Greece has just taken a decisive step to connect startup investment with long-term residency opportunities for non-EU nationals. With the new Joint Ministerial Decision 216761/2025, the state clarifies which documents are needed, how investments in Greek startups are certified, and how the holding of these investments is monitored under Article 100A of the Migration Code (Law 5038/2023). In practice, third-country investors who place capital in startups registered in the National Registry of Start-up Enterprises can now obtain and maintain a residence permit in Greece, provided specific investment and job-creation conditions are met. For the Greek innovation ecosystem, this framework creates a clear, institutional “bridge” between international capital and fast-growing Greek startups — and Startup Greece is here to help founders and investors navigate what this means in real terms.
Golden Visa for Startups: Detailed Requirements for Investments Under Article 100A
December 1, 2025 • by admin
216761/12-11-2025
Determination of the supporting documents for carrying out an investment in start-up enterprises and of the supporting documents and method for monitoring the holding of the investment, in accordance with Article 100A of Law 5038/2023
Decision No. 216761/2025
(Government Gazette B’ 6138/18-11-2025)
THE MINISTERS
OF FOREIGN AFFAIRS – OF DEVELOPMENT – OF MIGRATION AND ASYLUM
Having regard to:
-
The provisions of:
a) Article 176, paragraph 47A, points (a) and (b) of Law 5038/2023 “Migration Code” (Government Gazette A’ 81),
b) Article 100A of Law 5038/2023 “Migration Code” (Government Gazette A’ 81),
c) Article 90 of the Code of Legislation for the Government and governmental bodies (Presidential Decree 63/2005, Government Gazette A’ 98), which was maintained in force by point 22 of Article 119 of Law 4622/2019,
d) Presidential Decree 77/2023 “Establishment of a Ministry and renaming of Ministries – Establishment, abolition and renaming of General and Special Secretariats – Transfer of competences, service units, staff positions and supervised entities” (Government Gazette A’ 130),
e) Presidential Decree 79/2023 “Appointment of Ministers, Alternate Ministers and Deputy Ministers” (Government Gazette A’ 131),
f) Presidential Decree 106/2020 “Organisation of the Ministry of Migration and Asylum” (Government Gazette A’ 255),
g) Presidential Decree 5/2022 “Organisation of the Ministry of Development and Investments” (Government Gazette A’ 15),
h) Presidential Decree 32/2024 “Appointment of Ministers and Deputy Ministers” (Government Gazette A’ 32),
i) Presidential Decree 58/2025 “Appointment of Minister and Deputy Ministers” (Government Gazette A’ 111),
j) Law 4781/2021 “Organisation and operation of the Ministry of Foreign Affairs, Council of Hellenes Abroad, Regulation of issues of international development cooperation and humanitarian assistance and other provisions” (Government Gazette A’ 31), and
k) Article 171, paragraph 1, point (c) of Law 5038/2023 “Migration Code” (Government Gazette A’ 81). -
Joint Ministerial Decision No. 115/2023 of the Prime Minister and the Minister of Foreign Affairs “Delegation of competences to the Deputy Minister of Foreign Affairs, Alexandra Papadopoulou” (Government Gazette B’ 4524).
-
Joint Ministerial Decision No. 34693/21-02-2025 of the Ministers of Migration and Asylum and Development entitled “Determination of the procedure and other issues relating to the granting of an entry visa and residence permit in Greece to third-country nationals for investment purposes” (Government Gazette B’ 1136).
-
The report No. 142234/1.8.2025 of the General Directorate of Financial and Administrative Services, according to which no expenditure is caused to the current budget (ordinary and public investment) of the Ministry of Migration and Asylum.
-
The fact that by the provisions of this decision, the administrative procedure No. 131270, with the official title “Recommendation for the classification of investment plans in the context of granting residence permits to third-country nationals” in the National Register of Administrative Procedures “Mitos”, is amended,
we decide:
Article 1
Purpose
This decision is issued for the purpose of determining:
a) the supporting documents for the implementation of an investment by natural or legal persons in start-up enterprises, which are registered in the National Registry of Start-up Enterprises of the company “National Registry of Start-up Enterprises S.A.” of Article 72 of Law 4914/2022 (Government Gazette A’ 61),
b) the number of third-country nationals in the case of an investment carried out by a foreign legal person, in accordance with point (b) of paragraph 3 of Article 100A of Law 5038/2023,
c) the supporting documents for the holding (retention) of the investment, and
d) the method of monitoring the holding of the investment.
Article 2
Procedure
-
The procedure for certifying the implementation of investments in start-up enterprises, in accordance with the provisions of Article 100A of Law 5038/2023, as well as the procedure for monitoring the holding of the investments of that Article, is determined by the provisions of Joint Ministerial Decision No. 34693/21-02-2025 of the Ministers of Development and of Migration and Asylum entitled “Determination of the procedure and other issues relating to the granting of an entry visa and residence permit in Greece to third-country nationals for investment purposes” (Government Gazette B’ 1136), as well as by the provisions of Articles 6 and 7 of this decision.
-
The procedure for the entry of third-country nationals who wish to make an investment in start-up enterprises, in accordance with the provisions of Article 100A of Law 5038/2023, is determined by the provisions of Article 94 of Law 5038/2023.
Article 3
Supporting documents for certifying the implementation of the investment
The supporting documents for certifying the implementation of the investment are the following:
a) A certificate, issued within the last two months, from the company “National Registry of Start-up Enterprises S.A.” of Article 72 of Law 4914/2022 (Government Gazette A’ 61), stating that the enterprise in which the investment is made is registered in the National Registry of Start-up Enterprises at the time of payment of the contribution, in accordance with paragraph 1 of Article 100A. The certificate must also state the date on which the enterprise was registered in the “National Registry of Start-up Enterprises S.A.”.
b) Concerning the acquired securities in the start-up enterprise:
ba) Where the acquired securities are registered (nominative), a certificate of the start-up enterprise in which the capital is contributed, duly signed and certified, shall be submitted. The certificate shall contain the following:
i) The details of the capital increase carried out or of the issuance of the bond loan in which the investor participated.
ii) The details of the relevant announcements in the General Commercial Registry (G.E.MI.) concerning the decision of the General Meeting on the capital increase and the decision on Certification of Capital Contribution, or the corresponding decisions for the issue of the bond loan, and
iii) The number of shares or bonds acquired, the time and acquisition value (paid consideration) thereof, the percentage of the company’s capital and the percentage of voting rights held, as well as confirmation that these securities (shares or bonds) have been held up to the date of issuance of the certificate.
bb) Where the acquired securities are traded on regulated markets or multilateral trading facilities operating in Greece:
i) A certificate from the intermediary, investment firm or credit institution, stating the creation and details of the investor’s personal account in the Dematerialised Securities System (D.S.S.), the company in which they invested, the number of shares or bonds acquired and the acquisition value (paid consideration) thereof, as well as confirmation that these securities have been held up to the date of issuance of the certificate, and
ii) A certificate from the start-up enterprise in which the capital is contributed, stating the percentage of the company’s capital and the percentage of voting rights held by the investor after the implementation of the investment.
c) A certificate from a credit institution with the details of the relevant transfer(s) (remittance(s)) for the implementation of the investment (amount remitted, amount and date of crediting the beneficiary’s account, the ordering party and their relationship with the beneficiary/beneficiaries or joint beneficiaries and country of origin) and a bank document (account statement showing the transfer to the intermediary). In the event that the transfer is ordered by the spouse, the other party to a civil partnership and/or relatives by blood or marriage up to the second degree of the investor, the details of the third-party ordering person(s), the degree of kinship and recent certificates of family status or other equivalent documents issued by the country of origin, duly legalised and translated, proving the kinship relationship, shall also be submitted.
d) A Staff Table (employee registry) from the “ERGANI” information system, from which the creation of two (2) new jobs within one year from the implementation of the investment is evidenced, in order to establish compliance with the condition of creating new jobs under point (b), paragraph 2 of Article 100A of Law 5038/2023, or a Solemn Declaration (Υπεύθυνη Δήλωση) by the legal representative of the enterprise registered in the National Registry of Start-up Enterprises, bearing an authentication of the signature or a digital signature, stating the undertaking of the obligation to create at least two (2) jobs within the first year of the investment.
e) Proof of payment of an electronic fee in the amount of two thousand five hundred (2,500) euros, which is collected as a fee in favour of the “National Registry of Start-up Enterprises S.A.” and is non-refundable, irrespective of the outcome of the application.
Article 4
Supporting documents for certifying the implementation of the investment by a legal person
The additional supporting documents for certifying the implementation of the investment in the event that it is carried out by a legal person, in addition to the documents referred to in Article 3 of this decision, are the following:
a) A declaration by the legal person with its details and the details of the third-country nationals (shareholders or holders of company shares) proposed for the granting of a residence permit in Greece.
b) A certificate from the competent Chamber of Commerce or other competent public authority of the country where the legal person is established, from which the lawful existence and operation of the legal person, the ultimate beneficial owner (UBO – Ultimate Beneficial Owner), the composition of the Board of Directors (B.o.D.) and the persons binding the legal person with their signature arise. The certificates shall bear an apostille and be translated into the Greek language. Translation is not required for documents in the English language.
c) The financial statements of the last two years of the legal person, duly signed. For newly established legal persons, recent interim financial statements for the first financial year shall be submitted. In any case, the financial statements shall be accompanied by an auditor’s report, where required by the applicable legislation of the country of establishment. Otherwise, a Solemn Declaration under Article 8, paragraph 4 of Law 1599/1986 by the legal representative of the legal person shall be submitted.
d) Concerning the shareholding structure:
da) In the case of a domestic legal person, the documents evidencing the shareholding structure, as applicable depending on its legal form.
db) In the case of a foreign legal person, a copy of the minutes of the recent decision of the Board of Directors concerning the decision to move and reside in Greece of the third-country national(s), stating their capacity (shareholder or partner).
Article 5
Number of residence permits depending on the amount of the investment through a legal person
In the event that an investment is carried out by a legal person, a residence permit in Greece shall be granted to third-country nationals as follows:
a) For an investment implemented by a domestic legal person of at least 250,000 euros, a residence permit shall be granted to a third-country national who holds all of its company shares.
b) For an investment implemented by a foreign legal person, residence permits shall be granted to up to three (3) third-country nationals in total, who each hold at least thirty-three percent (33%) of the capital of the foreign legal person. The required minimum amount of investment by the foreign legal person is determined as follows:
MAXIMUM NUMBER OF RESIDENCE PERMITS DEPENDING ON THE AMOUNT OF INVESTMENT THROUGH A LEGAL PERSON (Article 100A of Law 5038/2023)
| Amount of Investment (€) | Number of residence permits |
|---|---|
| 500,000 | 1 |
| 1,000,000 | 2 |
| 1,500,000 | 3 |
Article 6
Conditions and monitoring of the holding of the investment
-
A third-country national holding a valid residence permit granted in accordance with Article 100A of Law 5038/2023 shall retain the investment securities for five (5) years from their acquisition. The enterprise receiving the investment is obliged to maintain, for at least five (5) years from the implementation of the investment, the same total number of jobs, increased by the new jobs created within the first year from the implementation of the investment under point (b) of paragraph 2 of Article 100A.
-
The competent authority for monitoring the holding of the investment after the granting of the residence permit is the Directorate of Foreign Direct Investments of the Ministry of Development. The above authority shall inform the Directorate of Residence Permits of the Ministry of Migration and Asylum of any change regarding the holding of the investment.
Article 7
Supporting documents for the holding of the investment
-
Nationals who have been granted a residence permit in Greece for an investment under Article 100A of Law 5038/2023 shall:
a) Submit, whenever requested during each year, to the Directorate of Foreign Direct Investments of the Ministry of Development, information on the holding of the investment.
b) Inform the Directorate of Foreign Direct Investments of the Ministry of Development of the disposal (liquidation) of part or all of the investment, as well as of the bankruptcy or corporate transformation of the company in which the investment was made, within a period of one (1) month from the date of disposal or bankruptcy/corporate transformation. The above authority shall inform the Directorate of Residence Permits of the Ministry of Migration and Asylum of the interruption of the holding of the investment.
c) Where the investor is a legal person, inform the Directorate of Foreign Direct Investments of the Ministry of Development of any change in the capacity (shareholder or partner) of the person who has been granted a residence permit in Greece, within one (1) month from the date of the change.
-
In the event of disposal or liquidation due to bankruptcy or corporate transformation of the investment in accordance with paragraph 10 of Article 100A, in order for the third-country national investor to retain their residence, they must carry out another investment under Article 100A or an investment in accordance with Articles 97 to 100. They are obliged to submit an application for change of the investment to the Directorate of Residence Permits of the Ministry of Migration and Asylum, accompanied by the respective specific supporting documents, within two (2) months from the disposal/liquidation. If the new investment is carried out in accordance with the provisions of Articles 97 to 99 and 100A, the Directorate of Residence Permits of the Ministry of Migration and Asylum shall forward the application to the Directorate of Foreign Direct Investments of the Ministry of Development for the certification of the new investment.
-
At the time of renewal of the residence permit, nationals holding a residence permit for an investment under Article 100A of Law 5038/2023 shall submit to the Directorate of Residence Permits of the Ministry of Migration and Asylum an application for a certificate of the holding of the investment, accompanied by the following supporting documents:
a) A certificate from the company “National Registry of Start-up Enterprises S.A.” of Article 72 of Law 4914/2022 (Government Gazette A’ 61) including the following:
i) that the enterprise in which the investment has been implemented continues to be registered in the National Registry of Start-up Enterprises at the time of submission of the application for renewal of the residence permit, and
ii) if the maximum operating period constituting a prerequisite for the registration or maintenance of the enterprise in the Registry has elapsed, whether the enterprise has been deleted from the National Registry for that reason.
b) Concerning the acquired securities:
ba) If the acquired securities are registered (nominative): a certificate from the enterprise in which the investment was made, confirming the continuous holding of the investment (acquisition of securities, percentage of capital and percentage of voting rights) until the date of issuance of the certificate.
bb) If the acquired securities are traded on regulated markets or multilateral trading facilities operating in Greece:
i) A certificate from the intermediary confirming the continuous holding of the investment until the date of issuance of the certificate.
ii) A certificate from the start-up enterprise in which the investment was made, confirming the continuous holding of the investment (percentage of capital and percentage of voting rights) until the date of issuance of the certificate.
c) A Staff Table from the “ERGANI” information system regarding the employment of staff in the enterprise where the investment was made, from which compliance with condition (c) of paragraph 2 of Article 100A of Law 5038/2023 is evidenced.
d) Proof of payment of an electronic fee in the amount of two thousand five hundred (2,500) euros for the residence permit under renewal, which is collected as a fee in favour of the “National Registry of Start-up Enterprises S.A.” and is non-refundable, irrespective of the outcome of the application.
-
The Directorate of Residence Permits of the Ministry of Migration and Asylum shall forward the application to the Directorate of Foreign Direct Investments of the Ministry of Development for the issuance of a certificate of the holding of the investment.
-
Where the investor is a legal person, it is jointly liable, together with the third-country national to whom the residence permit in Greece has been granted, for compliance with the obligations under Article 100A of Law 5038/2023 and this decision.
Article 8
Entry into force
The present decision shall enter into force on the date of its publication in the Government Gazette.
This decision shall be published in the Government Gazette.
Athens, 12 November 2025
The Ministers
Deputy Minister of Foreign Affairs
ALEXANDRA PAPADOPOULOU
Development
PANAGIOTIS THEODORIKAKOS
Migration and Asylum
ATHANASIOS PLEVRIS
Stay up-to-date with exclusive content.
admin