New Framework for Fines and Penalties Regarding Registration with Commercial Registry (GEMI)
New Penalty Framework for S.A., Ltd., P.C., and Foreign Company Branches in Greece
Joint Ministerial Decision 46982/2025 introduces a clearly defined framework of administrative penalties for violations related to the General Commercial Registry (GEMI), pursuant to Article 50 of Law 4919/2022. These penalties directly concern Société Anonyme (S.A.), Limited Liability Companies (Ltd.), Private Companies (P.C.), and foreign companies with branches in Greece, provided they fail to comply with their registration and publicity obligations under GEMI.
Key violations subject to administrative sanctions include the omission to publish acts and information required under Articles 30, 33, 34, 35, 39, and 43 of Law 4919/2022, and the failure to timely register annual financial statements. The penalty amount depends on the size of the company, as defined by Article 2 of Law 4308/2014. Specifically, listed S.A.s may face fines up to €100,000. For non-listed S.A.s, Ltd., P.C., and foreign branches, fines range from €1,000 for very small entities to €10,000 for large ones.
Non-compliance with provisions on the company name and trade name, as stipulated in Article 54 of Law 4919/2022, also constitutes a violation and may result in penalties based on the nature and severity of the infraction.
Significant attention is given to the accuracy of information submitted during company incorporation through the electronic One-Stop Service (e-GEMI). In cases where false or inaccurate declarations are identified during incorporation, fines are set at €5,000 for S.A., partnerships limited by shares, and P.C., and €2,000 for Ltd. and foreign company branches.
Failure to register with GEMI is treated as a serious offense. While the fines for such infractions are not set at fixed amounts, they will be determined proportionally, considering the company’s legal form, size, and the duration of the violation.
For S.A.s, Ltd., P.C., and foreign company branches operating in Greece, strict adherence to all publicity obligations, timely updates to GEMI, and proactive review of their articles of association and legal identifiers are now critical. Even a single missed filing may lead to considerable financial penalties, which may be imposed repeatedly in case of persistent non-compliance.
While the legal provisions are already in effect, systematic enforcement of penalties is expected to commence on January 1, 2026. Companies and foreign branches are granted a grace period until December 31, 2025, during which they may rectify any outstanding filings or errors without incurring fines.
Summary Table of Administrative Penalties (JMD 46982/2025)
| Violation | Description | S.A. (€) | Limited Liability Cos (€) | Foreign Branches (€) |
| Article 4 | Errors or omissions in incorporation via e-GEMI | 5,000 | 2,000 | 2,000 |
| Article 5 | Failure to register with GEMI | 10,000 | 2,000 | 1,200 |
| Article 6 | Missing mandatory elements in official documents | 500 | 200 | 120 |
| Article 7 | Late registration of a corporate act | 500 | 200 | 120 |
| Article 8 | Incorrect or incomplete automatic registration | 1,600–400 | 800–200 | 320 |
| Article 9 | Failure to publish mandatory corporate acts | 1,600–400 | 800–200 | 320 |
| Article 10 | Failure to publish financial statements | 10,000–1,000 | 5,000–1,000 | 1,000 |
| Article 11 | Violations regarding company name/trade name | 1,600–400 | 800–200 | 320 |
