In Greece, hotel transactions are governed by various legal sources and areas of law that ensure proper execution and regulation. The Civil Code governs contracts and property transactions, including sales and leases, while tourism law regulates hotel licensing, classification and compliance with the regulations and standards of the Ministry of Tourism. Real estate law addresses land use, zoning regulations, environmental law and property transfer processes, which are essential for hotel acquisitions and operations. Tax law covers capital gains tax, VAT and transfer taxes on hotel properties, which are critical for the financial aspects of these transactions. Labour law protects employee rights, particularly in cases of ownership changes, and involves collective bargaining agreements and social security considerations. Banking and finance law plays a significant role in securing financing for hotel acquisitions, including loans and other financial instruments. EU law governs competition and foreign investment within the EU, ensuring that hotel transactions comply with broader European regulations. Lastly, environmental law includes regulations concerning building codes and environmental impact assessments, which are necessary for hotel developments and operational compliance with sustainability standards. These combined legal areas ensure that hotel transactions in Greece are properly structured and executed.

In hotel transactions in Greece, the investment structure can be either a share deal or an asset deal, depending on the buyer’s goals, the seller’s preferences and tax considerations. The timing of the deal is typically influenced by the completion of due diligence and the receipt of any necessary regulatory approvals.

Under Greek law, a distinction is made between the creation of the obligation (the sale) and the act of transfer, as follows.

• Sale ‒ the seller agrees to sell the hotel asset to the buyer, and the buyer agrees to purchase it (a contractual transaction).
• Transfer ‒ the seller transfers ownership and possession of the hotel to the buyer, and the buyer takes ownership and possession (an in rem transaction).

Most hotel investments in Greece are structured through a Greek entity, often a société anonyme (SA) or private company (PC), which acquires and holds the hotel property. This entity is typically owned by a foreign parent company that is tax-resident in an EU jurisdiction or a third country with which Greece has a favourable double tax treaty.

The preference for share deals in hotel transactions is often driven by tax considerations. Share transactions are exempt from indirect taxes, real estate transfer taxes and share transfer taxes, except for tax on listed shares. Additionally, share deals do not require a notarial deed, unlike asset deals, which must be formalised through a notarial deed.

In conclusion, the decision between an asset deal and a share deal is a strategic one, influenced by tax incentives, legal constraints and the buyer’s business objectives, whether short-term or long-term.

In Greece, the details of hotel transactions, such as the parties involved and the sale price, are generally not made public. However, some aspects may be publicly accessible depending on the nature of the transaction.

If the deal involves an asset transfer, the transaction must be formalised through a notarial deed, which is a public document in Greece. The deed includes the names of the buyer and the seller, a description of the property and, importantly, the sale price, which must be explicitly stated as part of the formal documentation and for tax and registration purposes.

Transactions are also recorded with the Land Registry or Cadastre, where the notarial deed documenting the property transfer is officially registered. Since the deed includes the sale price, this information becomes part of the public record, along with the names of the buyer and the seller and the property description.

In the case of share deals, where the buyer acquires shares in a company that owns the hotel, the terms of the transaction are typically confidential. Share deals do not require the formalities of a notarial deed, and the sale price and other details generally remain private unless the company is publicly listed or required to disclose information under specific regulations.

While the specifics of a transaction may remain confidential, press releases or public announcements may disclose high-profile hotel transactions, including the identities of the parties involved and, in some cases, the sale price. However, this is usually at the discretion of the parties involved, particularly in cases where transparency or marketing is desired.

Confidentiality agreements often ensure that sensitive details about the transaction, such as the sale price, are kept private.

In Greece, foreign investors can establish businesses and handle most bureaucratic procedures digitally, with no discriminatory laws against foreign ownership. However, for companies based in Greece, it is mandatory to have an EU citizen as a director or legal representative, or alternatively, the investor can obtain a Greek residence permit for investment activity. Greece is a full EU and eurozone member, and all EU AML regulations apply. Foreign investors have the legal right to establish and own businesses, with reforms in place to promote investment, including a fast-track system for strategic projects and the Enterprise Greece Investor Ombudsman to assist with licensing and resolve issues.

On 23 May 2025, the Greek Parliament in line with the EU FDI Regulation enacted its long-awaited Law 5202/2025. This establishes Greece’s first FDI screening regime framework and allows the review of foreign investments that exceed the defined thresholds on grounds of public order or security. Foreign investments in designated “sensitive” or “highly sensitive” sectors must now be notified to the relevant Greek authorities and be subject to mandatory and suspensory review before they are implemented.

In Greece, various hotel ownership and management structures are commonly used, each offering distinct advantages and disadvantages. These structures include privately owned/independent hotels, hotel management agreements (HMAs), hotel lease agreements and franchising agreements.

Privately owned/independent hotels have traditionally been common, especially for small, family-run hotels in tourist regions. However, the prevalence of privately owned hotels is rapidly changing with the entry of international hotel brands. Global hotel chains are replacing many independent operations, offering brand recognition and standardised services that attract tourists. The owner retains full control over hotel operations, including pricing, staffing and marketing, while directly bearing the risks and receiving the profits.

HMAs are more common in larger or upscale hotels, particularly those owned by investors that prefer not to manage the property themselves. In an HMA, the owner retains ownership but contracts a third-party management company to handle day-to-day operations. The management company is responsible for staffing, marketing and operational efficiency, with the owner paying a management fee, often based on revenue or profit.

Hotel lease agreements are popular for larger hotels or well-known properties where investors prefer a hands-off approach. In this structure, the owner leases the hotel to a third party, which assumes full responsibility for operations. The lessee typically pays a fixed rent, often with a performance-based component, providing the owner with stable income and minimal operational involvement.

Franchising agreements are increasingly popular as global hotel brands expand in Greece. In a franchise agreement, the owner operates the hotel under the brand’s name, adhering to the brand’s standards. The owner benefits from the brand’s reputation and marketing, while paying franchise fees based on revenue.

Each structure provides varying levels of control, revenue models and risk distributions, with independent hotels offering the most control and HMAs, lease agreements and franchising models transferring operational risks to third parties.

In Greece, HMAs are typically used for international or large hotels and follow international standards and general framework agreements. These agreements are designed to maintain consistency across various jurisdictions while adjusting to local laws and regulations.

The structure of an HMA in Greece generally includes the following components.

• Parties ‒ the agreement is between the hotel owner and the management company (usually an international hotel chain).
• Term ‒ the duration usually ranges from five to 20 years, with renewal options.
• Management fees ‒ the management company receives a base fee (percentage of revenue) and a performance-based incentive fee tied to profitability.
• Responsibilities ‒ the management company handles daily operations, staffing, marketing and procurement, while the owner retains control over major decisions (eg, capital expenditures).
• Local adjustments ‒ while the terms reflect global standards, they adjust to local law issues such as labour laws, employee rights and permitting requirements.

Most HMAs in Greece follow international norms, but local regulations must be considered, as follows.

• Labour laws ‒ Greek labour laws are strict, especially concerning employee rights, unions and social security. Management companies must adjust their practices to ensure compliance.
• Tourism permitting ‒ hotels in Greece require permits from the Ministry of Tourism. The agreement must ensure compliance with classification regulations and local zoning laws.
• Taxation ‒ HMAs must adhere to local tax laws, including VAT and corporate tax. International operators must also comply with Greek transfer pricing rules, which can pose challenges in structuring fees.
• Property and environmental laws ‒ compliance with Greek building codes and environmental regulations is required for construction or renovation projects.

In conclusion, while HMAs in Greece follow global standards, they must be adapted to comply with local labour, tax and permitting regulations, presenting challenges for international hotel operators.

Hotel lease agreements in Greece typically involve a long-term arrangement between the lessor (property owner) and the lessee (hotel operator). These leases often span ten to 20 years, with options for renewal, reflecting the substantial investments involved in hotel operations. Rent is commonly structured as either fixed rent, a percentage of the hotel’s revenue or a hybrid of both. The lessee is responsible for managing the hotel, including operations, staffing, marketing and maintenance, while the lessor handles the property’s structural integrity.

Key terms of the lease also include clauses on capital expenditures and renovations, specifying responsibilities for improvements to the property. The lessee may be required to make periodic upgrades, which can be outlined in the agreement.

Exit clauses define the conditions under which either party can terminate the lease early, often involving penalties or required notice periods. Hotel lease agreements also include provisions on obtaining necessary operating licences, compliance with tourism regulations, and adherence to health, safety and labour laws. Revenue and profit-sharing terms are common, especially when rent is based on a percentage of revenue. The lease often establishes the hotel’s operating standards, ensuring consistency with brand requirements, if applicable.

Hotel lease agreements in Greece are governed by several key regulatory aspects. One important regulation is the Greek Tourism Law (Law 4276/2014) as currently in force, which mandates that hotels comply with specific classification standards, operational requirements and licensing rules. The lessee must follow a notification procedure, which has replaced the Special Operation Mark, to inform authorities before starting operations. The lawful operation of the accommodation facilities will be inspected on an ex post basis by the competent authorities.

Additionally, labour laws play a crucial role in hotel lease agreements, governing employment contracts, working hours, wages and social security contributions for hotel staff. Recently enacted Law 5053/2023 introduces new information requirements for employment agreements, such as specifying the probation period (if agreed), employee training (if required), and the social security institutions for main and supplementary insurance. Compliance with these new provisions is essential for the lessee.

Hotel leases must also adhere to Greek real estate laws, including property ownership and land use regulations. Furthermore, environmental regulations require investment in sustainable practices, presenting additional challenges for hotel operators to meet local and EU standards.

Hotel franchising agreements in Greece typically involve a long-term relationship between the franchisor (brand owner) and the franchisee (operator). The structure includes an initial franchise fee for the right to use the brand, along with ongoing royalties (typically 4–8% of gross revenue). Additional fees for marketing, training and reservations may apply. The term of the agreement is usually between ten and 20 years, with options for renewal, often contingent on the franchisee maintaining brand standards and performance targets.

The franchisee must comply with the franchisor’s operational standards, including hotel design, service quality and marketing practices. The franchisor provides continuous support, including training, brand guidelines and marketing resources. The agreement often includes exit clauses based on non-compliance with standards or financial failures.

In Greece, franchise agreements are primarily governed by general commercial and contract law, with no specific franchise legislation. However, various EU regulations, Greek Civil Code provisions and competition laws apply.

Key aspects of franchise law include the requirement to provide clear definitions of the obligations, rights and responsibilities of both the franchisor and franchisee. Franchisors must provide comprehensive pre-contractual disclosures to ensure transparency. Protecting IP, such as trade marks and branding, is critical for both parties, with franchisees typically granted the right to use the franchisor’s IP only during the term of the agreement. Franchise agreements must also comply with EU and Greek competition laws, avoiding anti-competitive practices.

Corporate law in Greece allows franchisees to operate under common structures such as the société anonyme (SA) and the private limited liability company, both offering limited liability. There are no general restrictions on foreign operations in Greece.

Under the Consumer Protection Law (Law 2251/1994), franchisees are not considered consumers, and commercial agent provisions apply to franchise agreements, including compensation and notice periods upon termination. Real estate and tenancy law may affect franchisors and franchisees, particularly when the franchisor subleases locations.

In recent years, the financing landscape for hotel transactions in Greece has evolved significantly, becoming more diverse and sophisticated. Following the financial crisis, limited bank lending and tighter credit standards pushed many investors to seek alternative sources of capital. As economic conditions stabilised and investor confidence returned, particularly in the tourism sector, hotel investments surged – supported by both traditional and non-traditional financing.

Today, hotel transactions in Greece benefit from a wide range of funding options. Traditional bank loans remain a key component, especially for well-established developers and operators. However, alternative instruments such as corporate bonds, private equity, mezzanine financing, intragroup loans and EU-backed tools such as Recovery and Resilience Facility (RRF) loans are increasingly utilised. REITs and specialised hospitality investment vehicles have also become more active in the market. This healthy diversity of financing options now coexists in a mature and competitive environment, allowing investors to structure deals creatively and efficiently. The availability of blended financing – often combining bank loans, equity, and EU-backed grants or loans – has further boosted large-scale and sustainable hotel developments.

Among these, traditional loans from Greek commercial banks, often combined with equity involvement, remain the most common form of financing for hotel acquisitions. These loans typically cover the majority of the purchase price, with the hotel property and related assets (such as equipment, operational rights and lease agreements) serving as collateral. In many cases, buyers incorporate equity capital to strengthen their financial position. This structure, sometimes enhanced through bond loans, provides a flexible and cost-effective solution due to its lower cost of capital. For larger or more complex transactions, private equity funding is increasingly used to support strategic acquisitions, particularly involving high-value or chain hotel properties. Overall, bank financing with equity involvement continues to dominate the market, offering favourable terms and flexibility, while coexisting with a broader and more sophisticated financing ecosystem that supports the growth and transformation of Greece’s hotel sector.

In Greece, foreign investors are generally permitted to finance hotel acquisitions without significant restrictions. The country maintains an open investment environment, aligning with EU regulations that ensure the free movement of capital. This openness applies to both equity investments and lending activities by foreign financiers.

When acquiring a hotel, a 3.09% real estate transfer tax is due, covering both the operating hotel and its real estate. In certain cases, this may be replaced by VAT at 24%. The transfer of the business as a going concern triggers a 2.4% digital transaction levy on the net asset value of the business. Income from hotel operations is subject to a corporate income tax rate of 22%. Depreciation for buildings is set at 4%, while equipment and fixed assets are depreciated at 10%. Hotels are exempt from the 15% annual special real estate tax if fully operational. Hotel services are subject to a reduced VAT rate of 13%, with construction and refurbishment works taxed at 24%. Real estate is subject to the Uniform Real Estate Property Tax (ENFIA), which is based on building size, location and use. A daily duty is imposed on hotel rooms depending on the star rating. Any gain from the sale of a hotel business is taxed at 22%, although if the transaction is structured as a share deal, no direct or indirect Greek taxation applies to foreign investors.

Greece offers various tax incentives and grants for hotel projects, including tax credits for foreign tax paid, enhanced job-related tax deductions, and deductions for scientific research expenses. The Strategic Investment Law (Law 4864/2021 as currently in force) supports large-scale, economically important projects with benefits such as income tax stabilisation, fast-track licensing and cash grants. The Development Law (Law 4887/2022 as currently in force) encourages tourism investments and offers aid in the form of tax exemptions, subsidies and risk financing. Greece’s Ministry of Development plans to introduce new support regimes under the Development Law, focusing on sectors such as manufacturing, tourism and border regions. Key updates include simplified procedures, enhanced transparency and a focus on sustainability, innovation and job creation. Investments will be evaluated based on equity capital, ESG criteria and project sustainability. Additionally, the country provides specific incentives for R&D, patent exploitation and green projects. Various aid schemes under the new laws promote tourism, digital transformation and environmental upgrades.

Main Zoning Classifications and Regulations Allowing Hotel Use

In Greece, there are two categories of areas governed by different legal regimes: areas within the city plan (in-plan areas), where urban planning has been completed, and areas outside the city plan (out-of-plan areas), which remain – at least partially – unregulated.

In-plan areas

In in-plan areas, permitted land uses are defined either at the municipal level or at the level of municipal units through General Urban Plans (GUPs) and Urban Planning Studies (UPSs), which are approved by ministerial decisions and presidential decrees, respectively. These plans determine land uses per urban planning unit (or even per building block), drawing on the categories set out in Presidential Decree 59/2018.

The land use category “hotel” is, in principle, permitted in areas designated for “Urban Centre” and “Tourism–Recreation” uses. Smaller-scale accommodation units (up to 150 beds) are also permitted within the “General Residential” zone, while very small units (up to 30 beds) may be permitted in areas designated as “Purely Residential”.

It should be noted that going forward, the corresponding planning regulations will be incorporated into the Local Urban Plans (to be approved by presidential decrees) and Implementation Urban Plans (to be approved by decision of the Co-ordinator of the Decentralised Administration).

Out-of-plan areas

In out-of-plan areas, land uses may be regulated by special decrees (eg, Residential Control Zones, special protective decrees for islands, etc). Otherwise, the provisions of Presidential Decree of 6/17.10.1978 (Government Gazette D’ 538) and Law 4759/2020 apply. Under that decree, the establishment of hotels is generally permitted in out-of-plan areas, subject to the specific conditions it sets out.

However, the construction and operation of a hotel may be prohibited under other applicable laws, such as forestry legislation, archaeological protection legislation and environmental legislation (eg, Natura 2000 areas), among others.

Finally, it is worth noting that in recent years, the Council of State – the Supreme Administrative Court of Greece – has imposed, through its case law, additional restrictions on the development of hotels in out-of-plan areas. For example, it has established requirements such as the presence of frontage on a road officially recognised as public via presidential decree, as well as an assessment of the carrying capacity of the area where the hotel is to operate.

Therefore, the legal regime applicable in out-of-plan areas is significantly more complex: it is not sufficient for the use to be permitted in principle; a thorough assessment is also required to determine compliance with all other legal requirements or those inferred indirectly from the Constitution, as interpreted by the courts.

Derogation for Hotel Use

In general, derogation from the applicable planning regime is not allowed. In other words, if the specific land use is not allowed in a specific area, it is very difficult to introduce it. The process would require the issuance of a presidential decree specific to the area and/or project, such as a Special Urban Plan (Article 8 of Law 4447/2016), a Special Spatial Plan for Strategic Investments (Article 7 of Law 4864/2021) or one of the other special urban planning tools prescribed by law. It should be noted that the conditions for such urban planning tools are very restrictive and most of the typical hospitality investments would not fulfil the criteria provided by law.

Finally, it should be noted that any amendments to the existing urban planning regime are permissible only to a limited extent and must not result in a fundamental alteration thereof, as such a modification would contravene constitutional provisions.

Τhe construction of hotel buildings is governed by a series of regulatory frameworks, which aim, on the one hand, to ensure the harmonious integration of such developments into the natural and built environment, and on the other, to secure their compliance with established standards of safety, hygiene and accessibility.

The most common restrictions refer to the following construction specifications.

• Applicable building terms (height, building and coverage coefficient, setbacks, etc) depend on whether the hotel is being constructed on an in-plan or out-of-plan property. For in-plan hotels, the building terms are prescribed by the relevant GUP and UPS applicable to the specific area (the building coefficient, or FAR, typically ranges between 0.6 and 1.2). Conversely, the construction of hotels in out-of-plan areas is governed by the aforementioned Presidential Decree of 6/17.10.1978 and Law 4759/2020. As a general rule, the maximum coverage ratio is set at 20%, and for plots up to 50,000 square metres, the maximum height is 10.5 metres and the building coefficient 0.18 (FAR = 18%), although exceptions and special conditions may apply.
• Density is a parameter that is intrinsically associated with the carrying capacity of an area. In urban areas, city plans typically take into account several parameters defined in Ministerial Decision No 32892/1414/2024 (GG D’ 200). In off-plan areas, where popular destinations usually are located and, therefore, hotels are developed, the issue of carrying capacity has become a concern in the last few years (as mentioned in 6.1 Zoning, this is a principle primarily introduced by the Council of State).
• Ministerial Decision No 216/2015 (GG B’ 10) specifies technical and operational requirements for hotels, including suitability criteria (eg, road access, distances from high-nuisance activities, etc) for the plot where the hotel is constructed.
• Τhe Building Construction Regulations (Ministerial Decision No 66006/2360/2023, GG B’ 3985) set out specifications for hotel buildings concerning structural safety, natural light and ventilation requirements, soundproofing and other technical matters.
• The number of required parking spaces for any type of building is determined by means of presidential decrees. For the region of Attica, said requirements are provided for in Presidential Decree 111/2004 (GG A’ 76), while for several other major cities in Greece Presidential Decree 350/1996 (GG A’ 230) is still in force. As a rule, hotels in the Attica region must provide one parking space for every six beds, whereas in other cities, the requirement typically ranges from one parking space per ten beds to one per 15.
• Hotel facilities are subject to the fire safety regulations (Presidential Decree 41/2018, GG A’ 80) applicable for establishments providing temporary accommodation.
• Hotel facilities must comply with the accessibility standards prescribed in Article 26 of Law 4067/2012 (eg, autonomous and safe access must be ensured, accessible sanitary facilities must be provided, etc). Hotels are also required to provide a minimum number of rooms for persons with disabilities, namely 5% of the hotel’s total capacity or, in any case, up to five rooms.

Building permits for hotels in Greece are primarily governed by Law 4495/2017 and Law 4002/2011. The permits are usually issued by the competent Urban Planning Office (for four- and five-star hotels, the process is handled by the Special Office for the Promotion and Licensing of Tourist Investments at the Ministry of Tourism (in Greek, EYPATE).

Prior to the issuance of the building permit, certain preliminary steps must be completed to verify whether the buildability and suitability conditions of the plot are met, depending on its location (eg, whether it is within or outside urban plans, traditional settlements, and archaeological zones) and the nature of the proposed activity (in this case, tourism development). These preliminary steps may include environmental permitting (depending on the scale of the project), through the submission of an Environmental Impact Assessment for the issuance of a Decision for the Approval of Environmental Terms. In this context, the Greek National Tourism Organisation (NTO) also provides an opinion regarding the touristic suitability of the site. Further requirements may include the approval of architectural studies by the NTO, as well as the acquisition of special approvals where applicable. Such a special approval may, for example, be required by the Architectural Council for projects located in traditional settlements, historic sites, archaeological zones or areas of outstanding natural beauty. In such cases, the Architectural Council assesses the conformity of the architectural design with the relevant regulations and restrictions, and its opinion is binding. Furthermore, special approval is required from the Central Archaeological Council (KAS) or the competent local Ephorate of Antiquities, when the property is located in an area of cultural or archaeological significance, such as historic centres, traditional settlements, or sites with excavation findings.

The application process for the issuance of a building permit is carried out exclusively electronically through the Electronic Building Permit Issuance System (e-Adeies), with the submission of all required documentation, technical studies (architectural, structural, electromechanical, etc), and special approvals where necessary, as previously outlined.

Prior to the full issuance of a building permit, a preliminary approval of the building permit may take place (as provided in Law 4495/2017, in conjunction with Law 4002/2011). The preliminary building approval certifies the right to obtain a building permit from an urban planning perspective, based on the regulations in force at the time of the pre-approval. It is generally optional, except in certain cases where it is mandatory – such as projects of particular environmental or urban planning significance, or for buildings with a surface area exceeding 3,000 square metres. For pre-approval, the required documents and studies are also submitted electronically via the Greek Government’s Unified Digital Portal, but the approval of the relevant authority of the Ministry of Tourism is required (again, for four- and five-star hotels).

As stated above, the submission and approval process takes place through an electronic system, and is therefore “automatic” in this sense. Hence, the time required for the issuance of a building permit depends on the third-party approvals and/or opinions required by law. For example, the process is significantly longer for larger hotels requiring the issuance of a Decision for the Approval of Environmental Terms. The process of the pre-approval entails the review of the submission by the building authority and is, therefore, more time-consuming; however, for the same reason, it also entails less risk for the investor, given the security that the authority’s sign-off provides.

A building permit is typically valid for four years, whereas a preliminary approval is valid for two years (conditions and exceptions apply).

Regarding a hotel refurbishment, construction work may fall into different categories: (i) works requiring a full building permit (eg, structural interventions, horizontal or vertical extensions); (ii) works requiring a small-scale building permit (eg, replacement of flooring, windows or roofing, without altering their shape or materials); and (iii) works that do not require a permit (eg, painting, internal repairs, replacement of plumbing or electrical systems, etc). Therefore, the type of permit required for the renovation of a hotel unit depends on factors such as whether the layout or capacity of the building would change, whether its external appearance would be altered, or whether its classification category (eg, star rating) would be affected.

A building permit constitutes an individual administrative act and serves as a legal prerequisite for the commencement of construction works. Under the general principles of administrative law, the validity of such an act may be challenged before the competent administrative courts through an application for annulment filed by any person with a legitimate interest.

The Council of State, through its established case law, has adopted a broad interpretation of the concept of legitimate interest, depending on the specific circumstances of each case. Notably, the Council does not always require the applicant to demonstrate close geographic proximity (eg, physical adjacency) to the property for which the building permit has been issued, in order to satisfy the requirement of personal legal interest.

The validity of a building permit may be contested within 60 days from the date on which the interested party gains actual knowledge not only of the permit’s issuance but also of its content.

In practice, there are no definitive strategies to prevent objections. However, ensuring that the building permit is issued in full compliance with all applicable legal requirements significantly increases the likelihood of a favourable outcome in any ensuing court proceedings, even if objections are raised.

The conversion of an existing building into a hotel, or the change of use of an existing hotel, is subject to multiple considerations, as follows.

• Land use regulations ‒ the intended use must be permitted under the applicable zoning or land use plan for the area.
• Building terms and restrictions ‒ particularly for plots located out-of-plan, the applicable building regulations for the new use must be observed. The change of use may also be subject to additional legislative constraints (eg, archaeological, architectural or other heritage-related restrictions).
• Building specifications ‒ specific technical standards may apply to certain types of buildings. For example, hotel buildings must comply with the requirements outlined in 6.2 Building and Development Regulations.
• Ownership-related restrictions ‒ if the building is co-owned, the consent of all or the majority of the co-owners may be required, depending on the applicable legal framework.

Accordingly, the legality of any intended conversion must be assessed on a case-by-case basis.

The protection of cultural heritage in Greece is governed by Law 4858/2021. The core principle is that any intervention (eg, renovation, change of use, restoration) on a building recognised as a monument requires prior authorisation from the competent Ministry (typically, the Central Council of the Ministry of Culture for Modern Monuments or the Architectural Council of the Ministry of Environment and Energy). All works must aim to preserve the monument and must not alter its character or authenticity.

When a hotel operates within a listed building, historic site or archaeological zone, the following restrictions apply.

• Prior approvals ‒ any construction work, renovation, layout modification or aesthetic enhancement must receive prior approval from the competent Ministry (ie, opinions of the competent councils which are, sometimes, incorporated into ministerial decisions) before a building permit application can be submitted.
• Permissible use ‒ the operation of a hotel is permitted only to the extent that it does not compromise the cultural significance or architectural integrity of the structure.
• Specialised studies ‒ restoration or rehabilitation works must be supported by specialised studies, prepared exclusively by qualified engineers and architects with proven experience in similar projects.

Regulatory Requirements to Operate a Hotel

Pursuant to the provisions of Law 4442/2016, the commencement of hotel operations requires the prior submission of a “notification of operation”. The process completes electronically through the online platform “Open Business”. It is important to note that no hotel may lawfully commence business activities prior to the submission of such a notification.

In order to submit the notification of operation, the following conditions must be fulfilled.

• The establishment of a hotel at the specific location must be permitted under the applicable spatial and urban planning regulations (see 6.1 Zoning).
• The relevant legislative provisions governing the reconstruction and development of hotel facilities must have been duly observed (see 6.2 Building and Development Regulations).
• The requisite building permits must have been lawfully issued in accordance with the applicable legal framework (see 6.3 Building Permits).

Procedure for Obtaining an Operating Licence

The procedure for obtaining an operating licence is prescribed in Chapter H’ (Article 39 et seq) of Law 4442/2016 and Joint Ministerial Decision No 8592/2017 (GG B’ 1750). The “notification of operation” is submitted by the person (natural or legal) operating the hotel through a standard form available online. The information required and registered through the notification form pertains to the operator’s identity and personal/corporate data, the exact location of the hotel, the different activities operating therein (eg, restaurants, bars, pools), the hotel’s capacity and classification (“star” rating system), the details (protocol numbers) of the documents to be kept at the hotel’s premises, etc.

Within five working days as of the submission of the notification, the competent Regional Tourism Authority informs other competent authorities (eg, Fire Department, Health Department, Building Office, Environmental Department) about the notification, so that such authorities may carry out inspections, controls, etc, as per each department’s jurisdiction.

Holders of notifications are required to keep within the hotel’s premises additional documentation proving the lawful construction and operation of the hotel pursuant to applicable legislation (eg, a copy of the notification form, as submitted; building permits and/or documents related to the legalisation/regularisation of any unauthorised constructions/arbitrary changes of use; the relevant fire certificate; any environmental licences, if applicable).

The final step of the licensing process is the issuance of a star classification certificate. The said certificate is issued by the Hellenic Chamber of Hotels. If the hotel is incorrectly classified in a higher category, its operation may be suspended by the competent authorities until the submission of an updated classification certificate.

Operating licences are not public.

Pursuant to Article 5A of Law 4276/2014, tourist accommodation facilities, including both primary accommodation (such as hotels and complex tourist accommodation) and non-primary accommodation (such as rooms to let), are to be classified into categories based on environmental criteria. However, this legislative provision merely grants the competent Ministers the authority to issue a decision specifying the applicable environmental criteria and classification categories; to date, no such ministerial decision appears to have been issued.

In this context, the only applicable legal instrument in force is Ministerial Decision No 216/2015 (GG B’ 10), which, under Article 4 and the relevant annex, establishes general criteria for the classification of hotels into star categories. These criteria primarily relate to the qualitative and quantitative characteristics of the hotels’ infrastructure and services (eg, amenities, facilities, service offerings) and do not specifically incorporate sustainability or environmental performance as a distinct, mandatory dimension. The said decision’s annex (Section 10.1) makes reference to certain standards relevant to environmental performance (“ECOLABEL, EMAS, ISO 14001, GREEN GLOBE, GREEN KEY, TRAVELIFE, or other specialised public or private certification schemes, as well as practices related to organic farming and the use of organic products”). However, such certifications are treated as optional criteria that award additional points in the classification process, but they are not compulsory for the issuance of a hotel operating licence or for the assignment of a specific star rating.

In the absence of binding national sustainability standards, certain hotel operators voluntarily adopt internationally recognised environmental certifications (eg, LEED (Leadership in Energy and Environmental Design), Green Key) as a means to align with global best practices and enhance the environmental profile of their properties.

There are specific employment law requirements relevant to hotel transactions in Greece, particularly regarding employee retention and the transfer of employees during acquisitions. Under Greek labour law, when a hotel business is transferred, employees automatically retain their rights, and the new employer (the buyer) is obliged to retain them. This is in line with Directive 2001/23/EC, implemented in Greece by Presidential Decree 178/2002, which protects employees’ rights during transfers of undertakings. The buyer must maintain the terms and conditions of the employees’ contracts, including wages and benefits, and is responsible for any outstanding employment liabilities, such as severance pay or unpaid wages.

Employees, including those on fixed-term contracts, are transferred to the new owner without any changes to their employment terms, ensuring continuity of service. If applicable, the new owner must also respect any existing collective bargaining agreements or trade union agreements, and they may need to consult with trade unions if significant changes to employment terms are planned. In larger transactions, employees must be informed and consulted about the transfer and any potential impact on their employment.

Additionally, Law 5053/2023 introduces further requirements for employment agreements, such as providing information about the probation period (if agreed), employee training (if required), and the social security institutions for main and supplementary insurance. These regulations ensure continuity of employment and further protect employee rights during hotel transactions in Greece.