Greece

Law 5221/2025 (Government Gazette 133A/28-07-2025,) is amending, among others, the Code of Civil Procedure and important articles of the Civil Code. The amendments to the Code of Civil Procedure (new Articles 807 para. 1, 808 and 808A), the Civil Code (Articles 1769, 1773 and 1778) and Legislative Decree 3082/1954 (Article 10), Government Gazette 257A, “on the publications of wills by notaries or consuls, etc.,” which concern the publication of wills and testaments and the declaration of a handwritten will as valid, shall enter into force on 1.11.2025, while the abolition of Articles 1770, 1771, 1772, 1774 and 1776 of the Civil Code concerning the above matters shall be effective from 1.1.2026. Thus, in the event of the testator’s death before 1.11.2025, the publication of wills and the issuance of certificates shall continue to be carried out by the Courts of First Instance. In the event of the testator’s death after 1.11.2025, the following shall apply: Competent for the publication of a testament is the Notary who drafted it or to whom it has been deposited or submitted, as well as, correspondingly, the Greek consular authorities (Art. 807 Code of Civil Procedure, 1769, 1773 Civil Code). The publication of a testament is effected by its entry, in its entirety, in the minutes drawn up and signed by the notary or the consul and the person who delivered it (in the case of a handwritten testament), a copy of which is entered in a special electronic platform for the publication of wills and testaments (“Register of Wills and Testaments”), the ownership, administration and management of which belongs to the notarial associations of the country (Art. 808 paras. 1,2 Code of Civil Procedure, 1769 para. 3, 1773 sec. d Civil Code). The originals of the testaments published, with their envelopes, shall be dated and signed by the notary or the consul and kept in their archive (Art. 808 para. 3 Code of Civil Procedure, 1769 para. 4, 1773 sec. c Civil Code). Copies of testaments and revocations of testaments, which have been published abroad, may be deposited with a Greek consular authority, and are sent to the Register of Wills and Testaments without delay, under the care of the consul who received them. The copies must be certified by the foreign authority that published the testament. If the testaments are drafted wholly or partly in a foreign language, there must be attached, upon their deposit, a translation into the Greek language of the foreign-language part, which is made by certified translators of the “Register of Certified Translators,” through the application “Certified Translators” of the Single Digital Portal “gov.gr,” a Greek consular authority, or a lawyer (Art. 808 para. 4 Code of Civil Procedure). The minutes of publication or refusal of publication of a testament by the notary or the consular authority may be challenged by opposition by any person having a legitimate interest before the single-member court of first instance of the place of residence or domicile of the deceased at the time of death, otherwise the single-member court of first instance of Athens (Art. 808 para. 6, 810 Code of Civil Procedure). Correspondingly, competent for declaring a published handwritten testament as valid is the notary who proceeded to its publication, and who is obliged to proceed to the declaration, by his act, provided that the applicant for the declaration appears before him through an attorney and with two (2) witnesses, who shall certify the authenticity of the handwriting and the signature of the testator, while in the case where, with the handwritten will, an exclusive heir is appointed who is not the spouse of the testator or a person with whom the testator has concluded a civil partnership or is not related to the testator by at least the fourth degree of kinship, the applicant for the declaration shall submit a handwriting expert’s report, in order to prove the authenticity of the handwriting and the signature of the testator. In this case, the minutes of publication shall be notified by the notary who proceeded to the declaration of the will as valid to the Greek State at the latest ten (10) days from the day following such declaration as valid (Art. 808A sec. a–d Code of Civil Procedure). For a testament published by a consular authority, competent to declare it valid is the notary who is designated through the Register of Wills and Testaments (Art. 808A sec. e Code of Civil Procedure).    

In accordance with Ministerial Decision (MD) 46982/2025 (Government Gazette 3542 B/ 08.07.2025), as from 01.01.2026, the penalties provided for in Article 50 of Law 4919/2022 concerning failure to comply with the provisions on publicity and registrations in the GEMI system will be implemented. The provisions of the above MD apply to all personal and capital companies, cooperatives, as well as branches and agencies of foreign companies, except for a) Limited Liability Social Association, b) Social Cooperative Enterprises, and c) Employees Associations. For companies under liquidation or special liquidation, the respective fine is reduced by half. More specifically, as of 01.01.2026, fines will be imposed by the competent GEMI Service for any violation of the obligations of publicity and correct and timely registration in GEMI. Based on the above Ministerial Decision, fines range from €50 to €100,000. The amount of the fine is determined on the basis of two criteria: first, the type and size of the entity, and second, the type of violation committed. The types of violations that incur a fine can be classified into the following eight (8) general categories: Violations regarding the correct, true and complete registration of information in the GEMI system upon the establishment of an entity, Art. 12 of Law 4919/2022 (€500 – €5,000). Failure to register the entity with the GEMI, Art. 16 of Law 4919/2022 (€1,000 – €10,000). Failure to include the required information in the corporate documents and letters, Art. 22 & 37 of Law 4919/2022 (€100 – €500). Delayed registration of acts that are subject to publicity with constitutive effect, e.g. amendment of articles of association, merger, division or conversion, dissolution, etc., Art. 25 of Law 4919/2022 (€100 – €500). Violations regarding the correct registration of information in the GEMI service in cases of automated registrations, i.e., without legality checks by GEMI, Art. 26 & 38 of Law 4919/2022 (€200 – €2,000). Failure to register publishable information and acts in the GEMI, Art. 30, 33, 34, 35, 39 & 43 of Law 4919/2022 (€200 – €2,000). Failure to submit financial statements within the applicable deadline (€1,000 – €100,000, which is threatened for companies listed on the Stock Exchange). Violations relating to the corporate name and trading title of an entity, Art. 54 of Law 4919/2022 (€200 – €2,000). The amount of the fine fluctuates depending on the legal type of the company, on the registration thereof to the GEMI Service of a Chamber or the central GEMI Service of the Ministry (i.e. the entities of ‘public interest’ of Art. 2 case l) of Law 4548/2018 and those licensed by the Hellenic Capital Market Commission), and, in addition, with regard to the above categories (v) – (viii), on the size of the company being classified as very small, small, medium or large based on Greek Accounting Standards (Law 4308/2014). Indicatively, the following information and acts are subject to publicity by registration to GEMI: the annual financial statements approved by the ordinary meeting and the election of auditors, amendments to the articles of association, including capital increases or reductions, the confirmation of payment of capital in case of SA and PC, the appointment and details of the members of the management (legal representatives), the details of the partners as well as their departure or entry into the company, the approval of transactions with related parties in the case of SA, the liquidation, dissolution, or transformation of a company, the change of registered office, the financial statements of the foreign company in the case of a branch, etc. How shall the violation be detected? a) Ex officio through the automatic checks of the system, b) ex officio upon a relevant control, c) following notification of the violation to GEMI by another public service or authority, d) following a random control, or e) following a complaint. The current framework provides initially for the notice to the liable persons to remedy the violation and, then, in case of non-timely compliance, for the notification of fine impose, granting a right to the liable persons to submit their opinions (prior hearing), within fifteen days of the relevant notification. The process at all stages is made digitally. If the fine is not paid timely (30 days), it is then assessed to and collected by the Independent Authority of Public Revenues. The amount of the fine is reduced by half if the liable person, within thirty (30) days of the date of notification of the fine, pays it and also remedies the respective violation. In the event of repetition of a violation within a period of three years, the amount of the fine imposed is doubled, while in the event of repeated violations within the same period, the amount of the fine is tripled. Finally, according to the above MD, information and acts that have not been registered may be submitted to GEMI until 31.12.2025, without the imposition of a fine. This note does not constitute a detailed presentation or interpretation of the legislative and regulatory framework, but aims to provide concise information on the new status, from 01.01.2026 onwards, that affects the daily operation of companies, in view of the activation of the mechanism for imposing fines for violations of the GEMI legislation based on Ministerial Decision 46982/2025. For any issues you may encounter or for further ad hoc information, it is recommended that you contact a legal advisor for appropriate guidance.  

The rise of remote work, especially after the Covid-19 pandemic, has highlighted the need for legislative flexibility and adaptation to the international practice of employees’ mobility and remote working by means of digital technologies, without restrictions on the employee’s place of residence. In this context, the Greek legal framework was reformed, initially by virtue of Law 4825/2021, and later by Law 5038/2023 (Immigration Code), enabling the issuance of a special entry visa for Digital Nomads (Visa D – Digital Nomads), which is valid for up to one year, and a residence permit (Residence Permit Type I.8.), which is valid for two years, with the possibility of renewal. More specifically, third-country nationals who wish to reside in Greece and work, either as self-employed professionals with economic activity abroad or under an employment or service contract with individuals or legal entities based outside Greece, by means of information and communication technologies, can apply for a Digital Nomad Visa and a Residence Permit, under the condition that they have sufficient financial resources of at least 3,500€ per month and full health insurance coverage. Additionally, the Law 5038/2023 enables holders of a Uniform Schengen Visa (Visa C), which permits a stay of up to 90 days within a 180-day period, to directly apply for a Digital Nomad Residence Permit, provided they meet the above-mentioned requirements. It is noted that a Digital Nomad Visa or Residence Permit does not grant to the holder the right to access the Greek labor market or engage in business activities in Greece, therefore, in such a case, the interested person shall assess the possibility to be subject to another type of residence permit. Having the right guidance and legal support, the transition process becomes simpler and more efficient. MStR Law, responding to the growing interest expressed by third-country nationals and remote workers in relocating to Greece, leverages its expertise and experience to support individuals seeking to obtain Digital Nomad residency status, provides the necessary legal services in matters of tax and labor law, as well as real estate rentals and acquisitions, ensuring compliance with applicable legal provisions and facilitating their establishment in Greece.  

The Legal Journey Behind the EO2 (Mavrovouni – Edessa, Giannitsa Bypass, Chalkidona Bypass) Road Axis Upgrade A Vision Brought to Life In the realm of infrastructure, transforming critical roadways represents a vision of progress—one that seeks to enhance safety, connectivity, and economic growth. The EO2 Road Axis construction, including the maintenance and upgrading of existing road networks, spanning vital sections from Mavrovouni to Edessa, including the Giannitsa and Chalkidona bypasses, exemplifies such a vision. This ambitious project involves the comprehensive improvement and expansion of the Thessaloniki–Edessa National Road, divided into five distinct sections. The project’s goal is to provide better access and connectivity while mitigating traffic congestion, ultimately benefiting both local and national interests. Our law firm, as the legal advisor to the contracting authority, has been deeply involved in the development of this transformative project, offering legal guidance and strategic support. We ensure the smooth progression of the project through its various stages, addressing the complex legal and regulatory challenges that arise. The Road Sections: A Complex Undertaking The EO2 upgrade is divided into five sections, each presenting its own unique legal, technical, and logistical challenges. These sections include the Halkidona Bypass, the Pellaia Greece Bypass, the Giannitsa Bypass, and the Mavrovouni–Edessa section. Our firm’s contribution spans all sections, focusing on addressing the intricate legal and technical hurdles involved in constructing a road network alongside existing infrastructure. Halkidona Bypass Section The new alignment of the Thessaloniki-Edessa National Road starts at the end of the existing technical bridging of the Axios River and its tributaries, extending to the constructed section of the Pellaia Greece Bypass. This section, approximately 6.34 km long, requires careful attention to land agreements and environmental approvals to ensure the smooth integration of the new road with the existing infrastructure. Pellaia Greece Bypass This section, part of the new National Road No. 2, has already been constructed with a cross-section width of 11 meters, including the hard shoulder (LEA), and 13 meters with the embankments. Future plans include expanding this section to the typical cross-section width of B4N*S, as will be done for new sections under the current partnership. The primary challenge involves adapting the existing infrastructure to accommodate future upgrades. Giannitsa Bypass Section The Giannitsa Bypass project involves the construction of side roads, intersections, bridges, culverts, and a retaining wall. Key features include 14 bridges and under/overpasses, totaling approximately 363.41 meters, 23 box or pipe culverts, and 25 Irish crossings. This section also includes 60 at-grade intersections, many located at the intersections of the side roads. The complex legal and technical requirements for these structures are essential to ensure both road safety and efficient traffic flow. Melissi-Mavrovouni Section This section forms part of the new National Road No. 2 and has already been constructed with a cross-section width of 11 meters, including the hard shoulder (LEA), and 13 meters with embankments. As with the Pellaia section, future modifications are planned to align this section with the standard B4N*S cross-section, in line with other new sections constructed under this partnership. The challenge here lies in managing future expansion while maintaining the integrity of the existing infrastructure. Mavrovouni-Edessa Section The proposed Mavrovouni–Edessa section involves the improvement of the Thessaloniki–Edessa National Road, specifically the road section between Mavrovouni and Edessa. This section, located in the Pella region, will feature a new road alignment with accompanying service roads to support local traffic. The key challenge is ensuring that the new design meets the traffic and environmental needs of both the local and regional areas while adhering to the necessary legal and environmental requirements.   Challenges Along the Way Integration of New and Existing Roadways One of the main challenges of the EO2 upgrade project lies in the integration of new road sections with existing networks. Particularly in the Halkidona, Giannitsa, and Mavrovouni–Edessa bypass sections, where the intersection of new and existing alignments created complex legal and technical issues. These required intricate coordination of legal agreements, design approvals, and environmental considerations. Environmental and Land Acquisition Challenges A key challenge was the acquisition of land for constructing the new road sections. The area involved multiple landowners with fragmented plots, requiring meticulous legal coordination. Our expertise ensured smooth land acquisition processes, preventing delays and the subsequent payment of any compensations that these delays may cause, thereby guaranteeing the availability of the necessary land for construction. Maintenance and Repairs A major aspect of the project involves the ongoing maintenance and repair of the road after its completion. Our firm has been instrumental in negotiating the terms of these agreements, ensuring that the contractor's obligations are clearly defined in the contract and that maintenance and repair conditions are aligned with the contracting authority's expectations. A Harmonious Partnership: The Public and Private Sectors United The EO2 upgrade project exemplifies the vital collaboration between the public and private sectors, which is essential for the successful delivery of large-scale infrastructure projects. This partnership combines the public sector's regulatory oversight and long-term vision with the private sector's efficiency, expertise, and capacity for innovation. The private sector entities have been central to the project, navigating its complexities with their specialized knowledge and resources. These preselected bidders are responsible for designing, constructing, and maintaining the road infrastructure, ensuring safety, sustainability, and timely delivery. Their expertise in road construction, bridge building, and environmental considerations has been key to overcoming technical challenges and ensuring the project proceeds without delay. As the project advances, the continued collaboration between the public and private sectors will be crucial to its success. The seamless integration of strategic oversight from the public authority with the private sector’s operational capacity remains fundamental to the project's timely and efficient completion. The Competitive Dialogue: Laying the Groundwork for Success The competitive dialogue phase has been critical in shaping the success of the EO2 Road Axis Upgrade. Now nearing completion, this phase allowed the contracting authority to discuss with prequalified bidders to refine technical designs, financial structures, and project specifications. The primary goal of this phase was to ensure that, in collaboration with the technical and financial advisors, the project met the highest standards of technical feasibility, legal compliance sustainability, and cost-effectiveness. A. Legal Expertise During the Competitive Dialogue Our firm played a crucial role during this phase, providing legal advice and strategic guidance. We ensured compliance with national and EU regulations, facilitated transparent communication, and helped resolve actual and potential legal issues, ensuring that all proposals aligned with the contracting authority's long-term objectives, thereby appropriately and effectively shaping the contractual documents. B. Key Challenges in the Dialogue Phase Several challenges arose during the dialogue phase, primarily in balancing the interests of the contracting authority with the proposals from bidders. Our firm helped maintain fairness and transparency, resolving potential conflicts and ensuring that bidders' expertise was fully integrated into the project’s development. C. Transition to the Next Phase: Competition Stage With the competitive dialogue phase concluding, the project is transitioning to the competition stage, where final proposals will be submitted and evaluated. The groundwork laid during the dialogue phase ensures that the selection of the contractor will be based on refined technical and financial proposals, setting the stage for the construction and maintenance phases. Conclusion: The Road Ahead The EO2 Road Axis Upgrade is more than just a physical transformation; it is a model of legal and technical collaboration. This project not only highlights the importance of public-private partnerships but also demonstrates how innovative legal strategies can overcome complex challenges. As the project moves toward completion, our law firm remains committed to ensuring its success and delivering a project that will serve both the public and private sectors for years to come, setting a benchmark for future infrastructure development in Greece.