Foreign Direct Investment (FDI) Screening in Greece 2026: Sectors, Thresholds & Filing Timelines

Introduction, quick summary and why 2026 matters

FDI screening Greece is becoming a central compliance workstream for cross-border deals touching sensitive sectors, and 2026 is a year in which investors are increasingly advised not to treat it as an afterthought. Greece participates in the European Union’s cooperation framework under Regulation (EU) 2019/452 together with national implementing measures, meaning acquirers should map both EU-level information-sharing and any domestic clearance obligations before signing. Greece has been developing and finalising its national FDI screening legislation, so investors should verify the precise scope and status of the national mechanism in force at the time of their transaction.

The practical effect for 2026 is a heightened expectation that dealmakers identify screening exposure early, build clearance conditions into transaction documents, and plan realistic filing timelines.

This guide sets out the legal framework, the sectors most likely to attract review, the filing triggers and timelines you should consider in your deal calendar, and the enforcement risks of closing without approval. It is written for practitioners and investors who need a working orientation. It is general information and not legal advice; confirm the current position for each transaction.

Overview: Is there an FDI screening regime in Greece?

Greece participates in the EU-wide approach to investment screening, applying the cooperation mechanism established by Regulation (EU) 2019/452 alongside national measures allowing the Hellenic Republic to review incoming investments on grounds of public order and security. The regime is not a blanket bar on foreign capital, Greece actively promotes inward investment through its investment promotion agency, Enterprise Greece, but it gives the state tools to examine, condition or block transactions that could threaten national security or critical assets. Because the national implementing framework has been evolving, investors should confirm the exact designated authority, sectors and thresholds applicable when they file.

Legal framework (EU and national)

The foundation is Regulation (EU) 2019/452, which does not create a single centralised EU authority but instead establishes a framework enabling Member States to maintain, adopt or amend their own screening mechanisms and to cooperate through structured information exchange. Under the European Commission’s FDI screening framework, when one Member State screens a transaction, other Member States and the Commission may comment or issue opinions where the investment could affect security or public order beyond a single country. In Greece, national implementing measures are published in the Government Gazette (FEK) via the National Printing House, with procedural responsibility resting with the competent national authority designated by the Greek State.

Investors should confirm the designated authority and current procedure at the outset of any deal.

Scope and definitions

The scope of FDI screening in Greece follows the EU concept of foreign direct investment: an investment by a foreign investor aimed at establishing or maintaining lasting and direct links with an undertaking that carries out an economic activity in a Member State, including investments that enable effective participation in the management or control of that undertaking. Key points investors should internalise:

• Direct and indirect acquisitions. Screening can reach not only direct purchases of Greek targets but also indirect acquisitions achieved through intermediate holding structures where the ultimate beneficial owner is a foreign investor.
• Control concept. The trigger is typically the acquisition of control or a lasting participation, though certain sensitive sectors may capture minority stakes below control thresholds.
• Cross-border context. Because the EU cooperation mechanism applies, a Greek transaction may draw comments from other Member States or the Commission, extending the practical review horizon.

Key sectors subject to FDI screening in Greece (2026 update)

Regulation (EU) 2019/452 sets out an indicative list of factors and sectors that Member States may consider when assessing whether an investment affects security or public order. Greece’s application of these priorities focuses on assets whose disruption or foreign control could compromise national resilience. The list below reflects sectors commonly associated with national security review and screening exposure across EU-aligned regimes; the precise Greek sector list should be confirmed against the national implementing measures in force.

Energy and utilities

Energy is a first-order concern. Investments in electricity generation and transmission, natural gas networks, LNG terminals, storage, and interconnectors are commonly scrutinised because foreign control over energy supply can create dependencies and single points of failure. Water supply and treatment infrastructure falls into the same category, given its role in public health and continuity of essential services.

Telecoms and digital infrastructure

Telecommunications networks, submarine cables, 5G infrastructure and data centres attract review because they underpin national communications, economic activity and, increasingly, defence-adjacent capabilities. Data infrastructure, including facilities processing or storing large volumes of sensitive personal or government data, is treated as strategically significant, reflecting concerns about surveillance, data integrity and resilience.

Defence and dual-use

Defence manufacturing, military technology and dual-use items, goods and technologies with both civilian and military applications, are among the most sensitive targets for investment screening. Acquisitions here are among the most likely to face conditions or prohibition, particularly where the investor is linked to a non-EU government or where the technology has clear security implications.

Critical infrastructure (transport, ports, airports)

Greece’s geography makes ports, airports and transport corridors strategically vital. Investments in port operations, airport concessions, logistics hubs and transport networks are examined for their impact on supply chains, mobility and, in coastal and island contexts, security. The concession-heavy nature of Greek infrastructure means many transactions in this space involve the state as counterparty, adding a further layer of regulatory attention.

Strategic real estate and proximity rules

Real estate near sensitive sites, military installations, border regions, ports and critical infrastructure, can trigger notification obligations even where the underlying commercial rationale appears benign. Greece also maintains separate, longstanding restrictions on the acquisition of property in designated border areas, which operate independently of FDI screening. Proximity to security-relevant locations is the operative concern, so investors should map the physical footprint of any real-estate-heavy target against known sensitive zones before signing.

Because national thresholds are set in domestic implementing measures published through the FEK, the precise percentages and tests can be updated over time. Investors should confirm the current position against the official Government Gazette and competent-authority guidance for each specific transaction rather than relying on generic figures.

Notification thresholds, filing triggers and filing timelines in Greece

The central operational questions for any acquirer are: does this deal require a filing, when must it be made, and how long will review take? Getting the answer wrong is expensive, it can delay closing, undermine protective covenants, or expose the parties to unwinding. This section sets out how to approach filing triggers and timelines in practice; exact statutory periods must be confirmed against the national measures and competent-authority guidance.

What triggers a filing

A notification obligation generally arises where a foreign investor acquires control of, or a lasting participation in, a Greek undertaking active in a screened sector. Triggers to model include:

• Acquisition of control. The acquisition of a controlling interest in a target operating in energy, telecoms, defence, critical infrastructure or other listed sectors is the paradigm trigger.
• Minority stakes in sensitive sectors. In the most sensitive areas, particularly defence, dual-use and certain critical infrastructure, participations below the level of control may still require notification because influence, not just control, is the concern.
• Indirect and upstream acquisitions. A change of control at a parent or holding level that carries with it a Greek screened asset can trigger review even where no Greek entity is directly transferred.
• Asset deals. Acquisitions of strategic assets, a port concession, an energy licence, a data centre, can trigger review independently of any share transfer.

Standard versus extended review

Under EU-aligned screening frameworks, review typically proceeds in defined phases. A standard review addresses whether the transaction raises public order or security concerns within an initial window. Where concerns are identified, or where cross-border cooperation under Regulation (EU) 2019/452 draws comments from other Member States or an opinion from the Commission, the review moves into an extended phase. In practice, straightforward cases can clear within the initial window, while complex or sensitive matters, especially those with defence, energy or non-EU state-linked investors, should be planned around a longer horizon.

Urgent and national security review

Authorities may prioritise cases raising acute national security concerns. Investors should not assume expedited handling works in their favour: expedition typically reflects heightened scrutiny rather than a fast track to approval. Where a transaction is time-sensitive, the better strategy is early engagement and pre-notification rather than reliance on any accelerated route.

Filing timeline, indicative step-by-step timetable

The following illustrative timetable helps in-house counsel and deal teams build screening into the transaction calendar. Exact statutory periods are set in national implementing measures and must be confirmed against competent-authority guidance for each deal, but this structure reflects the typical rhythm of an EU-aligned review.

• Pre-Day 0, Pre-notification. Informal engagement with the competent authority, scoping of the filing, and preparation of documentation.
• Day 0, Formal notification. Submission of the complete filing where the transaction falls within scope.
• Initial review window. The authority assesses the transaction and determines whether concerns exist; EU cooperation partners may comment during this period.
• Extended review. Triggered where public order or security concerns are identified or where cross-border cooperation is engaged; the authority may issue follow-up information requests that pause or reset the clock.
• Decision. Unconditional clearance, clearance with conditions or remedies, or prohibition.

The practical lesson is that a clean, complete filing shortens review, while incomplete submissions invite information requests that extend the process. Model your closing conditions around the extended-review scenario, not the best case.

Documents to submit

While the precise contents of a filing depend on the sector and structure, a robust submission should generally include:

• Identity and ownership structure of the foreign investor, up to and including the ultimate beneficial owner.
• Details of any state ownership, control or influence over the investor.
• Description of the target’s activities, assets and any screened-sector exposure.
• Transaction structure, value, funding and the rights the investor will acquire.
• Explanation of the strategic rationale and any factors relevant to public order or security.

Who reviews and coordinates the screening? Authorities and interagency process

Understanding the institutional architecture helps investors direct their filing to the right audience and anticipate where friction may arise.

Competent national authority

Procedural responsibility for foreign investment review in Greece sits within the Greek State’s designated competent authority, coordinated within central government. Investors and their counsel should treat the designated authority’s guidance and any published notices as the authoritative source for current procedure, and confirm the designated point of contact for a given transaction at the outset, as institutional arrangements may change as the national framework is implemented.

Interagency committee and experts

Security-sensitive assessments are rarely made by a single desk. Screening decisions typically draw on interagency input, bringing together economic, security, defence and sector-specialist perspectives so that the public order and security assessment is informed by relevant expertise. For investors, this means a filing may be read by audiences whose primary concern is security rather than commercial merit, a reason to address security considerations proactively in the submission.

Cooperation with the EU and other Member States

Because Greece operates within the Regulation (EU) 2019/452 cooperation mechanism, other Member States and the Commission may receive information about a screened transaction and may provide comments or an opinion where the investment could affect security or public order beyond Greece. This cross-border dimension is one of the principal reasons complex matters take longer, and it is why acquirers with pan-European footprints should coordinate their Greek filing with any parallel filings elsewhere.

Practical filing checklist and investor strategy

Effective compliance with FDI screening is a matter of preparation. The following playbook helps acquirers and their advisers manage investment-control obligations without derailing the deal.

Pre-deal due diligence

Screen the target for exposure before you commit. This means mapping the target’s activities, assets and physical locations against the screened-sector list and proximity rules, and tracing your own ownership chain to establish whether, and to what extent, you are a foreign investor for screening purposes. Early identification of a filing obligation is the single most valuable thing a deal team can do.

• Map target activities and assets against energy, telecoms, defence, dual-use, critical infrastructure, data and strategic real estate categories.
• Identify the ultimate beneficial owner and any state links in the acquirer’s structure.
• Assess proximity of any real estate to sensitive sites and border areas.
• Confirm whether minority-stake rules apply in the relevant sector.

Drafting deal protections

Where screening is or may be required, the transaction documents should reflect it. Build the clearance requirement into the deal architecture rather than bolting it on later:

• Conditions precedent. Make FDI clearance a condition to closing where a filing is required.
• Long-stop dates. Set realistic long-stop dates that account for extended review and cross-border cooperation.
• Escrow and holdbacks. Consider escrow or holdback mechanics to manage risk while approval is pending.
• Cooperation covenants. Oblige the parties to cooperate in preparing and prosecuting the filing and to share information promptly.

When to seek pre-notification or informal clearance

Early, discreet engagement with the competent authority through pre-notification can surface concerns before they harden into a formal objection, allowing the parties to shape remedies or reconsider structure. This is particularly valuable for borderline cases and for investors with state links, where a well-prepared narrative on security safeguards can materially improve the outcome.

Integrating remedies into the SPA

Anticipate that clearance may come with conditions. The sale and purchase agreement should allocate the risk and cost of remedies, for example, commitments on security of supply, governance safeguards, data localisation, or ring-fencing of sensitive activities, and specify who bears the burden if remedies materially change the economics of the deal. Deciding this at signing avoids a fraught renegotiation under time pressure.

Penalties, remedies and enforcement: risks of closing without approval

Closing a screened transaction without required clearance is a serious compliance failure. The consequences under EU-aligned screening frameworks can be significant and are designed to deter parties from treating screening as optional. The specific sanctions applicable in Greece are set by the national implementing measures and should be checked against the text in force.

Administrative sanctions

Authorities can typically impose financial penalties for failing to notify a transaction that required screening or for closing before clearance. Fines are a standard tool across EU-aligned screening regimes and are calibrated to remove any incentive to gamble on non-notification. The reputational cost of a public enforcement action can compound the direct financial exposure, particularly for regulated investors and funds with institutional backers.

Forced divestment and injunctive powers

The most disruptive remedy is the power to unwind. Where a transaction has closed without approval, or where an approved transaction breaches its conditions, authorities may order divestment, impose corrective measures, or suspend the exercise of rights attaching to the acquired stake. In practice this can mean an acquirer holds an asset it cannot control or must sell at a distressed valuation. Contractual arrangements that depend on a prohibited acquisition may also be exposed to invalidity, undermining the commercial bargain.

Practical mitigation and retrospective approvals

Where a filing has been missed, a retrospective or remedial route may exist, but it is a poor substitute for timely notification: it invites scrutiny, signals non-compliance, and offers no guarantee of clearance. The far better mitigation is process discipline, early screening, timely filing and clear conditionality in the transaction documents. If a gap is identified after signing, immediate engagement with counsel and, where appropriate, the authority is essential to limit exposure.

Comparisons: Greece versus selected EU peers

Cross-border acquirers rarely deal with Greece in isolation. Comparing the Greek approach with two of the EU’s most developed screening systems helps calibrate expectations and coordinate multi-jurisdictional filings. All three operate within the same EU cooperation framework under Regulation (EU) 2019/452, but the national tests, thresholds and timelines differ.

The practical takeaway for acquirers is to treat Greece as one node in a coordinated European filing strategy: align notification timing, ensure consistency of the narrative across jurisdictions, and anticipate that a filing in one Member State may prompt comment in others through the EU cooperation mechanism. For comparative policy context on how these regimes fit within global investment norms, the OECD’s investment work is a useful reference.

Next steps and contacts

Compliance with FDI screening rewards early planning. If you are evaluating or closing a transaction with any Greek nexus in a sensitive sector, the highest-value action is a pre-deal screening assessment followed by a tailored filing strategy. Review the broader Business lawyers Greece, full practice guide for wider corporate and M&A context, and consult a Greek merger control resource to distinguish merger control (assessed by the Hellenic Competition Commission) from FDI screening where both may apply. For deal-specific advice, request a pre-notification legal review before you sign, so that clearance conditions, timelines and remedies are built into your transaction from the outset.

Sources

1. Regulation (EU) 2019/452, official text (EUR-Lex)
2. European Commission, Foreign direct investment screening
3. Enterprise Greece, Hellenic Republic investment and trade promotion agency
4. National Printing House / Hellenic Government Gazette (ET)
5. Hellenic Republic, Ministry of Development
6. OECD, Investment
7. Athens Bar Association (ΔΣΑ)