GREECE Law and Practice Contributed by: Panagiotis (Notis) Sardelas, Matina Kagkelari and Aris Sifakis, Sardelas Petsa Law Firm
• financial institutions/credit companies licensed and supervised by the BoG (which, following the enact - ment of Greek Law 5072/2023, are permitted to grant consumer credit products, residential loans to individuals and credit solutions to indebted per - sons, both individuals and companies; or • EU-authorised banks or financial institutions oper - ating in Greece through passporting (branch or services). Foreign (third-country) lenders generally cannot offer regulated services in Greece unless they establish a licensed subsidiary. Other permissible non-bank financing avenues include factoring and leasing (which are also regulated activities). Greek law permits both domestic and foreign lenders to take security or guarantees over assets located in Greece, provided the creation and perfection follow the relevant Greek formalities, (eg, registration with the cadastre/land registry or pledge registry) and pay - ment of applicable costs or taxes. Non-EU entities face restrictions on direct ownership of real estate in specific “border areas” due to national security con - cerns. The creation, perfection and enforcement of security interests over assets in Greece are governed by Greek law, regardless of the loan agreement’s governing law. Foreign lenders can enforce their rights if they hold an enforceable title, which can often be recognised in Greece, particularly for EU judgments. 2.2 Regulators of Private Credit Funds As noted in 1.1 Private Credit Market , direct lending is a regulated activity in Greece. The BoG is the lead supervisor for entities that provide credit directly (ie, credit institutions and credit companies) or manage debt portfolios (credit servicing firms). The BoG also supervises financial leasing, factoring companies and microfinance institutions. The Hellenic Capital Mar - kets Commission (HCMC) regulates private credit when structured through investment vehicles, such as AIFs, and supervises the asset management firms overseeing them. The HCMC acts as the lead super - visory authority, operating within the broader EU regu - latory framework and in co-ordination with the Euro -
pean Securities and Markets Authority (ESMA) and other competent national authorities. 2.3 Restrictions on Foreign Investments As noted in 1.1 Private Credit Market , lending is a regulated activity in Greece. There are generally no outright prohibitions on foreign investment in private funds; however, as mentioned in 1.8 Impending Reg- ulation and Reform , significant FDIs are now subject to a mandatory screening regime, which became fully operational in November 2025. This framework requires non-EU investors – and EU entities under third-country control – to obtain prior clearance for acquisitions of 25% or more in “sensitive” sectors (such as energy, healthcare and digital infrastructure) or 10% or more in “highly sensitive” sectors (including defense, AI and cybersecurity). Pure portfolio invest - ments intended for financial purposes without man - agement influence are, however, typically exempt. 2.4 Compliance and Reporting Requirements Compliance and reporting requirements for credit pro - viders in Greece depend significantly on the specific type and regulatory classification of the respective entity – more specifically, as follows. Entities that qualify as credit institutions or regulated financial institutions fall under the supervision of the BoG and must comply with prudential, governance and periodic reporting obligations. Credit servicing firms and purchasers are operat - ing within the regulatory framework of Greek Law 5072/2023 and BoG Executive Committee Act 244/25.07.2025, effective as of July 2025, which established detailed and regular reporting obligations for credit servicing firms, with requirements covering loan portfolios, collateral policies and restructuring activities. Reporting obligations are also imposed on credit purchasers, centered on ownership structure, transparency and strategic portfolio changes. Entities structured as AIFs or managed by an AIF Manager (AIFMs) are subject to AIFMD-related trans - parency and reporting obligations under the supervi - sion of the HCMC. Following the implementation of the AIFMD II framework in Greece, AIFMs involved in loan origination activities will be required to implement
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