GREECE Trends and Developments Contributed by: Elizabeth Eleftheriades, Victoria Mertikopoulou, Argyro Pertsinidou and Angelos Charalampidis, Kyriakides Georgopoulos Law Firm
• PE firms that originate from outside the EU; • PE firms that originate from the EU but that are ultimately controlled by non-EU entities/persons; or • PE firms that originate from the EU in which non- EU entities/persons hold at least a 10% stake. The process involves submitting a detailed filing to the Ministry of Development, which then determines whether the investment raises any national security concerns. In straightforward cases, clearance may be granted within approximately 30 days. However, more complex cases may trigger an in-depth review that can take approximately 150 days. This new layer of regulatory oversight means that PE investors must incorporate FDI risk assessments and approval timelines into their deal planning. Failure to comply with the law can result in financial penalties or, in extreme cases, the unwinding of a completed transaction. As such, legal advisers must be engaged early in the process to identify any potential FDI trig - gers and prepare the necessary documentation. Labour and Employment Law Developments Μajor reforms have significantly reshaped the labour law landscape in Greece, with important implications for employers, including those involved in corporate transactions such as M&A. A key development is the gradual implementation of the digital work card system across certain business sectors, which is expected to be completed for all employers in 2026. The digital work card constitutes a compliance mechanism designed to monitor employ - ees’ actual working hours and to ensure adherence to statutory working time limits. In this context, it is essential that businesses maintain effective techni - cal interfaces with ERGANI II (ie, the employee digital platform of the Greek Ministry of Labour) and ensure that employees are adequately informed about their obligations under the new system. Failure to comply with the foregoing may result in substantial adminis - trative penalties following labour inspections. Furthermore, recent legislative measures have enhanced transparency regarding the terms and con - ditions of employment. In this context, employers are required to update employment contracts to reflect
essential working terms – such as working hours, job responsibilities or remuneration structures – in line with the new legal requirements. The objective is to ensure that all employees are clearly and proactively informed about the essential terms of their employ - ment relationship. It should be noted that existing labour legislation was recently consolidated and codified under the new Uni - fied Labour Code, adopted by Presidential Decree 62/2025. From a PE perspective, these reforms require thor - ough due diligence. Investors must assess whether target companies are compliant with new labour obli - gations, especially in relation to worktime monitoring and employee rights. Employment liabilities can sig - nificantly impact the valuation of a business and may necessitate post-acquisition integration measures such as policy updates, training programmes and software investments. Environmental and Sustainability Considerations Environmental, social and governance (ESG) factors are becoming increasingly important for PE investors, and 2025 has brought significant regulatory develop - ments in this area in Greece. One of the most impactful changes relates to coastal development. New legislation has introduced digital auctions for beach concession rights, replacing older discretionary methods. At the same time, the gov - ernment has expanded the boundaries of protected Natura 2000 zones and imposed stricter land-use regulations for areas near coastlines and ecologically sensitive environments. This is especially relevant for investments in tourism and hospitality, which often involve coastal properties. Additionally, the legal framework for REICs has been amended to support sustainability goals. REICs are now permitted to develop small-scale renewable ener - gy projects for their own consumption. This allows investment vehicles managed by PE firms to reduce operational costs, improve ESG performance and comply with emerging EU climate disclosure stand - ards.
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