Author: Phoebe Kouvelas, LL.M.
The 40% Greek cash rebate is generous, but it is also unforgiving: an application filed late, a cost that does not qualify or a gap in the paperwork can cost a production the entire grant.
On 28 April 2026, the Hellenic Film and Audiovisual Center – Creative Greece (EKKOMED) opened the application platform for Cash Rebate Greece 2026, with total public expenditure of EUR 100 million for the year. Of this, EUR 88 million is allocated to the film and television scheme (CRGR-FTV), EUR 10 million to the new animation and AR/VR scheme (CRGR-Animate) and EUR 2 million to digital games.
The programme returns 40% of eligible production costs incurred in Greece. For international producers, it is one of the most competitive incentives in Europe; for Greek producers and service companies, it is often the element that makes a project financeable. Yet the rebate is a state aid, granted by administrative decision and released only after an audit. The legal position of a production is therefore decided well before the first day of shooting.
The legal framework
Cash Rebate Greece was established by Section C of Law 5105/2024 ("Creative Greece"), which replaced the regime first introduced by Law 4487/2017.
At EU level, the scheme operates within the State aid rules for audiovisual works under the General Block Exemption Regulation (Regulation (EU) No 651/2014, Article 54). This explains several of its features: aid is limited to works that pass a cultural test, the territorial spending requirement is capped (here, eligible Greek costs may not exceed 80% of the total production budget), and aid is subject to transparency and cumulation limits. Producers combining the rebate with Eurimages, Creative Europe MEDIA or national funds from co-producing countries should therefore check the overall aid intensity of the project, not only each grant in isolation.
Under CRGR-FTV, the rebate is 40% of eligible costs incurred in Greece, paid as a lump sum of up to EUR 8 million per work, which may rise to EUR 10 million for strategic projects of national importance.
A legal checklist for producers
1. The right applicant. Action A is open to large enterprises, and to foreign producers established outside non-cooperative jurisdictions within the meaning of Article 65(3) of the Income Tax Code (Law 4172/2013), provided they contract with a Greek-established executive producer, which may act as co-beneficiary. Action B is reserved for SMEs. The applicant must operate under activity codes 59.11 or 59.12, be registered in the General Commercial Registry (GEMI) and, unless exempt, in the Register of Beneficial Owners before applying. A company still being set up must complete its publicity formalities before the project starts.
2. An eligible work and a sufficient Greek spend. Minimum eligible spend in Greece is EUR 200,000 for fiction features, EUR 60,000 for documentaries, EUR 45,000 for shorts, EUR 120,000 per episode for fiction mini-series of up to 16 episodes and EUR 35,000 per episode for other fiction series. Filmed stage performances, sport, news, talk shows, advertising and purely educational content are excluded, as are works that offend human dignity or promote discrimination.
3. Timing. This is the most common and least forgiving trap. The application must be filed on the State Aid Information System (OPSKE) at least ten days before the start of the investment project, and costs are eligible only from the date of filing. If works start before the application, other than preparatory pre-production, the whole project becomes ineligible. Shooting schedules, crew deal memos and location bookings should be checked against this date.
4. Eligible costs and their ceilings. Costs must be incurred and paid by the beneficiary in Greece and supported by invoices. The fees of the screenwriter, director, the two lead roles and music rights count together up to 30% of eligible costs; the executive producer's fee up to 10%; insurance and guarantees up to 5%; fuel up to 2%. Under Action A, invoices from foreign individuals or entities for the director and lead cast are accepted up to 20% of eligible costs. Marketing, fixed assets, financing costs and the producer's own equipment do not count.
5. Chain of title. Evaluators assess the investment plan, financing and cultural criteria, and the work must be lawfully produced and exploited. Before filing, the producer should hold written assignments or licences from the screenwriter, the author of any underlying work, the director and the composer, compliant with Law 2121/1993. Since Law 4996/2022 transposed Articles 18 to 22 of the DSM Directive (2019/790), authors and performers are entitled to appropriate and proportionate remuneration and to transparency reporting; agreements should reflect these rights, even though the right of revocation does not apply to audiovisual works.
6. Contracts aligned with the grant. Service-production, co-production and executive-producer agreements should allocate responsibility for the application, for keeping documents, for the audit and for the risk of a reduced or refused rebate. Because the subsidy is paid to the beneficiary's account and may not be assigned to third parties, financiers who lend against the rebate need security structured accordingly, rather than a simple assignment of the receivable.
7. Labour and permits. Cast and crew contracts, social-security registration and working-time notifications must comply with Greek labour law. Changes in shooting days do not require an amendment decision, but they must be reported in the auditor's final report, with all permits and work-schedule notifications kept up to date. Filming permits for public spaces, archaeological sites and monuments must be obtained separately.
8. Amendments. Reallocations between cost categories, changes to the physical scope or cultural content, extensions of up to six months and, under Action A only, budget increases of up to 10% may be approved on application. A new season or additional episodes always requires a new application.
9. Audit, certification and payment. Within six months of completion, the beneficiary files a completion request on OPSKE with the certified auditor's final report. EKKOMED has 30 working days to verify the file, and payment follows within three months of the certification decision. Producers should therefore budget for a gap of several months between the end of production and receipt of the rebate.
10. Remedies. A single electronic appeal may be lodged within ten days of notification of the evaluation result, as an administrative appeal under Article 25 of the Code of Administrative Procedure (Law 2690/1999). The decision on appeal is final at administrative level, so the first filing should be complete; extensions for missing documents are granted only in exceptional circumstances.
Conclusion
The current framework is more structured than the earlier regime, and EKKOMED has made clear that the evaluation will be strict: there is little room to correct a file once it has been submitted. The scheme was suspended in May 2024 to clear a payment backlog, so producers and financiers will also be watching whether disbursements keep to the timetable that the rules now set.
In practice, the rebate rewards preparation. A production that confirms its applicant structure, schedules its filing ahead of any start of works, secures a clean chain of title, aligns its contracts with the grant conditions and keeps its records audit-ready from day one is in the strongest position. Each of these steps is a legal step as much as a financial one, and each is easier to take before the camera rolls than after.