Dispute Resolution Greece 2026: Enforcing Foreign Arbitral Awards & Judgments

Last reviewed: May 7, 2026

Greece’s dispute resolution landscape entered a new phase when Law 5221/2025 was published in the Government Gazette (FEK A’ 133/28.07.2025), introducing sweeping amendments to the Code of Civil Procedure. For international claimants, in-house counsel and arbitration parties holding a foreign arbitral award or court judgment, the practical question is immediate: how do these reforms affect the recognition and enforcement process in Greece in 2026? This guide provides a step-by-step enforcement playbook, covering everything from the New York Convention route for arbitral awards, to EU and non-EU judgment recognition, interim relief, asset-recovery tactics, and the new timelines and digital-service provisions that are now reshaping dispute resolution Greece practice on the ground.

Quick Action Plan, 30 / 60 / 90 Days

Law 5221/2025, What Changed for Dispute Resolution Greece

Law 5221/2025 (Government Gazette A’ 133/28.07.2025) represents the most significant procedural overhaul in Greece in recent years. While the statute covers the full spectrum of civil litigation, several reforms directly affect enforcement proceedings for foreign awards and judgments. The law entered into force on a staggered basis, with certain provisions, notably the new framework for the issuance of payment orders and orders for repossession of leased premises, becoming effective as of May 1, 2026.

Key Reforms Relevant to Enforcement

The likely practical effect of these changes for foreign claimants is a reduction in total enforcement time, particularly in straightforward recognition cases. Industry observers expect the digital-service provisions and revised summons periods to remove weeks from the procedural calendar, while the streamlined payment-order framework offers an accelerated track for monetary claims entering the enforcement phase from May 1, 2026.

Enforcing Foreign Arbitral Awards in Greece, The New York Convention Route

Greece has been a signatory to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards since 1962. This remains the primary mechanism for enforcement of arbitral awards Greece practitioners rely upon. The relevant domestic provisions are found in Articles 903–906 of the Greek Code of Civil Procedure, as amended.

Step-by-Step Procedure for Recognition and Execution Greece

1. Identify the competent court. File a petition for recognition and enforcement before the Single-Member Court of First Instance at the place where the debtor is domiciled or where the assets are located. If neither criterion is met, the Athens Court of First Instance has general jurisdiction.
2. Prepare and file the petition. The petition must request that the court declare the foreign arbitral award enforceable in Greece. It should identify the parties, summarise the award, and cite the New York Convention and Articles 903–906 of the Code of Civil Procedure as the legal basis.
3. Assemble the required documents. Under Article IV of the New York Convention, the following must accompany the petition:
   • The duly authenticated original arbitral award, or a certified copy thereof.
   • The original arbitration agreement, or a certified copy thereof.
   • Certified Greek translations of both documents, prepared by a sworn translator or the Greek Ministry of Foreign Affairs translation service.
   • An apostille (for awards originating in Hague Convention member states) or consular legalisation for other jurisdictions.
   • A power of attorney authorising the Greek lawyer to act on behalf of the claimant.
4. Serve the petition on the respondent. Service must comply with the Code of Civil Procedure. Under Law 5221/2025, electronic service is now permissible where the respondent or their counsel has a registered electronic address. For respondents abroad, the existing 60-day summons period for special proceedings applies.
5. Attend the hearing. The court will examine whether the formal requirements of the New York Convention are met. The burden of proof rests on the party opposing enforcement to demonstrate that one of the Convention’s exhaustive grounds for refusal applies.
6. Obtain the court decision. If the court grants recognition, the award becomes an enforceable title in Greece and may be executed against the debtor’s assets using standard enforcement mechanisms (seizure of bank accounts, attachment of real property, garnishment of receivables).

Documents Required, Checklist

• Authenticated arbitral award (original or certified copy)
• Arbitration agreement (original or certified copy)
• Sworn Greek translations of both the award and the agreement
• Apostille or consular legalisation
• Power of attorney (notarised and apostilled, authorising Greek counsel)
• Certificate of non-appeal or finality (where available from the arbitral institution)
• Evidence of service of the arbitration notice on the respondent (to pre-empt due-process objections)

Grounds for Refusal, Public Policy and Other Defences

Article V of the New York Convention provides an exhaustive list of grounds on which a Greek court may refuse enforcement. These are construed narrowly by Greek courts, and the burden rests entirely on the party resisting enforcement:

• Incapacity of a party or invalidity of the arbitration agreement under the law applicable to it.
• Lack of proper notice, the respondent was not given proper notice of the arbitral proceedings or was otherwise unable to present their case.
• Award exceeds the scope of the submission to arbitration, the award deals with matters beyond the arbitration agreement.
• Irregular composition of the tribunal or procedure, the tribunal’s composition or the arbitral procedure did not accord with the parties’ agreement or, failing agreement, with the law of the seat.
• Award not yet binding, or set aside, the award has been suspended or annulled at the seat of arbitration.
• Non-arbitrability, the subject matter of the dispute is not capable of settlement by arbitration under Greek law.
• Public policy, enforcement would be contrary to the public policy of Greece. Greek courts interpret this ground restrictively, limiting it to fundamental principles of the Greek legal order (e.g., procedural fairness, constitutional guarantees). Mere errors of law or fact in the award do not satisfy this threshold.

Appeal Route and Timeline

An enforcement decision of the Single-Member Court of First Instance may be appealed before the Court of Appeal within the standard appellate deadline. The respondent may also raise enforcement objections through opposition proceedings (anakopi). Early indications suggest that Law 5221/2025’s procedural reforms may marginally shorten appellate timetables, but practitioners should plan for appeal proceedings lasting approximately 12–18 months in complex cases.

Enforcing Foreign Judgments in Greece, Recognition and Execution

The procedure for enforcement of foreign judgments in Greece depends on whether the judgment originates from an EU Member State or from a non-EU jurisdiction. The distinction carries significant practical consequences for required procedures, documentary burden and timelines.

EU Judgments, Brussels Ia Regulation (Recast)

Judgments from EU Member States benefit from the Brussels Ia Regulation (Regulation 1215/2012, recast), which abolished exequatur proceedings for most civil and commercial judgments. Under this framework:

• Direct enforcement. A judgment rendered in another EU Member State that is enforceable there is automatically enforceable in Greece without the need for a separate declaration of enforceability. The claimant presents the judgment together with the certificate issued under Article 53 of the Regulation to the competent enforcement authority (bailiff).
• Grounds for refusal remain narrow. The debtor may apply for refusal of enforcement only on limited grounds, including public-policy violations, lack of service giving the debtor adequate time to arrange a defence, or irreconcilable judgments.
• Required documents. A certified copy of the judgment, the Article 53 certificate, and a sworn Greek translation where the court or enforcement authority requests one.

Non-EU Judgments, Exequatur Proceedings

Judgments from non-EU states require a formal recognition and execution procedure (exequatur) before Greek courts. The governing provisions are Articles 323 and 905 of the Code of Civil Procedure. The key requirements are:

1. Filing a petition before the Single-Member Court of First Instance (same jurisdictional rules as for arbitral awards).
2. Establishing that the judgment is final and enforceable under the law of the country of origin.
3. Demonstrating compliance with Article 323 conditions:
   • The judgment was rendered by a court with jurisdiction under Greek private-international-law rules.
   • The defendant was properly served and had the opportunity to participate in the proceedings.
   • The judgment is not contrary to a prior Greek judgment between the same parties on the same cause of action.
   • The judgment is not contrary to Greek public policy or morality.
4. Submitting required documents: certified copy of the judgment, evidence of finality, proof of service on the defendant, apostille or consular legalisation, and sworn Greek translations.

Bilateral treaties between Greece and certain non-EU states may modify or supplement these requirements. Practitioners should verify whether a bilateral enforcement treaty exists with the judgment country before filing.

Practical Timeline for Judgment Recognition

For EU judgments, enforcement can proceed almost immediately once the Article 53 certificate and translation are prepared, often within days. For non-EU judgments, the exequatur process typically requires several months from filing to decision at first instance, depending on court caseload and whether the respondent contests recognition.

Interim Measures and Provisional Remedies in Dispute Resolution Greece

Greek law provides a robust suite of interim remedies available to claimants both before and during enforcement proceedings. These measures are critical for preserving assets and preventing dissipation while recognition is pending.

Available Remedies

• Provisional attachment (syntiritiki kataskesi). The court may order the provisional seizure of the debtor’s movable and immovable assets, bank accounts and receivables. This is the most commonly used measure in enforcement-related disputes.
• Preliminary injunctions. The court can prohibit the debtor from transferring, encumbering or otherwise disposing of specific assets.
• Deposit orders. The court may order the debtor to deposit disputed funds with the court or a designated depository.
• Arrest of ships and aircraft. For maritime and aviation claims, specialised arrest procedures are available under both domestic law and international conventions.

Procedure for Obtaining Interim Relief

1. File an application before the competent judge of the Single-Member Court of First Instance sitting as interim-relief judge.
2. Demonstrate urgency and a prima facie claim. The applicant must show a likelihood of success on the merits and an imminent danger that assets will be dissipated or that irreparable harm will occur without the measure.
3. Ex parte applications. In cases of extreme urgency, the court may grant interim measures without prior notice to the respondent. The respondent may subsequently challenge the order.
4. Interaction with arbitration. Greek courts may grant interim measures in support of pending or future arbitration proceedings, including foreign-seated arbitrations. This is particularly valuable where the New York Convention enforcement petition is still being prepared.

Under the amendments introduced by Law 5221/2025, the digital filing infrastructure supports faster scheduling of interim-relief hearings. Industry observers expect the combination of electronic filing and streamlined hearing schedules to shorten the time between application and decision for provisional measures.

Enforcement Timeline and Costs, Before and After Law 5221/2025

One of the most pressing questions for international claimants concerns how long enforcement actually takes. The table below provides indicative timelines based on practitioner experience, adjusted for the procedural improvements introduced by the Law 5221/2025 civil procedure reforms.

Estimated costs. Court fees for enforcement petitions in Greece remain modest by international standards. Filing fees for recognition proceedings before the Court of First Instance are typically in the range of a few hundred euros. Legal counsel fees vary depending on complexity, value of the claim and whether the matter is contested, but foreign claimants should budget for both the recognition phase and potential execution proceedings. Bailiff fees for physical enforcement acts (seizure of movable property, real-estate attachment) are regulated by statute and are generally predictable.

Seizure and Asset-Recovery Steps, A Tactical Playbook

Obtaining an enforceable title is only half the battle. Effective recovery requires a disciplined asset-tracing and seizure strategy. The following tactical sequence reflects best practice for dispute resolution Greece enforcement cases.

1. Conduct pre-filing asset intelligence. Before initiating enforcement, commission a discreet asset-tracing investigation in Greece. Focus on real property (searchable via the Hellenic Cadastre and land registries), bank accounts (identifiable through post-judgment disclosure orders), corporate shareholdings, vehicles and other registrable assets.
2. Obtain a provisional attachment order. Apply for provisional seizure simultaneously with, or even before, filing the recognition petition. This prevents the debtor from transferring or encumbering assets once enforcement proceedings become known.
3. Freeze bank accounts. Once the court grants provisional attachment, serve the order on the debtor’s banks. Greek banks are obliged to freeze the debtor’s accounts up to the amount specified in the court order. Under the EU Account Preservation Order Regulation (Regulation 655/2014), claimants enforcing EU-origin claims may also obtain a European Account Preservation Order targeting accounts in Greece or other EU Member States.
4. Attach real property. Register the attachment with the competent land registry or cadastral office. This creates a charge on the debtor’s immovable property and prevents sale or mortgage.
5. Garnish receivables and salary. Enforcement orders may be served on third-party debtors (e.g., the debtor’s clients, employers or tenants) requiring them to pay amounts owed to the judgment debtor directly to the claimant.
6. Initiate auction proceedings. If the debtor fails to satisfy the judgment, the claimant may instruct a bailiff to seize and auction movable or immovable property. Law 5221/2025 updates the electronic-auction platform provisions, and early indications suggest improved transparency and faster auction scheduling.
7. Coordinate cross-border recovery. Where the debtor holds assets in multiple jurisdictions, coordinate Greek enforcement with parallel proceedings under the Brussels Ia Regulation, the EU Account Preservation Order, or bilateral treaties.

Evidence Checklist for Asset Recovery

• Cadastre / land-registry search certificates
• Corporate registry extracts (GEMI, General Electronic Commercial Registry)
• Bank account information (from disclosure orders or voluntary sources)
• Vehicle registration records
• Shareholder and beneficial-ownership records
• Tax filings or public-record financial information (where accessible)
• Third-party intelligence reports (commercial investigators)

Defences, How to Challenge Enforcement and Practical Risks

Respondents in enforcement proceedings may rely on a limited but tactically significant set of defences. Claimants should anticipate these challenges and prepare counter-evidence proactively.

Common Defences

• Public policy. The most frequently invoked ground, though Greek courts apply it restrictively. A respondent must demonstrate that enforcement would violate fundamental principles of Greek public order, not merely that the foreign tribunal made a legal or factual error.
• Lack of due process. Allegations that the respondent was not properly notified of the underlying proceedings or was denied the opportunity to be heard. This risk can be mitigated by ensuring meticulous documentation of service at every stage of the original proceedings.
• Jurisdictional objections. For non-EU judgments, the respondent may argue that the foreign court lacked jurisdiction under Greek private-international-law standards.
• Award set aside at seat. For arbitral awards, evidence that the award has been annulled or suspended at the seat of arbitration will block enforcement.
• Irreconcilable judgments. A prior Greek judgment between the same parties on the same dispute takes precedence.

Mitigation Steps for Claimants

• Maintain a complete chain-of-custody file for service documents and hearing transcripts from the original proceedings.
• Obtain a certificate of finality or non-appeal from the originating court or arbitral institution.
• Commission a Greek-law opinion on enforceability before filing, to identify and address potential vulnerabilities in advance.
• File interim-relief applications at the earliest opportunity to prevent asset dissipation during contested enforcement.
• Monitor the debtor’s corporate and financial position throughout proceedings to detect asset-stripping attempts.

Practical Checklist and Sample Forms for Enforcement in Greece

The following checklist summarises the core documents and steps required to enforce a foreign arbitral award or judgment in Greece. Practitioners may request tailored templates and sample court forms through the Global Law Experts advisory team.

• Certified copy of the award or judgment (original-language version)
• Sworn Greek translation of the award or judgment (by a certified translator)
• Arbitration agreement (for award enforcement) or certificate of finality (for judgments)
• Apostille or consular legalisation on all foreign public documents
• Power of attorney (notarised, apostilled, and translated into Greek) authorising local counsel
• Article 53 certificate (for EU judgments under Brussels Ia)
• Evidence of proper service of the original proceedings on the respondent
• Asset-tracing report (cadastre, GEMI, bank-account identification)
• Interim-relief application (if assets are at risk of dissipation)
• Greek-law enforceability opinion (recommended for complex or high-value matters)

Key Legislative and Procedural Dates

Conclusion, Next Steps for Dispute Resolution Greece Enforcement

The enforcement of foreign arbitral awards and judgments in Greece has become materially more efficient following the entry into force of Law 5221/2025. Digital filing, streamlined service provisions, updated auction mechanisms and the new payment-order framework collectively reduce the procedural burden on international claimants. The fundamentals, however, remain unchanged: meticulous document preparation, proactive interim-relief strategy and early engagement of experienced Greek enforcement counsel are the determinants of success.

For parties holding an enforceable award or judgment, the recommended course of action is clear: instruct Greek counsel within the first 30 days, secure asset-preservation measures before filing recognition, and leverage the new procedural tools that Law 5221/2025 provides. The Global Law Experts Greece lawyer directory connects claimants with specialist dispute resolution Greece practitioners who can advise on enforcement strategy, document preparation and tactical execution from day one.

Sources

1. Kyriakides Georgopoulos Law Firm, Civil Procedure Reforms Introduced by Law 5221/2025
2. OPI, Law 5221/2025 Government Gazette 133/A/28-7-2025
3. SEE Legal, Civil Procedure Reforms Introduced by Law 5221/2025
4. ICLG, Litigation & Dispute Resolution Laws and Regulations: Greece
5. UNCITRAL, New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards
6. OECD, Greece Dispute Resolution Profile
7. Global Legal Insights, Litigation & Dispute Resolution: Greece
8. Papatriantafyllou & Thanasenari, Amendments to the Greek Code of Civil Procedure (Law 5221/2025)
9. AP Legal, New Framework for Payment Orders and Repossession Orders (2026)