Country：希腊 · Domestic ODI Filing
Greece · Domestic ODI Filing
Chinese enterprises investing in Greece must first complete domestic ODI filing or approval (involving the NDRC, commerce authorities and SAFE). As an EU member, Greece's strategic industries - ports, energy, telecom and critical technologies - are subject to the EU FDI screening regulation and Greece's national screening mechanism and require additional filings; conventional manufacturing, trade and renewables investments generally use the filing regime.
Key points
- Domestic process in three steps: NDRC filing or approval → MOFCOM filing and certificate → bank FX registration.
- EU FDI screening: investments in critical infrastructure, critical technologies and sensitive industries must be notified to the EU level and Greece nationally.
- Greece is generally open to foreign investment in conventional industries, but ports, energy and telecom are screened.
- Profit repatriation must follow SAFE compliant routes.
- Engaging local counsel to run EU screening and domestic ODI in parallel is recommended.
Procedure
- Conduct domestic feasibility study and structure design.
- Complete NDRC and MOFCOM ODI filings.
- Complete bank FX registration and remit capital.
- Assess whether EU or Greek FDI screening obligations are triggered and file accordingly.
- Complete GEMI registration and AADE tax registration in Greece.
Hard requirements
- Domestic entity must remain compliant; sensitive industries must pass EU and Greek screening.
Costs
Legal service fees extra; government fees low.⏱ ⏱ Timeline：ODI processing about 1-2 months; EU screening duration depends on industry.⚠ Common risks
- Remitting funds before filing completion leads to penalties.
- Triggering EU FDI screening without filing blocks the transaction.
- Profit repatriation must follow compliant routes.
Handbook
📘 Step-by-Step Handbook (with owner / timeline / cost / penalties)
Applies to：Chinese enterprises and organizations investing in Greece (incl. EU), requiring domestic ODI filing/approval first, then Greek local registration and applicable EU/Greek FDI screening.
Prerequisites
- Domestic investing entity remains compliant and completes internal decision procedures.
- If held by a Chinese parent, ODI must be completed before outbound capital injection.
- Know the State Council Provisions on Foreign Investment (Order No.837, effective 2026-07-01)
- Assess whether EU FDI screening (Reg (EU) 2019/452) and Greek strategic-industry screening are triggered
- Verify parent entity credentials via Qichacha-style tools (generic paradigm, no hardcoded names)
| Step | Action | Owner | Timeline | Cost | Official form / system | Notes & penalties |
|---|---|---|---|---|---|---|
| 1 | Pre-departure verification of the parent entity (generic Qichacha paradigm, no hardcoded names) Verify the domestic parent's business scope, administrative penalties, equity tracing and any restricted/prohibited classifications under the generic paradigm; form a reusable verification checklist without hardcoding natural-person names | Chinese legal / compliance | 1-2 weeks | Internal/data services | Qichacha-style enterprise credit report (generic template) | Verification conclusions serve as ODI filing attachments and internal decision basis Penalty：Entity defects cause filing rejection or follow-up compliance risk |
| 2 | Handle ODI filing/approval under the State Council Provisions on Foreign Investment (Order No.837, effective 2026-07-01) Domestic feasibility and structure design → NDRC approval/filing → MOFCOM filing and certificate → bank FX registration. Submit materials truthfully and cooperate with supervision | NDRC + MOFCOM + SAFE | 1-2 months | Low government fees; agency fees vary by complexity | NDRC filing/approval + MOFCOM filing with Certificate of Outbound Investment + SAFE FX registration | Order 837 effective 2026-07-01 is the latest superior basis Penalty：No filing: fine of 1‰-5‰ of investment; prohibited category: 5‰-10‰; applications not accepted for 3 years (Art.27) |
| 3 | Complete bank FX registration and remit capital (SAFE cross-border fund registration) Complete FX registration at a bank with the ODI certificate and remit capital to the Greek account through compliant routes | Bank / SAFE | 1-2 weeks | Bank fees | FX registration / capital remittance | Fund usage must match the filing Penalty：Remittance without registration is a violation |
| 4 | Assess whether EU/Greek FDI screening is triggered and file Determine whether ports, energy, telecom and critical technologies fall under EU 2019/452 and Greek national screening; file in parallel where needed | Greek law firm / EU advisor | By industry | Lawyer fees | EU member-state screening notification and Greek strategic investment/security review | Run in parallel with local counsel Penalty：No filing: transaction blocked or revoked |
| 5 | Greek local GEMI registration and AADE tax registration Complete GEMI registration, AFM tax number and bank account opening (see incorporation/tax dimensions) | Greek agent | 1-3 weeks+ | See incorporation dimension | e-YMS incorporation | Proceed after ODI completion |
| 6 | Profit repatriation and annual information reporting (domestic) Repatriate profits via SAFE compliant routes with tax paid; submit outbound investment annual information reports on time | Chinese finance / SAFE | Continuous | Internal | ODI annual information report (MOFCOM/NDRC) | Major changes require re-approval/filing Penalty：No report: order to correct / penalties |
✅ Self-check list
⚠ Common pitfalls
Remitting capital before filing影响：SAFE violation: fine of 1‰-5‰ of investment, affects profit repatriation (Order 837 Art.27)规避：Complete the NDRC + MOFCOM + SAFE three-step process first
Misjudging industries that trigger EU/Greek screening影响：Transaction suspended or revoked规避：Do FDI screening early; file sensitive industries in parallel
Applying with false materials影响：Revocation, confiscation, fines, 1-3 year ban (Order 837 Art.27)规避：Truthfully disclose beneficial owners and deal structure
Ignoring Order 837 2026-07-01 new rules影响：Using old departmental rules causes procedural gaps规避：Treat State Council Order 837 as the latest superior basis
Parent entity not verified before proceeding影响：Entity defects cause rejection and delay规避：Verify per generic Qichacha paradigm before departure (no hardcoded individuals)
Non-compliant profit repatriation route影响：FX compliance risk规避：Use SAFE compliant routes; retain tax certificates and board resolutions
📅 Ongoing post-incorporation obligations
- Submit ODI annual information reports on time (MOFCOM/NDRC)
- Re-approval/filing for major changes
- Cooperate with supervision (Order 837 Art.12, 26)
- Profit repatriation via SAFE compliant routes with tax paid
- Comply with outbound security review decisions (if applicable)
🔗 Official portals
📎 Source：NDRC; MOFCOM; SAFE; EU Foreign Direct Investment Screening Regulation (EU 2019/452)
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