GREECE Trends and Developments Contributed by: Claire Pavlou, Katerina Tzamalouka and Angeliki Papadaki, Kyriakides Georgopoulos Law Firm
East, and begins to exert adverse effects on critical sectors such as transport and tourism. FDI Screening: Reshaping the Landscape of Cross-Border Transactions One of the most consequential developments for transactional practice in Greece is the enactment of Law 5202/2025, which came into force in May 2025 and established the country’s first comprehensive for - eign direct investment (FDI) screening regime. Imple - menting EU Regulation 2019/452, the law introduces a two-tier screening mechanism: investments in sensi - tive sectors – including energy, transport, healthcare, and ICT and digital infrastructure – are subject to screening where a foreign (non-EU) investor acquires a stake exceeding 25%, while a more stringent 10% threshold applies to particularly sensitive sectors such as defence and national security, cybersecurity, artificial intelligence, ports and critical underwater infrastructure, and tourism infrastructure in border areas. The screening criteria apply both to direct third- country investors and to EU-based investors where the ultimate controlling entity or beneficial interest is connected to third-country individuals, undertakings, or governments. For investors and advisers, the practical implications of this new regime are significant. In addition to the FDI screening framework, foreign investments remain subject to pre-existing restrictions on the acquisition of real estate in border regions and certain islands on national security grounds, as well as sector-specific licensing and approval requirements. Together, these overlapping frameworks demand earlier and more strategic engagement with regulatory authorities, more thorough due diligence processes, and carefully drafted transaction documentation. Capital Markets Reform and Renewed Investor Confidence The revival of Greece’s capital markets has been one of the defining features of the country’s economic rehabilitation, and 2025 saw that revival deepen and broaden considerably. The acquisition of ATHEX by Euronext is significant from a structural perspective, providing Greek-listed companies with access to a deeper pan-European investor base and enhanced market infrastructure. The anticipated upgrade of
Greece by MSCI – together with the country’s invest - ment-grade credit rating – further strengthens the case for international portfolio and strategic invest - ment, improving the perception of Greek assets among institutional investors subject to index-linked mandates. Against this backdrop, Law 5193/2025, enacted in April 2025, introduced significant capital markets reforms designed to modernise the Greek capital mar - ket regulatory framework, strengthen investor protec - tion, improve financing access for Greek companies, and align Greek law with EU standards. Equity fun - draisings and corporate bond issuances throughout 2025 drew oversubscribed interest from international investors, reflecting the scale of the improvement in sentiment towards Greek assets over a relatively short period. For companies and their advisers, this environment creates a widened range of financing options. The improved capital markets framework means that equity fundraisings, initial public offerings, and bond issuances are increasingly viable alternatives to tra - ditional bank lending, which, while improved, remains selective and pushes several businesses – particularly in the mid-market – towards alternative funding sourc - es. The evolving regulatory landscape also demands careful attention to disclosure, corporate governance, and compliance requirements applicable to listed and pre-IPO companies, reinforcing the value of integrated legal and financial advisory support throughout the capital-raising process. The pace of legislative reform in the corporate govern - ance sphere has been considerable, and its cumula - tive effect is to raise the baseline of compliance obli - gations applicable to Greek companies across several dimensions. Law 5178/2025, enacted in February 2025, trans - posed Directive (EU) 2022/2381 on improving the gender balance among directors of listed companies into Greek law, introducing significant amendments to both Law 4706/2020 on corporate governance and Law 4548/2018 on sociétés anonymes . In particular, Governance, Compliance, Regulatory Modernisation and Interconnection
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