Foreign Direct Investment (FDI) under the new Ministerial Decision in Greece

A. Overview

Ministerial Decision 64260/11.11.2025 (the “Decision”) completes the operational layer of Greece’s newly established foreign-investment screening regime under Law 5202/2025. Its role is narrowly procedural: it sets out how an investor interacts with the national screening mechanism, the documents that must be submitted, and the point at which the authorities’ review formally begins. While it does not introduce substantive rules, the Decision strengthens the regime’s functionality and supports Greece’s alignment with EU Regulation 2019/452 on the screening of foreign direct investment into the Union.

B. Framework of Application

The Decision governs every filing required for an investment falling within the scope of Law 5202/2025 establishing a national foreign direct investments (FDIs) screening regime It codifies the interaction between foreign investors, Directorate B1, and the Interministerial Committee, ensuring that applications are handled uniformly and that authorities receive a complete and comparable file across all sectors.

C. Submission Procedure

The filing process is the following:

1. Lodgment

Investors or authorised representatives submit an open folder to the General Protocol Office of the Ministry of Foreign Affairs. The physical file must include all required documents together with an electronic copy.

2. Protocol Numbering

Once filed, the Ministry issues a protocol number. The applicant then seals the folder and labels it in accordance with the identification criteria listed in Annex A.

3. Postal Filing Alternative

Applications may also be submitted by registered mail in a sealed folder. For timing purposes, the date the investor lodges the file with the postal service is deemed the submission date.

4. Five-Day Verification Period

The five-day review period under Article 7(2) of Law 5202/2025 — during which the B1 Directorate of Extroversion Planning and Coordination of Extroversion Bodies assesses both the investment’s eligibility and the completeness of the file — begins once the Secretariat receives the submission. Upon receipt, the Secretariat also issues and communicates the protocol number to the applicant.

D. Required File Components

The documents that must be provided in hard copy and digital format. These include:

1. Application in Greek and English.

2. Solemn declaration confirming the investment is within the screening framework.

3. Mandate or authorisation or power of attorney for the investor’s representative.

4. Investment contract(s), including side agreements and implementation timeline.

5. Updated registry extracts (GEMI) for the target company.

6. Evidence of the target’s ownership structure.

7. Excerpt issued by the Foreign Investor’s Commercial Registry in relation to the establishment, registered seat, scope, management, representation and its up-to-date amended articles of association.

8. Documentation of the investor’s shareholding structure.

9. Three years of audited financial statements.

10. UBO declaration issued domestically or through the Greek UBO registry.

11. Participation diagrams capturing corporate and individual holdings.

12. CVs of principal shareholders and management.

13. PEP declaration and confirmation of non‑involvement in terrorist activities.

14. For individuals acting as investors: identity documents and detailed CV.

E. Formal Standards

The Decision also reinforces the integrity of the overall filing process by imposing several formal requirements under Article 3, including the need for consistent information across all submitted materials, the acceptance of declarations in either Greek or English, the obligation to provide proper translations, certifications, and apostilles where required by the document’s jurisdiction of origin, and a clear hierarchy under which the printed submission prevails over the digital version in the event of any discrepancy.

F. Final Remarks

By detailing the format, content, and workflow of the filing process, the Decision completes the operational framework of Law 5202/2025. Screening now moves from statutory concept to a functioning review system, giving both investors and authorities a predictable procedural baseline while Greece begins implementing its national-security review obligations.