a limited number of states — South Africa (90 days on ordinary passports), Singapore and Hong Kong (14 days). Kenya lists São Tomé and Príncipe among the nationalities exempt from the Electronic Travel Authorisation for stays not exceeding 60 days, published by the immigration authority as made under the Kenya Citizenship and Immigration (Amendment) Rules 2025; the gazetted Rules themselves were not obtained and the exemption requires confirmation at the date of travel, and the authority states in terms that admissibility is determined at the point of entry. Ghana requires a visa of nationals of African Union member states, granted on arrival or at a mission for 60 days, São Tomé and Príncipe falling into that residual category by elimination and visa-on-arrival being a discretionary grant at the frontier. No official list of the passport's total travel access is published, and aggregate counts circulated commercially are not used in this report. | Regulation (EU) 2018/1806, Art. 3(1) and Annex I; the destination-government sources at §6.9 and §19.1; Kenya Directorate of Immigration Services, etakenya.go.ke general information; Ghana Immigration Service, gis.gov.gh visa table (undated) — see Q8.20, Q8.21 |
| Q5.10 | Rely on an African mobility bloc | There is none to rely on. São Tomé and Príncipe is not a member of CEMAC, which is the Central African bloc that operates visa-free movement for nationals, the common passport, the CFA franc and the common central bank and banking supervisor; it is not a member of ECOWAS; it is not an East African Community partner state, and Kenya's own table places it in the 60-day African list rather than the 180-day EAC list; and it is not a member of OHADA, so a São Toméan company takes none of the OHADA uniform forms and has no recourse to the Common Court of Justice and Arbitration. It is a member of ECCAS, whose free-movement and establishment protocol ECCAS itself lists among priority measures still requiring effective application, and in May 2024 the São Toméan authorities were reported by ECCAS as asking for its implementation to be accelerated. São Tomé and Príncipe is one of only four states to have deposited an instrument of ratification of the African Union Protocol on Free Movement of Persons, which the AU's own status list records without any entry-into-force note. The AfCFTA Agreement, ratified 28 May 2019 and deposited 27 June 2019, is a trade instrument conferring rights on goods, services and traders and no right of entry, residence or establishment on natural persons. | cemac.int member-state listing; ecowas membership by elimination, corroborated by the ECCAS Central African listing; etakenya.go.ke EAC partner-state listing; ohada.org member-state listing; ECCAS Commission, *ECCAS in Brief* and the article of 24 May 2024; African Union free-movement protocol status list dated 8 August 2023; African Union AfCFTA status list dated 22 May 2026 — see Q8.21 |

*Assumptions: a holder of the Greek Article 100 permit travelling on a valid travel document, and separately a holder of a São Toméan ordinary passport. Short-stay Schengen mobility arises from the Greek residence permit and never from the São Toméan passport (§6.9, §19.4); nothing in this section may be read across the two limbs. Member states may temporarily reintroduce internal border controls, and eight had notified controls in force as at 2 August 2026, so "borderless" language is not used (§19.4). The AU publishes two entry-into-force dates for the AfCFTA Agreement — 22 May 2019 on its treaty page and 30 May 2019 on the status list — and neither reading was reconciled. The Kenyan and Ghanaian positions are the destination authorities' published statements; immigration exemption lists are amended frequently and both require confirmation at the date of travel. Derived from the cited Union instruments and destination-government sources; cross-referenced to §6.9, §7.10, §19.1 and §19.4.*

## Q.6 The property as a home

| Ref | What the family wants to do | What the position provides, and on what condition | Instrument |
|---|---|---|---|
| Q6.1 | Live in it, leave it empty, or let it | Nothing requires the property to be let, and nothing requires it to be occupied. Renewal is conditioned on the property remaining in the holder's full ownership and possession (*πλήρη κυριότητα και νομή*) and on the article's other conditions continuing to be met; there is no minimum-occupation rule and no maximum-vacancy rule. Letting is expressly permitted: third-country nationals who own properties are afforded the possibility of letting them. Granting a lease transfers detention to the tenant and not possession, so a lease does not defeat the condition. | Law 5038/2023, Arts. 100(1)(β), 100(4), 100(7) |
| Q6.2 | Short-let it on a platform | No, and the sanction is severe. Property acquired for the initial grant or renewal of an investor permit is prohibited from being let short-term within the framework of the sharing economy and from being sub-let; breach means the residence permit is revoked and a standalone administrative fine of €50,000 is imposed on the owners or holders. A short-term lease for this purpose is one concluded through a digital platform for a defined period of less than a year; the sub-letting prohibition is unqualified as to length. Property acquired on the €250,000 change-of-use route may also not be used as the seat or branch of a business, on the same penalty. | Law 5038/2023, Art. 100(7Α), inserted by Art. 64(1)(ββ) of Law 5100/2024, ΦΕΚ Α΄ 49/05.04.2024, pp. 1199–1200; Law 4446/2016, Art. 111(1), as replaced by Art. 84 of Law 4472/2017 — see Q8.23, Q8.24 |
| Q6.3 | House a parent or a student child in it, rent-free, or live in it themselves | Deemed income on the free grant of use of a dwelling of up to 200 sq m, to an ascendant or descendant, for use as that person's main residence, is exempt from tax, and such grants are expressly excepted from the lease-declaration obligation. A free grant to anyone else is taxed on deemed income of 3% of objective value. Personal owner-occupation is a different case: it does not ordinarily generate deemed property income equal to 3% of the property's value, the 3% rule principally concerning specified self-use or free-concession arrangements. Occupation may, however, be relevant to Greece's separate objective-expenditure or presumed-living-cost rules, which are a distinct regime from Art. 39 and are not examined in this report. | Law 4172/2013, Art. 39(1)–(2); ΠΟΛ.1013/2014, Art. 5 |
| Q6.4 | Know what the rent is taxed at | Property income is taxed autonomously on 95% of gross for an individual lessor, a flat 5% deduction standing for repairs, maintenance, refurbishment and other fixed and operating costs; the enacted scale is 15% to €12,000, 35% from €12,001 to €35,000 and 45% above €35,001. A lessor who is not a Greek tax resident is expressly excluded from the electronic-payments requirement and therefore from the 22% surcharge on the shortfall. | Law 4172/2013, Arts. 39(3)(α), 40(4) as replaced by Art. 112(7) of Law 4387/2016, ΦΕΚ Α΄ 85/12.05.2016, p. 2255, and 15(6)(c)(iv) as added by Art. 7(1) of Law 4646/2019 — see Q8.25 |
| Q6.5 | Understand the recurring obligations | A Lease Information Declaration must be filed electronically by the end of the month following commencement or amendment, for every initial or amended lease, irrespective of whether it is a written or oral agreement, with penalties under the Tax Procedure Code, electronic notification to the tenant, and separate filing by each co-owner. ENFIA is charged on rights over Greek property held on 1 January each year. The Ε9 property return is required of every person irrespective of nationality, residence or seat, with a further Ε9 within 30 days of any acquisition or change of right. Transfer tax on acquisition is 3% of taxable value in every case not otherwise provided for. | ΠΟΛ.1013/2014, Arts. 1(1), 4, 6, still in force via Art. 84(4) of Law 5104/2024; Law 4223/2013, Arts. 1(1)–(4) and 6(3); Law 3427/2005, Art. 23(1), as replaced by Art. 12(1) of Law 4223/2013; Law 1587/1950, Art. 4(1)(Γ), as replaced by Art. 11(1) of Law 4223/2013 — see Q8.26 |
| Q6.6 | Pass it to the children | Two things, and they pull in opposite directions. The tax scale is mild: for Category A beneficiaries — spouse, registered partner of at least two years, first-degree descendants, second-degree descendants and first-degree ascendants — nil on the first €150,000, then 1% on €150,000, 5% on €300,000 and 10% on the excess, applied per beneficiary on objective value. The primary-residence exemption is closed to this family: beneficiaries of the exemption are Greeks and citizens of member states of the European Union, and beneficiaries must be permanent residents of Greece. The two conditions are cumulative and either excludes the family. | Law 2961/2001, Arts. 29(1)–(2) as replaced by Art. 25(A)(14) and 26, section A(1), as replaced by Art. 25(A)(10), of Law 3842/2010, ΦΕΚ Α΄ 58/23.04.2010 — see Q8.26 |
| Q6.7 | Choose which country's succession law governs the Greek house | By default the law of the deceased's habitual residence at death applies, with a manifestly-closer-connection escape; a person may instead choose the law of a state whose nationality he possesses at the time of the choice or at death, the choice being made expressly in a declaration in the form of a disposition of property upon death or demonstrated by its terms. The chosen law governs the disposable part, reserved shares and other restrictions on disposal on death. The Regulation applies universally, so a non-EU law may be designated. This is the one place in this appendix where the second nationality does verified work: it enlarges the set of laws that may lawfully be chosen. What any particular such law provides was not examined, São Toméan succession law was not verified for this report, and the Portuguese *legítima* tradition may import forced-heirship rules that must be established locally. Greek tax, Greek land-registration requirements and the nature of rights *in rem* are outside the Regulation. | Regulation (EU) No 650/2012, Arts. 1(2)(d), (k), (l), 20, 21(1)–(2), 22(1)–(2), 23(2)(h); §6.10 and §13.3 |
| Q6.8 | Keep the Greek foothold in the family as a status and not only as an asset | For one adult heir. A permit may be granted to a person who is an adult and has acquired, in full ownership and possession, as intestate or testamentary heir or by way of parental gift, immovable property of objective value at least equal to the applicable threshold. Three conditions bite: the heir must be an adult; the test is objective value and not the price paid; and the threshold is the one then applicable — €800,000 for the Attica Region, the Thessaloniki regional unit, Mykonos, Thera and islands over 3,100 inhabitants, €400,000 elsewhere, and €250,000 on the change-of-use and listed-building routes. Splitting one property between several children will normally take each share below the threshold. | Law 5038/2023, Arts. 100(1)(ε) and 100(2), as replaced |
| Q6.9 | Sell it | Sale ends the status. Resale during the permit's validity to another third-country national gives the buyer a right to a permit with simultaneous revocation of the seller's residence permit. Before signing a contract of sale at any price, a third-country-national seller must produce a certificate from the competent Aliens and Migration service stating whether that property has been used to obtain an investor permit, and the buyer's notarial certificate must record the same, so the permit history follows the property. Revocation triggers a return decision, an appeal within an exclusive two-month deadline, an annulment application to the administrative court and, on a suspension order, an annual renewable type-Χ title; and the family members' derivative permits fall with the sponsor's. Where the €250,000 listed-building route was used, transfer before full restoration or total reconstruction is void and additionally attracts revocation and a €150,000 fine. | Law 5038/2023, Arts. 100(8), 100(11), 100(6), 15(1)(α), 15(2), 16(3), 16(4), 95(2), 95(3), 100(2)(δ), 100(4) second sentence, 100(7Α) fourth and fifth sentences; Law 3907/2011, Art. 21 |

*Assumptions: a single qualifying property held in the client's own name by a non-Greek-tax-resident individual on the €250,000 change-of-use route, long-let by elimination or not let at all. Greek tax positions are stated as at 2 August 2026 and require confirmation at the date of application; the statutory 3% transfer tax carries a municipal surcharge taking the effective rate to 3.09% in the acquisition-cost stack at §8.6 and Table E-1. The report proceeds on the three-year minimum residential lease term at §8.9 and Appendix E, item G6; the enacted 1987 text sets two years with a tenant-only right to extend, and the point is at Q8.22. Property is not the product: the asset is assessed on its merits against the property-without-immigration test at §8.15, and none of the above is a statement about value, rent or liquidity. Derived from Law 5038/2023, the Greek Income Tax Code and the cited property-tax instruments; cross-referenced to §8.9, §8.10, §8.11, §8.12, §8.14, §12.3 and §19.5.*

## Q.7 The citizenship component

| Ref | What the family wants to do | What the position provides, and on what condition | Instrument |
|---|---|---|---|
| Q7.1 | Pass the nationality to children born after the grant | The statute provides two routes and neither is automatic. A child born abroad to a São Toméan father or mother who declares the wish to be São Toméan is a national of origin, attribution taking effect from birth, transcribed against the birth record at the central registry, and the supporting declaration may be made before São Toméan diplomatic or consular agents; a child born in São Tomé and Príncipe to a São Toméan parent falls under a separate limb carrying no declaration condition on its face. Whether a parent naturalised under the investment framework transmits originary nationality is not stated anywhere in the Law and requires confirmation: the articles say only "São Toméan father or mother", without qualifying the mode of acquisition, and no registry practice, circular or decision applying them to a programme-naturalised parent has been located. The parent must still hold São Toméan nationality at the child's birth, and only filiation established during the child's minority produces nationality effects. | Lei n.º 7/2022, Arts. 2, 4, 5(a), 5(c), 21, 22(1) and 22(3), Diário da República I Série n.º 25, 10 March 2022 — see Q8.27, Q8.28; §6.10 and §16.6 |
| Q7.2 | Reach a further generation | Grandchildren of a São Toméan national born abroad appear in a separate limb which carries no express declaration condition, no age limit and no requirement that the intervening parent claimed the nationality; the limb is drafted more loosely than the children's limb, its registry treatment is untested, and it requires confirmation before any family plan rests on it. The official programme channel states only that citizenship may also be passed to future generations in accordance with the national law, which defers the question rather than answering it. | Lei n.º 7/2022, Art. 5(d); STP CIU, cip.gov.st — see Q8.29 |
| Q7.3 | Know where existing children stand | Children alive at the date of the grant do not use the origin provisions. Minor children of a person who acquires nationality may acquire it by declaration, and minor children may be granted nationality at the act of the parent's naturalisation on the parent's request, requestable by the child up to one year after attaining majority. Both are acquisition routes and not attribution, so within one family the legal category of the children may differ according to date of birth, and the position of the children born before the grant is the weaker of the two. | Lei n.º 7/2022, Arts. 7, 10(4), and the Chapter II / Chapter III architecture — §16.3, §16.4 |
| Q7.4 | Include adult children or ascendants | Neither gazetted instrument provides for them. The decree defines dependants as the spouse and/or children of the main applicant, expressly by reference to the Nationality Law's paragraphs on minor children and the spouse, and defines dependants elsewhere as household members who under the law may be included — subordinating the concept to what the Law permits. The Law's routes for children are confined to minors. The programme channel publishes categories of children up to 30 and of parents and grandparents from 55; neither has a located statutory basis, published administrative material does not amend a gazetted Law, and the annex's pricing of qualifying dependants other than the spouse does not define who qualifies. | Decreto-Lei n.º 07/2025, Arts. 3(d), 10(1)(b) and Anexo I §4, Diário da República I Série n.º 33, 1 August 2025; Lei n.º 7/2022, Arts. 7, 10(4)–(5) — see Q8.30; §16.4, §16.5 |
| Q7.5 | Know whether conscription can reach the family | Citizens naturalised under the decree enjoy a permanent exemption from compulsory military service, and the exemption extends to situations of a state of siege or national emergency, without prejudice to undefined general duties of collaboration with the authorities. It is confined to those naturalised under that diploma: a child later born to the family as a São Toméan by origin is not naturalised under it and does not carry the exemption. The exemption is granted by decree-law while the underlying duty is stated in the Constitution, and no ruling on that tension was located. | Decreto-Lei n.º 07/2025, Art. 16(1)–(2), Diário da República I Série n.º 33, 1 August 2025, p. 435; Constitution of São Tomé and Príncipe, Article 64 (English translation) — see Q8.31 |
| Q7.6 | Keep existing nationalities | Plural nationality is the statutory default: a São Toméan who acquires another nationality retains São Toméan nationality unless he declares otherwise, and the provision sits in the chapter on loss without being confined to citizens by origin. No renunciation, oath of exclusivity or nationality-declaration duty appears anywhere in either instrument. The constitutional guarantee is narrower — it protects the retention of an original nationality — so a naturalised citizen's retention rests on ordinary statute; no case law tests the point. | Lei n.º 7/2022, Art. 15(1); Constitution of São Tomé and Príncipe, Article 3 (English translation) |
| Q7.7 | Keep the arrangement discreet | It is not discreet, and should never be described as unlinked. The application file requires criminal-record certificates issued by the competent authorities of the countries of nationality — plural — and of residence for the last five years, a certified passport copy, proof of residence, and a document evidencing the statelessness position of the applicant and descendants; independent due-diligence providers must check all candidates. The file therefore names every passport the family holds. | Decreto-Lei n.º 07/2025, Arts. 10(2), 11(1) and Anexo III items 2, 3, 4 and 5 |
| Q7.8 | Add further nationalities later | The framework caps them, and the cap is mandatory. The grant of São Toméan nationality is barred to a person who already holds more than two foreign nationalities, with no waiver and no ministerial discretion. A naturalised citizen who acquires a fourth nationality loses São Toméan nationality immediately, loss taking effect from the date of registration of the verification. The counting basis is an interpretation rather than an established position — the coherent reading counts São Tomé itself, so a single further acquisition after the grant triggers loss — and nothing in either instrument provides a waiver, grandfathering or notice procedure. A family expecting to acquire further citizenships must sequence them. | Lei n.º 7/2022, Arts. 11(1), 11(2), 18; Decreto-Lei n.º 07/2025, Art. 15 — see Q8.32; the reported hold on applications from holders of three or more foreign nationalities is at §19.2 |
| Q7.9 | Understand how durable the status is | It is durable but is not equivalent to citizenship by birth. Loss of origin nationality arises only on a voluntary declaration while proving another nationality, or on exercising sovereign functions or non-compulsory military service for a foreign state. Deprivation of a naturalised citizen is available on materially wider grounds — acting against the security of the State, repeatedly acting against public health, and nationality obtained by falsification, other fraudulent means or by misleading the competent authorities — and is decreed after a final conviction, with reacquisition barred. The investment decree separately makes any violation of its provisions an administrative infraction punishable by, among other penalties, revocation of nationality, with only a prior hearing and proportionality guaranteed. That sits in conflict with the Law's conviction requirement and with the decree's own referral of loss back to the Law; the conflict is on the face of the instruments and is untested. | Lei n.º 7/2022, Arts. 14, 16(2), 16(3); Decreto-Lei n.º 07/2025, Arts. 15, 18(1)–(4) — see Q8.33; §6.8, and Chapter 19's schedule of principal conditions |
| Q7.10 | Recover the status if it is ever lost | Reacquisition requires actual permanent residence in São Tomé and Príncipe: three years for a citizen by origin, five years for a person who held it by naturalisation, and the five-year route is available only to a person who lost it by his own declaration. A person deprived on the wider grounds can never reacquire. "Permanent residence" is not defined in the Law and no implementing rule was found. The status should not be treated as reversible. | Lei n.º 7/2022, Arts. 16(3), 17(1), 17(2) |
| Q7.11 | Avoid having to move or maintain a presence | Neither instrument imposes any residence, physical presence or relocation obligation before or after the grant: the five-year legal-residence and national-language requirements may be dispensed with for the investment and donation limbs. The dispensation is discretionary in form and no published criteria govern its exercise. Four requirements are not dispensable — majority, criminal record, absence of a security or terrorism threat, and the carrying on of an activity conferring the capacity to assure one's own subsistence — and the file requires proof of residence somewhere. | Lei n.º 7/2022, Art. 10(1) and 10(3); Decreto-Lei n.º 07/2025, Arts. 10(1)(a)(i), 12 and Anexo III item 5 |
| Q7.12 | Call a consulate if something goes wrong | The network is small, and a family should plan on that basis. The ministry's own directory lists eight embassies — Angola, Belgium, Cape Verde, Gabon, Morocco, Nigeria, Portugal and Switzerland — one consular post, at Laayoune in Morocco, and two permanent missions, at the United Nations in Geneva and in New York. The ministry's Portugal page records no consulate in Portugal, where the largest diaspora lives. There is no post in South Africa, Singapore or Hong Kong, which are the destinations the passport reaches without a visa, and none in the United Kingdom or the United States. No accreditation table is published, so which further countries each embassy covers on a non-resident basis could not be established. | Ministério dos Negócios Estrangeiros, Cooperação e Comunidades, mne.gov.st embassy, consulate and permanent-mission directories — see Q8.34 |
| Q7.13 | Use the passport for European mobility | Never. Nationals of São Tomé and Príncipe are listed in Annex I of Regulation (EU) 2018/1806 and require a visa to cross the external borders of the Schengen member states. Within the reference structure, short-stay European mobility is a function of the Greek residence permit alone. | Regulation (EU) 2018/1806, Art. 3(1) and Annex I; §6.9, §19.4, Q5.1 |

*Assumptions: a main applicant naturalised under Article 10(2) of Lei n.º 7/2022 as implemented by Decreto-Lei n.º 07/2025, with the spouse and minor children included in the act. The programme's published contribution, processing and post-approval charges are set out at §6.4 and are not restated here; whether the post-approval schedule bites on a child who is a citizen by origin is unresolved and is at Q8.28. The São Toméan instruments were read in Portuguese from gazette facsimiles; no official São Toméan gazette repository was publicly reachable and the access routes are recorded at Appendix M, C-001 and C-002, and at Q8.35. The constitutional provisions are verified only in English translation. Nothing in this section is a European right or a step towards one. Derived from Lei n.º 7/2022 and Decreto-Lei n.º 07/2025; cross-referenced to §6.3, §6.4, §6.8, §6.9, §6.10, §16.4, §16.5, §16.6 and §19.2.*

## Q.8 Open questions requiring confirmation

The following could not be established from an authoritative text, or is stated in the body on a conservative reading that the competent authority has not confirmed. None of it may be asserted in either direction, and none of it is a capability of the position. Each entry states the open point and what would settle it. A family relying on any line in Q.1 to Q.7 that carries a pointer into this section should treat the pointer as part of the line.

**Living**

1. **Confirmation of the family members' employment position.** The conclusion stated at Q1.7 is the conservative one: a family member acquires no employment entitlement through an Article 100 family permit, because Article 89 grants access equally with a sponsor who has none under Article 100(9). No published judgment or interpretive circular reconciling the two provisions for Article 100 family members was located, and the competent authority could yet confirm a different interpretation. Nothing is asserted in the other direction, and no family plan should assume that a spouse or an ascendant may work. *What would settle it:* a ministerial circular, or a decided application.
2. **The survivors' position if the investor dies.** Article 90(2)(α) grants an autonomous permit on the sponsor's death only where the family has resided in Greece for at least a year beforehand, and whether Article 90 reaches family members admitted under Article 95(2) is unresolved. *What would settle it:* a ministerial ruling.
3. **Whether Article 95 has been amended in 2025–2026.** The Ministry publishes the unconsolidated April 2023 text, and Article 64 of Law 5100/2024 replaced Article 100 and Article 176(49) only. *What would settle it:* a systematic check of enactments since late 2024 against a consolidated Code.

**Schooling**

4. **The statutory limb of compulsory education,** including the age-16 backstop and the wording of Law 1566/1985 as amended by Law 4521/2018. Eurydice corroborates eleven compulsory years from age 4 to 15 but does not state the sixteenth-year rule. *What would settle it:* ΦΕΚ Α΄ 38/2018 from a retrievable official copy.
5. **Reception classes (ZEP).** The two-tier structure and the 2024 decisions (Φ1/42235/Δ1/22.04.2024 for primary; 99406/ΓΔ4/04.09.2024 for secondary) are corroborated, with minimum enrolments of nine at primary and seven at secondary, so a reception class is not available at every school; the decisions themselves are unread. *What would settle it:* both decisions.
6. **Whether Greek-taught first-cycle public higher education is free as a matter of statute.** The headline is corroborated and two exceptions are recorded, the Hellenic Open University and the International Hellenic University charging; the statutory limb at Articles 84, 105 and 109(2) of Law 4957/2022 is unverified. *What would settle it:* ΦΕΚ Α΄ 141/21.07.2022.
7. **Eligibility for English-taught Greek public university programmes.** Article 101(1) of Law 4957/2022 as enacted restricts them to graduates of schools with their seat abroad, while NKUA publishes a pathway open to graduates of a recognised foreign school based and legally operating in Greece, with no statutory citation on the programme site. The fees at Q2.6 are verified; the eligibility is not. *What would settle it:* the current statutory text and any amending instrument, together with a written answer from the university on the legal basis of the second pathway.
8. **The special-category quota for foreign nationals** under Ministerial Decision Φ.151/20049/Β6, ΦΕΚ Β΄ 272/01.03.2007. Neither the percentage figures nor the current category definitions could be verified, and the category reference to a lykeion "of the foreign or the domestic country" creates a live ambiguity for a child at a foreign-curriculum school located in Greece. *What would settle it:* the consolidated decision, checked in the year of application.
9. **Student welfare** — free meals, accommodation and the EYDOXOS textbook scheme. Whether nationality or residence status figures in the eligibility criteria is unknown, so entitlement for a third-country-national student is unproven. *What would settle it:* Articles 284–285 of Law 4957/2022 and the delegated joint ministerial decisions.
10. **Home or EU tuition rates in any other member state.** No authoritative source exists; EU law does not harmonise tuition, and other member states' residence tests look to residence there or to EEA nationality. There is no differential to export even at source, NKUA charging EU and non-EU applicants identically. *What would settle it:* written answers from each target institution or national authority. Until then the report does not state that a Greek permit produces EU-rate university fees elsewhere in Europe.

**Healthcare**

11. **Whether JMD Α3(γ)/ΓΠ/οικ.25132/2016 remains in force unamended.** It governs the terms on which the Article 33 route may be used at all by a privately insured person, and so bears on the position at Q3.3 of any family member who holds an AMKA on a basis other than the permit. *What would settle it:* the consolidated decision.
12. **How the floor for minors under 18 and for pregnancy interacts with private cover.** Article 33(2)(γ) of Law 4368/2016 lists both categories without any legal-status requirement, but the private-insurance restriction in the implementing decision is drafted generally and on its face bites on them too. This category is not presented as a clean answer for an insured family. *What would settle it:* an authoritative interpretation.
13. **Whether the competent Greek institution would refuse a European Health Insurance Card.** Each link in the chain is verified; the conclusion is an inference across four EU instruments and Greek law. *What would settle it:* a written answer from the competent Greek institution.
14. **Who bears the cost of treating beneficiaries of the public-access scheme.** Article 33(4) of Law 4368/2016 could not be retrieved; the rule against requiring an acknowledgement of debt is verified, the funding limb is not. *What would settle it:* the retrieved provision.

**Money and banking**

15. **Whether Greek banks operate a formal resident and non-resident account distinction, and what turns on it.** Law 4465/2017 creates none and imposes no AFM precondition. The widely repeated claim that the permit upgrades a family to a resident account is unverified. *What would settle it:* Bank of Greece supervisory guidance, or the banks' own published account-opening frameworks.
16. **Vehicle registration and the Personal Number.** The National Register record for vehicle registration makes no reference to residence permits, to an AFM or to third-country nationals and is flagged as being under legislative change; the Personal Number eligibility rules are unestablished; and whether gov.gr login works on AADE credentials alone, or additionally requires an AMKA or a Greek mobile number, is unknown. *What would settle it:* the revised procedure record and the digital-governance instrument.

**Mobility**

17. **Confirmation that the Article 100 permit card is issued on the uniform format for this category.** Greece's Article 39 notification (OJ C/2026/1154, 24 February 2026) does not name the investor permit, stating generally that since 6 November 2020 all residence permits for third-country nationals are in the Regulation (EU) 2017/1954 format. Everything the permit does at a border depends on it. *What would settle it:* a specimen card, or written confirmation from the Ministry.
18. **United Kingdom airside transit.** The Immigration Rules signpost a separate Appendix Visitor: Transit Without Visa Scheme which could not be retrieved. The report asserts neither that a Greek permit is, nor that it is not, sufficient for a change of planes. *What would settle it:* the Appendix text.
19. **Canada's electronic travel authorisation and transit programmes.** The visa limb is closed on primary regulation, but eTA eligibility sits outside section 190 and the transit programmes are administered separately. *What would settle it:* the current canada.ca criteria.
20. **The Kenyan exemption's statutory text, and the treatment of investment-programme passports generally.** The 60-day exemption at Q5.9 is verified from the immigration authority's published statement of the Rules and not from the Kenya Gazette, so an origin or residence proviso in the statutory text cannot be excluded; more broadly, it was not established whether São Tomé and Príncipe issues investor-naturalised citizens an ordinary passport of the same series as a citizen by origin, nor whether any destination applies heightened scrutiny to investment-programme passports as a class. *What would settle it:* the gazetted Rules, re-checked at the date of travel; and the passport-issuance provisions of Decreto-Lei n.º 07/2025 and its regulations from the São Toméan gazette.
21. **The visa position of a São Toméan passport holder for Nigeria, Egypt, Morocco and Angola,** none of which could be established from a government source of those states. Angola is the case to watch, because it is both an ECCAS member alongside São Tomé and a fellow lusophone state, and plausibility is not verification; where an exemption rests on a bilateral or lusophone instrument rather than a general nationality list, an origin, residence or duration-of-nationality condition is materially more likely to appear in the operative text and must be read rather than assumed neutral. Separately, the entry-into-force threshold of the African Union free-movement protocol could not be read, the AU's published text being a scan with no text layer, and the AU status list is dated 8 August 2023. *What would settle it:* the responsible authority's published position in each state; and a machine-readable protocol text with a status list later than August 2023.

**The property**

22. **The statutory minimum residential lease term.** The report proceeds on three years (§8.9, Appendix E item G6), resting on Article 2 of Law 1703/1987 as amended by Article 1(5) of Law 2235/1994, whose gazette text has not been inspected; the 1987 text as enacted sets two years with a tenant-only right to extend to three, and the law reaches only leases of a main residence. *What would settle it:* the gazette for Law 2235/1994.
23. **Whether the short-let prohibition binds pre-April-2024 holders at renewal.** Article 100(7Α) reaches property held for the initial grant or renewal, while Article 64(3) of Law 5100/2024 preserves legacy permits provided the conditions in force at the time of their grant continue to be met. *What would settle it:* a ministerial circular.
24. **Whether the joint decision under Article 176(49) on assessing and collecting the €50,000 and €150,000 fines has issued.** *What would settle it:* the decision, or confirmation from the Ministry that none has issued.
25. **The rental-income scale for income earned from 1 January 2026.** The enacted scale at Q6.4 is the three-band scale of Article 40(4); §8.9 and Appendix E item G8 record a reported four-band scale for income earned from 1 January 2026, together with a reported requirement from 1 April 2026 that rents be paid into a declared landlord bank account on pain of losing the 5% deduction. Both are reported and pending gazette confirmation. *What would settle it:* the gazetted amending provision.
26. **Current ENFIA rate tables and the supplementary tax, and the inheritance-tax texts against a consolidated version.** The Category A scale and the primary-residence exemption at Q6.6 were verified against the 2010 replacing text only. *What would settle it:* consolidated texts from AADE.

**The citizenship component**

27. **Whether a parent naturalised under the investment framework transmits originary nationality.** The words of Articles 5(a) and 5(c) are verified and carry no qualifier as to the parent's mode of acquisition; the legal conclusion for a naturalised parent is nowhere stated, and the rights of long-established nationals cannot be assumed to extend to a person naturalised through an investment programme. The programme is approximately one year old and no registry practice can yet exist. *What would settle it:* an instruction or circular of the Conservatória dos Registos Centrais or the Direcção-Geral dos Registos e Notariado, or a registered attribution in favour of the child of a programme-naturalised parent.
28. **Who makes the Article 5(c) declaration for a child too young to make it, within what period, and whether a child who is a citizen by origin nevertheless pays the post-approval charges.** The statute names no declarant and sets no time limit, by contrast with the express one-year-after-majority window elsewhere. The decree is expressed to apply to foreign natural persons who apply for nationality by investment or donation, which a child who is São Toméan from birth is not; but the annex's US$500 line for a citizen's newborn child up to one year is difficult to explain if such children were already citizens by origin needing only registration. The two questions are one linked question and must be read together with item 27. *What would settle it:* the declaration form and instructions issued under Article 22(1) or a consular instruction; and a fee notice of the responsible unit, or one documented Article 5 registration for a post-grant child.
29. **The grandchildren limb.** Whether the omission of the declaration condition is deliberate; whether the grandparent must have held the nationality at the grandchild's birth; whether the term used excludes great-grandchildren; and what evidence the registry requires across two generations. Reading the limb as automatic produces the result that a grandchild is better placed than a child. This is the least safe proposition in the framework to rely on. *What would settle it:* administrative guidance, or a registered attribution under that limb.
30. **Whether the responsible unit in fact admits applications for adult children or for ascendants, and under what instrument.** The programme channel publishes both classes and neither gazetted instrument provides them; no despacho or complementary instrument authorising them was located. *What would settle it:* the instrument relied on. See §16.4 and §16.5.
31. **Whether the military-service exemption survives the constitutional duty.** The exemption is granted by decree-law while the duty to render military service is stated in the Constitution; no ruling was found, the constitutional text is verified only in English translation, and whether conscription is operated at all could not be established. *What would settle it:* the military-service statute and any constitutional ruling.
32. **The counting basis of the fourth-nationality rule.** The coherent reading counts São Tomé itself, so a single further acquisition after the grant triggers loss; that is an interpretation and not an established position, and no implementing regulation, guidance or decision settles it. The only practical brake is that loss takes effect from registration combined with the absence of any duty on the citizen to report a new nationality, which is an enforcement gap and not a legal protection. *What would settle it:* an implementing regulation, administrative guidance or a decided case.
33. **The conflict between the decree's administrative revocation of nationality and the Law's conviction requirement.** The decree makes revocation of nationality a penalty for an administrative infraction with only a prior hearing and proportionality guaranteed, while the Law requires deprivation to be decreed after a final conviction and the decree itself refers loss back to the Law. The conflict is on the face of the instruments and is untested. *What would settle it:* a São Toméan judicial decision, or an instrument resolving the conflict.
34. **Consular reach and consular protection.** No accreditation table is published, so which further countries each post covers on a non-resident basis could not be established, and the ministry's own records are visibly incomplete; the proposition that consular protection is constitutionally guaranteed to citizens overseas could not be verified, and whether investment-route citizens are served on the same terms is addressed by no administrative guidance. *What would settle it:* the accreditation table and the constitutional text.
35. **Provenance of the São Toméan instruments.** No official São Toméan gazette repository was publicly reachable, the programme channel hosts neither instrument, and the reachable facsimiles are third-party hosted; the served files are byte-identical to the copies read, which establishes what the access route serves rather than independent authentication. The access routes are recorded at Appendix M, C-001 and C-002. *What would settle it:* official copies from the Diário da República de São Tomé e Príncipe.

---

## How this appendix should be read

Two propositions carry most of the practical weight of Q.1 to Q.6, and both are properly stated only with their conditions attached.

The first is that a Greek state-school education and the integration qualification for permanent status are the same decision. Minor third-country nationals residing in Greece are subject to compulsory school attendance on the same footing as Greek nationals and enrol on the documents required of Greek nationals; a leaving certificate from Greek compulsory education is, among other routes, one of the ways the integration condition for EU long-term resident status is satisfied; and a child who graduates from secondary education in Greece accesses Greek tertiary education on the same terms as a Greek national (Law 5038/2023, Articles 18(7)–(9), 145(2) and 160(1)). The condition is that the family lives in Greece: the five-year route to EU long-term resident status requires five years lawfully and continuously resident, tolerating only absences of under six consecutive months and not exceeding ten months in total, whereas Articles 95(1) and 100(4) make absence no obstacle to renewing the permit (§19.3). Whether the investor years count toward that five at all is unresolved and the whole long-term proposition turns on it (Article 143(2)(ε) read with Article 144(2)); that question, and the ten-year national route which asks far less presence, belong to the status analysis at §19.3 and §7.13 and are not capabilities of the position as it stands.

The second is that the Greek footing can be put in place at a distance. The basic payment account is an entitlement applying irrespective of the consumer's place of residence, with no genuine-interest test in Greek law and a reasoned written refusal if declined; the tax number and TAXISnet key issue free of charge on production of a valid residence permit, with identification by video call and lodgement by an authorised representative; the Greece-located account requirement in the purchase provisions attaches to the seller and not to the buyer; and dependants may enter with the investor or later, children under six not needing to enter Greece at all. What requires being in Greece is the status, not the set-up — biometrics are collected only in Greece and must be given within the exclusive twelve-month period (§19.3), and every presence-dependent benefit in this appendix carries its presence condition in the same sentence.

Neither proposition narrows the distance between a residence permit and a citizenship, and nothing in this appendix should be quoted without the qualification attached to it in the cell it came from. The report's position is unchanged: it examines one structure, states what each instrument provides and on what condition, and does not recommend it over the field.
