6 of February 2026 - Recent amendments to the Migration Code: material changes to the residence and employment regime for third-country nationals.Recent legislative interventions in the Migration Code introduce significant changes both to the procedure for examining residence permit applications and to specific regimes concerning family members of Greek citizens, investors’ family members, students, and persons who lost their residence status after many years of lawful presence in the country. At the same time, new categories of national entry visas are introduced for specialised personnel, start-ups and highly qualified individuals, which are analysed below. Understanding the new rules is critical, particularly as regards deadlines, the conditions for maintaining lawful status, and the options for moving to a more stable residence regime. 1. Time limit for examining applications and the operation of the one-stop service It is expressly stipulated that an application for the granting, amendment or renewal of a single residence permit is examined by the competent one-stop service within ninety (90) days from the submission of a complete file. This time limit may be extended by up to thirty (30) days, exclusively in exceptional and duly reasoned circumstances linked to the complexity of the application, with the applicant being informed through the electronic services of the Integrated Information System (IIS) “Migration”. Where additional supporting documents are requested, the applicant is invited to submit them within a reasonable time limit that may not exceed two (2) months, with the possibility of an extension of up to thirty (30) days in exceptional cases. For the period until the submission of the additional material, the initial 90-day time limit is suspended. Service of the decision is carried out in writing through the same electronic system. Furthermore, it is provided that applications are submitted exclusively electronically through the Integrated Information System “Migration”. The system may allocate applications to the competent one-stop services irrespective of the applicant’s place of residence, with the aim of balancing the administrative workload and speeding up processing. For this purpose, allocation is made on the basis of objective criteria, selecting the service with the smallest number of pending applications, in accordance with the regulatory framework governing the operation of the system. Finally, the immediate issuance of a decision on pending applications for initial granting or renewal of residence permits that fall within “safe” categories is provided for, subject only to considerations relating to public order and security. In this context, every residence permit that is issued or renewed has a minimum validity of two (2) years. This measure aims to reduce the administrative burden on the services of the Ministry of Migration and Asylum and the Decentralised Administrations, while strengthening legal certainty and the stability of the residence status of the persons concerned. 2. Proof of knowledge of the Greek language and culture for long-term resident status The recent amendments clarify and broaden the evidentiary means by which adequate knowledge of the Greek language, history and culture may be substantiated—an element that constitutes a basic prerequisite for acquiring long-term resident status. Such knowledge is no longer proven solely through attendance in Greek education, but also through a wider set of qualifications and evidence reflecting substantive integration in the country. In this context, diplomas from schools or Second-Chance Schools implementing a Greek curriculum, diplomas from secondary schools abroad that fall under the Greek education system, as well as Greek-language qualifications issued by university departments abroad are taken into account. The principal proof remains a certificate of Greek language proficiency at least at level B1, while the special certificate of adequate knowledge of the Greek language, history and culture issued following successful examination continues to be recognised. Likewise, the Certificate of Knowledge Adequacy for Naturalisation also constitutes sufficient proof. Of particular importance is that degrees from Greek higher education institutions—undergraduate, postgraduate or doctoral—are now expressly included, where the programme is taught predominantly in Greek, as an indication of substantive linguistic and cultural integration. 3. Ten-year residence permit (type “M.2”) In the same spirit of strengthening the stability of residence status, the ten-year residence permit is redefined. It is one of the main forms of long-term establishment of third-country nationals in Greece, providing full access to the labour market and enhanced legal certainty. This permit is granted to third-country nationals who have completed ten years of continuous lawful residence in the country on the basis of a definitive residence title and who meet the integration requirements applicable to long-term resident status. In parallel, a special possibility is provided for granting it to persons who were born in Greece or who have successfully completed at least six years of Greek schooling in the country before reaching the age of 23. For family members of a Greek citizen who lawfully reside in Greece together with that citizen for five (5) continuous years, the granting of a permanent residence card type “M.3” is provided, in accordance with the special regime governing these persons. The ten-year permit is granted upon application and requires, inter alia, full health insurance coverage, as well as no interruption of residence due to absence from the country for a period of two (2) consecutive years. The permit is revoked only where grounds of public order or security exist. Renewal for ten (10) years each time is provided for permits granted to persons who were born in Greece or who have successfully completed six (6) years of Greek schooling in the country before the age of 23, as well as for the permanent residence cards of family members of a Greek citizen, provided there has been no two-year absence from the country and there are no grounds of public order and security. 4. Possibility of changing the category of residence permit The recent provisions substantially broaden the scope for adjusting residence status to the actual circumstances of the person concerned, allowing a change of residence-permit category in a wider range of cases. The possibility is also provided to move to a family residence regime when a relevant bond arises, such as marriage or a civil partnership with a Greek citizen or with a third-country national lawfully residing in Greece, as well as in cases of having a child of Greek nationality or creating a relationship of dependency involving ascendants or descendants. Of particular importance is that an application for a highly qualified residence permit (“EU Blue Card” – type “E.1”) may be submitted even by persons already in Greece under a uniform entry visa or under a visa-exemption regime, provided that a relevant employment contract is submitted and the application is filed before the expiry of the permitted period of stay. Finally, the possibility is provided to move to a highly qualified employment regime also for persons who entered under an intra-corporate transfer, provided the relevant conditions are met. 5. Duration and renewal of the “EU Blue Card” (type “E.1”) The validity period of the “EU Blue Card” is redefined, with the aim of strengthening the stability of residence status for highly qualified employees working in Greece. The permit is now granted for three (3) years and renewed for an equal period each time, which reduces the frequency of administrative procedures and enhances predictability for both employee and employer. This arrangement enhances the practical value of the “EU Blue Card”, as it combines greater time security with flexibility regarding the duration of employment and the lawfulness of residence. 6. Broadening the concept of family members The recent amendments redefine and broaden the concept of family members, both for third-country nationals and for Greek or European Union citizens, so as to reflect more fully the actual family situation and to cover cases of increased dependency. Family members of a third-country national Family members are understood to be the spouse, provided that he/she has reached the age of 18, as well as the unmarried common children under 18, including lawfully adopted children. The same concept also covers other unmarried children under 18 of the sponsor or of the spouse, provided that custody has been lawfully granted to the respective parent. Furthermore, the adult children of the third-country national or of his/her spouse are expressly included, regardless of age, where they lack legal capacity and cohabit and are maintained by the sponsor, on the basis of the required court decision or an equivalent document recognised in the Greek legal order. Family members of a Greek citizen The concept includes the spouse and the partner under a civil partnership agreement, provided that the agreement has been concluded in Greece or before a Greek consular authority. It also includes direct descendants in the direct line under 21 or regardless of age where they are dependants, as well as directly dependent ascendants, including, as applicable, the corresponding persons of the spouse or partner. Of particular importance is that adult children who, as third-country nationals, lack legal capacity are expressly included regardless of age, where they cohabit and are maintained by the Greek citizen. Finally, another person not falling within the above categories may also be recognised as a family member, provided that he/she is maintained and serious health reasons make his/her personal care absolutely necessary. Family members of an EU citizen Similar provisions apply to family members of a Union citizen, recognising the spouse or, where applicable, the partner in a registered partnership relationship where such partnership is recognised as equivalent to marriage under the applicable regime. The concept includes descendants under 21 or dependants regardless of age, dependent ascendants, as well as adult children who, as third-country nationals, lack legal capacity and cohabit and are maintained by the sponsor. 7. Family members of a Greek citizen: permanent residence and a personal right of residence The residence regime for family members of a Greek citizen who are third-country nationals is strengthened. Permanent residence (type “M.3”) Family members of a Greek citizen who lawfully reside in Greece together with the Greek citizen for a continuous period of five (5) years acquire a right of permanent residence. The relevant permanent residence card is granted by decision of the competent authority, subject to grounds of public order and security, and is renewed every ten (10) years. An interruption of residence not exceeding two (2) consecutive years from the expiry of the residence card does not affect the right to acquire permanent residence. After acquisition, loss of the right occurs only in the event of absence from Greece for a period exceeding two (2) consecutive years. Personal right of residence The maintenance of a personal right of residence is safeguarded in cases of the death of the Greek citizen, dissolution of marriage or civil partnership under specific time conditions, or particularly difficult situations, such as where the family member became a victim of domestic violence. 8. Family reunification under investment residence titles For residence permits granted for investment reasons, the circle of family members is expanded. Beyond the spouse or partner and children up to 21, it is now possible to include adult children regardless of age, provided that they are third-country nationals, lack legal capacity, cohabit and are maintained by the sponsor. Lack of legal capacity is proven by a final court decision either of a Greek court or of a foreign court recognised in the Greek legal order, or by an equivalent document of the competent authority of the country of origin or habitual residence, duly legalised and translated. For children who reach the age of twenty-one (21), the granting of an autonomous residence permit of three-year duration is provided, upon submission of the previous family reunification permit. 9. Residence permit for studies (type “H.1”) The residence permit for studies has a duration equal to the maximum duration of studies of the specific programme and may be renewed, provided the educational institution certifies the maintenance of student status and the legal requirements continue to be met. Where the permit is granted for the entire duration of the programme, the student is obliged every two years to submit proof of enrolment and participation in examinations, as well as evidence of academic progress. In case of non-compliance within two (2) months after the end of the two-year period, the permit is revoked and the student must leave the country. Moreover, a special provision is introduced for third-country nationals who successfully complete their studies in Colleges and hold a residence permit type “H.5.2”. After graduation, they may apply for a residence permit for the purpose of seeking employment or engaging in entrepreneurial activity (residence permit type “H.11”), in accordance with the general provisions governing that regime. In this case, the rules concerning duration, conditions, rights and restrictions of the residence permit for job-seeking or entrepreneurship apply mutatis mutandis. 10. “Second-chance” residence permit (type “I.9”) By decision of the Secretary of the Decentralised Administration, an initial residence permit is granted to third-country nationals who held a definitive residence title or a residence card for at least five (5) years, the validity of which has expired, or whose issuance and service took place after its expiry, during the last year before the entry into force of the relevant law, and which was not renewed, or was revoked, or whose renewal application was rejected. 11. Special residence permit for third-country nationals over 65 years of age (type “A.4”) A special residence regime is provided for third-country nationals who have reached the sixty-fifth (65th) year of age and permanently reside in Greece, in cases where the residence permit they held cannot be renewed under the general provisions of the Migration Code. More specifically, the possibility is provided to grant a residence permit type “A.4” to persons who have not acquired an entitlement to a pension from a Greek social security institution due to failure to complete the required insurance days and who have developed the centre of their vital interests in Greece over a long period of time, which cannot be less than twenty (20) years. A further basic condition for granting the permit is the existence of private insurance that fully covers health risks during residence in the country. New categories of national entry visas 12. Visa “Z.13” for specialised technical staff of major investment projects A special national entry visa is established for third-country nationals who are transferred from an undertaking established in a third country to Greece, under a contract with a domestic company, for the purpose of constructing and operating production units in the sectors of technology, pharmaceuticals and industry. The visa is valid for the time required to fulfil the contractual obligation and may not exceed a total of twelve (12) months. It is required, inter alia, that the amount of the investment exceeds ten million (10,000,000) euros and that the contract expressly provides for the assumption of expenses for accommodation, full medical and pharmaceutical care (including expenses in the event of a work accident) and return travel. The visa holder may submit a request for a residence permit type “E.1” or “E.4” only with the domestic company or with another employer with its consent. Otherwise, he/she must depart within the period of validity of the visa. 13. “Tech Visa” – category “Z.13A” for Elevate Greece companies A twelve-month national entry visa is introduced for third-country nationals who are employed exclusively by companies registered and active in the National Register of Start-ups (“Elevate Greece”). The visa immediately grants the right of access to salaried employment with that specific employer, without requiring the prior issuance of a residence permit. It requires, inter alia, an employment contract of at least twelve months and a gross annual salary at least equal to 1.6 times the average gross annual salary in Greece, as well as evidence of high professional qualifications. During the visa’s validity, changing employer is not permitted. In the event of termination of the employment relationship—except where the employer breaches terms—the third-country national must depart immediately from Greek territory. Before the visa expires, an application may be submitted for a residence permit type “E.1” (EU Blue Card), provided employment continues with the same undertaking and the legal conditions are met. The possibility is provided for accompanying family members with a corresponding twelve-month national visa. 14. “Talent Visa” – category “Z.15” for persons with high educational qualifications A twelve-month national entry visa is established for third-country nationals who are graduates of a higher education institution abroad and holders of a master’s, doctoral or post-doctoral qualification obtained within the last five years, from an institution included in at least two international ranking lists, as determined by regulation. The visa aims at seeking employment or developing a professional activity and is granted subject, inter alia, to the existence of sufficient resources for subsistence. Before it expires, the person concerned may apply for a residence permit, provided the applicable legal conditions are met. 15. Obligations and sanctions for private individuals • Restrictions on the leasing of real estate to third-country nationals. The leasing of real estate to a third-country national who does not hold a passport or another travel document recognized by international conventions is not permitted, nor to a person who does not have a valid entry visa or residence permit. In the event of a violation, an administrative fine is imposed, by decision of the Secretary of the Decentralized Administration, ranging from EUR 1,500 to EUR 3,000. • Inaccurate declarations and unlawful access to employment. An administrative fine of EUR 150 is imposed on citizens who submit inaccurate declarations or certificates provided for under the applicable framework, as well as on third-country nationals who, although holding a residence permit, provide salaried work, services, perform work, or engage in independent economic activity without holding the corresponding permit/title that grants them the right of access to the labour market. • Facilitation of illegal stay or obstruction of checks. Anyone who facilitates the illegal stay of a third-country national or obstructs the investigations of the competent authorities for his/her identification, arrest and deportation shall be punished by imprisonment of at least two (2) years and a monetary penalty of at least EUR 5,000. If the act was committed for selfish motives, the penalties are increased to imprisonment of at least three (3) years and a monetary penalty of at least EUR 10,000. • Unlawful possession or use of travel documents. The unlawful possession or use of a passport or another travel document of a third person, as well as the possession or use of a forged travel document, is punishable by imprisonment of at least three (3) years and a monetary penalty of at least EUR 10,000. • Consequences for third-country nationals with lawful residence. In addition to the administrative or criminal consequences for the private individual involved, conduct linked to violations of the above rules may also be assessed at the level of the third-country national’s residence status, in particular where issues of public order or security arise, with possible effects on the renewal or the maintenance of the residence permit. Legal support Our firm specialises in immigration and residence law for third-country nationals, undertaking full legal eligibility checks, the strategic selection of the appropriate regime, the preparation and filing of applications before the competent authorities, as well as the handling of revocation or refusal cases. With systematic monitoring of legislative developments and experience in complex administrative procedures, we provide well-substantiated and tailor-made support to individuals, families, businesses and investors seeking lawful establishment and activity in Greece.
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