A URL that sells two things that cannot go together
Fetch this on 20 August 2026 and read the address bar before the copy: apartments-for-sale-in-athens-for-golden-visa-or-airbnb-use. The H1 says the same thing in sentence case: "Unlock Your Dream Residence in Athens: Golden Visa & Airbnb Investment Opportunities." The slug is not an accident of a content management system. Somebody chose those two nouns and joined them with a conjunction because both of them convert.
That combination is the precise thing the Migration Code forbids on property bought to obtain or renew an investor residence permit. Not discourages, not regulates. Forbids, with a number attached. The provision has been in force since 2024 and the interpretative circular restated it in April 2026, and the sales pages have not moved. This page is about the gap between the two, and about the part of the story that the enforcement record does not yet tell.
The short version
- Article 100 §7A of Law 5038/2023, added by Article 64 of Law 5100/2024, bans short-term letting in the sharing economy and subletting of property acquired in full ownership for the grant or renewal of an investor permit.
- Penalty: revocation of the permit plus a standalone €50,000 administrative fine on the owners or holders, collected as public revenue under KEDE.
- Short-term letting is defined by Article 111 of Law 4446/2016 as under 60 days with no services beyond accommodation and bed linen, whether or not a platform is used. The ban is wider than "Airbnb".
- Still allowed: long-term leases, and subleases to tourism enterprises under Article 1 §2 of Law 4276/2014 that genuinely offer services. Conversion-route property still cannot be a company seat.
- Older files are outside the ban: purchases under previously applicable provisions, and completions inside the Article 64 §4 transitional window.
- Named gap: no published count of §7A fines or revocations. General short-term-rental enforcement statistics exist, on a different legal basis, and are not the same thing.
What the statute actually says
The consolidated text of Article 100 of the Migration Code carries paragraph 7A, inserted by Article 64 of Law 5100/2024. Read against the TaxHeaven consolidation of Άρθρο 100 του Ν. 5038/2023 and of Άρθρο 64 του Ν. 5100/2024, with the Ministry-hosted PDF of Law 5100/2024 as consolidated with Law 5167/2024 alongside it, the operative sentence is this.
Τα ακίνητα που αποκτώνται κατά πλήρη κυριότητα για τη χορήγηση ή την ανανέωση της άδειας διαμονής επενδυτή δεν επιτρέπεται να εκμισθώνονται βραχυχρόνια στο πλαίσιο της οικονομίας του διαμοιρασμού, ούτε να υπεκμισθώνονται.
Property acquired in full ownership for the grant or renewal of an investor residence permit may not be let on a short-term basis within the framework of the sharing economy, and may not be sublet.
Three further rules travel with it in the same paragraph. Property acquired through the change-of-use route in §2(c) may not be used as the seat or a branch of a company. Breach of the letting prohibition triggers revocation of the residence permit and, separately, an administrative fine of €50,000 imposed on the owners or the holders of the permit, treated as public revenue and collected under the KEDE public-debt collection code. And two figures belong to the listed-building route rather than to letting: €150,000 where the required restoration is not completed by the first renewal, and €150,000 plus revocation where a listed building is transferred before the restoration is done.
One sourcing error is worth naming because it circulates in marketing copy. The €50,000 fine is not a creation of Law 5275/2026. It arrived in §7A through Law 5100/2024. If a page tells you the penalty is new in 2026, it has not read the paragraph, and the practical consequence of that mistake is that a buyer thinks they have a grace period they do not have.
What "short-term" and "sharing economy" actually mean
The prohibition uses terms of art, and the terms are defined elsewhere. Circular 1/2026, at Clarification 7, points at Article 111 of Law 4446/2016 (ΦΕΚ Α' 240). Sharing economy there means any model that uses digital platforms to create an open market for the temporary use of goods or services. Short-term letting means the letting or subletting of real estate, irrespective of whether it is posted on a digital platform, for a specific duration of less than 60 days, provided that no services are offered other than accommodation and bed linen.
Read those two definitions together and the scope of the ban stops being about a brand. A 59-day arrangement with a private tenant, agreed by email, never listed anywhere, with clean sheets on arrival and nothing else provided, is inside the definition of short-term letting. Delisting from a platform does not move a file out of §7A. Some professional summaries of the circular describe the restriction as reaching digital platforms only. Where the readouts differ, we take the circular read together with 4446/2016, because that is the definition the circular itself cites.
The date of the circular is itself a small clash in the secondary sources. Varnavas publishes its unofficial English translation dated 22 April 2026, while EY's tax alert dates it 21 April 2026. We write "Circular 1/2026 (Ministry, April 2026)" rather than pick a winner. The substance is not in dispute across Kanellos and IMI Daily's 22 April 2026 coverage.
What is still allowed
The ban is narrower than "you cannot earn from this property". Clarification 7(a) leaves long-term leases open, which is the income route that survives. It also leaves open a sublease to a tourism enterprise operating professionally under Article 1 §2 of Law 4276/2014, on the condition that services other than accommodation and bed linen are genuinely offered. The logic is consistent rather than generous: real hospitality services take the arrangement outside the Article 111 definition of short-term letting, so it is no longer the thing that §7A prohibits. A tourism label with no services behind it puts you back inside.
Two groups of owners sit outside the prohibition entirely, under Clarification 7(b). Properties acquired under previously applicable provisions, and properties completed inside the transitional window in Article 64 §4 of Law 5100/2024, which required a 10% deposit or a signed agreement by 31 August 2024. Law 5167/2024 extended the completion deadline to 28 February 2025, with 30 April 2025 as the close for buying an alternative property. Article 64 §3 adds that permits granted under the old framework remain in force and are renewed where the conditions that applied at grant continue to be satisfied. Watson Farley & Williams sets out the same transitional structure in its note on Law 5100/2024.
Can I let this Golden Visa property?
Article 100 §7A prohibits short-term letting in the sharing economy, and subletting, of property acquired in full ownership for the grant or renewal of an investor permit. Article 111 of Law 4446/2016 defines that as letting for less than 60 days with no services beyond accommodation and bed linen, whether or not a platform is involved.
The consequence in the same paragraph is revocation of the permit plus a €50,000 administrative fine on the owners or holders, collected as public revenue under KEDE.
Five live pages that still sell the old product
We read the public pages below on 20 August 2026. We did not contact anyone and we are not quoting a person. The claim being tested is narrow: does the page, as published, sell a Golden Visa buyer a use of the property that Article 100 §7A removes.
| Page and what it says | Verdict | Against the statute |
|---|---|---|
| greecegoldenvisa.com.gr, "Airbnb returns" Published 31 August 2025, title still carries 2026. Opens: "For many international investors purchasing property through the Greek Golden Visa Program, rental income is an important component… short-term rentals remain one of the most profitable ways to generate yield from a well-located property." Later: "transforming your Greek property from a static real estate holding into a dynamic, high-performance business asset that significantly enhances the overall ROI of your Golden Visa investment." | Sells the banned use | There is a hedge mid-page about verifying whether short-term letting is permitted, but it sits under a title that pairs Airbnb yield with the Golden Visa. For a post-2024 qualifying property that pair is what §7A forbids. |
| greekexclusiveproperties.com, "Golden Visa & Airbnb Investment Opportunities" The URL slug is apartments-for-sale-in-athens-for-golden-visa-or-airbnb-use. Body: "Whether your goal is securing European residency or optimizing your investment through Airbnb rentals, we offer end-to-end support." | Sells the banned use | The "or" is doing work the statute does not allow on one property. The same page also writes "over 3,000 residents" where the threshold is 3,100, and lists Ithaca as an €800,000 island. Both are zone errors, and we set out what the zones actually are in the zone map. |
| greekexclusiveproperties.com, maisonette in Voula Labelled "Golden Visa Eligible" with "Strong demand area for both long-term and short-term rentals." Attica, €795,000. | Two problems | The short-term half of the rental pitch is unavailable on a qualifying property, and at €795,000 in Attica it also sits under the Zone A €800,000 floor, so the eligibility label does not survive either. |
| homea.gr, Greece Golden Visa page The compliance box states that short-term letting is not allowed. The furnishing FAQ on the same page says "Furnishing your Golden Visa property makes it immediately attractive to international tenants and short-term rental guests," and claims full furnishing can raise rental income by 20 to 30% versus unfurnished. | Contradicts itself | The restrictions box is correct. The furnishing pitch on the same page monetises the audience the box just told to stay away. A reader who arrives through the FAQ never sees the box. |
| greekexclusiveproperties.com, north Athens units at €260k 40 m² Attica units at €250,000, "last chances to lock in EU residency at the €250K level", with the visa obtainable "before the completion of construction". | Timing is wrong | The §2(c) change of use has to be completed before the application, and Clarification 5 of the circular rules out a paper-only change of use. A permit promised before completion inverts the condition that makes €250,000 available at all. |
An honourable mention that does not make the five: Grekodom's November 2025 guide still carries a €260,000 Kavala example against a €250,000 floor. Kavala is Zone B at €400,000 unless the property is a genuine §2(c) conversion or a listed restoration. The page is at grekodom.com. Several firms do lead with the ban rather than around it, and they are not on this list for that reason.
Expert tip
If an agent is selling you Golden Visa and Airbnb on the same listing, the listing is selling a product the Migration Code removed. Long-term rent is the remaining income story, and Greek long-term yields are modest. Run them against the €350,000 fund route on the real-estate page before you treat "the flat will carry itself" as a given, and price the acquisition costs from the Greece cost chapter rather than from the brochure.
Enforcement is the named gap
Here is the part a marketing page would leave out. We could not find a published series of §7A enforcement. No monthly or annual count of €50,000 fines. No count of investor permits revoked for short-term letting. Searches of the Ministry of Migration and Asylum, AADE and Greek press on 20 August 2026 did not return a figure of the form "X permits pulled, Y fines at €50,000". Article 64 §2 of Law 5100/2024 authorises a joint ministerial decision to set the procedure for checking compliance with Article 100 and for collecting the §7A fines. We have not found its output published as a public dashboard.
IMI Daily reached the same open question from the other direction when it covered the circular, noting that whether the crackdown produces systematic audits or functions mainly as deterrence will shape how much the circular actually changes on the ground. That is the honest state of it in August 2026.
What is published is general short-term-rental enforcement, and it is a different legal basis: registry number obligations, activity codes, Law 5170/2025, ordinary tax audits. Greek reporting via Pliroforia describes AADE targeting 1,545 natural persons holding three or more properties, 2,145 listings deactivated for missing or fake registry numbers, and declared short-term rental income of €973.7m for 2025, with fines starting at €5,000 and doubling on repeat. The AADE circular sets out that machinery. None of those numbers are Golden Visa counts, and anyone presenting them as such is borrowing the credibility of a different dataset.
| Question | Art. 100 §7A, Golden Visa | General short-term rental rules |
|---|---|---|
| Who is caught | Owners of property used to grant or renew an investor permit | Any short-term rental operator in Greece |
| Money penalty | €50,000, standalone, on owners or permit holders | From €5,000, doubling on repeat, under the tax and registry rules |
| Non-money penalty | Revocation of the residence permit, family included | Listing deactivation, registry sanctions, tax assessment |
| Enforcing body | Migration authorities, procedure set by JMD under Art. 64 §2 | AADE |
| Published outcome data | Not found as of 20 August 2026 | Yes, in AADE communications and press reporting |
Where the yield buyer actually appears
We looked for the first-person account. Someone who bought a Golden Visa flat for short-let income and then met §7A. We did not find a live Reddit or Hacker News thread of that shape, and we are not going to manufacture one.
What does exist is anticipation. An Expat.com thread on buying a holiday home in Greece, running around 2024, has the pattern in miniature: a retiree planning a purchase partly for short-let income, and a regular participant explaining that a restriction aimed at Golden Visa property is coming. That is the buyer profile, visible before the rule bit, in a forum where nobody was selling anything.
So the yield buyer is documented twice: in 2024 forum anticipation, and in 2026 agent copy that still promises the yield. The punished yield buyer is not in the public record this research reached. That absence is the finding, and it cuts both ways. It does not mean the fine is theoretical, because the statute does not require a press release to be applied. It does mean nobody can currently tell you the odds, and any adviser who quotes you one is guessing.
Frequently asked
Can I put my Golden Visa flat on Airbnb?
Not if the property is the one that got you the investor permit or is being used to renew it. Article 100 §7A of the Migration Code, added by Article 64 of Law 5100/2024, says property acquired in full ownership for the initial grant or the renewal of an investor residence permit may not be let short term in the sharing economy, and may not be sublet. The consequence written into the same paragraph is revocation of the permit plus a standalone administrative fine of €50,000 on the owners or holders, collected as public revenue under the KEDE public-debt collection code. A separate property you own outside the qualifying investment is a different question and is governed by the ordinary short-term rental rules, not by §7A.
Does the ban apply if I let privately, rather than on a platform?
On the reading in Circular 1/2026 it does. The circular points at Article 111 of Law 4446/2016 for the definitions, and that article defines short-term letting as the letting or subletting of real estate, irrespective of whether it is posted on a digital platform, for a specific duration of less than 60 days, provided no services are offered other than accommodation and bed linen. The words that matter are 'irrespective of whether it is posted on a digital platform'. A 59-day private arrangement with a friend of a friend, with no services beyond a made bed, sits inside the definition. Some professional summaries describe the ban as covering digital platforms only. We prefer the circular read together with 4446/2016, which is broader.
Are long-term leases allowed?
Yes. Clarification 7 of Circular 1/2026 keeps long-term leases open, and long-term letting is the remaining income story for a Golden Visa property. There is a second permitted case: a sublease to a tourism enterprise operating professionally under Article 1 §2 of Law 4276/2014, where services beyond accommodation and bed linen are actually offered, which is what takes the arrangement outside the short-term-letting definition. One carve-out survives regardless: a property acquired through the §2(c) change-of-use route may not be used as the seat or a branch of a company, even where letting it long term would be fine.
I bought under the old €250,000 rules. Am I banned too?
Clarification 7(b) puts two groups outside the ban. Properties acquired under previously applicable provisions, and properties completed inside the transitional window created by Article 64 §4 of Law 5100/2024, where a 10% deposit or a signed agreement was in place by 31 August 2024. That completion deadline was later extended by Law 5167/2024 to 28 February 2025, with a 30 April 2025 close for an alternative property. Article 64 §3 also keeps old-framework permits in force and renewable so long as the conditions that existed at grant continue to be met. This is exactly the point where you want a lawyer to date your file rather than a website to reassure you, because the whole answer turns on which side of a deposit date you sit on.
What is the actual penalty?
Two things at once, and the second is the expensive one.
- •Revocation of the investor residence permit, which reaches the family members who hold derivative permits, not only the investor.
- •A standalone administrative fine of €50,000 imposed on the owners or holders, treated as public revenue and collected under KEDE.
The same paragraph carries two other numbers that belong to the listed-building route rather than to letting: €150,000 for failing to complete the required restoration by the first renewal, and €150,000 plus revocation where a listed building is transferred before the restoration is done.
Is there data on how many Golden Visa permits were pulled for this?
No, and that absence is one of the findings of this piece. We searched the Ministry of Migration and Asylum, AADE and Greek press on 20 August 2026 and found no published series of §7A fines or of permits revoked for short-term letting. What is published is general short-term-rental enforcement on a completely different legal basis: registry number checks, deactivated listings, income cross-checks under the ordinary tax rules. Those are real numbers about a different regime, and presenting them as Golden Visa enforcement would be wrong. Article 64 §2 of Law 5100/2024 authorises a joint ministerial decision setting out the checking procedure and the collection of the §7A fines. We have not found a public dashboard reporting its output.
Where to go from here
If you still do not know which price tier your property sits in, the checker on the zone map settles that before letting becomes a question at all. If someone is selling you the story that the Golden Visa is pricing locals out of Greek housing, or the mirror-image story that it is a yield market worth crowding into, the numbers are in the housing-market study. If the underlying question is whether the program still earns its price at all, that argument is in is it worth it. The document list and the filing sequence sit in the Greece requirements guide, and the full dossier is at Greece Golden Visa.
Sources
- Άρθρο 100, Ν. 5038/2023 (Migration Code), consolidated text including §7A. taxheaven.gr
- Άρθρο 64, Ν. 5100/2024, the amending article that inserted §7A and the transitional provisions in §§3 and 4. taxheaven.gr
- Υπουργείο Μετανάστευσης και Ασύλου, Ν. 5100/2024 consolidated with Ν. 5167/2024, ΦΕΚ Α' 49/5.4.2024. migration.gov.gr PDF
- Άρθρο 111, Ν. 4446/2016 (ΦΕΚ Α' 240), definitions of sharing economy and short-term letting, as cited by Circular 1/2026.
- Circular 1/2026, Ministry of Migration and Asylum, April 2026. Ministry PDF not located on migration.gov.gr as of 20 August 2026. Unofficial English translation and Clarification 7 via Varnavas Law, dated 22 April 2026.
- EY Greece tax alert on the application of Article 100 of Law 5038/2023, dating the circular 21 April 2026. ey.com
- Kanellos Legal, Circular 1/2026 explained. kanelloslegal.com
- IMI Daily, 22 April 2026, on the circular. imidaily.com
- Watson Farley & Williams, note on Law 5100/2024 and the transitional regime, secondary. wfw.com
- General short-term rental enforcement, not Golden Visa: Pliroforia reporting on AADE targeting of multi-property owners, pliroforia.gr, and the AADE circular, aade.gr PDF.
- Expat.com Greece forum thread on buying a holiday home, approximately 2024. expat.com
- Live sales pages read 20 August 2026: greecegoldenvisa.com.gr, greekexclusiveproperties.com Athens page, Voula maisonette, homea.gr, north Athens €260k units, grekodom.com.
Not legal advice. Reflects Article 100 §7A of Law 5038/2023 as added by Article 64 of Law 5100/2024, and professional readouts of Circular 1/2026 available on 21 August 2026. Confirm your purchase dates, your title and the permitted use of the property with a Greek lawyer before letting it on any basis.