# 17. Implementation Process This chapter sets out the reference structure's implementation as a sequence of working steps: what happens at each step, who acts, which documents are in play, what is known about duration, and what can stall progress. The legal content of each component is treated in Chapters 6 to 9; the sequencing logic itself is summarised at §5.9 and the risks created by ordering (above all, that the €250,000 property is paid in full before any residence decision exists) are analysed at §14.17. Durations below are labelled: a figure is either a verified official standard or statutory time limit, or a reported practice figure that cannot be verified and must be treated as indicative. No duration in this chapter is a commitment, and no step's outcome is guaranteed: citizenship, residence, banking and tax decisions rest with the respective governments and institutions alone (see §18.9). ## 17.1 Initial strategy assessment Implementation begins with a structured assessment of the client's position: nationalities held by each family member, countries of residence and tax residence, the objectives sought, the funding available and its origin, and the time horizon. The client provides the facts; Kestrel Private conducts the assessment as coordination work, not as legal or tax advice (see §18.1). Kestrel Private's professional engagement is charged as a fixed professional engagement fee agreed in writing before work begins, published on kestrelprivate.com/fees.[^17-1] No documents are filed at this stage and no government is engaged. The step has no fixed duration; nothing later in this chapter should begin until it is complete. It stalls, properly, where the facts are incomplete: an undisclosed nationality, an unresolved residence history or an unclear funding source is far more expensive discovered later than established here. ## 17.2 Rights and objectives mapping The second step maps each of the client's objectives to the single legal instrument that would provide it, and identifies the objectives the structure cannot meet. Chapter 4 carries the full mapping, consolidated at §19.1 and Appendix A; at implementation level the discipline matters because it fixes which workstreams are actually required. Short-stay Schengen mobility requires the Greek permit: that mobility arises from Article 21 of the Convention Implementing the Schengen Agreement and attaches to the permit, never to the São Tomé and Príncipe passport.[^17-2] An additional nationality requires the citizenship component, assessed against home-country nationality law (§13.2). Objectives the structure does not provide (EU citizenship, unrestricted EU employment, and banking or tax outcomes, which cannot be guaranteed) should be identified at this step, before any cost is incurred (§1.7, §13.14). ## 17.3 Suitability decision Before any engagement of professionals or governments, Kestrel Private must reach a documented suitability view under the criteria of Chapter 13, including the decline criteria at §13.14: whether each component provides a meaningful benefit to this client, whether the client can bear the property, liquidity and programme risks of Chapter 14, and whether source of funds is likely to withstand scrutiny. Where the answer is negative, the correct output of the process is a recommendation not to proceed, or to proceed with fewer components (§13.12, §13.13). The decision is Kestrel Private's to recommend and the client's to make; it binds no government. ## 17.4 Source-of-funds pre-clearance The source-of-wealth and source-of-funds file is assembled before anything is filed anywhere, because every later gate consumes the same file: the São Tomé application requires a declaration of the lawful origin of funds with supporting bank documentation and a due-diligence report from an entity recognised by the responsible unit;[^17-3] the Greek acquisition passes through lawyers, a notary and a credit institution which are themselves obliged entities under Greek anti-money-laundering law with a statutory duty to refuse where due diligence cannot be completed;[^17-4] and any bank considers the same evidence again. The standards, evidence classes and common inconsistencies are Chapter 15's subject (Appendix F is the checklist); the FATF and OECD's joint report describes the multi-layered, independently repeated screening the client should expect.[^17-5] The client produces the records; Kestrel Private coordinates assembly and consistency-checking; regulated advisers opine where needed. Duration depends entirely on the state of the client's records: from weeks where a business owner's affairs are already audited to substantially longer where historical documentation must be reconstructed (a general observation, not a verified figure). The step stalls on the deferral triggers of §15.14; an application that would fail here should be deferred, not filed and refused. ## 17.5 Family eligibility confirmation Each family member is tested against the two programmes' distinct family rules before costs are committed (Chapter 16 sets out the rules and evidence in full; Appendix G is the checklist). - **Greece.** The family circle is fixed by Article 95(2) of Law 5038/2023: the spouse or cohabitation-agreement partner, unmarried children under 21, the direct ascendants of the spouses or partners, and adult children lacking legal capacity who live with and are maintained by the sponsor, the incapacity being proved by a final court judgment or an equivalent legalised document of the country of origin or habitual residence (Article 95(2)(ε)); family permits expire simultaneously with the sponsor's, and a child reaching 21 receives a three-year independent permit.[^17-6] - **São Tomé and Príncipe.** The gazetted decree defines dependants as the spouse and/or children of the principal applicant by reference to the Nationality Law: minor children, and the spouse only via Article 6 of that Law, which requires cumulatively a marriage of more than five years and the regime of community of acquired property (*comunhão de bens adquiridos*), or a court-recognised de facto union of more than three years.[^17-3] The programme channel publishes broader categories (a de facto partner, children up to 30, parents and grandparents aged 55 and above) for which no statutory basis is visible in either gazetted text; inclusion of such dependants rests on administrative practice and requires confirmation at the date of application.[^17-7] Passport issuance to adult dependent children was reported placed on hold by the unit's memorandum of 10 April 2026, pending a revised dependency framework; no lifting of the hold had been located as at 2 August 2026.[^17-8] - **Nationality caps.** São Toméan law bars a grant to a person already holding more than two foreign nationalities, and a naturalised citizen who later acquires a fourth nationality immediately loses São Toméan nationality; from April 2026 the unit is reported to have placed applications from persons holding three or more foreign nationalities on hold.[^17-9] Each family member's own nationality-law position (§13.2) is confirmed here. Documents in play: birth, marriage and dependency evidence, police clearances, consent and custody documentation, translations and legalisation (§16.7–§16.10). The step stalls on documentary gaps (a missing custody order, an unobtainable clearance from a former country of residence) and on the São Toméan dependant-definition uncertainty above, which must be resolved by an applicant-specific legal explanation before a family application is priced or filed. ## 17.6 Property selection Property selection is the client's decision, taken with the client's own advisers against Chapter 8's investment tests; Kestrel Private coordinates the process but the property must pass the property-without-immigration test (§8.15) on its own merits. The immigration gates for the reference category are, in outline: full ownership and possession of one property with a minimum acquisition value of €250,000 — and, on undivided co-ownership, a residence right only where the co-owners are spouses or partners under a cohabitation agreement, or where each co-owner's share is itself worth at least €250,000, so that two co-buyers who are not spouses or cohabitation partners need €250,000 each (Article 100(1)(b); §7.6);[^17-6][^17-11] conversion of the principal spaces to residential use completed, per the official administrative record, after 5 April 2024 and before the residence application is submitted;[^17-10] for industrial buildings, engineer-certified non-operation for at least five years;[^17-11] and the notarial deed's statutory duty to state whether the property has previously been used for a permit.[^17-6] The €250,000 threshold is reported to operate once only per property, the April 2026 administrative guidance being read as corroborating that a property already used for a permit cannot be redeployed at €250,000 by another investor; the once-only effect as such is not established in the statutory text, which imposes the disclosure duty and no more. Whether a resold conversion property (converted by an earlier owner and never itself used for a permit) can support a new €250,000 application is an administrative-practice question on which no rule has been located; it requires confirmation at the date of application and bears directly on the resale buyer pool assessed at §8.7. The same guidance excludes properties already residential on 5 April 2024 and paper-only conversions, and provides for revocation where arrangements reduce the effective investment below the statutory minimum.[^17-12] The step stalls where marketed stock fails these gates on inspection, and commercially where the asking price reflects the statutory floor rather than the district market (§8.3, §8.7). Selection should not conclude before §17.7 has begun on the shortlisted property. ## 17.7 Property legal and technical due diligence Two regulated professionals now work in parallel on the selected property; Appendix E consolidates the checklist. - **The lawyer** searches title and encumbrances: mortgages, prenotations, seizures, claims and pending litigation. Greek professional practice takes the title chain back at least 20 years, the period of extraordinary usucapion; the depth is practice, not a published statutory search rule.[^17-13] Which certificates exist depends on the property's cadastral status: in areas of full cadastral operation the search runs against the property's KAEK identifier; in legacy registry areas it runs through person-based indexes and books.[^17-13] By its announcement of 27 May 2026 the Hellenic Cadastre reported 99% of the country with cadastral data posted, and 71% in full cadastral operation as at April 2026, so either branch may apply to a 2026–27 purchase.[^17-14] - **The engineer** produces two distinct documents: the building-legality certificate that no unauthorised constructions or uses exist, required with the owner's declaration on every transfer deed,[^17-15] and the change-of-use technical report in the prescribed form naming the qualifying planning acts, which certifies the conversion and its post-5 April 2024 completion by the issue date of the relevant planning act.[^17-16] For industrial buildings the report must additionally establish five-year non-operation through power-disconnection or tax evidence.[^17-16] The Electronic Building Identity (reported mandatory for transfers since 1 April 2022, the activating instrument not pinned, so the date and the current scope require confirmation at the date of application) and the energy performance certificate complete the technical file.[^17-17][^17-18] Client role: instruct and pay; Kestrel Private: coordinate scope and completeness; professionals: report in writing. No published tariff market exists for technical due diligence: written quotations are required (§10.8). Duration is property-specific and unverified as a market figure. The step stalls on planning defects, unregularised works, registry backlogs and, decisively, on any indication that the conversion is paper-only rather than an actual completed change of a building's use.[^17-12] A property that fails here is replaced, not excused. ## 17.8 Tax and structural assessment Before contracts are signed, the holding structure and the tax consequences of each later step are assessed by regulated tax advisers in each relevant jurisdiction (Chapter 9 sets out the substance). Three implementation-level decisions are taken here. First, the holding form: the Greek route admits acquisition through a legal person only where the applicant holds 100% of it, evidenced at filing. Personal ownership is the reference case.[^17-19] Second, the acquisition-tax position of the specific property (transfer tax at 3.09% or, exceptionally, VAT), which is property-specific and confirmed by the lawyer and notary before signing (§8.6, §10.6). Third, the home-country interaction: the structure changes no home-country tax position by itself (§9.12), and death-tax exposure in both jurisdictions is reviewed with the client's estate planning (§6.10, §9.12). Where the client contemplates genuine relocation, the elective Greek regimes are scoped now — but implemented only at §17.14. This step also fixes the funds-flow plan: which accounts remit, in whose name, and with what currency-conversion arrangements (§10.9, §14.13). ## 17.9 Engagement of local regulated professionals The professional bench is engaged before any filing: Greek immigration counsel, the property lawyer, the notary (a public official in the Greek system), the engineer, an accountant or tax representative, and, on the citizenship side, the programme's designated application channel. São Toméan law requires promotion of the citizenship programme to be licensed, with unlicensed promotion punishable by a fine of up to US$500,000, and the programme's official channel states that applications must be initiated through a licensed agent.[^17-3][^17-20] Chapter 18 defines each role and its boundary; the operative point here is that every regulated act — conveyancing, filing, certification, tax advice — is performed by the locally admitted professional, with Kestrel Private coordinating scope, sequence and completeness (§18.1). Documents in play: engagement letters and written fee quotations (which feed the cost model of Chapter 10), and powers of attorney — for Greece, drawn before a Greek consular authority or a foreign notary and apostilled or consular-legalised, since the entire Greek acquisition and filing can be executed by proxy.[^17-21] The step stalls on document legalisation logistics and on conflicts checks; it should not be compressed, because a defective power of attorney invalidates steps taken under it. ## 17.10 Property reservation and acquisition The acquisition sequence in Greece is: tax number, funds, deed, registration. - **Tax number (AFM).** A Greek tax number is a practical precondition of purchase: it is required for the electronic tax declaration, the notarial deed and every later filing. It is issued to non-residents without any residence requirement, electronically, with identification in person or by video call; in practice a tax representative is designated alongside.[^17-22] - **Reservation.** Both recent threshold transitions were drafted around a 10% deposit or a pre-agreement, which reflects the standard Greek conveyancing sequence.[^17-23] Private reservation agreements are not themselves regulated by the permit legislation and no reservation step is mandatory: no reservation payment should be made before the due diligence of §17.7 is complete, and any reservation instrument should be reviewed by the lawyer first. - **Payment.** The full price must be paid before the residence application, and only through the statutory channels: a crossed bank cheque to the seller's account at a credit institution operating in Greece, a credit transfer as defined in Greek payment-services law, or a card payment through a payment provider operating in Greece. Payment may also be made by the buyer's spouse or relatives by blood or marriage up to the second degree. All payment details are recorded in the notarial deed.[^17-6] Cash has no place anywhere in the sequence, and the price must be fully stated: arrangements that reduce the effective investment below the statutory minimum attract revocation, and under-declaration is precisely the abuse pattern Greek authorities police.[^17-12] For a non-resident buyer, remitting the purchase funds through the banking system from foreign accounts in the buyer's own name also documents the acquisition against Greek deemed-income rules.[^17-24][^17-25] - **Deed and registration.** The transfer-tax declaration is made electronically through the tax administration's application, for which the buyer's tax number is required; the sequence of declaration, payment and execution for the individual transaction is set by the notary and is confirmed with the notary before the appointment.[^17-22] The notary certifies the parties, the property, the consideration, the payment method and full payment, and whether the property has previously been used for a permit.[^17-6] The deed is then registered at the land registry or cadastre; for the residence filing, an attestation that registration has been applied for (or a lawyer's certificate) suffices at initial issuance, with the definitive registration certificate submitted at renewal.[^17-19] Who acts: client (or attorney under power of attorney), lawyer, notary, seller, banks; government acts only as tax authority and registry. Duration: no official standard exists for a private conveyance; the calendar is driven by due diligence, funds transfer and registry practice (unverified as a market figure). Stall points: objective-value complications in the tax declaration, the seller's own certificates (energy, engineer, tax clearances), registry backlog, and funds arriving by a non-qualifying route — a payment outside the statutory channels cannot support the permit. The structural point for §14.17 stands at the end of this step: the client now owns the property, in full, before any residence decision exists. ## 17.11 Residence application The Greek filing is digital-only, through the immigration portal, and may be made by a proxy holding an apostilled or consular-legalised power of attorney before the applicant has ever entered Greece.[^17-21] The stages are: 1. **Filing.** The file comprises, for the change-of-use category: passport (with entry evidence where the applicant has entered; not required for the proxy route), the notarial certificate covering parties, property, price, payment method and full payment and prior permit use, registration proof or the attestation/lawyer's certificate, 100%-ownership evidence where an entity is used, the engineer's technical report, a private insurance policy, the E9 property-declaration copy, and the electronic fee — €2,000 for the main applicant plus €16 for the card (€150 per family permit; minors exempt from the permit fee; €150 for a child's three-year independent permit at 21, the €450 rate in Article 171 §1(β) being reserved to permits granted under the first sentence of Article 90 §5; see §7.9).[^17-19][^17-6] 2. **Certificate of submission.** On a complete filing the applicant receives the certificate of submission (the "blue receipt"), valid until the decision; it certifies lawful residence and its holder temporarily enjoys the rights flowing from the requested permit. Whether it supports short-stay circulation in other Schengen states is not documented in any official source located, in either direction; travel planning should assume that Schengen mobility begins with the card, not the receipt.[^17-6] 3. **Biometrics — the one compulsory visit.** On the proxy route the applicant (and each family member) must enter Greece within an exclusive 12-month period from filing and submit biometric data (both index fingerprints to passport specifications, collected only in Greece) together with the outstanding insurance document. Attendance is by summons; after two failures to appear the application is rejected.[^17-21] Entry for the visit uses whatever visa or visa-waiver route the traveller's own passport requires; an optional national D-visa entry route carries a €180 consular fee.[^17-19] 4. **Decision.** The official record's completion standard is 50 days, against a statutory limit of two months under Article 100(10), both running from file completion; on the proxy route the file completes only when biometrics are given, so the applicant controls the critical path and neither figure may be read as an end-to-end time.[^17-10][^17-11] The official counterweight is the Ministry's own caseload data: as at March 2026, 10,032 investor applications were pending, including 3,399 filed in 2024 — verified official evidence of multi-year effective processing at the tail.[^17-26] No reliable end-to-end figure can therefore be stated; practice reports circulate but are unverifiable. A refusal is subject to administrative appeal within two months (fee €50, decided within 30 days).[^17-10] 5. **Card collection.** The card may be collected by proxy: for the investor categories a certified copy of the passport is accepted, so no second visit is required for collection.[^17-6] Who acts: applicant and family (biometrics), Greek counsel (filing and follow-up), the Ministry of Migration and Asylum (decision). Stall points: incomplete technical or notarial documents, insurance policies that do not meet the applied minimums (§17.17), summons logistics for large families, and the caseload tail. Health insurance must satisfy the statutory full-sickness-insurance condition; the coverage minimums applied in practice were fixed under the predecessor Code and their formal survival requires confirmation at the date of application.[^17-27] ## 17.12 Citizenship application The São Tomé and Príncipe application runs in parallel, through the programme's designated application channel, and its stages are fixed by the decree:[^17-3] 1. **Preparation and submission.** The application is submitted electronically via the responsible unit's platform, on the official form in Portuguese or English, with the Annex III documents: certified passport copies, criminal-record certificates (issued within the last three months) from countries of nationality and of residence of the last five years, proof of residence, a medical certificate, the declaration of lawful origin of funds with supporting bank documentation, certified translations, apostilled or consular-authenticated foreign documents, proof of payment of the US$5,000 due-diligence and processing fee (non-refundable after submission), and a due-diligence report issued by a recognised entity. 2. **Admission and preliminary appreciation.** The unit admits only complete files and makes a preliminary appreciation within 15 days, with power to request additional elements (a statutory time limit). 3. **Due diligence and review.** Independent qualified external entities engaged by the unit perform due diligence; interviews may be required in person or by video. A consultative Review Committee chaired by a Public Prosecutor's representative (with members from the migration service, finance ministry, registries and the Financial Intelligence Unit) verifies anti-money-laundering compliance, and the file may be precautionarily suspended on serious concerns. 4. **Public Prosecutor consideration.** The completed file goes to the Ministério Público for a prior visto, given within 30 days under the Nationality Law; if the visto is refused, the process lapses.[^17-3][^17-28] 5. **Decision.** After the visto (or Public Prosecutor silence), the unit's Director decides within 15 days with legal reasoning. The Nationality Law separately provides for grant by Government decree on the Justice Minister's favourable opinion; the articulation between the two acts is not spelt out in either text and requires an applicant-specific legal explanation — no reading should be assumed.[^17-3][^17-28] 6. **Contribution deposit.** Delivery of the approval certificate is conditional on deposit of the contribution (US$90,000 single applicant; US$95,000 family of two to four; US$5,000 per additional qualifying dependant) into the National Transformation Fund's dedicated bank account within 90 days, failing which the process lapses. The contribution is non-refundable; the decree contains no express refund clause for any post-deposit scenario (§6.7, §14.15). 7. **Oath and registration.** After deposit, the applicant swears the oath of fidelity before a public official in São Tomé and Príncipe or, where abroad, before the competent diplomatic or consular agent — the decree imposes no travel or residence requirement. The file then passes to the central registry for transcription, from which the citizenship documents follow (§17.15). Two post-decision features must be diarised from the outset: the Public Prosecutor may institute judicial opposition before the administrative court within six months of the declaration of acquisition (without suspensive effect), and the decree's sanctions extend to revocation of nationality (§6.8).[^17-3] On timing: the statutory time limits above are verified; the programme channel publishes approximately 1.5–3 months to decision and about three months from approval to passport, and industry reporting of programme-supplied data put average processing at 2.5 months in the first cohort — published and reported figures respectively, not independently audited, and the programme's short operating history means they carry limited predictive weight (§6.12).[^17-20][^17-29] "Approval in principle" is the channel's vocabulary; the decree's own sequence is admission, visto, decision, deposit, oath. ## 17.13 Banking application Banking starts early, in parallel with §17.6, and its outcome is never assumed. Under Greek anti-money-laundering law an institution that cannot fully complete customer due diligence must not establish the relationship; nothing obliges any bank to accept a customer, and account opening is a risk-based commercial decision.[^17-4] From 10 July 2027 the directly applicable EU Anti-Money-Laundering Regulation carries the same refusal obligation and expressly requires collection of all nationalities held.[^17-30] The EU right to a basic payment account attaches to consumers legally resident in the Union — it is not available to the non-resident applicant, though a client who later holds the Greek permit is legally resident in a member state and may engage that right subject to its conditions.[^17-31] Remote onboarding by video identification exists in Greek regulation, but whether a given bank offers it to a non-resident third-country national is that bank's own decision (reported).[^17-32] Practical sequence: the statutory purchase-payment channels may be satisfied by credit transfer from the client's existing foreign accounts, so a Greek account is not a statutory precondition of the acquisition; the payment route must be confirmed with the notary before funds move.[^17-6] A Greek personal account is nonetheless commonly needed for utilities, insurance premiums, tax payments and, where the property is let, receipt of rent into an account declared to the tax administration (§17.17). Documents in play: passport(s), tax number, address and activity evidence, and the source-of-funds file of §17.4; the client should expect to disclose all nationalities and, where a citizenship-by-investment document is presented, to be asked for original-identity documents — international standard-setters recommend exactly that, and a Greek account will in any event be reported under the Common Reporting Standard to the client's jurisdiction(s) of tax residence.[^17-5][^17-33] Duration: no official standard exists; weeks to months should be planned for, without commitment (a planning observation, not a verified figure). Appendix H carries the checklist; §9.4–§9.5 the analysis. ## 17.14 Tax-residence implementation This step exists only where the client contemplates genuine relocation to Greece and separately qualifies; for the reference client (a non-resident holding the permit without relocation) there is nothing to implement, and the default position is no Greek tax residence (§9.6). Where relocation is real, implementation is carried by Greek tax counsel: establishing residence under the ordinary tests, and, where elected, applying for one of the three elective regimes by the statutory deadline — for the investor regime, an application by 31 March of the tax year, non-Greek tax residence in seven of the eight preceding years, and a €500,000 qualifying investment completed within three years with proof of transfer into a Greek bank account. Two implementation traps follow from the statutory text: the €250,000 reference property is half the investor-regime investment threshold, and the regime's investment-condition waiver attaches to a different permit category — the investment-activity permit under Article 16 of Law 4251/2014 — not to the property permit used in this structure.[^17-34] The amounts and conditions in this area are amended from time to time and require confirmation at the date of application; relocation also changes the client's deemed-income, filing and home-country positions (§9.7, §9.12, §14.10). ## 17.15 Approval and document issuance **Greece.** The decision issues the five-year permit as a stand-alone electronic card; collection may be by proxy against a certified passport copy (§17.11). A 2026 law is reported to run the five-year card validity from issuance rather than the application date; the gazette text had not been read at the date of this report and the point requires confirmation — it matters to the renewal diary of §17.17.[^17-35] The card is the document that carries the Schengen mobility of §7.10; the position of the certificate of submission is undocumented in either direction (§17.11). **São Tomé and Príncipe.** After the oath and registration, the citizenship documents issue: the certificate of registration, national identity card and passport. The programme channel publishes an aggregate charge of US$750 per applicant for the three documents (the gazetted fee schedule contains no document fees, so the amount requires confirmation at the date of application) and states that the passport currently follows approval by about three months.[^17-29][^17-20] Passports are issued by the migration and frontiers service, which publishes electronic-passport infrastructure.[^17-36] Identity-card issuance is a separate authority's function: from 9 April 2026 it is reported possible remotely by video verification with the civil registry and notary office, enrolment having previously been in person in São Tomé, Lisbon or Brussels.[^17-8] The passport's validity period is not published in any official source located and must be confirmed at the date of application. The six-month judicial-opposition window of §17.12 runs from the declaration of acquisition of nationality — that is, from registration, not from the issue of the passport, so it is already running by the time the documents arrive; approval is not the end of legal exposure (§14.15). ## 17.16 Post-approval compliance The position now created is maintained, not merely held. On the Greek side, the standing conditions are: the property remains in the holder's full ownership and possession (sale revokes the permit, subject to §7.12); no short-term letting or sub-letting, on pain of revocation and a €50,000 fine; and, for the change-of-use category, the principal spaces remain residential and the property is not used as a company seat or branch.[^17-6] The holder must declare to the migration registry, within two months, every change of personal status — expressly including change of nationality — and any loss, renewal or change of passport details (passport renewal is declarable at latest by the next permit renewal or reissue application); failure carries a €100 fine, €200 on repetition, and a reissued card carries a €100 fee. Card details are changed only downstream of the foreign authority's own documents.[^17-37] The first Greek tax obligations also land here: the E9 property declaration by 31 January of the year following the deed (the classic first compliance failure of foreign owners), annual property tax, and, where the property is let, lease declaration, an energy certificate for each new tenancy, rent received into a bank account declared to the tax administration, and income-tax filings (§17.17).[^17-38] On the São Toméan side, the standing constraints are the fourth-nationality rule — acquiring a fourth nationality causes immediate loss of São Toméan nationality by operation of law — and the loss grounds specific to naturalised citizens.[^17-28] At borders, the practical rule is to travel on the passport whose identity data match the permit: one member state's published guidance — the only such rule located, and not a Schengen-wide rule — requires a 100% match of five identity parameters, including nationality, between permit and travel document; no published rule establishes how Greece re-keys a permit to a newly acquired second nationality, which is a Greek-counsel question at the time it arises.[^17-39] ## 17.17 Renewal and monitoring calendar The structure's continuing obligations resolve into a calendar; the table below seeds Appendix J. | Obligation | Cycle or deadline | Action and documents | Consequence of default | |---|---|---|---| | Qualifying property retention | Standing, life of permit | Retain full ownership and possession; long-term letting only | Sale revokes the permit; short-term letting: revocation and €50,000 fine[^17-6] | | Greek permit renewal | Every five years; file within the two months before expiry. On the current consolidated text, late filing is possible up to three months after expiry at €100 per month of delay; the amending instrument has not been identified and the late-filing rule requires confirmation at the date of application[^17-6] | Proof property remains in ownership and possession; definitive registration certificate if deferred at first issuance; fresh insurance policy; €2,000 fee plus €16 card; E9 copy; solemn declarations (no short-term letting; spaces remain residential; no company seat)[^17-19] | Beyond the grace window, application barred absent proven force majeure[^17-6] | | Renewal biometrics | Expected at each five-year renewal — no express rule located; requires confirmation | Appearance in Greece for fingerprint capture for the new card | Unconfirmed; where re-capture is required, the initial procedure's sanction (rejection after two failures to appear on summons) is the applicable rule[^17-21] | | Private health insurance | Annual, per family member | Policy meeting the applied minimums (fixed under the predecessor Code, still applied in practice — requires confirmation); foreign policies only with an express Greece-cover clause[^17-27] | Residence condition unmet at renewal | | ENFIA (annual property tax) | Annual; 2026: lump sum by 31 March or 12 monthly instalments — dates restated each year | Assessment via the tax portal; payment remotely | Interest and enforcement; unpaid ENFIA blocks a future sale[^17-40] | | E9 property declaration | By 31 January of the year following any change | Update the property statement (acquisition, disposal, alteration) | Penalties; first-year omission is the commonest failure[^17-38] | | Greek income-tax return | Only where Greek-source income arises (e.g. rent); filing window 15 March–15 July of the following year | Return via accountant or tax representative | Penalties and interest on assessed Greek-source income[^17-24][^17-25] | | Letting events | On each new lease | Lease declaration to the tax administration; from 1 April 2026 rent into a landlord bank account declared to the tax administration (reported); energy certificate for the new tenancy; three-year minimum term on primary-residence leases (reported) | Loss of the 5% deemed-expense deduction (reported); unmarketable tenancy documents[^17-41][^17-18][^17-42] | | Passport renewal (any nationality held) | Declare at latest by the next permit renewal or reissue application | Declaration via the migration registry; permit reissue where needed (€100) | €100 fine, €200 on repetition; identity mismatch at borders[^17-37][^17-39] | | Change of nationality (including the São Tomé acquisition) | Declare within two months | Declaration via the migration registry; Greek-counsel advice on whether and how the permit is re-keyed (no published rule) | €100/€200 fine; unresolved permit–passport pairing[^17-37] | | São Tomé passport | Validity not officially published — requires confirmation at the date of application | Renewal through the issuing migration and frontiers service | Travel-document gap on the citizenship side[^17-36] | | São Tomé opposition window | Once: six months from the declaration of acquisition of nationality | Diarise opening and expiry; retain counsel availability | Opposition, if instituted and successful, can end in loss of nationality[^17-3] | | São Tomé nationality cap | Standing | No acquisition of a fourth nationality without accepting immediate loss of São Toméan nationality | Loss by operation of law[^17-28] | | Family permit expiry | Simultaneous with the sponsor's permit; child at 21 → three-year independent permit (€150 — §7.9) | Renew family permits with the sponsor's cycle | Family members' residence lapses with the sponsor's[^17-6] | Caption: The calendar assumes a single applicant (family rows as noted) holding the €250,000 change-of-use permit, with the property either long-let or held vacant, and no relocation to Greece. Greek tax dates reflect the 2026 filing calendar and are restated annually; all fees and dates require confirmation at the date of application. Sources: Law 5038/2023 (consolidated) Articles 11, 19–20, 95, 100 and 171; JMD 214926/2025; KYA οικ. 53821/2014 as applied in practice; published AADE calendars and reported letting rules; Decreto-Lei n.º 07/2025 and Lei n.º 7/2022; São Toméan migration-service publications. The calendar is also the chapter's closing argument for sequence: every row exists only because an earlier step was taken in the right order — funds cleared before filings, property proven before purchase, purchase completed before the residence application, and the citizenship stages run to the decree's own clock. Where the order is inverted, the failure modes of §14.17 stop being theoretical. ### Notes [^17-1]: Kestrel Private, "Fees", https://kestrelprivate.com/fees (accessed 4 August 2026). [^17-2]: Convention Implementing the Schengen Agreement, Article 21, 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). [^17-3]: Decreto-Lei n.º 07/2025 ("Regulamentação da Nacionalidade por Investimento ou Doação"), Diário da República of São Tomé and Príncipe, I Série, N.º 33, 1 August 2025, pp. 429–440 (Arts. 3.º, 4.º, 6.º, 8.º–14.º, 18.º, 22.º; Anexos I and III) — gazette facsimile, Portuguese original, via https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026). [^17-4]: Law 4557/2018 (Government Gazette A′ 139/30.07.2018), Articles 5 and 13 — consolidated Greek text via https://www.taxheaven.gr/law/4557/2018/article/13/view (accessed 2 August 2026); the refusal clause's paragraph number awaits gazette confirmation. [^17-5]: FATF/OECD, *Misuse of Citizenship and Residency by Investment Programmes*, FATF, Paris, November 2023, ¶¶139, 145, 156, 170, https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Misuse-CBI-RBI-Programmes.pdf (accessed 2 August 2026). [^17-6]: Law 5038/2023 (Immigration Code, Government Gazette A′ 81/01.04.2023), Articles 10 §8, 11 §1, 17 §1, 95 §2, 100 and 171 — consolidated Greek text (codified through Law 5307/2026) via https://www.taxheaven.gr/law/5038/2023 (article views; accessed 2 August 2026). The consolidated text governs Articles 11 §1 and 17 §1, which have been amended since the 2023 gazette; the amending instrument for Article 11 §1 has not been identified and the late-renewal rule stated from it requires confirmation at the date of application. [^17-7]: São Tomé and Príncipe Citizenship by Investment Unit, "Become a Citizen", cip.gov.st — archived capture of 17 July 2026, https://web.archive.org/web/20260717032201/https://cip.gov.st/become-a-citizen (accessed 2 August 2026). [^17-8]: IMI Daily, "São Tomé Introduces Remote Passport Issuance, Clarifies Three-Nationality Rule", 11 April 2026 (CIU Director's memorandum of 10 April 2026; remote identity-card verification with the Civil Registry and Notary Office from 9 April 2026; adult-dependant passport hold), https://www.imidaily.com/africa/sao-tome-introduces-remote-passport-issuance-clarifies-three-nationality-rule/ (accessed 2 August 2026); reported tier. [^17-9]: Lei n.º 7/2022 (Lei da Nacionalidade), Diário da República of São Tomé and Príncipe, I Série, N.º 25, 10 March 2022, Article 11.º — gazette facsimile, Portuguese original, via https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf (accessed 2 August 2026); the April 2026 administrative hold on applicants holding three or more foreign nationalities per IMI Daily, 11 April 2026 (note 17-8), reported tier. [^17-10]: National Registry of Administrative Public Services (mitos.gov.gr), "Permanent golden visa (change of use) – Initial issuance", 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). [^17-11]: Law 5100/2024, Article 64 (Government Gazette A′ 49/05.04.2024), as codified with Law 5167/2024 — official consolidated PDF, Greek original, via 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). [^17-12]: Circular 1/2026 of the Secretary General for Migration Policy, 21 April 2026 — content verified 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; reported tier. [^17-13]: Global Law Experts, "How to check property title, Greece" (20-year chain reflecting the extraordinary-usucapion period; cadastral and legacy-registry certificate sets), https://globallawexperts.com/how-to-check-property-title-greece/ (accessed 2 August 2026); reported tier — professional practice, not a published statutory search rule. [^17-14]: Hellenic Cadastre announcement of 27 May 2026 (99% cadastral data posted; 71% in full cadastral operation as at April 2026), via GTP Headlines, "Greek land registry reaches 99% national coverage", https://news.gtp.gr/2026/05/27/greek-land-registry-reaches-99-national-coverage/ (accessed 2 August 2026); reported tier. [^17-15]: Law 4495/2017, Article 83 (Government Gazette A′ 167/03.11.2017) — consolidated Greek text via https://www.taxheaven.gr/law/4495/2017/article/83/view (accessed 2 August 2026). [^17-16]: JMD 214926/2025 (Government Gazette B′ 6014/11.11.2025), Article 2 §§2.6–2.7 and section 3 — FEK text, Greek original, via https://www.pomida.gr/assets/File/1236_20250206014.pdf (accessed 2 August 2026). [^17-17]: proper.gr, Electronic Building Identity guide (dossier contents; Completeness Certificate), https://proper.gr/ilektroniki-taftotita-ktiriou-odigos/ (accessed 2 August 2026); reported tier — the 1 April 2022 mandatory date rests on extracts. [^17-18]: Law 4122/2013, Article 12 (energy performance certificate on sale and letting) — consolidated Greek text via https://www.taxheaven.gr/law/4122/2013/article/12/view (accessed 2 August 2026). [^17-19]: JMD 214926/2025 (Government Gazette B′ 6014/11.11.2025), Articles 1–3 (change-of-use document list §2.6; renewal document list §3; entry and D-visa provisions) — FEK text, Greek original, via https://www.pomida.gr/assets/File/1236_20250206014.pdf (accessed 2 August 2026). The JMD governs renewal documents only; the renewal window and late-filing rule are matters of Article 11 §1 of Law 5038/2023 (note 17-6). [^17-20]: São Tomé and Príncipe Citizenship by Investment Unit, cip.gov.st home page — archived capture of 10 July 2026, https://web.archive.org/web/20260710224801/https://cip.gov.st/ (accessed 2 August 2026); official-site content, reported tier. [^17-21]: Law 5038/2023, Articles 10 §11 and 14 §§6–8 (Government Gazette facsimile A′ 81/01.04.2023, cross-checked against the consolidated text), Greek original, via https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf (accessed 2 August 2026). [^17-22]: AADE, "Issuance of Tax Identification Number and Authentication Key and Appointment of tax representative" (non-residents; the tax number is required for the myProperty declaration and the notarial deed), https://www.aade.gr/en/greeks-abroad-non-residents/registration-tax-register/issuance-tax-identification-number-and-authentication-key-and-appointment (accessed 2 August 2026). [^17-23]: Law 5007/2022 (Government Gazette A′ 241/23.12.2022), Articles 91 (threshold) and 92 (transition: 10% deposit or pre-agreement; deposit deadline subsequently extended), via the Hellenic Bank Association note https://www.hba.gr/News/Details/2285 and LawNet (accessed 2 August 2026); and Law 5100/2024, Article 64 §4 (transition: 10% deposit or pre-agreement deadlines), as codified with Law 5167/2024 — source as note 17-11. [^17-24]: Law 4172/2013, Articles 30–34 and 67 (deemed-income rules; non-resident carve-outs; filing window) — consolidated Greek texts via https://www.taxheaven.gr/law/4172/2013/article/33/view and adjacent article views (accessed 2 August 2026); reported tier pending gazette confirmation. [^17-25]: AADE, "FAQs for Greeks abroad and Non-residents" (November 2025 edition), FAQs 16–17 and 28, https://www.aade.gr/sites/default/files/2025-11/FAQs_omogeneis_en_0.pdf (accessed 2 August 2026). [^17-26]: Ministry of Migration and Asylum, monthly bulletin "Νόμιμη Μετανάστευση — Μάρτιος 2026, 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); Greek original. [^17-27]: KYA οικ. 53821/2014 (21 October 2014, under Article 136 §3 of Law 4251/2014) — signed ministry-hosted text, Greek original, https://migration.gov.gr/wp-content/uploads/2020/05/ΚΥΑ53821_2014.pdf (accessed 2 August 2026); formal survival under Law 5038/2023 unresolved — amounts applied in practice, subject to confirmation. [^17-28]: Lei n.º 7/2022 (Lei da Nacionalidade), Articles 10.º–12.º, 15.º–16.º and 19.º–22.º — source as note 17-9. [^17-29]: São Tomé and Príncipe Citizenship by Investment Unit, "Financial Layout" (US$750 per-applicant documents charge), official programme site on the government domain, https://cip.gov.st/donation-to-the-national-transformation-fund (accessed 4 August 2026); official-site content, reported tier. [^17-30]: Regulation (EU) 2024/1624 (AMLR), Articles 21(1), 22(1)(a) and 90, OJ L, 19.6.2024, https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401624 (accessed 2 August 2026). [^17-31]: Directive 2014/92/EU (Payment Accounts Directive), Article 16(2) with Article 2(2), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0092 (accessed 2 August 2026). [^17-32]: Bank of Greece, Executive Committee Act 172/1/29.05.2020 (remote electronic identification) — Act not read; described via ICLG, *Fintech Laws and Regulations: Greece 2025*, https://iclg.com/practice-areas/fintech-laws-and-regulations/greece (accessed 2 August 2026); reported tier. [^17-33]: OECD Global Forum, "Status of commitments for the automatic exchange of financial account information (AEOI)", 27 July 2026, https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/aeoi-commitments.pdf (accessed 2 August 2026). [^17-34]: Greece, Law 4172/2013, Article 5A §§1–5 (non-Greek tax residence in seven of the eight preceding years; qualifying Greek investment of at least €500,000 to be completed within three years, the condition being disapplied only for a holder of a residence permit for investment activity under Article 16 of Law 4251/2014; flat tax of €100,000 per tax year plus €20,000 per included relative, with no credit for foreign tax; maximum 15 tax years; cessation on non-payment or on failure to complete the investment); consolidated text, https://www.taxheaven.gr/law/4172/2013/article/5Α/view (accessed 2 August 2026; Greek). Amounts and conditions are amended from time to time and require confirmation at the date of application. Corroborated by ICLG, *Private Client Laws and Regulations 2026 — Greece* (Zepos & Yannopoulos), 14 January 2026, https://iclg.com/practice-areas/private-client-laws-and-regulations/greece/, and International Bar Association, "Procedure and supporting documentation for application to the Greek non-dom taxation regime", https://www.ibanet.org/Procedure-and-supporting-documentation-for-application-to-the-Greek-non-dom-taxation-regime. On the permit-category waiver: Iason Skouzos TaxLaw, "The non-dom tax regime — Article 5A of the Greek Income Tax Code", https://www.taxlaw.gr/en/practice-areas/tax-law/the-non-dom-tax-regime-alternative-taxation-of-foreign-source-income-of-individuals-transferring-their-tax-residence-to-greece-article-5a-of-the-greek-income-tax-code/ (all accessed 2 August 2026). [^17-35]: Law 5275/2026 (Government Gazette A′ 17/06.02.2026) — listing via https://www.kodiko.gr/nomothesia/document/1279125/nomos-5275-2026; reported content via IMI Daily, https://www.imidaily.com/program-updates/greece-to-propose-golden-visa-changes-addressing-backdated-permits/ (both accessed 2 August 2026); the FEK text has not been read and its contents are not stated as law. [^17-36]: São Tomé and Príncipe, Serviço de Migração e Fronteiras — official site (electronic passport; e-passport PKI certificates; fee schedule), https://www.smf.st/ and https://www.smf.st/epassport/index.html (accessed 2 August 2026); Portuguese original. [^17-37]: Law 5038/2023, Articles 19 §§1, 4 and 20 §1 (declarations; reissue fee; fines) — Government Gazette facsimile A′ 81/01.04.2023, cross-checked against the consolidated text — source as note 17-21. [^17-38]: Law 3427/2005, Article 23 (E9 declaration by 31 January of the following year) — consolidated Greek text via https://www.taxheaven.gr/law/3427/2005/article/23/view (accessed 2 August 2026); reported tier pending gazette confirmation. [^17-39]: Belgian Immigration Office (IBZ), "Visa-free travel with residence permits — general principles" (100% match of five identity parameters including nationality), https://dofi.ibz.be/en/themes/entry/border-control/visa-free-residence-permits/general-principles (accessed 2 August 2026); Belgian national guidance — the only published national matching rule located, not a Schengen-wide rule. [^17-40]: esd.gr, «ΕΝΦΙΑ 2026: αναλυτικός οδηγός» (2026 payment schedule; instalment plans), https://esd.gr/enfia-2026-neow-odigos-me-erotiseis-kai-apantiseis/ (accessed 2 August 2026); reported tier; Greek original. The ENFIA-certificate precondition for transfer deeds: Article 54Α of Law 4174/2013, consolidated text via https://www.taxheaven.gr/law/4174/2013/article/54α/view (accessed 2 August 2026). [^17-41]: newmoney.gr and concordant press on the landlord bank-account rule from 1 April 2026 (Article 210 of Law 5222/2025, entry deferred), https://www.newmoney.gr/roh/palmos-oikonomias/oikonomia/pos-tha-plirononte-ta-enikia-apo-1i-ianouariou-2026/ (accessed 2 August 2026); reported tier; Greek original. [^17-42]: Iason Skouzos TaxLaw, "The duration and termination of a lease contract" (three-year minimum on primary-residence leases, Article 2 of Law 1703/1987 as amended), https://www.taxlaw.gr/en/practice-areas/real-estate/the-duration-and-termination-of-a-lease-contract/ (accessed 2 August 2026); reported tier — gazette text unread.