An EUR 250,000 commercial-to-residential project can involve several processes at the same time. The legal use of the main spaces is changed to residential. The property is sold and registered. Construction and fit-out continue toward delivery. The buyer and lawyer prepare the residence-permit application.
These processes are connected, but they are not interchangeable. Saying “the conversion is complete” should never be used to imply that the apartment is finished, ready to occupy or guaranteed to support a residence-permit decision. Investors need separate evidence for separate milestones.
Timeline 1: the legal change of use
For the current EUR 250,000 conversion route, the official procedure states that the property must be acquired in full ownership and possession, the main spaces must be converted to residential use, and the investment must concern one property. The 120-square-metre minimum used in the standard EUR 400,000 and EUR 800,000 routes does not apply to this exception.
The change of use may be carried out by the seller or the buyer. It must have been completed after Article 64 of Law 5100/2024 entered into force on 5 April 2024 and before the Golden Visa application is submitted. Where a change-of-use permit existed earlier, the official procedure says an application is accepted only where the change of use for the specific property has been properly updated or revised after the law entered into force.
This is a legal and technical evidence question, not a description of the apartment’s finishes.
Timeline 2: the property transaction
The buyer must also become the owner through the notarial deed and the required registration process. The official filing materials include a notarial certificate covering the parties, property, consideration, payment method, full payment and related Article 100 details.
Proof of registration at the competent Land Registry or cadastral office is normally required. For initial issuance, the official procedure also describes a permitted alternative based on proof of the registration application or the corresponding lawyer’s certificate; full registration evidence must then be supplied with the renewal application.
Completion of the change of use does not transfer title. Completion of the deed does not by itself prove that every construction item has been delivered.
Timeline 3: construction and handover
Construction completion is governed by the contract, technical scope and applicable building requirements. The buyer should request a written schedule identifying structural work, internal partitions, mechanical and electrical systems, finishes, common areas, testing, snagging, utility applications and handover documents.
The practical delivery date should be connected to objective evidence. Depending on the project, that may include site inspections, engineer confirmations, updated plans, the electronic building identity file, energy documentation, equipment schedules, keys, meter information, warranties and a signed handover protocol.
A project can have a completed qualifying change-of-use act while fit-out, common-area work or utility connections remain outstanding. The buyer’s contract should explain which incomplete items are permitted at each payment stage and what evidence is required before the next payment.
Timeline 4: the residence-permit filing
The immigration filing has its own sequence. Under the official procedure, the change of use must be complete before submission. The agreed property consideration must also have been paid in full through a permitted payment method, and the filing requires the specified notarial, registration, technical, insurance and personal documents.
The Ministry’s Circular 1/2026 further clarified that prior completion of the connection to public-utility networks, such as electricity, is not a prerequisite for bringing a property within Article 100. That clarification should be read narrowly. It does not state that unfinished construction is complete, that a unit is habitable, or that the seller has satisfied the contractual delivery standard.
The engineer’s report is route-specific evidence
The official procedure requires an engineer’s technical report concerning the change of use of the main spaces. The report must identify the relevant act—such as the building permit, small-scale works approval, file update or building-permit revision—and certify the qualifying change from the previous use to residential use after the legal date.
For certain industrial-building cases, additional certification is required regarding the absence of industrial activity during the previous five years, supported by the evidence described in the procedure.
The buyer should not treat a generic progress report or construction certificate as a substitute for this route-specific report. Equally, the Golden Visa engineer’s report should not be treated as a complete snagging report or warranty document unless it expressly covers those separate matters.
Build a four-column evidence schedule
A practical way to control the transaction is to maintain four columns:
| Track | Key question | Evidence to request | Decision affected |
|---|---|---|---|
| Change of use | Has the qualifying legal change been completed for this unit after the required date? | Relevant permit, update or revision; plans; route-specific engineer report | Golden Visa route and filing readiness |
| Ownership | Can this seller transfer this exact property, and has the deed been registered? | Title review, deed, cadastral or registry evidence, notarial certificate | Acquisition and immigration file |
| Construction | Is the unit complete to the contractual specification? | Progress inspections, completion evidence, snag list, handover protocol | Payment, possession and occupancy |
| Immigration | Are all applicant and property documents ready for submission? | Lawyer’s filing checklist, payment evidence, insurance and personal documents | Application timing |
No single document closes all four tracks.
Link payments to evidence, not labels
If the buyer is paying in stages, each milestone should be defined by deliverables. “Conversion complete,” “construction complete” and “ready for filing” should have separate definitions.
Before a final payment or major instalment, the buyer should ask: Which legal act has been issued? Which work has been inspected? Which documents have been delivered? Which defects remain? What happens if the next milestone is late? Does the payment schedule remain consistent with the full-payment requirement before the residence-permit filing?
These questions allow the lawyer, engineer, notary and project team to work from the same facts.
How Santheos reviews a conversion project
Santheos’ internal legal and risk-control teams review the project documentation available to the company, while the technical team tracks the conversion and construction evidence relevant to the project. The review keeps legal use, title, transaction, construction and immigration-support materials in separate workstreams so that one milestone is not presented as proof of another.
For the investor, the practical objective is clear: know what is complete today, identify the document that proves it, record what remains to be done, and connect every payment and filing decision to the appropriate evidence.
For additional change-of-use and filing questions, use the Santheos Greece Golden Visa Encyclopedia: 338 Answers.
Sources
- National Registry of Administrative Public Services, Permanent golden visa (change of use) – Initial issuance, updated 4 August 2026
- Law 5100/2024, Article 64, Government Gazette A 49/5 April 2024
- Government Gazette B 6014/2025, Joint Ministerial Decision 214926/2025
- Ministry of Migration and Asylum, Circular 1/21 April 2026, Diavgeia publication ΨΣΙ746ΜΔΨΟ-ΔΧΜ
- EY Greece, summary of Circular 1/2026 including the utility-connection clarification, 29 May 2026
