Licence for the operation of Anonymous Investment Company in Real Estate (A.E.L.A.)

From National Registry of Administrative Public Services



3f984da4-5e67-48f6-843f-60a60619e354 837784 Άδεια λειτουργίας Ανώνυμης Εταιρείας Επενδύσεων σε Ακίνητη Περιουσία (Α.Ε.Ε.Α.Π.)

At a glance

Points of service

Directorate of Entities of the HCMC Department for the Licensing of Collective Investment Undertakings, HELLENIC CAPITAL MARKET COMMISSION

Digital provision points

  • The service is not provided digitally

Number of required documents

7

Fees

5,000 €

Deadline of completion

6 months

Description

The procedure concerns the granting of an operating licence for a Real Estate Investment Company (REIC).

Basic information

Competent body

MINISTRY OF ECONOMY AND FINANCE

Authority/Public body’s Unit responsible for the institutional framework of the procedure

Authority responsible for the provision of the procedure

HELLENIC CAPITAL MARKET COMMISSION

Service / organizational unit of a authority entity

Directorate of Entities of the HCMC Department for the Licensing of Collective Investment Undertakings

Validity duration

Indefinite

Notes

REIC is a public limited company (société anonyme) which operates for the purpose of the direct or indirect acquisition, sale, management, development and exploitation of real estate, by any appropriate means, in accordance with Articles 41 to 64 of Law 5193/2025. It is licensed by the Hellenic Capital Market Commission, provided that it meets the requirements of the relevant legislation. After obtaining the relevant licence, it must be incorporated through the General Commercial Register (GEMI).

Last update

31/07/2026

Application

Application Type

Application

Submission by:

Presented by the applicant (email), Submitted by the applicant (in person or by post)

Submitted by:

Legal entities, Persons

Title

Granting of an operating licence for a REIC.

Notes:

Submissions should be made by email to info@cmc.gov.gr, to the Central Registry of the Hellenic Capital Market Commission. The entire file must also be submitted in hard copy, for which no protocol number is issued.

What you will need

Means of authentication, identification and signature

Identification document

    Print

    Requirements

      Fees

        Related

        Means of redress or appeal:

        Other Law 3371/2005: capital market matters, etc. Article 25 Legal remedies: ‘Without prejudice to the provisions of Article 25 of Law 3340/2005 (Government Gazette, Series I, No 112/10.5.2005), decisions of the Hellenic Capital Market Commission in general may be challenged before the courts as follows: (a) Decisions of the Hellenic Capital Market Commission imposing a financial penalty may be challenged by way of an appeal on the merits before the Athens Administrative Court of Appeal, which hears the case at first and final instance, within 60 days from their notification. b) All other decisions of the Hellenic Capital Market Commission issued as enforceable individual administrative acts may be challenged by an application for annulment before the Athens Administrative Court of Appeal, within 60 days from their notification. Decisions of the Administrative Court of Appeal may be appealed before the Council of State in accordance with the provisions in force.

        Rules concerning a lack of reply from the competent authority and the legal consequences for the use:

        Law 3371/2005: capital market matters, etc. Article 25 Legal remedies: ‘Without prejudice to the provisions of Article 25 of Law 3340/2005 (Government Gazette, Series I, No 112/10.5.2005), decisions of the Hellenic Capital Market Commission in general may be challenged before the courts as follows: (a) Decisions of the Hellenic Capital Market Commission imposing a financial penalty may be challenged by way of an appeal on the merits before the Athens Administrative Court of Appeal, which hears the case at first and final instance, within 60 days from their notification. b) All other decisions of the Hellenic Capital Market Commission issued as enforceable individual administrative acts may be challenged by an application for annulment before the Athens Administrative Court of Appeal, within 60 days from their notification. Decisions of the Administrative Court of Appeal may be appealed before the Council of State in accordance with the provisions in force.Other

        This concerns cases where the request for the granting of an operating licence is rejected.

        Output & Results

        Methods of receipt

        Email, In person or by post

        Output

        Administrative Act, Decision

        Steps

          Digital steps

            Other information

            Alternative titles

            Operating licence for a Real Estate Investment Company

            Official title

            Granting of an operating licence for a REIC

            Languages supported

            Greek, English

            Legislation

              Categories

              Τype of procedure

              Trigger

              Applied for

              Trigger (submission method)

              Application (digital)

              Type

              Outgoing

              End of Process

              Ιndefinite

              N1

              ,,,,,,,,,,


            • 1 Income Assets and financial position of shareholders proving their ability to establish a REIC.

              No No

            • 2 Tax Tax clearance certificate for (domestic) shareholders, demonstrating their eligibility to establish a REIC. Corresponding foreign certificate. Management executives must have tax clearance.

              No No

            • 3 Conditions for non-commission of criminal offenses Prospective shareholders and management executives must not be charged with criminal offences.

              No No

            • 4 Bankruptcy law Prospective shareholders and management executives must not be bankrupt.

              No No

            • 5 Educational Management executives must have at least higher education.

              No No

            • 6 Professional Management executives must have significant experience and certifications.

              No No

            • 7 Financial The licence is granted to specialised investors/shareholders with a minimum investment capital of EUR 40 000 000 and for up to five years. The shares of the REIC must be listed on the Athens Stock Exchange.

              No No

            • 1 A fee of EUR 5 000 is payable for the examination of an application for an operating licence. 5000 €

              Cost Calculation One-off

              Method of Payment Bank of Greece

              Type of Cost Administrative Fee (not provided by e-paravolo webpage)

              Fee Link http://www.hcmc.gr/el GR/web/portal/elib/lawsministerial

              No

            • 1 A number of relevant supporting documents. Tax/chamber / studies – specialisations / financial position Legal documents from legal entities

              A number of relevant supporting documents. Tax/chamber / studies – specialisations / financial position

              Relevant link: http://www.hcmc.gr/el GR/web/portal/elib/decisions?catyear=2007

              Submission by: Presented by the applicant (email), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Notes: For the establishment of a REIC through GEMI, a special-purpose operating licence is required, granted by decision of the Board of Directors of the Hellenic Capital Market Commission. This is not a standard citizen request, and an organised and detailed file is submitted with the application, covering the organisation, procedures and personnel of the company under incorporation. The following shall be assessed: The suitability of prospective shareholders (legal and natural persons) as regards their honesty/integrity and financial standing. It is very likely that there will also be foreign shareholders from within and outside the European Union. The scope of the assessment varies depending on the percentage holding of each prospective shareholder. Each prospective shareholder with a qualifying holding is assessed individually. The suitability of the individuals who will manage the company in terms of honesty and integrity, and the necessary knowledge and experience. The structure and organisation of the applicant company in relation to the requirements laid down by specific laws, European regulations, and ministerial and HCMC decisions. As an indication of the supporting documents required, reference is made to the annex to HCMC Decisions 3/452/1.11.2007 and 4/452/1.11.2007, which can be consulted by browsing the attached HCMC link containing the 2007 decisions.

              Document submitted under requirements: No


              No 9338

            • 2 Fee for examination of an application for a REIC operating licence Proof of payment / Receipt

              Fee for examination of an application for a REIC operating licence

              Submission by: Presented by the applicant (email), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Notes: The REIC under licensing pays a fee of EUR 5 000 for the examination of an application for the granting of an operating licence. Fees and contributions payable to the Hellenic Capital Market Commission are deposited with the Bank of Greece (SWIFT BIC BNGRGRAA), in the Hellenic Capital Market Commission’s account, account number 26215-4, and ΙΒΑΝ GR5901000240000000000262154.

              Document submitted under requirements: No


              No 7053

            • 3 Recommendations Letter of Recommendation

              Recommendations

              Submission by: Presented by the applicant (email), Submitted by the applicant (in person or by post)

              Submitted by: Persons


              Document submitted under requirements: No


              No 8711

            • 4 Curriculum Vitae Curriculum Vitae (CV)

              Curriculum Vitae

              Submission by: Presented by the applicant (email), Submitted by the applicant (in person or by post)

              Submitted by: Persons


              Document submitted under requirements: No


              No 7597

            • 5 Tax clearance certificate. Tax clearance certificate

              Tax clearance certificate.

              Relevant link: https://www.gov.gr/en/ipiresies/periousia-kai-phorologia/phorologia-politon/apodeiktiko-phorologikes-enemerotetas

              Submission by: Presented by the applicant (email), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Relevant Procedure: Certificate of no outstanding tax debts

              Notes: Shareholders (natural persons and/or legal persons) and key executives must be up to date with their tax obligations

              Document submitted under requirements: No


              No 3461

            • 6 Questionnaire for natural and legal persons Questionnaire

              Questionnaire for natural and legal persons

              Relevant link: http://www.hcmc.gr/el GR/web/portal/aeeap

              Submission by: Presented by the applicant (email), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Notes: Questionnaire for assessing the suitability of persons of supervised companies.

              Document submitted under requirements: No


              No 6947

            • 7 Applicant company questionnaire Questionnaire

              Applicant company questionnaire

              Relevant link: http://www.hcmc.gr/el GR/web/portal/aeeap

              Submission by: Presented by the applicant (email), Submitted by the applicant (in person or by post)

              Submitted by: Legal entities, Persons

              Notes: The purpose of the questionnaire is to determine precisely the categories of business activity that the applicant company intends to carry out after the granting of the operating licence, in accordance with the relevant legislation. For this reason, the responses should be as comprehensive and representative as possible in order to provide a clear picture of the investment strategy and the activities that the Company intends to develop.

              Document submitted under requirements: No


              No 6947

            • Law 40 - 64 5193 2025 56 Α

              Description Reform of the institutional framework of Greek Real Estate Investment Companies.

              Legal references https://api.et.gr/apiLAW/1/2025/5193/pdf

            • Board of Directors Decision 4/452 2007

              Description Fit-and-proper criteria for persons directing the activities of investment firms, investment intermediary companies, mutual fund management companies, portfolio investment companies and real estate investment companies.


            • Board of Directors Decision 3/452 2007

              Description Fit-and-proper criteria for persons directing the activities of investment firms, investment intermediary companies, mutual fund management companies, portfolio investment companies and real estate investment companies.


            • 1 Receipt and registration of application

              Responsible for Implementation Competent Department

              Μethod of Implementation Manual Action

              Description SUBMISSION OF APPLICATION AND MATERIAL FOR REGISTRATION UNDER A PROTOCOL NUMBER The REIC under licensing submits the application and evidential material to the offices of the Hellenic Capital Market Commission and the competent department registers it under a protocol number.

              Notes The digital files are submitted by email to info@cmc.gov.gr and the entire physical file/printouts are submitted at our offices.

              No No


            • 2 Evaluation of the material and details of the application

              Responsible for Implementation Competent Employee

              Μethod of Implementation Inspection

              Description The competent officer examines the information, requests additional information and clarifications, and prepares the relevant recommendation, which is forwarded to the head of the department.

              No No


            • 3 Drafting of the department’s recommendation and its acceptance by the Directorate

              Responsible for Implementation Responsible Head of Department

              Μethod of Implementation Inspection

              Description The Head of the Department examines the proposal and the supporting documentation, requests further information and clarifications, and adds his or her comments to the relevant proposal, which he or she then forwards to the Directorate.

              No No


            • 4 Submission of a recommendation to the Board of Directors of the Hellenic Capital Market Commission

              Responsible for Implementation Competent Director

              Μethod of Implementation Signature

              Description The Director examines the recommendation and, after any comments, forwards the recommendation signed by all persons concerned to the Board of Directors for examination of the matter.

              No No


            • 5 Issuance of Board of Directors decision granting the licence or rejecting the application

              Responsible for Implementation Board of Directors

              Μethod of Implementation Inspection

              Description The Board of Directors decides whether or not to grant the operating licence

              Notes Additional information may be requested. If, after examination of the documents submitted, no evidence emerges of non-compliance with the legislation in force, the Hellenic Capital Market Commission grants the company a REIC operating licence.

              No Yes


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