Greece has fired a warning shot at the networks behind fake golden visa property deals. Circular 1/2026, a 31-page directive signed by Secretary General for Migration Policy Konstantina Papakosta, tells one-stop services across the country to refer misleading advertisements and sham investment transactions to the tax authority (AADE) and the Hellenic Anti-Money Laundering Authority.
That anti-fraud provision occupies only the circular’s final two pages. The other 29 pages do something practitioners may find equally consequential: They resolve 22 procedural questions that had generated inconsistent treatment of applications from one regional office to the next.
The Fraud Problem
Since Greece raised its golden visa thresholds in September 2024, social media and overseas platforms have been flooded with ads promoting properties at €180,000 to €230,000 as golden-visa-eligible.
The mechanism, as described by Greek financial outlet Mononews, works like this: A buyer pays the full statutory price on paper (€800,000 in Athens, say), then receives a portion back through prepaid rent agreements, furniture allowances, or undocumented cash.
Alexander Varnavas of Varnavas Law Firm, which also prepared the unofficial English translation of the circular, explained that such advertising had been observed over the past year. Authorities have long reviewed contracts for concealed refunds designed to circumvent the legal minimums, he told IMI, but political pressure to intensify those investigations appears to be mounting.
Clarification 23 does not define what triggers an investigation. It states that when the ministry identifies or receives complaints about such practices, it will forward them to the tax authority and the AML authority. Confirmed violations will result in sanctions under Article 100 of Law 5038/2023, including permit revocation.
Mononews reported that Migration Minister Thanos Plevris has assembled a dossier on firms believed to be involved. That claim comes from Mononews, not from the circular or the ministry directly, and should be treated accordingly.
Varnavas told IMI that any promotion of a golden visa investment below €250,000, the current floor for real estate, “should be treated as a clear red flag.” Retaining a specialist lawyer is, in his view, “no longer optional but essential,” given that the framework now imposes eligibility criteria at the level of the property itself, particularly for change-of-use and listed-building projects.
Not everyone in the market views the crackdown with alarm. For Mercan Greece President Theodoros Kioutsoukis, the tightening is overdue: Investments must be “genuine, transparent, and fully traceable,” he told IMI.
Enforcement cooperation between the ministry, tax authorities, and the AML authority demonstrates a commitment to protecting the program, not undermining it, Kioutsoukis argues. For institutional developers operating within a regulated framework, “this evolution is not a challenge but an opportunity.”
Thresholds Restated
None of the investment thresholds are new; all were set by Article 64 of Law 5100/2024 in September 2024. The circular restates them as a reference for one-stop services.
In the Region of Attica, the Regional Unit of Thessaloniki, the Regional Units of Mykonos and Thira (Santorini), and islands with more than 3,100 inhabitants, the minimum is €800,000 for a single property of at least 120 square meters of main areas. Everywhere else, it is €400,000 with the same constraints.
A €250,000 route survives for two categories: Properties converted from non-residential to residential use, and listed buildings requiring restoration. Neither carries a minimum surface area requirement.
Single Property, One-Time Use
Law 5100/2024 introduced the single-property requirement, but questions lingered about whether it applied to every investment category. The circular confirms it does. Multi-property portfolios are dead across all four routes.
Ancillary spaces (parking and storage) purchased in the same deed and building may count toward the minimum price, but not toward the 120 sq. m. floor.
The circular’s worked example: An investor buys a 60 sq. m. apartment in a converted industrial building for €248,000 and an underground parking space for €8,000 under the same deed. Total: €256,000. It qualifies under the €250,000 change-of-use route because migration law does not treat the parking space as a separate property.
Converted and listed-building properties may be used for a golden visa only once under the €250,000 threshold. If the first permit holder sells the resulting residence to another third-country national, that buyer must meet the standard €400,000 or €800,000 thresholds. Once the conversion is done and the first permit granted, the favorable threshold is spent.
Change of Use: Where the Circular Gets Specific
Law 5100/2024 created the €250,000 change-of-use pathway, but left regional offices to interpret the details. Conflicting readings had turned it into a minefield, and several clarifications now close the gaps.
A conversion must have occurred after 5 April 2024, when Law 5100/2024 took effect. Properties that were already residential on that date cannot be flipped to commercial and back again to qualify at €250,000.
Off-plan projects face the same barrier: If a building permit was issued for offices and later amended to construct residences, no existing property has physically changed use. Only an actual building changing function counts, not a blueprint.
Industrial buildings may qualify, provided no industrial undertaking operated there for at least five years. Handicraft and workshop buildings are exempt from this waiting period.
Mixed-use conversions are also possible: If part of a former factory becomes offices and part becomes apartments, only the residential units qualify at €250,000. The commercial portions must meet the standard thresholds.
Either the buyer or the seller may carry out the conversion. That detail, buried in Clarification 5, gives developers flexibility to convert buildings before selling individual units to golden visa applicants.
Browse Greek Golden Visa Qualifying Properties on IMI Real Estate
Grandfathering for Legacy Investors
Clarification 6 addresses a question that had gone unanswered for months. Investors who purchased property at the old €250,000 threshold but never applied for a residence permit can still do so, provided three conditions are met: The investment was completed before the new financial criteria took effect, it met the thresholds applicable at the time, and payment was made in accordance with current requirements (meaning a notary’s certificate substantiating the method of payment is required).
The same logic applies to investors whose permits expired without renewal. They may re-enter the program under the thresholds that applied when they originally bought, as long as they can document how they paid.
Airbnb Ban: Narrower Than It Sounds
Law 5100/2024 banned short-term rentals on golden visa properties, but left the exact scope ambiguous. The circular now defines it, and the prohibition is narrower than many assumed.
It covers only lettings of fewer than 60 days where no services beyond accommodation and bed linen are provided. Long-term leases to tourism enterprises operating hotel-type businesses remain permitted, provided additional services are offered. And properties purchased under previous thresholds or within the transitional period are not subject to the ban at all.
Change-of-use properties face one extra restriction: They may not serve as the registered seat or branch of a business.
Swapping Properties Without Losing the Permit
Investors who want to replace their qualifying asset must buy the new property before selling the old one. The one-stop service verifies the replacement, and only then may the investor dispose of the original.
Sell first, buy second, and the service will partially revoke the permit. The investor would then have to re-enter Greece and file a fresh initial application.
Procedural Fixes
Several clarifications deal with the paperwork bottlenecks that have slowed the program:
Encumbrance certificates are no longer required for initial applications and should not be requested by one-stop services, even for cases filed before 31 March 2024 under the old law. Where property registration at the Mortgage Registry or Cadastral Office is delayed, services may issue the permit based on proof that the registration application has been filed; the final documents can follow during the five-year permit or at renewal.
Proof of connection to utility networks (electricity, water) is not required in any category. For off-plan purchases, the investment is often complete before construction. For conversions, the change of use is certified by an engineer’s report, not by whether the power is on.
Varnavas expects the procedural clarifications to improve application quality and possibly speed up processing. Greater consistency in how one-stop services review files “reduces ambiguity and enhances predictability,” he told IMI, calling the overall impact on investors “largely positive.”
Employment, Sanctions, Insurance, and the Olomeleia Portal
Golden visa holders still cannot work in Greece. They may own shares and sit on boards as non-executive members, but may not serve as legal representatives or executive directors.
The suspension on Russian and Belarusian applicants remains in force, and now explicitly extends to change-of-purpose applications under Article 12 of Law 5038/2023. Beneficiaries of international protection whose status was granted by another EU member state or a third country (rather than Greece) may apply for a golden visa like any other third-country national.
All lawyer-submitted applications must go through the “Olomeleia” portal. Submissions filed outside this system using the lawyer’s personal credentials will be archived without fee refund.
Applicants must hold valid insurance at the time of filing. If it is missing, the authority grants 30 calendar days to produce it. After that, the application is rejected.
The Numbers Behind the Crackdown
Demand has never been higher. Approvals reached 8,879 in 2025, up approximately 96% from 4,535 the year before, according to data reported by Greek media.
As of February 2026, Chinese nationals account for 48.1% of all initial investor permits (10,593), followed by Turkish nationals at 16.3% (3,578). Lebanon, Iran, the UK, Israel, the US, Egypt, Armenia, and Serbia round out the top ten.
More than €5 billion has flowed into Greek real estate through the program over its lifetime, per Mononews. With volumes like these, the incentive to inflate declared prices and return cash under the table is considerable, and so is the government’s incentive to be seen cracking down.
Whether that crackdown produces systematic audits or functions mainly as deterrence will shape how much the circular actually changes on the ground.
Kioutsoukis sees the direction of travel as unambiguous: Tighter rules “strengthen confidence in the market” and protect compliant investors.
Varnavas argues the changes also align Greece with broader EU expectations around investment migration, strengthening the program’s international credibility as one of eight European golden visas still operating.
