Greece's Register of Disqualified Directors: what boards and shareholders should check.

Duration and consequences

The appointment of a disqualified director is void (article 56α par. 3). The disqualification lasts 15 years from the date the judgment became irrevocable where the custodial sentence exceeds five years, and five years where it is up to five years (article 56β). The ΓΕΜΗ and One-Stop-Shop systems are linked to the register and block the registration of a listed person in any of these roles (article 56δ par. 2).

Fines (article 56ζ): a disqualified director who knowingly manages company affairs faces a fine of €20,000 to €500,000; a company that knowingly entrusts its management to a disqualified director faces €50,000 to €1,000,000. Law 5338/2026 extended the ministerial power to set the criteria and procedure for these fines (article 57 par. 18 of Law 4919/2022).

What changed in October 2026

Article 38 of Law 5338/2026 made the following changes, in force from publication on 5 October 2026:

• Access: besides the authorities of article 6 of Law 4557/2018, the Anti-Money Laundering Authority and the business registers interconnection system (BRIS), the register is now open to the National Transparency Authority and the Hellenic Competition Commission.
• Private persons: they may obtain information from the register if they have a reasonable interest (εύλογο ενδιαφέρον) under article 5(2) of the Code of Administrative Procedure. The previous text required a specific legal interest (ειδικό έννομο συμφέρον).
• Data sources: the register is fed electronically, in particular from ΓΕΜΗ and, in place of the Insolvency Register and the e-justice portal, from the National Criminal Record kept by the Ministry of Justice.
• EU exchange: ΓΕΜΗ exchanges information on disqualified directors, the length of and grounds for disqualification with other EU Member States through BRIS, which replaces the e-justice portal for this exchange. A joint ministerial decision will settle interoperability with the National Criminal Record.

What boards, shareholders and buyers should check

Practical steps, not a statement of law:

• Before appointing a board member, manager or liquidator, ask for a written confirmation that the person is not disqualified in Greece or in another EU Member State, and keep it with the company records.
• In an acquisition or a new joint venture, include the disqualification check in the due diligence on the target's managers and in the seller's warranties.
• If you have a reasonable interest, for example as a shareholder, creditor or prospective counterparty, consider a request for information from the register through ΓΕΜΗ.
• Foreign directors: disqualification in another Member State on the same grounds also counts, so ask about every country where the person has served.