<!-- 19. What the Structure Provides—and What It Does Not — from "After the EU's Golden Passports", Kestrel Private, 6 August 2026. Canonical: https://kestrelprivate.com/research/after-the-golden-passports -->

# 19. What the Structure Provides—and What It Does Not

Save for its final section, this chapter adds no new facts. It consolidates, in one place, the attribution work done throughout the report: which instrument creates each right, on what conditions, and where the boundaries of the coordinated position lie. Section 19.10 answers a narrower question — what the position enables for a household living in Greece — and to do so it cites three instruments the report has not previously had occasion to use; it creates no right that the sections before it do not. Every entry below is drawn from the component chapters and cross-referenced to them, so that the reader can test any line against the underlying analysis. The former investor-citizenship model conferred a single European nationality carrying a wide bundle of rights. The reference structure does not reproduce that bundle in separated form: it provides a distinct and materially narrower set of rights, each created by its own instrument and on its own conditions, and none of them a substitute for the nationality of a member state. Setting out what each instrument does and does not create is the substance of this chapter.

## 19.1 Consolidated rights summary

Subject to eligibility, due diligence and government approval, and where the client separately qualifies, the structure may provide the capacities set out below. The matrix is written in the indicative for legibility; every entry reading "Yes" is conditional on that approval gate and on the conditions stated in the final column.

The matrix is the full-dress version of the summary at §4.9 and seeds Appendix A. The four component columns correspond to the components defined at §5.1: the citizenship component (São Tomé and Príncipe), the residence component (the Greek investor residence permit, type «Β.5»), the property component (the qualifying Greek property held in the client's own name), and the optional layer (company, banking and tax-residence arrangements). No cell should be read across columns as cumulative: each right is created by one instrument and each condition attaches to that instrument alone.

| Right or capacity | Citizenship component (STP) | Residence component (Greek permit) | Property component | Optional layer | Conditions and qualifications |
|---|---|---|---|---|---|
| Reside in Greece | No | Yes — lawful residence under the conditions of the permit, five years, renewable for equal periods[^19-1] | No — ownership confers no residence right | No | Full ownership and possession of one qualifying property must continue throughout;[^19-1] there is no minimum-stay or physical-presence condition for renewal (Art. 100 §4).[^19-1] Biometrics are collected only in Greece; where the application is filed by proxy before entry, the applicant and each family member must enter Greece within an exclusive 12-month period from filing to give them, and two failures to appear at the summoned date cause the application to be rejected (Arts. 10 §11, 14 §7)[^19-2] |
| Access to employment | No | No — the permit does not establish a right of access to any form of employment (Art. 100 §9)[^19-1] | No | No — company ownership is not a labour-market right | Employment requires a separate title; whether shareholder or board activity is permitted as a statutory carve-out is not established and requires confirmation at the date of application |
| Short-stay travel in other Schengen states | No — São Tomé and Príncipe is an Annex I (visa-required) country[^19-3] | Yes — up to 90 days in any 180-day period on the permit and a valid travel document (CISA Art. 21(1))[^19-4] | No | No | Subject to the entry conditions of SBC Art. 6(1)(a), (c) and (e) and to not being on the national alert list of the state concerned;[^19-4] days spent in Greece under the permit do not count against the budget[^19-5] |
| Visa-free travel on the passport itself | Limited — visa-free access to a limited number of states; verified examples are South Africa (90 days), Singapore and Hong Kong (14 days),[^19-8] while the Schengen states,[^19-3] the United Kingdom[^19-6] and the United States[^19-7] all require visas | Not applicable — the permit is not a travel document[^19-9] | No | No | No official list of the passport's total travel access is published; commercial counts and passport rankings are not used in this report (see §6.9) |
| Vote or stand for public office | A matter of São Toméan constitutional and electoral law, not verified in this report — requires confirmation at the date of application | No — the permit confers residence and no political rights; Art. 100 creates no electoral capacity[^19-1] | No | No | Political rights in the European Union follow EU citizenship, which the structure does not provide (§19.8) |
| Transmit status to children | Yes, subject to nationality law — a child born abroad after the parent's naturalisation is a national of origin only upon a declaration of the wish to be São Toméan, with registration[^19-10] | No — family members hold derived family-reunification permits (title O.1) that expire simultaneously with the sponsor's permit[^19-1] | By succession under the applicable succession law | By succession, as shares | The parent must still hold São Toméan nationality at the child's birth; acquisition of a fourth nationality causes immediate loss (Art. 11(2) Lei 7/2022)[^19-10] |
| Own property in Greece | No bearing — ownership is acquired under Greek property law, not through nationality | Conditioned on ownership; the permit does not create it | Yes — full ownership and possession (πλήρης κυριότητα και νομή) of one property of at least €250,000 acquisition value[^19-1][^19-11] | Acquisition through a Greek or EU entity requires evidence of 100% ownership[^19-12] | The change of use of the main spaces must have been completed after 5 April 2024 and before the application is submitted[^19-11] |
| Let the property | No | Long-term letting expressly permitted (Art. 100 §7); short-term and sub-letting prohibited (Art. 100 §7A)[^19-1][^19-13] | Follows the permit's restrictions while the permit is relied upon | No | Change-of-use property may not be used as the seat or branch of a business;[^19-1] breach of the letting prohibition carries revocation of the permit and a €50,000 administrative fine[^19-1][^19-14] |
| Tax position | None automatically | None automatically — immigration residence is not tax residence | None — ownership does not create non-dom status | A company does not create personal tax residence | Any tax result depends on the client separately satisfying the residence, domicile, physical-presence, reporting and continuing-compliance rules of each relevant jurisdiction (see Chapter 9) |
| Family inclusion | Spouse and/or children per Arts. 10(4)–(5) of Lei 7/2022[^19-15][^19-10] | Spouse or cohabitation partner, unmarried children under 21, direct ascendants of the spouses or partners, and adult children lacking legal capacity (Art. 95 §2)[^19-1] | Not applicable | Not applicable | The spouse limb runs through Art. 6 of Lei 7/2022 — cumulatively, marriage of more than five years under the regime of community of acquired property (*comunhão de bens adquiridos*), or a court-recognised de facto union of more than three years; the children limb covers minor children at the naturalisation act, requestable up to one year after majority.[^19-10] Nationality may not be granted to a person already holding more than two foreign nationalities (Art. 11(1));[^19-10] acceptance of applications from holders of three or more foreign nationalities, and passport issuance to adult dependants aged 18 and over, were both placed on hold by the programme channel's memorandum of 10 April 2026, and no evidence of their lifting was located as at 2 August 2026 (reported).[^19-17] The programme channel's published broader dependant categories rest on administrative practice, not published law[^19-16] |

Table 19.1 — Consolidated rights matrix. Assumptions: subject throughout to eligibility, due diligence and government approval, and to the client separately qualifying under each relevant instrument; a single main applicant who is a third-country national of a state listed in Annex I of Regulation (EU) 2018/1806; the Greek permit obtained under the €250,000 change-of-use category of Article 100 §2(γ) of Law 5038/2023 as amended by Article 64 of Law 5100/2024; the property held in the client's own name; status stated as at 2 August 2026. Sources: Law 5038/2023 (consolidated) and its gazette facsimile; Law 5100/2024, Art. 64; the official administrative record for the change-of-use category; JMD 214926/2025; Decreto-Lei n.º 07/2025 and Lei n.º 7/2022 of São Tomé and Príncipe; CISA Art. 21; Regulation (EU) 2016/399; Regulation (EU) 2018/1806; Regulation (EC) No 1030/2002; the destination-government sources for passport travel access.

## 19.2 Citizenship rights

Subject to eligibility, due diligence and the government's decision, the citizenship component may provide a second nationality and passport, an alternative sovereign and consular relationship, and reduced dependence on a single country of nationality. It is granted by special naturalisation under Article 10(2) of Lei n.º 7/2022 as implemented by Decreto-Lei n.º 07/2025, on a non-refundable contribution to the National Transformation Fund.[^19-15][^19-10] Its purpose is additional nationality and nothing else; the analysis of who benefits and who obtains little practical value is at §§6.13–6.14.

Two eligibility limits bear directly on this client profile and are stated here because they determine whether an application is possible at all. Nationality may not be granted to a person who already holds more than two foreign nationalities (Art. 11(1) of Lei n.º 7/2022).[^19-10] Invoking that cap, the programme channel's director placed acceptance of new applications from holders of three or more foreign nationalities on hold by memorandum of 10 April 2026; the memorandum is not public, the position is reported rather than officially published, and no evidence of its lifting was located as at 2 August 2026.[^19-17] The dependant limbs carry their own conditions: the spouse qualifies through Article 6 of the Nationality Law, which requires cumulatively 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; children qualify as minor children at the naturalisation act, requestable up to one year after majority.[^19-15][^19-10]

Transmission exists in the statute but is not automatic. A child born abroad after the parent's naturalisation is a national of origin only upon a declaration of the wish to be São Toméan, registered with the central registry; grandchildren born abroad fall under a separate limb with no express declaration wording, and no registry practice can yet exist for a programme one year old.[^19-10] Transmission is therefore properly described as subject to nationality law, as the executive summary has it, and requires confirmation at the date of application. The parent must still hold São Toméan nationality when the child is born: acquisition of a fourth nationality causes immediate loss of it.[^19-10]

Two further attributes belong on the record. Citizens naturalised under the decree are permanently exempt from compulsory military service.[^19-15] Dual nationality is permitted: a São Toméan who acquires another nationality retains São Toméan nationality unless he declares otherwise.[^19-10] The passport's travel access is limited and must be assessed against the client's existing nationality rather than against a ranking (see §6.9).

## 19.3 Residence rights

Subject to eligibility, due diligence and the approval of the Greek authorities, the residence component may provide lawful residence in Greece under the conditions of the permit. 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; no cap on the number of renewals appears in the statute, and periods of absence from Greece are no obstacle to renewal.[^19-1] There is no minimum-stay or physical-presence condition (Art. 100 §4).[^19-1]

That absence is a genuine feature of this permit, and it is bounded in two ways that must be read with it. First, at least one attendance in Greece is unavoidable: biometrics are both index fingerprints, collected only in Greece, and no consular route appears in the instruments read. Where the application is filed by proxy before entry, the applicant and each family member must enter Greece within an exclusive twelve-month period from filing to give biometrics and to lodge the outstanding insurance document, and two failures to appear at the summoned date cause the application to be rejected (Art. 14 §7).[^19-2] Whether fingerprints are re-captured at each five-year renewal is not expressly ruled in the instruments read and requires confirmation at the date of application. Second, the permit's years count toward the seven-year residence track for naturalisation — the investor permit is expressly on that list — but the absence of any presence condition means the permit alone does not accumulate the language examination, the evidenced economic and social integration or the Greek tax returns for the residence years that naturalisation also requires.[^19-18] A permit held without genuine relocation therefore accumulates time without accumulating the remaining requirements; there is no investor fast-track to Greek citizenship (see §7.13 and §19.7).[^19-18]

Family members are included under Article 95 §2 on the categories set out in the matrix, on family-reunification permits that expire simultaneously with the sponsor's permit; a child reaching 21 receives an independent three-year permit.[^19-1] The permit does not establish a right of access to any form of employment.[^19-1] Renewal re-proves the property position documentarily — continuing ownership and possession, a fresh insurance policy, the €2,000 fee, the E9 declaration, solemn declarations on letting and use, and, where registration was evidenced at initial issuance only by an attestation that registration had been applied for or by a lawyer's certificate, the definitive transcription and registration certificate — but does not re-run the investment review.[^19-12] The application, documentary and biometric mechanics are at §§7.7 and 17.11.

## 19.4 Schengen mobility

Short-stay mobility in the other Schengen states arises from the Greek residence permit and from nothing else. 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 for up to 90 days in any 180-day period within the territories of the other member states.[^19-4] The right is subject to conditions: a valid travel document, the entry conditions of Article 6(1)(a), (c) and (e) of the Schengen Borders Code, and not being on the national alert list of the state concerned.[^19-4][^19-5] The Greek permit is a stand-alone uniform-format document under Regulation (EC) No 1030/2002 and so falls squarely within the definition that carries this effect.[^19-9]

Two mechanics are worth stating because they are commonly misunderstood. Periods of stay authorised under a residence permit are not taken into account in the 90/180 calculation, so days spent in Greece do not consume the budget available for the rest of the area.[^19-5] And a residence-permit holder must be authorised to enter other member states for transit back to the issuing state even where the short-stay conditions are not all met, unless subject to a national no-entry alert.[^19-5]

The permit also carries a documented administrative convenience. The Entry/Exit System, fully operational at all external border crossing points since 10 April 2026, does not apply to holders of residence permits within the Borders Code definition — subject to the provision's own carve-outs for the categories covered by its points (a) and (b) — and the Commission's guidance confirms the practical rule that residence-permit holders of the operating states are exempt.[^19-19][^19-20] ETIAS, when it enters operation — it is not in operation as at 2 August 2026 and no launch date is published — will likewise not apply to residence-permit holders.[^19-21][^19-22] This is a convenience of the permit and must not be dressed up as a right of free movement.

Two caveats attach. The first concerns document pairing. No EU provision requires the travel document presented under Article 21 to be the passport against which the permit was issued; but the uniform permit card carries the holder's nationality as a mandatory printed entry, and the only published national standard located — Belgian guidance — requires both documents to be carried and all five identity parameters, including nationality, to match, failing which travel "is not possible with that combination".[^19-23][^19-9] As practice rather than as a rule of Schengen law, the client cannot rely on presenting the São Tomé passport with a Greek permit issued against another nationality; the position requires Greek counsel's confirmation before travel and before any declaration under Article 19, and whether Greece re-keys a permit to a newly acquired second nationality while the original subsists is unpublished.[^19-2] The second concerns internal borders. Member states may temporarily reintroduce internal border controls as a last resort, and as at 2 August 2026 eight Schengen states had notified controls in force.[^19-24] The Article 21 right is unaffected, but "borderless" language is not accurate and is not used in this report.

The Schengen Area comprises 29 countries; Cyprus is not part of the area without internal border controls and Ireland stands outside it (see §7.10).[^19-25] Cyprus applies Article 2(1)(c) of Decision No 565/2014/EU, under which holders of residence permits issued by Schengen member states require no Cyprus short-stay visa for stays of up to 90 days in any 180-day period,[^19-26][^19-27] counted against a separate Cyprus budget and not against the Schengen one; the recognition runs one way only, and permits issued by Cyprus are not valid for entry into the area without internal border controls.[^19-28] The concession expressly does not apply to citizens of Türkiye and Azerbaijan, who must follow the regular visa procedure unless they are family members of an EU citizen.[^19-27]

## 19.5 Property rights

The property component may provide full ownership and possession of one Greek property with a minimum acquisition value of €250,000, held in the client's own name and forming part of the client's estate.[^19-1][^19-11] Ownership is real and is the point of the component; it is not, and must not be read as, capital preservation or recoverability (see §12.3).

Ownership carries obligations because it is simultaneously an immigration condition. The property must remain in the holder's ownership and possession for the permit to be renewed, and sale during the permit's validity revokes the seller's permit while giving a qualifying third-country-national buyer a right to a permit of his own.[^19-1] Long-term letting is expressly permitted; short-term and sub-letting are prohibited for this category, with revocation of the permit and a standalone €50,000 administrative fine on the owners for breach.[^19-1][^19-13][^19-14] The property may not be used as the seat or branch of a business.[^19-1] The main spaces must remain in residential use, and this is re-declared at each renewal.[^19-12] Circular 1/2026 of the Secretary General for Migration Policy is reported, from two concordant professional sources, to provide that permits may be revoked where arrangements reduce the effective investment below the statutory minimum; the circular's own text has not been opened.[^19-29] The investment merits of the asset, assessed independently of the immigration benefit, are the subject of Chapter 8 and of the test at §8.15.

## 19.6 Optional business and banking position

The optional layer provides professional establishment and application coordination. It does not provide approvals. A company may be established and a registered office, accounting and corporate-service arrangements put in place; bank-account applications may be prepared and submitted. Whether an account is opened is a decision of the institution's compliance function, not of any adviser, and it cannot be guaranteed (see §§9.4–9.5). A company does not create personal tax residence, and the permit does not confer a right of access to employment that a corporate structure could supply.[^19-1] Where the qualifying property is acquired through a Greek or EU entity, evidence of 100% ownership is required as part of the residence file.[^19-12] The circumstances in which the layer is unnecessary are at §9.16.

## 19.7 Potential tax position

The structure may support a tax-residence position where the client separately qualifies. It does not create one. An immigration residence permit is not a tax residence: the Greek investor permit has no physical-presence condition at all, which is precisely why it cannot of itself establish presence-based tax residence.[^19-1] Property ownership does not create non-dom status, and a company does not create personal tax residence. Any tax result depends on the client satisfying the domestic residence, domicile, physical-presence, reporting and continuing-compliance requirements of the relevant jurisdiction, and on the client's position in every other relevant tax jurisdiction (see Chapter 9, and §9.12 in particular). The same separation governs naturalisation, where the tax-return requirement is one of the conditions the permit alone does not satisfy (§19.3).

## 19.8 Rights that remain unavailable

The executive summary's list of what the structure does not provide is restated here, with the legal reason for each, because the reasons are the point.

- **EU citizenship and an EU passport.** Transactional investor citizenship in the European Union has ended following the Court of Justice's judgment in *Commission v Malta*;[^19-30] neither component is capable of conferring the nationality of a member state (see §2.4).
- **Immediate Greek citizenship.** Naturalisation runs on the 3/7/12-year residence structure with examination, integration and tax-return requirements; the investor permit sits on the seven-year list and confers no fast-track.[^19-18]
- **Unrestricted residence throughout the EU.** Article 21 CISA gives short stays only;[^19-4] free movement under Directive 2004/38/EC applies to Union citizens who move to or reside in a member state other than their own, and to their family members, not to third-country nationals in their own right.[^19-31]
- **Unrestricted employment.** Article 100 §9 of Law 5038/2023 states expressly that the permit does not establish a right of access to any form of employment.[^19-1]
- **Visa-free Schengen entry from the second passport.** São Tomé and Príncipe is listed in Annex I of Regulation (EU) 2018/1806, whose Article 3(1) requires a visa for crossing the external borders.[^19-3]
- **Automatic tax residence or non-dom status.** No immigration instrument in the structure imposes presence, and tax residence is a matter of each jurisdiction's own domestic law (§19.7).
- **Guaranteed bank-account opening.** Account opening is an institutional credit and compliance decision (§9.5).
- **Guaranteed citizenship or residence approval.** Both are government decisions, taken after due diligence, on statutory grounds that include refusal (§18.9); the São Toméan file additionally requires the Public Prosecutor's prior visto, and refusal causes the process to lapse.[^19-15]
- **Guaranteed rental income, appreciation or resale liquidity.** These are market outcomes, not legal entitlements, and the letting restrictions above narrow the tenant pool (Chapter 12).
- **Protection from future legislative or policy change.** Both programmes rest on instruments their legislatures and ministers may amend; the São Toméan fee schedule is alterable by joint order, though changes do not affect processes already admitted,[^19-15] and the Greek thresholds have been amended three times since 2013 (§7.14).

## 19.9 Principal conditions and continuing obligations

The structure is not a completed transaction. It is a position with continuing conditions on both sides, and the client's exposure is to their breach as much as to market outcomes.

- **Hold the property.** Ownership and possession must continue; sale during the permit's validity revokes the permit.[^19-1] Where registration was evidenced at initial issuance only by an attestation that registration had been applied for, or by a lawyer's certificate, the definitive transcription and registration certificate must be produced at renewal.[^19-12]
- **Observe the use restrictions.** No short-term letting or sub-letting; no company seat or branch; the main spaces must remain residential — each re-declared at renewal.[^19-1][^19-12]
- **Renew on time.** Renewal is applied for within the two months before expiry; late filing is possible up to three months after expiry with a fine of €100 for each month of delay, and beyond that is barred absent proven force majeure.[^19-1]
- **Maintain insurance.** Full sickness insurance is a condition of the residence title, evidenced by a private insurance policy at issuance and again at each renewal; the coverage minimums fixed under the predecessor Code are still applied in practice and require confirmation at the date of application.[^19-2][^19-32]
- **Declare changes of status.** Change of nationality and any loss, renewal or change of passport details must be declared through the migration information system within two months, with fines for default.[^19-2]
- **File and remain compliant.** Greek tax obligations arising from ownership of the property and from any Greek-source income are the subject of Chapter 9 and require confirmation with Greek tax counsel at the date of application; the naturalisation record's own requirements presuppose filed Greek tax returns for the residence years (§19.3).[^19-18]
- **Revocation exposure on both sides.** The Greek permit may be revoked for breach of the letting prohibition,[^19-1] and is reported — from two concordant professional sources, the circular text itself being unopened — to be revocable where arrangements reduce the effective investment below the statutory minimum.[^19-29] On the citizenship side, 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 administrative sanctions include revocation of nationality; separate statutory loss grounds apply to naturalised citizens, including acquisition by fraud, decreed after final conviction and with no possibility of reacquisition.[^19-15][^19-10]

The renewal and monitoring calendar that operationalises these obligations is set out at §17.17.

## 19.10 What the position enables in practice

The sections above attribute each right to the instrument that creates it. A family asks a narrower question: what changes for the household. This section answers it on the same instruments, together with three the chapter has not so far had occasion to set out — the equal-treatment and education provisions of the Immigration Code, the statute governing access to public health structures, and the Greek law transposing the European payment-accounts directive. It adds no right those instruments do not create.

Two things govern the whole of it. First, every capability below belongs to the residence component; none rests on the citizenship component, which was outside the scope of the verification underlying this section (see §19.2 and Appendix Q). Second, these are capabilities of living in Greece. The permit imposes no presence condition (§19.3), while a school place, hospital access and an integration record are consequences of presence — the freedom from presence and the benefits that presence unlocks cannot both be taken.

The right-hand column states the position under the Maltese and Cypriot investor-naturalisation routes, both closed following the Court's judgment in *Commission v Malta*.[^19-30] It is there because the comparison is what makes the affirmative entries testable; nothing in it is obtainable today.

| Capability | Under the reference structure | Under EU citizenship, as it was |
|---|---|---|
| Bring the household in on one application | Spouse or registered cohabitation partner; unmarried common children under 21; unmarried children of either partner under 21 where custody is lawfully held; and the direct ascendants of both spouses or partners — each on a family-reunification permit expiring at the same moment as the investor's (Art. 95 §2(α)–(δ)).[^19-1] The two years' lawful residence that Art. 84 §1 otherwise requires before family members may be applied for does not apply, Art. 95 §2 operating by derogation from it; each member still applies and still satisfies the general conditions of Art. 8.[^19-33][^19-2] Art. 95 states no express age or dependency condition for the ascendant limb, and the category of direct ascendants extends beyond parents to grandparents in the direct ascending line, subject to documentary proof of the complete civil-status chain; this is the absence of a statutory condition from a defined eligible category and not an inference from silence, and neither the general conditions of Art. 8 nor the ordinary documentary scrutiny falls away.[^19-1][^19-2] The survivors' position on the investor's death is open (open point 2 below) | Family members held rights of their own under Directive 2004/38/EC;[^19-31] children naturalised with the parent held the citizenship permanently and in their own right |
| Add family members in stages | Dependants may enter Greek territory with the investor or at a later time; those aged six and over enter to give biometric data, and children under six need not enter Greece at all — Ministry of Migration and Asylum, ref. 265272/Σ.133411 of 25 October 2024, section I.[^19-34] The applicant and each family member have an exclusive twelve-month period from filing in which to enter and give biometrics, fingerprints being compulsory from age six (Arts. 10 §11, 14).[^19-2] | No entry step and no biometric step arose |
| Keep a child in status past 21 | A child included under Art. 95 §2(β) or (γ) receives an autonomous residence permit for three years, the sole obligation being production of the previous family-reunification permit (Art. 95 §2, final sentence).[^19-1] The holder of an autonomous permit has immediate access to dependent employment and to studies at any level (Art. 90 §7); the provision reaches dependent employment and studies, and is not a general right of self-employment.[^19-1] | Nothing turned on the child's 21st birthday; the child was a citizen |
| Work in Greece on the permit | No. The permit does not establish a right of access to any form of employment (Art. 100 §9).[^19-1] Letting the property is expressly permitted and is not employment (Art. 100 §7).[^19-1] Nor does a family member acquire an employment entitlement merely through an Art. 95 §2 family permit: Art. 89 §1 grants family members access equally with the sponsor, and the investor sponsor has no employment right under Art. 100 §9.[^19-1] Employment would therefore require an independently qualifying status unless the competent authority confirms a different interpretation (open point 1 below) | Employed or self-employed activity in any member state, as of right (TFEU Arts. 45 and 49)[^19-35] |
| Live anywhere in Greece, not only where the property is | Third-country nationals residing lawfully in the country have freedom of movement and establishment throughout the territory (Art. 18 §1); the permit does not tie the family to the region in which the property lies.[^19-33] | The same, and throughout the Union (TFEU Art. 21)[^19-35] |
| Put the children into Greek state school | As of right, with no separate application, quota or fee: minor third-country nationals residing in Greek territory are subject to compulsory school attendance on the same footing as Greek nationals, and those attending any level have unrestricted access to the activities of the school community (Art. 18 §7).[^19-33] The trigger is residence in Greece rather than the permit category, and it is a duty as well as a right | The same in Greece, and in every other member state (TFEU Art. 18)[^19-35] |
| Enrol without an immigration assessment at the school gate | The documents required are the corresponding documents provided for Greek nationals (Art. 18 §8).[^19-33] Enrolment on incomplete documentation is an exception reserved to beneficiaries of protection, asylum applicants and persons whose residence has not been regularised; a lawfully resident family produces the ordinary set, and the school does not adjudicate the parents' immigration position. Class placement, mid-year entry and reception-class provision rest on instruments that could not be retrieved (open point 3 below) | The same |
| Choose an international school instead | Published 2026–27 schedules. ACS Athens publishes €9,050 Pre-School, €11,393 Kindergarten, €13,782 Grades 1–5, €14,898 Grades 6–8 and €16,348 Grades 9–12, with registration of €221 to €963 and the two-year IB Diploma at €1,400 published separately from those totals.[^19-36] Across the five schools examined, published day fees run from €6,990 at early-years level to €17,320 at Years 12–13, with the four Athens schools clustering at €13,000–€17,500 at secondary level; Pinewood, in Thessaloniki, publishes boarding at €11,900.[^19-36] Schedules are annual and are set by each school; admission is contractual | Identical: these are private contracts and are nationality-blind. The difference was that a citizen could equally use a state school in any member state |
| Go on to a Greek public university after Greek secondary school | Third-country nationals who have graduated from secondary education in Greece have access to tertiary education under the same terms and conditions as Greek nationals, subject to more specific provisions (Art. 18 §9).[^19-33] This is equality of treatment and not an easier route: the same Panhellenic examinations, sat in Greek, and the same fee position as a Greek national. The statutory basis of tuition-free first-cycle study, eligibility for English-taught programmes and the special-category quota for foreign nationals are open (open point 4 below) | The same in Greece, and home-fee status in every member state (TFEU Art. 18)[^19-35] |
| Take EU or home tuition rates elsewhere in the Union | No such entitlement follows from the permit and none could be sourced: EU law does not harmonise tuition, and residence-based fee tests in other member states look to residence in that state or to EEA nationality. There is no differential at source either — the National and Kapodistrian University of Athens publishes its English-language MD at €17,000 for 2026–27 for EU and non-EU citizens alike[^19-37] | Home-fee status across the Union, and the free movement to take the place up (TFEU Arts. 18 and 21)[^19-35] |
| Be insured from the first day | Full sickness insurance covering the totality of the risks covered for Greek nationals is a general condition of the right of residence and not a filing formality (Art. 8(ε)), evidenced at grant and again at each renewal.[^19-2][^19-32] Because the permit carries no access to employment (Art. 100 §9), the family acquires no insurable status through it and falls in the residual class that Art. 8(ε) directs to private insurers.[^19-1][^19-2] A lapse is a defect in the residence title itself. The minimum risks a policy must cover cannot be stated from an authoritative text (open point 5 below) | An EU citizen who worked, or was otherwise insured in a member state, was inside that state's public system by virtue of the insurance (Regulation (EC) No 883/2004, Art. 1(c))[^19-38] |
| Use Greek public hospitals | Not on the permit. A statutory route exists — third-country nationals holding lawful residence documents, together with their spouse and minor or dependent children, have free access to public health structures where they are neither directly nor indirectly insured — but it is conditional on holding an AMKA and is verified electronically (Law 4368/2016, Art. 33 §§1, 2(α), 3 and 5).[^19-39] Whether a holder of an Article 100 permit who has no employment and no insurance relationship can obtain an AMKA was not established for this report, and the permit itself confers no access to employment (Art. 100 §9). Public health access dependent on an active AMKA should therefore not be treated as a benefit of the permit: compliant private medical insurance is the practical basis of cover. | Public cover through the national system of the state of insurance, as of right |
| Carry a European Health Insurance Card | The card is issued by the competent institution to insured persons and their family members (Regulation (EC) No 883/2004, Arts. 1(c) and 19(1)), and the coordination regulations reach third-country nationals only where they are legally resident and in a situation not confined in all respects within a single member state (Regulation (EU) No 1231/2010, Art. 1).[^19-38] The card follows insurance, not the permit, and cover elsewhere in Europe is governed by the territorial scope of the private policy. Whether the competent Greek institution would issue a card to a privately insured Article 100 holder is open (open point 6 below) | The card followed the citizen's own national insurance and was usable across the Union |
| Open a Greek bank account | As an entitlement rather than a commercial favour. Consumers legally resident in the Union have the right to open and use a payment account with basic features at credit institutions established in Greece, and the right applies irrespective of the consumer's place of residence (Law 4465/2017, Art. 16 §2, transposing Directive 2014/92/EU).[^19-40] The Directive defines legal residence in the Union by reference to a right to reside conferred by Union or national law (Art. 2(2)), and the Article 100 permit is such a right.[^19-40] Greece did not take the "genuine interest" option: every credit institution offering consumer payment services must offer the basic account (Art. 16 §1), a decision is due within ten business days (Art. 16 §3), and a refusal must be written, free of charge, reasoned and signposted to the competent authority and to alternative dispute resolution (Art. 16 §7)[^19-40] | The same right, on the same footing |
| Not be refused on grounds of nationality or residence | Credit institutions may not discriminate against consumers legally resident in the Union by reason of nationality or place of residence, and the conditions for opening and maintaining a basic account may not entail discriminatory treatment (Law 4465/2017, Art. 15).[^19-40] Anti-money-laundering refusal grounds are unaffected. Whether Greek institutions operate a formal resident/non-resident account category, and what turns on it, is open (open point 7 below) | The same |
| Treat the entitlement as a banking relationship | No. It is an entitlement to a payment account with basic features and to nothing beyond: cash deposits and withdrawals in the Union at the counter and at machines, direct debits, card payment transactions including online payments, and credit transfers including standing orders, at least in euro and with an unlimited number of transactions (Law 4465/2017, Art. 17 §§1–3).[^19-40] It confers no entitlement to an overdraft, a credit card, a mortgage or a private-banking relationship, and the opening of an ordinary commercial account remains an institutional credit and compliance decision (§19.8; §§9.4–9.5) | The same floor, with commercial access decided on ordinary terms |
| Use the Greek account throughout the euro area | A payer or payee in the Union may not specify the member state in which a euro payment account is to be located, provided the account is reachable, reachability itself being an obligation on payment service providers (Regulation (EU) No 260/2012, Arts. 9 §§1–2 and 3).[^19-41] An employer, insurer or utility in another member state may not lawfully require a local account instead | The same |
| Obtain a basic account in another member state | The Directive imposes the obligation on every member state and expresses it irrespective of the consumer's place of residence.[^19-40] What transfers is the residence status, not the Greek account. Only the Greek transposition was examined for this report: another state may operate the "genuine interest" option, must refuse on anti-money-laundering grounds, and may legislate further grounds of its own | The same right, with the freedom to move there and open the account in person (TFEU Art. 21)[^19-35] |

Table 19.2 — Capabilities of the residence component for a family resident in Greece. Assumptions: as for Table 19.1, and in addition that the family actually resides in Greece; every entry in the middle column is sourced to the residence component and none to the citizenship component; school and university fees are published 2026–27 schedules, are annual and are set by each institution; status as at 2 August 2026. Sources: Law 5038/2023, Articles 8(ε), 10, 14, 18, 84, 95 and 100, as amended by Article 64 of Law 5100/2024; Ministry of Migration and Asylum ref. 265272/Σ.133411 of 25 October 2024; Law 4368/2016, Article 33; Law 4465/2017 with Directive 2014/92/EU; Regulation (EU) No 260/2012; Regulation (EC) No 883/2004 and Regulation (EU) No 1231/2010; the Treaty on the Functioning of the European Union; Directive 2004/38/EC; the schools' and the university's published fee schedules.

The following bear directly on the entries above and require confirmation at the date of application; all are set out with the full capability detail and their instruments at Appendix Q. The first states the position the report takes and names the confirmation that would displace it; the remainder could not be established from an authoritative text and may not be asserted in either direction.

1. **The employment position of family members admitted under Article 95 §2.** The conclusion stated in the table is the conservative one: a family member does not acquire an employment entitlement merely through the family permit, Article 89 §1 granting family members access equally with the sponsor and Article 100 §9 leaving the investor sponsor without any such access. No published judgment or interpretive circular reconciling the two provisions for Article 100 family members was located. A different interpretation would require confirmation from the competent authority — a ministerial circular or a decided application.
2. **The position of the surviving family if the investor dies.** Article 90 §2(α) grants an autonomous permit on the sponsor's death only where the family has resided in Greece for at least a year beforehand, and whether Article 90 reaches members admitted under Article 95 §2 is unresolved. Requires a ministerial ruling.
3. **Enrolment documents, class placement, mid-year entry and reception classes.** Presidential Decree 79/2017 and Ministerial Decision 79942/ΓΔ4/2019 could not be retrieved, and the 2024 decisions governing reception classes are unread; minimum enrolment thresholds apply, so a reception class is not available at every school. Requires retrievable consolidated copies of each instrument.
4. **The tertiary limb beyond Article 18 §9.** Whether Greek-taught first-cycle public higher education is free as a matter of statute — two institutions are on record as charging — eligibility for the English-taught programmes of Greek public universities, and the special-category quota for foreign nationals. Requires Law 4957/2022 and the current consolidated ministerial decision, checked in the year of application.
5. **The risks a private sickness policy must cover.** Article 176 §10 delegates this to a joint ministerial decision that could not be identified by number or gazette, and no minimum sum insured, exclusion, pre-existing-condition, maternity or repatriation requirement can be stated from an authoritative text; the amounts fixed under the predecessor Code are still applied in practice (§19.9).[^19-32] Requires identification of the decision in force.
6. **Whether the competent Greek institution would issue a European Health Insurance Card to a privately insured Article 100 holder.** Each link in the chain is verified; the conclusion drawn from them is an inference. Requires a written answer from the competent institution.
7. **Whether Greek credit institutions operate a formal resident/non-resident account category, and what turns on it.** Law 4465/2017 creates none and imposes no tax-number precondition; the proposition that the permit upgrades a family to a resident account is unverified. Requires supervisory guidance or the institutions' own account-opening frameworks.

None of the capabilities above qualifies §19.8. None is a right of EU citizenship, none is created by the citizenship component, and each is held on the conditions of the permit and for as long as those conditions continue to be met (§19.9).

### Notes

[^19-1]: Greece, Law 5038/2023 (Immigration Code), Government Gazette A′ 81/01.04.2023, Articles 11, 89, 90, 95, 100 and 171, consolidated text (codification runs through Law 5307/2026); via [https://www.taxheaven.gr/law/5038/2023](https://www.taxheaven.gr/law/5038/2023) (accessed 2 August 2026). Greek-language instrument. 
[^19-2]: Greece, Law 5038/2023, Articles 8(ε), 10 §11, 14, 17 §1, 19 and 20, gazette facsimile of Government Gazette A′ 81/01.04.2023; [https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf](https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf) (accessed 2 August 2026). Greek-language instrument. 
[^19-3]: Regulation (EU) 2018/1806 (visa lists), Article 3(1) and Annex I, consolidated version of 30 December 2025; [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230) (accessed 2 August 2026). 
[^19-4]: Convention Implementing the Schengen Agreement, Article 21, as replaced by Regulation (EU) No 265/2010, Article 1(2), 25 March 2010; [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265) (accessed 2 August 2026). 
[^19-5]: Regulation (EU) 2016/399 (Schengen Borders Code), Article 6(1), 6(2) and 6(5)(a), consolidated version of 12 October 2025; [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02016R0399-20251012](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02016R0399-20251012) (accessed 2 August 2026). 
[^19-6]: United Kingdom, Immigration Rules Appendix Visitor: Visa national list, VN 1.1.(a) item 85 (São Tomé and Príncipe), version updated 30 July 2026; [https://www.gov.uk/guidance/immigration-rules/immigration-rules-appendix-visitor-visa-national-list](https://www.gov.uk/guidance/immigration-rules/immigration-rules-appendix-visitor-visa-national-list) (accessed 2 August 2026). 
[^19-7]: United States, Department of State, Visa Waiver Program designated-country list (São Tomé and Príncipe absent), archived capture of 6 July 2026; [https://web.archive.org/web/20260706071940/https://travel.state.gov/content/travel/en/us-visas/tourism-visit/visa-waiver-program.html](https://web.archive.org/web/20260706071940/https://travel.state.gov/content/travel/en/us-visas/tourism-visit/visa-waiver-program.html) (accessed 2 August 2026). Archived capture used because the live page is not reachable to research tooling. 
[^19-8]: Verified visa-free anchors, destination-government sources: South Africa, Department of Home Affairs, visa-exempt countries schedule (São Tomé and Príncipe ordinary passports, 90 days), issued 9 December 2025, [http://www.dha.gov.za/index.php/immigration-services/exempt-countries](http://www.dha.gov.za/index.php/immigration-services/exempt-countries); Singapore, Immigration and Checkpoints Authority, visa requirements (São Tomé and Príncipe absent from the visa-required lists), [https://www.ica.gov.sg/enter-transit-depart/entering-singapore/visa_requirements](https://www.ica.gov.sg/enter-transit-depart/entering-singapore/visa_requirements); Hong Kong SAR, Immigration Department, visit visa / entry permit requirements ("SAO TOME AND PRINCIPE — 14 Days"), [https://www.immd.gov.hk/eng/services/visas/visit-transit/visit-visa-entry-permit.html](https://www.immd.gov.hk/eng/services/visas/visit-transit/visit-visa-entry-permit.html) (all accessed 2 August 2026). 
[^19-9]: Regulation (EC) No 1030/2002 (uniform residence-permit format), Articles 1 and 4, consolidated version of 21 November 2017, and Regulation (EU) 2017/1954, Annex (mandatory card entry "8. Nationality."); [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02002R1030-20171121](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02002R1030-20171121) (accessed 2 August 2026). 
[^19-10]: São Tomé and Príncipe, Lei n.º 7/2022 (Lei da Nacionalidade), Diário da República I Série N.º 25, 10 March 2022, Articles 2, 4, 5, 6, 10, 11, 15, 16, 21 and 22; gazette facsimile at [https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf](https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf) (accessed 2 August 2026). Portuguese-language instrument. 
[^19-11]: Greece, National Registry of Administrative Public Services, "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](https://en.mitos.gov.gr/index.php/ΔΔ:Permanent_golden_visa_(change_of_use)_–_Initial_issuance) (accessed 2 August 2026). 
[^19-12]: Greece, Joint Ministerial Decision 214926/2025, Government Gazette B′ 6014/11.11.2025, Article 2 §§2.6 and 3 (documents for Article 100 permits, including the deferred transcription and registration certificate at renewal); [https://www.pomida.gr/assets/File/1236_20250206014.pdf](https://www.pomida.gr/assets/File/1236_20250206014.pdf) (accessed 2 August 2026). Greek-language instrument. 
[^19-13]: Greece, Law 5100/2024, Article 64, Government Gazette A′ 49/05.04.2024, as codified with Law 5167/2024; official consolidated PDF at migration.gov.gr, [https://migration.gov.gr/wp-content/uploads/2025/03/Νόμος-5100_2024-κωδικοποιημένος-με-τον-5167_2024-ΦΕΚ-Α-49_5.4.2024.pdf](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). Greek-language instrument. 
[^19-14]: Greece, Notarial Coordinating Circular 13/11.04.2024 (golden-visa amendments; €50,000 fine), 11 April 2024; [https://enotariat.gr/?p=14285](https://enotariat.gr/?p=14285) (accessed 2 August 2026). Greek-language document. 
[^19-15]: São Tomé and Príncipe, Decreto-Lei n.º 07/2025 (Regulamentação da Nacionalidade por Investimento ou Doação), Diário da República I Série N.º 33, pp. 429–440, 1 August 2025, Articles 3, 10, 11, 14, 16, 18 and 22; gazette facsimile at [https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf](https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf) (accessed 2 August 2026). Portuguese-language instrument. 
[^19-16]: São Tomé and Príncipe Citizenship by Investment Unit, cip.gov.st "Become a Citizen" page, archived capture of 17 July 2026; [https://web.archive.org/web/20260717032201/https://cip.gov.st/become-a-citizen](https://web.archive.org/web/20260717032201/https://cip.gov.st/become-a-citizen) (accessed 2 August 2026). Statement of the official programme site; the extended dependant categories have no located statutory basis. 
[^19-17]: IMI Daily, "São Tomé Introduces Remote Passport Issuance, Clarifies Three-Nationality Rule", 11 April 2026, reporting the Citizenship by Investment Unit director's memorandum of 10 April 2026; [https://www.imidaily.com/africa/sao-tome-introduces-remote-passport-issuance-clarifies-three-nationality-rule/](https://www.imidaily.com/africa/sao-tome-introduces-remote-passport-issuance-clarifies-three-nationality-rule/) (accessed 2 August 2026). Reported source; the memorandum is not public. 
[^19-18]: Greece, National Registry of Administrative Public Services, "Πολιτογράφηση Αλλογενών Αλλοδαπών" (naturalisation of foreign nationals), last updated 30 July 2026; [https://mitos.gov.gr/index.php/ΔΔ:Πολιτογράφηση_Αλλογενών_Αλλοδαπών](https://mitos.gov.gr/index.php/ΔΔ:Πολιτογράφηση_Αλλογενών_Αλλοδαπών) (accessed 2 August 2026). Greek-language record. 
[^19-19]: Regulation (EU) 2017/2226 (Entry/Exit System), Article 2(3)(c) and (e), consolidated version of 12 June 2026; [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02017R2226-20260612](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02017R2226-20260612) (accessed 2 August 2026). Article 2(3)(c) carries the qualifier "other than those covered by points (a) and (b)". 
[^19-20]: European Commission (DG HOME), "The Entry Exit System is fully operational since 10 April 2026. Who is exempt?", 27 July 2026; [https://home-affairs.ec.europa.eu/news/entry-exit-system-fully-operational-10-april-2026-who-exempt-2026-07-27_en](https://home-affairs.ec.europa.eu/news/entry-exit-system-fully-operational-10-april-2026-who-exempt-2026-07-27_en) (accessed 2 August 2026). 
[^19-21]: Regulation (EU) 2018/1240 (ETIAS), Article 2(2)(d), consolidated version of 12 June 2026; [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1240-20260612](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1240-20260612) (accessed 2 August 2026). 
[^19-22]: eu-LISA, ETIAS activity page ("currently not in operation"), status as at 2 August 2026; [https://www.eulisa.europa.eu/activities/large-scale-it-systems/etias](https://www.eulisa.europa.eu/activities/large-scale-it-systems/etias) (accessed 2 August 2026). 
[^19-23]: Belgian Immigration Office (IBZ), "Visa-free travel with residence permits — general principles", status as at 2 August 2026; [https://dofi.ibz.be/en/themes/entry/border-control/visa-free-residence-permits/general-principles](https://dofi.ibz.be/en/themes/entry/border-control/visa-free-residence-permits/general-principles) (accessed 2 August 2026). The only published national identity-matching standard located; treated as the strictest documented benchmark, not as the Schengen norm. 
[^19-24]: European Commission (DG HOME), "Temporary reintroduction of border control" and current notifications table, status as at 2 August 2026; [https://home-affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area/temporary-reintroduction-border-control_en](https://home-affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area/temporary-reintroduction-border-control_en) (accessed 2 August 2026). 
[^19-25]: European Commission (DG HOME), "Schengen area" page (29 countries; Cyprus and Ireland status), status as at 2 August 2026; [https://home-affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area_en](https://home-affairs.ec.europa.eu/policies/schengen-borders-and-visa/schengen-area_en) (accessed 2 August 2026). 
[^19-26]: Decision No 565/2014/EU of the European Parliament and of the Council, Articles 1, 2(1)(c) and 5, 15 May 2014; [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014D0565](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014D0565) (accessed 2 August 2026). 
[^19-27]: High Commission of the Republic of Cyprus in the United Kingdom, "Visa Information" (application of Decision No 565/2014/EU; Türkiye and Azerbaijan exception), status as at 2 August 2026; [https://cyprusinuk.com/visa-information/](https://cyprusinuk.com/visa-information/) (accessed 2 August 2026). Official mission site. 
[^19-28]: European Commission, Practical Handbook for Border Guards (2022 edition), pp. 74 and 95 and footnote 83; [https://home-affairs.ec.europa.eu/system/files/2022-11/Practical%20handbook%20for%20border%20guards_en.pdf](https://home-affairs.ec.europa.eu/system/files/2022-11/Practical%20handbook%20for%20border%20guards_en.pdf) (accessed 2 August 2026). The 2022 edition is stale for Bulgaria, Croatia and Romania and is relied on here only for the Cyprus points. 
[^19-29]: Greece, Circular 1/2026 of the Secretary General for Migration Policy, 21 April 2026; content via Sioufas & Associates note and IMI Daily, [https://www.sioufaslaw.gr/golden-visa-διευκρινίσεις-εφαρμογής-του-άρθρ-100/](https://www.sioufaslaw.gr/golden-visa-διευκρινίσεις-εφαρμογής-του-άρθρ-100/) (accessed 2 August 2026). The circular text itself has not been opened; content is reported from two concordant professional sources. 
[^19-30]: Court of Justice of the European Union (Grand Chamber), judgment of 29 April 2025 in Case C-181/23, *Commission v Malta*, EU:C:2025:283, operative part and paragraphs 96–102 and 106; [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0181](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0181) (accessed 2 August 2026). 
[^19-31]: Directive 2004/38/EC, Articles 2(1) and 3(1), consolidated version; [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004L0038-20110616](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004L0038-20110616) (accessed 2 August 2026). 
[^19-32]: Greece, KYA οικ. 53821/2014 of 21 October 2014 (private-insurance coverage minimums), signed text hosted by the Ministry of Migration and Asylum; [https://migration.gov.gr/wp-content/uploads/2020/05/ΚΥΑ53821_2014.pdf](https://migration.gov.gr/wp-content/uploads/2020/05/ΚΥΑ53821_2014.pdf) (accessed 2 August 2026). The instrument's formal survival under the current Immigration Code is unresolved; the amounts are stated as fixed under the predecessor Code and still applied in practice, subject to confirmation at the date of application. 
[^19-33]: Greece, Law 5038/2023 (Immigration Code), Articles 18 §§1 and 7–9 (equal treatment; access to education) and 84 §1 (qualifying period for family reunification), gazette facsimile of Government Gazette A′ 81/01.04.2023, Article 18 at pp. 4125–4126; [https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf](https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf) (accessed 2 August 2026). Greek-language instrument; same gazette facsimile as note 2.
[^19-34]: Greece, Ministry of Migration and Asylum, Secretary-General for Migration Policy, document ref. 265272/Σ.133411 of 25 October 2024, section I (entry of dependent members; biometric data from age six). Greek-language administrative document; no publicly retrievable copy was located, and the document is cited for the Ministry's own instruction on entry and biometrics only.
[^19-35]: Consolidated version of the Treaty on the Functioning of the European Union, Articles 18, 20, 21, 22, 45 and 49, OJ C 202, 7.6.2016; [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12016E/TXT](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12016E/TXT) (accessed 5 August 2026).
[^19-36]: International-school fee schedules for the 2026–27 school year, published by each school: ACS Athens, "Tuition and Fees", [https://www.acs.gr/admissions_financial_tuition_fees/](https://www.acs.gr/admissions_financial_tuition_fees/) (accessed 5 August 2026); St Catherine's British School, "School Fees 2026-27", [https://www.stcatherines.gr/admissions/school-fees/](https://www.stcatherines.gr/admissions/school-fees/) (accessed 5 August 2026); Byron College, "School Fees 2026-2027", [https://www.byroncollege.gr/admissions/fees/](https://www.byroncollege.gr/admissions/fees/) (accessed 5 August 2026); International School of Athens and Pinewood — The American International School of Thessaloniki, published 2026–27 schedules (verified 2 August 2026). Annual schedules, set by each school and subject to change; the ACS Athens divisional totals and the separately itemised registration and programme charges are stated as the school publishes them.
[^19-37]: National and Kapodistrian University of Athens, MD Programme in English, "Tuition fees" ("Tuition fees for the academic year 2026-2027 for EU and non-EU citizens are €17.000"); [https://medicen.uoa.gr/tuition-fees/](https://medicen.uoa.gr/tuition-fees/) (accessed 5 August 2026).
[^19-38]: Regulation (EC) No 883/2004 (coordination of social security systems), Articles 1(c) and 19(1), [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32004R0883](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32004R0883); and Regulation (EU) No 1231/2010 (extension to third-country nationals), Article 1, [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R1231](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R1231) (both accessed 5 August 2026).
[^19-39]: Greece, Law 4368/2016, Article 33 §§1, 2(α), 3 and 5 (free access to public health structures for uninsured persons), Greek-language instrument, cited by gazette and article reference; no official copy retrievable to research tooling was located. Whether an Article 100 holder without employment can obtain an AMKA was not established for this report.
[^19-40]: Greece, Law 4465/2017, Government Gazette A′ 47/04.04.2017, Articles 15, 16 §§1–3 and 7 and 17 §§1–3, transposing Directive 2014/92/EU on payment accounts, Articles 2(2), 15 and 16; Directive at [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0092](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0092) (accessed 5 August 2026). Greek-language transposing instrument, cited by gazette and article reference.
[^19-41]: Regulation (EU) No 260/2012 (technical and business requirements for credit transfers and direct debits in euro), Articles 3 and 9(1)–(2); [https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012R0260](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012R0260) (accessed 5 August 2026).
