Buying a Greek island, and where in Greece a buyer from outside the EU needs permission first

Two questions get asked about Greek property in the wrong order. People ask what it costs before they ask whether they are allowed to buy it, and for a foreign buyer the second question has a longer answer.

The short answer: a private island or islet, and any property standing on one, cannot be acquired without a permit from the Minister of National Defence, granted after the concurring opinion of all the General Staffs — and that rule applies wherever in Greece the island lies, not only near a border. A public islet is not for sale at all; it can only be leased. Separately, in the areas the law designates as border areas, a buyer with nationality or seat outside the EU and EFTA cannot acquire any right over property until a committee lifts the prohibition, and that list includes Thira (Santorini), the entire Dodecanese, Lesbos, Chios, Samos, Skyros and the northern border prefectures. A transaction concluded without the permission that applies to it is void, not merely penalised.

Every rule below is cited to the statute it comes from, with the date we read it, and where our conclusion is a reading of two statutes together rather than something either states, this page says so.

Buying a Greek island requires the Minister of National Defence's permit, wherever the island is

The rule is article 28(1) of Law 1892/1990, and its reach is wider than most readers expect.

It requires a permit from the Minister of National Defence for the acquisition, by act between living persons, of real or obligatory rights by natural or legal persons:

• in private islands or islets, and
• in property on private islands or islets,
• «οπουδήποτε και εάν αυτές βρίσκονται» — wherever they are located.

So this is not a border-area rule that happens to catch some islands. It is a national rule about islands as such. An islet in the Saronic Gulf an hour from Athens is inside it exactly as an islet off Rhodes is.

The permit is granted «ύστερα από σύμφωνη γνώμη όλων των Γενικών Επιτελείων» — after the concurring opinion of all the General Staffs. Not a majority of them, and not the opinion of the service whose area it is. The application goes to the Ministry of National Defence, filed by the interested party, and a joint decision of the Ministers of National Defence and of Citizen Protection governs everything else about how the permit is issued.

The sanction is the part to read twice: «Η μη τήρηση των ως άνω προϋποθέσεων συνεπάγεται την ακυρότητα της σχετικής δικαιοπραξίας κατ' εφαρμογή του άρθρου 174 του Αστικού Κώδικα» — failure to observe those conditions makes the transaction void under article 174 of the Civil Code. Not voidable at the state's option, and not a fine. The deed does not transfer anything.

Public islets in Greece cannot be bought at all, only leased

The second sentence of article 28(1) draws a line that no listing will draw for you: «Επί δημοσίων νησίδων δεν μεταβιβάζεται η κυριότητά τους αλλά παρέχεται η δυνατότητα μίσθωσης, υπό τις ανωτέρω προϋποθέσεις.»

On public islets ownership is not transferred. A lease is possible, on the same conditions — meaning the Defence permit still applies to the lease.

This is why the handful of Greek islands genuinely on the market are small, privately held and expensive, and why much of what circulates as "Greek islands for sale" concerns either a plot on an inhabited island or an islet that is not in private hands to begin with. Before any price discussion, the question is which of the three the property is.

What a Greek island comes with: a certificate that the State claims no ownership

Article 28(2) adds a step that is easy to miss and hard to fix afterwards.

Where real rights over the extent are being acquired, a certificate must be issued by the competent Κτηματική Υπηρεσία — the state property service — confirming that the State asserts no ownership rights over it. The Ministry of National Defence is the body that sees to its issue.

Read plainly: Greece does not assume that a private island is private. Somebody has to certify that the State is not the owner, and that certificate is part of the file rather than a formality the buyer's lawyer can waive.

Where in Greece a buyer from outside the EU needs permission before the purchase: the border-area list

The island rule is about islands. The border-area rule is about who you are.

Article 25(1) of Law 1892/1990, in the wording given to it by article 114(2) of Law 3978/2011, prohibits every act between living persons by which any real or obligatory right over immovable property situated in a border area is created in favour of natural or legal persons with nationality or seat outside the member states of the European Union and the European Free Trade Association. The same paragraph prohibits transferring shares or partnership interests in, or changing the partners of, a company of any form that owns property in those areas — so holding the purchase through a company does not step around the rule.

The areas are listed in article 24(1), as it stands after article 43(1) of Law 4278/2014:

Two entries deserve naming out loud, because they are among the most heavily marketed places in the country. Santorini is a border area. The Dodecanese is a border area, and that is Rhodes, Kos, Patmos, Symi, Kalymnos and the rest of the group.

Article 24(2) allows a presidential decree, proposed jointly by the Ministers of Foreign Affairs, Finance, National Defence, Economy, Citizen Protection and Rural Development, to lift the designation of an area — or to designate further areas. The list is therefore a current state rather than a permanent one, which is a reason to check it on the day rather than to trust a page, this one included, that was written on another day.

How the border-area permission is obtained: the committee, the documents, and the Defence veto

Article 26, as replaced by article 114(3) of Law 3978/2011 and with its first point replaced by article 43(2) of Law 4278/2014, sets out the route.

Persons who fall in the article 25(1) categories — that is, the very people the prohibition binds — may apply for it to be lifted, stating in the application the purpose for which the property will be used. The application goes before a committee constituted with a five-year term at each Decentralised Administration, chaired by its Secretary General or his deputy, with one representative each of the Ministries of National Defence, of the Economy and of Citizen Protection.

Then the decisive sentence. The prohibition is lifted by a decision taken «με πλειοψηφία του συνόλου του αριθμού των μελών της και με θετική οπωσδήποτε ψήφο του εκπροσώπου του Υπουργείου Εθνικής Άμυνας» — by a majority of the committee's total membership and in any event with the representative of the Ministry of National Defence voting in favour. Defence has a veto that no majority overrides.

What the file must contain was set by a joint ministerial decision of 21 March 2024, published in ΦΕΚ 1893/Β of 26 March 2024. For a natural person:

• an application signed by the applicant and the counterparty, with notarised signatures, giving the exact location of the property and what it will be used for;
• a short curriculum vitae;
• a criminal record extract issued within the previous six months;
• a certified copy of a valid passport;
• a residence permit, visa or other proof of lawful stay in the EU or EEA;
• a birth certificate;
• a survey or area diagram locating the property on a 1:50,000 map extract or certified aerial photograph.

For a legal person, add the certificate of incorporation certified by the authority of the foreign state, the articles of association and registry extract, three years of financial statements, a certified list of the management body with their personal details and criminal records, and a certificate that the entity is not bankrupt, under administration or in liquidation. Foreign documents must be apostilled or consularly certified and officially translated, and beneficial owners are checked under Law 4557/2018.

Two absences in that decision matter as much as its contents. It sets no fee and no deadline for the decision, and article 7(2) places every cost of the transaction and of the lifting procedure on the applicant. A purchase that depends on this consent therefore has no date by which the answer must arrive, which is a thing to carry into the promissory contract rather than to discover inside it.

There is also a wholesale route. Article 27, as amended by article 2(20) of Law 4092/2012, lets the article 26 committee, with the approval of the Minister of National Defence, lift the article 25(1) prohibitions for whole categories of transaction defined by legal form, monetary value or the location or value of the property — and lets the Minister of National Defence re-impose them at any time. Whether any such blanket lifting is currently in force for ordinary residential purchases is not something we could establish, and we do not assume it.

Best places to buy in Greece, read as a legal question rather than as a view

"Where to buy in Greece" is usually answered with scenery. For a buyer from outside the EU, the first cut is legal, and it divides the country in two.

Outside the border areas, an ordinary purchase is an ordinary purchase: a notarial deed, registration, transfer tax, and no consent from anybody. Inside them — Santorini, the Dodecanese, Lesbos, Chios, Samos, Skyros, Evros, Rodopi, Xanthi, Thesprotia, Preveza, Kastoria, Kilkis, Florina and the named eparchies and communities — the same purchase needs a committee decision first, with the documents above, no fee, no deadline, and a Defence veto.

That does not make the border areas unbuyable. It makes them a different transaction, with a timetable nobody controls, and it is the reason a promissory contract on Santorini should be written around the consent rather than around a completion date.

What does not change between the two halves of the country is the tax. Transfer tax is 3% plus a municipal surcharge of 3% of the tax, so 3.09% of the taxable amount, charged on the assessed value held on the register rather than on the price paid. That arithmetic, and the first-home exemption a non-resident cannot use, is in our page on Greek transfer tax.

How this meets the golden visa, and why that is our reading rather than a rule

A third-country buyer taking the investor permit is, by definition, a person with nationality outside the EU and EFTA. Article 25(1) binds exactly that person.

We looked for an exemption and did not find one. None appears in articles 25 to 27 of Law 1892/1990, and none appears in article 100 of Law 5038/2023, which sets the investor thresholds and says nothing about border areas. On that reading, an €800,000 purchase on Santorini or in the Dodecanese needs the committee's decision before the deed, and a deed signed without it is void under article 174 of the Civil Code — which would also mean no investment, and therefore no permit.

We state that as a reading of two statutes together, not as a rule either one declares. It is the kind of conclusion that should be confirmed by a lawyer for the specific prefecture before money moves, and if you are told no consent is needed, the thing to ask for is the provision that says so.

What we could not establish about the 2026 tightening

Greek reporting through 2026 describes this regime being tightened: purchases in the Dodecanese and in Thrace, an exchange in Parliament in June 2026, and statements by the Minister of National Defence about a new framework for border areas.

We could not find an enacted instrument amending articles 24 to 28, and we are not going to imply the 2014 wording is the last word when the news says otherwise. Two things are certain: the regime is live, because its document list was re-set in March 2024; and it is being administered now, because the Aegean committee's own page was updated in May 2026, and the South Aegean committee — the one covering the whole Dodecanese prefecture and, in the Cyclades, the island of Thira alone — receives applications on Tuesdays and Thursdays between 12:00 and 15:00.

Check for a 2026 amendment before you sign. That is the honest instruction, and it is a better one than a confident date.

Frequently asked questions about buying a Greek island and buying property in Greece as a foreigner

More on Greek property, residence and tax

What the investor permit asks for, zone by zone, and how the border-area consent meets it is in the Greek residence guide. What a purchase costs in tax, and why the rate is 3.09% rather than 3%, is in Greek transfer tax. Whether property still buys residence across this set of countries is in the property and residence piece. Every instrument named here, with the date we read it, is on the sources page: the statute at Law 1892/1990, articles 24 to 28, the document list at ΦΕΚ 1893/Β of 26 March 2024, and the committee's own description of its work at the Decentralised Administration of the Aegean.