Golden Visa, Asset Regeneration and Smart Buildings: New Balances in the Greek Real Estate Market.

DMN Properties
May 25
3 min read

Based on remarks by Liliana Kouloumpi at the 4th Real Estate Conference by capital.gr x Forbes

The Greek real estate market is undergoing a period of transformation, with the Golden Visa program evolving to incorporate new investment models. At the 4th Real Estate Conference by capital.gr x Forbes, Liliana Kouloumpi, Corporate Governance Officer & Head of Legal Operations at DOMINION GROUP, outlined how a new subcategory of the program—focused on change-of-use and refurbishment of existing buildings—is reshaping the landscape.

The New Golden Visa Subcategory: An Emerging Market Segment

As highlighted, this specific subcategory has effectively been active for the past 18 months, following the issuance of regulatory guidelines by the Ministry toward the end of 2024.

This segment allows investors to qualify for a Golden Visa through real estate investments starting at €250,000—significantly lower than the mainstream thresholds of €400,000 or €800,000—provided that the property undergoes a change of use and is converted into residential stock.

Currently, this niche represents approximately 15%–20% of the overall Golden Visa market. While still not part of the program’s core segment, it is considered one of the fastest-growing areas and is expected to gain substantial traction in the coming years.

From Development to Asset “Recycling”

The importance of this category extends beyond investment activity, aligning closely with sustainability and circular economy principles.

As Kouloumpi explained:

No new buildings are developed under this framework
Existing, often inactive properties are repurposed
Through renovation and change of use, assets are reintroduced into the market

This approach contributes to:

Increasing the supply of available housing, particularly critical amid the ongoing housing shortage
Enhancing the quality of properties, both in energy efficiency and functionality
Utilizing aging building stock, which dominates the Greek real estate landscape

Notably, these properties are restricted to long-term rental use and cannot be used for short-term rental platforms such as Airbnb, thereby supporting the supply of permanent housing—albeit to a limited extent.

However, as emphasized, this initiative alone cannot resolve the housing crisis and must be complemented by broader policy measures.

Listed Buildings: Opportunity or Investment Risk?

Special attention was given to listed (preserved) buildings, which are also eligible under this scheme. However, they present significant challenges:

Complex licensing procedures
Involvement of archaeological authorities
Difficulty in forecasting total investment costs

In such cases, the investment equation becomes highly uncertain, often making it difficult to assess profitability due to unpredictable regulatory and technical factors.

Bureaucracy and Asset Maturity: Key Market Barriers

According to Kouloumpi, the first major challenge foreign investors encounter is Greek bureaucracy.

Because the Golden Visa operates within a strict legal framework:

It is not enough for a property to be attractive or within budget
It must meet specific legal and technical requirements

This makes due diligence—both legal and technical—absolutely critical. Investors, often operating remotely, require transparency, structured guidance, and reliable reporting throughout the process.

A major issue in the Greek market is the immaturity of assets, including:

Unclear or problematic property titles
Land registry inconsistencies
Urban planning and zoning irregularities

As a result, properties are often brought to market before they are transaction-ready, leading to delays and, in some cases, deal collapse when investors withdraw due to prolonged processes.

Although digitization has improved certain aspects, fragmentation across public services and the lack of centralized coordination continue to hinder efficiency.

Smart Buildings and Data: A New Regulatory Challenge

Another critical topic raised was the rapid emergence of smart buildings and the vast data they generate.

Kouloumpi noted that, from a regulatory and compliance perspective, the market is not yet fully prepared to handle this new reality. The legal framework is still evolving, with the EU AI Act (2024) being gradually implemented through 2025–2026.

Smart buildings:

Collect extensive user behavioral data
Control key functions (lighting, temperature, access)
Often rely on biometric technologies (Face ID, fingerprints)

This creates significant risks, including:

Data privacy violations
Cybersecurity threats
Misuse or leakage of sensitive personal information

She pointed out real-world examples where connected devices—such as robotic vacuum cleaners—were found to capture and transmit images from private spaces, illustrating the seriousness of the issue.

The Changing Role of Developers and Property Managers

This shift is redefining the role of real estate professionals. Developers and property managers are no longer solely focused on construction and operations; they increasingly function as:

Data collectors
Data processors

This raises complex questions around liability, compliance, and governance—areas that the industry will need to urgently address.

Conclusion

The Golden Visa is evolving into a more sophisticated and multifaceted investment tool, with the new change-of-use category unlocking significant opportunities for both investors and the broader real estate market.

However, this evolution comes with notable challenges:

Bureaucratic and regulatory complexity
The need for asset maturity and market readiness
Emerging risks related to technology and data management

As Kouloumpi concluded, real estate is now required to engage with issues it traditionally did not face—making the road ahead more demanding, yet full of strategic opportunities.