Joint Ministerial Decision 46982/2025 (Government Gazette B’ 3542/08.07.2025) specifies the registrations and fines of the General Commercial Registry (G.E.MI.) for breaches of Law 4919/2022.
The Decision enters into force on 1 January 2026 and applies to all obliged entities.
According to Ministerial Decision 46982/2025, those required to register with G.E.MI. must complete their registration and ensure the accuracy of their details by 31 December 2025. From 1 January 2026, the process of imposing fines will commence for those who have not proceeded to make the required registrations.
The fines will be imposed for infringements of Law 4919/2022, with their amounts defined according to the nature of each obligation. The new Decision elaborates on the provisions of the law while granting a “grace period” to those who correct or supplement their details in G.E.MI. by the end of 2025.
Scale of fines
The fines are graded according to the type of entity and the nature of the infringement.
Below are the categories provided in the Decision.
1) Imposition of fines for failure to publish financial statements
One of the most important obligations for all companies in Greece is the publication of their financial statements. If this obligation is not fulfilled as provided by law, significant fines will apply, which are considerably higher than those imposed under previous frameworks.
Article 10 of the Decision imposes these fines for breaches of Articles 34(1)(ia), 35(1)(e), 39(i), 43(i), 44, and 45 of Law 4919/2022. This includes the failure to submit financial statements and accompanying reports within the statutory deadline. The obligation does not include the opening and closing balance sheets of liquidation or interim financial statements.
Details on the fines that will be imposed:
A) Entities recorded with the G.E.MI. Service of the General Secretariat of Commerce
€10,000 - Branches and agencies of foreign companies
€10,000 - Companies (Very Small, non-listed)
€25,000 - Companies (Small, non-listed)
€50,000 - Companies (Medium-sized, non-listed)
€100,000 - Companies (Large, non-listed or listed on the Stock Exchange)
B) Other entities (Chamber G.E.MI. Services)
€10,000 - Branches and agencies of foreign companies, cooperatives
€1,000-€10,000 - Capital and partnerships whose partners are exclusively legal persons (Law 4308/2014, Article 1(2)(b))
In these companies, the fine varies by size:
€1,000 - Very Small companies
€2,500 - Small companies
€5,000 - Medium-sized companies
€10,000 - Large companies
2) Imposition of fines for submission of incorrect data
According to Article 4 of the Joint Ministerial Decision (Article 12 of Law 4919/2022), if the registration in the G.E.MI. has been completed but the information entered is incomplete or inaccurate, or if errors are found during the legality and completeness check of the supporting documentation, contrary to the Principle of Accuracy (Article 1(e) of the Decision), a fine
will be imposed ranging from €500 to €5,000, depending on the company type.
Examples include incorrect or missing identity details of natural or legal persons, company seat information, residence permits, and so forth.
Details on the fines that will be imposed:
€500 - General Partnerships (O.E.), Limited Partnerships (E.E.), Joint Ventures, European Economic Interest Groupings (E.E.I.G.), Civil Companies (Article 784 of the Civil Code)
€2,000 - Private Companies (I.K.E.), Limited Liability Companies (E.P.E.), Cooperatives
€5,000 - Public Limited Companies (S.A.), European Companies (S.E.), Partnerships Limited by Shares (E.E. by shares)
3) Imposition of fines for failure to register with the G.E.MI.
Companies and branches of foreign entities operating in Greece that are required to register with the G.E.MI. are listed in Article 16 of Law 4919/2022.
Failure to do so, as provided in Article 5 of the Decision, triggers the following fines:
A) Entities recorded with the G.E.MI. Service of the General Secretariat of Commerce
€10,000 - Companies (of any type)
€6,000 - Branches and agencies of foreign companies
B) Other entities (Chamber G.E.MI. Services)
€1,000 - General Partnerships (O.E.), Limited Partnerships (E.E.), Joint Ventures, European Economic Interest Groupings (E.E.I.G.)
€1,200 - Branches and agencies of foreign companies, Private Companies (I.K.E.), Limited Liability Companies (E.P.E.), Cooperatives
€2,000 - Public Limited Companies (S.A.), European Companies (S.E.), Partnerships Limited by Shares (E.E. by shares)
4) Imposition of fines for omission of required company details on documents and correspondence
As provided in Article 6 of the Joint Ministerial Decision, in addition to their registration obligation, companies must indicate certain information on all official documents and correspondence (Articles 22 and 37 of Law 4919/2022). This obligation does not apply to internal company documents or correspondence (e.g. payroll records, internal communications), nor to goods, sales receipts, or invoices. It concerns external documents and correspondence used in dealings with third parties, and particularly clients, such as promotional or informational brochures issued by the company, and order forms.
According to the law, company documents and letters must include the following:
a) The G.E.MI. number (for domestic companies or branches of companies from other EU Member States) or the Registration Registry and Registry Number (for companies established in third countries).
b) The company type and legal form.
c) The company name.
d) The registered office of the company.
e) The indication that the company is in liquidation, if applicable.
f) Whether the share capital is subscribed and paid up (for capital companies only).
If any of the above information is missing, a fine will be imposed according to Article 6 of the Decision, with the amount varying by company type.
A) Entities recorded with the G.E.MI. Service of the General Secretariat of Commerce
€500 - Companies (of any type)
€300 - Branches and agencies of foreign companies
B) Other entities (Chamber G.E.MI. Services)
€100 - General Partnerships (O.E.), Limited Partnerships (E.E.), Joint Ventures, European Economic Interest Groupings (E.E.I.G.), Civil Companies (Article 784 Civil Code)
€120 - Branches and agencies of foreign companies, Private Companies (I.K.E.), Limited Liability Companies (E.P.E.), Cooperatives
€200 - Public Limited Companies (S.A.), European Companies (S.E.), Partnerships Limited by Shares (E.E. by shares)
5) Imposition of fines for late submission of applications for registration with the G.E.MI.
Companies and branches of foreign entities are obliged to file their details with the G.E.MI. within specific deadlines, as laid down in Articles 18 and 25 of Law 4919/2022:
- 20 days from the date of the relevant decision for domestic companies, and
- 3 months from the date of registration of the decision in the register of the country of the parent company for foreign branches.
If these deadlines are not met, a fine will be imposed under Article 7 of the Decision, equal in amount to that provided for the previous violation.
Details on the fines that will be imposed:
A) Entities recorded with the G.E.MI. Service of the General Secretariat of Commerce
€500 - Companies (of any type)
€300 - Branches and agencies of foreign companies
B) Other entities (Chamber G.E.MI. Services)
€100 - General Partnerships (O.E.), Limited Partnerships (E.E.), Joint Ventures, European Economic Interest Groupings (E.E.I.G.), Civil Companies (Article 784 Civil Code)
€120 - Branches and agencies of foreign companies, Private Companies (I.K.E.), Limited Liability Companies (E.P.E.), Cooperatives
€200 - Public Limited Companies (S.A.), European Companies (S.E.), Partnerships Limited by Shares (E.E. by shares)
6) Imposition of fines for submission of false or incorrect data
Certain acts of companies already registered with the G.E.MI. must also be entered into the Register. This registration is normally automatic, but companies have the opportunity to review and correct any errors before final confirmation. If the final entry contains mistakes or incomplete information (Article 26 of Law 4919/2022) or if false or unlawful data have been filed (Article 36 of Law 4919/2022), or if the Principle of Accuracy is otherwise breached, a fine will be imposed pursuant to Article 8 of the Decision.
Details on the fines that will be imposed:
A) Entities recorded with the G.E.MI. Service of the General Secretariat of Commerce
€400 - Branches and agencies of foreign companies
€400 - Very Small companies (non-listed)
€500 - Small companies (non-listed)
€1,000 - Medium-sized companies (non-listed)
€2,000 - Large companies (non-listed or listed on the Stock Exchange)
B) Other entities (Chamber G.E.MI. Services)
€200 - General Partnerships (O.E.), Limited Partnerships (E.E.), Joint Ventures, European Economic Interest Groupings (E.E.I.G.), Civil Companies (Article 784 Civil Code)
€320 - Branches and agencies of foreign companies, Cooperatives
€320 - €1,600 - Public Limited Companies (S.A.), Private Companies (I.K.E.), Limited Liability Companies (E.P.E.), European Companies (S.E.), Partnerships Limited by Shares (E.E. by shares)
For these companies, the fine varies by size:
€320 - Very Small companies
€400 - Small companies
€800 - Medium-sized companies
€1,600 - Large companies
The size of each company is determined in accordance with Article 1(c) of the Decision, which refers to Article 2 of Law 4308/2014. The relevant reference date for classification is the balance-sheet date, when the prescribed criteria must be met.
A company is classified as follows:
Very Small company - does not exceed two of the following limits:
Total assets: €450,000
Net turnover: €900,000
Average employees: 10
(Exceptionally, companies with up to 10 employees and annual turnover not exceeding €1,500,000 also qualify as Very Small.)
Small company - does not exceed two of the following limits and is not classified as Very Small:
Total assets: €5,000,000
Net turnover: €10,000,000
Average employees: 50
Medium-sized company - does not exceed two of the following limits and is not classified as Very Small or Small:
Total assets: €25,000,000
Net turnover: €50,000,000
Average employees: 250
Large company - exceeds two of the above limits for medium-sized companies.
This distinction is essential for determining the fine amount, as certain fines depend on both the company type and its size.
7) Imposition of fines for infringements concerning information that must be mandatorily registered and published in the G.E.MI.
This fine, provided for in Article 9 of the Ministerial Decision, applies to any case where information required to be mandatorily entered in the G.E.MI. is false, inaccurate or incomplete and does not fall under any of the previous categories. It is a general sanction for infringements of several provisions of Law 4919/2022 (Articles 30, 33-35, 39, 43).
Unlike earlier provisions that dealt solely with registered acts, this fine focuses on the data of the partners and the company itself. If a specific fine is already prescribed for a given infringement, that one takes precedence. The new sanction functions as a “catch-all” clause, covering cases not otherwise regulated.
Details on the fines that will be imposed:
A) Entities recorded with the G.E.MI. Service of the General Secretariat of Commerce
€400 - Branches and agencies of foreign companies
€400 - Very Small companies (non-listed)
€500 - Small companies (non-listed)
€1,000 - Medium-sized companies (non-listed)
€2,000 - Large companies (non-listed or listed on the Stock Exchange)
B) Other entities (Chamber G.E.MI. Services)
€200 - General Partnerships (O.E.), Limited Partnerships (E.E.), Joint Ventures, European Economic Interest Groupings (E.E.I.G.), Civil Companies (Article 784 Civil Code)
€320 - Branches and agencies of foreign companies, Cooperatives
€320-€1,600 - Public Limited Companies (S.A.), Private Companies (I.K.E.), Limited Liability Companies (E.P.E.), European Companies (S.E.), Partnerships Limited by Shares (E.E. by shares)
In these cases, the fine varies by size:
€320 - Very Small companies
€400 - Small companies
€800 - Medium-sized companies
€1,600 - Large companies
8) Imposition of fines for infringements relating to company name and distinctive title
These infringements concern the information declared in G.E.MI. upon the establishment of a company, and specifically its name and distinctive title, which are publicly accessible and form an essential part of the company’s identity. For this reason, compliance with the relevant legal framework (Article 54 of Law 4919/2022) is deemed particularly important, safeguarding both the public and other undertakings.
A breach of Article 54 of Law 4919/2022 includes:
a) Failure to comply with the legal rules on the formation of the company name or title;
b) Use of wording implying connection with public authorities, bodies, offices, non-profit institutions, associations, organisations or chambers, without proper authorisation;
c) Use of wording that offends public decency or has abusive, racist or sexist content;
d) Reservation of an identical name or title to that of an existing entity without consent; and
e) Non-compliance with final court decisions.
Details on the fines that will be imposed:
A) Entities recorded with the G.E.MI. Service of the General Secretariat of Commerce
€400 - Branches and agencies of foreign companies
€400 - Very Small companies (non-listed)
€500 - Small companies (non-listed)
€1,000 - Medium-sized companies (non-listed)
€2,000 - Large companies (non-listed or listed on the Stock Exchange)
B) Other entities (Chamber G.E.MI. Services)
€200 - General Partnerships (O.E.), Limited Partnerships (E.E.), Joint Ventures, European Economic Interest Groupings (E.E.I.G.), Civil Companies (Article 784 Civil Code)
€320 - Branches and agencies of foreign companies, Cooperatives
€320-€1,600 - Public Limited Companies (S.A.), Private Companies (I.K.E.), Limited Liability Companies (E.P.E.), European Companies (S.E.), Partnerships Limited by Shares (E.E. by shares)
Fines by size:
€320 - Very Small companies
€400 - Small companies
€800 - Medium-sized companies
€1,600 - Largecompanies
Procedure for imposing fines - Mitigating and aggravating factors
As stated in Article 13 of the Decision, the above infringements (Articles 4-11) may be established in the following ways:
a) Automatically by the competent authorities, via detection through the G.E.MI. information system;
b) Ex officio by the competent G.E.MI. Unit following a check;
c) Upon notification from another public service or authority;
d) Through random inspection; and
e) Upon complaint by a third party.
Automatic detection occurs through cross-checking with the Independent Authority for Public Revenue (A.A.D.E.). All other cases are verified manually by the competent G.E.MI. Unit following the relevant check.
Under Article 13(4) of the Decision, once a breach is identified, the G.E.MI. Unit follows the procedure of Article 30(1) of Law 4919/2022: the offender must be called to provide an explanation. The entity concerned must, within 10 days of being notified, either justify why no breach has occurred, or request correction of the error or omission in the G.E.MI.
No fine is imposed if the entity itself requests correction before detection by the G.E.MI. (Article 13(5)).
If the 10-day period lapses without action, a notice of violation is issued and the offender is formally notified of the fine. After the notice, the entity has 15 days to submit objections.
If these are rejected, the fine becomes enforceable.
Mitigating factor - Early payment (Article 14(4) of the Decision)
If the fine is paid within the first month following its imposition (30 days) and the related error is corrected in G.E.MI. within the same period, the amount is reduced by half. If, however, payment of the fine entails waiver of the right to challenge it, including judicially.
Aggravating factor - Repeat offence (Article 12 of the Decision)
If the same infringement is repeated within three years, the new fine is doubled. In case of multiple recurrences within the same period, the fine is tripled. Repeat offences are recorded in the company’s G.E.MI. file.
Conclusions
As the date of entry into force approaches, particular attention is required to ensure compliance and to avoid the imposition of fines. The new provisions introduce a significantly stricter penalty framework aimed at ensuring the accuracy and transparency of entries in the G.E.MI. It is strongly recommended that companies review their obligations and take all
necessary steps before 31 December 2025 to avoid sanctions.
These regulations leave no room for errors or delays. Contact our team for practical, specialised support on compliance with the new G.E.MI. fines regime.
