Greece: A Corporate/Commercial Overview

Current Cconomic Landscape in Greece

The Greek economy is expected to maintain its dynamic growth in 2026, benefiting from favourable developments at an international level. Geopolitical restructurings underpin Greece's geostrategic footprint at a time when the EU seeks to gradually reduce its dependence on Russian minerals. Against this backdrop, Greece can reinforce its role as an emerging energy hub in Central and Eastern Europe, given the growing LNG sales and investments in LNG carriers, storage, and regasification units (FSRUs). In addition, Greece may benefit from ongoing restructurings in the logistics sector, where activities relocate to friend-shoring or near-shoring markets, allowing the country to develop into a transit hub and attract investments in the logistics market as well. Finally, the Greek economy is further strengthened by the global rise of tourism, capitalising on the country's competitive advantage.

The positive outlook of the Greek economy is further signalled by the performance of macro-economic indicators, including inter alia:

• firstly, the real GDP grew on an annual basis by 2% during the first three quarters of 2025, higher than the respective euro area (EA: 1.7% and Eurozone: 1.5%);
• secondly, the average unemployment rate has fallen to 9%, reduced by 1.3% compared to 2024; and
• thirdly, the improved fiscal performance, which is reflected by the rating within the investment grade by all major rating agencies, as well as in the yield on the 10-year government bond, which is lower than that of the French and Italian sovereign bonds (see Alpha Bank Issue of Economic Research dated December 24, 2025).

Moreover, the acquisition of the Athens Stock Exchange by Euronext in 2025 underscores the strong performance of the Greek economy, while enabling Greek companies listed on ATHEX to gain enhanced access to international and European investors.

The injection of funds from the Recovery and Resilience Fund (RRF) has also contributed and is expected to continue contributing to the growth of the Greek economy. In December 2025, Greece submitted its seventh request for the collection of subsidies, becoming the third EU country to do so and its sixth request for the collection of RRF loans. Following these, total disbursements shall reach EUR24.57 billion, corresponding to approximately 68,3% of the funds allocated to Greece (see https://greece20.gov.gr/7o-aitima/).

Transactional Trends During 2025

In 2025, real estate accounted for by far the greatest number of transactions in Greece, driven by both domestic and foreign activity. More than one-third of the real estate transactions focus on the hospitality sector both in Athens and the region, reflecting the dynamic rise of tourism. The second-largest category of real estate investments has been residential premises, including both luxury properties and professionally managed house rentals. The above dynamic is further reinforced by the implementation of urban regeneration projects in Athens (including the Elliniko project) and Thessaloniki. Investments in logistics centres are also taking a significant share of real estate investment portfolios.

Energy-related transactions still dominate in strategic importance and value. Acquisitions of both under-development and operating RES portfolios are continuing at a steady pace, while investments (acquisitions and financing) in energy storage projects are accelerating rapidly. This growth is driven by the newly introduced regulatory framework, incentive aid from the RRF scheme and the increasing saturation of the electricity grid. Regarding LNG, two terminals are currently operating in Greece (the Revithousa terminal operated by DESFA and the FSRU in Alexandroupoli sponsored by Gastrade), while four more LNG projects are in the licensing phase. These projects are expected to attract private equity investment and financing, including bank lending and EU funding, in the coming years.

The Greek data centre market is rapidly growing and attracting strong interest from international investors. Almost two years ago, the Greek government passed Law 5069/2023, introducing for the first time a distinct regulatory framework for the installation and operation of data centres. The country aims to position itself as a regional technology and data hub, leveraging its strategic geographic location and the growing demand for cloud computing and AI services. To date, international investors (Microsoft, Data4, Digital Realty and Dromeus Capital) have already launched data centre projects primarily in the region of East Attica, while other investors are planning on doing the same. The key challenges facing this emerging market are high energy consumption, limited cooling water availability, and the need for an accelerated licensing process. According to IPTO data, West Macedonia and Thessalia have the highest energy capacity (almost 700 MW and 650 MW, respectively), followed by Central Macedonia and Sterea Ellada (500 MW each) and Epirus-West of Greece (400 MW). Currently, an integrated data centre roadmap is being processed by the Greek government based on land planning, energy capacity and environmental criteria, with the aim to set up a safe business environment in Greece for the implementation of data centre projects.

Finally, a large number of transactions have been recorded in the food and beverage sector (with a focus on dairy products and wineries), where historic brands have been acquired and local and international funds have strategically positioned themselves in the market.

New Legislation’s Immediate Impact on Investments

The FDI screening regime introduced by Law 5202/2025 is a key piece of legislation that significantly affects foreign direct investment. In short, the legislation captures investments, both greenfield as well as mergers and acquisitions, in sensitive and particularly sensitive business sectors which are consummated by third- country investors (non-EU Member States), provided that the foreign investor holds a minimum participation in the target entity:

• at least 25% for the sensitive sectors; and
• at least 10% for the particularly sensitive sectors.

The “sensitive” sectors include energy, transport, health, information and communication technologies, or digital infrastructure, while the “particularly sensitive” sectors include defence and national security, cybersecurity and artificial intelligence, port infrastructure, critical subsea infrastructure and tourism infrastructure in border zone areas.

The law sets out a specific screening mechanism that may be initiated either upon the request of the foreign investor to the competent Directorate, set up for this purpose, or ex officio if the foreign investor fails to submit such a request. The screening mechanism may last up to 135 days if it enters the in-depth screening process.

In practice, the FDI regime introduces a new investor screening process and is applied in addition to existing procedures such as merger control and real estate investment clearances in border zone areas. Foreign investors are advised to take the FDI screening regime into account when assessing the structure and timeline of their investments, to mitigate potential delays or impacts.

KLC has been at the forefront of these investments and continues to be a key go-to law firm, leveraging its experience and legal expertise in such transactions and its leadership in the relevant legal practice areas.