On June 2nd, Law 5203/2025 was adopted, restructuring and amending the existing Development Law 4887/2022. The amendment pursues the following:
- Establishment of new aid schemes, while revising or abolishing existing ones,
- Introduction of a new fast licensing incentive (Fast-Track Licensing) and a loan guarantee incentive under specific schemes,
- Enhancement of evaluation and audit mechanisms for investment plans,
- Simplification of the operations of collective administrative bodies involved in various procedural stages.
The Twelve Aid Schemes of the New Development Framework
- Modern Technologies (new)
- Green Transition – Environmental Upgrade of Enterprises
- Social Entrepreneurship & Handicrafts (new)
- Special Support Areas (new)
- Agri-Food, Primary Production & Processing, Fisheries and Aquaculture
- Manufacturing – Supply Chain
- Business Extroversion
- Tourism Investments
- Alternative Tourism
- Large-Scale Investments
- European Value Chains
- 360° Entrepreneurship
The new development Framework includes:
New Incentives & Funding Instruments
- Introduction of Fast-Track Licensing:
This new incentive significantly reduces the bureaucratic burden for investment projects falling under the “Special Support Areas” and “Large-Scale Investments” schemes. Specifically, all required licenses and approvals — including zoning, environmental, and operational permits — for the execution of works, such as construction of buildings for the installation of the investment, must be issued within 2 months from the date of full dossier submission by the investor to the Directorate-General for Development Laws and Foreign Investments (G.D.AN.N.A.X.E.) of the Ministry of Development. The two-month timeframe excludes any period required for the investor to provide additional documents upon administrative request. For environmental approvals, the new process is aligned with the fast-track process which had so far been reserved only for strategic investments, as provided in Articles 3 and 9 of Law 4864/2021.
- Introduction of a loan guarantee incentive via the Hellenic Development Bank (HDB) and the European Investment Bank (EIB):
For SMEs: eligible investment plans that have received a formal acceptance decision under any aid scheme, may apply for either short-term or long-term financing through the Hellenic Development Bank S.A. by utilizing the HDB’s Development Law Financial Instrument Guarantee Fund (DeLFI GF) or other subsidized financing tools provided by HDB.
Large-Scale Investment scheme: companies whose projects fall under the “Large-Scale Investments” aid scheme, regardless of whether they are large corporations or SMEs, may apply for medium – to long-term loans from the European Investment Bank (EIB). These loans are backed by a guarantee from the Greek State, ensuring more favorable borrowing terms and reduced financial risk. EIB independently evaluates the investment proposals based on its internal financial and risk assessment criteria. Specific terms, including interest rates, repayment schedules, and disbursement conditions, are established through a ministerial decision to be jointly issued by the Ministers of National Economy & Finance and Development.
Increase in Maximum Aid Amounts
The cap on cumulative aid per investment project is raised:
- From €10 million to €20 million per project undertaken by a single enterprise; and
- From €30 million to €50 million per project undertaken by associated or affiliated enterprises.
Inclusion of Very Small Enterprises
Very small enterprises may now participate in the “Social Entrepreneurship & Handicrafts” scheme, broadening access to micro-scale business operations.
Enhancement of sustainable investments
A new prerequisite for the granting of aid under any of the schemes, where such aid is co-financed by operational programs of the Partnership Agreement for Regional Development (PA) for the period 2021-2027, is the compliance with the “Do No Significant Harm” principle, ensuring that the subsidized activities do not cause significant harm to the environment, in line with Article 17 of Regulation (EU) 2020/852.
Refined and realistic Application and Assessment process
- Investors may now submit the same investment plan under multiple aid schemes, provided criteria are met. Once an investment plan is formally included in one scheme, all other pending applications for that same project are automatically rejected.
- Entities must declare any state support associated with the investment.
- The obligation whereby investment plans exceeding 700.000 Euro had to be accompanied in the application stage by a confirmation report signed by a member of the National Registry of Certified Evaluators has now been abolished.
- Applications are submitted through the Development Law Information System (P.S.-An) and are addressed to regional authorities, as provided in each aid announcement; the competency of the authorities is no longer dependent on financial thresholds per investment plan.
- Assessment period by the competent authorities is extended from 45 to 90 days, due to expected increase in application volume and complexity.
- Introduction of comparative assessment as the sole assessment method (eliminating “first in, first out” principle which applied so far).
- Licensed auditors intervening when assessment deadlines from the competent authorities have lapsed now have 30 days to assess plans (up from 10).
More flexible accommodation of changes occurring during the implementation of the investment plan
- Changes regarding the identity or legal status of the investment entity can now be submitted up until the issuance of the final completion decision, providing greater flexibility and legal clarity; the past regime allowed for such modification request up until the filing of request for final audit, which is an earlier step.
- The transformation of sole proprietorships into legal entities is now explicitly considered as reason for a modification request, without affecting the approved investment plan.
- Investors can switch the type of aid (e.g., from grant to leasing and vice versa) through formal modification requests.
- The law clarifies that an extension of the investment completion deadline can be requested in cases of force majeure, ensuring procedural safeguards for investors facing unexpected disruptions.
- Extensions of the completion deadline for reasons other than force majeure will be granted for the maximum period of 2 years, including extensions granted upon horizontal legislative interventions.
- Modification requests can now be submitted earlier, at the 25% completion milestone, in addition to the 50% or 65% milestones.
Long-term obligations of the investors and revocation of aid decisions
- Investors may now proceed with corporate transformations after submitting a request for approval of the relevant change in the investment plan to the competent authorities; there is no longer a requirement to await formal approval before proceeding, as was the case under the previous regime. This reform is intended to enhance corporate flexibility and adaptability throughout the life cycle of the investment project, while reducing administrative delays.
- Revocation of an investment project due to the submission of inaccurate or misleading information or the concealment of material facts, will result in repayment of any financial aid received, with an additional 10% surcharge. This rule applies regardless of whether the project was partially or fully completed at the time of revocation.
- Revocation of aid decisions is due if at least 10% of the eligible investment cost has not been implemented within 24 months from the publication date of the inclusion decision summary. This is to encourage timely project implementation, ensuring that benefits are directed to projects that demonstrate active progress.
Other Implementation Insights
- Companies may utilize up to ½ (up from 1/3) of the total approved tax exemption amount per year, provided that the implementation of 50% or 65% of the investment plan’s cost has been certified.
- State aid schemes will be announced during Q1 and Q3 of each year.
The minimum content of each state aid scheme call now also includes:
- Clearly defined weighting coefficients used in the project evaluation process, providing greater transparency and predictability.
- The possibility of awarding scoring bonuses (evaluation incentives) to investment projects where the applicant requests a lower aid intensity than the maximum allowable percentage established in the aid scheme call.
Broader Access for Medium Enterprises
Medium enterprises may now be eligible for all types of aid, previously limited to smaller firms.
Special Support Areas Scheme Reform
The former “Fair Development Transition” scheme is replaced with “Special Support Areas”, a scheme specifically designed to support investment projects implemented in regions facing acute economic and demographic challenges. This includes:
- Border regional units located along Greece’s northern frontier,
- Areas where the per capita GDP does not exceed 70% of the national average, or where there is a documented population decline due to adverse economic and social conditions,
- De-carbonization zones, as defined in Article 155 of Law 4759/2020,
- Regions affected by natural disasters.
- Medium and even large enterprises can now benefit from fast-track licensing and multiple types of incentives.
