Introduction

This guide is written for brokers, valuers, notaries, accountants, lawyers, and investors active in the Greek real estate market. It answers a question that comes up daily in practice: in which cases does Greek law require that a property valuation be carried out by a Certified Valuer registered with the Registry of Certified Valuers of the Ministry of National Economy and Finance, and in which cases is a valuation required but the law also accepts other providers, or the requirement comes from supervisory practice rather than a statutory provision.

The distinction matters in practice. A common belief in the market is that "everything requires a Certified Valuer." That is not correct. There are cases where the Registry's competence is exclusive, cases where the law alternatively accepts sworn auditors, court-appointed experts, or committees, and cases where the requirement comes from a supervisory authority or a bank's internal policy.

Each case carries three markers:

  • Statutory / Supervisory: whether the requirement arises from an express statutory provision or from a supervisory framework and practice.
  • Registry exclusive / Alternative: whether the law names only the Certified Valuer under Law 4152/2013, or also accepts others.
  • Mandatory / Discretionary: whether the engagement is imposed or merely permitted.

Each section closes with Sources: the primary source (Government Gazette or codified text) and, where used, the secondary source with an explicit label. Where a detail has not been verified against a primary text, it carries the flag [to be verified]. No provision, article, or amount has been added without a source.

Note: This text is informational and educational in character and does not constitute legal advice. For a specific case, the current legislation must be checked at the time of the transaction and, where necessary, the opinion of a lawyer obtained.


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PART A — The institutional framework

A.1 Law 4152/2013 and the Registry of Certified Valuers

The valuation profession was deregulated by Law 4152/2013 (Government Gazette A' 107/9.5.2013), sub-paragraph Γ of the first article. The Sworn Valuers' Body (Σ.Ο.Ε.) was abolished (sub-para. Γ.11: repeal of Article 15 of Law 820/1978, Presidential Decree 279/1979, and Article 2 of Law 2515/1997), and its place was taken by the Registry of Certified Valuers, kept at the Ministry of National Economy and Finance.

The transitional clause in sub-para. Γ.11 is critical: "Wherever the current legislation refers to the Special Body of Sworn Valuers (Σ.Ο.Ε.), this shall henceforth mean the whole of the certified valuers under this Law." Through this clause, older provisions that referred to sworn valuers were automatically transferred to the Registry.

Registry branches (sub-para. Γ.4):

Branch Subject matter
Α Real estate
Β Mechanical installations and equipment
Γ Businesses and intangible assets
Δ Movable property of any kind

Registration is per branch. The Registry includes both natural and legal persons; a legal person is registered provided it employs at least one certified valuer (a natural person) who signs and bears responsibility.

Registration requirements (sub-para. Γ.2, as amended by Article 125 of Law 5162/2024): a tertiary-education degree, the absence of disqualifying grounds, and proof of competence through examinations or a recognised certification from an accredited body or professional association. In practice, the REV (TEGoVA) and MRICS/FRICS (RICS) qualifications are accepted as proof of competence.

Foreign valuers: A national of an EU member state who lawfully practises the profession in their own country may apply for registration under Directive 2005/36/EC, as transposed by Presidential Decree 38/2010, subject to possible compensatory measures.

A.2 Professional conduct, oversight and liability

Code of Conduct: Established by Ministerial Decision 19928/292 (Government Gazette B' 1147/13.5.2013), under the authorisation of sub-para. Γ.8 of Law 4152/2013. Core principles: independence and objectivity, avoidance of conflicts of interest, confidentiality, competence and diligence, and compliance with recognised valuation standards. This should not be confused with the separate "Banking Code of Conduct" under Law 4224/2013.

Disciplinary Council and sanctions: Article 125 of Law 5162/2024 (Government Gazette A' 198/5.12.2024) replaced sub-paras. Γ.2, Γ.9 and Γ.10. The scale of sanctions, under sub-para. Γ.10 as currently in force, is:

"a) A written reprimand. b) A fine of up to one million (1,000,000) euros […]. In case of repetition […] up to two million (2,000,000) euros. Specifically, where a fine is imposed on a legal person, the fine may reach an amount equal to ten times the fee invoiced to the client. c) Temporary suspension of certification for a period of up to one year. d) Final removal of the certified valuer from the Registry."

Civil liability: There is no specific statutory provision; contractual liability towards the client and tortious liability (Civil Code Art. 914) towards third parties apply. Banks and public bodies require, in practice, professional indemnity insurance, although this is not a statutory condition of registration.

Sources: - Ministerial Decision 19928/292/2013 (Government Gazette B' 1147): https://www.lawspot.gr/nomothesia/ypoyrgiki-apofasi-19928-292/ - Law 5162/2024 (Government Gazette A' 198): https://www.taxheaven.gr/law/5162/2024 - Sub-para. Γ.10 as in force: https://www.lawspot.gr/nomothesia/n-4152-2013/arthro-proto-par-g10-nomos-4152-2013-exoysies/ - Ministerial Decision 36259 ΕΞ 2025 (Government Gazette B' 966/4.3.2025) — concerns the Registry, content [to be verified]: https://www.kodiko.gr/nomothesia/document/1123999/yp.-apofasi-36259-eks-2025-2025

A.3 Valuation standards

Law 4152/2013 refers to recognised valuation standards. The European Valuation Standards (EVS 2025) of TEGoVA and the International Valuation Standards (IVS 2025) of the IVSC are applied. No binding national valuation standards issued by ministerial decision have been identified as of the reference date [to be verified].

Sources: European Valuation Standards, Greek edition (Hellenic Valuers' Association): https://avag.gr/

A.4 Two institutions that should not be confused

  1. The Certified Valuer under the Registry (Law 4152/2013): a professional holding state certification, subject to disciplinary oversight and personal liability.
  2. The court-appointed expert (Code of Civil Procedure Art. 368 et seq.): a person appointed by the court for a specific trial or non-contentious proceeding.

A Certified Valuer may be appointed as a court expert. But where the law provides for a court expert, it does not require registration with the Registry. Confusing these two institutions is the most common source of error in related commentary.


PART B — Case-by-case list

B.1 Company law

B.1.1 Contributions in kind to a Société Anonyme (ΑΕ)

  • Provision: Law 4548/2018 (Government Gazette A' 104/13.6.2018), Articles 17–18.
  • What is required: A valuation report for each contribution in kind, both at incorporation and at every capital increase. The value stated in the report sets the ceiling for recording the contribution in the share capital.
  • Who may act (Art. 17 §3): "two sworn accountant-auditors or an audit firm or, as the case may be, two independent certified valuers." Alternative.
  • Mandatory or discretionary: Mandatory, subject to the exceptions in Article 18.
  • Deadlines: The contribution is not permitted more than six months after the report is drawn up; publicity is required at the General Commercial Registry (GEMI).
  • Practical note: For real estate, market practice favours two certified valuers of Branch Α, independent of each other and of the company.

B.1.2 Private Company (ΙΚΕ)

  • Provision: Law 4072/2012 (Government Gazette A' 86/11.4.2012), Article 77 §2.
  • Verbatim: "Capital contributions in kind are permitted only where the item contributed constitutes an asset capable of monetary valuation […]. A valuation is not required if the value of the contribution, under the articles of association or the decision increasing the capital, does not exceed five thousand (5,000) euros."
  • Who acts: The provision historically refers to Articles 9 and 9a of Codified Law 2190/1920; Codified Law 2190/1920 has been replaced by Law 4548/2018, so the valuation follows Article 17 of Law 4548/2018 (sworn auditors or certified valuers). Alternative.
  • Practical note: For general and limited partnerships (ΟΕ/ΕΕ) no mandatory valuation of contributions is provided.

B.1.3 Limited Liability Company (ΕΠΕ)

  • Provision: Law 3190/1955, Article 5 [to be verified against the current wording]. Valuation of contributions in kind follows the procedure of ΑΕ law (Article 17 of Law 4548/2018). Alternative.

B.1.4 Corporate transformations

  • Provision: Law 4601/2019 (Government Gazette A' 44/9.3.2019).
  • What is required: An experts' report on the draft agreement and the exchange ratio.
  • Who acts: Under the prevailing interpretation, the persons referred to in Article 17 §3 of Law 4548/2018 (sworn auditors or certified valuers) [to be verified against the exact article of Law 4601/2019]. Alternative.
  • Tax incentives: Legislative Decree 1297/1972, Law 2166/1993, Law 4935/2022.

Sources (secondary): https://www.taxheaven.gr/circulars/30472/ · Full text of Law 4601/2019: https://www.taxheaven.gr/law/4601/2019

B.1.5 Real Estate Investment Companies (ΑΕΕΑΠ)

  • Provision: Law 5193/2025 (Government Gazette A' 56/11.4.2025), Part A, Articles 40–64, which recast the framework of Law 2778/1999. Specifically: Article 54 "Valuation," Article 46 (acquisition of real estate/holdings), Article 48 (transactions with related parties).
  • What is required: A valuation of the portfolio by a regular independent valuer (Article 54); for transactions with related parties involving real estate, a prior valuation "in accordance with paragraph 3 of Article 17 of Law 4548/2018" and notification to the Capital Market Commission at least 15 days beforehand (Article 48 §2).
  • Who acts: The law uses the term "independent valuer," not "certified valuer." In practice, ΑΕΕΑΠ companies engage certified valuers. Statutorily alternative, in practice Registry.
  • Valuation frequency: Article 53 provides for a semi-annual statement of investments; the exact frequency of valuation under Article 54 is [to be verified].

B.1.6 Alternative Investment Fund Managers

  • Provision: Law 4209/2013 (AIFMD). Valuation by an external valuer holding professional registration or equivalent guarantees. The Registry is not named. Alternative.

B.2 Enforcement proceedings

B.2.1 Auction of real estate

  • Provisions: Code of Civil Procedure Articles 993 §2 and 995 §1 (attachment of real estate), as shaped by Laws 4335/2015 and 4842/2021. Article 954 §2 concerns the attachment of movables ("the valuation […] made by the bailiff or the expert," with the starting bid at least two-thirds of the valuation) and applies to real estate only by reference.
  • What is required: The attachment report for real estate includes a valuation of the market value at the time of attachment; the starting bid equals the market value and may not be lower than the objective (tax) value.
  • Who acts: The bailiff, who may engage a certified valuer from the Registry, a natural or legal person, who delivers a written valuation within a set deadline. Registry exclusive where an engagement is made; the engagement itself is discretionary.
  • Application to correct the price: Under interim-measures proceedings, inadmissible if filed less than 15 working days before the auction. In practice a substantiated counter-valuation report from a certified valuer is required.
  • Administrative enforcement (ΚΕΔΕ, Legislative Decree 356/1974): applies paragraphs 2–4 of Article 954 of the Code of Civil Procedure by analogy.
  • Article 23 of Law 4549/2018 (price correction after unsuccessful auctions using a newer valuation report) [to be verified for exact wording].

Sources: - Code of Civil Procedure Art. 954: https://www.lawspot.gr/nomothesia/kpold/arthro-954-kodikas-politikis-dikonomias/ - Code of Civil Procedure Arts. 993, 995: https://www.lawspot.gr/nomothesia/kodikas-politikis-dikonomias - Case law (Piraeus Court of Appeal 101/2026, referring to Arts. 954 §2, 992 §2, 993 §2): https://www.efeteio-peir.gr/?p=15384 - Secondary commentary: https://efotopoulou.gr/

B.3 Insolvency and protection of the family home

B.3.1 Out-of-Court Debt Settlement Mechanism

  • Provision: Law 4738/2020 (Government Gazette A' 207/27.10.2020), Book Two, Chapter A, as in force (codified by Law 5313/2026).
  • What is required: Application of the "no worse off" principle for creditors, which requires the liquidation value of the security.
  • Eligibility threshold: An application may be filed once total debts exceed 5,000 euros (Platform User Guide, version 6.0/21.8.2025). There is no statutory threshold of 75,000 euros for the valuation obligation.
  • Who acts: The liquidation value is calculated by the platform from submitted data; a valuation by an independent valuer is provided for in the cases set out by the law and the joint ministerial decisions [to be verified for the exact provision]. Alternative on the letter of the law, Registry in practice.

Sources: - Law 4738/2020: https://www.taxheaven.gr/law/4738/2020 - Out-of-Court Mechanism Platform User Guide (mitos.gov.gr): https://mitos.gov.gr/

B.3.2 Acquisition and Leaseback Entity

  • Provision: Law 4738/2020, Article 218.
  • What is required: Determination of the market value of the ownership right over the primary residence "in accordance with the valuation of a certified valuer, the cost of which is borne by the Entity, which appoints them."
  • Who acts: A certified valuer, appointed by the Entity. Registry exclusive, mandatory.
  • Discount rate on value: [to be verified in the body of the article].

B.3.3 The Katseli Law

  • Provision: Law 3869/2010, Article 9 (for pending cases); Law 4605/2019 (the now-closed platform).
  • Who acts: The law does not name the Registry; courts accept reports from certified valuers as evidence and appoint court experts. Alternative.

B.4 Banking and supervisory framework

B.4.1 Residential mortgage credit

  • Provision: Law 4438/2016 (Government Gazette A' 220/28.11.2016), Article 18 (transposing Article 19 of Directive 2014/17/EU).
  • Verbatim: "The internal and external valuers who carry out property valuations on behalf of credit providers are professionally competent, registered with the Registry of Certified Valuers under Law 4152/2013, and independent of the credit-approval process."
  • Who acts: Registry exclusive, mandatory. The single express statutory provision that makes registration with the Registry a condition for an entire category of private-sector valuations.

B.4.2 Supervisory framework for credit institutions

  • Provisions: Regulation (EU) 575/2013 (CRR), Articles 208 and 229; Bank of Greece Governor's Act 175/29.7.2020 on the valuation of real estate taken as collateral; EBA Guidelines EBA/GL/2020/06.
  • What is required: A valuation by an independent, adequately qualified valuer on origination and at regular intervals thereafter.
  • Who acts: An "independent valuer." Whether Governor's Act 175/2020 expressly requires Registry registration is [to be verified in the body of the Act]. Banks' internal policies impose it. Supervisory, not statutory.

B.4.3 Servicers, funds and securitisations

  • Provisions: Law 5072/2023 (credit servicers, replacing Law 4354/2015); Law 3156/2003 (securitisations); Law 4649/2019 ("Hercules").
  • Who acts: The Registry is not named at the level of statute. Supervisory/contractual, Registry in practice.

B.5 Taxation

B.5.1 Property Taxation Code — Law 5219/2025

  • Provision: Law 5219/2025 (Government Gazette A' 130/18.7.2025), codified by Law 5301/2026 (Government Gazette A' 74/15.5.2026). Notified by AADE Circular Ε.3038/23.7.2025. It unifies transfer tax, inheritance/gift/parental-benefit tax (formerly Law 2961/2001), and the Single Property Tax (formerly Law 4223/2013, ΕΝΦΙΑ).
  • Within the Objective Value system (Art. 4): The taxable value is determined objectively. No valuer is required.
  • Outside the Objective Value system (Art. 3, "Determination of the market value of real estate outside the ΑΠΑΑ system"): The market value is determined by the Tax Administration on the basis of comparable data. The deadline for the provisional determination (five working days) is [to be verified in the body of the article].
  • Mixed system (Art. 5).
  • Article 112, "Calculation of transfer registration fees and valuation by a certified valuer" — verbatim:

§1: "In these cases, the value of the transferred property is determined on the basis of a special valuation report of the Tax Administration, issued following an application by the head of the land registry office."

§2: "The Tax Administration may request a valuation of the market value from a Valuer of the Registry of Certified Valuers for the following assets, provided they are the subject of taxation: a) real estate and rights in rem over it falling under Articles 3 and 5, b) shares of companies not listed on the Stock Exchange […], and c) other movable property of significant value, works of art, or collections of valuable items […] under Article 63."

§3: "Certified valuers may also act following an application by the taxpayer or a preliminary court decision. The certified valuer's finding has the status of an expert report. If the taxpayer who requested the valuation […] files a return […] at the value determined by the valuer […] they are deemed to have fully accepted the valuation report and are exempt from interest and penalties for inaccuracy […]."

  • Who acts and character: A valuation by a certified valuer is discretionary ("may"), on the initiative of the Tax Administration, the taxpayer, or the court. There is no provision for a lottery draw. It applies to real estate under Articles 3 and 5, not to property wholly within the Objective Value system. When the taxpayer requests the valuation and declares its value, they are exempt from interest and penalties for inaccuracy — this is the practical incentive. Statutory, Registry exclusive once triggered, discretionary.
  • Digital tools: myPROPERTY; the valuemaps.gov.gr geoportal (Article 124 of Law 5162/2024).

Sources: - Article 112 of Law 5219/2025: https://www.taxheaven.gr/law/5219/2025/arthro/112 - Law 5219/2025 in full: https://www.taxheaven.gr/law/5219/2025 · Government Gazette A' 130/2025: https://www.dsanet.gr/Epikairothta/Nomothesia/130A.pdf - AADE Circular Ε.3038/2025: https://www.aade.gr/egkyklioi-kai-apofaseis/o-3038-23-7-2025 - Law 5162/2024, Article 124: https://www.taxheaven.gr/law/5162/2024

B.5.2 Zone values

  • Provision: Article 41 §1Β of Law 1249/1982, as replaced by Article 61 of Law 4587/2018 and amended by Article 51 of Law 4646/2019.
  • What is required: Preparation of recommendations for setting the starting values of the Objective Value system.
  • Who acts: Certified valuers of the Registry in the field of real estate, selected through a Public Call by the Ministry, acting as expert rapporteurs to the First-Instance Committee of each Regional Unit. Registry exclusive, mandatory.

B.5.3 Acquisition presumptions — Council of State decision 2086/2025

  • Provisions: Article 32 of Law 4172/2013 (Income Tax Code); Article 28Α of the Income Tax Code.
  • Case law: Council of State decision 2086/2025 held, in a case involving the purchase of a property for a price of 56,000 euros against an objective value of 331,403 euros, that the taxpayer may rebut the acquisition presumption by proving the actual price paid, without first having to challenge the objective value under Article 41 §6 of Law 1249/1982.
  • Who acts: No mandatory valuation. A certified valuer's report is, in practice, the strongest form of evidence before the Dispute Resolution Directorate (ΔΕΔ) and the administrative courts. Discretionary.

B.5.4 Single Property Tax (ΕΝΦΙΑ) and inheritance/gift/parental-benefit tax

  • Provision: Law 5219/2025 (formerly Law 4223/2013 and Law 2961/2001); administrative appeal under Article 63 of the Tax Procedure Code (Law 5104/2024).
  • What is required: Objective determination within the Objective Value system; Article 3 outside the Objective Value system. The discretionary mechanism of Article 112 applies. A valuer's or engineer's report may serve as evidence in a dispute. Discretionary.

B.6 Inheritance law

B.6.1 Acceptance of an inheritance with the benefit of inventory

  • Provisions: Civil Code Arts. 1902–1912; Code of Civil Procedure Arts. 838 et seq. (non-contentious proceedings).
  • What is required: A declaration accepting the inheritance with the benefit of inventory, filed with the registry of the probate court (Civil Code Art. 1902), and preparation of the inventory within four months (Civil Code Art. 1903), with a possible extension; failure results in loss of the benefit (Civil Code Art. 1911). The deadline where the heir resides abroad is [to be verified].
  • Who prepares and who values (Code of Civil Procedure Art. 838): The inventory is drawn up by a notary appointed by decision of the Justice of the Peace, who also appoints two experts to value the inventoried items. If the parties jointly propose a notary and experts, those persons are appointed, unless serious reasons dictate otherwise.
  • Who acts: A notary and court-appointed experts. The law does not require a certified valuer from the Registry. The Justice of the Peace may appoint a certified valuer as an expert — a possibility, not an obligation.
  • Practical note: An heir accepting with the benefit of inventory has an interest in requesting the appointment of a certified valuer as expert, so that the valuation can withstand challenge by creditors. The tax return for the inheritance (see B.5.4) is a separate procedure.

B.6.2 Liquidation, vacant estates, forced heirship, and partition

  • Provisions: Civil Code Arts. 1913 et seq. (liquidation); Civil Code Arts. 1865 et seq. (vacant estate); Law 4182/2013 (escheat to the State); Civil Code Arts. 1825 et seq. (forced heirship); Code of Civil Procedure Arts. 478 et seq. (partition).
  • Who acts: A court-appointed expert under Code of Civil Procedure Art. 368 et seq., or private reports from certified valuers used as opinions. An express reference to a certified valuer in Law 4182/2013 is [to be verified]. Alternative, discretionary.
  • Practical note: For the forced heirship share, the valuation date is the date of death — a retrospective valuation with an express statement of the date of value.

B.7 Family law

  • Provision: Civil Code Art. 1400 (claim to a share in acquired assets).
  • Who acts: A court-appointed expert or private reports. Alternative, discretionary.

B.8 Expropriation and planning law

B.8.1 Compulsory expropriation

  • Provision: Law 2882/2001 (Government Gazette A' 17/6.2.2001), Article 15, as in force.
  • Wording (per secondary citation): for determining compensation, "the Committee of paragraph 1 of Article 15, or an Independent Certified Valuer at the discretion of the competent body, gives an opinion within two months of the file being forwarded."
  • Who acts: A committee or an independent certified valuer, at the body's discretion. Alternative. The valuation does not bind the court in the provisional and final determination of compensation (Arts. 19–21).
  • Practical note: The Constitution (Art. 17) requires full compensation. The affected party has an interest in submitting their own report.

B.8.2 Other planning and forestry provisions

  • Provisions: Law 1337/1983, Article 9 (contribution in cash); Laws 4495/2017 and 4759/2020 (land-use adjustment schemes, Land Bank); Law 5148/2024; Law 2971/2001 (foreshore); Laws 998/1979, 4280/2014 and 5058/2023 (forest land).
  • Who acts: An express reference to a certified valuer in each individual provision is [to be verified]. Historically, committees and the Public Property Directorate.

B.9 Public property and local government

B.9.1 Municipal real estate

  • Provision: Law 3463/2006 (Government Gazette A' 114/8.6.2006), Article 186 §5.
  • What is required: A valuation of the price before a municipality sells, exchanges, or purchases a property.
  • Who acts: The Committee under Article 186 §5, made up of two municipal councillors and one municipal engineer, as follows from each municipality's constitution decisions. A certified valuer is not, as a rule, required. The committee under Article 7 of Presidential Decree 270/1981 concerns the conduct of auctions, not valuation. Amendments under Laws 4555/2018 and 5056/2023, and the corresponding arrangement for Regions (Law 3852/2010), are [to be verified].
  • Practical note: For properties of significant value, municipalities frequently also request a certified valuer's report, so that the decision withstands legality review.

Sources: - Law 3463/2006 (codified): https://www.kodiko.gr/nomothesia/document/43235/nomos-3463-2006 - Constitution of the Article 186 §5 Committee (example, Municipality of Ilion, 2026): https://www.ilion.gr/ads070-2026/

B.9.2 Buyout of State-occupied real estate

  • Provision: Law 5024/2023 (Government Gazette A' 41/24.2.2023), Articles 6–8, as amended by Law 5113/2024.
  • What is required: The buyout price is based on the objective (tax) value with discounts based on economic and social criteria (Article 7); special cases of disputed ownership (Article 8).
  • Who acts: No certified valuer is expressly required.

B.9.3 Development of public assets, State leases, public-law legal entities

  • Provisions: Law 3986/2011 (TAIPED, the Hellenic Republic Asset Development Fund); Law 4389/2016 (the Superfund); Law 3130/2003 (State leases); Presidential Decree 715/1979 (ΝΠΔΔ); Law 4182/2013.
  • Who acts: Independent valuers, committees, or the Public Property Directorate, depending on the case; an express reference to the Registry is [to be verified per provision]. Alternative.

B.10 Investment law

  • Provisions: Law 4887/2022, Law 4399/2016, Law 4864/2021, ESPA.
  • Who acts: A certified valuer, under the applicable implementation guides [to be verified per programme]. Regulatory, not a formal statutory provision.

B.11 Immigration law

B.11.1 Investor residence permit (Golden Visa)

  • Provision: Law 5038/2023, Article 100, as amended by Article 64 of Law 5100/2024; Joint Ministerial Decision 95391/20.3.2024 (supporting documents, under the authorisation of Article 176 §1 of Law 5038/2023).
  • Thresholds: 800,000 euros in Attica, the Regional Unit of Thessaloniki, Mykonos, Santorini, and islands with more than 3,100 residents; 400,000 euros in the rest of the country; 250,000 euros for a change of use or restoration of a listed building.
  • What is required: A notarial deed, payment through the banking system, and, in special cases, an engineer's certificate.
  • Who acts: A notary, a bank, an engineer. No certified valuer's report is required. A valuation is only indirectly involved if the investment is made through a contribution of real estate to a company (Article 17 of Law 4548/2018).

B.11.2 Border areas

  • Provision: Law 1892/1990, Articles 24–26; Joint Ministerial Decision Φ.114/497810/2023 (Government Gazette B' 1893/26.3.2024).
  • What is required: Lifting of the restriction by decision of the Decentralised Administration's Committee, for persons from outside the EU/EFTA.
  • Who acts: The Committee, applying national-security criteria. A valuation by a certified valuer as a condition is not found in the provisions [subject to final verification in the body of the Joint Ministerial Decision].

B.12 Anti-money laundering (AML)

  • Provision: Law 4557/2018, as in force.
  • What is required: Due diligence, enhanced for high-risk transactions. The law does not impose a property valuation; banks request one in practice to release incoming wire transfers. Supervisory/practice-based.

B.13 Accounting standards

  • Provisions: Law 4308/2014 (Greek Accounting Standards, ΕΛΠ); IFRS 13, IAS 16, IAS 40; Law 2065/1992 (revaluation using statutory coefficients).
  • Who acts: No accounting standard legally requires a certified valuer from the Registry. Sworn auditors, under ISA 620, require in practice a certified valuer's report for significant properties. Audit practice.

PART C — Differences based on nationality and tax residence

Statutory valuation obligations attach to the type of transaction or proceeding, not to nationality or tax residence.

Category What differs Is a Registry valuation required?
Greek and EU/EFTA nationals No special obligation Only what applies to everyone (Part B)
Third-country nationals Golden Visa (thresholds, engineer's certificate); border areas (Committee) Not by statute; only indirectly, through a contribution of property to a company
Greek tax residents Acquisition presumption (Income Tax Code Art. 32) No; a discretionary form of evidence (Council of State 2086/2025)
Non-resident taxpayers Conditional exemption from the presumption; enhanced AML due diligence Not by statute; banks request a report in practice

PART D — Summary reference table

Case Provision Registry Mandatory/Discretionary Statutory/Supervisory
Residential mortgage to a consumer Law 4438/2016 Art. 18 Exclusive Mandatory Statutory
Zone values (recommendations) Law 1249/1982 Art. 41 §1Β Exclusive Mandatory Statutory
Acquisition and Leaseback Entity Law 4738/2020 Art. 218 Exclusive Mandatory Statutory
Property tax, real estate outside/mixed ΑΠΑΑ Law 5219/2025 Art. 112 Exclusive once triggered Discretionary Statutory
Real estate auction Code of Civil Procedure Arts. 993 §2, 995 Exclusive when engaged Engagement discretionary Statutory
Expropriation Law 2882/2001 Art. 15 Alternative (or Committee) Mandatory, not binding on the court Statutory
Contribution in kind to ΑΕ Law 4548/2018 Art. 17 Alternative (or sworn auditors) Mandatory Statutory
Contribution in kind to ΙΚΕ above €5,000 Law 4072/2012 Art. 77 Alternative Mandatory Statutory
Corporate transformations Law 4601/2019 Alternative Mandatory Statutory
ΑΕΕΑΠ Law 5193/2025 Arts. 46, 48, 54 "Independent valuer" Mandatory Statutory
Out-of-Court Mechanism Law 4738/2020 Alternative Case-by-case Statutory
Inheritance inventory Code of Civil Procedure Art. 838 No (court experts) Valuation mandatory, valuer's status discretionary Statutory
Forced heirship, partition, Civil Code Art. 1400 Code of Civil Procedure Art. 368 et seq. No Discretionary Statutory
Business loans CRR Arts. 208/229, Governor's Act 175/2020 In practice Mandatory (supervisory) Supervisory
Servicers, securitisations Law 5072/2023, Law 3156/2003 In practice Contractual Supervisory/contractual
Municipal real estate Law 3463/2006 Art. 186 §5 No (Committee) Valuation mandatory Statutory
Buyout of State-occupied real estate Law 5024/2023 Arts. 6–8 No (objective value) Statutory
Golden Visa Law 5038/2023 Art. 100 No (engineer) Discretionary Statutory
Border areas Law 1892/1990 No Discretionary Statutory
AML Law 4557/2018 No Discretionary Supervisory/practice
Fair value under Greek GAAP/IFRS Law 4308/2014, IFRS 13 No Discretionary Audit practice

PART E — Practical points for the professional

Common misconceptions

  1. "A transfer outside the Objective Value system requires a valuation by a certified valuer." No. The Tax Administration determines the value (Article 3). The valuation under Article 112 is discretionary — but whoever requests it and declares that value is exempt from interest and penalties for inaccuracy.
  2. "An inheritance inventory requires a certified valuer." No. It requires a notary and two experts appointed by the Justice of the Peace.
  3. "The Golden Visa requires a valuation report." No. It requires a notarial deed, payment through the banking system, and, in special cases, an engineer's certificate.
  4. "ΑΕΕΑΠ companies are required to use a certified valuer." The law says "independent valuer." In practice this means the Registry.
  5. "Every bank valuation is a statutory requirement." Only for residential mortgages to consumers. For the rest, the obligation is supervisory.
  6. "Municipalities need a certified valuer for every sale." The law provides for the Committee under Article 186 §5.

What a broker or notary should ask the client for

  • The purpose of the valuation, which determines the basis of value and the intended recipient.
  • The date of value (current or retrospective).
  • Title deeds, a land registry extract, building permits, any regularisations, an energy performance certificate, leases, and encumbrances.
  • Who will receive the report.

When a valuation is advisable even though not mandatory

  • A purchase at a price noticeably below the objective (tax) value (the presumption, Council of State 2086/2025).
  • A transfer outside the Objective Value system, to activate the exemption under Article 112 §3.
  • An incoming wire transfer from abroad (AML).
  • A Golden Visa investment close to the threshold.
  • Acceptance of an inheritance with the benefit of inventory where creditors exist.
  • Partition or divorce, before trial.
  • A property of a municipality or public-law legal entity of significant value.

AVMs and ESG

Automated valuation models give a quick indication of value, but no provision in Part B accepts them as equivalent to a report: they are not signed by a person bearing liability, they do not include a site inspection, and they are not subject to disciplinary review. ESG criteria are incorporated into valuations through EVS 2025 and banking practice, without a Greek provision imposing a specific methodology.


PART F — Consolidated list of sources

Primary (Government Gazette, codified texts, official websites)

Provision Source
Law 4152/2013 sub-paras. Γ.2, Γ.10 https://www.lawspot.gr/nomothesia/n-4152-2013/arthro-proto-par-g2-nomos-4152-2013-eggrafi-sto-mitroo/ · https://www.lawspot.gr/nomothesia/n-4152-2013/arthro-proto-par-g10-nomos-4152-2013-exoysies/
Registry of Certified Valuers https://minfin.gov.gr/e-ypiresies/mitroo-pistopoiimenon-ektimiton/ · https://www1.gsis.gr/gspp/dhpe/valuers/
Ministerial Decision 19928/292/2013 (Code of Conduct) https://www.lawspot.gr/nomothesia/ypoyrgiki-apofasi-19928-292/
Law 5162/2024 Arts. 124–125 https://www.taxheaven.gr/law/5162/2024
Ministerial Decision 36259 ΕΞ 2025 https://www.kodiko.gr/nomothesia/document/1123999/yp.-apofasi-36259-eks-2025-2025
Law 4548/2018 Arts. 17–18 https://www.taxheaven.gr/law/4548/2018/arthro/17
Law 4072/2012 Art. 77 https://www.lawspot.gr/nomothesia/n-4072-2012/arthro-77-nomos-4072-2012-kefalaiakes-eisfores/
Law 4601/2019 https://www.taxheaven.gr/law/4601/2019
Law 5193/2025 (ΑΕΕΑΠ) https://www.taxheaven.gr/law/5193/2025
Law 2778/1999 https://www.taxheaven.gr/law/2778/1999
Code of Civil Procedure Arts. 954, 993, 995, 838 https://www.lawspot.gr/nomothesia/kpold/arthro-954-kodikas-politikis-dikonomias/ · https://www.lawspot.gr/node/25720
Law 4738/2020 (Art. 218, Out-of-Court Mechanism) https://www.taxheaven.gr/law/4738/2020 · http://www.keyd.gov.gr/ryumish-ofeilvn-foreas-apokthshs/
Law 4438/2016 Art. 18 https://www.lawspot.gr/nomikes-plirofories/nomothesia/n-4438-2016/arthro-18-nomos-4438-2016-ektimisi-tis-axias-toy-akinitoy
Bank of Greece Governor's Act 175/29.7.2020 https://www.bankofgreece.gr/RelatedDocuments/ΠΕΕ175-Θέμα2ΑΝΑΡΤΗΣΗ.pdf
Law 5219/2025 (Arts. 3, 112) https://www.taxheaven.gr/law/5219/2025/arthro/112 · https://www.dsanet.gr/Epikairothta/Nomothesia/130A.pdf
AADE Circular Ε.3038/2025 https://www.aade.gr/egkyklioi-kai-apofaseis/o-3038-23-7-2025
Zone values, Public Call https://minfin.gov.gr/anathesi-se-pistopoiimenous-ektimites-engegrammenous-sto-mitroo-pistopoiimenon-ektimiton-sto-pedio-ton-akiniton-tou-ypourgeiou-ethnikis-oikonomias-kai-oikonomikon-tis-syntaxis-eisigisis-gia-ton-kath-2/
Council of State decision 2086/2025 https://www.taxheaven.gr/circulars/51836/ste-2086-2025
Law 2882/2001 https://www.e-nomothesia.gr/index.php/n-2882-2001.html
Law 3463/2006 Art. 186 https://www.kodiko.gr/nomothesia/document/43235/nomos-3463-2006
Law 5024/2023 https://www.taxheaven.gr/law/5024/2023
Law 5038/2023 / Joint Ministerial Decision 95391/2024 (Golden Visa) https://migration.gov.gr/golden-visa/ · https://www.taxheaven.gr/news/72076/
Joint Ministerial Decision Φ.114/497810/2023 (border areas) https://www.e-nomothesia.gr/kat-oikonomia/kya-ph114-497810-2023.html
Law 4557/2018 / National Risk Assessment Report https://www.taxheaven.gr/law/4557/2018 · https://minfin.gov.gr/wp-content/uploads/2023/12/Έκθεση-Εκτίμησης-Κινδύνου.pdf
CRR 575/2013 https://eur-lex.europa.eu/legal-content/EL/TXT/?uri=CELEX:32013R0575
EVS (Greek edition) https://avag.gr/

Secondary (commentary, law firms, news outlets — supplementary)


This guide reflects the framework as of the reference date. Real estate legislation changes frequently; the current validity of each provision should be checked before every transaction. Points flagged [to be verified] require reading the original Government Gazette text before publication elsewhere.

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