ΕλληνικάFor any company seeking to operate in the Greek defence sector, registration in the Unified Registry of Defence Sector Enterprises is the first administrative step. It is also where most of the mistakes are made, because registration is frequently presented as a certification, or as a key that opens the market by itself. It is neither. This article sets out what the registry actually is under Presidential Decree 59/2025, who may register, what must be settled before a single document is collected, and what remains necessary after registration is granted.
What the registry is, and what it is not
The Unified Registry of Defence Sector Enterprises was established by article 64 of Law 3978/2011 and constituted by Presidential Decree 59/2025 (Government Gazette A’ 113 of 30 June 2025). The competent authority for its creation, maintenance and updating is the General Directorate for Defence Investments and Armaments of the Ministry of National Defence, acting through its Directorate of Defence Investments and Technological Research. The registry replaces the former Registry of Manufacturers of Defence Material, which operated under Presidential Decree 3/2008.
It is an administrative registry, not a certification issued by a private body. The distinction is not merely terminological. Registration records that an undertaking has been entered in a particular branch following examination of its documents; it is neither a quality accreditation of its products nor a guarantee of suitability for any given tender. Marketing that promises a defence certification or guaranteed accreditation is simply inaccurate.
The three branches, and why the category is decided first
The registry is structured according to the commercial activity concerned into three branches: suppliers of defence material, divided into sub-branches of traders and manufacturers; providers of services related to defence material; and contractors for infrastructure works with a related defence object.
The branch is not chosen; it follows from the actual activity. Before any document is collected, the applicant entity, the products or services, the type of counterparty targeted and the capabilities to be relied upon must be established. A dossier assembled before the branch has been determined almost always results in re-submission.
The dual legal function of registration
The registry performs two functions at once. It is an official list of approved economic operators established in European Union Member States, and for domestic operators registered in the suppliers and service providers branches it also operates as a professional registry within the meaning of article 58(1) and article 64(3) and (4) of Law 3978/2011.
The practical consequence is that GDAEE maintains and updates e-Certis as to the existence of the registry, so that contracting authorities in other Member States may use the information it contains. A registered operator produces its registration certificate to the contracting authority for each contract; registration is not a one-off event but something relied upon in every procedure.
The transitional regime, a point often missed
Under the transitional provisions of Presidential Decree 59/2025, certificates issued under the former Registry of Manufacturers of Defence Material remain valid until they expire. For undertakings already registered under the old regime the question is therefore not whether to move to the new registry but when, and the answer depends on the expiry date of the existing certificate read against the timetable of the tenders they intend to enter. Preparation of the new dossier should begin well before expiry rather than after it.
The current guide and version control
GDAEE publishes an application guide for registration, which governs the structure of the dossier and the supporting documents. The version published at the date of this article is v.1 of August 2025. Because administrative guidance changes faster than the regulatory framework, every submission should begin with a check of the live GDAEE page and a comparison of the dossier against the current version. A saved checklist should never be treated as permanently current, and that check should have a named owner in the matter-opening list.
Groups, reliance on third-party resources and joint ventures
Where the applicant belongs to a group, or relies on resources and means made available by other undertakings, documentation is required, in particular agreements evidencing mutual commitments that those resources will remain available throughout the validity of the registration certificate. A general reference to group capability is therefore insufficient: what is needed is a contract whose duration matches the validity of the registration.
A joint venture of economic operators may be registered only where all of its members are themselves registered. That rule shapes the design of cooperation structures and should be examined before the structure is agreed, not after the application is filed.
Evidencing capability
Every capability statement must be traceable to supporting material. Corporate records, personnel, facilities, quality systems, technical experience and subcontractors should be organized so that each assertion in the dossier can be linked to a specific document. The most common failure is not an absence of capability but an inability to evidence it in the form the administration requires.
Fee and procedure
The application is addressed to GDAEE’s Directorate of Defence Investments and Technological Research, accompanied by the documents required by the guide. A fee is payable to the bank account of the Ministry of National Defence Support Unit held at the Bank of Greece in favor of the registry, in every case where a certificate is to be issued. The exact amount and payment details should be confirmed against the current guide at the time of submission.
Readiness before submission
Before filing there should be a document register, a responsibility matrix, a gap tracker and a completeness review, so that missing evidence and dependencies are identified in advance. The legal team can prepare and remediate the dossier; it cannot guarantee registration, the authority’s timing or eligibility for any particular tender. Any presentation promising such an outcome should be avoided.
What registration does not cover
Registration does not establish compliance with every tender, security, export-control or prime-contractor requirement. A foreign defence group needs a wider issues map covering corporate presence, the procurement route, capability evidence, contractual flow-downs, classified-information triggers, industrial security clearance where applicable, sanctions and dual-use and export controls. The objective is a controlled market-entry programme, not the misleading proposition that a single registry entry opens the whole defence sector.
Conclusion
Registration is a necessary step, not a sufficient condition. The correct sequence is to establish the actual activity and branch first, then check the current version of the guide, then organize traceable evidence, and only then assemble and file the dossier. The reverse order, beginning with document collection, is also the most expensive.
Frequently asked questions
What is EMEAT?
The Unified Registry of Defence Sector Enterprises, which is the Ενιαίο Μητρώο Επιχειρήσεων Αμυντικού Τομέα,established by article 64 of Law 3978/2011 and constituted by Presidential Decree 59/2025 (Gazette A’ 113 of 30 June 2025), under the competence of GDAEE.
Does it replace the old MKAY registry?
Yes. It replaces the Registry of Manufacturers of Defence Material under Presidential Decree 3/2008, while existing certificates remain valid until they expire.
What branches exist?
Suppliers of defence material, with sub-branches of traders and manufacturers; providers of related services; and contractors for infrastructure works with a related defence object.
Can a joint venture register?
Yes, provided that all of its members are themselves already registered.
Is registration enough to bid for a contract?
No. A registered operator produces its registration certificate for each contract, while the tender, security and export-control requirements are assessed separately.
What does it cost?
A fee is payable in favour of the registry in every case where a certificate is issued. The amount and payment details should be confirmed against the current GDAEE guide.
Contact
OIKONOMAKIS LAW advises on applicability and branch assessment, review of the dossier against the current version of the guide, organisation of capability evidence, group and joint-venture questions, and the wider planning of entry into the Greek defence market for foreign groups.
Email: leads@oikonomakislaw.com
Athens office: +30 21 0360 0036
Offices in Greece: Athens · Thessaloniki · Piraeus · Heraklion, oikonomakislaw.com/contact-us/
Disclaimer
This article is provided for information, reflects the position as at the legal review date stated above and does not constitute legal advice on any particular matter. The version of the guide and the documents required should be confirmed with GDAEE at the time of submission.
Sources
Presidential Decree 59/2025 (Gazette A’ 113 of 30.06.2025), constitution and operation of the registry, full text, https://www.gdaee.mil.gr/wp-content/uploads/%CE%A0%CE%94-59-%CE%A6%CE%95%CE%9A-%CE%91%CE%84-113.2025-%CE%95%CE%9C%CE%95%CE%91%CE%A4.pdf
GDAEE, Application Guide for registration, v.1 August 2025, https://www.gdaee.mil.gr/wp-content/uploads/%F0%9F%93%98-%CE%9F%CE%B4%CE%B7%CE%B3%CF%8C%CF%82-%CE%91%CE%AF%CF%84%CE%B7%CF%83%CE%B7%CF%82-%CE%B3%CE%B9%CE%B1-%CF%84%CE%B7%CE%BD-%CE%9A%CE%B1%CF%84%CE%B1%CF%87%CF%8E%CF%81%CE%B9%CF%83%CE%B7-%CF%83%CF%84%CE%BF-%CE%95%CE%BD%CE%B9%CE%B1%CE%AF%CE%BF-%CE%9C%CE%B7%CF%84%CF%81%CF%8E%CE%BF-%CE%95%CF%80%CE%B9%CF%87%CE%B5%CE%B9%CF%81%CE%AE%CF%83%CE%B5%CF%89%CE%BD-%CE%91%CE%BC%CF%85%CE%BD%CF%84%CE%B9%CE%BA%CE%BF%CF%8D-%CE%A4%CE%BF%CE%BC%CE%AD%CE%B1-%CE%95%CE%9C%CE%95%CE%91%CE%A4v.1.Aug-2025.pdf
GDAEE, registry page, https://www.gdaee.mil.gr/en/registry-of-manufacturers-of-defense-material/
Law 3978/2011, article 64, establishment of the registry, https://nomoskopio.gr/n_3978_11_64.php
National Registry of Administrative Procedures, registration procedure, https://mitos.gov.gr/index.php/%CE%94%CE%94:%CE%95%CE%BD%CE%B9%CE%B1%CE%AF%CE%BF_%CE%9C%CE%B7%CF%84%CF%81%CF%8E%CE%BF_%CE%95%CF%80%CE%B9%CF%87%CE%B5%CE%B9%CF%81%CE%AE%CF%83%CE%B5%CF%89%CE%BD_%CE%91%CE%BC%CF%85%CE%BD%CF%84%CE%B9%CE%BA%CE%BF%CF%8D_%CE%A4%CE%BF%CE%BC%CE%AD%CE%B1
Presidential Decree 3/2008 (Gazette A’ 9/2008), operating regulation of the former registry, now replaced
Prepared by Christos Oikonomakis, Chairman, OIKONOMAKIS LAW