Banking & Finance 2025 Comparisons

Greece’s economy is expected to continue its growth trajectory in 2025, with a GDP growth rate projected at 2.3% by year-end, significantly above the euro area average; tourism and domestic consumption are expected to remain key contributors. Investment remains a crucial driver of Greece’s economic stability, particularly with the support of European Recovery funds, which continue to provide substantial liquidity for infrastructure, green, and digital projects.

As of 2025, the NPL (non-performing loan) ratio of Greek Banks has improved to 3.1% due to the securitisation transactions supported by the state guarantee programme “Hercules” (Hellenic Asset Protection Scheme – HAPS III) and secondarily to loan sales by the significant institutions. However, the high volume of loans held by servicers has increased, amounting to EUR74.8 billion (31.5% of GDP) at the end of 2024, due to additional securitisation and slow progress in the servicers’ workout processes, which weighs on the economy.

In addition, the European Central Bank (ECB) has maintained a tight monetary policy to combat inflation, resulting in rising interest rates. Headline inflation in Greece averaged 3% in 2024, 0.6 purchasing power standard (PPS) above the euro area average and is projected at 2.8% in 2025. Disinflation has been constrained by accelerating service prices and the uptick in electricity prices. In 2025, the average interest rate on loans to non-financial corporations stands at 6.5%, with rates on consumer and mortgage loans also following such a trend. While mortgage lending remains subdued, corporate lending has maintained strong growth at 12% year-over-year.

Geopolitical tensions, particularly the war in Ukraine, turmoil in the Middle East, and rising trade protectionism, such as US tariffs, pose mainly external risks to Greece’s financial stability. While Greece’s direct exposure is limited, these factors could spill over through slower euro area growth, market volatility, and pressure on asset quality. The banking sector is more resilient than in the past and supported by EU funds and solid domestic demand, but the combined application of available microprudential and macroprudential policy tools remains essential.

The high-yield bond market has played a critical role in shaping Greece’s financial market trends, particularly as the country has recovered from its debt crisis and gained investment-grade status.

The high-yield market has offered legal entities the benefit of lower yields due to Greece’s recent credit upgrades. This has led to greater diversification in financing strategies, with companies issuing bonds to secure long-term financing and investors becoming more willing to take on corporate debt at higher returns.

Additionally, the involvement of international investors in Greece’s high-yield market has increased, enhancing liquidity and encouraging more sophisticated financial structures. This trend aligns with broader European high-yield market activity, which is becoming more attractive due to the demand for yield amidst global economic uncertainty.

The Greek loan market operates as a regulated environment where lending activities are primarily reserved for duly licensed credit institutions. Other financial institutions, such as credit companies, microfinance institutions and servicers, licensed by the Bank of Greece (BoG) or benefiting from the EU passporting rules, may also provide, under certain conditions, loans or other forms of credit. Special treatment has been formed by the legal practice for bond loans, which are only issued by Sociétés Anonymes and subscribed by private placement or through a public offering.

Notably, a major regulatory change in 2023 broadened the scope of credit companies and servicers. Credit companies may now provide all forms of credit not only to individuals but also to businesses, while servicers may now provide credit for refinancing or restructuring purposes in relation to loans they manage themselves or on behalf of other servicers. Despite these changes, market uptake has so far been limited.

Regarding microfinance institutions, a key 2025 reform strengthened the framework by aligning it with EU principles of responsible microcredit. The law streamlines licensing, clarifies oversight, and modernises procedures such as liquidation and special clearance procedure, intending to foster greater access to small-scale financing and improve institutional efficiency.

HoldCos are gaining momentum in the Greek credit market. The inclusion of a holding company in the corporate structure may allow tax optimisation and efficiency with respect to dividends and interest payments.

Preferred equity is gaining ground, given the very active involvement of private equity and venture capital schemes in the Greek market. These investors have developed a range of preferred equity structures tailored to meet the specific needs of various industries, thereby enhancing flexibility and appeal for Greek businesses seeking capital.

Sustainability considerations have become increasingly embedded in Greek lending practices, particularly through syndicated financings where Greek systemic banks integrate ESG compliance requirements and indemnities for breaches. Green and sustainability-linked lending is especially prominent in the energy sector, with banks and international investors financing renewable projects and green infrastructure in line with the EU Green Deal and Fit-for-55 targets.

Beyond the environmental sector, inclusive financing initiatives have also gained ground through state-backed programmes. The “My Home II” scheme supports primary residence acquisition via co-financed housing loans, half of which are interest-free through RRF funds, while the “Upgrade My Home” programme provides co-financed loans for improving the energy efficiency of existing dwellings. These initiatives combine social policy goals with environmental sustainability, broadening the reach of sustainable finance at the retail level.

The regulatory framework is also evolving. Greece has transposed the Corporate Sustainability Reporting Directive through Law 5164/2024, which aligns with the European Sustainability Reporting Standards (ESRS), imposing enhanced reporting obligations on the ESG risks and policies of the financial institutions. In parallel, the EU Taxonomy Regulation (EU 2020/852) establishes a common classification for environmentally sustainable activities, shaping the design and labelling of ESG-linked financial products.

Credit institutions established and operating in Greece are required to be licensed by the BoG, in cooperation with the ECB, in order to provide financing to a company. Credit institutions, which may be established as

• a Société Anonyme (SA);
• a credit co-operatives of Law 1667/1986;
• a European Societe (SE); or
• a European Co-operative Society (SCE),

must meet specific requirements, which in brief are the following:

• EUR18 million in fully paid-up initial capital (different thresholds apply to credit co-operatives and branches of non-EU credit institutions);
• fit and proper assessment for shareholders, management and the key function holders (eg, risk management, CFO, internal audit);
• a comprehensive business plan covering the first three years;
• implementation of the required policies and procedures (eg, internal control, AML, IT, risk management, outsourcing, consumer protection, conflict of interest, corporate governance, etc); and
• participation in the Deposit Guarantee Scheme.

Non-bank financial institutions – such as authorised servicers, microfinance providers and credit companies – may also extend credit, subject to licensing by the Bank of Greece and compliance with AML and governance requirements. The licensing process broadly mirrors that of banks and requires, among other things, a detailed business plan, information on ownership and management (including “fit and proper” assessments), and evidence of sufficient initial capital.

EU/EEA licensed institutions can operate in Greece via EU passporting rules, while non-EU banks require a separate license from the BoG.

The Greek loan market operates within a regulated environment, where lending activities are primarily reserved for duly licensed credit institutions and other authorised financial institutions. For more, please refer to section 2.1 Providing Financing to a Company together with section 1.4 Alternative Credit Providers.

The receipt of security or guarantees by foreign lenders is not restricted or impeded in any way.

There are no restrictions or controls regarding foreign currency exchange.

In principle, there are no restrictions on the utilisation purpose of loans or debt securities. However, credit institutions are bound by Law 4557/2018 on the prevention of the use of the financial system for money laundering or terrorist financing, implementing the Directive (EU) 2015/849 (the “4th Anti-money Laundering Directive”), Directive (EU) 2018/843 (the “5th Anti-money Laundering Directive”) and Directive (EU) 2018/1673 on combatting money laundering by criminal law. Therefore, when credit institutions lend monies to borrowers, they routinely incorporate appropriate language in the debt agreements to eliminate or mitigate the risk of AML breaches. In the finance documentation, information undertakings and conditions precedent on the delivery of information by the borrower can be found, which can pertain to the nature and scope of the borrower’s anticipated use of the debt proceeds. The insertion of such language will align with the respective credit institution’s internal “know-your-customer” procedure (KYC), which has been developed and implemented to monitor suspicious operations.

Greek law does not recognise the common law concept of agency and the split of ownership under trusts. However, a concept resembling that of a security agent and trustee, which can be found in bond loans governed by Greek law, is that of a bondholder agent. In bond loans governed by Greek law, a bondholder agent is appointed to act on behalf of all bondholders, holding and enforcing security interests in its name for the account and benefit of all bondholders. This role allows for centralised enforcement and registration of security rights, effectively replicating the function of a trustee in this context.

If another law governs the bond loan, the person entitled to hold personal and in rem security interests in its name and on behalf of the bondholders is recognised by Greek law as having the powers vested in the bondholder agent. As a matter of Greek law, an additional requirement which has to be met in this case is the insertion of parallel debt language in the finance documentation so that the person can validly hold the benefit of the security interests in their own name.

The rights under a loan agreement may be contractually assigned by way of sale. A Bank may also sell a loan portfolio to a credit-acquiring company. Another option is to transfer the loans as part of a securitisation transaction, which has been substantially employed primarily by Greek banks.

A security interest is an ancillary right to that of the principal obligation it secures, and, as a result, it is transferred by operation of law together with the transfer of the principal claim it secures.

In Greece, debt buybacks by borrowers or sponsors are generally permitted under specific conditions and are used as a tool for restructuring and reducing debt. Debt buyback is found on bond loans and would entail the cancellation of the respective bonds when the borrower repays the debt. This practice is common in distressed debt scenarios or when companies have financially strong sponsors who may infuse additional capital into the business.

In Greece, “certain funds” provisions are critical and required in public acquisition finance transactions, particularly during takeovers or mergers. Such provisions have not yet become a standard part of acquisition financing in private markets, but other mechanisms, such as commitment letters, ensure deal certainty and protect sellers and buyers by reducing the risk of funding withdrawal.

Short-form and long-form agreements are used for documentation depending on the transaction size and complexity.       

Law 5193/2025 marks a significant update to Greece’s financial regulatory framework, introducing measures across digital resilience, microfinance, and sustainable finance. It supplements and transposes key EU initiatives while also enhancing the supervisory powers of the Bank of Greece and the Hellenic Capital Market Commission (HCMC). The main areas of reform include some of the following.

• Digital Operational Resilience Act (DORA): The law supplements Regulation (EU) 2022/2554 and transposes Directive (EU) 2022/2556, imposing new ICT resilience and governance obligations on financial institutions and their critical third-party providers. Oversight is shared between the Bank of Greece and the HCMC, which now hold broader supervisory and sanctioning powers.
• Microfinance institutions: The framework for microfinance has been modernised, with simplified licensing and updated procedures for liquidation and asset recovery, ensuring closer alignment with EU standards for microcredit.
• European Green Bonds and Sustainability Disclosures: The law also designates the Bank of Greece as a competent authority for implementing EU Regulation 2023/2631, equipping it with oversight and enforcement powers to supervise compliance with the European green bond regime and sustainability-related disclosure obligations.

The BoG has recently issued two significant regulatory acts introducing an enhanced corporate governance framework for financial institutions and prudential supervision rules for credit servicers and obligations for credit purchasers. In particular:

• BoG Act 243/2/07.07.2025 introduces a comprehensive corporate governance and internal control framework aligned with the European Banking Authority’s Guidelines on Internal Governance (EBA/GL/2021/05), replacing the long-standing Governor’s Act 2577/2006. It applies to credit institutions established in Greece, Greek branches of non-EEA banks and other financial institutions (e-money institutions, microfinance providers, leasing, factoring and credit providers). The Act:
1. reinforces the role of boards and independent non-executive members, clarifies the responsibilities of the key functions of the institutions (ie internal audit, compliance and risk management);
2. fosters the development of a robust internal control framework; and
3. requires the implementation of stricter policies on risk management, compliance, conflicts of interest, codes of conduct and whistleblowing.
• Significant institutions must adapt their frameworks by 1 October 2025, while less significant institutions have until 1 January 2026 to meet the board composition requirements with respect to the number of non-executive members of the board.
• BoG Act 244/25.07.2025 strengthens the prudential supervision of credit servicers by introducing stricter rules on corporate governance, risk management, suitability assessment of the BoD of the servicers, along with detailed reporting obligations on loan portfolios, collateral policies, performing and non-performing exposures, restructurings and write-offs. Servicers managing assets exceeding EUR1 billion are required to establish an Audit Committee, while servicers providing credit under Law 5072/2023 are additionally required to maintain a Risk Management Committee. The Act also extends comprehensive reporting requirements to credit purchasers and credit institutions, ensuring greater transparency and supervisory oversight.

Moreover, Law 5123/2024 modernised the legislative framework for taking security interests over movable assets and tracing their status, in line with EU and international best practices to facilitate the extension of credit. The changes incurred by Law 5123/2024 are twofold:

• firstly, they pertain to certain technical provisions regarding the creation of pledges; and
• secondly, they introduce the Single Central Electronic Registry of Pledges (the “Register”) managed by the Hellenic Cadastre.

The Register is a public database that enhances transparency and legal certainty, ensuring that pledge agreements are enforceable against third parties. The Register has commenced operation as of 30 June 2025 upon the issuance of a relevant decision by the Hellenic Cadastre, but certain operational matters are still pending resolution.

One of the key changes introduced by the law is the flexibility in how pledges are created, as pledge agreements may now be formalised through electronic means, including digital signatures and the use of government-certified electronic platforms like gov.gr. This shift away from traditional formalities speeds up the process and aligns it with modern digital practices.

The registration requirement with the Register extends to the securitisation transactions and securitisation servicing agreements of Laws 3156/2003 and 5072/2023. Moreover, the Law reiterates and specifies the concept of a notional pledge on movable assets introduced by the Greek Civil Code and repeals certain provisions of Law 2844/2000 governing the creation and operation of the floating charge on business receivables. Similar to the other forms of a pledge, notional pledges may now be digitally formalised and must be registered in the Register to ensure their validity. The law also grants parties the option to initiate enforcement through the service of a payment order, further simplifying the process. Registration with the Register is not required for pledges on claims arising from the pledgor’s bank accounts maintained with the lending bank when the bank is also the pledgee. With respect to the establishment of a pledge for shares listed on the Athens Stock Exchange or for those held in book-entry form following dematerialisation or immobilisation, provisions of Law 4569/2018 should remain applicable.

A significant change in pledge enforcement entitles the pledgee to collect the pledged claim without any further requirement after the lapse of a 10-day grace period once the secured claim becomes due. In case the pledged claim becomes due before the secured claim, the provisions of the Greek Civil Code apply. The purpose of such a provision seems to be to streamline the enforcement process by aligning the interests of the pledgees and the pledgors.

In Greece, no direct provision imposes a specific cap on the amount of interest that can be charged in loan or credit agreements. An exception would be the maximum default interest rate charged by credit institutions, which cannot exceed 2.5% per annum of the contractual interest.

For credit granted by non-bank institutions, the contractual and default interest rate should align with the reference rate determined by the Bank of Greece.

A noteworthy point is that Law 3259/2004 establishes a limitation on the overall outstanding debt in such agreements. Specifically, the total outstanding debt arising from any form of loan or credit agreement with a credit institution may not exceed three times the amount of the capital originally drawn down for each loan or credit agreement. This threshold applies to the aggregate sum of the capital drawn down across all agreements in cases involving multiple loans or credits. For current revolving accounts, the limit is set at three times the debt amount as it stood at the time of the last disbursement.

In Greece, certain financial contracts are subject to mandatory disclosure requirements, particularly for entities involved in public markets or under regulatory supervision and subject to the size and purpose of the financial contract.

Listed companies must comply with capital market disclosure requirements, which include disclosure obligations for financial reporting, including annual, semi-annual, and quarterly reports. Additionally, significant shareholding changes must be disclosed to the Hellenic Capital Market Commission (HCMC).

Credit institutions must meet additional requirements, which demand disclosure of holdings above certain levels, particularly if these holdings can influence management decisions.

The tax treatment of interest payments and related financial transactions varies depending on the nature of the credit, the type of lender, and the specific terms of the agreements.

Interest payments made under bond loans to foreign entities or Greek non-banking institutions are generally subject to a withholding tax at a rate of 15%. As an exception, interest payments on bond loans made to credit institutions are exempt from withholding tax. Pursuant to the provisions of Law 5193/2025, withholding tax in respect of the income after 11 April 2025 from listed corporate bonds, acquired by private individuals who are tax residents of Greece, was reduced to 5%.

Digital transaction duties, corporate income tax, real estate transfer tax and VAT, besides withholding tax, may be relevant to lenders making loans or taking security from entities incorporated in Greece. In particular, loans made in Greece, except for those granted by Greek banking institutions or branches of foreign banking institutions operating in Greece, are subject to digital transaction (formerly referred to as stamp duty). The applicable rate is 2.4% for loans between natural persons or between natural and legal persons, and 3.6% for loans between legal persons.

Also, there is the special levy imposed by Law 128/1975, which applies to loans provided by financial institutions operating in Greece or abroad (except bond loans). It is also worth mentioning the real estate transfer tax, which is triggered if a common facility is secured by real estate. In addition, mortgages and pledges require registration, which is subject to a registration fee currently set at approximately 0.8% of the secured amount, along with notary and registration fees. In contrast, for bond loan transactions, a reduced flat registration fee of EUR100 per security interest applies.

Tax concerns can be mitigated by properly structuring the transaction. The parties may structure the financing in the form of a bond loan, which benefits from exemptions with respect to stamp duty (now Digital Transaction Duty) and the levy of Law 128/1975.

In some instances, double taxation treaties (DTTs) are enforceable, or EU legislation could be applicable, which may reduce the withholding tax.

If a foreign lender is actively involved in managing or overseeing loans in Greece, this could constitute a permanent establishment trigger for the lender, exposing them to Greek corporate tax on their profits. Mitigation involves ensuring the proper structure of the transaction to minimise the risk that the foreign lender has a physical presence or significant business activities in Greece.

Please also refer to 4.2 Other Taxes, Duties, Charges or Tax Considerations.

Depending on the type of financing, certain assets will typically be required by the lenders to form the collateral package. Together with the form that the security typically takes, the most common assets encumbered for the benefit of the financiers are set out below.

• Ownership rights, such as shares, share units, participations and interests in legal entities: the security may take the form of financial collateral or a pledge (see Pledge below).
• Claims arising out of bank accounts, intragroup or other loans or credit agreements, insurance contracts, lease contracts, etc: the security may take the form of assignment of claims (see Assignment below) by way of pledge (for credit claims and claims on bank accounts, the security may also form financial collateral). If certain conditions are met, a floating charge may also be permissible.
• Movable assets: the security may take the form of a pledge. If certain conditions are met, a floating charge may also be permissible.
• Immovable assets: the security may take the form of a mortgage or prenotation of a mortgage (see Mortgage below).

The valid creation of a pledge in accordance with the Greek civil code would entail the delivery of the underlying asset to the lender.

In relation to the costs, each official service by a court bailiff would be in the region of EUR40.

Pledge

A pledge is perfected by execution of a private agreement with a certified date (such as a notarial agreement) or by an electronic document, service of the agreement via a court bailiff to the respective legal person and registration with the Unified Electronic Pledge Registry (the “Registry”). A share pledge, the most common security over ownership rights, should be registered with the shareholders’ book if the shares are paper-form, and the relevant certificates should be annotated. In the case of dematerialised shares, the pledge agreement should be serviced to the central securities depository and registered in its system.

Assignment

Claims are commonly secured through an assignment by way of pledge or, if certain criteria are met, under financial collateral. The assignment agreement is established by executing a private agreement with a certified date (such as a notarial agreement) or by an electronic document service via a court bailiff to the debtor of the assigned claim, which owes obligations according to the contract, and registration with the Registry. For bond loans, any annotation must be made on the physical bond certificate (if issued), and the bondholder register must reflect the encumbrance. Floating charges require registration with the competent pledge registry and service of the agreement on the pledgor. A notification form in connection with the assignment agreements should be registered with the Registy, and the agreement should be delivered to the pledgor.

Mortgage

A mortgage is perfected by the registration of the respective title, which confers the right to record a mortgage upon the lender with the competent land registry or cadastral office (as applicable). The said title is comprised of a notarial deed or a court decision. The perfection of a prenotation of a mortgage also includes the registration of the respective title, which may be a court decision, a payment order, or minutes of a mediation procedure, with the land registry or cadastral office.

The establishment of the following security interests of:

• prenotation of mortgage;
• mortgage;
• notional pledge; and
• floating charge,

is subject to a flat registration fee at the competent public registry, along with fees proportional to the secured amount (currently around 0.8%). However, the recent enactment of Law 5142/2024 stipulates that these flat and proportional fees will be redefined by virtue of a joint decision by the Ministers of Digital Governance and Economy, following input from the Hellenic Cadastre.

Specifically for bond loans, the fee for each registration of security interests with the relevant public registries is EUR100, while the fee of a notary is fixed at EUR2,500 per deed.

Subject to the above specific perfection steps required for each security, a written agreement is needed to create all security interests. If the actions are not followed, the validity of the relevant security interest may be questioned.

There is no universal or similar security interest in the Greek legislation over a company’s present and future assets. According to Greek law, an individually defined movable asset or right may become the subject of a security interest. A floating charge that can be granted over a company’s present and future assets, which are at least identifiable, is only available if the parties to the security are businesses. Future assets may be the subject of a security interest as long as they can be identified or are identifiable.

Certain restrictions apply to companies in relation to the giving of downstream, upstream and cross-stream guarantees. In principle, related party transactions are void. Special approval of such transactions by the board of directors or, exceptionally, by the general assembly of the shareholders and the publication of the announcement of such approval is required to make the transaction valid. Irrespective of the body authorising the transaction, the board of directors proceeds with publishing the announcement of the approval with the general commercial registry.

An additional requirement is imposed on companies with listed shares. The board should obtain a fairness opinion issued by an independent auditor for transparency purposes before authorising the granting of the guarantee.

The company may validly give the guarantee immediately upon obtaining the written consent of all shareholders that they will abstain from convening the general meeting to resolve this respect, or eventually ten days after the publication date of such approval in the registry.

For further information, please see 5.4 Restrictions on the Target.

Financial assistance restrictions are in place in Greece, prohibiting the target company from making prepayments, granting loans or providing guarantees for the acquisition of its own shares.

Financial assistance may be permitted if the following conditions are met:

• the financial assistance is made on an arm’s length basis;
• a report is prepared by the board of directors stating how the said transaction serves the corporate interest of the company, its terms and any liquidity or solvency risk it might entail; the report should be communicated to the general assembly of the shareholders and published in the general commercial registry;
• shareholders’ approval during the general meeting is obtained with an enhanced quorum and majority;
• the company’s net equity should meet or exceed the paid-up share capital, along with any non-distributable reserves, at all times.

The target company should record in the liabilities section of its balance sheet a non-distributable reserve in the amount equal to the financial assistance to be provided.

Stamp duty might be applicable for granting the guarantees or security, depending on whether the secured credit triggers stamp duty. Giving a guarantee or security in connection with a non-bank loan agreement might give rise to payment of a stamp duty.

A security interest is an ancillary or accessory right. That means that security rights are dependent on the underlying obligation they secure. Therefore, the security right is automatically extinguished if the debt is discharged.

To publicise the release of the security, certain formalities should be followed. The process is relatively straightforward, but it may vary slightly depending on the type of asset and the specific security involved.

If a security interest has been registered with a competent authority, such as a land registry, cadastral office, or the Unified Electronic Pledge Registry, it is necessary to either deregister the interest or update the registry to reflect the change in the beneficiary of the security interest.

The release of any type of security may also include the execution of a written agreement between the pledgor and the pledgee, confirming the repayment or discharge by other means of the secured obligation.

The Greek code of civil procedure has detailed rules governing the priority of competing security interests. These rules come into play if the auction proceeds are insufficient to cover the claims of all creditors. According to the said legislation, claims may come with privileges of the following types, which in turn determine the class of the respective creditors:

• claims established by operation of law come with a general privilege;
• claims created due to a pledge or mortgage come with a special privilege; and
• unsecured claims come without privilege.

Regarding the allocation of proceeds in an auction procedure, a distinction should be made based on when the respective debt obligations arose. For secured debts incurred before 17 January 2018, Greek law provides that the proceeds from the sale of collateral in bankruptcy are allocated after deducting bankruptcy costs and top-priority claims. In particular, 65% goes to secured creditors, 25% to creditors with general privilege (such as the tax authorities, social security funds, and employees), and 10% to unsecured creditors. If any of these creditor categories are not present, the distribution is adjusted accordingly. On the other hand, for secured debts created on or after 17 January 2018, and provided the collateral was initially unencumbered and properly registered, the order of payment prioritises certain employee claims, followed by secured creditors. Within each class of creditors, payment follows the absolute priority rule: whoever registered its security earlier gets paid first.

The priority of claims among a group of lenders or between two separate groups of lenders can be contractually varied by entering into a subordination or inter-creditor agreement. This is a common practice in syndicated loans or mezzanine finance structures involving different debt tranches.

Contractual subordination provisions should remain effective in the insolvency of a borrower incorporated in Greece so long as they do not alter the statutory ranking of creditors and do not conflict with mandatory provisions of the law. As such, claims with a general privilege (eg, unpaid social security contributions) may override any contractual subordination. Furthermore, the insolvency administrator may challenge certain transactions if deemed detrimental to creditors.

In the context of a securitisation transaction, a statutory pledge over the business receivables is established for the benefit of the bondholders over the receivables and the collections of the receivables.

In principle, enforcement of security interests typically necessitates judicial proceedings. For most forms of collateral – such as mortgages, pledges, and non-possessory pledges – creditors must obtain an enforceable title (eg, a court judgment or payment order) and proceed with enforcement through court-supervised mechanisms, such as public auctions. The process entails strict steps and procedural requirements.

Self-help remedies, where a creditor unilaterally enforces a security interest without court involvement, are generally not permitted in Greece, but are now available in Greece following the enactment of Law 5123/2024. In particular, the creditor may now collect the pledged claim without any further requirement after the lapse of a 10-day grace period once the secured claim becomes due and payable in whole or in part. In case the pledged claim becomes due before the secured claim, the provisions of the Greek Civil Code apply. The purpose of such a provision seems to be streamlining the enforcement process by aligning the interests of the pledgees and the pledgors.

For security interests established under the Legislative Decree 17.7/13.8.1923, for the benefit of credit institutions, enforcement is more streamlined; No enforceable title is required, while secured creditors may publish a notice for the public auction of the pledged assets immediately, bypassing the three-day period that applies in standard enforcement procedure.

The most expedited and straightforward enforcement process is set out for the realisation of security in the form of financial collateral. Aside from not requiring an enforcement title or the three-day waiting period, the financial collateral can be sold directly by the creditor, or the creditor may acquire ownership of the collateral and set off its value against the financial obligations owed by the debtor.

Regarding guarantees, enforcement typically involves initiating judicial action against the guarantor to obtain a court judgment. Under civil law, guarantors may raise specific defences, such as the benefit of discussion. However, in commercial contexts, guarantors often waive these defences in the guarantee agreement.

In Greece, the choice of foreign law is generally valid and enforceable in accordance with Regulation (EC) No 593/2008 (Rome I). This framework allows the contracting parties broad autonomy to select the law applicable to their contract.

However, this freedom is subject to certain limitations. Greek courts may refuse to apply a foreign law where such application would be manifestly incompatible with Greek public policy (ordre public), as provided under civil law. Public policy encompasses mandatory rules that cannot be derogated from by private agreement (ius cogens). Furthermore, pursuant to Article 33 of the Greek Civil Code, a provision of foreign law will not be applied if the effects it produces are contrary to a mandatory rule of the forum.

In addition, overriding mandatory provisions of Greek law (rules of immediate application) may apply irrespective of the parties’ choice of law, particularly in areas involving tax, customs and administrative issues.

With respect to submission to jurisdiction clauses, these are generally enforceable under Greek law. However, unilateral jurisdiction clauses – such as jurisdiction rules on exclusive competence (eg, in proceedings that concern rights in rem in immovable property, a Greek court may decline to respect the choice of a foreign jurisdiction) or clauses granting the right to sue exclusively to one party (eg, “only the bank may bring proceedings before a court of its choice”, or clauses in contracts with national authorities) – may be scrutinised by Greek (and EU) courts. If such a clause creates a significant imbalance between the parties, especially where one party is in a weaker bargaining position (such as a consumer or a small business), it may be deemed invalid.

Waivers of immunity can be upheld under Greek law, provided the entity waiving immunity has the capacity to do so. State-owned entities or sovereign borrowers may be subject to different rules depending on whether Greek or EU laws restrict their ability to waive immunity in a contract. Greek courts would review such waivers carefully to ensure they do not violate any sovereign or any Greek public law principles.

Judgments issued in other EU Member States (other than those issued in Denmark) are enforceable in Greece without retrial of the merits of the case. There are certain grounds for the refusal of the recognition of such an EU judgment, such as if the judgment is irreconcilable with an earlier judgment given in another Member State.

A judgment by a foreign court can be recognised and enforced in Greece first and foremost if it is stipulated in EU Regulations or International Conventions. Secondly, a foreign judgment against a company may be enforceable in Greece if certain conditions are met; the judgment should be final, not subject to appeal in the foreign jurisdiction and should not violate Greek public policy, and the foreign court had proper jurisdiction in accordance with the Greek law. The Greek court will not retry the merits of the case; it will merely examine if the requirements for the recognition of the foreign decision are met.

Greece is a contracting party to a significant number of international conventions related to arbitration, most notably the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (ratified by Law 4220/1961, the “NYC”).

Traditionally, the enforcement of foreign arbitral awards in Greece has been primarily governed by the NYC. However, in cases where the Convention did not apply – due to the reciprocity and commerciality reservations adopted by Greece – foreign arbitral awards were, until recently, declared enforceable only upon the cumulative satisfaction of the requirements set out in Articles 903, 905(1), and 906 of the Greek Code of Civil Procedure (GCCP), thereby imposing a more onerous standard than that established by the NYC.

This landscape has been fundamentally reshaped by Law 5016/2023 on International Commercial Arbitration (the “Greek International Arbitration Law”), which is based on the UNCITRAL Model Law, including its 2006 amendments. The new law expressly incorporates NYC’s regime and introduces a unified legal framework for the recognition and enforcement of all foreign arbitral awards.

Pursuant to Law 5016/2023, a foreign arbitral award is recognised as binding and can be declared enforceable upon written application to the competent court, in line with international standards. The enactment of this law effectively displaces the previous reliance on the GCCP provisions and establishes a clear, streamlined, and internationally aligned enforcement mechanism. Again, the Greek court will not re-examine the merits of the case but only assess whether the fulfilment of the above exists.

A foreign lender’s ability to enforce its rights under a loan or security agreement could be impeded if it were to be ruled that the said enforcement action is inconsistent with the principles of good faith and proportionality. The Greek courts could interpret this as an abusive exercise of rights and consequently render the agreement void.

The commencement of insolvency proceedings in Greece may influence a lender’s ability to enforce loans, security interests, or guarantees. Once a petition is filed for the declaration of insolvency, the court may take preventive measures to protect the debtor’s estate and prevent actions that could harm its creditors. Such measures may include suspending individual enforcement actions by creditors or prohibiting any transfer of assets from or to the debtor. In this pre-insolvency stage, enforcement actions by unsecured lenders may be suspended until the insolvency decision is published.

In contrast, secured creditors are largely unaffected by preventive measures and may be enforced against the secured assets, except in cases where there is a valid request to sell the business as a going concern and thus realise more value. Finally, creditors secured with financial collateral maintain a privileged position, being completely excluded from the scope of the preventive measures and may be enforced immediately.

During the insolvency stage, all individual enforcement actions are suspended. However, secured creditors are exempt from such suspension regarding assets over which they hold security for a period of nine months from the declaration of insolvency. After the expiry of this period, suspension extends to secured creditors’ enforcement actions. Exceptionally, individual enforcement actions of secured creditors are suspended in cases where the court decision rules the sale of the business assets as a going concern or of its individual operating units and the asset over which security has been granted forms part of these assets. In both cases, if the sale process is terminated because no satisfactory offers were received or 18 months have elapsed since the insolvency declaration without any pending auction, secured creditors regain their right to enforce for a period of nine months after the termination date. After this period, enforcement actions are suspended for them as well. The seizure of an asset from the insolvency estate by a secured creditor remains effective until the sale of such asset through public auction or the reversal of the seizure. Again, during the insolvency process, financial collateral takers are not impacted by the suspension and can continue to enforce their rights without restrictions.

Insolvency law allows for super-senior ranking of the creditors’ claims arising out of new financing in the context of rehabilitation. The super-senior privilege applies to financing provided to keep the business operational, either in the form of cash, loans, or essential goods and services. The purpose of this provision is to incentivise lenders and suppliers to offer necessary funding to keep the debtor’s business afloat during the rehabilitation phase, as these monies are vital for business continuity and for underpinning the restructuring efforts.

In all other respects, the payment order of the creditors on a company’s insolvency traces the prioritisation established in the Greek code of civil procedure.

Insolvency processes may take up to five years, from submitting the insolvency petition to the company’s discharge. A typical insolvency process may take two years to complete.

The insolvency law enacted in 2020 is currently in force and aims to streamline proceedings, improve recovery rates for creditors, and balance the interests of both debtors and creditors. However, recoveries for creditors are not always commensurate with the value of the company at the time of entering insolvency proceedings. Delays, administrative inefficiencies, and volatile market conditions may impact the realisable value of assets.

There are two available company rescue procedures outside of insolvency proceedings in Greece.

The first is an out-of-court debt settlement, which is an electronic platform-based process where the debtor negotiates and enters into a debt restructuring agreement with certain creditors, including financial institutions and the Greek state. This procedure does not require court involvement or any ratification, making it a faster and less formal alternative to judicially-driven insolvency procedures.

The second one is a rehabilitation procedure that involves a more structured approach, where the debtor and its creditors negotiate a rehabilitation agreement, including a business plan for restructuring the company’s debts. Unlike the out-of-court process, the court must ratify the rehabilitation agreement to make it binding on all parties, ensuring that it treats creditors fairly. It may allow the company to avoid insolvency by restructuring its obligations under the supervision of the court.

Both mechanisms are designed to offer flexibility and efficiency, encouraging the resolution of financial distress before insolvency proceedings become necessary.

When a borrower, security provider, or guarantor becomes insolvent in Greece, lenders may face the following risks.

Automatic Stay on Enforcement

Upon the declaration of insolvency, a temporary stay may be imposed on creditors’ enforcement actions, which can delay lenders from realising their security. While secured creditors maintain priority, their ability to immediately enforce security may be limited, particularly during restructuring efforts.

Claw-Back of Transactions

Lenders face the risk of claw-back actions, which can nullify transactions made in the period leading up to the insolvency declaration. This can include preferential payments or transfers of assets that occurred within a “suspect period” prior to insolvency.

Challenges to Guarantees

Guarantors may attempt to escape liability if the guarantee is not structured to cover amendments to the loan or changes in the financial status of the borrowing company.

Decline in the Asset Value

Delays in the liquidation process or deteriorating market conditions may reduce the value of the assets securing the credit, further impacting the recovery for secured creditors. If liquidation is not completed within 18 months, piecemeal liquidation might be forced, which can yield lower returns.

The project finance activity has remained robust through 2025, primarily driven by the continued implementation of EU funding programs, including the Recovery and Resilience Facility (RRF), supporting Greece’s ongoing environmental initiatives, digital transformation, and infrastructure modernisation efforts.

The main players sourcing project financing are in the energy industry, followed by transport, tourism, real estate, telecommunications and digital infrastructure. There are also some project financings used for waste and water management facilities.

Recent deals in the energy sector span from modest solar PV installations and wind farms to projects like the installation of submarine cables for the interconnection of islands with the IPTO.

Projects implemented via PPP structures continue to gain momentum in Greece.

Law 3389/2005 is the foundational legal framework for Public-Private Partnerships (PPPs) in Greece, facilitating collaboration between the public and private sectors in delivering infrastructure projects and public services. The law simplified the previously cumbersome process, contemplating that the PPP projects can be implemented upon approval from the Interministerial PPP Committee.

Law 4412/2016 and 4413/2016 govern public procurement in Greece, designed to align with EU legislation, cover the procurement of public works, supplies, and services and apply to both public sector agencies and entities active in regulated industries.

Significant reforms to Law 4412/2016 were introduced with the enactment of Law 4782/2021, which modernised the public procurement processes..

Depending on the specific sector in which the project is classified, other law might become relevant. For projects with energy assets, Law 3468/2006, as amended, regulates the production of electricity from renewable energy sources (“RES”), Law 4001/2011 on the operation of electricity and natural gas energy markets for the exploration, production and hydrocarbon transmission networks and Law 4014/2011, as amended, sets out the requirements for the environmental licensing of projects.

There are no prohibitions or other restrictions on the types of projects that can be executed as PPPs.

There is no requirement under Greek law that the project documents should be governed by Greek law. The parties are free to choose the law of a foreign jurisdiction to govern the project contracts.

For more, see 6.2 Foreign Law and Jurisdiction and 6.3 Foreign Court Judgments.

In principle, there are no restrictions on foreign entities’ ability to own or have real estate property in Greece. Certain restrictions apply to the acquisition of real estate located in the designated border areas of Greece by legal persons with seats outside the EU, in which case special authorisation needs to be granted by the competent public authority; otherwise, the acquisition is void.

Foreign lenders can directly exercise remedial rights on mortgages and prenotations of mortgages created on an intangible asset in the same manner as a domestic lender would (see also 3.2 Restrictions on Foreign Lenders Receiving Security).

When selecting a project financing structure, the parties should carefully assess specific commercial and jurisdictional realities rather than relying on a standard model. In Greece, where regulatory delays and zoning approvals are often time-consuming, structures that account for pre-completion risks – such as extended grace periods in loan agreements or phased equity contributions – are particularly useful.

Projects with long-term, contracted revenue streams can support higher debt ratios, allowing lenders to rely on predictable cash flows. In contrast, toll road concessions with demand risk may necessitate hybrid structures that blend availability payments with user fees. Tax considerations, including VAT treatment on construction inputs and transfer pricing rules for related-party service contracts, may also shape the project and financing structure. Ultimately, the financing structure must reflect not only project-specific risk allocation but also local legal, regulatory, and market-specific dynamics to ensure economic viability.

The various business objectives and motivations of the respective sponsors will dictate the appropriate legal structure for the project company. Commonly, sponsors combine their efforts with those of other entities by forming horizontal or vertical joint ventures. This is particularly seen in the construction and management of large, complex projects that require substantial capital outlays or resources, proprietary knowledge, or management skills, which each of the participants lacks individually.

When structuring the deal, key issues will be the amount of risk and cost-sharing, the level of control and ownership structure the participating firms wish to have, and the governance mechanism. The project company may assume any legal form permitted by the Greek legal system. In most cases, the project company is organised as a private, unlisted company (société anonyme). If this legal form is chosen, then Law 4548/2018 on the reform of Sociétés Anonymes will apply. Apart from other advantages, such as being a separate legal entity and the limited liability of the shareholders, a project company organised as a société anonyme can have greater access to funding, as it can issue bond loans. Bond loans offer beneficial tax treatment compared to other credit arrangements and flat fees for the registration of the registrable collateral.

Greece has very recently enacted Law 5202/2025, establishing a framework for the screening of foreign direct investments (“FDI”). While the law does not directly address nationalisation or expropriation, it introduces mechanisms that may significantly impact foreign investments in sectors considered sensitive to national security or public order.

Under this law, FDIs in sectors such as energy, transport, healthcare, information and communication technologies, digital infrastructure, defence, and tourism infrastructure in border areas are subject to mandatory notification and review. Investments that result in a shareholding of 25% or more trigger a screening process.

The Interministerial Committee for Screening of the Foreign Direct Investments conducts the initial assessment, and the Minister of Foreign Affairs issues the final decision in cases requiring an in-depth investigation. The authorities have the power to approve, impose conditions, or prohibit the investment. Non-compliance with the notification requirement can lead to the reversal of the investment and administrative sanctions ranging from EUR5,000 to EUR100,000, or even up to twice the value of the investment in certain cases.

For more information, see 8.4 Foreign Ownership.

In the Greek market, projects are predominantly financed by local and international commercial banks, with bond loans being the most common structure. We have also witnessed projects involving the significant import of foreign equipment or technology, which rely on export credit agencies to provide guarantees or lend directly. Multilateral institutions also play a crucial role by providing long-term financing, guarantees, and co-financing solutions for large-scale projects. Blended financings are also frequently seen in project finance deals. Multilaterals often combine their resources with governmental programmes (such as Greece’s Recovery and Resilience Facility) to de-risk investments and attract private investment.

Generally, there are no statutory limitations on the export of natural resources from Greece. Due to recent geopolitical tensions, the EU has imposed comprehensive export restrictions targeting specific countries. These sanctions include bans on the export of goods that might contribute to these countries’ military, technological, or industrial capabilities. Export prohibitions apply to dual-use goods, advanced technology items, and certain energy sector equipment, aiming to curb the military and economic infrastructure of sanctioned countries.

A series of legislative instruments governs the environmental regulatory framework in Greece. For instance, for projects in the energy and infrastructure sectors, Laws 4014/2011, 4685/2020, 4964/2022, and 5037/2023, as amended and currently in force, regulate the environmental licensing process. In particular, Law 3468/2006, as amended, regulates the production of electricity from renewable energy sources (“RES”), Law 4001/2011 on the operation of electricity and natural gas energy markets for the exploration, production and hydrocarbon transmission networks and Law 4014/2011, as recently amended, sets out the requirements for the environmental licensing of projects. Furthermore, the recent enactment of Law 5215/2025 established a comprehensive regulatory framework for the production and integration of biomethane and hydrogen in Greece for the first time. Law 5215/2025 introduced Greece’s first comprehensive framework for the production and integration of biomethane and hydrogen, marking a significant step towards diversifying the country’s clean energy mix. Greek banks and investors must also adhere to additional environmental standards, which are also incorporated as obligations in the project financing documentation.

The regulatory body overseeing environmental laws is the Ministry of the Environment and Energy, which oversees these approvals.

The most significant legal framework is Law 3850/2010, as amended and in force, along with Law 5053/2023 and specific legislative provisions, in compliance with EU law (primarily EU Directive 89/391/EEC) regarding the health and safety of workers in Greece. The prevention of workplace accidents, the implementation of preventive measures to ensure workplace safety, and equal treatment among workers are issues that fall within the scope of this legislation. Lenders and investors often require evidence of adherence to health and safety standards, such as documented risk assessments and health and safety plans, as part of due diligence processes. Additionally, Law 4808/2021 introduced innovative provisions, including the obligation for businesses employing more than 20 people to adopt a policy for the prevention of violence and harassment in the workplace. The Hellenic Labour Inspectorate is responsible for the inspections and enforcement of such rules.