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Greece – New Administrative Sanctions Framework for 2026
The Greek Ministry has introduced significant changes to the General Commercial Registry (GEMI) compliance requirements through Ministerial Decision No. 46982/2025.
Effective 1st of January 2026, this comprehensive update establishes a structured framework for administrative sanctions, fundamentally changing how compliance is enforced across Greek business entities.
Key Changes
The legislation introduces a sophisticated tiered penalty structure that considers company type, size, and the nature of violations. This represents a significant evolution in GEMI’s enforcement capabilities, with fines ranging from €100 to €100,000 for non-compliance. The framework is designed to ensure proportional enforcement while maintaining robust oversight of corporate compliance.
Implementation Timeline
Companies have until the 31st of December 2025 to address any compliance issues without incurring penalties. This grace period provides organizations with the opportunity to review and update their compliance status proactively.
Starting 1st of January 2026, the new regulations take effect, and the new penalty structure will be enforced.
Scope of Application
The changes apply to all business entities registered under GEMI, with specific new penalties levied based on organizational structure and size. This includes Societe Anonyme (AE), Limited Liability Companies (EPE), Private Companies (IKE), partnerships, branches of foreign entities, and listed companies. Companies in liquidation or special liquidation status may be eligible for reduced sanctions.
Activities Subject to Penalties
The new framework introduces fines for various compliance failures, including:
- Errors in company establishment via e-YMS
- Failure to register with GEMI
- Omission of mandatory information on corporate documents
- Late submissions of applications and registrations
- Errors in automatic filings
- Incorrect registration and publication of data
- Failure to file financial statements
- Improper reservation of company names and distinctive titles
Penalty Structure and Enforcement
The new framework implements a sophisticated penalty system:
- General violations incur fines from €100 to €6,000
- Non-filing of financial statements can result in penalties up to €100,000
- Repeated violations within three years face double or triple fines
Penalties are calibrated according to company classification:
- Large enterprises
- Medium-sized enterprises
- Small enterprises
- Micro enterprises
Enforcement Process
GEMI has established an electronic notification system for managing compliance issues. Companies receive official notices through this system and have the right to respond and raise objections.
Assessments are based on the company’s classification at the time of the breach, with specific procedures for different types of violations.
How Mercator® by Citco (Mercator) Can Help
Our team can provide comprehensive support to navigate these new requirements effectively. We offer:
- Detailed compliance status reviews
- Management of GEMI notices and responses
- Support for filing updates and corrections
- Ongoing compliance monitoring
- Guidance on maintaining GEMI compliance
Contact mercator@citco.com for assistance with your GEMI compliance needs and detailed information about fine structures specific to your organization type.
