Greece has expanded its foreign investment screening regime. International companies completing or planning acquisitions of Greek entities now face mandatory pre-notification obligations that did not previously apply to a broad range of transactions. Failing to file on time can result in suspension of the transaction or, in serious cases, unwinding of a completed deal.
Greece's updated investment screening legislation introduces a mandatory notification requirement for qualifying foreign investments in sectors designated as strategically sensitive. The obligation applies to transactions meeting defined ownership and value thresholds, with notification required before closing. Companies that miss the filing deadline risk having their transaction suspended or referred for full security review.
This alert sets out what changed, which business categories are affected, the applicable thresholds, the compliance deadline, and the five immediate steps international companies should take now.
What changed – the regulatory development and effective date
Greece transposed the EU's foreign direct investment screening regulation into national investment legislation, establishing a formal Επιτροπή Ελέγχου Ξένων Επενδύσεων (Foreign Investment Screening Committee). The Committee operates within the Ministry of Development and reviews transactions for national security and public order implications.
The updated rules took effect in early 2025. They extend the notification obligation beyond defence and critical infrastructure to a materially wider set of sectors. The change is directly aligned with the EU's push to harmonise screening mechanisms across member states. Greece's approach mirrors frameworks already in place in Germany, France, and the Netherlands, but introduces Greece-specific procedural steps that practitioners must follow precisely.
The core change is structural. Previously, screening was largely discretionary and applied on a post-closing basis in limited categories. Under the new rules, pre-closing notification is mandatory for qualifying transactions. The Screening Committee must issue a clearance decision – or allow the statutory review period to lapse without objection – before the transaction may close lawfully.
Disclosure obligations attach to the notification itself. The filing must include a prospectus-level description of the investor's ownership structure, ultimate beneficial owners, source of funds, and the nature of the target's activities. Incomplete filings are rejected and the clock does not restart until a compliant submission is received. For transactions involving an investment fund as the acquirer, the fund's management structure and limited partner composition must also be disclosed.
Who is affected – threshold criteria and business categories
The notification obligation applies to any foreign investor – including investors from EU member states – acquiring a qualifying interest in a Greek entity. The obligation triggers at a defined ownership threshold. Acquisitions that take the investor's holding above ten percent, twenty-five percent, or fifty percent of voting rights in a target company are each treated as separate notification events.
The sectors subject to mandatory screening include:
- Energy infrastructure, including electricity generation, transmission, and storage assets
- Telecommunications networks and spectrum assets
- Transport infrastructure – ports, airports, and rail corridors
- Financial services, including banking, payment systems, and securities offering platforms
- Defence and dual-use technology industries
Beyond these core categories, the legislation extends screening to companies whose activities touch health infrastructure, water supply, digital infrastructure, and media. A target company with activities across more than one of these categories requires a single consolidated notification covering all relevant aspects.
For transactions in the securities and capital markets space. including IPO-related restructurings, pre-listing acquisitions, and transfers of interests in listed entities. the listing requirements of the Athens Stock Exchange do not displace the screening obligation. Both regimes apply in parallel. An international investor acquiring a stake in a listed Greek company in connection with a securities offering must satisfy both the exchange's disclosure obligations and the screening notification requirement before the acquisition closes.
Non-EU investors face a somewhat more stringent review standard. Where the acquirer is domiciled outside the EU – or where the ultimate beneficial owner is a non-EU national – the Screening Committee applies additional criteria relating to geopolitical risk and reciprocity. Practitioners advising non-EU clients should treat the notification as the beginning of a dialogue, not a formality.
For a broader view of how Greece's capital markets regulatory system operates alongside this screening regime, see our overview of capital markets law in Greece.
To explore how the screening regime intersects with banking and finance transactions, visit our analysis of banking and finance law in Greece.
To receive an expert assessment of how these new notification rules affect your transaction in Greece, contact us at info@ferrazwhitmore.com.
What to do now – immediate actions and compliance timeline
The compliance deadline is transaction-specific: notification must be submitted before signing in certain cases, and in all cases before closing. There is no grace period for transactions that have already signed but not yet closed where the threshold criteria are met.
International companies should take the following five steps immediately.
First, audit your existing and pipeline transactions. Identify every Greek target in which you hold or propose to acquire an interest at or above the ten percent threshold. Include indirect acquisitions through holding structures. The obligation applies regardless of whether the Greek entity is the primary target or an incidental part of a wider group acquisition.
Second, assess sector classification. The designated sectors are defined broadly in the investment legislation. A target company in digital services or health technology may fall within scope even if its primary commercial activity is not intuitively strategic. Obtain a formal legal opinion on classification before assuming the obligation does not apply.
Third, prepare the notification file in advance. The filing requires detailed corporate and financial information about both the investor and the target. Assembling this documentation – particularly for investment fund structures with complex limited partner registries – typically requires several weeks. Starting early avoids delays that push the transaction timeline past a scheduled closing date.
Fourth, build the screening timeline into your transaction schedule. The Screening Committee has a statutory period of up to thirty working days to issue a decision on standard notifications. With the possibility of extension for complex or sensitive matters. Factor this into longstop dates and financing commitment periods.
Fifth, engage a lawyer in Greece with experience in both investment screening and capital markets transactions. The interaction between the screening notification. The disclosure obligations under securities legislation. Additionally, the listing requirements of the Athens exchange creates a multi-layered compliance challenge. A law firm in Greece with cross-border transaction experience can coordinate the parallel filings and manage the Committee process. For a comparison of how similar obligations are structured in other EU jurisdictions, see our alert on investment screening developments in Portugal.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our capital markets and corporate law practice assists international investors, investment funds, and listed companies with foreign investment screening notifications, securities offering compliance, IPO-related restructurings, and cross-border acquisitions in Greece and across Europe. As an international law firm advising on Greek regulatory matters, we combine Portuguese civil law expertise with English common law discipline to deliver precise, results-oriented counsel. Our team has advised on screening and disclosure obligations across both civil law and common law systems, including before EU member state investment review bodies. To discuss how the new Greek notification requirements apply to your transaction, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.