The new provisions introduce significant changes to property reporting requirements, the calculation of ENFIA (the Unified Property Ownership Tax), and the obligations of property owners, tenants, and beneficiaries of gratuitous-use arrangements.
Under the new framework, property taxation will, in certain cases, be based on the actual floor area of a building as recorded in the Electronic Building Identity (EBI), even where this is smaller than the area stated in the Hellenic Cadastre, title deeds, or building permits.
The amendment also establishes a new procedure for declaring property use through the Property Ownership and Management Registry (M.I.D.A.) and introduces penalties of up to €1,000 for individuals who fail to submit the required declarations or provide inaccurate information used to obtain public benefits, grants, or subsidies.
Changes to Property Declarations
Until now, the completion of the E9 Property Declaration and the calculation of ENFIA have been based primarily on information derived from the Hellenic Cadastre or, where no final cadastral registration existed, from the property’s title deed.
While the new legislation preserves this general principle, it introduces a significant exception for properties with an Electronic Building Identity. Specifically, where the actual floor area of a building is smaller than the area recorded in the Cadastre, title deed, or building permit, property taxation will be calculated on the basis of the smaller verified area, provided that it is documented through the Electronic Building Identity.
This change is intended to address cases in which property owners are effectively taxed on floor areas larger than those they actually possess, resulting in inflated ENFIA liabilities.
Conversely, where the actual floor area exceeds that recorded in official documents, or where the property’s use has changed, taxation will continue to reflect the property’s actual condition.
Impact on ENFIA
The same principle will apply to the calculation of ENFIA. For properties with an Electronic Building Identity, the tax will be assessed on the basis of the actual square metres certified in the property’s electronic record.
The measure is expected to reduce the taxable floor area—and therefore the ENFIA burden—for owners whose properties display discrepancies between their actual characteristics and the data maintained in other public registries.
New Filing Sequence
The amendment also regulates the process for updating the Property Ownership and Management Registry (M.I.D.A.) regarding the use of a property.
Where a property-use declaration is required, taxpayers must first submit their property details declaration and subsequently update the Registry with information regarding the property’s use.
The obligation to report the establishment, acquisition, or modification of property rights by 31 January of the following year remains unchanged, while special filing deadlines continue to apply in cases of inheritance.
€500 Fine for Failure to Submit a Property-Use Declaration
For the first time, the legislation introduces specific sanctions linked to the registration of property use.
A fine of €500 will be imposed where the required declaration is not submitted:
- Within three months of the commencement of a lease agreement or a gratuitous concession of use; or
- Within the statutory deadlines associated with the submission of the Single Aid Application for agricultural subsidies.
The penalty will be imposed on the party responsible for updating the Registry.
Fines of up to €1,000 for False Declarations
More severe sanctions apply in cases involving inaccurate or misleading information.
A tenant or beneficiary of a gratuitous-use arrangement who submits a property-use declaration containing false information that is subsequently used to obtain benefits, grants, or subsidies will be subject to a €1,000 fine.
Where the inaccurate information is not used to secure any form of financial assistance, the penalty will be reduced to €100.
Transitional Provisions
The new rules concerning the declaration of actual building floor area and the calculation of ENFIA will apply from the 2027 tax year onwards.
Property declarations already submitted, as well as ENFIA assessments issued before the new provisions enter into force, will not be deemed inaccurate solely because of discrepancies in floor area, provided that the smaller actual area can be substantiated through the Electronic Building Identity.
Likewise, ENFIA certificates issued on the basis of such declarations will remain valid, and no retrospective tax penalties will be imposed under the new framework.
