A creditor seeking to enforce a judgment in Greece may obtain information on the debtor’s assets through various means, including searches in digital databases such as the Land Registry (Hellenic Cadastre), the General Commercial Registry (Genikó Emporikó Mitróo, or GEMI), and the official e-auction platform. Additional information may be accessed by filing requests with public authorities, depending on the nature of the assets sought.

General Means of Identifying Assets

Hellenic Cadastre

The Hellenic Cadastre is a centralised, map-based land registration system that records real property rights across most regions of Greece. Access to the records is available online. Only authorised representatives such as lawyers and notaries can access these records. Key functions and services of the Hellenic Cadastre include:

• access to accurate identification of ownership and other rights (eg, usufruct, easements, mortgages) over real property;
• changes in ownership due to sales or inheritance;
• information on whether the real property in question is the subject of a legal dispute; and
• access to title deeds and relevant underlying documents.

In certain areas of Greece, the older system of Land Registry Offices remains in force, pending full transition to the Hellenic Cadastre. These areas are still governed by the traditional regime of transcriptions and registrations. Property rights are recorded chronologically in hard copy and access requires in-person visits.

General Commercial Registry

GEMI provides free-of-charge detailed information on:

• a company’s name, seat, tax identification number, and articles of association;
• a company’s management, shareholders, and corporate ownership;
• annual financial statements, depending on the type of the company registered; and
• the status of a company (ie, initiation of restructuring proceedings, declaration of insolvency, or liquidation).

The publication of the company’s management and partnership may be of essence, given that – under Greek law – one’s shares in a company are subject to seizure. Also, in some cases (depending on the company type), partners may also be liable for the company’s debts.

GEMI is accessible to the general public via its website. If a company fails to upload its annual financial statements, any further publication is suspended.

Digital Insolvency Registry

The Digital Insolvency Registry is an online database listing insolvent persons and entities, including basic information (eg, names and tax identification numbers) about insolvency proceedings. Detailed records, including information about third-party claims “announced” to the insolvency administrator, can be inspected in hard-copy books held at the locally competent court of first instance.

Financial institutions

Under Greek law, bank secrecy is strictly protected. As a rule, a creditor cannot obtain information as to whether the debtor holds bank accounts with a Greek bank, nor the balances or encumbrances of such accounts. By exception, a creditor who holds a first-instance judgment – whether from a Greek or a foreign state court – may serve a provisional attachment note upon a bank as third party. In that case, the bank is under a duty to respond within eight calendar days, disclosing whether it maintains accounts in the debtor’s name, the corresponding balances, and any existing encumbrances.

Tiresias credit bureau

The Greek credit reporting system is operated by Tiresias SA, a private company supervised by the Bank of Greece. It maintains databases on individuals’ and companies’ credit history, including non-performing loans, bounced cheques, and court-imposed payment orders. Banks use this information to assess creditworthiness. Access is restricted, in order to ensure data protection and privacy, and entries are kept for limited periods.

Administrative authorities

Under specific circumstances and should legitimate interest be proven, tax authorities may disclose information on a person’s declared income, property, and assets. For this purpose, an order by the locally competent Attorney General must usually be issued.

e-Auction

Auctions in Greece are conducted digitally on the official website of the Greek State, e-Auction, and are managed by competent notaries. The e-Auction platform is accessible to anyone without charge. It provides information on real properties to be auctioned (eg, the location of the property, the owner-debtor, initial bidding price).

Miscellaneous registries

Other useful registries are:

• the ships registry and the aircraft registry;
• the Intellectual Property Organization (IPO)’s trade mark registry;
• the Electronic Pledge Registry (for the establishment and enforcement of pledge rights ‒ ie, pledge over movable property without delivery of the encumbered items to the pledgee, or pledge on registered instruments, claims and rights – through a unified and modern legal framework).

Litigation Proceedings for Identifying Assets

Identifying assets through litigation is limited. In the pre-judgment phase, exhibit production decisions can potentially be of help to creditors – albeit having to satisfy a very high procedural threshold to be successful. In the post-judgment phase, reference is made to the analysis under “Financial Institutions” in this section.

If enforcement is – or is very likely to be – unsuccessful owing to lack of assets owned by the debtor, the creditor may apply for a court order compelling the debtor to:

• submit a detailed list of its asset alienations in the past five years; and
• be sworn under oath as to the list’s accuracy and completeness.

Post-judgment, assuming the judgment is enforceable, competent court bailiffs can track down and seize movable and immovable property of the debtor. Irrespective of whether assets have been identified, various tools are available to seize property, impose freezing orders, or establish judicial escrows.

In Greece, court judgments are categorised based on several criteria.

Participation of Litigant Parties

• Adversary proceeding judgments – all litigant parties participate in the proceedings by appearing before court on the day of the hearing, if required, and submitting written pleadings and exhibits.
• Default judgments – these are issued when at least one of the parties does not participate in the proceedings and is not deemed legally represented by another party. The legal consequences of default vary, depending on who is the party in default (ie, claimant or respondent) and whether the party in default was legally summoned. As a general rule, in the case of default by claimant, the case is dismissed, unless the respondent has a legitimate interest that the case be tried or has filed a counterclaim. If the respondent is in default and the lawsuit is admissible and legally valid, a presumption is made that respondent confesses to the facts presented in the lawsuit. The lawsuit is, thus, granted. If served with the default judgment, and if there was a serious ground for the default (eg, a force majeure event), the party in default may file to set aside the default judgment. Without service to the respondent, the default judgment remains unenforceable.

Relief Sought and Granted

• Declaratory judgments – these judgments establish the existence or non-existence of a legal relationship or right. Declaratory judgments are not enforceable and yet, if they declare the validity of a monetary claim, they can ground payment orders.
• Constitutive judgments – these judgments establish, amend or nullify legal relationships that did not exist prior to the handing down of the judgment, becoming effective once rendered definitive. Constitutive judgments are not enforceable. Rather, they are binding not just on the parties but on any third party, upon becoming “definitive” (more on this notion in “Enforceable Titles” at the end of this subsection).
• Performance judgments – these judgments order the respondent to perform or refrain from specific actions (eg, awarding damages). They are enforceable, provided legal conditions are met.

Binding Effect

• Final judgments – these judgments uphold or reject (in whole or in part) claims, adjudicating a dispute in a binding way. Only final judgments that are not or no longer subject to an appeal or to an application to set aside owing to default are vested with enforceability and res judicata effect. Under certain conditions, first-instance judgments may be provisionally enforceable, even if they produce no res judicata effect. Final judgments that produce res judicata effect and enforceability may still be challenged either:
1. through an appeal on cassation before the Supreme Court for legal errors; or
2. through an application for reconsideration due to grave irregularities (eg, procedural fraud, or corruption of judge).
• Non-final judgments – these judgments are of preparatory nature and usually regulate procedural matters (eg, postponing the progress of pending proceedings, or ordering performance of certain procedural acts or the furnishing of documents). They are not enforceable.

Revocability

• Final judgments are irrevocable. They may be subject to an appeal before a higher court, an appeal on cassation before the Supreme Court, an application for reconsideration before the court that has issued them, and – if issued in default – to an application to set aside a default judgment.
• Non-final judgements are revocable. They are not subject to any means of appeal. Means of appeal filed against a final judgment are considered to have been filed against any non-final judgments issued before the final one.

Subject Matter

Judgments are also discerned according to whether the court tried the case on its merits or whether it only dealt with a procedural matter, usually rejecting the action as inadmissible.

Injunctive Relief

• Injunctive measures – in the case of imminent risk, injunctive relief is ordered to prevent or mitigate immediate harm until an ordinary hearing on the lawsuit can be held or possibly even until a first-instance judgment in the merits is issued. The court is at liberty to order any means it deems necessary and appropriate for the case at hand. Judgments ordering provisional measures do not resolve the dispute in a final way and do not form enforcement titles.
• Provisional orders – they provide immediate relief until the hearing on provisional measures is held. Depending on the urgency of each case, provisional orders may even be issued on the same day the application for interim measures is filed. They normally contain little to no reasoning. Under exceptional circumstances, they may even be granted without the counterparty being summoned.

Enforceable Titles

Per Article 904 of Greek Code of Civil Procedure (GrCCP), as a general rule, only definitive judgments (see “Relief Sought and Granted”) are enforceable. First-instance judgments may also be enforceable if declared provisionally enforceable by the court. Other enforceable titles are:

• arbitral awards;
• trial transcripts evidencing settlement reached before the court or determining procedural costs;
• notarial deeds;
• payment orders or orders for return of use of leased property;
• foreign titles declared enforceable; and
• any orders and deeds deemed enforceable under law.

Once an enforcement title is obtained, enforcement proceedings may be initiated, in accordance with the provisions of the GrCCP.

Types of Claim

The enforcement procedure – as well as the means of enforcement – vary depending on the nature of the enforceable claim, as follows.

• Non-monetary claims – these concern:
1. the delivery recovery of possession of movable assets or anonymous debt instruments (Articles 941–942 of the GrCCP);
2. the delivery the recovery of possession of immovable property (Article 943 of the GrCCP);
3. the performance of an action that can also be performed by a third party (Article 945 of the GrCCP) or an action that can only be performed by the debtor (Article 946 of the GrCCP);
4. the omission or acceptance of a certain act (Article 947 of the GrCCP);
5. the ordering of the debtor to provide a declaration of will (Article 949 of the GrCCP); and
6. the delivery or return of a child in matrimony disputes (Article 950 of the GrCCP).
• Monetary claims (Articles 951–1054 of the GrCCP) ‒ enforcement is conducted either through seizure of the debtor’s assets or through a judgment regarding compulsory administration (Article 1034 of the GrCCP) or personal detention (Article 1047 of the GrCCP). Depending on the material of the enforcement, it is categorised into:
1. seizure (Article 951(1) of the GrCCP):
1. of the debtor’s movable property in their possession (Articles 953–981 and Articles 1017–1021 of the GrCCP) or in the possession of a third party (Articles 982–991 of the GrCCP);
2. of real property, ships, and aircraft (Articles 992–1016 and Articles 1017–1021 of the GrCCP); and
3. of special assets (Articles 1022–1033 of the GrCCP);
2. compulsory administration (Article 951(1) of the GrCCP and Articles 1034–1046 of the GrCCP); and
3. personal detention (Articles 1047–1054 of the GrCCP).

Direct-Indirect (Principal) vs Auxiliary Enforcement

Enforcement proceedings are further divided into three categories, based on the manner performed and the result they bring about, as follows.

• Direct (or physical) enforcement – the claim is satisfied directly and with a natural way (eg, through the forcible removal of the movable asset from the debtor’s possession (Article 941 and Article 942 of the GrCCP) or through the forcible removal of the debtor from the property (Article 943 of the GrCCP)).
• Indirect enforcement – the debtor is forced to voluntarily perform its obligation under the threat of adverse consequences befalling thereon in the event of non-performance (eg, when the debtor is ordered to perform a certain action (Article 946 of the GrCCP) or to omit and/or accept a certain action (Article 947 of the GrCCP)).
• Auxiliary enforcement – the compliance of the debtor cannot be achieved through direct or indirect enforcement. The debtor’s obligation is rendered as a result into a monetary claim (Article 945 and Article 948 of the GrCCP), which is enforced through the GrCCP provisions for enforcement of monetary claims.

Objective Versus Personal Enforcement

Enforcement may be further categorised as objective (ie, against property) or personal (ie, against the person), as follows.

• Enforcement against the debtor’s property – this is directed at the debtor’s property, either entirely (total enforcement in bankruptcy proceedings) or only targeting specific assets sufficient to satisfy the claim (individual enforcement). Bankruptcy proceedings generally preclude individual enforcement.
• Enforcement against the debtor itself – this is directed towards the debtor personally, including personal detention and compulsory administration of the debtor’s property or business.

Procedural Steps

The procedure for enforcing a domestic judgment in Greece typically comprises the following steps.

• Obtaining of an enforceable title – see 2.1 Types of Domestic Judgments (Enforceable Titles).
• Issuance of a writ of enforcement by the court or the authority that has issued the enforcement title ‒ this entails the affixation both of the heading “In the Name of Greek People” and the declaration “The competent bodies are ordered to enforce the present title” to the original enforceable title. The original enforceable title (with these two affixations) is then stamped and signed by the competent judge or notary public (in the case of notarial documents for enforceable titles) and the secretariat of the court. The writ of enforcement is issued against payment of a fee calculated on the basis of the amount of the claim for which enforcement is sought.
• Service of a true copy of the writ of enforcement along with an enforcement order (ie, invitation of the debtor to voluntarily comply with the writ of enforcement) signed by a lawyer is served upon the debtor.
• Following service of the enforcement order, the debtor has three business days to voluntarily comply with its obligations (Article 926(1) of the GrCCP). Upon lapse of this deadline, enforcement measures may be imposed on the debtor.

No enforcement proceedings may be initiated from August 1st to August 31st(Article 940A of the GrCCP).

Enforcement-Related Costs

Enforcement costs are borne by the debtor, but are advanced by the creditor (Article 932 of the GrCCP). These include all necessary costs incurred by the creditor for the enforcement proceedings from commencement to conclusion. Typical costs involved in enforcement proceedings relate to:

• the fees for the issuance of the writ of enforcement;
• statutory attorney’s fees for the drafting of the enforcement order (Article 72 of the Code of Lawyers);
• the service of the writ of enforcement and of the enforcement order upon the debtor by a competent court bailiff;
• the imposition of attachments on the debtor’s assets;
• expert fees (Article 954(19(2)) of the GrCCP);
• fees of keepers and persons appointed as sequestrators (Article 956 of the GrCCP) for safekeeping of attached property;
• court bailiff fees;
• publication of enforcement-related reports;
• excerpts from notary attachment reports for the purposes of conducting auctions of the debtor’s property; and
• enforcement-related litigation (in the event that the debtor challenges the validity of the enforcement order or of the imposed enforcement measures).

Costs incurred due to the creditor’s excessive diligence or own fault in seeking to enforce its claim(s) are not recoverable.

Timing Considerations

The duration of enforcement proceedings varies significantly depending on the specifics of each case, such as the type of enforcement and any objections raised by the debtor. By way of example, enforcement for the recovery of real property possession may be completed within a single business day, whereas enforcement of a monetary claim typically spans several months – from the initial attachment to the auction of the seized asset. Real property may be auctioned no earlier than seven months and no later than eight months from the date of seizure.

If the debtor files an objection against the enforcement measures and obtains a stay of enforcement, the proceedings remain suspended until a first-instance judgment is issued on the objection. Owing to the heavy backlog in Greek courts, such objections often take years to be heard ‒ for example, an objection filed in 2025 may not be scheduled for hearing until 2035.

Attachment of Debtor’s Assets Held by Third Parties

The most time- and cost-efficient method of enforcing a monetary claim (see 2.2 Enforcement of Domestic Judgments) is through the attachment of the debtor’s assets held by third parties. In essence, the creditor targets claims the debtor may have against third parties ‒ most commonly Greek banks ‒ and seizes them directly (see also 1.1 Options to Identify Another Party’s Asset Position (Financial Institutions)).

To that end, the creditor serves the enforcement title and an attachment notice upon the third party through a court bailiff. Once served, the third party is required to file a declaration with the competent court of first instance, stating whether the debtor has any claims against it – in the case of banks, whether the debtor maintains accounts, the exact balance, and any encumbrances thereon. If such claims are seized, they are automatically transferred to the creditor by operation of law.

Please refer to the analysis in 1.1 Options to Identify Another Party’s Asset Position (Financial Institutions) in conjunction with 2.3 Costs and Time Taken to Enforce Domestic Judgments (Attachment of Debtor’s Assets Held by Third Parties) and 1.1 Options to Identify Another Party’s Asset Position (Litigation Proceedings for Identifying Assets).

Please refer to the analysis in 2.3 Costs and Time Taken to Enforce Domestic Judgments(Timing Considerations).

Objections Against Enforcement Actions

Per Articles 933–937 of the GrCCP, a debtor subject to enforcement proceedings in Greece may challenge the validity of the enforcement measures and seek their annulment. Such objections may relate either to the validity of the enforcement title itself or to defects in the enforcement process — for example, irregularities in the service of the enforcement order.

Process for filing objections

Objections are filed with the locally competent court of first instance (Article 933(1) of the GrCCP). Such objections must contain at least one ground for challenge. Additional grounds can be brought forward through a subsequent court document, which must be filed and served upon the counterparty at least eight calendar days before the hearing (Article 933(3) of the GrCCP). According to the law (Article 933(2) of the GrCCP), the hearing must be scheduled within 60 days from filing of the objection. This provision is never observed in practice (see 2.3 Costs and Time Taken to Enforce Domestic Judgments (Timing Considerations)).

Deadlines

In cases of indirect enforcement (see 2.2 Enforcement of Domestic Judgments (Direct-Indirect (Principal) Versus Auxiliary Enforcement)), the objection must be filed within 45 calendar days from the imposition of the attachment or the garnishment (Article 934(1)(a) of the GrCCP). In cases of direct enforcement, the deadline is 30 days from the last act of enforcement (eg, the service of the writ of execution to the debtor), as per Article 934(1)(b) of the GrCCP.

Tiered approach

The GrCCP mandates a tiered approach to addressing irregularities in enforcement acts. Each act of enforcement is deemed autonomous and must be separately challenged within a specific timeframe. Failure of the debtor to meet this requirement leads to the irregularity in the act of enforcement being deemed waived and thus cured. The annulment of a single act of enforcement does not automatically affect subsequent acts of enforcement. These must be challenged separately.

Suspension of Enforcement Proceedings (Article 938 of the GrCCP)

Please refer to 2.3 Costs and Time Taken to Enforce Domestic Judgments (Timing Considerations). Following the filing of an admissible objection against enforcement measures and its proper service upon the creditor, the debtor may seek stay of enforcement until a judgment on its objection is issued. If an appeal is filed against said judgment, enforcement may remain suspended until a judgment on the appeal is issued.

The application for a stay of enforcement is tried by the court before which the objection is pending. The enforcement is suspended if the court is satisfied that:

• there is an imminent risk that the enforcement may lead to the debtor’s interests being irreparably harmed; and
• at least one of the grounds of the objection against enforcement appears to be prima facie valid.

Pursuant to Article 938(2) of the GrCCP, in enforcement proceedings against real property for the satisfaction of monetary claims, a stay of enforcement is not permitted. A stay may only be granted only at the appellate stage, if the judgment on the objection is appealed and the court of second instance orders the suspension.

Please refer to 2.1 Types of Domestic Judgments (Relief Sought and Granted). As a general rule, only definite performance judgments are enforceable (see 2.1 Types of Domestic Judgments (Enforceable Titles)). First-instance judgments that have been declared provisionally enforceable by the court may also be enforced. Constitutive and declaratory judgments are not enforceable.

No central register of judgments exists. Case files are kept with the court and only the parties to the proceedings are allowed access.

In recent years, for judgments issued by the courts in Athens, Piraeus, Thessaloniki and several other large cities across Greece, any interested party to the proceedings may apply for the receipt of a digitally certified copy of a judgment. Using the filing number of a judicial document (eg, a lawsuit or an appeal), any interested party may receive information on the status of the proceedings on “Solon”, the official website of the Greek Judiciary.

Enforcing foreign judgments in Greece is a complex process entailing a large number of legal issues. The complexity lies in the fact that legal practitioners have to navigate a large set of potentially applicable provisions stemming from the GrCCP, the bilateral agreements concluded between Greece and third countries (which have more than doubled in number since 1980), the multilateral conventions to which Greece is party (mainly deriving from the Hague International Conference on Private International Law), and – most importantly – a double-digit number of EU regulations. What is more, these instruments are regularly amended, thereby introducing issues of a transitional nature.

The aforementioned international instruments take precedence over the GrCCP provisions as per the clear letter of both the GrCCP (Article 905) and the Greek Constitution (Article 28). EU regulations take precedence over all other legislative frameworks, followed by international treaties (bilateral and multilateral), and lastly the domestic framework of the GrCCP.

EU Law

The main EU regulations that regulate enforcement of judgments in civil and commercial matters within the EU are:

• Regulation (EU) No 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters (“Brussels I Recast”), replacing Regulation (EC) No 44/2001 – Articles 36–60 (Articles 32–58 of Regulation (EC) 44/2001) are of interest;
• Regulation (EC) No 805/2004 creating a European Enforcement Order for uncontested claims;
• Regulation (EC) No 861/2007 establishing a European Small Claims Procedure – Articles 20–23 are of interest;
• Regulation (EC) No 1896/2006 creating a European order for payment procedure;
• Regulation (EU) No 655/2014 establishing a European Account Preservation Order procedure to facilitate cross-border debt recovery in civil and commercial matters;
• Regulation (EU) 2015/848 on insolvency proceedings (recast), replacing Regulation (EC) No 1346/2000 – Articles 19–33 (formerly Articles 16–26) are of interest;
• Regulation (EU) No 650/2012 on jurisdiction, applicable law, recognition, and enforcement of decisions and acceptance and enforcement of authentic instruments in matters of succession and on the creation of a European Certificate of Succession – Articles 39–61 are of interest;
• Council Regulation (EU) 2019/1111 on jurisdiction, recognition, and enforcement of decisions in matrimonial matters and matters of parental responsibility, and on international child abduction, replacing Council Regulation (EC) No 2201/2003 – Articles 30–75 (Articles 21–52 of Council Regulation (EC) No 2201/2003) are of interest;
• Council Regulation (EC) No 4/2009 on jurisdiction, applicable law, recognition, and enforcement of decisions and co-operation in matters relating to maintenance obligations – Articles 16–38 are of interest; and
• Council Regulation (EU) 2016/1103 implementing enhanced co-operation in the area of jurisdiction, applicable law, recognition, and enforcement of decisions in matters of matrimonial property regimes, and Council Regulation (EU) 2016/1104 implementing enhanced co-operation in the area of jurisdiction, applicable law, recognition, and enforcement of decisions in matters of the property consequences of registered partnerships.

For the enforcement of judgments issued in other EU member states under the above-mentioned instruments, no declaration of enforceability (“exequatur”) is required.

Multilateral Treaties

Greece has acceded to a series of multilateral international conventions, which have either exclusively focused on – or included within them – the issues of recognition and enforcement.

Two Lugano Conventions

The first category includes the two Lugano Conventions on jurisdiction, recognition, and enforcement of judgments in civil and commercial matters.

• The first Lugano Convention was signed on 16 September 1988, ratified in Greece by Law 2460/1997, and came into force on 1 September 1997. It linked the EU member states with those of the European Free Trade Association (EFTA). Articles 25–51 are the relevant articles.
• The second was signed on 30 October 2007, ratified by the EU on 18 May 2009, and came into force for all its member states on 1 January 2010. Norway has applied the new convention since 1 January 2010, Switzerland since 1 January 2011, and Iceland since 1 March 2011. Articles 32–58 are the relevant articles. Article 69, paragraph 6 of the new convention provided for the abolition of the first Lugano Convention. Thus, after the expansion of the EU, the new convention now pertains to the relationships of EU member states with three countries: Switzerland, Norway, and Iceland.

Hague Conference on Private International Law

This second category includes the following instruments:

• the Convention of 2 October 1973 on the Recognition and Enforcement of Decisions relating to Maintenance Obligations, ratified by Law 3171/2003 and in force in Greece since 1 February 2004 – relevant articles are Articles 19–33;
• the Convention of 29 May 1993 on Protection of Children and Co-Operation in Respect of Intercountry Adoption, ratified by Law 3765/2009 and in force in Greece since 1 January 2010 – relevant articles are Articles 23–27 and Article 2, paragraph 6, which records the conditions for recognising foreign adoptions;
• the Convention of 19 October 1996 on Jurisdiction, Applicable Law, Recognition, Enforcement and Co-Operation in Respect of Parental Responsibility and Measures for the Protection of Children, ratified by Law 4020/2011 and in force in Greece since 1 June 2012 – relevant articles are Articles 23–28;
• the Convention of 30 June 2005 on Choice of Court Agreements, signed by the EU on 1 April 2009 and in force since 1 October 2015 – relevant articles are Articles 8–15;
• the Hague Convention of 13 January 2000 on the International Protection of Adults – relevant articles are Articles 22–27;
• the Convention of 23 November 2007 on the International Recovery of Child Support and Other Forms of Family Maintenance, signed by the EU on 6 April 2011 and in force since 1 August 2014 – relevant articles are Articles 19–35; and
• the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters, adopted by the Council of the EU on 12 July 2022 (except for Denmark) and in force in Greece since 1 September 2023.

United Nations

This third category includes the following conventions and model laws:

• the Geneva Convention of 19 May 1956 on the Contract for the International Carriage of Goods by Road (CMR), ratified by Law 559/1977 – the relevant article is Article 31, which prevails over Regulation 44/2001;
• the 1958 Convention on the Recognition and Enforcement of Foreign Arbitral Awards (the “New York Convention”), ratified by Legislative Decree 4220/1961 (see 4.1 Legal Issues Concerning Enforcement of Arbitral Awards);
• the 1965 Convention on the Settlement of Investment Disputes Between States and Nationals of Other States (the “ICSID Convention”), entered into force on 14 October 1966 and ratified in Greece by Compulsory Law 680/1968 – Articles 53–55 are the relevant articles; and
• the UNCITRAL Model Law of 30 May 1997 on Cross-Border Insolvency, adopted into Greek law by Law 3858/2010 (Adaptation of Greek Law to the 1997 UNCITRAL Model Law on Cross-Border Insolvency) and other provisions – Articles 15–24 are the relevant articles.

Bilateral Agreements

To date, Greece has ratified the following bilateral judicial assistance agreements in civil matters, which are currently in force:

• Greek–Albanian Agreement of 17 May 1993 (Articles 23–30);
• Greek–Armenian Agreement of 21 November 2000 (Articles 17–23);
• Greek–Bulgarian Agreement of 10 April 1976 (Articles 27–33);
• Greek–German Agreement of 4 November 1961;
• Greek–Georgian Agreement of 10 May 1999 (Articles 21–29);
• Greek–Yugoslav Agreement of 18 June 1959;
• Greek–Chinese Agreement of 17 October 1994 (Articles 20–27);
• Greek–Cypriot Agreement of 5 March 1984 (Articles 21–28);
• Greek–Lebanese Agreement of 5 April 1975 (Articles 3–11);
• Greek–Hungarian Agreement of 8 October 1979 (Articles 24–31);
• Greek–Ukrainian Agreement of 2 July 2002 (Articles 20–25);
• Greek–Polish Agreement of 24 October 1979 (Articles 21–31);
• Greek–Romanian Agreement of 19 October 1972 (Articles 21–28);
• Greek–Soviet Agreement of 21 May 1981 (Articles 23–34);
• Greek–Syrian Agreement of 2 June 1981 (Articles 21–29);
• Greek–Czechoslovak Agreement of 22 October 1980 (Articles 22–29); and
• Greek–Tunisian Agreement of 12 April 1993 (Articles 28–36).

These agreements can be classified as follows:

• pure recognition and enforcement agreements:
1. Greek–German Agreement of 4 November 1961; and
2. Greek–Yugoslav Agreement of 18 June 1959;
• general judicial assistance agreements – the remaining agreements cover all issues of judicial assistance, including the recognition and enforcement of foreign judgments;
• recognition and enforcement of foreign arbitral awards – some agreements refer directly to the New York Convention, whereas others contain specific provisions usually included in the same chapter as foreign judicial decisions; and
• EU member state bilateral agreements – these agreements are superseded by EU regulations but only in the areas covered by the latter and they maintain their significance where no overlap exists.

Domestic Law

Key provisions of Greek law are those of Articles 323, 780, 903, 905 and 906 of the GrCCP. With the exception of Article 905, said provisions have remained unchanged since 1967. International treaties and EU regulations prevail over domestic provisions of Greek law. However, they do not regulate procedural matters. These are governed by the GrCCP (see 3.4 Process of Enforcing Foreign Judgments).

As a general rule, the res judicata effect of foreign judgments is automatically recognised in Greece. No further proceedings are required, to the extent that the conditions for recognition set out in Article 323 of the GrCCP are met. Notably, under Article 323 of the GrCCP, the res judicata effect and possible formative effect of a foreign judgment are recognised within the Greek legal order if:

• the foreign judgment produces res judicata effect in the place of origin (this condition must be met at the time the application for declaration of enforceability is heard);
• according to Greek law, the foreign court that has issued the judgment had jurisdiction over that dispute;
• the parties’ right to be heard has been respected;
• the foreign judgment does not contradict any judgment issued by a Greek court on the same dispute, between the same parties, producing res judicata effect; and
• the recognition of the foreign judgment does not result in violation of international public policy, as defined in Article 33 of the Greek Civil Code.

According to well-established case law, and within the meaning of Article 33 of the Greek Civil Code, international public policy is of strict scope. This notion does not concern all mandatory rules of law. Only these mandatory provisions – of either substantive or procedural nature – reflecting the fundamental social, economic, legal and moral principles of the Greek legal order fall within this scope of international public policy. Public policy is deemed breached in the following indicative instances: corruption and general criminal offences, violation of the primary EU law, violation of the law of free competition, tax evasion, money laundering, smuggling, fraud, etc. The court examines possible violations of public policy of its own motion.

The conditions for the declaration of enforceability must be met cumulatively. The burden of invocation and the objective burden of proof lies with the party applying for the declaration of enforceability.

With the exception of EU judgments, foreign court judgments must be declared enforceable in Greece. If a foreign judgment has been in issued in a non-EU state that has not signed any bilateral agreement with Greece, nor is a signatory to one of the above-mentioned international treaties, Article 905 of the GrCCP shall apply. According to said provision, a foreign judgment may be declared enforceable in Greece if:

• that judgment is enforceable in the place of origin (this condition must be met at the time the application for declaration of enforceability is heard); and
• all above-mentioned conditions set out in Article 323(b)–(e) of the GrCCP are met.

ECJ Decisions

Declaration of enforceability is not required for decisions of the ECJ, which are executed according to the provisions of the GrCCP (Article 280 and Article 299 of the Treaty on the Functioning of the European Union (TFEU)). The enforcement clause is affixed by the competent authority of the Ministry of Justice after verifying the authenticity of the title only, without investigating other conditions – particularly whether fundamental constitutional rights of the domestic legal order were violated.

ECHR Decisions

According to the prevailing view, judgments of the ECHR are enforced in accordance with the provisions applicable to the recognition and declaration of enforceability of foreign judgments (Articles 323 and 905 of the GrCCP).

Special Reference to UK Judgments Post-Brexit

Following Brexit, as of 1 January 2021, Brussels I Recast and the 2007 Lugano Convention no longer apply to the UK. Brussels I Recast continues to apply with reference to proceedings which have commenced on or before 31 December 2020. Therefore, UK judgments issued in proceedings which commenced before 31 December 2020 are binding and enforceable in Greece, in accordance with Brussels I Recast.

With reference to proceedings that have commenced/shall commence on/after 1 January 2021, on 8 April 2020 the UK applied to accede to the Lugano Convention, as an independent contracting state. However, this requires the unanimous consent of the other parties to that convention, including the EU member states. On 4 April 2021, the EC rejected ‒ in a communication to the European Parliament and the European Council ‒ the entry of the UK to the Lugano Convention. As things stand, no unanimous consent has not been given so far. On 1 January 2021, the UK rejoined the 2005 Hague Convention on Choice of Court Agreements, which also regulates the recognition and enforcement of foreign judgments but only in cases in which a foreign judgment has been issued on the basis of a prorogation clause. Therefore, the 2005 Hague Convention on Choice of Court Agreements is currently in force between Greece and the UK, given that the former is an EU member state (the term “judgment” does not include decisions or court orders issued on interim measures requests).

On 12 January 2024, the UK signed and on 27 June 2024 ratified the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters as an independent contracting state with reference to proceedings. The 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters entered into force in the UK on 1 July 2025. No bilateral or any other international treaty on the recognition and enforcement of foreign judgments is currently in force between Greece and the UK.

Recognition

If a judgment has not been issued by a UK court on the basis of prorogation clause, the recognition of that judgment in Greece shall be regulated by Article 323 of the GrCCP. If a judgment is issued by a UK court on the basis of a prorogation clause, Articles 8 and 9 of the 2005 Hague Convention on Choice of Court Agreements apply to the recognition of that judgment in Greece (and vice versa). In such cases, Article 4 et seq of the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters apply as well.

Enforcement

If a judgment is not issued by a UK court on the basis of a prorogation clause, the declaration of enforceability of said judgment in Greece shall be regulated by Article 905 of the GrCCP.

If a judgment is issued by a UK court on the basis of a prorogation clause, Articles 8 and 9 of the 2005 Hague Convention on Choice of Court Agreements in conjunction with Articles 4 et seq of the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters apply respectively to the declaration of enforceability of that judgment in Greece (and vice versa).

Only foreign performance judgments (see 2.1 Types of Domestic Judgments (Relief Sought and Granted)) may be declared enforceable in Greece.

Non-EU foreign judgments are declared enforceable in Greece in accordance with the procedure set out in Article 905(1) of the GrCCP.

• A standalone application is filed with the locally competent single-member court of first instance. This is either the court of the place where the debtor holds assets or – should the allocation of such court not be feasible – the Athens Single-Member Court of First Instance. The application is adjudicated in accordance with the provisions of the GrCCP on non-contentious proceedings (Articles 740–781 of the GrCCP).
• The application for a declaration of enforceability may be submitted by any party entitled to initiate enforcement based on the foreign judgment. Neither addressing the application against the debtor nor serving it upon the latter is required. Summoning the debtor to participate in the proceedings is not required, unless ordered by the court (Article 748(3) of the GrCCP).
• A certified copy of the foreign title accompanied by an official translation into Greek must be submitted, along with the foreign authority’s certificate confirming its enforceability in the place of origin (also officially translated into Greek).
• The court may of its own motion order that further evidence be provided, as well as consider even inadmissible or invalid evidence (Article 759 of the GrCCP).
• There will be no revisiting of the merits of the case. The party against whom a declaration of enforceability is sought is precluded from raising any objections to the claim.

As soon as a foreign court judgment is declared enforceable in Greece, enforcement proceedings in accordance with Articles 904 et seq of the GrCCP may be initiated.

The costs incurred in the proceedings for the declaration of enforceability of foreign judgments are relatively limited. They extend to the following:

• statutory fees to be paid for the filing of the application by a lawyer;
• expenses for the official translation of the foreign judgment and any relevant documents into Greek;
• expenses for the service of the application along with the summons upon the party against whom the application is filed, if ordered by the court;
• statutory fees to be paid for the applicant’s representation before court by a lawyer.

No fees apply to the issuance of the writ of enforcement.

As mentioned in 3.4 Process of Enforcing Foreign Judgments, once declared enforceable, foreign judgments are enforced in Greece in accordance with the provisions of the GrCCP that apply to domestic judgments. In light thereof, as regards the challenging of enforcement, please refer to 2.5 Challenging Enforcement of Domestic Judgments.

Greece is a signatory to the New York Convention, ratified by virtue of Legislative Decree No 4220/1961, which entered into force on 16 July 1962. Greece has adopted a dualist model, distinguishing between domestic and international arbitration, subjecting them to different legal regimes presenting notable differences. Domestic arbitration is regulated by Articles 867–903 of the GrCCP, whereas international arbitration is regulated by Law 5016/2023.

Domestic and International Arbitral Awards

Arbitrations seated in Greece concerning disputes not presenting any international element are considered domestic, whereas arbitrations seated in Greece on international disputes are considered international.

On the internationality of arbitration, Article 3(2) of Law 5016/2023 adopts the criteria prescribed in Article 1(3)(a) and (b) of the UNCITRAL Model Law. More specifically, an arbitration is deemed to be international if;

• the parties to an arbitration agreement have, at the time of the conclusion of that agreement, their places of business in different states; or
• one of the following places is situated outside the state in which the parties have their places of business:
1. the place of arbitration, if determined in ‒ or pursuant to ‒ the arbitration agreement; or
2. any place where a substantial part of the obligations of the commercial relationship is to be performed or the place with which the subject matter of the dispute is most closely connected.

As of their issuance, both domestic and international arbitral awards advance to res judicata and are enforceable without any further proceedings (Article 896 of the GrCCP and Article 43 of Law 5016/2023, accordingly). Arbitral awards are not subject to any means of appeal. Any party may apply to set aside an arbitral award rendered in Greece, provided that it has legal interest. The grounds for setting aside are exclusively enumerated in Article 897 of the GrCCP (for domestic arbitral awards) and in Article 43(2) of Law 5016/2023 (for international arbitral awards).

Pursuant to Article 43(7) of Law 5016/2023, by express and specific agreement in writing, the parties may waive at any time their right to seek to set aside an arbitral award. In such case, the parties maintain the right to raise in the context of enforcement proceedings grounds that constitute setting-aside grounds.

The filing of an application to set aside an arbitral award does not result automatically to stay of enforcement. Pursuant to Article 899(3) of the GrCCP, upon the filing of an admissible application to set aside, the applicant may apply for stay of enforceability of the arbitral award. The application for stay of enforceability is tried in accordance with the provisions of the GrCCP on interim measure proceedings (Articles 686 et seq). It is admitted if the court is satisfied that at least one of the grounds for setting aside put forward is likely to be valid.

Foreign Awards

On the basis of the territoriality principle, arbitral awards rendered by arbitral tribunals seated abroad are considered foreign. In contrast to arbitral awards rendered in Greece, the recognition of foreign arbitral awards and a declaration of their enforceability are required.

Enforceability of Foreign Awards

Recognition of foreign arbitral awards and declarations of their enforceability are governed by the New York Convention. On 18 April 1980, Greece proceeded to make the reservations of reciprocity and commerciality, in accordance with Article 1(3) of the New York Convention. Nonetheless, both reservations have been rendered moot, given that ‒ under Article 45(1) of Law 5016/2023 ‒ the New York Convention controls the recognition and enforcement of any foreign arbitral award.

As already mentioned in 4.1 Legal Issues Concerning Enforcement of Arbitral Awards, arbitral awards rendered in Greece are enforceable as of their issuance. Enforcement is governed by Articles 904 et seq of the GrCCP. Once declared enforceable in Greece, foreign arbitral awards are enforced the same way ‒ ie, pursuant to the above-mentioned provisions of the GrCCP.

Please refer to 2.1 Types of Domestic Judgments and 3.3 Categories of Foreign Judgments Not Enforced. Only arbitral awards upholding performance claims are enforceable. Awards ordering interim relief measures are also enforceable. Arbitral awards of declaratory nature or constitutive effect are not enforceable.

Please refer to 4.2 Variations in Approach to Enforcement of Arbitral Awards. Procedural matters pertaining to the declaration of enforceability of foreign arbitral awards are governed by Articles 903 and 906 in conjunction with Article 905 of the GrCCP.

Application Process

For the declaration of enforceability of foreign arbitral awards, a standalone application is filed with the locally competent single-member court of first instance. This is either the court of the place where the debtor holds assets or – should the allocation of such court not be feasible – the Athens Single-Member Court of First Instance. The application is adjudicated in accordance with the provisions of the GrCCP on non-contentious proceedings (Articles 740–781 of the GrCCP).

The application for a declaration of enforceability may be submitted by any party entitled to initiate enforcement based on the foreign judgment. Neither addressing the application against the debtor nor serving it upon the latter is required. Summoning the debtor to participate in the proceedings is not required, unless ordered by the court (Article 748(3) of the GrCCP).

The judgment on the application for recognition and declaration of enforceability is subject to appeal. Yet, neither the time limit for the filing of the appeal nor the actual filing of the appeal suspend the binding effects of the judgment.

If summoned to participate in the above-mentioned proceedings, the party withstanding recognition and declaration of enforceability may raise any of the grounds set out in Article V of the New York Convention. If not summoned, that party may file a third-party challenge against the judgment admitting the application for recognition and declaration of enforceability of the foreign arbitral award, pursuant to Article 773 of the GrCCP. Said third-party challenge may be premised on the grounds set out in Article V of the New York Convention.

Required Documentation

Deviating from Article IV of the New York Convention, Article 45(3) of Law 5016/2023 provides for a more favourable legal framework. More specifically, pursuant to Article 45(3) of Law 5016/2023, the party applying for recognition and enforcement of a foreign arbitral award must submit to the competent court the original award or an authenticated copy thereof. For awards drafted in a language other than Greek, the court may require the applicant to supply an official translation.

In accordance with Article VII(1) of the New York Convention, Article 45(3) of Law 5016/2023 prevails over Article IV of the New York Convention as a more favourable provision. Against this backdrop, the applicant is not required to submit with the court the original arbitration agreement or a duly certified copy thereof. Moreover, the applicant is not required to submit the duly authenticated original award or a duly certified copy thereof, either. The submission of the original award or of an authenticated copy thereof suffices.

Please refer to 2.3 Costs and Time Taken to Enforce Domestic Judgments.

Please refer to 2.5 Challenging Enforcement of Domestic Judgments.