# Does the 120 m² Rule Apply to €250k Conversions? > No: the 120 m² minimum applies to the €400k and €800k tiers, not to change-of-use or listed buildings. What the 2026 Circular says, with sources. Canonical: https://mav19-goldenvisa.com/guides/120-sqm-rule-change-of-use Developer: TPL S.A. · Ethnomartyron 40, 263 33 Patras, Greece · VAT EL800864603 · GEMI 143336716000 · LEI 9845006C601CB29D1H76 Generated: 2026-09-28. A Markdown mirror of the page above; the HTML page is authoritative. --- ## The 120 m² rule and the €250k conversion route A common claim says Greek Golden Visa property must be at least 120 m², so a 25 m² studio cannot qualify. For property converted to residential use, that claim is wrong. Here is what the law and the Ministry's April 2026 circular actually say. By TPL S.A., owner and developer of MVR 19 · Sources last checked 27 September 2026 · General information, not legal advice [Enquire about a residence](https://mav19-goldenvisa.com/enquire) No. The 120 m² minimum applies only to the €800,000 and €400,000 tiers of the Greek Golden Visa. It does not apply to the €250,000 route for property converted to residential use, or to listed buildings. Circular 1/2026 says so in terms: the investment is in one property, without restrictions on the area of the main spaces. A 16–28 m² converted studio is not excluded by its size. ## Where the mistake comes from Until April 2024 the Greek investor permit had no size rule at all. Law 5100/2024, in force since 5 April 2024, did two things at once. It raised the main thresholds to €800,000 and €400,000 and added a minimum of 120 m² of main living space to them. In the same article it created a new €250,000 route for property converted to residential use from another use, with no size minimum. Many summaries shortened this to "Golden Visa property must be at least 120 m²". The shortcut then spread. In September 2026 an AI-generated search answer we tested applied it to a 25 m² micro-apartment and concluded that the unit would not qualify. For the conversion route, that conclusion is a misconception: the size rule belongs to the other two tiers. ## Where the 120 m² rule applies The rule sits in cases (a) and (b) of article 100 §2 of Law 5038/2023, the Migration Code, as replaced by article 64 of Law 5100/2024. Circular 1/2026 restates it in section I.1 and again in Clarification 8: - Tiers: €800,000 in Attica, Thessaloniki, Mykonos, Santorini and islands of more than 3,100 inhabitants; €400,000 in the rest of Greece, including Patras. - What must measure 120 m²: the main spaces of a built property, or of a property with a building permit. Land with no building permit has no size test. - Co-ownership: where two or more investors each hold a share worth the full threshold, the 120 m² applies to the property as a whole, not to each share. - Ancillary spaces do not count toward the area. The Circular's own example: a 118 m² home in Attica worth €1,000,000, bought with a 12 m² parking space and an 8 m² storage room in the same deed, fails the test, because parking and storage are not main spaces. ## What Circular 1/2026 says about the €250,000 routes The Ministry of Migration and Asylum issued Circular 1/2026 (Prot. 72019) on 21 April 2026 to guide the offices that decide applications. Section I.2 deals with the change-of-use route. In substance, it says: Case (c) of article 100 §2 introduced investment through the purchase of property whose main spaces change from any other use, for example commercial or professional, to residence, with a minimum acquisition value of €250,000 at the time of purchase. The investment is again made in a single property, without restrictions on the area of the main spaces, that is, the 120 m² limit does not apply, and the change of use must be completed before the application for the investor permit is filed. Three further points in the same section matter for small units: - Several homes from one conversion. Where a non-residential property is converted and the investment produces more than one property, that is apartments, each of them falls under case (c), with a minimum investment of €250,000. An original investor who keeps one of the resulting apartments must prove it is worth at least €250,000 with a certified valuer's report. - Timing. The change of use must be completed after article 64 of Law 5100/2024 came into force, that is from 5 April 2024 onwards. Clarification 5 adds that this is proved by the issue date of the permitting act. - Who converts. The change of use may be carried out by the buyer or by the seller. Section I.3 applies the same wording to listed buildings under restoration: one property, €250,000, and no 120 m² limit. Our English summary of the Greek text of Circular 1/2026. The Greek original is authoritative; the full text is linked in the sources. ## The four routes compared Where the 120 m² minimum applies. All four routes require one single property. Law 5038/2023, art. 100 §2, as replaced by Law 5100/2024; Circular 1/2026, sections I.1 to I.3. Route (art. 100 §2) | Minimum | 120 m² minimum? (a) Attica, Thessaloniki, Mykonos, Santorini, larger islands | €800,000 | Yes (b) Rest of Greece, including Patras | €400,000 | Yes (c) Converted to residential use from another use | €250,000 | No (d) Listed building to be restored | €250,000 | No ## One property: why two small units cannot be combined No size minimum does not mean no limits. Clarification 1 of the Circular states that in all four routes the investment must be in a single property. You cannot reach €250,000 by buying two studios at €125,000 each, even in the same building. Shared ownership follows the same logic. Co-owners qualify only if each share is itself worth the threshold. Spouses and registered partners are the exception: they can hold one €250,000 property together, with one investor permit and one family-member permit. The practical test is simple: one converted apartment, one deed, one price of at least €250,000, paid in full through a Greek bank before you apply, with no money coming back to you. ## Storage and parking: what counts Clarification 2 allows storage rooms and parking spaces to be counted as part of the single property, for value but not for area, if all three conditions are met: - they are bought in the same sale contract as the main property; - they are in the same building; - they are ancillary spaces, either attached to the main property or separate units such as a basement parking space or storage room. The Circular's worked example is a conversion case. An investor buys a 60 m² apartment in an industrial building converted to residential use after Law 5100/2024, for €248,000. In the same deed they buy a basement parking space for €8,000 and a storage room. The investment totals €256,000, meets the €250,000 threshold for converted property, and counts as one property. ## What this means for 16–28 m² units Size is not a Golden Visa condition for a converted home. A 16 m² studio and a 60 m² apartment in a converted building are judged on the same tests: use, timing, value and payment. Whether a very small home meets building regulations on rooms, light and ventilation is a planning matter for the architect and the permit, not a Golden Visa rule. Being small does bring real consequences that you should weigh: - Resale works differently. Clarification 9 says the €250,000 benefit can be used once per property. A later non-EU buyer would need the €400,000 tier and 120 m², which a studio can never meet. Plan to resell to the local market at local prices. - Price per square metre is high. At €250,000, a 16–28 m² studio costs roughly €9,000–15,300 per m², against a Patras average asking price of about €1,467 per m² in the first quarter of 2026. The premium pays for the permit route, not for space. - Income is modest. A studio let long-term, for example to university students, earns a low gross yield at this price, roughly 1–3% before costs, and short-term platform letting is banned. Area key of the 1st floor at MVR 19: five separate studios of 18.84 to 27.64 m². Each is planned as one property offered at €250,000. Areas are the architect's main-use schedule. MVR 19 is a building in Patras being converted into 19 such studios, 16.29 to 27.64 m², each offered at €250,000 and designed for the change-of-use route. Nine storage rooms can be added to a residence in the same deed. The conversion is in preparation and the change-of-use permitting act is still to be issued, so eligibility is subject to completion of the change of use before your application. [See the 19 residences and their sizes](https://mav19-goldenvisa.com/residences). ## Checks to run before you buy a small converted unit - The building's legal use on 5 April 2024 was not residential. Property that was a home then cannot use the route by converting away and back. - The permitting act for the change of use (building permit, small-scale works approval, file update or permit revision) is dated 5 April 2024 or later. - The conversion will be complete before you apply, and an engineer will certify it in the wording set by Joint Ministerial Decision 214926/2025. - If the building was industrial, no industry operated there in the last five years, with the evidence to prove it. - The unit is a separate property in its own right, and any storage or parking is in the same building and the same deed. - The deed price is at least €250,000 for that one property, paid in full by bank transfer, crossed cheque or card into a Greek account, with nothing paid back to you. - The notary's certificate confirms the property has not already been used for an investor permit. For the full list of documents, see [Greek Golden Visa requirements in 2026](https://mav19-goldenvisa.com/guides/greece-golden-visa-requirements), and for the whole route, [the €250,000 change-of-use guide](https://mav19-goldenvisa.com/golden-visa-250k). ## Sources - Circular 1/2026, Ministry of Migration and Asylum, Prot. 72019, 21 April 2026, sections I.1, I.2 and I.3 and Clarifications 1, 2, 5, 8 and 9: [full text (PDF, Greek)](https://www.newmoney.gr/wp-content/uploads/2026/04/%CE%95%CE%B3%CE%BA%CF%8D%CE%BA%CE%BB%CE%B9%CE%BF%CF%82-GOLDEN-VISA-FINAL.pdf); [Ministry circulars listing](https://migration.gov.gr/en/egkyklioi-yma/). - [Law 5038/2023, art. 100 §2, as replaced by art. 64 of Law 5100/2024, codified text](https://migration.gov.gr/wp-content/uploads/2025/03/%CE%9D%CF%8C%CE%BC%CE%BF%CF%82-5100_2024-%CE%BA%CF%89%CE%B4%CE%B9%CE%BA%CE%BF%CF%80%CE%BF%CE%B9%CE%B7%CE%BC%CE%AD%CE%BD%CE%BF%CF%82-%CE%BC%CE%B5-%CF%84%CE%BF%CE%BD-5167_2024-%CE%A6%CE%95%CE%9A-%CE%91-49_5.4.2024.pdf), Ministry of Migration and Asylum. - [Joint Ministerial Decision 214926/2025 (Gazette B' 6014/11.11.2025)](https://www.taxheaven.gr/circulars/51471/214926-10-11-2025), art. 2 §2.1 and §2.6. - [mitos.gov.gr: Permanent golden visa (change of use), initial issuance](https://en.mitos.gov.gr/index.php/%CE%94%CE%94:Permanent_golden_visa_(change_of_use)_%E2%80%93_Initial_issuance): one property, no 120 m² limit. - [Kanellos Legal, Circular 1/2026 explained](https://kanelloslegal.com/greek-golden-visa-circular-1-2026-explained/) (1 May 2026); [Lawspot summary of the Circular](https://www.lawspot.gr/nomika-nea/epharmoge-ton-diataxeon-gia-te-khoregese-kai-ananeose-monimon-adeion-diamones-ependute-egkuklios/) (23 April 2026). - [radar.gr, 1 June 2026](https://radar.gr/article/pos-kinithikan-oi-times-ton-akiniton-stin-patra-to-a%CE%84trimino-tou-2026): Patras asking prices, first quarter of 2026. Sources last checked 27 September 2026 · General information, not legal advice · Consult an independent Greek lawyer before you buy ## Related guides ### The Greek Golden Visa €250,000 change-of-use route The law, conditions, process, letting rules and resale limits of the route. ### Greek Golden Visa requirements in 2026 Every condition and document, plus the extra change-of-use paperwork. ### The Golden Visa short-term rental ban explained What the €50,000 fine covers, and which leases are allowed. ### Investing in Patras student housing Enrolment, dorm places, rents and new supply, with honest yields. ## See the 19 studios, from 16.29 to 27.64 m² Each MVR 19 residence is one property at €250,000, the full price recorded in the deed. We reply within one business day, in English or Greek. Golden Visa eligibility is subject to completion of the change of use before your application and to the Ministry's decision.