Recent judgments of the Greek Council of State mark an important development in naturalisation cases, particularly as regards the assessment of economic integration.
The Court held that the income requirement introduced under the recent amendments to the Greek Citizenship Code cannot operate as an absolute and irrebuttable threshold. While an annual income equal to or higher than the statutory minimum wage remains a relevant criterion, it must be assessed together with the applicant’s overall financial situation, long-term economic conduct and broader evidence of integration.
In practice, this means that the Administration may not automatically reject naturalisation applications solely because the declared income falls below the prescribed threshold, especially where other evidence demonstrates economic independence, long-standing residence, property ownership, employment history or genuine participation in Greek society.
This development is particularly significant for applicants affected by the financial consequences of the COVID-19 pandemic or by periods of reduced employment. It confirms that naturalisation decisions require an individualised assessment rather than a mechanical application of quantitative criteria.
The judgments may also provide a basis for requesting the reconsideration of rejected naturalisation applications, where the rejection was based exclusively or primarily on failure to meet the income threshold.
Overall, the case-law underlines that, even in an area where the legislator enjoys broad discretion, administrative authorities must apply the legal criteria in a manner consistent with the purpose of the law, the principle of proportionality and the actual circumstances of each case.