Expert Column · Legal Review
Before paying a reservation deposit, an investor needs to know who can answer a question, who can prove the answer and who will accept responsibility for the next step. A single contact person can make a purchase easier to follow, but a single conversation cannot replace separate legal and technical judgments.
What is confirmed
The Hellenic Cadastre’s certificate guidance identifies cadastral sheets and registered-rights records that can show ownership interests and burdens. These are source documents for a title examination; a project brochure is not the equivalent of that examination.
The current Mitos change-of-use procedure requires full ownership and possession of one property acquired for at least €250,000. It also identifies distinct notarial, registration and engineering evidence. A reservation document does not perform all of those functions.
The Ministry’s Circular 9 of 25 September 2024 explains Article 100 of Law 5038/2023 as amended by Article 64(1) of Law 5100/2024. It is administrative guidance on the investor-residence framework, not an assessment of the property being offered to you.
Expert analysis
Define the instruction before assessing the answer
My proposed starting point is a written responsibility sheet. It should identify the buyer’s appointed lawyer, the notary, the property engineer, the seller and the person managing the document requests. Record who each professional represents and the scope of their engagement. Santheos internal review does not automatically create an independent lawyer-client relationship with the buyer.
A useful legal question is precise: “Does the evidence available today support signing this agreement on these terms?” The answer should identify the documents examined, their dates, unresolved matters and any conditions that must be satisfied. “The project is progressing” answers a different question. It says nothing about whether a payment obligation has become unconditional.
Use a handoff that preserves responsibility
Construction coordination belongs to the project team. The engineer determines the technical evidence and permit treatment for the particular property. The lawyer examines the legal consequences of those findings and the protection offered by the contract. If the drawings change, the project coordinator should circulate the revision; the engineer and lawyer should then reconsider the parts of their own conclusions affected by that change.
For example, a proposed alteration may improve a room layout while changing the area or description expected in the deed. The coordinator can obtain the revised papers and track the response. The coordinator cannot resolve the discrepancy merely by renaming a file. Ask for the engineer’s explanation and the lawyer’s written position before relying on the revised description.
Separate three decision points
At reservation, ask which risks remain and how the deposit terms address them. Before the final deed, ask whether the agreed evidence and contractual conditions have been satisfied. Before residence filing, ask whether the transaction records support the particular application. A conclusion at one stage should identify its scope; it should not silently become permission to pass every later stage.
The practical output is a short issue log with a named owner, evidence requested, response date and resolution. Escalate a material conflict to the professional whose judgment is required. Proceed only when that professional has documented the resolution and the buyer understands any remaining contractual exposure.
Investor checklist
- Request a responsibility sheet naming the buyer’s lawyer, notary, engineer and project coordinator, with the scope of each appointment.
- Obtain the current title and cadastral material for the exact property; ask the lawyer which further searches are required.
- Compare the reservation description with the legal and technical file, marking every unresolved difference for professional review.
- Ask the lawyer to explain the deposit, cancellation and unresolved-condition clauses before you sign or transfer funds.
- Record each technical question against the engineer responsible and each legal conclusion against the lawyer responsible.
- Stop the next commitment if ownership, property identity or a material condition remains unresolved; escalate with the conflicting documents attached.
- Keep the dated written resolution and the approved document version together before requesting a decision to proceed.
Case evidence
Illustrative Scenario. A buyer receives a revised plan after a reservation draft has been circulated. The appropriate response is to request a comparison with the contractual description and separate technical and legal answers before signing; no private client or internal project outcome is being presented here.
For the related title and signing-authority questions, read Who Owns the Property and Who Can Sign?, then use the Santheos Golden Visa Q&A to prepare your document requests.
Official sources
- Hellenic Cadastre, Certificates issued by cadastral offices; publication date not displayed; sections on registered rights and copies of cadastral sheets; retrieved 8 September 2026.
- Ministry of Migration and Asylum / Mitos, Permanent investor residence permit — change of use, initial issuance; updated 3 August 2026; Article 100, ownership condition 4 and documentary requirements; retrieved 8 September 2026.
- Ministry of Migration and Asylum, Circular 9; dated 25 September 2024; instructions on Article 100 of Law 5038/2023 as amended by Article 64(1) of Law 5100/2024; retrieved 8 September 2026.
