Ministerial Decision 46982/2025 (Government Gazette B’ 3542/08.07.2025) has introduced the full implementation of the administrative penalty framework for breaches of corporate disclosure obligations to the General Commercial Registry (G.E.MI.), in accordance with Law 4919/2022 and the applicable corporate legislation.
As of 1 January 2026, this framework is fully and automatically enforced, with no grace period.
Who is affected
The disclosure obligations to G.E.MI. apply to all legal forms of business entities, including indicatively:
- Public Limited Companies (S.A.)
- Limited Liability Companies (LTD)
- Private Capital Companies (IKE)
- General and Limited Partnerships
- Sole proprietorships
- Cooperatives
- Branches of domestic and foreign companies
Acts and information subject to mandatory disclosure
The following, among others, must be duly submitted to G.E.MI.:
- Annual Financial Statements
- Articles of Association amendments
- Changes in management and legal representation
- Dissolution, liquidation and deletion decisions
- Corporate transformations (mergers, spin-offs, conversions)
- Other corporate acts required by law to be published
All submissions must be made timely, accurately and in full compliance with the applicable legal framework.
Administrative penalties and sanctions
Failure to comply with G.E.MI. disclosure obligations may result in significant administrative fines, including indicatively:
- Non-submission of Financial Statements: fines of up to EUR 100,000
- Late or incomplete filings: fines ranging from EUR 100 to EUR 10,000
- Submission of inaccurate or unlawful information
- Repeat infringements: doubling or tripling of fines within a three-year period
Violations are identified automatically, through data cross-checks, inspections by G.E.MI. authorities, complaints and sample audits.
End of the transitional period – Current status
Ministerial Decision 46982/2025 provided for a transitional grace period until 31 December 2025, during which companies could, without penalties:
- complete their registration with G.E.MI.
- file pending corporate acts
- correct errors or omissions in previous filings
This transitional period has now expired.
As of 1 January 2026, any omission, delay or non-compliant filing may immediately trigger the imposition of administrative penalties.
Important clarification on roles and responsibilities
Our firm provides accounting services and preparation of Financial Statements.
The ultimate responsibility for compliance with corporate law and G.E.MI. disclosure obligations remains exclusively with the company itself.
Many acts subject to G.E.MI. disclosure:
- require legal assessment and interpretation,
- relate to the validity and legality of corporate decisions,
- do not constitute accounting actions.
For this reason, cooperation with a legal advisor is strongly recommended, in order to ensure the legality and completeness of filings and to avoid significant administrative sanctions.
Recommended immediate actions for businesses
- Review the completeness and accuracy of all data registered with G.E.MI.
- Monitor the G.E.MI. Electronic Message Inbox on businessportal.gov.gr on a regular basis.
- Contact your accountant promptly regarding Financial Statement matters.
- Engage a legal advisor for corporate acts and decisions.
Conclusion
Compliance with G.E.MI. disclosure obligations is no longer a formal requirement but a critical risk management issue. Timely action, proper internal organization and cooperation with qualified advisors are essential to avoid substantial financial penalties.