GREECE Trends and Developments Contributed by: Stefanos Charaktiniotis, Danai Falconaki, Stathis Orfanoudakis and Nadia Axioti, Zepos & Yannopoulos
Introduction Following a confident recovery in M&A activity dur - ing 2024, the Greek M&A market sustained its strong momentum through 2025, demonstrating continued resilience and growth. Greece’s M&A landscape reached unprecedented heights in 2025 with 183 transactions generating EUR20.6 billion in deal value, more than doubling the EUR7.0 billion recorded in the previous year. This performance positions Greece as a relatively strong performer in the European market, which experienced a decline in deal volumes in the final quarter coupled with more selective activity. In parallel, the capital markets played a significant role for Greek companies, as initial public offerings (IPOs), equity fundraisings and corporate bond issuances drew oversubscribed interest, reflecting renewed investor confidence in Greek assets. Notwithstanding this strong performance, several defining trends shaped the 2025 landscape. The intro - duction of Greece’s national foreign direct investment (FDI) screening regime under Law 5202/2025 marked a pivotal moment for transactions involving foreign investors, particularly in sensitive sectors such as technology and defence, which have emerged as are - as of growing strategic and geopolitical importance. At the same time, deal timelines have significantly extended, and an increasing number of transactions are being aborted even after prolonged negotiations, reflecting persistent valuation gaps. Furthermore, while mega-deals drove aggregate value, the mid- market did not see comparable growth, mirroring broader EMEA trends where activity shifted towards fewer but significantly larger transactions. The predictions for 2026 appear cautiously optimistic, particularly in the mid-market segment, where inbound investor activity remains robust while family-owned businesses increasingly explore strategic alternatives. Greece is well-positioned to benefit from a strategi - cally favourable European environment, particularly for assets offering visible cash flows and regulatory clarity. Sectors such as technology, media and tel - ecommunications (TMT), hospitality and tourism are likely to lead the deal flow pace for yet another year, but it remains to be seen whether the recent trends in terms of M&A activity in the healthcare and food and beverage sectors will follow the same pace in 2026.
FDI and Tightened Regulatory Scrutiny On 23 May 2025, in alignment with Regulation (EU) 2019/452, the Greek Parliament enacted Law 5202/2025, establishing a comprehensive national framework for the screening of foreign direct invest - ments that may pose risks to security or public order. The law targets investments in sensitive sectors (eg, energy, transport, health, ICT/digital infrastructure) at more than 25% stakes and in particularly sensitive sectors (eg, defence, cybersecurity, AI, ports, critical underwater and border-area tourism infrastructure) at more than 10% stakes. Foreign investments fall under the screening criteria if made by a third-country investor, or by an EU investor controlled by or con - nected to third-country persons, undertakings or gov - ernments. Procedural Joint Ministerial Decision no. 64260/11.11.2025 supplemented the law and estab - lished the notification process before the Interminis - terial Committee for the Screening of Foreign Direct Investments (FDISIC), which reviews notified transac - tions and within 30 days either exempts or opens an investigation that may result in approval, conditional approval, prohibition or reversal. A separate Joint Ministerial Decision is anticipated to establish a dedi - cated regime of fines for non-compliance. Sanctions are expected to range from EUR5,000 to EUR100,000, with the possibility of fines reaching up to twice the investment value in cases of serious violations. The national FDI screening regime, coupled with restrictions applicable to foreign investments involving real estate occupation or ownership in border regions and on certain islands for national security reasons as well as other sector-specific regulatory requirements, reflects a broader trend of intensifying regulatory scru - tiny. These developments often demand earlier and more strategic engagement with regulatory authorities, more thorough due diligence processes, and more carefully drafted condition precedents in transaction documentation. Both buyer and seller sides should allocate sufficient time and resources to the regulatory workstream, engage experienced local counsel at an early stage, and build appropriate flexibility into deal timetables to accommodate the increasingly rigorous regulatory environment, particularly given the uncer - tainties inherent in the newly introduced FDI regime. Market participants that proactively manage regula -
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