A buyer may intend to own the property personally while a spouse or family member provides the funds. Greek Golden Visa law allows certain third-party family payments, but the relationship and the payment trail cannot be left informal.
The important question is not simply, “Did the seller receive the money?” The file must show who paid, how the payment was made, which account was debited, which recipient account was credited and why the payer was legally permitted to pay for this buyer.
Who may pay under Article 100(5)
Article 100(5) of Law 5038/2023, in the form introduced by Article 64 of Law 5100/2024, states that the agreed price or rent must be paid in full through one of the specified channels:
- a crossed bank cheque to the beneficiary's payment account held with a credit institution operating in Greece;
- a credit transfer within the meaning of Law 4537/2018; or
- a POS terminal installed by a payment-service provider operating in Greece, debiting the buyer's bank credit or debit card and crediting the beneficiary's payment account with a qualifying provider.
The same provision permits payment by the buyer's spouse or by relatives by blood or marriage up to the second degree. It does not say that any friend, business associate or unrelated company may substitute as payer.
If the proposed payer falls outside the named categories, the transaction team should obtain a property-specific legal answer before any funds move. A later explanation cannot safely replace a compliant payment structure.
What must appear in the transaction record
Article 100(5) requires the parties to declare the detailed payment information before the notary and have it recorded in the deed. The required information includes, in particular:
- identification of the seller, buyer and any third-party payer;
- the payer's payment-account number;
- the payer's address;
- an official personal-document number;
- a payer identification number or the payer's date and place of birth;
- the payment method;
- the debited payer account and credited beneficiary account; and
- the buyer's solemn declaration describing the marriage or family relationship with the third-party payer.
Article 100(6) then requires a notarial certificate describing the parties, property, payment method and detailed payment information. Joint Ministerial Decision 214926/2025, Government Gazette B 6014/11.11.2025, also identifies the notarial certificate and, where relevant, the discharge deed among the residence-file documents.
Build the evidence before the transfer
The cleanest payment file is prepared before the bank instruction is submitted. It should include:
- A payer-authorisation note. Name the buyer, payer, relationship and intended payment amount.
- Relationship evidence. Obtain the marriage or civil-status documents the buyer's lawyer considers sufficient, with authentication and translation where required.
- Account-holder confirmation. Verify that the sending account belongs to the permitted payer and that the beneficiary account is the account approved for the transaction.
- Payment reference wording. Use a stable reference tying the payment to the buyer, exact unit, reservation or deed and ST project number where applicable.
- Bank evidence. Preserve the instruction, debit confirmation, SWIFT or credit-transfer data and beneficiary credit confirmation.
- Deed reconciliation. Give the notary the final payment schedule early enough to record the payer and transaction data accurately.
Screenshots of a banking application, an unsigned spreadsheet or a developer's receipt alone may not establish the complete statutory trail.
Avoid three common mismatches
The payer is permitted, but the deed names only the buyer
Where a spouse actually sends the funds, the third-party payer information and relationship declaration should not disappear from the deed file.
The recipient differs from the contractual seller
If payment is requested to a project company, escrow account, creditor or another recipient, the buyer's lawyer and notary should document why that recipient is entitled to receive the relevant amount. Do not rely only on emailed bank instructions.
The payment schedule mixes different purposes
A single transfer may be difficult to reconcile if it combines property price, furniture, taxes and services. Separate purposes and invoices before payment, especially where only the real-estate consideration is being relied on for the Golden Visa threshold.
Hypothetical example
An investor will own a conversion apartment. The investor's spouse transfers EUR 250,000 directly to the seller's approved account. Before the transfer, the lawyer checks the relationship documents; the bank reference identifies the buyer and unit; the notary receives the debit and credit information; and the deed records the spouse as third-party payer together with the required relationship declaration.
This scenario illustrates the statutory evidence chain. It is not an actual permit approval and does not establish that incomplete documents would be accepted.
Investor questions
- Is the payer within the family categories expressly named in Article 100(5)?
- Does the sending account belong to that payer?
- Does the receiving account belong to the contractual beneficiary or have documented authority?
- Will the deed state all third-party payer and account details required by Article 100(5)?
- Will the notary issue the certificate required for the residence file?
- Are the reservation, deed, bank records, tax declaration and discharge deed consistent?
Santheos's internal legal and risk-control review checks the transaction evidence supplied for a Santheos project. The buyer's lawyer and notary must confirm the individual payer structure before funds are released.
Related Santheos reading
- EUR 250,000 Conversion Golden Visa: Payment Trail and All-In Budget
- Who Owns the Property and Who Can Sign?
- Buying a Conversion Project Through a Company
Official sources
- Law 5100/2024, Government Gazette A 49/5.4.2024, Article 64, replacing Article 100 of Law 5038/2023; see Article 100(5)-(6): official Ministry-hosted consolidated text.
- Joint Ministerial Decision 214926/2025, Government Gazette B 6014/11.11.2025, special supporting documents for Article 100: official MITOS change-of-use procedure.
- Ministry of Migration and Asylum, Circular 1/2026, 21 April 2026, Clarification 23 on misleading payment structures and undocumented fund transfers: official listing.
Continue your research
- Engineer Report for a Greece Golden Visa Conversion Project: What It Must Confirm
- EUR 250,000 Commercial Conversion Projects in Athens: How to Choose the Right Location
- EUR 250,000 Conversion Golden Visa Greece: Payment Trail and All-In Budget
Prepared by: Santheos Research & Project Team. Last reviewed: September 2026. General information only, not legal, tax or immigration advice. Eligibility is subject to final legal review. Review the Greece Golden Visa Encyclopedia, the official Mitos entry, or contact Santheos for a property-specific discussion.
