Dispute Resolution 2026 Comparisons

There are three main dispute resolution methods in Cyprus used to resolve commercial disputes: litigation, arbitration and mediation.

Litigation

Commercial disputes are resolved at first instance before the District Courts of Cyprus. Decisions issued by the District Courts of Cyprus are binding and enforceable, notwithstanding the litigants’ right to an appeal. In addition, the District Courts may grant interim relief. For further details, see 2. Litigation.

Arbitration

Arbitration in Cyprus is regulated by the Arbitration Law, Cap 4 and the International Commercial Arbitration Law of 1987 (Law 101/1987). Arbitral awards may be declared enforceable pursuant to an application to the District Court. For further details, see 3. Arbitration and 9.2 Enforcement of Arbitral Awards.

Mediation

Mediation is regulated by the Certain Aspects of Mediation in Civil Matters Law (Law 159(I)/2012), which applies to both domestic and cross-border disputes. Mediation is a voluntary process by which the parties mutually agree to appoint a neutral mediator to assist them in reaching a settlement. Although mediation is separate from litigation, the District Courts of Cyprus may, at any stage prior to the issuance of a judgment, invite parties who have initiated proceedings before them to attempt mediation as an alternative means of resolving their dispute.

Litigation remains the dominant method of resolving commercial disputes in Cyprus. However, arbitration has become increasingly popular due to its flexibility, the faster proceedings in comparison to litigation and the relatively easy way in which arbitral awards can be declared enforceable. In contrast, although mediation is an efficient and court-encouraged form of alternative dispute resolution, it remains the least utilised of the three methods discussed above.

Furthermore, litigation in Cyprus is typically used for domestic disputes as well as in cases where urgent interim remedies are required in aid of foreign judicial or arbitral proceedings. Arbitration is particularly prevalent in construction disputes and cross-border commercial transactions. As regards mediation, it is increasingly used as a voluntary and confidential process, particularly in disputes where the parties wish to preserve their business relationships or in cases where mediation has been encouraged by the courts.

In Cyprus, commercial dispute resolution continues to develop, with a clear shift towards alternative dispute resolution methods alongside litigation. As mentioned, litigation remains the dominant method, particularly in domestic disputes and in cases requiring urgent interim remedies. However, the time-consuming nature of court proceedings have encouraged parties to explore alternative dispute resolution methods such as arbitration and mediation, which can provide faster and more cost-effective outcomes.

In recent years, arbitration has gained significant popularity, especially in construction and cross-border disputes. Its growth is supported by adherence to the New York Convention, which provides for international enforceability of arbitral awards. Arbitration clauses are increasingly included in commercial contracts, reflecting the preference of parties to use arbitration as their chosen method of dispute resolution.

Although historically less common, mediation has been steadily gaining traction, particularly in disputes where parties seek to preserve ongoing business relationships. The courts’ active encouragement of mediation under Law 159(I)/2012, combined with its confidential, cost-effective and generally faster nature, has contributed to its increased use as an alternative to litigation.

The limitation periods that apply in relation to different types of claims are regulated by the Limitation Law of 2012 (Law 66(I)/2012). The general limitation period, where legislation does not provide otherwise, is ten years from the completion of the basis of the claim. The limitation period for contractual claims is six years. The same limitation period generally applies in relation to claims founded in tort. However, specific limitation periods apply in relation to certain torts. In particular, the limitation period for negligence, nuisance and breach of statutory duty is three years and the limitation period for defamation and malicious falsehood is one year. Law 66(I)/2012 also provides that where the claim concerns the fraud of the defendant, or if the defendant intentionally concealed a fact related to the basis of the claim, or if the claim concerns a remedy of consequences inflicted because of a mistake, the limitation period does not start to run until the claimant discovers – or could have discovered by reasonable diligence – the fraud, concealment or mistake.

Furthermore, the courts may extend the aforesaid limitation periods by up to two years if this appears to be just and reasonable under the circumstances of the case.

It is important to note that the issue of limitation is examined by the court only if this matter is raised by a defendant in the proceedings. Otherwise, the court will not examine whether a particular claim is statute-barred.

Since 2023, and pursuant to major reforms in the justice system, the court structure comprises of three tiers. The courts of first instance consist of six District Courts, which deal with all civil cases as well as criminal cases concerning offences that are punished with up to five years’ imprisonment. Criminal offences that are punished with more than five years’ imprisonment are tried by the Assize Court. There are also special-jurisdiction tribunals, namely the Family Court, the Industrial Disputes Tribunal and the Rent Control Tribunal. The Administrative Court exclusively tries recourses against administrative acts of state authorities and public bodies and the International Protection Administrative Court deals with political asylum cases. There is also a Military Court, which tries offences committed by members of the military. A major legislative reform is the establishment of a Commercial Court and of an Admiralty Court: however, these do not operate yet. Admiralty cases are currently adjudicated at first instance by a member of the Supreme Court.

At the second tier is the Court of Appeal, which hears and tries appeals of civil, criminal and administrative cases.

The third tier consists of the Supreme Court and the Supreme Constitutional Court. The Supreme Court, inter alia, hears at third level appeals of civil and criminal nature on points of utmost public interest or of general public importance or on the consistency of law on conflicting decisions of the Court of Appeal. Furthermore, the Supreme Court has exclusive jurisdiction to issue prerogative orders of habeas corpus, mandamus, certiorari, quo warranto and prohibition. The Supreme Constitutional Court has, inter alia, jurisdiction to hear at third level appeals on administrative law matters on points of utmost public importance or where there are conflicting judgments of the Court of Appeal. It also has jurisdiction to decide on constitutional matters referred to by any inferior court, to try applications submitted by the President of the Republic of Cyprus contesting the constitutionality of proposed legislation and to resolve certain conflicts between institutions.

Compulsory pre-action conduct was introduced in the civil procedure by the new Civil Procedure Rules, which entered into force on 1 September 2023. In particular, the new Rules provide for three types of “pre-action protocols” which must be followed depending on the nature of the claim. In essence, the claimant must send a demand letter to the prospective defendant, setting out the basis of the claim, together with all relevant documents that support the claim. The prospective defendant must respond within the prescribed time period and declare whether the claim is accepted or refused and on what grounds. In any case, the parties are required to follow a reasonable procedure and enter into negotiations in order to avoid litigation. Failure to comply with the pre-action conduct may be taken into account by the court during the management of the case, and it may order the party who did not comply to pay those costs incurred that might have been avoided had the pre-action conduct been complied with.

However, it must be noted that compliance with the pre-action conduct is not necessary in the following circumstances:

• where the claim is of urgent nature;
• where the limitation period of the claim is about to expire; or
• for other reasonable grounds – eg, where the claimant intends to apply to the court for interim relief without prior notice to the defendant.

The main stages of court proceedings are as follows.

• Pre-action procedure –
1. Before filing a claim, parties are generally expected to follow pre-action conduct as outlined at 2.3 Pre-Action Conduct.
2. If this fails and an out-of-court settlement cannot be reached, the claimant can proceed to file a statement of claim.
• Filing the claim –
1. The claimant files a claim form with or without the statement of claim attached.
2. If it is not filed together with the claim form, the statement of claim can be filed within 28 days of serving the claim form.
3. The claim form expires within 12 months after filing unless it is served on the defendants or unless it is renewed by a leave of the court.
• Service and notice of appearance –
1. The claim form must be served on the defendant within 12 months after filing.
2. The defendant must file a notice of appearance within 14 days as of service of the claim form or of the statement of claim if that is not filed together with the claim form.
• Defence –
1. Once notice of appearance is filed, the defendant must submit their statement of defence within 28 days unless an extension is granted.
• Case management –
1. After pleadings are completed, all parties file a directions’ questionnaire within 28 days, including a list of witnesses.
2. The court schedules a case management hearing to decide whether the claim will proceed as an ordinary claim or a small claim.
3. Court instructions are issued regarding discovery, the filing of witness statements, and other pre-trial requirements.
• Hearing –
1. The case is set for hearing depending on the court’s schedule.
2. The claimant must prove the claim on the balance of probabilities.
3. After the hearing, parties present their oral or written addresses, and the judgment is reserved.
• Judgment and appeal –
1. Once issued, the judgment is binding and enforceable notwithstanding the right to an appeal.
2. Appeals can be filed within 42 days for final judgments or 14 days for interim judgments. The filing of an appeal does not automatically suspend the enforceability of the first-instance judgment, unless the court grants an order for stay regarding the entire or part of the judgment, pending the appeal.
• Timeline –
1. Civil proceedings at first instance generally take three to five years to be fully completed.

The general rule is that court proceedings are public. This includes the public conduct of all court hearings and the public announcement of the court’s judgment. However, Rule 37 of the Civil Procedure Rules of 2023 provides that the public may be precluded from the entire or any part of the trial upon a decision of the court in the following circumstances:

• in the interest of the safety of the Republic, the constitutional order or public order;
• in the interest of public safety or the public morals;
• where the interests of children or the protection of the private life of the parties so demand; or
• in other special circumstances, where in the court’s opinion the publicity would adversely affect the interests of justice.

Furthermore, the court may order that the identity of any party or witness should not be disclosed, where it is deemed that this non-disclosure is necessary for the protection of that party or witness.

In addition, according to Rule 5 of the Civil Procedure Rules, the court records in a case remain confidential and are accessible only to the parties. Any person other than the parties to the case can search the court’s files only after obtaining a specific leave from the President of the District Court, who must be satisfied that there are good reasons for granting such leave.

Interim relief, and particularly interlocutory injunctions, are commonly sought by the litigants in the Cypriot courts, especially in the context of cross-border disputes. For the key types of interim relief, please see 6.1 Availability of Interim Relief.

The key types of final relief in commercial litigation are the following:

• an award for general and/or special damages for the purpose of remedying the loss suffered by the claimant – very rarely and only in exceptional circumstances the court may also award punitive or exemplary damages;
• specific performance of a contractual obligation;
• declaratory judgment for the recognition of the rights or obligations of the parties over a particular cause or matter; and
• final injunction order of prohibitory or mandatory nature.

The general rule is that a claimant is entitled to an award for damages corresponding to the losses which the claimant proves they actually suffered. It must be noted, however, that the purpose of an award for damages differs in principle between contractual claims and claims in tort.

The damages awarded for a breach of contract aim to put the innocent party in the position they would have been in had the contract been performed, to the extent that this can be done with money. This reflects the principle of restitution. However, if the damages cannot be assessed on this basis, the court will assess the damages on the basis of the expenditure incurred by the claimant or on the basis of the benefit obtained by the defendant.

In tortious claims, the damages are assessed with the aim of putting the claimant in the position they would have been in had the wrongful act not been committed. Therefore, special damages are awarded for the monetary losses actually incurred by the claimant and which the claimant must prove during the hearing. General damages may also be awarded as a remedy for suffering that cannot be specifically assessed with money (eg, for pain and suffering in cases of personal injury).

Arbitration is a well-established dispute resolution mechanism in Cyprus, particularly in the context of international commercial disputes. It is most commonly used in sectors such as construction and shareholder disputes.

There are no general restrictions on the use of arbitration in Cyprus. However, certain matters are not arbitrable, including criminal matters and issues involving public policy, such as the winding up of companies and certain aspects of insolvency. Disputes concerning rights in rem over immovable property may also fall outside the scope of arbitration.

The main advantages of arbitration in Cyprus include:

• procedural flexibility;
• party autonomy in the appointment of arbitrators; and
• confidentiality.

Arbitration is often perceived as faster than court proceedings and allows parties to select arbitrators with relevant expertise.

Arbitration can be costly, particularly in complex international disputes, and there is only limited scope for appeal or review of awards. In practice, it does not always result in significant time savings, especially where procedural issues arise or court assistance becomes necessary.

Cyprus does not have a dominant domestic arbitral institution. The ETEK ADR Centre is among the more frequently used local options in the construction sector. In practice, parties often refer disputes to international institutions such as the London Court of International Arbitration (LCIA) and International Chamber of Commerce (ICC).

The duration of arbitral proceedings varies depending on the complexity of the dispute, but typically ranges between 12 and 24 months. Simpler or expedited matters may be resolved more quickly.

Arbitration in Cyprus is primarily governed by:

• the International Commercial Arbitration Law (Law 101/1987), which is based on the UNCITRAL Model Law; and
• the Arbitration Law (Cap 4), which applies to domestic arbitration.

Cyprus is also a party to the New York Convention.

The courts have a supportive role in arbitration, including:

• granting of interim relief;
• assistance with the appointment or removal of arbitrators;
• taking of evidence; and
• recognition and enforcement of awards.

Court intervention is generally limited and arises mainly in relation to:

• challenges to jurisdiction or the arbitration agreement;
• applications to set aside awards;
• interim measures; and
• enforcement proceedings.

Arbitral tribunals may award:

• damages;
• declaratory relief; and
• in appropriate cases, specific performance.

They may also grant interim measures, although enforcement typically requires court involvement.

Alternative dispute resolution mechanisms available in Cyprus include:

• mediation;
• conciliation; and
• expert determination.

There is no general obligation to engage in ADR, although the courts may encourage it. A refusal to consider ADR may be taken into account in costs.

Participation in ADR does not, in itself, affect a party’s right to litigate or arbitrate, unless there is a contractual requirement to do so.

ADR may take place at any stage of a dispute. As a general rule, it does not suspend limitation periods.

Mediation and similar ADR processes are generally treated as confidential.

Costs are usually shared between the parties, unless otherwise agreed.

The courts are generally supportive of ADR and may encourage parties to explore settlement.

Appendix B of the Civil Procedure Rules provides for a range of legal fees that may be charged in civil cases according to the size of the claim. Lawyers may charge legal fees according to the said Appendix B or make a different agreement with their clients. Indeed, many lawyers charge their fees on an hourly basis or agree a fixed fee for a particular legal work.

The Advocates’ Code of Conduct provides that a lawyer should take into account a number of factors, including, inter alia:

• the time needed to carry out a particular work;
• the financial situation of their client;
• the complexity of the legal issues raised;
• the urgency of the matter;
• their expertise in that particular field; and
• the possibility that they may be restricted from undertaking other legal work or clients.

In any case, the legal fees charged must be just and reasonable under the circumstances.

Third-party funding is not governed by any legislation in Cyprus. However, in a recent judgment, dated 5 March 2026, the Court of Appeal held that third-party funding is not prohibited, provided that it is made in good faith and that it is not contrary to public policy. An agreement for third-party funding may be contrary to public policy if it is made, for example, with the purpose of advancing unnecessary or abusive claims or where its content is illegal or unethical.

Contingency fee arrangements are generally not permitted in Cyprus.

According to the Law on Insurance and Reinsurance and other Related Matters of 2016 (Law 38(I)/2016), insurance coverage is available for litigation regarding both civil and criminal proceedings and for out-of-court settlements. However, it is uncertain that insurance coverage is available for arbitration and ADR since Law 38(I)/2016 is silent in this respect.

The general rule is that the losing party is ordered to pay the costs of the winning party. Nevertheless, the court has a wide discretion in awarding costs in a different manner as the court may deem appropriate under the circumstances, including an order that each party bears its own costs, or that one party pays only a specific amount of the other party’s costs, or costs incurred only after or until a specific date or before the filing of the proceedings or only in relation to a specific part of the proceedings.

In making an order as to the costs of the proceedings, apart from the aforementioned general rule, the court may take into account the conduct of the parties during the proceedings as well as whether the parties complied with the pre-action protocols provided for by the Civil Procedure Rules. Furthermore, the court may take into account a number of other factors – for example, whether the winning party was successful only in relation to a certain part of their claim or whether it was reasonable for a party to raise, pursue or dispute a particular allegation or matter.

Usually, the costs are assessed by the Registrar of the Court, according to the order of the court. However, it is possible for the parties to reach an agreement as to the amount of the costs and, provided that such amount is reasonable under the circumstances, the court will normally approve that agreement.

Article 32(1) of the Courts of Justice Law of 1960 (Law 14/1960) confers an extensive power to the courts to grant interlocutory injunctions (prohibitory, perpetual or mandatory). Even though there is no exhaustive list of the injunctions that a Cypriot court may grant, the key types of interim relief are the following.

• Freezing orders (also known as “Mareva injunctions”) – A freezing order prohibits the alienation of the defendant’s assets in order to prevent a risk of dissipation pending the adjudication of the claimant’s claim. Worldwide freezing orders are also available and extend to assets of the defendant which are located outside Cyprus. Freezing orders may under certain circumstances be issued against third persons, against whom the claimant has no cause of action but who hold assets of the defendant (“Chabra orders”). A freezing order is usually accompanied by an ancillary disclosure order for the disclosure of the defendant’s assets in order to ensure that the freezing order will be complied with.
• Order for the appointment of a receiver – When there is a risk that a freezing order will most likely be violated by the defendant and that as a result it is not sufficient to protect the claimant’s interests, the court may order the appointment of a receiver over particular assets in order to ensure that those will not be dissipated and will preserve their value.
• Norwich Pharmacal orders – These are disclosure orders usually issued against persons or entities that may have been involved in a wrongdoing, either wilfully or innocently. In this way, the claimant may secure information and documents which will enable the claimant to institute and substantiate a claim against the wrongdoers. They are also useful for the purpose of asset tracing. “Gagging orders” are usually granted simultaneously with Norwich Pharmacal orders, prohibiting the respondent from informing the suspected wrongdoers about the existence of the proceedings, mainly in order to protect the available evidence that will be disclosed pursuant to the Norwich Pharmacal order.
• Anton Piller relief – This is a very severe order allowing the claimant’s advocates and/or representatives to enter into certain premises and collect evidence over a specific matter.
• Anti-suit injunctions – These are injunctions preventing the commencement or continuation of judicial proceedings in other jurisdictions. For reasons of comity towards the courts of other sovereign states, anti-suit injunctions are very rarely granted and are entirely precluded in relation to EU member states where Regulation (EU) No 1215/2012 on civil and commercial matters applies.
• Quia timet injunctions – These are injunctions available to the applicant before the commission of an actionable wrong against them and are designed to protect the applicant from a threatened damage or violation of their rights. Essentially, quia timet injunctions may be granted where no cause of action has been generated yet against the respondent.
• Injunctions in aid of foreign proceedings – The recently enacted Articles 32(A1) and 32(AB1) of the Courts of Justice Law of 1960 (Law 14/1960) provide for the power of the Cypriot courts to grant interim relief in support of foreign proceedings, either before the commencement of or during or even after the issuance of a judgment in the said foreign proceedings.
• Injunctions in aid of domestic or foreign arbitration proceedings – see 6.2 Interim Relief to Support Arbitration and ADR.

It is generally possible for the parties to arbitration proceedings to apply to the court for interim relief in support of the arbitration, pursuant to the provisions of Article 9 of the International Commercial Arbitration Law of 1987 (Law 101/1987) and of the recently enacted Articles 32(A1) and 32(AB1) of the Courts of Justice Law of 1960 (Law 14/1960). The possibility of obtaining interim relief from the court applies both in relation to domestic and foreign arbitrations and the relevant application may be made to the court before the commencement or during the arbitration proceedings or after the issuance of the arbitral award. The power of the court to grant interim relief in support of a foreign arbitration is exercised:

• when the respondent resides within the jurisdiction of the court;
• where the property or the subject of the relief is located within the jurisdiction of the court; or
• where some other material link with the Republic of Cyprus exists.

However, it must be noted that these provisions only concern arbitration proceedings. The Cypriot legislation does not contain any provisions for the granting of interim relief in relation to other ADR methods.

According to the recently enacted Article 32(A1) of the Courts of Justice Law of 1960 (Law 14/1960), an application to the court for interim relief may be made either before the commencement of, or during the course of, or after the issuance of a decision in the context of the relevant judicial or arbitration proceedings.

A claimant who resides outside the European Union may be ordered to provide security for costs, upon an application by the defendant. The granting of an order for security for costs ultimately depends on the discretion of the court. One of the key factors to be taken into account is whether that claimant possesses assets in Cyprus which might be available for enforcement towards the defendant’s costs. Where the court orders a security for costs, it usually suspends the proceedings until such security is provided; and, where that security is not provided within the time prescribed by the court order, the court may dismiss the claim.

It is possible for a party to judicial or arbitration proceedings to apply to the court for interim injunctions. Such an application may be filed by the interested party either before the commencement of or during the judicial or arbitration proceedings in question, as well as after the issuance of a judgment on the merits of the case. The possibility to apply for an interim injunction also exists in support of foreign judicial or arbitration proceedings.

According to Article 32(1) of the Courts of Justice Law of 1960 (Law 14/1960), in order to grant an interim injunction the court must be satisfied that:

• there is a serious issue to be tried on the merits of the case;
• there is a visible possibility that the applicant may be entitled to a remedy; and
• unless the requested injunction is granted, it will be difficult or impossible to fully administer justice at a later stage.

If these three requirements are met, the court will proceed to examine whether, under the circumstances of the case, it is just and equitable to grant the requested injunctions. In addition to the aforesaid requirements, in a case where the application for an injunction is filed on an ex parte basis, that is without notice to the respondent, the applicant must also (i) establish that there is urgency in granting the injunctions before the respondent is notified of the proceedings and (ii) make full and frank disclosure of all material facts to the court. If the court is satisfied that the requested injunction should be granted without prior notice to the respondent, the court will also request that the applicant provide a security, usually in the form of an undertaking or a bank guarantee, for any damage that may be incurred by the respondent if it later appears that the injunction should not have been granted.

According to Rule 24 of the new Civil Procedure Rules of 2023, both the claimant and the defendant can apply to the court for the issuance of a summary judgment before the case proceeds to a hearing on the merits. The court may grant a summary judgment against the claimant or the defendant, either in relation to the entire claim or regarding a particular matter where:

• the courts thinks that
1. the claimant does not have real prospects of success in the claim or the particular matter, or
2. the defendant does not have real prospects of successful defence in the claim or the particular matter; and
• there is no other imperative reason why the claim or particular matter should proceed to trial.

Currently, under Cyprus law there is no provision for a single, unified class action regime. However, the Civil Procedure Rules provide mechanisms for collective redress.

Rule 20.3 of the Civil Procedure Rules clarifies that when a claimant claims a remedy to which some other person is jointly entitled with the claimant, then all persons jointly entitled to the remedy must be parties to the claim. In the event that such person does not agree to be a claimant, then that person must be added as a defendant to the claim.

Further, Rule 20.7 of the Civil Procedure Rules allows for representative proceedings, whereby numerous persons having the same interest in one cause or matter may be authorised by the court to sue or be sued through one or more representatives. The court must be satisfied that the parties share a common legal and factual interest.

In addition, Rule 3.7 of the Civil Procedure Rules provides for the joinder of parties, allowing multiple claims to be joined in a single action where their claims arise out of the same transaction or series of transactions and involve a common question of law or fact.

Finally, the Law on Issuance of Judicial Orders and Registration of Representative Actions for the Protection of the Collective Interests of Consumers (Law 91(I)/2023) implements the EU Directive 2020/1828 on representative actions for the protection of the collective interests of consumers in Cyprus. The law allows qualified entities, such as consumer organisations and designated public bodies, to bring representative actions in order to seek injunctive and redress measures on behalf of groups of consumers.

As aforementioned, Cyprus does not have a single, unified class action system. Standing in collective proceedings arises through the provisions of Rules 20.3, 20.7 and 3.7 of the Civil Procedure Rules and, in cases of consumers’ rights, through the provisions of Law 91(I)/2023 described at 7.1 Procedural Mechanisms.

In Cyprus, representative actions can provide both injunctive and compensatory relief. Under the Civil Procedure Rules, courts may grant the following:

• declaratory orders;
• injunctive relief;
• specific performance; or
• damages for actual or consequential loss.

Under Law 91(I)/2023, implementing Directive (EU) 2020/1828, qualified entities may seek both injunctive and redress measures on behalf of affected consumer groups. These include:

• refunds;
• price reductions;
• repair or replacement;
• termination of contracts; and
• compensation for losses.

In addition, the courts have discretion to order, inter alia, the immediate cessation of the infringement as well as the publication of a corrective statement.

Arbitration in Cyprus is governed by the Arbitration Law (Cap 4) and the International Commercial Arbitration Law (Law 101/1987). These laws establish arbitration as a consensual process typically involving two or more parties who have entered into an arbitration agreement, either as a standalone agreement or as a clause within a contract. While Cypriot arbitration law permits the participation of multiple parties where they are bound by the same arbitration agreement, it does not include any provisions addressing class or representative actions in arbitration proceedings.

As a result, there is no established practice in Cyprus supporting the use of class actions or mass claims within arbitration proceedings.

Overall, the landscape of class actions and mass claims in Cyprus is still developing, particularly following the introduction of Law 91(I)/2023, which enables consumer collective actions. In addition, the Civil Procedure Rules provide for representative actions and the consolidation of similar claims in certain circumstances, reflecting an increasing emphasis by the courts on efficiency and cost management.

In summary, Cyprus is transitioning from a system with limited collective litigation to one characterised by a gradually evolving mass claims framework.

Cyprus operates a structured disclosure regime under Order 31 of the Civil Procedure Rules, providing for both general and specific disclosure. There is a duty on each party to disclose documents which are or have been in their possession, custody or control, and on which they rely, or which are necessary for the proper understanding of their case. Disclosure is typically made by way of a witness statement accompanied by a list of documents.

Disclosure takes two forms: (i) general disclosure, which is mandatory and occurs at an early stage, and (ii) specific disclosure, which may be sought for identified documents or narrowly defined categories of documents that are relevant and material to the issues in dispute, including documents adverse to a party’s case.

The scope of disclosure is limited by the requirement of a “reasonable search”, taking into account:

• proportionality, including the volume of documents;
• the complexity of the case;
• the cost and ease of retrieval; and
• the importance of the documents.

The court retains broad case management powers to regulate disclosure, including refusing or limiting it on grounds such as lack of relevance, privilege, confidentiality or disproportionality.

Failure to comply may lead to adverse inferences and the exclusion of undisclosed documents at trial. Documents disclosed are also subject to an implied undertaking that they may be used only for the purposes of the proceedings, unless the court orders otherwise or the disclosing party consents.

Cyprus law recognises several categories of privilege, largely reflecting common law principles. These include:

• legal professional privilege (covering confidential lawyer–client communications for the purpose of obtaining or giving legal advice);
• litigation privilege (applying to documents created for the dominant purpose of litigation); and
• without prejudice privilege (protecting genuine settlement discussions).

Limited forms of public interest privilege may also arise. Documents covered by privilege may be withheld from disclosure and inspection, even if they are otherwise relevant.

Privilege may be waived either expressly or impliedly. Express waiver occurs where a party voluntarily discloses privileged material. Implied waiver may arise where a party relies on the substance of privileged communications (eg, by referring to legal advice), or where disclosure to third parties is inconsistent with maintaining confidentiality. Once waived, privilege is generally lost in respect of the relevant material.

There is no general right to withhold documents solely on the basis of confidentiality. Parties remain subject to their disclosure obligations, subject to relevance and proportionality. That said, the court may refuse disclosure or inspection where there are compelling confidentiality concerns. In such cases, the court will balance the need for confidentiality against the requirements of a fair trial.

Witness evidence is primarily given by written witness statements, which stand as evidence-in-chief. As a general rule, witnesses are required to attend trial for cross-examination, unless the court directs otherwise. Witnesses are subject to cross-examination and re-examination, and the court has wide powers to control the scope of evidence and questioning.

In interlocutory proceedings, evidence is usually provided by affidavit or written statement, although cross-examination may be permitted. There is no system of pre-trial depositions.

Failure to serve a witness statement in advance may result in the witness being prevented from giving evidence without the court’s permission. Witnesses may also be compelled to attend by way of witness summons.

Expert evidence is permitted but subject to the court’s control. Permission is required, and the court may limit the scope of expert evidence or direct the use of a single joint expert. Experts are usually appointed by the parties, although the court may influence or direct the process. Their evidence is typically given in written reports, supplemented where necessary by oral testimony.

Experts owe an overriding duty to the court, which takes precedence over any duty to the instructing party. Their evidence must be independent and objective, and they are expected to address all relevant matters, including those adverse to their opinion. The court may also direct joint meetings between experts or, in appropriate cases, concurrent evidence.

Different enforcement procedures apply depending on the place where the foreign judgment was issued. Judgments issued by the courts of an EU member state are generally directly enforceable in Cyprus according to the provisions of Regulation (EU) No 1215/2012 (Recast Brussels I Regulation) and no declaration of enforceability is required. In practice, the district court in which enforcement proceedings will be instituted will provide the applicant with a Cypriot case number, in the context of which the applicant may directly take enforcement measures.

Judgments issued by the courts of a country with which Cyprus has signed a bilateral treaty for mutual recognition and enforcement of judgments, may be registered and become enforceable in Cyprus pursuant to the provisions of and the procedure specified in that bilateral treaty. Usually, an application for the recognition and enforcement of that judgment in Cyprus is required. Judgments issued by the courts of the United Kingdom and of certain countries of the Commonwealth may be enforced in Cyprus according to the provisions of Mutual Enforcement of Certain Judgments of Courts of the Commonwealth Countries Law, Cap 10. An application to the court must be filed by the judgment creditor in order to have a foreign judgment registered and enforced pursuant to Cap 10. Moreover, judgments issued by the courts of a country with which Cyprus did not sign a bilateral treaty may be enforced in Cyprus by filing a court action in Cyprus based on common law (“common law enforcement”). Essentially, the basis of such Cypriot court action will be the amount awarded to the judgment creditor by the foreign court.

Foreign arbitral awards may be enforced in Cyprus pursuant to the provisions of the New York Convention of 1958 on the Recognition and Enforcement of Foreign Arbitral Awards, provided that the country in which that award was issued is a contracting state to the New York Convention. The New York Convention was ratified in Cyprus by the Law No 84/1979. Furthermore, the provisions of the International Commercial Arbitration Law (Law 101/1987) also apply, which to a large extent resemble the provisions of the New York Convention. In any case, an application must be filed to the district court for the recognition and enforcement of the foreign award and the respondent has a right to object. Regarding domestic awards, an application for recognition and enforcement is also required, either pursuant to the provisions of Law 101/1987 (if the arbitration is classified as an international commercial arbitration) or under the provisions of the Arbitration Law Cap 4.

With the exception of foreign judgments issued by the courts of an EU member state which are directly enforceable under Regulation (EU) No 1215/2012, an application for the recognition and enforcement of a foreign judgment or an arbitral award may typically take six to eight months to be fully adjudicated (including issuance of the judgment). However, this time may be prolonged depending on the complexity of the case or where the applicant applies for interim relief in the context of registration and enforcement proceedings.

The grounds for resisting enforcement of a foreign judgment or arbitral award are listed in the particular legislation or treaty pursuant to which the recognition and enforcement is sought. These grounds are quite limited and typically include the following:

• the respondent was not duly notified of the judicial or arbitration proceedings in question and the judgment or award was entered into in default of appearance of the respondent;
• recognition and enforcement would be contrary to the public policy of the Republic of Cyprus;
• the formalities provided for in the relevant legislation or treaty are not complied with by the applicant;
• the judgment debt has been paid in full;
• the foreign judgment is irreconcilable with a judgment given by a Cypriot court in a case between the same parties; and
• the foreign judgment or arbitral award is not final and binding on the parties according to the law of the country where it was issued.

In relation to arbitral awards, additional grounds for resisting enforcement may apply – eg, grounds of validity or violation of the agreement for referral of the dispute to arbitration.

Despite the fact that the use of artificial intelligence in dispute resolution is not directly regulated by any national legislation, the EU AI Act (EU Regulation 2024/1689) applies directly in Cyprus. In addition, other relevant legislations which may act as indirect safeguards for using artificial intelligence in dispute resolution are the General Data Protection Regulation (EU Regulation 2016/679), complemented by the Cyprus Data Protection Law (Law 125(I)2018).

The EU AI Act classifies AI systems used in the administration of justice or in alternative dispute resolution (ADR) as high-risk. This means that such tools must be subject to human oversight, with judges, arbitrators or mediators retaining ultimate decision-making authority. AI can assist in analysis, document review or outcome prediction, but it cannot independently decide legal disputes.

Furthermore, the GDPR Regulation and the Cyprus Data Protection Law prescribe that any AI systems used in dispute resolution, which often process personal data (including legal and financial information), must do the following:

• process such data lawfully;
• minimise collection to what is strictly necessary; and
• ensure transparency regarding how the data is used.

In addition, AI must not replace human judgment, as doing so would violate Article 6 of the European Convention on Human Rights, which guarantees the right to a fair trial. AI can therefore assist in analysis and decision support but cannot independently decide legal outcomes.

Finally, lawyers and legal professionals using AI in dispute resolution remain bound by professional responsibility rules under the Cyprus Code of Conduct for Advocates. They must ensure that AI outputs are accurate, reliable and legally sound, maintain client confidentiality, and disclose any limitations or risks associated with AI-generated recommendations. Failure to exercise due diligence could result in professional negligence or ethical violations.

At present, courts in Cyprus have not formally integrated the use of AI. Nevertheless, it is expected that AI will evolve to play an assistive role in dispute resolution, supporting legal professionals in case management while preserving the primacy of human judgment and the integrity of legal safeguards.