Ship Arrests, Interim Measures and Enforcing Arbitral Awards in Greece, a Practical 2026 Guide

A ship arrest in Greece remains one of the most powerful tools available to maritime claimants seeking urgent security, and the enactment of Law 5016/2023 (FEK A 21/4.2.2023) has significantly strengthened the country’s position as an arbitration-friendly jurisdiction. Greek courts routinely grant precautionary arrests of vessels even when the underlying dispute is subject to foreign-seated arbitration, and the modernised framework for recognising and enforcing arbitral awards gives claimants a clear procedural path from petition to recovery. This guide provides a step-by-step operational playbook, covering arrest mechanics, interim relief, enforcement of awards, and tactical considerations, designed for shipowners, charterers, P&I clubs, cargo underwriters, and in-house counsel who need to act decisively in Piraeus and across Greek ports.

At a Glance, Emergency Action Checklist

• Arrest. A precautionary ship arrest can be obtained from a Greek judge on duty within 24–72 hours where a prima facie maritime claim and a risk of dissipation or removal of the vessel can be demonstrated.
• Interim measures. Greek courts grant interim relief, including arrest, attachment of assets, evidence preservation, and injunctions, in support of both domestic and foreign-seated arbitration proceedings.
• Enforcement. Foreign arbitral awards are enforceable in Greece under the New York Convention and Law 5016/2023, typically through an ex parte recognition procedure before the single-member Court of First Instance.
• Key reform. Law 5016/2023 introduced a rebuttable presumption in favour of arbitrability, expanding the scope of disputes that can be resolved by arbitration and simplifying enforcement for international commercial and maritime claims.

Legal Framework for Ship Arrest in Greece and Law 5016/2023

What Law 5016/2023 Changed

Published in the Official Gazette on 4 February 2023 (FEK A 21), Law 5016/2023 consolidated and modernised Greece’s international commercial arbitration regime. The statute replaced the former Law 2735/1999 and drew heavily on the 2006 revision of the UNCITRAL Model Law. For maritime practitioners, the most consequential innovation is Article 3.4, which establishes a rebuttable presumption in favour of arbitrability: any dispute of a financial nature is presumed arbitrable unless a specific statutory provision expressly excludes it. As the Wolters Kluwer Arbitration Blog analysis explains, this reversed the position under the 1999 Law, which contained no equivalent presumption and generated uncertainty over the arbitrability of certain maritime claims.

Law 5016/2023 also codified the power of Greek courts to order interim measures in support of arbitration (including foreign-seated proceedings), streamlined the procedure for recognising and enforcing international arbitral awards, and reduced the grounds on which enforcement may be refused, aligning Greece more closely with leading arbitration seats worldwide. Industry observers expect that Greece’s ranking among top countries for international arbitration will continue to rise as a result of these reforms.

Relevant Statutes and Conventions

The legal framework governing precautionary ship arrest in Greece and enforcement of arbitral awards sits across several interlocking instruments. The principal sources are:

• Greek Code of Civil Procedure (CCP), Articles 682–738. These provisions regulate interim and precautionary measures generally, including the arrest of movable assets such as vessels.
• International Convention Relating to the Arrest of Sea-Going Ships (Brussels, 1952). Greece is a party to the 1952 Arrest Convention, which defines the categories of “maritime claim” that justify arrest and permits sister-ship arrests under specific conditions.
• Law 5016/2023, International Commercial Arbitration Act. Governs international arbitration proceedings seated in Greece, interim measures in support of arbitration, and recognition/enforcement of both domestic and foreign arbitral awards. The English translation is available for international practitioners.
• New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958). Greece is a signatory; enforcement is available through domestic procedural mechanisms, now supplemented by Law 5016/2023.
• Greek Code of Private Maritime Law (CPML). Supplementary provisions relevant to maritime liens, mortgages, and enforcement against vessel interests.

Interim Measures and Precautionary Ship Arrest in Greece

Can Courts Grant Interim Relief to Support Arbitration?

Yes. Greek courts have jurisdiction to order interim measures in support of arbitration regardless of whether the seat is in Greece or abroad. Under Law 5016/2023 and the CCP interim-measures regime, the existence of an arbitration clause does not deprive Greek courts of the power to grant precautionary relief, provided the vessel or assets are within Greek territory. This is a critical point for foreign-seated London, Singapore, or Hong Kong arbitrations: claimants can obtain a ship arrest in Greece to secure their position while the arbitral tribunal is constituted or proceedings are ongoing. For further detail on how Greek courts interact with international arbitral proceedings, see local court intervention in international arbitration.

Types of Interim Measures Available

Greek courts can grant several categories of interim measures in arbitration-related maritime disputes:

• Precautionary arrest of a vessel. The most commonly sought measure, the ship is physically detained in port and prevented from sailing until security is provided or the court lifts the order.
• Attachment of assets. Extends beyond the vessel to bank accounts, freight receivables, or other assets of the debtor within Greece.
• Injunctions. Prohibitory or mandatory orders restraining a party from disposing of assets or requiring specific performance of an obligation.
• Preservation of evidence. Orders securing documents, cargo samples, or physical evidence at risk of destruction, particularly valuable in collision, pollution, or cargo damage disputes.
• Security orders. Orders requiring a party to post security (cash deposit, bank guarantee, or letter of undertaking) for a specified amount.

Threshold Test for a Precautionary Ship Arrest in Greece

To obtain a precautionary arrest, the applicant must satisfy four cumulative criteria before the competent single-member court or judge on duty:

• Prima facie claim. A credible maritime claim falling within the categories recognised under the CCP and the 1952 Arrest Convention, including claims for cargo damage, demurrage, salvage, towage, collision, crew wages, bunkers, mortgage enforcement, and general average.
• Urgency. Circumstances requiring immediate protective action, typically evidenced by the transient nature of the vessel’s call at a Greek port.
• Risk of dissipation or removal. A genuine risk that the debtor will remove the vessel from the jurisdiction or dissipate assets, frustrating eventual enforcement.
• Balance of convenience. The court must be satisfied that the potential harm to the applicant from refusal outweighs the prejudice to the respondent from granting the arrest.

Practical Examples and Court Trends

Reported practice from Piraeus and other Greek port courts in the period 2024–2026 confirms a consistently pro-claimant approach to precautionary ship arrests. Industry observers note that judges on duty at Piraeus have granted arrest orders on an ex parte basis within 24 hours of filing in urgent cases, particularly where the vessel’s stay in port was limited. In several reported instances, courts have granted arrest orders in circumstances where the underlying dispute was subject to London-seated LMAA arbitration, affirming that the existence of a foreign arbitration clause does not bar interim measures under Greek law.

Early indications suggest that the enactment of Law 5016/2023, and its explicit codification of court-ordered interim measures in aid of arbitration, has further emboldened claimants and given judges a clearer statutory basis for such orders. Greek courts remain, in the assessment of leading practitioners, firmly pro-arbitration when granting interim relief.

Ship Arrest Procedure in Greece, Step-by-Step Checklist

Emergency Checklist for Claimants

Speed is essential. The following documents and steps should be prepared before, or immediately upon, the vessel’s arrival at a Greek port:

1. Power of attorney. A duly executed power of attorney authorising the Greek lawyer to act on behalf of the claimant. Notarisation and apostille are required if executed abroad; in urgent cases, courts may accept a faxed or scanned copy subject to later ratification.
2. Affidavit / sworn statement of claim. A detailed statement setting out the factual basis of the maritime claim, the quantum sought, and the reasons justifying urgent arrest.
3. Evidence of the underlying claim. Contracts (charterparty, bill of lading, bunker supply agreement), invoices, survey reports, correspondence, and any arbitral notice of dispute or pending proceedings.
4. Evidence of quantum. A clear calculation of the amount claimed, supported by documentation (invoices, demurrage calculations, expert estimates, repair quotations).
5. Vessel particulars. IMO number, flag, registered owner, beneficial owner, and current location/AIS tracking data. Identify whether the target vessel is the vessel in question or a sister ship of the debtor.
6. Evidence of urgency and dissipation risk. Port-call schedule, trading patterns, single-ship company structure, or other evidence indicating the vessel may leave Greece imminently.

Filing, Judge on Duty, and Expected Timelines

The arrest petition is filed before the single-member Court of First Instance at the port where the vessel is located. In practice, claimants file before the judge on duty (δικαστής υπηρεσίας), who is available outside regular court hours, including evenings, weekends, and public holidays. In genuinely urgent cases, an arrest order can be issued ex parte within 24 to 72 hours of filing. The court may set a hearing date for the respondent to be heard, typically within days or weeks of the arrest, but the vessel remains under arrest pending that hearing unless security is posted. Once the order is granted, it is served on the vessel’s master and the port authority, which physically prevents the vessel from sailing.

Tactical Options for Respondents

Respondents, typically shipowners or their P&I clubs, have several avenues to challenge or lift an arrest:

• Posting security. The most common route to release. The respondent offers a bank guarantee, P&I club letter of undertaking (LOU), or cash deposit in an amount satisfying the court that the claim is adequately secured. Greek courts widely accept first-class bank guarantees from institutions operating in Greece, and P&I club LOUs from International Group clubs are routinely treated as equivalent security.
• Challenging the claim on the merits. At the inter partes hearing, the respondent may argue that the applicant has no prima facie case, that the quantum is grossly overstated, or that the claim does not fall within a recognised maritime claim category.
• Jurisdictional objections. Arguments that the Greek court lacks jurisdiction to order interim measures, though, post-Law 5016/2023, this ground is increasingly difficult to sustain for arbitration-related arrests.
• Forum non conveniens / misjoinder. Where the respondent argues that another forum is more appropriate or that the wrong vessel or entity has been arrested.
• Wrongful arrest claim. If the arrest is ultimately found to have been obtained abusively or without reasonable cause, the respondent may pursue a damages claim for wrongful arrest, though successful claims remain rare in Greek practice.

Special Categories, Bunker Arrests, Sister-Ship, and Greek-Flagged Vessels

Bunker Arrests: Practical Checklist

Bunker supply claims are among the most frequently arrested maritime claims in Greek ports. A bunker arrest in Greece requires the claimant to demonstrate a supply of bunkers to the vessel (or its operator/charterer), supported by bunker delivery notes, invoices, and ideally a fuel sampling report. Claimants should be aware that bunker supply contracts often contain waiver-of-arrest clauses or jurisdiction agreements; Greek courts will examine these clauses carefully, and a clear waiver may defeat the arrest application. Where the bunker supplier contracted with the charterer rather than the registered owner, establishing a direct claim against the vessel requires additional evidence of agency or contractual privity.

Sister-Ship Arrests: Law and Practice

Greece, as a party to the 1952 Arrest Convention, permits sister-ship arrests, the arrest of a vessel other than the vessel in respect of which the maritime claim arose, provided that both vessels are in the same beneficial ownership at the time of arrest. Claimants must produce evidence of common ownership (e.g., corporate registry extracts, beneficial ownership declarations, or fleet management evidence) to persuade the court that the sister-ship connection is established.

Arrest of Greek-Flagged Vessels, Additional Implications

Arresting a Greek-flagged vessel may engage additional regulatory considerations, including mortgage registration at the Greek ship registry (Piraeus) and potential priority disputes among secured creditors. Mortgage holders and preferred maritime lien claimants should be aware that the arrest process intersects with enforcement proceedings under the Code of Private Maritime Law, which establishes a hierarchy of claims that can affect the distribution of proceeds in any judicial sale.

Enforcing Arbitral Awards in Greece, Procedure, Timeline, and Defences

Recognition and Enforcement of Domestic vs Foreign Awards

The procedure to enforce an arbitral award in Greece depends on the seat of the arbitration. For domestic awards (seated in Greece), enforcement is governed by Law 5016/2023 and the CCP provisions on enforcement titles. For foreign awards, Greece’s obligations under the New York Convention apply, with the procedural framework now supplemented and clarified by Law 5016/2023. The practical effect is that claimants seeking to enforce London, Singapore, Paris, or other foreign-seated arbitral awards in Greece benefit from a streamlined statutory route. For detailed analysis of recent enforcement trends, see enforcing arbitral awards in Greece (2026).

The likely practical effect of Law 5016/2023 and its alignment with the UNCITRAL Model Law is that Greek courts will apply a narrower set of refusal grounds, consistent with the pro-enforcement bias embedded in both the New York Convention and the new domestic statute. This represents a meaningful improvement over the position under the prior regime, where procedural ambiguities occasionally delayed recognition.

Procedure: Ex Parte Recognition, Documents, and Timing

The standard enforcement procedure involves the following steps:

1. Filing an application before the competent single-member Court of First Instance (typically at the domicile of the debtor or the location of assets, including a vessel in port).
2. Submitting required documents: the original or certified copy of the arbitral award, the arbitration agreement, certified translations into Greek, and any authentication or apostille required under the Hague Convention.
3. Ex parte hearing. The initial recognition application is typically heard ex parte, the debtor is not notified in advance. The court examines the formal requirements and issues a recognition order.
4. Service and enforcement. Once the recognition order is granted, it is served on the debtor and may be enforced like a domestic court judgment, including through arrest, attachment, or judicial sale of assets.

Realistic timelines vary. In straightforward cases where documentation is in order, the ex parte recognition order can be obtained within two to six weeks of filing. Contested enforcement proceedings (where the debtor opposes recognition) may extend to several months, depending on court schedules and the complexity of the defences raised.

Common Defences and How to Mitigate Them

Debtors opposing enforcement of a foreign award in Greece typically invoke one or more of the following grounds, mirroring the exhaustive list in Article V of the New York Convention:

• Public policy. The award is contrary to Greek public policy, the narrowest and most rarely successful ground, reserved for fundamental procedural irregularities or results that offend core principles of Greek law.
• Invalid arbitration agreement. The agreement to arbitrate was invalid under the law governing it, or the party lacked capacity to enter into it.
• Excess of jurisdiction. The tribunal decided matters beyond the scope of the arbitration agreement.
• Procedural irregularity. The debtor was not given proper notice of the arbitration or was unable to present its case.
• Award not yet binding or set aside. The award has been annulled at the seat or is subject to a pending set-aside application.

Claimants can mitigate these risks by ensuring that the arbitration agreement is clearly drafted, that due process is rigorously observed throughout the proceedings, and that all documentation submitted to the Greek court is complete, properly authenticated, and accurately translated. Engaging Greek counsel early, ideally before the award is rendered, to prepare for enforcement is a practical step recommended in connection with the preparation for and conduct of arbitration hearings.

Practical Tactical Guidance and Illustrative Case Examples

Two anonymised scenarios illustrate the practical mechanics of ship arrest and award enforcement in Greece:

Scenario A, Arrest to secure P&I exposure. A cargo claimant with a substantial cargo damage claim under a bill of lading subject to London arbitration identified a vessel owned by a single-ship company calling at Piraeus for bunkering. The claimant’s Greek lawyers filed an arrest petition before the judge on duty on a Saturday afternoon. The arrest order was granted ex parte within hours, and the vessel was detained. The owner’s P&I club provided a letter of undertaking within 48 hours, and the vessel was released. The underlying claim proceeded to London arbitration, secured by the LOU, a textbook use of a precautionary ship arrest in Greece to obtain security for a foreign-seated dispute.

Scenario B, Enforcement of a foreign award. A Greek shipowner holding a London-seated LMAA award against a foreign charterer identified assets (including sub-freight receivables and a vessel) in Greece. The shipowner applied for recognition and enforcement under the New York Convention, supported by Law 5016/2023. The ex parte recognition order was obtained within three weeks. The charterer’s opposition on public-policy grounds was dismissed, and enforcement proceeded against the identified assets. The entire process from filing to final enforcement took approximately four months.

Practical dos and don’ts:

• Do monitor vessel movements via AIS tracking and instruct Greek counsel in advance of the vessel’s arrival.
• Do prepare all arrest documentation (power of attorney, affidavit, supporting evidence) before the vessel enters Greek waters.
• Do not delay, vessels may leave port at short notice, and the opportunity for arrest is lost once the ship sails.
• Do not underestimate the importance of accurate quantum evidence; courts may reduce the security amount if the claim is poorly quantified.

Checklist and Immediate Next Steps

What to Do in the First 24 / 48 / 72 Hours

• First 24 hours. Identify and verify vessel location (AIS). Instruct Greek counsel. Execute power of attorney. Assemble arrest documentation package. File arrest petition before judge on duty.
• First 48 hours. Obtain and serve arrest order. Notify port authority. Communicate with P&I club and/or respondent regarding security. Begin preparing for inter partes hearing.
• First 72 hours. Evaluate any security offers (bank guarantee, LOU). Negotiate quantum and terms. If security is satisfactory, agree release; if not, maintain the arrest and prepare for hearing.

For urgent instructions or to connect with experienced admiralty practitioners in Piraeus and across Greek ports, consult the Global Law Experts lawyer directory for Greece.

Sources

1. Law 5016/2023, Codified Text (Kodiko.gr)
2. Law 5016/2023, English Translation (LBR Cloud)
3. Wolters Kluwer Arbitration Blog, Greece’s New Law on International Commercial Arbitration
4. ShipArrested.com, Ship Arrest in Greece
5. HFW, The Shipping Law Review: Greece (2024)
6. Global Law Experts, Enforcing Arbitral Awards in Greece (2026)