An industrial building can fall within the EUR 250,000 change-of-use route only if the property and conversion satisfy the applicable requirements. For this type of building, the engineer's report carries an additional evidentiary burden: it must address the absence of installed and operating industry in the building during the previous five years.
This is not satisfied by changing a label on a marketing brochure. The engineer must identify the public or tax evidence used to reach the conclusion.
The current official requirement
Joint Ministerial Decision 214926/2025, Government Gazette B 6014/11.11.2025, sets the special supporting documents for Article 100 of Law 5038/2023. The official MITOS procedure and Circular 1/2026 describe the wording expected in an engineer's technical report for a change-of-use investment.
For an industrial building, the report must additionally certify that no industry was installed and operating in the building during the previous five years. The engineer may support that finding by referring to:
- a power-disconnection certificate from HEDNO/DEDDIE or the municipality;
- E2 tax forms for the preceding five years; or
- a combined review of other documents issued by tax or other public authorities.
The report must also identify the act demonstrating the change of the main spaces to residential use after Article 64 of Law 5100/2024 entered into force. Depending on the property file, that may be a building permit, approval of small-scale building works, file update, permit revision or another applicable act.
What the five-year test is not
It is not the same as proving that construction has finished. It is also not the same as proving that the building is currently vacant.
A photograph of an empty factory today does not establish what occurred throughout the preceding five-year period. A disconnected meter may be relevant, but the engineer must assess the period covered and whether other evidence is required. Likewise, an E2 form must be matched to the correct owner, property and year.
Build a year-by-year evidence table
Before reservation, ask the project team to prepare a controlled table:
| Period | Evidence requested | Property identifier | What it demonstrates | Gap or follow-up |
|---|---|---|---|---|
| Year 1 | E2/public record/utility evidence | Address and KAEK | Declared use or non-operation | To be completed |
| Year 2 | E2/public record/utility evidence | Address and KAEK | Declared use or non-operation | To be completed |
| Year 3 | E2/public record/utility evidence | Address and KAEK | Declared use or non-operation | To be completed |
| Year 4 | E2/public record/utility evidence | Address and KAEK | Declared use or non-operation | To be completed |
| Year 5 | E2/public record/utility evidence | Address and KAEK | Declared use or non-operation | To be completed |
The exact five-year window should be stated by the engineer rather than assumed by the sales team. If ownership changed during that period, the evidence chain may need documents from more than one owner.
Match the building, the unit and the conversion act
Industrial conversions often involve a large parent building that is later divided into individual residential units. The investor should ask the engineer and lawyer to reconcile:
- the historic industrial building and its permit file;
- the current cadastral identifiers;
- the horizontal-property constitution and amendments;
- the exact residential unit being acquired;
- the act completing the change of use; and
- the engineer's five-year non-operation evidence.
Circular 1/2026 also addresses investments created through interventions or vertical or horizontal additions to industrial buildings, and new independent buildings on plots containing industrial buildings whose use changes to residential. The technical report must identify the relevant configuration. Do not assume that evidence for the parent building automatically describes every resulting unit correctly.
Hypothetical evidence problem
Suppose a former industrial building is marketed as a conversion project. The developer provides a current engineer drawing and a recent electricity disconnection notice. No E2 forms or other public records are provided for the earlier four years, and the notice does not state when industrial operation ended.
The documents may be useful, but they do not yet demonstrate a complete five-year chain. The appropriate next step is not to declare the project ineligible; it is to identify the missing period, request supporting public or tax evidence and obtain the engineer's reasoned conclusion.
This is a hypothetical due-diligence scenario, not an actual project or permit decision.
Investor checklist
- Does the engineer's report use the wording and route identified in Decision 214926/2025?
- What exact start and end dates define the previous five years?
- Which public or tax documents support each part of that period?
- Do all records refer to the same building, ownership history and identifiers?
- Is the relevant change-of-use act identified by number and date?
- If new units were created, does the report connect the parent building to the exact unit purchased?
- Are missing years or contradictory uses explained in writing?
Santheos's internal legal and risk-control team checks the property-specific engineering and documentary package before an industrial conversion project is described as fully eligible. The description must remain tied to the reviewed unit and evidence, not to the building name alone.
Related Santheos reading
- Engineer Technical Report for an EUR 250,000 Greece Golden Visa Conversion Project
- When Must Change of Use Be Completed?
- How an Architect Reads a Conversion Floor Plan Before Reservation
Official sources
- Joint Ministerial Decision 214926/2025, Government Gazette B 6014/11.11.2025, special supporting documents and certification of Article 100(2)(c)-(d): official MITOS procedure, updated in 2026.
- Ministry of Migration and Asylum, Circular 1/2026, reference 72019, 21 April 2026: official circular listing and Diavgeia record.
- EUGO/Gov.gr, Issuance of Building Permits (e-Permits), current service description including when a change of use requires a building permit: official procedure.
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.
