As of 1 January 2026, Joint Ministerial Decision 46982/2025 (Government Gazette B’ 3542/2025) entered into force, setting out the criteria and the level of administrative penalties for businesses that fail to comply with their obligations towards the General Commercial Registry (GEMI). The new framework aims to ensure the accuracy, completeness, and timely updating of corporate information. Its implementation takes place in two phases, allowing liable entities sufficient time to achieve compliance.
Accordingly, until 31 December 2025, liable entities were invited to make any necessary corrections, amendments, or outstanding registrations in GEMI without the imposition of penalties, so that their corporate profile is accurate before the enforcement of the new sanctions.
01.01.2026: Inspections and Penalties
As of the beginning of the new year, GEMI conducts inspections ex officio, on a sample basis, or following a complaint. Penalties will apply to capital companies, general and limited partnerships, cooperatives, and branches of foreign companies.
Main Categories of Violations
The eight categories of violations include:
1. Errors or omissions during company incorporation through the e-OSS.
2. Failure to register with GEMI.
3. Failure to include mandatory information on documents and letters of the company/branch of a foreign company.
4. Overdue submission of a registration application in GEMI.
5. Incorrect or incomplete automatic registrations.
6. Violations related to information the entities are required to file and publish in GEMI.
7. Failure to publish financial statements.
8. Use of a non-compliant company name or trade name.
Penalty Categories
Penalties are determined based on the type of violation, the legal form of the entity, and/or its size, as specified in the Joint Ministerial Decision.
Penalty Imposition Procedure
Before a penalty is imposed, GEMI invites the liable entity to comply within ten (10) days. In case of non-compliance within the deadline, the liable entity or its legal representatives receive, via the GEMI messaging inbox, an electronic notice of the penalty to be imposed, which constitutes a written call to a hearing under Article 6(2) of Law 2690/1999 (A’ 45).
Upon receiving this notice, the liable entity may submit its views through an electronic application within fifteen (15) days. If the explanations are not accepted, the administrative act imposing the penalty is issued.
The liable entity may benefit from a 50% reduction of the penalty if, within thirty (30) days of receiving the penalty decision, the corresponding amount is paid and the required registration is completed.
Conclusion
The new sanction framework for GEMI represents a significant step towards enhancing transparency and the reliability of corporate information. Timely and accurate updating of corporate records is now an essential requirement for effective corporate governance, reducing legal risks, and avoiding administrative sanctions. Compliance with the new obligations ensures not only adherence to the regulatory framework but also a consistent, trustworthy, and institutionally robust corporate presence.
*** Following the issuance of the new Joint Ministerial Decision 104666 (ΦΕΚ Β’7204/2025), the aforementioned compliance deadline for liable entities has been extended until 31.01.2026.
This flash information update prepared by AP Legal team, aims to inform you about developments in corporate legislation. Stay tuned for further updates and contact our expert team for more information on your rights.
