<!-- 7. The European Residence Component — from "After the EU's Golden Passports", Kestrel Private, 6 August 2026. Canonical: https://kestrelprivate.com/research/after-the-golden-passports -->

# 7. The European Residence Component

This chapter sets out the legal architecture of the residence component: the Greek investor residence permit, in its €250,000 change-of-use category, as it stands as at 2 August 2026. The property as an asset is assessed in Chapter 8; the costs are built up in Chapter 10; the risks are consolidated in Chapter 14.

## 7.1 Purpose of the residence permit

The residence component of the reference structure is a Greek investor residence permit supported by qualifying real estate. Within the coordinated position described in Chapter 5, it is the component from which every European right in the structure derives. The citizenship component provides none of them (see Chapter 6); the two components are complementary parts of one coordinated position, each assessed on its own legal terms.

Subject to the conditions of the permit, the residence component may provide:

- lawful residence in Greece under the conditions of the permit;
- a renewable European residence position while the qualifying conditions continue to be met;
- short-stay travel in other Schengen states, up to 90 days in any 180-day period (§7.10);
- a physical European base; and
- inclusion of qualifying family members under the applicable rules (§7.9).

It is a residence permit and nothing more. It confers no Greek or EU citizenship and no passport, establishes no right of access to employment (§7.11), does not of itself create tax residence (see §9.6), carries no voting or political rights, and provides no guaranteed route to eventual naturalisation (§7.13).

Because Greek law itself imposes no physical-presence requirement on this permit, either to hold it or to renew it — Article 100(4) provides in terms that intervals of absence do not impede renewal (§7.8) — it is suited to the "residence held in reserve" objective described in §3.4: a lawful European position maintained from abroad and used if circumstances change. The same characteristic is the reason the permit does not, of itself, mature into citizenship (§7.13).

## 7.2 Legal basis of the investor-residence programme

The permit is created by Article 100 of Law 5038/2023, the Greek Immigration Code (Government Gazette A′ 81/01.04.2023), as the permanent investor residence permit, permit type «Β.5»; the Code entered into force on 31 March 2024 (Article 179).[^7-1] Article 100 was amended by Article 64 of Law 5100/2024 (Government Gazette A′ 49/05.04.2024), which set the current thresholds and restrictions and entered into force on publication — hence 5 April 2024 as the hinge date recurring through this chapter.[^7-2] The market's historical name for the category, the "golden visa", appears in the title of the official administrative record itself; this report uses the statutory description.

A note on citation. This chapter cites the consolidated text of Law 5038/2023, codified through Law 5307/2026, rather than the 2023 gazette text alone, because provisions material here — Articles 11(1) (late renewal) and 17(1) (card collection) — have been amended since 2023. No official consolidation of the Code was located for this report: the consolidated wording was read through a commercial codification service and cross-checked against the gazette facsimile, and the amending instruments for those two articles have not been identified in the sources read, so both rules are stated subject to confirmation (§7.7, §7.8).[^7-1][^7-6]

Beneath the statute sit three administrative layers. Documentation is fixed by Joint Ministerial Decision 214926/2025 (Government Gazette B′ 6014/11.11.2025), whose Article 1 keeps in force the common documents of the predecessor decision (JMD 95391/2024, Article 2).[^7-4] The official administrative record for the category is maintained on the National Registry of Administrative Public Services (mitos.gov.gr) by the Ministry of Migration and Asylum and was last updated on 31 July 2026 — the date given in Chapter 1, which is the record's update stamp and not the date of any instrument.[^7-3] Circular 9/2024 is cited in that record's legal basis; Circular 1/2026 of the Secretary General for Migration Policy (21 April 2026) tightened the category in the respects described at §7.5 and is cited here from professional summaries, the circular text itself not having been opened.[^7-3][^7-5]

Permits granted under the predecessor provision (Article 20B of Law 4251/2014) or under earlier conditions remain in force and are renewed provided the conditions in force at the time of their grant continue to be met (Article 64(3) of Law 5100/2024).[^7-2] Greek practice on threshold changes has, to date, been to grandfather issued permits (§7.14).

## 7.3 Standard property thresholds

Article 100(2), as amended, sets two standard minimum-investment thresholds, defined by location; the position is summarised below.

| Zone or category | Minimum investment | Property conditions |
|---|---:|---|
| The Region of Attica; the Regional Unit of Thessaloniki (Region of Central Macedonia); the Regional Units of Mykonos and Thira (Region of South Aegean) — the Regional Unit of Thira comprising Thira (Santorini), Ios, Folegandros, Sikinos and Anafi; and islands with a population, according to the latest census, over 3,100 | €800,000 | One single property; where the property is built, or a building permit has been issued for it, at least 120 m² of main spaces |
| All other areas of Greece | €400,000 | One single property; where the property is built, or a building permit has been issued for it, at least 120 m² of main spaces |
| Exception — change of use to residential, or restoration/reconstruction of a listed building | €250,000 | One single property; no minimum floor area (§§7.4–7.5) |

*Minimum investment under Article 100 of Law 5038/2023, as amended by Article 64 of Law 5100/2024, as at 2 August 2026. The table summarises the provision; the zone description follows the statutory wording, and compressed renderings such as "Attica and the larger islands" are not the statute. The statute fixes the high-value zone by **regional unit**, not by island. The Regional Unit of Thira extends well beyond Santorini, and the islands within it that fall below the 3,100 population limb — Ios, Folegandros, Sikinos and Anafi — are nonetheless in the €800,000 zone; a €400,000 acquisition on any of them supports no permit, and the defect cannot be cured, the price having to be paid in full before the application is submitted (§7.6). The constitutive instrument for the regional units is Article 3 of Law 3852/2010, whose text was not opened for this report: the composition of the Regional Unit of Thira is stated from secondary administrative sources and must be confirmed before any island acquisition is priced against a threshold.[^7-33] The 3,100 limb is measured by the latest census, so the qualifying set moves with each census. The minimum stated is the value of the acquisition; on undivided co-ownership it is the value of each co-owner's share, except where the co-owners are spouses or cohabitation partners (§7.6). Sources: consolidated statutory text; official administrative record.*[^7-1][^7-2][^7-3]

The reference structure uses neither standard threshold: it relies on the exception described in §7.4. What a statutory price floor does to the pricing of eligible stock is a property question, not an immigration question, and is examined at §8.3 and §8.7.

## 7.4 The €250,000 change-of-use category

By exception, €250,000 suffices in two cases: a property whose main spaces change use to residential, and a listed or preserved building (διατηρητέο) being restored or fully reconstructed.[^7-1][^7-2] In each case the investment must be in one single property, and no minimum floor area applies — the 120 m² condition attaches only to the standard thresholds.[^7-1] In the statutory wording the exception is framed by the character of the property rather than by zone.[^7-1][^7-2] What that does to the composition and pricing of the stock available at €250,000 in the principal urban markets is a property-market question, examined at §8.7.

The reference structure uses the change-of-use limb. The listed-building limb carries obligations of its own — the restoration must be completed by the first renewal, and transfer of an unrestored listed building is void, with administrative fines of €150,000 attaching to those breaches under Article 100(7A) of the consolidated text — and it is not the reference route. The mapping of those fines to particular breaches within Article 100(7A) requires confirmation against the gazette text of Law 5100/2024; the consolidated risk treatment is in Chapter 14.[^7-1]

The €250,000 threshold is, in effect, once-only per property. The notary must certify in the deed whether the property has previously been used for the issuance of a permit (Article 100(6)), and a selling third-country national must obtain certification on the same point (Article 100(11)).[^7-1] Professional commentary on Law 5100/2024, corroborated by the reported contents of Circular 1/2026, states that a property previously used for a permit cannot be redeployed at €250,000 by a subsequent investor; this report treats the once-only effect as the reported administrative position rather than express statutory text.[^7-5][^7-29] Whether a resold conversion property could support a fresh €250,000 application by a later buyer is a distinct open administrative question, examined for resale purposes at §7.12 and §8.14.

The design of the provision indicates what the category was directed at. No explanatory statement of purpose accompanying Article 64 of Law 5100/2024 has been read for this report, and none is quoted here; what follows is drawn from the structure of the provision itself. The reduced figure is not generally available. It is available only where the main spaces of a building are converted from another use to residential; only where that conversion is complete before the application is submitted; and only where completion is certified by an engineer against a named planning act (§7.5).[^7-1][^7-4] Where the building was industrial, the engineer must certify in addition that no industrial activity has been installed and in operation in it for at least the last five years.[^7-1][^7-3] The threshold is once-only per property, the property may not be let short-term or sub-let, and it may not serve as the seat or branch of a business (§7.12).[^7-1] On its face the provision therefore conditions the lower threshold on a building being taken out of a non-residential — in the industrial limb, a disused — use, put into residential use, and kept there.

What a design of that kind is capable of supporting, and what defeats it, is a property question rather than an immigration one, and it is assessed at §8.15. This report asserts no delivered outcome under the category: no official evaluation of its effects was located for this report, and uptake cannot be counted from the published statistics (below).

Two cautions close the section. The category is not universally available: it exists only for properties satisfying the conversion or restoration conditions in full. And no official statistics measure it — the Ministry's monthly bulletins publish no breakdown of permits by investment category, so uptake of the €250,000 change-of-use category is not published in official statistics as at 2 August 2026.[^7-9]

## 7.5 Change-of-use requirements

The statutory condition is brief. Under Article 100(2) the main spaces of the property must change use to residential; the change may be effected by the buyer or by the seller; and it must have been completed before the application is submitted. The statutory text contains no calendar date.[^7-1]

The completion window comes from the administrative record, which states that the conversion "must have been completed after the entry into force of Article 64 of Law 5100/2024, i.e. after 5 April 2024, and before the application is submitted".[^7-3] This report accordingly cites the administrative record — not Article 100 itself — for the after-5-April-2024 limb. The two are consistent, but a reader checking the statute alone will find only the before-application condition.

The evidence establishing the qualifying conversion is fixed by JMD 214926/2025, whose full documentary schedule is set out at Appendix E. At initial issuance the file turns on four things: evidence of lawful entry or residence, or filing by proxy before any entry (§7.7); the notarial certificate covering the parties, the property, the price, the payment method and all payment details, full payment, and whether the property has previously been used for a permit; proof of land-registry or cadastral registration, for which an attestation that registration has been applied for, or a lawyer's certificate, suffices at initial issuance, with the definitive certificate submitted at renewal; and the engineer's technical report certifying the change of use. To these are added evidence of full ownership where the property is acquired through a Greek or EU legal person, a private insurance policy (§7.7), the €2,000 electronic state fee and a copy of the E9 property-tax declaration.[^7-4]

The engineer's report follows a prescribed formula, certifying the conversion by reference to named planning acts — a building permit, a small-scale works approval, an update of the building-permit file, or a building-permit revision — with completion after the entry into force of Article 64 of Law 5100/2024 (the decision's own words; the administrative record's gloss is at §7.4) certified by the issue date of the relevant act.[^7-4] On the decision's own terms, a conversion licensed before 5 April 2024 can therefore qualify through a post-5 April 2024 file update or revision — but only within the substance rule of Circular 1/2026, set out below, which excludes paper amendments and requires an actual completed change of use.

That evidentiary rule must be read with the substance rule in Circular 1/2026, whose contents are reported as follows: a property already in residential use on 5 April 2024 cannot qualify by being cycled out of and back into residential use; a paper amendment to a building permit does not count, only an actual completed change of a building's use; mixed conversions are possible; case-handling services must refer misleading advertising and suspicious payment flows to the tax authority and the anti-money-laundering authority; and permits may be revoked where arrangements reduce the effective investment below the statutory minimum.[^7-5] The decision fixes the evidentiary date; the circular polices substance. A property whose "conversion" is documentary rather than real fails the category even where the paperwork recites the right dates — a matter for the technical due diligence described at §8.5 and §17.7.

Industrial buildings attract an additional condition: the engineer must certify that no industrial activity has been installed and in operation in the building for at least the last five years,[^7-1][^7-3] evidenced under the JMD by a power-disconnection certificate from the electricity distribution operator or the municipality, by the E2 tax forms for the preceding five years, or by combined evidence from tax and other public authorities.[^7-4] The reported position under Circular 1/2026 is that the five-year condition applies unless the space was a handicraft or workshop use.[^7-5]

## 7.6 Eligible property and ownership conditions

The applicant must hold full ownership and possession (πλήρης κυριότητα και νομή) of one property with a minimum acquisition value of €250,000 at the time of purchase.[^7-1][^7-3] Co-ownership is expressly regulated. On undivided co-ownership of a property meeting the paragraph 2 minimum, the residence right is granted only if the co-owners are spouses or partners who have concluded a cohabitation agreement; in any other case it is granted only where each co-owner's share is itself worth at least the paragraph 2 minimum (Article 100(1)(b)).[^7-1][^7-2] Each threshold limb repeats the point in terms: for the change-of-use and listed-building categories the minimum value of a co-ownership share is €250,000 (Article 100(2)(c) and (2)(d)).[^7-1][^7-2] Two spouses may therefore share one €250,000 conversion property; two co-buyers who are not spouses or cohabitation partners require €250,000 each — €500,000 between them. Where the property is acquired through a Greek or EU legal person, the applicant must own the entity in full (§7.5).[^7-4]

Payment is prescribed exhaustively. The full price must be paid before the application is submitted, by crossed bank cheque to the seller's account at a credit institution operating in Greece, by credit transfer within the meaning of Article 4 point 24 of Law 4537/2018, or through the point-of-sale facility of a payment provider operating in Greece; payment may also be made by the buyer's spouse or by relatives by blood or marriage up to the second degree.[^7-1] Every payment detail is recorded in the notarial deed, and the notary certifies the parties, the property, the consideration, the method and execution of payment, full payment, and whether the property has previously been used for a permit (Article 100(6)).[^7-1] The rails are exclusively banking rails: funds must arrive through credit institutions, which carry their own customer due-diligence and refusal obligations. Source-of-funds preparation is addressed in Chapter 15 (for digital-asset-origin wealth, §15.9).

Eligibility under Article 100 is an immigration question only. Title, encumbrances, planning legality and building compliance are separate questions of Greek property law, examined through the due diligence described at §§8.4–8.5. A property can satisfy Article 100 in full and still be a poor asset (§8.3); the two assessments are never collapsed into one.

## 7.7 Application process and documentation

Application is digital-only, through the Ministry's portal. The applicant need not have entered Greece to file: Article 10(11) of the Code permits filing by a proxy holding a power of attorney executed before a Greek consular authority, or before a foreign authority or notary and bearing the Hague apostille or equivalent legalisation.[^7-6][^7-3]

The filing then obliges one visit. Within an exclusive period of 12 months from filing, the applicant — and each included family member — must enter Greece and submit biometric data together with the outstanding insurance document. Biometrics comprise fingerprints of both index fingers, captured to passport specifications, and are collected only in Greece: no consular route exists in the instruments read for this report. Attendance is by summons; after two failures to appear the application is rejected (Article 14(7)).[^7-6] Entry for the visit may be on any lawful basis — for most clients, visa-free entry or a Schengen visa on the original passport, depending on that passport's position under the EU visa lists;[^7-28] an optional national (type D) entry-visa route exists at a consular fee of €180.[^7-4]

The residence card may be collected by proxy for permits issued under Articles 97, 98 and 100 — types B.2, B.3 and B.5, together with type «Β.6» under Article 100Α in the consolidated text — for which a certified copy of the passport is accepted in place of the original; the facility does not extend to type B.4 (Article 17(1)).[^7-6] Article 17(1) is cited in its amended, consolidated version; the amending instrument is not identified in the sources read for this report, and the rule requires confirmation at the date of application.

Insurance is a condition of residence, not a formality. Article 8(ε) of the Code requires full sickness insurance for the risks covered for nationals; because the permit carries no labour-market access, cover is obtained from private insurers unless the applicant's foreign policy expressly covers the holder for the period of residence in Greece.[^7-6][^7-8] The operative document at issuance and at renewal is an insurance policy of a private insurance body, produced annually.[^7-4][^7-3] The minimum coverages applied in practice were fixed under the predecessor Code by JMD οικ. 53821/2014; they are set out with indicative premiums at §10.10, and their formal survival under the current Code requires confirmation at the date of application.[^7-8]

Timing requires care. Article 100(10) sets a statutory limit: the permit is issued within two months of all elements of the file reaching the issuing authority.[^7-1][^7-2] The administrative record states a shorter completion standard of 50 days.[^7-3] Both run from completion of the file — and on the proxy route the file completes only when biometrics are given — so neither may be read as an end-to-end time. An application for reconsideration lies within two months of service of the decision, on a €50 fee, and is decided within an exclusive period of 30 days (Article 16(2)).[^7-6] The official pendency data are the honest counterweight: as at March 2026, 10,032 investor applications were pending, and 3,399 initial applications filed in 2024 were still undecided.[^7-9] Processing time cannot be assured, and no timing representation should be relied upon (sequencing is addressed at §17.11).

Application fees are set out with the family schedule at §7.9; the full cost build-up is at §10.7.

## 7.8 Residence-permit duration and renewal

The permit is granted for five years and is renewable for equal periods each time, provided the property remains in the holder's ownership and possession; the statute imposes no cap on renewals. Periods of absence from Greece are statutorily no obstacle: Article 100(4) provides in terms that intervals of absence from the country do not impede renewal.[^7-1] There is therefore no physical-presence requirement at grant or at renewal — the statutory basis of the "held in reserve" characteristic described at §7.1.

The renewal application is filed within the two months before expiry. In the current consolidated text of Article 11(1), a late application may be filed up to three months after expiry, subject to a fine of €100 for each month of delay, beyond which renewal is barred absent proven force majeure; the original 2023 text, which allowed one month's grace at a flat €100, has been superseded by amendment.[^7-6] The amending instrument is not identified in the sources read for this report, and the late-renewal rule — including the fine — requires confirmation at the date of renewal.

The renewal file re-proves the property position documentarily; it does not re-run the investment review. Under the JMD it comprises proof that the property remains in the holder's ownership and possession; a fresh private insurance policy; the €2,000 state fee, charged again at each renewal; an E9 copy; the definitive land-registry or cadastral certificate where deferred at initial issuance; and solemn declarations that the property is not let short-term or sub-let (for the post-2024 categories) and, for the change-of-use category, that the main spaces remain in residential use and the property is not the seat or branch of a business.[^7-4][^7-7] Whether adult holders re-attend fingerprinting for each new card is strongly implied by the biometric provisions but is not the subject of an express rule located for this report; it requires confirmation at the date of renewal.[^7-6]

Law 5275/2026 (Government Gazette A′ 17/06.02.2026) is reported to provide, among administrative changes, that the five-year validity of the card runs from issuance rather than from the application date — a change affecting only card validity, not the residence clock that matters for naturalisation (§7.13). The gazette text has not been read for this report; the change is stated as reported only and requires confirmation at the date of application.[^7-27]

Interim status. On filing a complete application the applicant receives a certificate of submission — the "blue receipt" — valid until the decision. It certifies lawful residence in Greece, and its holder temporarily enjoys the rights flowing from the permit applied for (Article 10(8)).[^7-6] Whether the certificate supports short-stay movement in other Schengen states is not addressed by any official source located for this report; the prudent working assumption is that mobility under Article 21 of the Schengen Convention begins with the issued permit, not the receipt — a point to be confirmed with Greek counsel at engagement.

## 7.9 Family-member inclusion

Family membership follows Article 95(2) of the Code: the spouse, or the partner with whom the investor has a cohabitation agreement; unmarried children under 21; the direct ascendants of the spouses or partners — that is, of both the investor and the spouse or partner; and adult children of the investor or of the spouse or partner who lack legal capacity, regardless of age, where they live with and are maintained by the sponsor, the incapacity being proved by a final judgment of a Greek court, or of a foreign court recognised in the Greek legal order, or by an equivalent document of the competent authority of the country of origin or habitual residence, duly legalised and translated (Article 95(2)(ε)).[^7-7] Family members receive family-reunification permits (type O.1), which expire simultaneously with the sponsor's permit; a child reaching 21 receives an independent residence permit (type O.2) for three years.[^7-7]

Each family member files an individual application, holds qualifying insurance in their own name, and attends the biometric appointment within the 12-month period running from that person's own filing (§7.7).[^7-6] The common and family documentary requirements sit in JMD 95391/2024 (Article 2), which remains in force; the family evidence list is addressed in Chapter 16 and requires confirmation against the current decision at the date of application.[^7-4]

| Fee item | Amount |
|---|---:|
| Main applicant state fee (παράβολο) — initial issuance | €2,000 |
| Main applicant state fee — each renewal | €2,000 |
| Electronic residence card, per card issued | €16 |
| Family-reunification permit (type O.1) | €150 |
| Independent three-year permit (type O.2) of a child reaching 21 | €150 |
| Minor children | Exempt from the state fee |

*Statutory fee schedule under Article 171 of Law 5038/2023 and the official administrative record, whose fee table totals €2,016 (€2,000 + €16) for the main applicant's initial issuance. The €2,000, the €150 and the exemption for minors are Article 171 (paragraphs 1(γ), 1(β) and 2(γ) respectively); the €16 card charge appears only in the administrative record. Amounts in euro as at 2 August 2026; every figure is per person, and family composition drives the total — see Chapter 11 for family cost models and §10.7 for the single-applicant build-up. On the fee for the child's independent permit the Code distinguishes two routes: Article 171 §1(β) prices types O.1 and O.2 at €150 and reserves €450 for the three-year independent O.2 permit granted under the* first *sentence of Article 90 §5, while Article 95(2) grants the investor's child that permit by analogous application of the* second *sentence. The fee applicable to this route is therefore €150 on the face of the Code; the €450 figure circulates in practice and requires confirmation against the administrative record at the date of application. The same second-sentence reading permits no further renewal, which is why the independent permit is in practice a bridge to about age 24 and not to 27.*[^7-7][^7-3]

## 7.10 Schengen travel rights

The Greek permit is issued as a stand-alone card in the EU uniform format under Regulation (EC) No 1030/2002, with an electronic chip; it is therefore a "residence permit" within Article 2(16)(a) of the Schengen Borders Code, with full effect under Article 21 of the Convention Implementing the Schengen Agreement.[^7-6][^7-13][^7-12]

Under Article 21(1) of the Convention, as replaced by Regulation (EU) No 265/2010, a third-country national holding a valid residence permit issued by a member state may, on the basis of that permit and a valid travel document, move freely within the territories of the other member states for up to 90 days in any 180-day period (the period as substituted by Regulation (EU) No 610/2013), subject to conditions: a valid travel document, satisfaction of the relevant entry conditions of the Schengen Borders Code, and absence from the national alert list of the member state concerned.[^7-10][^7-11] Days spent in Greece under the permit are not counted against the 90/180 allowance for the rest of the area (Article 6(2) of the Schengen Borders Code).[^7-12] The mobility in practice — its limits, registration duties in some states, and the temporary reintroduction of internal border controls by several member states — is examined at §4.4; the consolidated rights position is at §19.4.

One nationality-specific limit belongs here rather than only in the catalogue of limits. Cyprus, which is not part of the area without internal border controls, recognises Schengen residence permits for short stays under Decision No 565/2014/EU; the published Cypriot position is that the concession does not apply to citizens of Turkey or of Azerbaijan, who must follow the ordinary visa procedure unless they are family members of an EU citizen.[^7-32] For a Türkiye-national holder — 16.6% of the investor cohort (§7.14) — the Greek permit therefore does not open Cyprus (see §4.4 and §13.2).

The attribution rule bears restating. This mobility is a creature of the residence permit: it attaches to the permit and travels with the permit. Nationals of São Tomé and Príncipe remain on the visa-required list (Annex I of Regulation (EU) 2018/1806); the citizenship component provides no Schengen access of any kind (see §6.9).[^7-28]

Document pairing at the border requires attention in a two-passport structure. The uniform-format card prints the holder's nationality as a mandatory field, no passport-number field is prescribed, and in practice the permit records the nationality of the passport against which the application was made.[^7-13] EU law requires the permit "and a valid travel document" and prescribes no matching standard between them; the border check examines the travel and residence documents together, with matching left to operational practice.[^7-10][^7-15] The only published national matching rule located for this report is Belgium's: official guidance requires the traveller to carry both documents and requires a 100% match of five identity parameters — name, first name, sex, date of birth and nationality — between passport and permit, with an express example that a dual national cannot pair the passport of one nationality with a permit recording the other.[^7-14] That is national administrative guidance, not a Schengen-wide norm, and is cited as the strictest documented practice.

What follows for the reference structure — stated as practice, not as a provision of EU law — is that where the citizenship component is acquired, the passport whose identity details, including nationality, match the permit remains the travel document for the permit, and both documents are carried where both are relevant to the journey. The São Tomé passport does not become the travel document for the Greek permit merely because both are held. Greek law provides a declaration route for changes: the holder must declare a change of nationality, and any change of passport details, through the Ministry's electronic services, generally within two months (fines of €100, and €200 on repetition, attach to non-declaration), and the details recorded on the card may be changed only on the basis of the foreign authorities' own documents, on a reissue application carrying a €100 fee.[^7-6] Whether Greece will re-key a permit to a newly acquired second nationality while the original subsists is not addressed in any published rule located for this report and requires confirmation with Greek counsel at engagement. Where the original nationality is lost on naturalisation — a home-country-law question addressed at §13.2 — the declaration route becomes obligatory.

## 7.11 Employment and business limitations

The permit does not establish a right of access to any form of employment (Article 100(9)).[^7-1] The exclusion is categorical: no salaried employment in Greece, and no employment right elsewhere in the EU, arises from the permit. A family that needs the right to work in Europe fails the suitability screen for this structure (see §1.7 and §13.4).

Within that limit, three points define the permitted economic perimeter:

- Letting the property. Article 100(7) expressly permits letting of the acquired property, subject to the short-term-letting prohibition described at §7.12.[^7-1]
- Investment activity. Law-firm guidance seen by Kestrel Private, but not cited as authority in this report, treats activity as a shareholder, partner or company board member as falling outside "employment" for this purpose. The current Code contains no express statutory carve-out that this report could verify; the position requires confirmation with Greek immigration counsel before any reliance is placed on it.
- Business use of the property. A change-of-use property may not be used as the seat or branch of a business, and the renewal file includes a solemn declaration on the point (§7.8, §7.12).[^7-1][^7-4]

Company formation in Greece or elsewhere is legally separate from the permit and is examined in Chapter 9; a company neither requires nor confers residence rights (§4.7, §9.2), and managing a company from Greece raises tax questions of its own (§9.6–§9.7).

## 7.12 Property holding and disposal requirements

The permit lives and dies with the property.

Retention. The permit remains valid, and is renewable, only while the property remains in the holder's full ownership and possession; renewal is refused without documentary proof of that position (§7.8).[^7-1][^7-4]

Sale. Resale during the permit's period of validity gives a qualifying third-country-national buyer the right to a permit and **simultaneously revokes the seller's permit** (Article 100(8)); a selling third-country national must first obtain certification whether the property has been used for the issuance of a permit (Article 100(11)).[^7-1] Exit from the asset is therefore exit from the residence position: the two cannot be separated, and the investment consequences are examined at §12.10 and §14.14. Whether the buyer of a previously used conversion property could qualify at €250,000, or must instead satisfy the standard thresholds, is an open administrative question requiring confirmation at the time (§7.4, §8.14).

Letting. Long-term letting is expressly permitted (Article 100(7)). Short-term letting in the framework of the sharing economy, and sub-letting, are prohibited for properties acquired for the initial grant or renewal of an investor residence permit, the change-of-use category included; the further prohibition on use as a company seat or branch is confined by its terms to properties acquired under Article 100 §2(c) (Article 100(7A)).[^7-1][^7-2] Breach carries revocation of the permit and a standalone administrative fine of €50,000, confirmed both in the consolidated statutory text and in the notarial profession's coordinating circular on the 2024 amendments.[^7-1][^7-19] The renewal file includes a solemn declaration of compliance (§7.8). The commercial consequence — no short-term-letting income can lawfully be earned or priced into an exit — is examined at §8.10.

How far back the prohibition reaches is not settled on the face of the statute. Article 100(7A) extends in terms to properties held for renewal, while Article 64(3) of Law 5100/2024 renews permits already issued on the conditions in force when they were granted; the two provisions pull in opposite directions and no instrument read for this report reconciles them. A holder of an older permit who relies on letting income should obtain Greek immigration advice on the point before letting, and should assume the prohibition applies until advised otherwise.

Practical liquidity. Greek primary-residence leases are reported across professional sources to carry a mandatory minimum duration of three years even where a shorter term is agreed (Article 2 of Law 1703/1987, as amended by Article 1(5) of Law 2235/1994); the gazette text has not been read for this report and the rule requires confirmation with Greek counsel.[^7-31] On that footing a let property cannot be recovered vacant at short notice, and selling costs the holder the permit; the resulting operational illiquidity is developed at §8.9 and §8.14.

## 7.13 Residence versus eventual naturalisation

Greek law contains no investor fast-track to citizenship, and this report makes no naturalisation representation of any kind. The position as at 2 August 2026, per the official administrative record for naturalisation (last updated 30 July 2026), is as follows.[^7-16]

The required period of prior lawful residence in Greece is structured as three, seven or 12 years by residence title: three years for defined exceptional categories; seven years for holders of specified residence titles — a list that expressly includes the investor permanent residence permit; and 12 years for holders of any other valid residence title.[^7-16] Years held under the investor permit therefore count toward the seven-year track.

Counting years is the smallest part of the test. The substantive requirements presuppose an actual life in Greece: the PEGP examination (Greek language, history, geography, culture and institutions); evidenced economic and social integration, including Greek tax returns for the years of residence; and an application fee of €550 (€100 for EU citizens, stateless persons and refugees), with a €200 fee on resubmission.[^7-16]

The permit's defining convenience — no physical-presence requirement — is therefore also its naturalisation ceiling. A holder who maintains the permit from abroad accumulates permit years but not the actual residence, tax record, language capability or integration evidence the tests require. **The permit alone, without genuine relocation, does not lead to Greek citizenship.** The same logic applies to EU long-term-resident status under Directive 2003/109/EC, which requires five years of legal and continuous residence together with resources and sickness insurance — continuity a non-resident holder does not accumulate.[^7-17]

Where eventual EU citizenship is the true objective, it is not achievable without genuine relocation, with the tax-residence consequences examined at §9.6–§9.7; and naturalisation remains in every case a discretionary act of the Greek state, never guaranteed (§18.9). Chapter 2 explains why residence-by-investment remains lawful while transactional citizenship does not (§2.6), and why no lawful structure can shortcut naturalisation (§2.7).

## 7.14 Legislative and policy-change risk

The programme's own history is the clearest evidence of its policy risk: three threshold regimes since 2013, two of the changes falling within roughly sixteen months, with continuous administrative tightening since.

- From its introduction in 2013 until April 2023, the minimum investment was €250,000 nationwide.[^7-18]
- Article 91 of Law 5007/2022 (Government Gazette A′ 241/23.12.2022) raised the minimum to €500,000 in designated high-demand areas; Article 92 was the transitional provision, preserving the prior €250,000 threshold where a 10% deposit was paid by 30 April 2023 — extended to 31 July 2023 by Article 177(11) of Law 5038/2023 — with completion of the investment, including on any substitute property, by 30 April 2024, the original deadline of 31 December 2023 having itself been extended.[^7-18]
- Article 64 of Law 5100/2024 set the current structure from 5 April 2024 — €800,000/€400,000 with the €250,000 exceptions — with its own transition: old-regime investments required a 10% deposit or pre-agreement by 31 August 2024 and completion by 28 February 2025 (extended by Article 37(1) of Law 5167/2024 from the original 31 December 2024), with substitute-property completion by 30 April 2025.[^7-2]
- Administrative change has continued: the documentation overhaul of JMD 214926/2025 (November 2025),[^7-4] the reported administrative amendments of Law 5275/2026 (February 2026; §7.8),[^7-27] and the anti-abuse instructions of Circular 1/2026 (April 2026; §7.5).[^7-5]

Each threshold change to date has grandfathered issued permits (Article 64(3) of Law 5100/2024).[^7-2] That is the pattern to date; it is not a guarantee. Nothing prevents a future legislature from raising thresholds again, closing the change-of-use category, altering renewal conditions or ending the programme, and the structure provides no protection from future legislative or policy change (§1.7; the consolidated risk treatment is at §14.1–§14.2).

Scale keeps the programme politically visible. As at March 2026, 30,439 investor permits and 56,917 family-member permits were in force; nationals of China account for 48.4% of initial investor permits and nationals of Türkiye for 16.6%; new monthly filings fell from 864 in March 2025 to 427 in March 2026.[^7-9]

Policy has also operated at nationality level, at EU as well as national level. The European Commission's Recommendation of 28 March 2022 asked member states to repeal investor-citizenship schemes immediately; for investor-residence schemes it recommended strong checks and safeguards rather than repeal, but it also recommended, at points 3 to 5, that member states assess the withdrawal of naturalisations granted to sanctioned Russian and Belarusian nationals and those supporting the war, that they immediately withdraw and refuse to renew such persons' investor-residence permits, and that they suspend issuance of investor-residence permits to Russian and Belarusian nationals.[^7-20] The Recommendation is not binding, but it is the instrument against which the national measure should be read: Greece announced on 28 February 2022 the suspension "until further notice" of issuance and renewal of investor permits for Russian citizens, and the current status of that suspension requires confirmation at the date of application (see §13.2).[^7-30] The general point holds for every client: an EU instrument has already recommended the withdrawal and non-renewal of issued investor-residence permits for a defined class of holders, and member states have acted on it.

At EU level otherwise, the judgment in Commission v Malta (C-181/23, 29 April 2025) concerned investor citizenship; it says nothing about investor residence permits, and the Commission itself distinguishes the two ("These schemes are different to investor residence schemes (or 'golden visas')…").[^7-21][^7-22] The European Parliament's March 2022 resolution demanded EU regulation of investor residence; no such instrument has been adopted.[^7-23] As at 2 August 2026 no EU instrument prohibits investor residence schemes, and no new Commission initiative on them has followed the Malta judgment — a dated statement of absence, not an assurance.[^7-24] The adopted direction of travel is scrutiny rather than prohibition: from 10 July 2027 the EU Anti-Money-Laundering Regulation makes "investment migration operators" obliged entities, requires enhanced due diligence on third-country nationals applying for residence rights in exchange for investment, and lists such applicants as a higher-risk factor.[^7-25]

Member-state closures are the nearer precedent: Spain ended its programme with effect from 3 April 2025 — a programme in which approximately 94% of permits were reported to be property-linked — and Portugal removed real estate from its programme in 2023 (both reported).[^7-26] Greece has so far responded to volume by raising thresholds and tightening evidence rather than by closing; the choice between those paths remains open to it at any time.

The consequence for the reference structure should be stated plainly: the structure's European residence position and its Schengen mobility depend on the continuity of the Greek permit and its renewal conditions — not on the citizenship component, which carries no European rights. The position falls to be assessed on the law in force at the date of application, and no assumption should be made that the €250,000 category, or the programme itself, will remain available on current terms (§14.1, §14.2, §17.6).

### Notes

[^7-1]: Hellenic Republic, *Law 5038/2023 — Immigration Code* (Government Gazette A′ 81/01.04.2023), Article 100 (permit type «Β.5») and Article 179; consolidated text codified through Law 5307/2026, read via https://www.taxheaven.gr/law/5038/2023/article/100/view (accessed 2 August 2026), and cross-checked against the gazette facsimile (A′ 81/01.04.2023) at https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf (accessed 2 August 2026). No official consolidation of the Code was located for this report; the codification service is a secondary vehicle for the consolidated wording, and the gazette facsimile is the primary text for provisions unamended since 2023. Where the original gazette text has been amended, the consolidated text governs. 
[^7-2]: Hellenic Republic, *Law 5100/2024* (Government Gazette A′ 49/05.04.2024), Article 64, as codified with Law 5167/2024 (A′ 207/20.12.2024, including Article 37(1)); official consolidated PDF, Ministry of Migration and Asylum, https://migration.gov.gr/wp-content/uploads/2025/03/Νόμος-5100_2024-κωδικοποιημένος-με-τον-5167_2024-ΦΕΚ-Α-49_5.4.2024.pdf (accessed 2 August 2026). 
[^7-3]: Hellenic Republic, National Registry of Administrative Public Services (ΜΙΤΟΣ), *Permanent golden visa (change of use) – Initial issuance*, competent authority the Ministry of Migration and Asylum, last updated 31 July 2026, https://en.mitos.gov.gr/index.php/ΔΔ:Permanent_golden_visa_(change_of_use)_–_Initial_issuance (accessed 2 August 2026). 
[^7-4]: Hellenic Republic, *Joint Ministerial Decision 214926/2025* (Government Gazette B′ 6014/11.11.2025) — special supporting documents for Article 100 permits; gazette PDF via https://www.pomida.gr/assets/File/1236_20250206014.pdf, with concordant text reproductions at https://www.taxheaven.gr/circulars/51471/214926-10-11-2025 and https://www.retv.gr/2025/11/21492626-golden-visa.html (all accessed 2 August 2026). 
[^7-5]: Circular 1/2026 of the Secretary General for Migration Policy, 21 April 2026 — contents reported via Sioufas & Associates, https://www.sioufaslaw.gr/golden-visa-διευκρινίσεις-εφαρμογής-του-άρθρ-100/, and IMI Daily, https://www.imidaily.com/europe/greece-cracks-down-on-golden-visa-fraud-in-sprawling-new-circular/ (both accessed 2 August 2026). The circular text itself was not opened for this report; its contents are stated as reported. 
[^7-6]: Hellenic Republic, *Law 5038/2023*, Articles 8, 10(8), 10(11), 11(1), 14, 16(2), 17(1), 19 and 20; consolidated text codified through Law 5307/2026 (article views at https://www.taxheaven.gr/law/5038/2023), cross-checked against the gazette facsimile (A′ 81/01.04.2023) at https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf (both accessed 2 August 2026; Article 16 accessed 4 August 2026). Articles 8, 10, 14, 16, 19 and 20 are cited from the gazette text and match the consolidation. Article 16(2) provides for an application for reconsideration (αίτηση θεραπείας) to the issuing authority, not examined if lodged more than two months after service of the decision, accompanied by a €50 fee and decided within an exclusive period of 30 days; Article 16(1) excludes a legality appeal and Article 16(3) leaves annulment to the administrative court (Gazette A′ 81, p. 4132). Articles 11(1) and 17(1) are cited in their amended, consolidated versions, which differ from the 2023 gazette text; the amending instruments were not identified in the sources read for this report, and both rules are stated in the text as requiring confirmation. 
[^7-7]: Hellenic Republic, *Law 5038/2023*, Articles 95(2) and 171; consolidated text, https://www.taxheaven.gr/law/5038/2023/article/95/view and https://www.taxheaven.gr/law/5038/2023/article/171/view (accessed 2 August 2026). 
[^7-8]: Hellenic Republic, *Joint Ministerial Decision οικ. 53821/2014* (21 October 2014, issued under Article 136(3) of Law 4251/2014) — minimum private-insurance coverages for residence-permit purposes; signed text hosted by the Ministry of Migration and Asylum, https://migration.gov.gr/wp-content/uploads/2020/05/ΚΥΑ53821_2014.pdf (accessed 2 August 2026). The decision's formal survival under Law 5038/2023 is unconfirmed; its amounts remain applied in practice and are stated subject to confirmation at the date of application. 
[^7-9]: Hellenic Republic, Ministry of Migration and Asylum, monthly bulletin *Νόμιμη Μετανάστευση — Μάρτιος 2026*, Annex B (ΠΑΡΑΡΤΗΜΑ Β), golden-visa Tables 12α–17, https://migration.gov.gr/wp-content/uploads/2026/04/ΠΑΡΑΡΤΗΜΑ-Β_Μάρτιος_2026_ΥΜΑ-GR-Ενημερωτικό-Μάρτιος-Β-Νόμιμη-Μετανάστευση.pdf (accessed 2 August 2026). 
[^7-10]: *Convention Implementing the Schengen Agreement*, Article 21(1), as replaced by Regulation (EU) No 265/2010, Article 1(2), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265 (accessed 2 August 2026). 
[^7-11]: Regulation (EU) No 610/2013 of 26 June 2013 (substituting "90 days in any 180-day period" throughout the Schengen acquis), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013R0610 (accessed 2 August 2026). 
[^7-12]: Regulation (EU) 2016/399 (Schengen Borders Code), Articles 2(16) and 6, consolidated version of 12 October 2025, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02016R0399-20251012 (accessed 2 August 2026). 
[^7-13]: Regulation (EC) No 1030/2002 (uniform format for residence permits), Articles 1 and 4a, consolidated version of 21 November 2017, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02002R1030-20171121; and Regulation (EU) 2017/1954, Annex (prescribed card entries, including entry 8, "Nationality"), https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R1954 (both accessed 2 August 2026). 
[^7-14]: Belgian Immigration Office (IBZ), *Visa-free travel with residence permits — general principles* (national administrative guidance), https://dofi.ibz.be/en/themes/entry/border-control/visa-free-residence-permits/general-principles (accessed 2 August 2026). 
[^7-15]: European Commission, *Practical Handbook for Border Guards* (2022 edition), Second Part, Section I, points 3.6–3.7, https://home-affairs.ec.europa.eu/system/files/2022-11/Practical%20handbook%20for%20border%20guards_en.pdf (accessed 2 August 2026). 
[^7-16]: Hellenic Republic, National Registry of Administrative Public Services (ΜΙΤΟΣ), *Πολιτογράφηση Αλλογενών Αλλοδαπών* (naturalisation of aliens), legal basis the Code of Greek Citizenship (Law 3284/2004, as amended), last updated 30 July 2026, https://mitos.gov.gr/index.php/ΔΔ:Πολιτογράφηση_Αλλογενών_Αλλοδαπών (accessed 2 August 2026). 
[^7-17]: Council Directive 2003/109/EC of 25 November 2003 concerning the status of third-country nationals who are long-term residents, Articles 4(1) and 5, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32003L0109 (accessed 2 August 2026). 
[^7-18]: Hellenic Republic, *Law 5007/2022* (Government Gazette A′ 241/23.12.2022), Article 91 (threshold) and Article 92 (transitional provision); consolidated text of Article 92, which fixes completion of the investment, including on any substitute property, at 30 April 2024, read at https://www.taxheaven.gr/law/5007/2022/article/92/view (accessed 4 August 2026). The extension of the deposit deadline to 31 July 2023 is primary legislation and not circular guidance: *Law 5038/2023*, Article 177(11) (Government Gazette A′ 81/01.04.2023, p. 4214) — «Η προθεσμία πληρωμής προκαταβολής του άρθρου 92 του ν. 5007/2022 (Α' 241) παρατείνεται έως την 31η Ιουλίου 2023» — gazette facsimile at https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf (accessed 4 August 2026). Gazette A′ 241/2022 itself was not opened for this report; the Article 91/92 allocation and the scope of Article 91's designated areas rest on the Hellenic Bank Association's summary, https://www.hba.gr/News/Details/2285 (accessed 2 August 2026), and require confirmation against that gazette. 
[^7-19]: Greek Notarial Coordinating Circular 13/11.04.2024 (Law 5100/2024 amendments; €50,000 fine; 2024 transitional dates), https://enotariat.gr/?p=14285 (accessed 2 August 2026). 
[^7-20]: European Commission, *Recommendation C(2022) 2028 final* of 28 March 2022 on immediate steps in the context of the Russian invasion of Ukraine in relation to investor citizenship schemes and investor residence schemes, points 1–2 (citizenship schemes; residence-scheme checks) and points 3–5 (assessment of withdrawal of naturalisations; immediate withdrawal and non-renewal of investor-residence permits of sanctioned or war-supporting Russian and Belarusian nationals; suspension of issuance to Russian and Belarusian nationals), read via https://investmentmigration.org/wp-content/uploads/2022/07/recommendation-limit-access-individuals-connected-Russian-Belarusian-government-citizenship-residence-EU-through-investor-schemes_en.pdf (accessed 2 August 2026). 
[^7-21]: Court of Justice of the European Union (Grand Chamber), judgment of 29 April 2025, *Commission v Malta*, Case C-181/23, EU:C:2025:283, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0181 (accessed 2 August 2026). 
[^7-22]: European Commission, press release IP/20/1925 of 20 October 2020, https://ec.europa.eu/commission/presscorner/api/files/document/print/en/ip_20_1925/IP_20_1925_EN.pdf (accessed 2 August 2026). 
[^7-23]: European Parliament, resolution of 9 March 2022 with proposals to the Commission on citizenship and residence by investment schemes (2021/2026(INL)), OJ C 347, 9.9.2022, p. 97, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022IP0065 (accessed 2 August 2026). 
[^7-24]: European Commission, *Investor citizenship schemes* policy page, reviewed for initiatives concerning investor residence schemes, https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/democracy-eu-citizenship-anti-corruption/eu-citizenship/investor-citizenship-schemes_en (accessed 2 August 2026 — a dated statement of absence). 
[^7-25]: Regulation (EU) 2024/1624 of 31 May 2024 (Anti-Money-Laundering Regulation), Articles 3(3)(l) and 41 and Annex III point (g); OJ L, 19.6.2024; applies from 10 July 2027; https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401624 (accessed 2 August 2026). 
[^7-26]: Professional and press reporting on the closure of Spain's investor residence programme (3 April 2025; approximately 94% of permits reported property-linked) and Portugal's 2023 removal of real estate from its programme, via globalcitizensolutions.com and spainexpat.com (accessed 2 August 2026) — reported tier, context only. 
[^7-27]: Hellenic Republic, *Law 5275/2026* (Government Gazette A′ 17/06.02.2026) — gazette listing via https://www.kodiko.gr/nomothesia/document/1279125/nomos-5275-2026; reported contents via IMI Daily, https://www.imidaily.com/program-updates/greece-to-propose-golden-visa-changes-addressing-backdated-permits/ (both accessed 2 August 2026). The gazette text was not read for this report; contents are stated as reported and require confirmation. 
[^7-28]: Regulation (EU) 2018/1806 (the EU visa lists), Annexes I and II, consolidated version of 30 December 2025, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). 
[^7-29]: Watson Farley & Williams, *Understanding the new Golden Visa Law No. 5100/2024 — key points and implications* (professional commentary; once-only use of the €250,000 threshold per property), https://www.wfw.com/articles/understanding-the-new-golden-visa-law-νο-5100-2024-key-points-and-implications/ (accessed 2 August 2026). 
[^7-30]: GTP Headlines, *Greece freezes Golden Visa program for Russian citizens* (reporting the Ministry of Migration and Asylum announcement of 28 February 2022), https://news.gtp.gr/2022/02/28/greece-freezes-golden-visa-program-for-russian-citizens/ (accessed 2 August 2026). No official Ministry publication of the order was located for this report; the announcement is cited from a trade outlet and the 2022 measure is stated as reported. The position as at 2 August 2026 is unverified and requires confirmation at the date of application. 
[^7-31]: Greek residential-lease minimum duration — Article 2 of Law 1703/1987, as amended by Article 1(5) of Law 2235/1994 (three-year minimum term for primary-residence leases; early termination by notarial deed no earlier than six months after commencement), stated uniformly across professional sources including Iason Skouzos TaxLaw, *The duration and termination of a lease contract*, https://www.taxlaw.gr/en/practice-areas/real-estate/the-duration-and-termination-of-a-lease-contract/ (accessed 2 August 2026). The gazette text has not been read for this report; the rule requires confirmation with Greek counsel. 
[^7-32]: Decision No 565/2014/EU, Articles 1, 2(1)(c) and 5 (unilateral recognition by Cyprus of residence permits issued by Schengen member states), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014D0565; application and the Turkey/Azerbaijan exception per the High Commission of the Republic of Cyprus in the United Kingdom, *Visa Information*, https://cyprusinuk.com/visa-information/ (both accessed 2 August 2026). 
[^7-33]: Hellenic Republic, *Law 3852/2010* ("Kallikratis" — new architecture of local government and decentralised administration, Government Gazette A′ 87/07.06.2010), Article 3, the constitutive instrument for the regions and their regional units, including the Regional Units of Mykonos and Thira of the Region of South Aegean; gazette listing at https://www.kodiko.gr/nomothesia/document/108066/nomos-3852-2010 (accessed 4 August 2026). The text of Article 3 was not opened for this report. The load-bearing point at §7.3 — that Article 100(2)(a) fixes the €800,000 zone by regional unit and not by island — rests on the consolidated statutory text itself (notes 7-1 and 7-2), which reads «τις Περιφερειακές Ενότητες Μυκόνου και Θήρας της Περιφέρειας Νοτίου Αιγαίου». The stated composition of the Regional Unit of Thira (the municipalities of Thira, Ios, Folegandros, Sikinos and Anafi) rests on secondary administrative sources and requires confirmation against Article 3 before any acquisition on an island of that unit is priced against a threshold.
