Foreign investment screening in Greece

In short

Some investments in Greece by investors from outside the European Union must be filed with the Greek state and reviewed before they are completed.

Law 5202/2025, in force since 23 May 2025, sets up a national screening mechanism that applies Regulation (EU) 2019/452. The committee was set up by Cabinet Act 11/2025, and the filing procedure has applied since 11 November 2025 (JMD 64260/2025). The review looks only at whether the investment may affect security or public order. It concerns businesses governed by Greek law that are active in a list of sensitive sectors, and it starts at a holding of 25% in the business, or 10% in the most sensitive sectors.

An investment outside the listed sectors, or below the thresholds, does not need this filing. Where the filing is required, it has to be made before the investment is completed, so the question is best settled before the transaction documents are signed.

What we do for the investor

The work usually covers these steps:

01
Assessment of whether the investment needs to be filed: the investor's ownership chain up to the persons or the state that ultimately control it, the activity of the target against the listed sectors, and the percentage to be acquired, counted as the law requires.
02
A check of whether the target or its subsidiaries own real estate in a border area, and whether Chapter B of Law 1892/1990 applies.
03
Advice on the transaction documents, so that completion is conditional on clearance and the timetable allows for the review.
04
Preparation of the file: the application in Greek and English, the declaration, and the corporate, ownership and financial documents, with translations and apostilles for documents issued abroad.
05
Lodging the file with the Ministry of Foreign Affairs and dealing with the B1 Directorate on requests for corrections, further information and any hearing.
06
Advice on mitigation measures that the decision may impose, and on the position of an investment that has already been completed without a filing.

01

The legal basis

Law 5202/2025 (Government Gazette Α' 84/23.5.2025) sets up the Greek mechanism for screening foreign direct investments on grounds of security or public order and contains the measures that apply Regulation (EU) 2019/452 in Greece. It has been in force since its publication on 23 May 2025.

Two further acts complete it. Cabinet Act 11 of 28 May 2025 (Gazette Α' 97/11.6.2025) established the committee that carries out the review. Joint Ministerial Decision 64260 of 10 November 2025 (Gazette Β' 6009/11.11.2025), issued by the Ministers of Foreign Affairs and of Development, sets the filing procedure, the application form and the supporting documents. It has been in force since its publication on 11 November 2025.

The list of sectors is an Annex to the law and can be amended by joint ministerial decision, so it should be checked in its current form for each transaction.

02

Which investors are covered

The first case is the plain one: an investor from a third country, meaning a person or a company from outside the European Union, invests in a business that is active in one of the listed sectors.

The law also looks through investors established in the EU. An EU investor is covered where it is controlled by a person or company of a third country, or directly or indirectly by the government of a third country, including state bodies and through the ownership structure or significant funding, and the target is active in a listed sector. In the most sensitive sectors, it is enough that a third-country person, company or government holds at least 10% of the EU investor.

The business invested in, which the law calls the target, is one that has been or is about to be established under Greek law or is otherwise governed by it. The mechanism therefore covers the purchase of a holding in an existing business, the setting up of a new one, and a joint venture in which a foreign investor takes part.

03

Sectors and thresholds

Sensitive sectors. An investment is screened where it concerns infrastructure, assets, goods or services that are essential in energy, transport, health, information and communication technologies or digital infrastructure, and the holding in the target reaches at least 25%. It is screened again when the holding rises to 30%, 40%, 50% and 75%.

Particularly sensitive sectors. The threshold is 10% where the activity of the target concerns defence and national security (including dual-use items and military equipment on the EU lists), cybersecurity or artificial intelligence, port infrastructure, critical subsea infrastructure, or tourism infrastructure in border areas. Here an investment is screened again when the holding rises to 20%, 25%, 30%, 40%, 50%, 60%, 70% and 75%.

The percentage is not counted on the investor's own shares alone. Shares held by companies of the investor's group, by members of the investor's family and by organisations or foundations they control are added, and agreements outside the articles, such as agreements on the exercise of voting rights, are taken into account.

04

What is not covered

The law excludes portfolio investments, that is, securities acquired by individuals purely as a financial investment, without the intention or the possibility of influencing the management or control of the business.

It also excludes restructurings within a group and mergers of several entities into one, provided that the shares or the percentage of control and influence held by foreign investors do not increase and no additional rights arise that change their real participation in the management or control of the target.

Finally, it does not apply to tender procedures that were pending when the law came into force and in which a binding offer had been received, or to contracts for the development of assets that had not been completed by that date.

05

Who decides

The review is carried out by the Interministerial Committee for the Screening of Foreign Direct Investments (ΔΕΕΑΞΕ), a government committee in which the Ministries of Foreign Affairs and of Development always take part. The final decision to approve, prohibit or unwind an investment, or to impose specific conditions or mitigation measures, is taken by the Minister of Foreign Affairs on the committee's recommendation.

The B1 Directorate of the Ministry of Foreign Affairs (Directorate for Extroversion Planning and Coordination of Extroversion Bodies) acts as the committee's secretariat and coordinates the procedure. During the review it is the investor's only point of contact.

06

The procedure and its time limits

The investor files the application and the complete file with the B1 Directorate before the investment is completed. The law defines completion as the moment when the last condition precedent of the parties' investment decision is satisfied.

Within 5 days of receiving the application, the B1 Directorate confirms that the investment falls within the law and checks that the file is formally complete; if something is missing or wrong, it asks the investor to correct or complete it. Within 10 days of the first notice, or of the corrected or completed file, it passes the file to the chair of the committee.

Within 30 days of receiving the file, the committee either decides unanimously that the investment is released from screening or opens an in-depth investigation. In an in-depth investigation the committee may ask for further information and documents and may invite the investor to a hearing. Within 30 days of opening it, the committee recommends approval, prohibition or specific conditions or mitigation measures; it may extend this period by 30 days with a reasoned decision. The period is also suspended while comments from another EU member state or an opinion of the European Commission are awaited, and for 20 days where the committee takes expert advice. Delay by the investor in providing information is a ground for extension.

The Minister of Foreign Affairs then decides, within an indicative period of 30 days from the recommendation. If no decision is issued within 60 days of the recommendation, the investment is deemed approved. Where the target is, or is about to become, unable to pay its debts, the committee may decide that the time limits of the review under article 8 are halved. In exceptional cases the committee may recommend mitigation measures or a prohibition without an in-depth investigation.

07

What the file contains

Under Joint Ministerial Decision 64260/2025 the file is lodged on paper with the General Protocol of the Ministry of Foreign Affairs, by the investor, its legal representative or an authorised person, or is sent by registered post. It contains the application in Greek and in English, a solemn declaration and a USB stick with the same documents in digital form.

The supporting documents include the investment agreement with any side letters and the timetable, or a letter of intent where the agreement has not yet been signed; recent commercial registry extracts and evidence of the shareholding of both the target and the investor; the investor's last three published financial statements with the auditors' reports; its beneficial ownership declaration; a chart of its holdings; the curricula vitae of its main shareholders and management; and a declaration on politically exposed persons. An investor who is an individual files a copy of the passport and a detailed curriculum vitae instead of the corporate documents.

Documents issued abroad must be translated into Greek and carry an apostille, or consular legalisation where the Hague Convention does not apply.

08

Closing without clearance

If an investment that falls within the law is not filed, or is filed after it has been completed, that is in itself a ground for imposing mitigation measures or for unwinding it. The committee may also open the review on its own initiative.

A decision of the Minister of Foreign Affairs that prohibits or unwinds an investment, or imposes specific conditions or mitigation measures, makes the related investment transactions void by operation of law. The decision may order the reversal of the share sale, set a deadline for compliance and require any other measure needed to remove the effects of the transaction. The investor may keep a holding in the target that does not exceed the thresholds of article 6.

There are also administrative fines. A fine of €5,000 to €100,000 applies to an investor who does not file, does not provide the information or documents required (unless the investor has declared in writing that it withdraws from the investment), or makes false statements. A fine of up to twice the value of the investment applies to an investor who proceeds despite a prohibition, obtains approval on false information or does not comply with the mitigation measures or the unwinding ordered. Failure to submit the documents requested within the time limits, or the submission of false information, is a ground for prohibiting the investment. Fines are imposed by the Minister of Foreign Affairs after the investor has been heard. The authority, procedure and method of collection of the fines are to be set by a joint decision of the Ministers of National Economy and Finance and of Foreign Affairs.

09

The EU cooperation mechanism

When an in-depth investigation opens, the B1 Directorate notifies the investment to the European Commission and to the other EU member states under Regulation (EU) 2019/452. Other member states may send comments and the Commission may issue an opinion within the time limits of the Regulation; while these are awaited, the committee's 30-day period is suspended.

For the purposes of the Regulation the B1 Directorate may ask companies and individuals for information on planned or completed investments, which must be provided within 25 days.

Regulation (EU) 2026/1386 of 17 June 2026 replaces Regulation (EU) 2019/452, which it repeals with effect from 17 January 2028 (art. 30). It applies from 17 January 2028, with some provisions applying from 16 July 2026 (art. 31). Any change to the Greek rules should be checked for each transaction.

10

Border areas

Law 5202/2025 is expressly without prejudice to Chapter B of Law 1892/1990 (Α' 101) on transactions in border areas, and lists tourism infrastructure in border areas as a particularly sensitive sector.

11

Sources

Statutes and official sources for the facts on this page, read on 11 November 2026. The page is general information, not legal advice.

Law 5202/2025 (Gazette Α' 84/23.5.2025), measures applying Regulation (EU) 2019/452 on the screening of foreign direct investments: https://ia37rg02wpsa01.blob.core.windows.net/fek/01/2025/20250100084.pdf
Joint Ministerial Decision 64260/10.11.2025 (Gazette Β' 6009/11.11.2025): procedure, application and supporting documents: https://ia37rg02wpsa01.blob.core.windows.net/fek/02/2025/20250206009.pdf
Cabinet Act 11 of 28.5.2025 (Gazette Α' 97/11.6.2025): establishment, composition and operation of the Interministerial Committee for the Screening of Foreign Direct Investments (ΔΕΕΑΞΕ): https://ia37rg02wpsa01.blob.core.windows.net/fek/01/2025/20250100097.pdf
Regulation (EU) 2019/452 of 19.3.2019 establishing a framework for the screening of foreign direct investments into the Union: https://eur-lex.europa.eu/eli/reg/2019/452/oj
Law 1892/1990 (Gazette Α' 101), Chapter B: transactions in border areas

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FAQ

Questions clients ask

Does every foreign investment in Greece have to be filed for screening?

No. The filing under Law 5202/2025 is required only where the investor is from outside the EU, or is an EU investor controlled or partly held by third-country persons or governments as the law describes, the target is active in one of the sectors listed in the Annex to the law, and the holding reaches 25%, or 10% in the particularly sensitive sectors.

When must the filing be made?

Before the investment is completed. The law defines completion as the moment when the last condition precedent of the parties' investment decision is satisfied. A filing made after completion is, like a missing filing, a ground for mitigation measures or for unwinding the investment.

How long does the screening take?

The law sets 5 days for the first check of the file, 10 days for it to reach the committee and 30 days for the committee either to release the investment from screening or to open an in-depth investigation. An in-depth investigation runs for 30 days, which can be extended by 30 more and suspended in certain cases, and the Minister of Foreign Affairs then decides. If the Minister issues no decision within 60 days of the committee's recommendation, the investment is deemed approved.

Is an investor based in the EU exempt?

Not always. An investor established in an EU member state is covered if it is controlled by a person or company of a third country or by a third-country government and the target is in a listed sector. In the particularly sensitive sectors it is enough that a third-country person, company or government holds at least 10% of the EU investor.

What happens if the investment is completed without a filing?

The committee can open the review on its own initiative. The lack of a filing is a ground for mitigation measures or for unwinding the investment, and the investor is liable to an administrative fine of €5,000 to €100,000. If the Minister of Foreign Affairs prohibits or unwinds the investment, or imposes specific conditions or mitigation measures, the related transactions are void by operation of law.

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