GREECE Law and Practice Contributed by: Ioannis Charalampopoulos, Petros Machas and Alexandros Saratsiotis, Machas & Partners
3. Fund Managers 3.1 Origin of Promoters/Sponsors of Alternative Funds
2.10 Anticipated Changes for Funds Several important forthcoming legal and regulatory changes will affect alternative funds in Greece and could impact earlier responses in this chapter: • AIFMD II (Directive (EU) 2024/927): Entered into force on 15 April 2024, bringing major reforms to the AIFMD regime covering delegation, liquidity risk management, supervisory reporting, deposi - tary and custody services, and harmonised rules for funds that originate loans. Key changes include new liquidity tools (e.g., redemption gates, swing pricing), enhanced reporting and depositary flex - ibility, including cross–border depositary appoint - ments, and calibrated loan origination rules to facilitate pan–European private credit funds. EU Member States, including Greece, are required to transpose the Directive into national law by 16 April 2026, with certain reporting provisions extending to 16 April 2027. As of now, AIFMD II has not yet been transposed into Greek legislation and is therefore not yet part of the domestic legal framework. • Expanded Bank of Greece Reporting (Reg. 2695/23.06.2025): Beginning 1 December 2025, all investment entities operating in Greece (including AIFs, REICs, UCITS, etc) must submit detailed statistical reports to the central bank on holdings, loans, returns, liabilities, and fees. UCITS report monthly; other entities report quarterly. The first transmission of accounting data for monthly reports will have a reference period of December 2025 and will occur by the 10th working day of January 2026. For quarterly data, the reference period will be the fourth quarter of 2025. These reforms collectively signal a trend towards modernisation, enhanced investor protection, clar - ity around emerging asset classes, and streamlined licensing/capital market access – important factors for structuring and operating AIFs in Greece in the near term.
Promoters and sponsors of alternative funds estab - lished in Greece typically originate from a diverse range of jurisdictions, both within the European Union and third countries. A significant portion of sponsors comes from EU Member States, notably Luxembourg and Cyprus, due to their established fund ecosystems and regulatory proximity. These jurisdictions often host the fund’s ultimate holding structures or related SPVs, while Greece is selected when investments are intended to be deployed locally (e.g. real estate, infra - structure, or private equity opportunities in Greece or the broader Southeastern Europe region). While Greece has not yet been established as a pri - mary jurisdiction for international sponsors setting up funds on a stand-alone basis, its strategic geo - graphic position, the improving and maturing regula - tory landscape, and tailored vehicles such as VCMFs attract sponsors aiming to combine local substance with broader cross-border structuring. The establish - ment of Greek fund managers to access EU marketing passports under the AIFMD framework is a common practice and the main jurisdiction for funds under management is Luxembourg. Greek sponsors (rang - ing from investment firms, family offices, and financial institutions) also play a substantial role, particularly in domestically oriented strategies. 3.2 Legal Structures Used by Managers The legal structures used by sponsors to serve as alternative fund managers revolve around regulated corporate forms. • For mutual fund AIFs, management must be carried out by an Alternative Investment Fund Manager (AIFM). The AIFM may be established in Greece as a société anonyme licensed under Law 4209/2013 or in another EU Member State, provided it is authorised under the AIFMD frame - work and has completed the required passporting procedures and notifications. • For VCMFs, management is assigned either to a venture capital mutual fund management com - pany established as a société anonyme solely
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