Up to 75% Aid: The “Large Investments” Regime of Development Law N.4887/22 Announced with a total budget of €150 million

Introduction

The “Large Investments” Regime aims to support large-scale investment projects focusing on critical sectors of the Greek economy. Its purpose is to significantly boost development and create multiplier benefits for local economies through the implementation of high value-added projects.

The budget for the Regime in 2025 amounts to a total of €150,000,000, allocated as follows:

• €75,000,000 for tax exemptions
  This concerns investment projects opting for support through tax exemption, offering significant incentives to reduce the tax burden on investors.
• €75,000,000 for direct financial aids, which include:
  • Capital grants
  • Subsidies for financial leasing
  • Subsidies for new employment costs

The direct aids are funded through the Public Investment Budget (PIB) of the Ministry of Development.

Eligible Beneficiaries & Participation Requirements

The beneficiaries of the incentives provided under the “Large Investments” Regime are the entities of investment projects that:

• Have, or are about to establish, business activity within the Greek territory at the time their investment project’s operations commence.
• Operate or will operate under one of the following legal forms:
  • Commercial companies (such as S.A., Ltd., Private Companies, General Partnerships, Limited Partnerships),
  • Cooperatives,
  • Special forms of cooperative entities such as Social Cooperative Enterprises (SCEs), Agricultural Cooperatives, Producer Groups, Urban Cooperatives, Agricultural Partnerships,
  • Companies under merger, provided they complete the necessary publicity procedures before the start of investment works,
  • Joint ventures conducting commercial activity,
  • Public and municipal enterprises, as well as their subsidiaries, under the following strict conditions:
    • They have not undertaken the execution of a public purpose,
    • They have not received exclusive state assignment for providing specific services,
    • Their operation is not subsidized by public resources during the compliance with the long-term obligations, according to Article 25 of the law.

Non-Eligible Enterprises (Exclusions)
The following categories of enterprises are explicitly excluded from eligibility under the Regime:

• Enterprises under state aid recovery procedures according to previous European Commission decisions (Deggendorf principle) at the time of application.
• Problematic enterprises, according to paragraph 18 of Article 2 of the General Block Exemption Regulation (GBER), assessed both at the applying company level and at the group level.
• Enterprises that have relocated or refuse to commit that they will not relocate the business establishment where the initial investment is to be implemented:
  • If the relocation took place within two (2) years before the application submission, or
  • If they refuse to commit that they will not transfer the establishment to another EU member state for at least two (2) years after investment completion.
• Enterprises implementing investment projects on behalf of the public sector resulting from project execution, concession, or service provision contracts.

Types of Investment Projects Funded:

1. Establishment of a new productive unit.
2. Expansion of production capacity of an existing installation (unit).
3. Diversification of the production of an existing installation into new products or services never before produced or provided, provided the subsidized expenses exceed by at least 200% the book value of reused assets recorded in the tax year prior to the application.
4. Fundamental change of the overall production process of an existing unit, where for large enterprises the subsidized investment expenses must exceed the depreciation of the last three tax years of the assets related to the activity being modernized. If such depreciation is not clearly reflected, the condition is deemed unmet. Furthermore, replacement investments and acquisition of shares in another enterprise are not considered initial investments.

Fundamental Participation Requirement for Potential Beneficiaries – Incentive Character

The state aid provided under the “Large Investments” Regime strictly functions as an incentive, in accordance with current national and European regulatory frameworks. The subsidies are granted exclusively for investment activities that would not occur without the existence of this incentive.

The core prerequisite for maintaining the incentive status is the submission of a written application for inclusion in the Regime before the commencement of any work related to the investment project.
Any start of works prior to submitting the application:

• Automatically leads to rejection of the application, or
• If an approval decision has already been issued, it triggers its withdrawal regardless of the investment’s implementation stage, within the monitoring timeframe defined after project completion.

Definition of “Start of Works”
According to the General Block Exemption Regulation (GBER, Article 2, point 23), the “start of works” means:

• For construction investments:
  The earlier of either the physical start of construction activities

 or

the first legally binding commitment to order equipment or any other expense that makes the investment irreversible.

The following do not count as start of works:

• Land acquisition.
• Preparatory actions such as obtaining permits or conducting feasibility studies.

• For acquisition investments:
  The start of works is considered the date of acquisition of the assets directly related to the purchased installation.

Project Budget, Amount and Intensity of Aid

Under the present regime, investment projects eligible must concern investments with a total budget of eligible expenses exceeding €15.000.000.

The aid amount cannot exceed €20.000.000, unless a lower threshold applies according to paragraph 1 of article 4 of the General Block Exemption Regulation (GBER).

Total aid per entity and cooperating enterprises:

• For a single enterprise, the limit is €20.000.000.
• For the entirety of cooperating or affiliated enterprises, the limit rises to €50.000.000.

Within this aid regime, specific restrictions apply concerning the timeframe and maximum aid amounts per investment project. Initially, these restrictions relate to investment projects within three years from the date of submission of the inclusion application. This means the total aid amount received by an investor must comply with the limits within three years.

The aid amount taken into account is the one approved by the inclusion decision. If the total aid amount exceeds the established limits, the excess is proportionally reduced by type of aid and category of expenses. There is the possibility of increasing these limits by 50% when aid is provided as a tax exemption, i.e., exemption from paying income tax. However, this increase always remains subject to the general restrictions preventing exceeding the limits.

Additionally, for eligible expenses outside regional aid, the maximum aid per investment project cannot exceed €1.000.000. An exception applies to expenses concerning Small and Medium Enterprises (SMEs), for which this limit specifically ensures clear financing boundaries.

The aid percentages for eligible expenses are determined based on the maximum thresholds provided by the Regional Aid Map, as outlined below:

Aid intensities are structured based on the size of the enterprise and the region where the investment takes place. The primary distinction is as follows:
 
Aid Limit per Investment Project:
The maximum aid amount that can be granted to a single investment project does not exceed €20.000.000, unless stricter limits apply under the General Block Exemption Regulation (GBER).
 
Conditions and Restrictions:

• Increased intensities for SMEs do not apply to investment projects with expenses exceeding €50.000.000.
• In certain areas designated by the European Union, aid may be granted regardless of enterprise size for any initial investment.
• For large enterprises in restricted areas, aid applies only to new economic activities.

• Very large investment projects (above €50.000.000) follow a tiered aid calculation: 100% intensity for the first €55.000.000 of expenses, 50% for the segment up to €110.000.000, and zero for any amount beyond that.

Types of Aid
The following types of aid-incentives are provided for investment projects falling under this scheme, designed to effectively support the development and sustainability of investments:

• Tax exemption: Exempts from paying income tax on the pre-tax profits of the company, according to the applicable tax legislation, except for the tax corresponding to profits distributed or assumed by partners. The exemption amount is calculated as a percentage of the value of the eligible expenses of the investment project or the value of new machinery and other equipment acquired through financial leasing, which is recorded as an equivalent reserve in a separate account in the financial statements.
• Grant: Provision by the State of a cash amount to cover part of the eligible expenses, calculated as a percentage thereof.
• Financial leasing subsidy: Coverage by the State of part of the financial leasing installments contracted for the acquisition of new machinery and other equipment. The subsidy is calculated as a percentage of the acquisition value, included in the paid installments, and lasts up to seven (7) years, starting from the date of project completion.
• Employment cost subsidy: Coverage by the State of part of the wage costs for new jobs created and linked to the investment project, provided that no other state aid is received for these positions.

Investment projects belonging to specific aid schemes are excluded, specifically: in the agri-food sector (primary production, processing of agricultural products, and fisheries, Articles 65-71), tourism investments (Articles 84-90), and alternative forms of tourism (Articles 91-97) of Law 4887/2022.
 
Fast-Track Licensing Incentive
Within the framework of the scheme, a special fast-track licensing procedure is provided for investments subject to the aid scheme.
 
After the investor submits a complete file to the General Directorate of Development Laws and Direct Foreign Investments, all required permits and approvals (including environmental and spatial planning) must be issued within two (2) months. If any documents are missing, the administration may request additional information, “freezing” the deadline until their submission.
 
The process proceeds with absolute priority, and if the deadline is exceeded, the responsibility transfers to the Minister of Development, who must decide within one (1) month. The General Secretariat of Private Investments is also considered a competent licensing authority.
 
This fast-track licensing procedure is designed to drastically reduce waiting times for permit issuance, limit bureaucratic uncertainty, and strengthen investment confidence. It creates a more predictable and investor-friendly administrative environment, with clear deadlines, institutional accountability, and specific intervention mechanisms in case of delays. The strategic goal is the immediate start of investment project implementation, without unjustified administrative obstacles, thus enhancing the overall attractiveness of the country as an investment destination.
 
Basic Categories of Eligible Expenses
 
Eligible Expenses for Regional Aid
Expenses eligible for regional aid within investment projects are defined as follows:
 
Firstly, eligible are investment expenses in tangible fixed assets, which include:

• The construction, expansion, and modernization of building facilities, as well as auxiliary spaces. Special provisions exist for constructions ensuring accessibility for people with disabilities or reduced mobility, as well as for landscaping of the surrounding area. However, these expenses cannot exceed 45% of the total eligible expenses at the regional aid level. It is noted that for certain activities, such as logistics services (code 52.29.19.03), this percentage rises to 70%, while for investments in preserved buildings it may reach up to 80%. Additionally, constructions legalized under the relevant articles of laws 1337/1983, 4178/2013, and 4495/2017 are subsidized.
• The purchase of part or all of existing fixed assets, such as buildings, machinery, and other equipment, under the conditions that the business has ceased operation, the purchase is made from an unrelated party (except for small businesses acquired by employees or family members of the previous owner), and the transaction occurs under normal market conditions. Importantly, assets already financed under development laws or other schemes before purchase are not subsidized.
• The purchase and installation of new modern machinery and other equipment, including technical installations and transportation means moving within the unit.
• Leasing rents of new machinery and equipment, on condition that ownership of the equipment transfers to the lessee at the end of the contract.
• The modernization of special installations (non-building) and mechanical installations.

Secondly, eligible are investment expenses in intangible assets, which include:
 

• Technology transfer through the purchase of intellectual property rights, exploitation licenses, patents, know-how, and unpatented technical knowledge.
• Quality assurance systems, certifications, as well as the supply and installation of software and business organization systems.

To be eligible, these expenses must cumulatively meet the following conditions:

• They must be used exclusively at the funded business establishment,
• Remain connected to the investment project for the duration of long-term obligations,
• Be depreciated according to applicable accounting rules, and
• Be purchased from independent third parties with no familial or related ties to the buyer.
• Additionally, for large enterprises, the maximum percentage of intangible asset expenses is capped at 30% of the total eligible cost, while for SMEs it is 50%.

 
Thirdly, eligible expenses include the wage costs of new jobs created as a result of the investment, calculated for two (2) years from the creation of each job. Wage costs are eligible expenses only independently, not combined with other investment expenses.
 
Conditions for wage costs include that the investment must result in a net increase in the number of employees, recorded in Annual Work Units (AWUs) at the business establishment, relative to the average of the previous twelve months before the application. Positions must be filled within three (3) years from investment completion, and each job must be maintained for at least five (5) years in large, four (4) years in medium, and three (3) years in small enterprises.
 
Eligible Expenses Outside Regional Aid
Within the framework of investment projects subject to this scheme, there is the possibility of additional support beyond regional aid for specific categories of eligible expenses, as defined in Article 6 of Law 4887/2022 and the General Block Exemption Regulation (GBER).


The eligible expenses concern the following categories:

• Consulting Services for Small and Medium-sized Enterprises (SMEs): Studies and fees of external consultants related to investment projects of new SMEs (enterprises with a management period of less than 12 months at the time of application submission) are supported. Expenses for routine operational consulting, such as tax or legal services, are not covered.
• Energy Efficiency Measures: Eligible are the additional investment expenses aiming to achieve a higher level of energy efficiency, except for measures in buildings governed by Article 38 of the GBER. Only investments exceeding the applicable Union standards or complying before these standards come into effect are supported.
• High-Efficiency Cogeneration from Renewable Energy Sources (RES): Investments in newly installed or renovated production capacity are subsidized with aid limits up to 45% for renewable energy sources and up to 30% for other related investments.
• Installation of Efficient District Heating/Cooling Systems: Investment expenses related to the construction or upgrade of energy-efficient systems are supported in accordance with Directive 2012/27/EU.
• Environmental Damage Remediation and Habitat Restoration: Eligible are the costs of remediation and restoration work, reduced by the increase in land or property value. Damages from natural phenomena or cessation of industrial unit operation are not covered.
• Efficient Use of Resources and Support for the Circular Economy: Additional investment expenses aimed at improving resource efficiency compared to less environmentally friendly alternatives are subsidized.
• Professional Training of Employees: Eligible expenses include salaries of trainers and trainees, operating costs, materials, and consulting services, aiming at upgrading or retraining personnel. Mandatory training required by law is excluded.
• Participation of SMEs in Trade Fairs: Expenses for renting, installing, and managing booths at trade fairs are supported.
• Hiring Employees in Disadvantaged Positions and with Disabilities: Eligible are salary expenses for up to 12 months (or up to 24 months in particularly disadvantaged cases) under specific conditions of a net increase in the number of employees.
• Research and Development Projects: Expenses for personnel, materials, equipment, and other related categories for basic research, industrial research, experimental development, and feasibility studies are supported.

Non-Eligible Expenses

• Operating Expenses: Expenses related to the operation of the investment, such as payroll, rents, utility bills, and other operational needs, are not funded.
• Purchase of Furniture and Office Equipment: Funding for office furniture and utensils is excluded unless they constitute an integral and necessary part of the investment’s productive equipment.
• Purchase of Passenger Cars: The purchase of passenger cars with up to six (6) seats is not considered an eligible expense.
• Purchase of Plots, Land, and Agricultural Parcels: Expenses for land acquisition are not subsidized. In cases of acquiring building facilities, the value of the plot on which these are erected is not covered.
• Contributions to Share Capital in Kind: Contributions to share capital concerning real estate, machinery, or other fixed assets are not subsidized.
• Construction or Expansion of Building Facilities on Non-Owned Land: Construction or expansion of building facilities on land not owned by the investment entity is not considered eligible unless:
  • The land has been granted by the State or a General Government body, or
  • It has been legally leased from a public or private entity, with the lease registered or transcribed according to the procedures of the Independent Authority for Public Revenue (AADE) and the Land Registry, ensuring the right of use for at least the duration of the long-term obligations of the investment plus four (4) years.

 
Scoring Criteria
The scoring criteria for the “Processing – Supply Chain” scheme (Law 4887/2022) are divided into four scoring groups, as detailed below:
 
Group A: Evaluation of the Investment Project’s Readiness (score 0-45)
Factors demonstrating the investment’s readiness for implementation are examined, such as:

• Availability of the installation site.
• Submission of applications for environmental permits, building permits, requests for building permit revisions, requests for installation permits.
• Priority is given to organized hosting sites.
• Next come designated areas without full permits.
• Finally, installations outside these areas receive lower scores.

 
Group B: Evaluation of the Financial Data of the Entity (score 0-25)
The evaluation varies depending on whether the entity is existing or new:

• For existing entities, financial ratios are calculated based on the average of financial figures recorded in the financial statements of the two (2) most recent closed fiscal years prior to the application for inclusion.
• For new entities, the evaluation is based on the financial figures of their shareholders/partners from the two most recent closed fiscal years, as follows:
  • Shareholders/Partners as Legal Entities: If they hold more than 25% participation in the investment entity, the financial figures of the companies they participate in for the last two years are cumulatively considered.
  • Shareholders/Partners as Individuals with stakes in other companies: If they hold over 25% participation in the investment entity and over 25% in other companies, the financial figures of those companies are also cumulatively considered.
  • Shareholders/Partners as Individuals exercising Management: If they hold over 25% participation in the investment entity, do not hold over 25% in other companies, but have exercised executive management (e.g., CEO, Executive Chairman) in other companies for at least 6 months per year, the financial figures of those companies are included.

 
Group C: Evaluation of Sustainable Development Elements (score 0-15)
The score for Group C is based on two main criteria:

• STEP Seal Index: Evaluation of the existence of certifications related to environmental management, social responsibility, and sustainable development.
• Extroversion Index: Calculated as the average export percentage of the business based on the two most recent closed fiscal years prior to the application for inclusion. The higher the export percentage, the higher the score.

 
Group D: Evaluation of Employment Increase (score 0-15)
The score in this group is derived from the number of new dependent employment positions expected to be created by the investment project, relative to the total eligible investment cost (calculated in thousands of euros).


The more jobs created relative to the amount spent, the higher the score.
 
Period, Submission Method, and Implementation Duration of Investment Projects
The submission period for applications to include investment projects under this scheme begins on July 1, 2025, and ends on September 10, 2025. Applications are submitted through the Development Laws Information System and are filed with the following competent authorities:
For all other investment projects, submission is made to the Directorate General of Development Laws and Foreign Direct Investments of the General Secretariat for Private Investments of the Ministry of Development.
 
For more information regarding the new support scheme – Large Investments of the updated Development Law 4887/2022 and the planning of your investment projects, you may contact us at the phone numbers 231 0 552000 & 210 9580000 or via email at [email protected].