Key takeaway: Greece’s Golden Visa short-term rental ban is a residence-permit investment rule, not a nationwide Airbnb ban. Under Article 64 of Law 5100/2024 (amending Article 100 of the Migration Code), properties acquired in full ownership and possession by third-country nationals for the initial grant or renewal of an investor residence permit must not be let short-term in the sharing economy or sublet. Breach of that rule (and of the related seat-of-business ban for certain €250,000 change-of-use investments) triggers revocation of the residence permit and a separate administrative fine of €50,000 on the owners and/or holders. A €150,000 fine in the same article attaches to different listed-building violations — do not conflate the two amounts.
If you manage, host or own holiday inventory in Greece, viral posts often blur three different regimes: the Golden Visa acquisition restriction, municipal freezes on new AMA registrations in parts of Athens and Thessaloniki, and ordinary AADE short-term rental compliance for everyone else. This article separates those layers for Greek hosts, property managers, owners and investors. It is journalism based on official and published legal texts — not legal advice. Verify your deed, permit file and listing status with a Greek immigration lawyer and accountant before you change a calendar.
What the official housing portal actually says
The Ministry of National Economy and Finance and the Ministry of Migration & Asylum summarise the measure on the Housing Policy Portal (stegasi.gov.gr). In plain terms:
- Properties acquired in full ownership and possession by third-country nationals for the initial grant or renewal of an investor residence permit must not be rented short-term in the sharing economy, and must not be sublet.
- Properties acquired under the €250,000 change-of-use route (paragraph 2(c) of Article 100 as rewritten) must not be used as the registered seat or branch of a business.
That portal page points expressly to Article 64 of Law 5100/2024. The same language appears in the TaxHeaven article text and in the Ministry of Migration’s published consolidated PDF of the law.
What Law 5100/2024 Article 64 / Migration Code Article 100(7A) bans
Paragraph 7 of Article 100 still states that third-country nationals who hold property may lease it. Paragraph 7A then draws the hard line:
Properties acquired in full ownership and possession by third-country nationals for the initial grant or renewal of an investor residence permit are prohibited from being rented short-term in the framework of the sharing economy, and from being sublet. In addition, properties acquired … under the terms of paragraph 2(c) may not be used as the seat or branch of a business. In case of non-compliance with the first and second sentences, the residence permit is revoked and an independent administrative fine of fifty thousand (50,000) euros is imposed on the owners and/or holders of the property…
Source: TaxHeaven — Ν. 5100/2024 Άρθρο 64; same wording in the Ministry of Migration consolidated PDF.
€50,000 vs €150,000 — quote carefully
Social posts often mix the fine amounts. The statute itself distinguishes them:
- €50,000 — for breach of the first and second sentences of paragraph 7A: short-term sharing-economy letting / subletting, or (for paragraph 2(c) properties) use as a business seat or branch; plus residence-permit revocation.
- €150,000 — for failure to meet the listed-building full restoration / reconstruction condition in the second sentence of paragraph 4; and separately where a transfer deed is concluded contrary to the listed-building transfer ban in paragraph 2(d).
Fines are public revenue collected under the Code for Collection of Public Revenues (Law 4978/2022). Joint ministerial decisions may still refine audit and collection procedure (Article 176(49) as rewritten).
What “short-term” means in practice
Article 64 itself uses the Greek formulation “short-term in the framework of the sharing economy” and “subletting,” without reprinting a day-count inside paragraph 7A. Secondary legal commentary and firm notes on Ministry circulars commonly point to the definition in Article 111 of Law 4446/2016: letting or subletting for a fixed duration of fewer than sixty (60) days, whether or not posted on a digital platform, where no services are offered beyond accommodation and provision of bed linen. Long-term leases and certain leases to tourism enterprises that provide additional services are widely described as outside that sharing-economy short-let profile — but structure any hotel-type or commercial lease with counsel, especially where the seat-of-business ban applies.
Platform choice does not create a loophole. Whether the stay is sold on Airbnb, Booking.com or offline, the Golden Visa rule is about the use of the qualifying property. For ordinary (non–Golden Visa) channel strategy, see our Booking.com vs Airbnb comparison for Greece.
Who the ban hits — and who it does not
Primarily hit: third-country nationals whose Greek real-estate acquisition is the basis for an investor residence permit (Golden Visa) under the post–Law 5100/2024 Article 100 framework, including renewals that depend on that qualifying property. Managers listing such units on short-term calendars create risk for the investor’s permit and for the owners/holders named in the fine provision.
Not a blanket ban on Greek short-term rentals: EU/Greek citizens’ ordinary holiday homes, professional portfolios that are not Golden Visa qualifying assets, and long-term residential leases remain outside this specific Article 100(7A) restriction — though they remain subject to AADE registry, stay declarations, climate resilience fee and any local planning rules. For fee mechanics, see our guide to the climate resilience fee for Greek short-term rentals.
Non-retroactivity: circular text we could not open as a primary PDF
We did not retrieve an official Ministry PDF of Circular EGK 240/2024 (often referenced as Circular 9 / ΑΠ 240076 of 25 September 2024) in this research pass. Secondary legal commentary quotes the circular as stating that the short-term / subletting prohibition does not cover properties acquired under the previously applicable provisions, nor properties for which the investment is completed within the transitional period of Article 64(4) of Law 5100/2024. Firm summaries (for example Machas & Partners) describe the same idea: current holders under prior rules, and investors who met the statutory transitional deposit/completion conditions, are treated as outside the new short-term ban.
Treat that as secondary reporting of ministry guidance. Ask your lawyer to produce the circular text and map it to your purchase dates, deposit proofs and completion deeds. Do not assume “old Golden Visa” status from a listing screenshot alone.
Transitional window (statute, not folklore)
Article 64(4) sets a transitional path allowing completion under the prior regime if statutory deposit / payment / preliminary-agreement conditions were met by the stated August 2024 cut-offs, with completion deadlines that were later extended by subsequent legislation (TaxHeaven notes the first-sentence completion deadline was extended to 28 February 2025 by Law 5167/2024, with a further fallback date in the article). If your file sits near those dates, only a notary and immigration counsel can say which regime applies.
What is NOT banned nationwide
- Not every Greek apartment on Airbnb. The Article 100(7A) restriction is tied to Golden Visa–qualifying acquisitions for permit grant/renewal — not to every short stay in Greece.
- Not long-term leasing as such. Paragraph 7 still affirms a leasing possibility; paragraph 7A carves out sharing-economy short-term letting and subletting.
- Not identical to Athens / Thessaloniki new-AMA freezes. Those are separate housing-pressure measures that suspend new short-term rental registry numbers (AMA) in named municipal districts. They can block new registrations or complicate transfers for ordinary STR stock — they are not the same legal instrument as the Golden Visa sharing-economy ban. For the wider planning and zoning picture, see Greece’s tourism spatial plan and short-term rental zoning.
- Not a substitute for AADE compliance on properties that lawfully remain in the short-term market: stay declarations, AMA display, and ΤΑΚΚ remain separate duties.
| Property situation | Can it be short-term rented? | What to check |
|---|---|---|
| New Golden Visa purchase under post–5100/2024 Article 100 (qualifying asset for grant/renewal) | No — sharing-economy short-term and subletting banned under Art. 100(7A) | Deed purpose; permit file; management contract; remove STR calendars; model long-term or other lawful use with counsel |
| €250,000 change-of-use Golden Visa route (para. 2(c)) | STR/subletting banned; also no use as business seat/branch | Use change completion; company seat address; same €50,000 + revocation risk for 7A breaches |
| Pre-law / transitional Golden Visa property (if circular + Art. 64(4) apply to your facts) | Secondary commentary says STR ban does not cover these — verify | Circular EGK 240/2024 text; deposit date; completion deed; lawyer letter on file |
| Ordinary Greek STR (not a Golden Visa qualifying asset) | Yes, if AMA/local rules allow — subject to AADE and municipal measures | AMA; stay declarations; ΤΑΚΚ; district AMA freeze if in Athens/Thessaloniki red zones |
| Long-term residential lease of a Golden Visa asset | Generally contemplated by para. 7; structure carefully | Lease term vs <60-day definition; no disguised short-lets; tax treatment |
Checklist for managers and hosts
- Flag every unit financed or held as a Golden Visa qualifying asset — ask owners for the residence-permit type and the notarial purpose clause.
- Match purchase timing to Law 5100/2024 / Article 64(4) transitional facts; store deposit proofs and completion deeds.
- Read Article 100(7A) with counsel: short-term sharing-economy letting, subletting, and (where relevant) seat-of-business use.
- Do not invent fine amounts: €50,000 + revocation for 7A first/second-sentence breaches; €150,000 for the listed-building failures named in the same paragraph.
- Audit OTAs and the PMS: if the unit is in the banned cohort, close short-stay availability at the source of truth and verify public calendars.
- Rewrite owner reports: replace “Airbnb yield” assumptions with lawful long-term or alternative uses; contribution maths still matter for remaining lawful inventory — see our shoulder-season pricing playbook for non-banned stock.
- Separate municipal AMA freezes from Golden Visa rules when advising buyers in central Athens or Thessaloniki.
- Keep AADE hygiene for any property that remains lawfully in short-term rental: registry number, stay declarations, climate fee receipts.
- Get written legal advice before accepting a management mandate on a Golden Visa asset marketed for tourist nights.
- Re-check primary sources after any new circular — ministry guidance has already been used once to clarify non-retroactivity.
Practical scenarios
Scenario A — New €800,000 Athens apartment bought for a 2025 Golden Visa. Treat sharing-economy short stays and subletting as prohibited under Article 100(7A). Listing it for weekend tourism nights is the exact risk the statute prices at permit loss plus €50,000.
Scenario B — Investor under prior thresholds who completed within the transitional path. Secondary commentary on EGK 240/2024 says the STR prohibition does not cover that cohort. Still confirm with the circular text and your notary file before you keep an AMA calendar live.
Scenario C — Greek host with three AMA apartments and no Golden Visa. Article 100(7A) is not your restriction. Your constraints are AADE rules, fees, and any local registration freeze or zoning instrument — different playbook.
Scenario D — Manager asked to “just list it as Airbnb until the permit arrives.” If the acquisition is already framed for investor residence, short-term use can undermine the permit strategy itself. Refuse until counsel clears the use.
Conclusion
Greece’s Golden Visa short-term rental ban is real, statute-backed and expensive when it applies — but it is not a nationwide shutdown of holiday rentals. Article 64 of Law 5100/2024 / Article 100(7A) of the Migration Code targets properties acquired for investor residence permits: no sharing-economy short-term letting, no subletting, and for change-of-use investments no business seat or branch, with €50,000 and permit revocation for those breaches. Keep the €150,000 figures attached to the listed-building violations the law actually names. Use the Housing Policy Portal and the statute text as your anchors; treat circular non-retroactivity claims as guidance to verify with a lawyer; and keep Athens/Thessaloniki AMA freezes in a separate compliance folder.
This article is for information only and is not legal, tax or immigration advice. Rules and circulars change — confirm against current official texts and your advisers before acting.
