The Ministerial Decision 46982/18.06.2025, which establishes the regulatory framework governing the imposition of administrative sanctions by the General Commercial Registry (G.E.MI.), has entered into force. This decision specifies the violations subject to penalties, the criteria for calculating fines, the procedure for their imposition, and the amount of the imposed fines, aiming to enhance transparency, regulatory compliance, and commercial publicity.
The new regime applies to all businesses required to register with G.E.MI., including Sociétés Anonymes (S.A.), Limited Liability Companies (L.L.C.), Private Companies (P.C.), General Partnerships, Limited Partnerships, cooperatives, civil law partnerships, joint ventures, as well as branches of foreign companies operating in Greece.
The primary categories of violations that result in sanctions, along with the corresponding fines, which vary depending on the legal form and size of the business, are set out below.
- Failure to publish financial statements
A particularly strict framework is provided for businesses that fail to publish their annual financial statements and the relevant accompanying reports on G.E.MI. within the prescribed deadline. This obligation applies to capital companies, cooperatives, branches of foreign companies, as well as General Partnerships and Limited Partnerships that fall under the provisions of Law 4308/2014. Opening and closing balance sheets, as well as interim financial statements, are exempt from this obligation.
The amount of the fines imposed in the event of non-compliance is determined based on the legal form, the entity category, and the size of the business. For entities kept in the G.E.MI. Service of the General Secretariat of Commerce, the fines range from EUR 10,000 to EUR 100,000. For the rest, i.e. those registered with the G.E.MI. Service of the Chambers of Commerce, the fines range from EUR 1,000 to EUR 10,000.
- Violations during establishment of a company through the electronic One-Stop-Shop (e-Y.M.S.)
Administrative fines are also imposed in cases of establishment of companies through the electronic One-Stop-Shop service (e-Y.M.S.), when the procedure is completed without prior verification of the legality of the submitted data. Violations identified in this context include, inter alia, the registration of inaccurate or incorrect information in the information system (such as identity details, registered office, or residence permit), as well as failure to submit required legalization documentation. The amount of administrative fines ranges from EUR 500 (for partnerships, joint ventures, civil law companies, and European Economic Interest Groupings (EEIGs) to EUR 5,000 (for Sociétés Anonymes, European Companies, and Limited Partnerships by Shares).
- Failure to register with G.E.MI.
The non-registration of obliged legal entities or branches with G.E.MI., regardless of whether they are active or under liquidation, constitutes a violation subject to penalties. Fines range from EUR 1,000 for General Partnerships, Limited Partnerships, EEIGs, and Joint Ventures (registered with the G.E.MI. Department of the Chambers of Commerce), up to EUR 10,000 for companies of any form that are registered with G.E.MI. Service of the General Secretariat of Commerce.
- Failure to include mandatory information in corporate documents
Penalties are also imposed for the failure to include essential information in corporate documents, such as the G.E.MI. number, legal form, corporate name, registered office, liquidation status, or reference to paid-up capital. This obligation applies to any paper or electronic document addressed to third parties (letters, advertising brochures, orders, advertising materials, etc.), with the exception of internal documents and retail receipts. Fines range from EUR 100 to EUR 500, depending on the legal form and category of the entity.
- Late submission of an application for registration with G.E.MI.
The submission of an application after the deadline of twenty (20) days for domestic companies (from the date of the relevant decision was taken) or three months for branches of foreign companies (from the corresponding registration in the national registry of the parent company's registered office) results in administrative sanction. Fines range from EUR 100 to EUR 500, depending on the corporate form.
- Violations related to automatic registrations with G.E.MI.
Where inaccuracies, incomplete information, or false statements are identified in acts that are automatically registered with G.E.MI., fines ranging from EUR 200 to EUR 2,000 are provided, depending on the legal form and size of the business.
- Other omissions of mandatory registration and publication of data in G.E.MI.
For any other case of omission, error, or submission of non-compliant information, which is not covered by another special provision, a fine ranging from EUR 200 and EUR 2,000 is imposed, depending on the legal form of the business, the category of the entity, and, for capital companies, their size.
- Violations related to corporate name and distinctive title
Non-compliance with the requirements for the formation of a corporate name or a distinctive title, such as the use of terms that refer to public authorities without approval, the adoption of offensive expressions, the reservation of an identical corporate name without relevant consent, or failure to comply with court decisions, is subject to a fine ranging from EUR 200 to EUR 2,000, depending on the legal form and size of the business.
Imposition procedure and reduction of fines
Violations may be identified ex officio by the competent authorities (through G.E.MI. automation systems or audits), following notification by another public authority, a random check, or even upon a complaint submitted by a natural person or legal entity.
In the event of a violation, the G.E.MI. Service notifies the obliged party to comply within ten (10) working days. If no action is taken, an electronic fine notice is issued and sent via the G.E.MI. electronic message inbox and by email. The obliged party has fifteen (15) days to submit substantiated objections. If the deadline passes without action or the submitted information is deemed insufficient, the fine is digitally served or, if this is not possible, sent by post to the obliged party' s registered seat or establishment.
The fine is reduced by half if the obliged party, within thirty (30) days of notice, pays it and at the same time proceeds with the registration, modification, or deletion of the violation. The same reduction also applies to legal entities under liquidation or special liquidation.
In the event of non-payment, the fine is certified and collected through the Independent Authority for Public Revenue (A.A.D.E.), in accordance with the Public Revenue Collection Code.
In the event of a repeat offence of the same violation within three years, the fine is doubled, while in the case of repeated violations, it is tripled.
Finally, if at the time the violation was identified, the obliged party has changed its entity category or corporate legal form or size category, the amount of the fine is calculated based on the criteria applicable at the time the violation was committed.
Transitional period for the implementation of fines – No fines until 31.12.2025
The full implementation of the new framework comes into effect as of 1 January 2026. Until then, a transitional period is in place during which the necessary technical and organizational adjustments are made, giving obliged parties the opportunity to comply without the imposition of fines.
Specifically, by 30 September 2025, the competent Information Systems Department of G.E.MI. and One-Stop-Shop undertakes the completion of critical projects, including the development of an electronic fine-managing system, the interconnection with the A.A.D.E. registry for the identification of non-registered businesses, and the enhancement of the interoperability of the information systems, enabling the automatic imposition of fines.
By 31 December 2025, obliged parties are required to proceed with registrations, corrections or updates of data in G.E.MI., in order to avoid future sanctions.
In summary, the transitional period provides businesses with the necessary time to smoothly adapt to the new, digitally supported, and stricter oversight framework, aiming to enhance the transparency of the business environment and protect the public interest.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
