Hotel transactions in Greece sit at the intersection of multiple legal disciplines.

• The Civil Code provides the foundational framework for contracts, property transfers and lease arrangements.
• Tourism law – principally Law 4276/2014 as amended – governs hotel licensing, classification and operational compliance under the oversight of the Ministry of Tourism.
• Real estate law addresses land use, zoning, spatial planning and the property transfer process, including registration with the Land Registry or Cadastre.
• Tax law is critical to transaction structuring, covering real estate transfer tax, VAT, capital gains, corporate income tax and the Uniform Real Estate Property Tax (ENFIA).
• Labour law – including the transposition of EU Directive 2001/23/EC through PD 178/2002 and the more recent Law 5053/2023 – protects employee rights during ownership changes and imposes specific information requirements for employment agreements.
• Banking and finance law underpins hotel acquisition financing, including bond loan structures, syndicated lending and security packages.
• EU law governs competition, state aid, and – since May 2025 – foreign direct investment screening under the new national FDI regime (Law 5202/2025).
• Environmental law, including building codes and environmental impact assessments, applies to hotel development, renovation and ongoing operational compliance.
• Additionally, the regulatory framework for short-term rentals (Law 5170/2025, effective October 2025) has introduced new quality, safety and licensing standards that affect the competitive landscape between traditional hotel accommodation and platform-based rental properties.

Hotel investments in Greece are structured either as share deals or asset deals, with the choice driven by the buyer’s objectives, the seller’s preferences and tax efficiency considerations.

Under Greek law, a distinction exists between the creation of the obligation (the sale agreement) and the act of transfer. The sale creates a contractual obligation between the parties; the transfer is the in rem act by which ownership and possession pass to the buyer.

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

Share deals are frequently preferred for tax reasons. Share transactions are exempt from indirect taxes, real estate transfer taxes and share transfer taxes (except in the case of listed shares). Importantly, share deals do not require a notarial deed, whereas asset deals must be formalised through a notarial deed, registered with the competent Land Registry or Cadastre, and are subject to real estate transfer tax at 3.09%.

The decision between an asset deal and a share deal is ultimately a strategic one, balancing tax optimisation, legal formalities, successor liability considerations and the buyer’s long-term business objectives.

The degree of publicity depends on the transaction structure. In asset deals, the transaction must be formalised through a notarial deed, which is a public document under Greek law. The deed includes the identities of the buyer and seller, a description of the property and the sale price. Upon registration with the Land Registry or Cadastre, this information becomes part of the public record.

In share deals, the terms of the transaction are generally confidential. Share transfers do not require notarial form, and the sale price and other commercial terms remain private unless the company is publicly listed or subject to specific disclosure obligations. Confidentiality agreements typically ensure that sensitive deal terms are not disclosed.

In practice, high-profile hotel transactions may be the subject of press releases or public announcements, but this is at the discretion of the parties and is usually driven by marketing or investor-relations considerations rather than legal obligation.

Greece maintains an open investment environment, and foreign investors are generally free to acquire hotel properties and hotel-owning companies. There are no discriminatory laws against foreign ownership, and Greece actively promotes foreign investment through mechanisms such as the fast-track system for strategic projects and the Enterprise Greece Investor Ombudsman. 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.

FDI Screening

The most significant recent development in this area is the enactment of Law 5202/2025, which establishes Greece’s first national FDI screening regime, implementing EU Regulation 2019/452. The law was enacted on 22 May 2025 and became fully operational on 11 November 2025 following the publication of implementing regulations. The regime introduces a mandatory, suspensory pre-closing notification requirement for foreign investments in designated sensitive and particularly sensitive sectors of the Greek economy.

Sensitive sectors – including energy, transport, health, information and communications technology, and digital infrastructure – trigger screening when the foreign investor’s stake reaches or exceeds 25%. Particularly sensitive sectors – including defence technologies, AI, cybersecurity, port and underwater infrastructure, and tourism infrastructure in border areas – trigger screening at a lower threshold of 10%. The regime does not include thresholds for investment value, meaning that any investment in the relevant sectors, regardless of size, must be notified.

The screening is conducted by the Interministerial Committee for the Screening of Foreign Direct Investments (FDISIC), supported by Directorate B1 of the Ministry of Foreign Affairs. The process involves a Phase I review of up to 30 calendar days, with the possibility of a Phase II in-depth investigation of up to 140 additional days (extendable to a maximum of 150 days). During Phase II, the EU Cooperation Mechanism under Regulation 2019/452 may be triggered, involving the European Commission and other member states.

Non-compliance with the notification obligation carries administrative sanctions ranging from EUR5,000 to EUR100,000, and in cases of serious breach – such as implementing a prohibited investment or providing false information – fines may amount to double the value of the investment. The FDISIC also has ex officio investigation powers over non-notified transactions.

For most hotel acquisitions, this regime will not apply, as hospitality is not a designated sensitive sector (unless the hotel is located in a border area and qualifies as tourism infrastructure). However, foreign investors in the Greek hotel market should assess whether any ancillary elements of their investment – such as digital infrastructure, energy assets or port-related facilities – may fall within its scope. In all cases, early legal advice is recommended to determine notifiability and avoid delays.

Separately, national security restrictions continue to apply to specific sectors such as airports, electricity and media, as well as to land purchases in border areas or certain islands by non-EU investors. Specifically, Articles 24–26 of Law 1892/1990, as amended by Article 114 of Law 3978/2011, restrict individuals and legal entities from outside the EU or EFTA from acquiring ownership or other contractual rights over real estate located in designated “border areas” of Greece. These areas cover a substantial portion of the country, including, among others, the Dodecanese, various Aegean islands, certain Ionian islets, and regions in Thrace, Macedonia and Epirus. The restriction also extends to changes in the ownership structure of companies holding property in these areas. However, exemptions may be granted on a case-by-case basis if a permit is issued by the competent state committee.

In Greece, hotel ownership and management structures encompass privately owned independent hotels, hotel management agreements (HMAs), hotel lease agreements and franchising agreements.

Privately owned independent hotels have historically been the backbone of Greek hospitality, particularly in the form of small, family-run properties in tourist regions. However, the landscape is evolving rapidly with the entry of major international hotel brands. Global chains are increasingly replacing or absorbing independent operations, bringing brand recognition, standardised service levels and access to international distribution systems. The independent owner retains full operational control – over pricing, staffing, procurement and marketing – but directly bears all risks and rewards.

Hotel management agreements are increasingly common in larger or upscale properties, particularly those owned by institutional investors or private equity funds who prefer not to manage the property directly. The owner retains ownership while contracting a professional management company to handle day-to-day operations, staffing, marketing and procurement. Compensation typically comprises a base management fee (as a percentage of revenue) and an incentive fee tied to profitability. HMAs are the preferred structure for most international luxury and upper-upscale brands entering the Greek market.

Hotel lease agreements are popular for larger or well-established properties where the owner seeks stable, predictable income with minimal operational involvement. The lessee assumes full operational responsibility and typically pays fixed rent, often with a performance-based component. This structure is common in urban hotels and resort properties where the operator’s expertise adds significant value.

Franchising agreements are gaining ground as global hotel brands expand their footprint in Greece. The owner operates the hotel under the brand’s name and standards, benefiting from the franchisor’s reputation, reservation systems and marketing infrastructure. The owner pays initial franchise fees and ongoing royalties (typically 4–8% of gross revenue) while retaining operational control within the brand’s framework.

Each structure offers a different balance of control, risk and revenue participation. The trend in the Greek market is clearly towards more professionally managed structures – HMAs and franchises – reflecting the sector’s maturation and the growing presence of international institutional capital.

Hotel management agreements in Greece follow international standards and framework agreements, adapted to local legal requirements. The typical structure includes the following elements.

• Parties – The agreement is between the hotel owner (or the owning entity) and the management company, usually an international hotel chain or professional operator.
• Term – Duration typically ranges from five to 20 years, with renewal options, often subject to performance benchmarks.
• Management fees – The management company receives a base fee (calculated as a percentage of gross revenue) and an incentive fee tied to gross operating profit or similar profitability metrics.
• Responsibilities – The management company handles day-to-day operations, staffing, marketing, revenue management and procurement. The owner retains approval rights over material matters such as annual budgets, capital expenditure programmes and key personnel appointments.

From a regulatory perspective, several areas require careful attention.

• Greek labour law is strict, particularly concerning employee rights, collective agreements, social security contributions and termination protections. Law 5053/2023 introduced additional information requirements for employment agreements, including specifications on probation periods, training obligations and social security institutions. Management companies must structure their employment practices to ensure full compliance.
• Hotels require permits from the Ministry of Tourism and must comply with classification regulations and local zoning laws. The operator must follow a notification procedure to the competent authorities before commencing operations, replacing the former Special Operation Mark.
• Taxation presents additional complexity. HMAs must comply with Greek VAT rules, corporate income tax obligations and transfer pricing requirements, which are particularly relevant for international operators structuring cross-border management fees.
• Environmental and building regulations apply to any construction, renovation or refurbishment projects undertaken during the term of the agreement.

Typical Structure and Terms

Hotel lease agreements in Greece typically involve a long-term arrangement – commonly ten to 20 years, with renewal options – between the property owner (lessor) and the hotel operator (lessee). Rent is structured as fixed rent, a percentage of the hotel’s revenue, or a hybrid of both. The lessee assumes responsibility for hotel operations, staffing, marketing and routine maintenance, while the lessor typically retains responsibility for the property’s structural integrity, although the precise allocation is heavily negotiated.

Key contractual terms include:

• capital expenditure and renovation obligations (specifying which party bears the cost of periodic upgrades and any brand-mandated property improvement plans);
• exit and termination clauses (with notice periods and penalties);
• compliance with operating licences and tourism regulations;
• revenue and profit-sharing mechanisms; and
• operating standards (particularly important where the hotel operates under a brand).

Main Regulatory Aspects

The regulatory framework for hotel leases encompasses several critical areas.

Tourism law (Law 4276/2014, as currently in force and codified through subsequent amendments) mandates compliance with classification standards, operational requirements, and licensing rules. Lawful operation requires a Special Operating Mark (ESL), which presupposes a Classification Certificate issued by the Hellenic Chamber of Hotels confirming the property’s star rating; the lessee must follow the notification procedure to inform the competent authorities before commencing operations, with lawful operation subject to ex post inspection.

Labour law governs employment contracts, working hours, wages and social security contributions for hotel staff. Law 5053/2023 (now codified in Presidential Decree 62/2025, the “Labour Code”) introduced additional information requirements for employment agreements – including the probation period (capped at six months), employee training obligations and social security institution details – with disclosure timelines of one week for core terms and one month for the remainder.

Real estate law, including property ownership and land use regulations, must be observed, and environmental regulations require investment in sustainable practices to meet both domestic and EU standards.

An important recent development affecting the broader accommodation market is Law 5170/2025, which introduced comprehensive new regulatory standards for short-term rentals, with the core property requirements of Article 3 effective 1 October 2025. The law imposes mandatory safety, insurance and quality requirements on properties registered in the AADE Short-Term Stay Registry and listed on platforms such as Airbnb. In parallel – under separate measures rather than Law 5170/2025 itself – a freeze on new short-term rental registrations in the 1st, 2nd and 3rd municipal districts of central Athens, initially imposed for 2025, has been extended through 2026. These measures aim to level the competitive playing field between traditional hotel accommodation and the short-term rental sector, and may influence investor decisions regarding hotel lease structures in urban markets.

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

The franchisee must comply with the franchisor’s operational standards, covering hotel design, service quality, guest experience and marketing practices. The franchisor provides ongoing support including training, brand guidelines, quality assurance and marketing resources. The agreement typically includes exit clauses triggered by non-compliance with standards, failure to meet financial benchmarks, or change-of-control events.

Greece has no specific franchise legislation. Franchise agreements are governed by general commercial and contract law, civil code provisions and competition law (both Greek and EU). Key regulatory aspects include:

• clear contractual definitions of obligations, rights and responsibilities;
• pre-contractual disclosure requirements to ensure transparency;
• intellectual property protection (trade marks, trade names and branding) for the duration of the agreement; and
• compliance with EU and Greek competition law, including restrictions on anti-competitive practices.

Corporate law permits franchisees to operate under standard Greek company structures – SA (société anonyme) or IKE (private company) – both offering limited liability. Under Consumer Protection Law (Law 2251/1994), franchisees are not classified as consumers; commercial agent provisions may apply, particularly regarding compensation and notice periods upon termination. Real estate and tenancy law may also be relevant where the franchise arrangement involves subleasing of locations.

The financing landscape for hotel transactions in Greece has evolved significantly over the past decade, becoming deeper, more diverse and considerably more sophisticated. The restructuring of the Greek banking system following the sovereign debt crisis, combined with the sustained growth of the tourism sector and improving investor confidence, has produced a mature and competitive financing environment.

Today, hotel transactions benefit from a wide range of funding options. Traditional bank loans remain the most common form of financing, particularly for established developers and operators. Greek commercial banks have developed genuine sectoral expertise in hospitality lending and now offer tailored, project-specific financing – including bond loan structures, revolving credit facilities, and bespoke security packages calibrated to the cash-flow characteristics of hotel assets. Beyond bank lending, the market increasingly features private equity, mezzanine financing, intragroup loans, EU-backed instruments (including RRF loans and grants), real estate investment funds (REITs), and specialised hospitality investment vehicles.

The most common structure combines bank debt with equity capital. The bank loan typically covers the majority of the acquisition cost, with the hotel property and related assets (equipment, operational rights, leases) serving as collateral. Borrowers frequently contribute equity to strengthen their financial position and improve leverage ratios. For larger or more complex transactions – particularly those involving international joint ventures or luxury property acquisitions – private equity participation is increasingly used. The availability of blended financing – combining bank loans, equity, and EU-backed grants or subsidised loans – has been a notable catalyst for large-scale and sustainable hotel developments.

Greek banks have also integrated themselves into international financing networks, enabling them to participate in syndicated lending arrangements and to attract diverse sources of capital into the Greek hospitality sector. This has reinforced Greece’s position as a major hotel investment destination and provided a more resilient capital base for the sector.

Foreign financiers are generally permitted to lend for hotel acquisitions in Greece without significant restrictions. Greece maintains an open capital market aligned with EU regulations ensuring the free movement of capital. This applies to both equity investments and lending activities by foreign financial institutions. The new FDI screening regime under Law 5202/2025 applies to equity investments in sensitive sectors, not to lending activities per se, though foreign investors should assess whether their overall transaction structure triggers notification obligations.

The acquisition of an operating hotel, including the legal title to the underlying real estate, triggers a 3.09% real estate transfer tax (ETT) payable by the buyer. In limited cases involving the sale of new hotel buildings before first use, this is replaced by 24% VAT – although the application of VAT to such sales has been suspended under Law 5246/2025 until 31 December 2026, meaning the 3.09% ETT applies in practice. The transfer of the business as a going concern triggers a 2.4% Digital Transaction Duty (DTD) on the higher of the net asset value or the agreed consideration; the DTD was introduced by Law 5135/2024 with effect from 1 December 2024, replacing the previous stamp duty regime. Asset-deal transfers also benefit from exemptions where structured under tax-neutral reorganisation regimes (Laws 1297/1972, 2166/1993, or the Income Tax Code restructuring provisions). If structured as a share deal, no real estate transfer tax, indirect tax or share transfer tax applies (except for listed shares), which is one of the principal reasons for the prevalence of share deal structures in the Greek market. Capital gains tax on share transfers by individuals remains suspended until 31 December 2026.

Income from hotel operations is subject to corporate income tax at 22%. Depreciation allowances apply at 4% for buildings and 10% for equipment and other fixed assets. Hotels that are fully operational are exempt from the 15% annual Special Real Estate Tax (SRET). Hotelier services are subject to a reduced VAT rate of 13%; for all-inclusive packages, 10% of the total price is subject to 24% VAT and the remainder to 13%. Construction and refurbishment works are subject to the standard VAT rate of 24%. Real estate is subject to the annual Uniform Real Estate Property Tax (ENFIA), comprising a principal tax based on size, location and use, plus a supplementary tax for legal entities of 5.5‰ on the total property rights value (1‰ for self-used properties).

A daily Climate Resilience Fee (which replaced the previous “stayover tax” in 2024 and was significantly increased by Law 5162/2024 with effect from 1 January 2025) is imposed on hotel rooms based on star rating, ranging from EUR1.50 to EUR15 per room per night. Equivalent fees apply to short-term rentals (EUR2/EUR4 per night in low season; EUR8/EUR15 per night in high season, depending on size). Since July 2025, cruise passengers disembarking at Greek ports are subject to a per-person cruise duty: EUR20 for Mykonos and Santorini in the high season (1 June to 30 September), EUR12 in the shoulder season, and EUR4 in winter; reduced rates apply at other ports.

Greece offers a range of tax incentives and grants for hotel projects. The Strategic Investments Law (Law 4864/2021, as recently codified by Law 5255/2025) supports large-scale, economically significant projects (typically with budgets exceeding EUR20 million) with benefits including income tax stabilisation, fast-track licensing, cash grants and accelerated depreciation. The Development Law (Law 4887/2022, as substantially reformed by Law 5203/2025 in June 2025) targets tourism investments and offers aid in the form of tax exemptions, cash grants, leasing subsidies and employment subsidies, with aid intensities reaching up to 75% in certain regions. Three new aid schemes were launched in 2025–26 covering special regional aid, major investments (with minimum budgets from EUR15 million and aid up to EUR20 million), and manufacturing/supply chain. Additional incentives exist for R&D, patent exploitation, green and digital transition projects, 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, as recently codified in Law 5306/2026 (the “Spatial and Urban Planning Code”).

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 (both as recently codified in the Spatial and Urban Planning Code). 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, as codified in the Spatial and Urban Planning Code), 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 that 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 recently codified in the Spatial and Urban Planning Code. 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, as codified in the Spatial and Urban Planning Code (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 (as codified in the Spatial and Urban Planning Code) and Law 4002/2011. The permits are usually issued by the competent Urban Planning Office (for four- and five-star hotels with a capacity exceeding 300 beds, the process is handled by the Special Office for the Promotion and Licensing of Tourist Investments at the Ministry of Tourism (in Greek, EYPATE).

Preliminary Steps

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.

Application Process

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 having a capacity of more than 300 beds).

Duration of Procedure

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).

Hotel Refurbishment

Regarding a hotel refurbishment, construction work may fall into different categories:

• works requiring a full building permit (eg, structural interventions, horizontal or vertical extensions);
• works requiring a small-scale building permit (eg, replacement of flooring, windows or roofing, without altering their shape or materials); and
• 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.

Τo 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 11882/2025 (GG B’ 3340). 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.

Other competent authorities (eg, Fire Department, Health Department, Building Office, Environmental Department) are automatically informed (through the aforementioned database) of the submission of the notification. This enables them to carry out inspections, controls, etc, as per each department’s jurisdiction. Τhe competent Regional Tourism Authority is obligated to transmit the notification without delay and, in any case, within five working days, to any additional authority it deems appropriate, so that such authority may exercise its supervisory powers in accordance with the law. Finally, the Hellenic Chamber of Hotels is also automatically informed on the submission of the notification for hotel establishments.

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.

When a hotel business is transferred – whether by way of an asset deal, lease or management change – employees automatically transfer to the new employer with their existing rights preserved. The framework derives from EU Directive 2001/23/EC, originally transposed by Presidential Decree 178/2002, subsequently codified in Articles 347–356 of Presidential Decree 80/2022, and most recently consolidated under Presidential Decree 62/2025 (which entered into force on 11 July 2025 and constitutes the new Labour Law Code, abolishing PD 80/2022). The buyer (or incoming operator) must maintain the existing terms and conditions, including wages, benefits and seniority. Critically, the transferor and the transferee remain jointly and severally liable for all employment obligations arising up to the date of transfer – meaning the new owner inherits any unpaid wages, severance, social security arrears or other liabilities accrued under the previous employer.

Law 5053/2023 (transposing EU Directive 2019/1152) introduced enhanced information requirements, including a six-month cap on probation periods, mandatory written communication of basic employment terms within one week of commencement, and disclosure of training obligations and social security institutions. Subsequent reforms (Laws 5078/2023, 5089/2024, 5163/2024 and 5184/2025) further refined the framework on working time, anti-discrimination and digital reporting. Most recently, Law 5239/2025 (“Fair Work for All”), published in October 2025, modernises and consolidates the regime by simplifying registration formalities, streamlining hiring procedures, introducing greater flexibility in working time arrangements, and reinforcing post-expiry coverage of collective agreements.

Two sector-specific points are particularly relevant for hotel transactions. First, hotel employment is governed by binding sectoral collective labour agreements – currently the POX–POEET hotel sectoral agreement signed on 19 February 2025 and valid until 31 December 2026 (5% wage increase in 2025 and 3% in 2026), and the broader hospitality, tourism and bakery sectoral agreement signed on 17 March 2026, effective from 1 April 2026 and covering the 2026–27 period (8% wage increase in 2026 and 4% in 2027, with sectoral minimum wage of EUR950 rising to EUR988). Both agreements preserve the statutory right of seasonal hotel employees to be re-employed in the following season – which the new owner must honour. Second, the digital work card system became mandatory for the hotel and food service sectors on 1 March 2025 (following a pilot phase from September 2024), with administrative fines of EUR10,500 per non-activated employee, EUR3,000 for misreporting actual working hours, and additional fines for related infractions. An incoming hotel owner must therefore ensure full compliance from the closing date.