GREECE Law and Practice Contributed by: Anna Manda and Maria Kallidopoulou, Karatzas & Partners
9. Foreign Direct Investment/ Subsidies Review
8.3 Ability of Third Parties to Appeal Clearance Decisions Any third party that establishes a direct, per - sonal and present legitimate interest regarding the clearance decision may appeal against the HCC decision before the Administrative Court of Appeal of Athens. The relevant timeframe for the appeal (60 calendar days) starts to run from the publication of the HCC decision in the Greek Government Gazette. To the best of the authors’ knowledge, there has not been any successful appeal against an HCC clearance decision.
9.1 Legislation and Filing Requirements In April 2025, draft FDI screening legislation (the “Greek FDI Law”) was published, which aims to transpose Regulation (EU) 2019/452 into nation - al law and to establish a formal mechanism for the screening and approval of foreign direct investments in Greece. Based on the draft provi - sions, the Greek FDI Law will require that foreign investors submit a mandatory pre-closing filing for acquisitions of 25% and above in targets active in sensitive sectors (including energy and transport) and 10% and above in targets active in highly sensitive sectors (including defence and cybersecurity). In addition, apart from the notification require - ments under the Foreign Subsidies Regulation, which entered into force within 2023, the Greek legal regime does not provide for any further fil - ing requirements in relation to foreign subsidies.
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