GREECE Law and Practice Contributed by: Theodoros Skouzos and Natalia Skoulidou, Iason Skouzos TaxLaw
7. Foreign Investment/National Security 7.1 Applicable Regulator and Process Overview Greece adopted its first comprehensive, cross-sector FDI screening regime in May 2025 via Law 5202/2025, implementing EU Regulation 2019/452. It comple - ments existing sectoral rules (defence, media, critical infrastructure) and is mandatory and suspensory: cov - ered transactions must be notified and cannot close until clearance is granted. Competent Authority Reviews are carried out by a specialised FDI Screen - ing Authority within the Ministry of National Economy & Finance, in co-ordination with sectoral ministries and security services. The Minister issues the final decision. Investments Subject to Review The regime applies to: • non-EU/EEA investors; • EU/EEA investors controlled by third-country per - sons; and • investments conferring effective control in “sensi - tive” or “highly sensitive” sectors. The following sensitive sectors have a higher thresh - old of 25% voting rights: • energy; • transport/logistics; • ports; • airports; • water; • telecoms/digital infrastructure; • health infrastructure; • data-related ICT; and • strategic real estate. The following highly sensitive sectors have a 10% threshold: • defence/dual use;
• sensitive AI; • critical minerals; and • tourism in border regions.
Exclusions are available for portfolio (non-control) investments and purely intra-EU investors. There is no special exemption for sovereign wealth or state- owned entities. Notification and Standstill Filing is mandatory when thresholds are triggered. Signing is allowed, but closing is prohibited until approval. Review Process and Timeline Similar to other EU regimes, the following applies. • Phase 1 (30–45 days): initial assessment after filing is deemed complete. Many cases clear here. • Phase 2 (90–120+ days): launched when security/ public order concerns arise. This phase includes consultations with security bodies, ministries, the competition authority and possibly the European Commission. Possible Outcomes Potential outcomes are: • unconditional clearance; • conditional clearance (remedies); • prohibition; or • orders to amend or unwind an already implement - ed but unapproved investment. Complex reviews may last up to five months. 7.2 Criteria for National Security Review The Greek regime follows the EU’s national security framework but is tailored to domestic priorities. Core Assessment Criteria • Security of critical infrastructure – energy, water, transport, ports, airports, telecoms, health, finan - cial infrastructure. • Security of supply of essential inputs – energy, raw materials. • Protection of sensitive technologies – AI, cyberse - curity, space, defence.
• cybersecurity; • subsea cables;
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