A) EU Regulations on the enforcement of foreign judgments applied directly in Greece

As an EU Member State, Greece directly applies the following EU regulations governing the recognition and enforcement of civil and commercial judgments issued by the courts of other EU Member States:

1. Regulation (EU) 1215/2012 (Brussels I bis) jurisdiction, and recognition/enforcement of civil & commercial judgments; exequatur abolished in EU Member States.
2. Regulation (EU) 2015/848 (Insolvency, recast), replaces and repeals Regulation 1346/2000; applies to proceedings opened from 26 June 2017.
3. Regulation (EU) 2019/1111 (Brussels IIb, recast), replaces 2201/2003 (Brussels IIa) from 1 August 2022; matrimonial matters, parental responsibility, and international child abduction.
4. Regulation (EC) 2015/2421 (European Small Claims Procedure); the small claim is limited to €5,000.
5. Regulation (EC) 4/2009 (Maintenance Regulation), jurisdiction, applicable law (via 2007 Hague Protocol), recognition/enforcement and cooperation in maintenance matters.
6. Regulation (EU) 650/2012 (Succession Regulation), jurisdiction, applicable law, recognition and enforcement of decisions and acceptance/enforcement of authentic instruments; European Certificate of Succession.
7. Regulation (EC) 805/2004 (European Enforcement Order for uncontested claims), automatic enforcement across the EU without introducing domestic proceedings.
8. Regulation (EC) 2015/2421 (Adoption of the European Order for Payment).
9. Regulation (EU) 655/2014 (European Account Preservation Order) cross-border bank account freezing to secure claims.

(B) Bilateral Treaties related to the enforcement of foreign judgments

Greece has signed and ratified the following Bilateral Treaties on civil and commercial judgments issued by the Courts of the other contracting State (alphabetically):

1. Greece – Albania Treaty of 17.5.1993, ratified by Law 2311/1995, οn civil and criminal matters.
2. Greece – Armenia Treaty of 21.11.2000, ratified by Law 3007/2002, οn civil, family, and criminal matters.
3. Greece – Bulgaria Treaty of 10.4.1976, ratified by Law 841/1978, οn civil and criminal matters.
4. Greece – Germany Treaty of 4.11.1961, ratified by Law 4305/1963, οn civil and commercial matters.
5. Greece – Georgia Treaty of 10.5.1999, ratified by Law 2813/2000, οn civil and criminal matters.
6. Greece – (Former) Socialist Federal Republic of Yugoslavia (still valid between Slovenia, Croatia, Serbia, Montenegro, North Macedonia, Bosnia – Herzegovina) Treaty of 18.6.1959, ratified by Law 4007/1959, οn civil, commercial and criminal matters.
7. Greece – China Treaty of 17.10.1994, ratified by Law 2358/1995, relating οn civil and criminal matters.
8. Greece – Cyprus Treaty of 5.3.1984, ratified by Law 1548/1985, on civil, family, commercial and criminal matters.
9. Greece – Lebanon Treaty of 5.4.1975, ratified by Law 1099/1980, on civil, commercial and criminal matters.
10. Greece – Hungary Treaty of 8.10.1979, ratified by Law 1149/1981, on civil and criminal matters.
11. Greece – Ukraine Treaty of 2.7.2002, ratified by Law 3281/2004, on civil matters.
12. Greece – Poland Treaty of 24.10.1979, ratified by Law 1184/1981, on civil and criminal matters.
13. Greece – Romania Treaty of 19.10.1972, ratified by Law 429/1974, on civil and criminal matters.
14. Greece – the (Former) Union of Soviet Socialist Republics, which is still valid between Greece and the post-Soviet countries: Russia, Azerbaijan, Belarus, Kazakhstan, Moldova, Tajikistan, Turkmenistan, Uzbekistan, (excluding Georgia, Armenia, Ukraine, which have entered into separate Treaties) Treaty of 21.5.1981, ratified by Law 1242/1982, on civil (including commercial and family) matters and judgments relating to judicial expenses.
15. Greece – Syria Treaty of 2.6.1981, ratified by Law 1450/1984.
16. Greece – (Former) Czechoslovakia (still valid between Greece and Czech Republic and Slovakia) Treaty of 22.10.1980, ratified by Law 1323/1983, on civil and criminal matters.
17. Greece – Tunisia Treaty of 12.4.1993, ratified by Law 2228/1994, on civil and commercial matters.
18. Greece-Ukraine Treaty, signed in 2.7.2002, but not ratified yet, on civil matters.

(C) International Conventions related to the enforcement of foreign judgments

Greece has signed and ratified the following International Conventions on civil and commercial judgments issued by the courts of the contracting States:

1. The Hague Convention on Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters 2019, ratified by EU (including Greece as a Member State of EU) on 29 August 2022, through EU Council Decision 2022/1206, adopted on 12 July 2022, and by Greece on 1 September 2023, as provided by the Convention rules.
2. The Lugano Convention on Jurisdiction and the Recognition and Enforcement of Judgments in Civil and Commercial Matters 2007 concerning recognition/enforcement of judgments originating from Switzerland, Norway and Iceland. The Convention was ratified by EU on 18.05.2009 and applied to Greece on 1.1.2010.
3. The Hague Convention of 2 October 1973 on the Recognition and Enforcement of Decisions relating to maintenance obligations ratified by Law 3171/2003.
4. The Hague Convention of 19 October 1996 on Jurisdiction, Applicable Law, Recognition, Enforcement and Cooperation with respect to Parental Responsibility and Measures for the Protection of Children ratified by Law 4020/2011.
5. EU Convention of 20 May 1980 on recognition and enforcement of decisions concerning custody of children and on restoration of custody of children ratified by Law 2104/1992 (applies only to judgments of courts of non-EU Member States that have not ratified the Hague Convention 1996).
6. The Hague Convention of 23 November 2007 on the International Recovery of Child Support and Other Forms of Family Maintenance. Greece is bound by the Hague Convention 2007 pursuant to its approval by the European Union.
7. The Hague Convention of 30 June 2005 on Choice of Court Agreement. Greece is bound by the Convention 2005 pursuant to its approval by the European Union.
8. The Geneva Convention of 19 May 1956 on the Contract for the International Carriage of Goods by Road, ratified by Law 559/1977.
9. The UNCITRAL Model Law of 30 May 1997 on Cross-Border Insolvency ratified by Law 3858/2010.

Greece has made Reservations only to the 1973 and 1996 Hague Conventions, expressly maintaining jurisdictional safeguards and limited application for certain sensitive family relationships.

1. Hague Convention of 2 October 1973 (Maintenance obligations)

Greece has made specific reservations under Article 26 of the Hague Convention. Greece reserves the right not to recognize or enforce decisions or settlements regarding maintenance obligations in the following cases:

• Between collaterals, except for brothers and sisters.
• Between in‑laws.
• Between spouses whose marriage has been declared void or annulled, when the decree (divorce, annulment, nullity) was rendered by default in a State, where the defaulting party did not have her habitual residence.

2. Hague Convention of 19 October 1996 (Parental Responsibility / Child Protection)

Greece has made specific reservations under Article 55(1)(b) of this Convention.

• It has reserved the jurisdiction of its own authorities to take protective measures regarding a child’s property located in Greece.
• It has reserved the right not to recognize foreign decisions on parental responsibility or protective measures that are incompatible with measures taken by Greek authorities, including provisional measures related to the child’s property.

In the absence of an applicable EU instrument or international/bilateral treaty, foreign civil judgments may be recognised and enforced under the Greek Code of Civil Procedure (GCCP), primarily Articles 323, 780, and 904–905.

• Recognition (ipso jure). If the Article 323 conditions are met, a foreign judgment rendered in contentious proceedings has res judicata effect in Greece without a separate recognition petition (e.g., no conflict with Greek public policy, proper jurisdiction of the foreign court under Greek conflict rules, due process, non- irreconcilable Greek judgment).
• Enforcement (exequatur). To execute the judgment in Greece, the creditor files an application for a declaration of enforceability under Article 905 GCCP before the Single-Member Court of First Instance (ex parte/voluntary jurisdiction), with the required documents and Greek translations.
• Non-contentious decisions. Foreign judgments from voluntary/ex parte proceedings are assessed under Article 780 (conflict-of-laws conformity and public-policy review).

It is noteworthy, where a specific convention, treaty or EU regime applies, those rules override the “GCCP”.

A foreign Court judgment may be recognized and declared enforceable in Greece, only if it satisfies the following core criteria, as set by the articles 323, 780, 904, 905 of the “GCCP” concerning recognition and enforcement of foreign judgments in Greece:

1. Finality / enforceability. In the state of origin, it is both final (res judicata) for recognition under Art. 323, and enforceable for an exequatur under Art. 905.
2. Jurisdiction. The foreign court has international jurisdiction under Greek conflict-of-jurisdiction principles (and no Greek exclusive jurisdiction has been infringed).
3. Due process. The defendant was properly served and had an unchallenged opportunity to be heard, without any deprivation of his defense rights.
4. Non incompatibility. It is not in conflict with a prior Greek judgment between the same parties on the same dispute (res judicata).
5. Greek public policy. Its content does not contravene standard business practices, or Greek public policy or good morals (ordre public/boni mores).
6. Non-contentious matters. Decisions delivered under voluntary jurisdiction are additionally reviewed under 780 GCCP (conflict-of-laws conformity and public-policy control).

Enforcement is not confined only to money judgments. Greek courts may recognise and enforce declaratory judgments and non-monetary orders (e.g., injunctions, specific performance, status or registral orders), provided they are determinable and compatible with Greek enforcement mechanisms and public policy. Criminal and administrative judgments are generally excluded from enforcement, unless they contain a civil compensation.

Because the Hague Convention is now operative as EU law, the Council Decision (EU) 2022/1206, it prevails over national legislation—including the Greek Code of Civil Procedure—whenever its provisions apply and conflicts might occur. This reflects its status as lex specialis, i.e., special law, in matters concerning recognition and enforcement of foreign judgments within civil and commercial contexts.

• EU judgments. Under Regulation (EU) 1215/2012 (Brussels I Recast), judgments of EU courts are directly enforceable in Greece without exequatur, via a document-based filing with the competent enforcement authority (see below Q.7/Q.8).
• Judgments under bilateral/multilateral instruments. Unless the applicable instrument itself provides a simplified route, foreign judgments issued under treaties, conventions, or other arrangements follow the general Greek exequatur procedure, as outlined under Q.6 below.

Enforcement of foreign judgments in Greece follows the standard exequatur procedure, under Article 905 “GCCP”: a foreign judgment is enforced only after it has been declared enforceable (exequatur) by the competent Single-Member Court of First Instance upon the petition of the interested party.

At the hearing of a petition for a declaration of enforceability, the claimant must file before the Greek court:

1. The foreign judgment (or a certified copy) together with proof of authenticity (typically an apostille) and a certified Greek translation.
2. A certificate (or equivalent document) issued by the state of origin asserting that the judgment is enforceable under the law of that state, together with a certified Greek translation.

The claimant bears the burden of proof that all conditions for recognition and enforcement are satisfied under the applicable regime (Greek law, a bilateral treaty, or an international convention). Potentially, the court may require additional documents. For example, where the judgment was issued in default, the claimant must submit a proof of service (e.g., a certificate of service) showing that the absent party was duly and timely summoned.

However, for EU judgments, enforcement is typically document-based before competent enforcement authority and more streamlined than ordinary recognition proceedings. In practice, the creditor files:

1. A copy of the judgment satisfying authenticity requirements.
2. A certificate from the Member State of origin confirming enforceability and containing an extract of the judgment and, where relevant, details on recoverable costs and interest.
3. Certified Greek translations of the above.

The duration of the exequatur proceedings depends on the caseload of the competent court and may be extended if an appeal is lodged. Indicatively:

• Hearing before the Court of First Instance: typically scheduled 3–6 months from filing.
• Issuance of the court’s decision: normally delivered 3–6 months after the hearing.

Summary procedure. There is no summary procedure available for non-EU foreign judgments.

However, as noted above ( see Q.7), EU judgments are exempted from the exequatur proceedings, since they are directly enforceable in Greece.

Interim relief may be granted while recognition/enforcement proceedings are still pending, provided the Greek courts have jurisdiction over the request and the statutory conditions for interim measures are satisfied.

The applicant to ensure an interim relief on the grounds of Art. 682 of GCCP must show:

1. the existence of a claim/right that must be secured or preserved, or a situation that must be temporarily regulated; and
2. an urgent need or imminent danger that must be repelled.

Where these conditions are met, the court may order appropriate interim measures (e.g., restraints on disposal of assets) to safeguard the effectiveness of the pending enforcement.

There is no statutory time limit in Greece to seek recognition of a foreign judgment; however, enforcement of a foreign judgment in Greece is subject to a general statutory 20-year limitation period from the issuance date of the foreign judgment.

Under Greek law—particularly Articles 323 and 905 of the Greek Code of Civil Procedure (GCCP)—the following grounds allow a defendant to object to the enforcement of a foreign judgment in Greece:

1. Lack of enforceability in the state of origin.

A judgment cannot be enforced in Greece if it is not enforceable according to the law of the issuing country.

2. Violation of boni mores or public policy.

Enforcement can be refused if the judgment is manifestly contrary to the Greek public policy, or boni mores or standard business practices, encompassing constitutional, moral, social, or legal values. Notably, Greek courts have held that punitive damages are enforceable, provided they are not excessive.

3. Lack of jurisdiction of the foreign court

If the foreign court did not have jurisdiction under Greek conflict-of-law rules, then enforcement may be challenged.

4. Violation of the right to a fair defense

If the defendant was deprived of the opportunity to defend themselves or participate in the proceedings—unless such deprivation derives from a law that applies equally to locals and foreigners—enforcement may be refused.

5. Conflict with a Greek judgment (res judicata)

Enforcement will be denied if there is a prior Greek judgment on the same dispute, between the same parties, which is final and binding (res judicata).

Greek courts do not have the power to reconsider the merits of a foreign judgment when it comes to recognition and enforcement. Their role is strictly limited to ensuring procedural and jurisdictional compliance rather than reviewing and re-litigating the substance of the case. This approach strongly supports legal certainty and respects the authority of foreign judicial decisions, provided they meet the procedural and jurisdictional safeguards set under Greek law.

When recognition or enforcement of a foreign judgment is sought, the Greek courts will examine primarily whether the foreign court had jurisdiction over the defendant, according to the Greek conflict of law rules and not the similar rules of the foreign court.

This reflects the “mirror-image” principle, pursuant to which:

• Greek courts mirror their own jurisdictional standards to test the foreign court’s competence.
• It is irrelevant which jurisdictional rules the foreign court actually applied.
• In practice, this means the judge asks: “If this case had been brought in Greece, would a Greek court of this type have had jurisdiction under our own rules?”

When applying the mirror-image test, the Greek court will examine the following criteria:

1. General jurisdiction rules under the Greek Code of Civil Procedure (GCCP), such as:
   • Defendant’s domicile or habitual residence in the foreign court’s country.
   • Place of performance of a contractual obligation.
   • Location of property for rights in rem.
2. Special jurisdiction rules for certain matters (e.g., tort, maintenance, consumer contracts).
3. Exclusive jurisdiction of Greek courts — If Greek law reserves exclusive jurisdiction over a matter (e.g., real property located in Greece, certain company law issues, public register matters), a foreign court’s judgment in such a case will not be recognized.

• If an EU regulation, Hague Convention, or bilateral treaty applies, the jurisdictional check will be made in line with those instruments instead of pure domestic rules.
• For example:
  • Brussels I Recast Regulation or Lugano Convention limits jurisdictional objections.
  • Under the 2019 Hague Convention, jurisdiction rules are harmonized and Greece must follow the Convention’s list of acceptable jurisdictional bases.

• Greek law does not prescribe the domestic method of service for the original foreign proceedings.
• Validity of service is determined under the law of the State where the judgment was rendered.
• Even if the service is valid under foreign law, Greek courts will refuse recognition, if the defendant was deprived of the right to defense, pursuant to the Art. 323.3 GCCP.
• Under Greek domestic rules (Art. 323 & 905 GCCP), default judgments can be recognized only if:
  • The defendant was given fair notice and opportunity to defend himself.
  • No other refusal grounds (public policy, lack of jurisdiction, res judicata conflict) apply.
• Besides, the ability to enforce a default judgment in Greece depends specifically on EU Regulation, bilateral treaty, or international convention rules.

In sum, ensuring procedural fairness equivalent to that available to Greek nationals is a public policy safeguard.

In Greece, recognition and enforcement of a foreign judgment is not    discretionary — it is a matter of strict legal compliance.

If any of the statutory preconditions are not met, the Greek court is bound to refuse the requested recognition or enforcement.

• This obligation arises chiefly under:
  • Articles 323 & 905 GCCP (for recognition and enforcement respectively)
  • Relevant EU regulations, international conventions, or bilateral treaties (when applicable)

Greek law applies the rule of a generalized enforceability of foreign judgments in Greece. Any foreign judgment from a foreign judicial body competent under its own domestic law to resolve civil disputes — including summary proceedings — can be recognized and enforced in Greece.

However, criminal and administrative court judgments are exempted, unless they award or contain civil law compensation orders (e.g., damages to a victim).

Recognition must be refused if enforcement would be manifestly contrary to Greek public policy both in:

• Substantive law (e.g., incompatible rights or obligations).
• Procedural law (e.g., violation of defense and due process rights of the defendant).

The issue of punitive and multiple damages has been addressed by two Supreme Court of Greece landmark cases:

• Supreme Court (Plenary) 17/1999
• Supreme Court 1260/2002

In those cases Supreme Court of Greece held that:

• Punitive damages do not automatically violate public policy.
• They are enforceable if they are not excessive with relevance to the actual harm suffered.
• In case they are disproportionate, enforcement must be refused on public policy grounds.

Under Greek law, the key factor is whether the judgment is enforceable in its State of origin, not whether an appeal is still pending. If foreign law allows the judgment to be enforced, despite a pending appeal, Greek courts may declare it enforceable in Greece. This is consistent with Articles 905 GCCP and relevant treaties/EU regulations, which require checking enforceability according to the law of the state of origin.

The judgment of the Single-Member Court of First Instance by which a foreign judgment is recognized or declared enforceable is subject to appeal by a party domiciled in Greece within 30 days and by a party domiciled abroad or having an unknown address within 60 days from service to that party of the Single-Member Court judgment. In case the judgment is not served by any party, the deadline of the appeal is two years starting from its official delivery (Article 518 of the GCC).

The Court of Appeal judgment is final and enforceable. The defeated party is entitled to file a Cassation Appeal against the Court of Appeal judgment before the Supreme Court on limited legal grounds (Article 552 and 553 of the GCCP); however, such an Appeal does not stay enforcement proceedings unless the Supreme Court grants the requested stay of enforcement either under terms or not (Article 565 of the GCCP).

The right to interest in the foreign judgment must be expressly stated in the foreign judgment itself or provided under the substantive law applied by the foreign court. If the foreign judgment is silent on interest and the applicable substantive law does not ipso jure provide for it, then Greek courts are not empowered to add any statutory interest rate on their own, unless the parties agreed on it. When the Greek court declares the foreign judgment enforceable, the enforcement order will include the interest terms exactly as recognised from the foreign judgment. Interest will then accrue during Greek enforcement as per the recognised terms. If the foreign interest rate is manifestly excessive and its enforcement would breach Greek public policy, the Greek court could reduce or refuse it (see Q.16).

The foreign judgment can remain in the original currency during the recognition (declaration of enforceability) proceedings before the Greek court. The court simply declares that the foreign decision is enforceable in Greece as is, including the foreign currency amount. Under Article 291 GCC (Greek Civil Code), the enforceable amount must be converted into euros for actual enforcement (e.g., seizure of assets, bank account garnishment). Conversion is done at the exchange rate on the date of payment, not the date of judgment or recognition.

The creditor seeking enforcement must initially pre-pay on his own all enforcement-related expenses. These include:

• Court filing fees for an enforcement order.
• Bailiff service fees
• Costs for service of documents
• Lawyer’s fees for enforcement procedure
• Translation or certification costs

Subsequently, the expenses may be recovered from the debtor on the enforcement proceedings, only if they were necessary for its successful outcome. If expenses are disputed, the debtor can challenge them before the competent enforcement court.

In Greece, there is no specific legal framework regulating third-party funding of the enforcement proceedings.

1. No statutory provisions
   • The Greek Code of Civil Procedure (GCCP) and other procedural statutes are silent on whether a third party (e.g., litigation funder, investor) can finance the enforcement of a judgment.
   • The Greek Code of Lawyers (the respective Greek Code of Ethics) provides a contingency fee agreement between lawyer and client amounting to 30% on the total recovery of the creditor.
   • Such arrangements are not outrightly prohibited, but they are also not expressly regulated.
2. Practical effect
   • Funding agreements are treated as private contracts between creditor and funder on the grounds of freedom of transactions.
   • As long as they do not violate general principles of Greek law (e.g., public policy, usury laws, ethical rules), funding agreements are considered valid.
3. Liability for adverse costs
   • There is no provision making a third-party funder automatically liable for the opposing party’s costs in enforcement proceedings.
   • Cost liability rests on the named party to the enforcement action (i.e., the judgment creditor).
   • The creditor could agree privately with the funder that the latter covers any adverse costs, but this is purely contractual and not enforceable by the court against the funder.
4. Regulatory context
   • Unlike in some common law jurisdictions, there is no licensing or regulatory regime for litigation or enforcement funding in Greece.
   • Ethical considerations for lawyers still apply — lawyers cannot share fees with non-lawyers, since it is prohibited by the Bar rules.

I hereby express my input on the most significant developments likely to shape the enforcement of foreign judgments in Greece landscape over the next five years, based on current legislative trends, EU initiatives, and judicial practice:

1. Digitalisation of Enforcement Proceedings

The Greek Ministry of Justice has been rolling out e-filing of enforcement applications, digital service of process, and electronic auctions. These are significant innovations resulting in shorter timelines for enforcement, especially in EU judgment cases.

2. The introduction of third-party funding in the Greek legislation

Litigation and enforcement funding by third parties shall render Greece an attractive hub for secure and effective enforcement of high-value judgments and awards.

3. Hague Convention 2019 has a broader impact in Greece since it allows:

• Broader, harmonised recognition rules for judgments from non-EU states that are also contracting parties of it.
• Reduction in parallel exequatur procedures and fewer disputes over jurisdiction.
• Likely to make Greece more attractive for cross-border asset recovery.

4. Harmonisation of enforcement procedures

The EU is exploring new digitalised instruments to:

• Streamline enforcement of judgments from third countries (complementing Hague 2019).
• Enhance asset tracing tools to locate debtor property across Member States.

This could lead to automatic recognition for a wider range of judgments, reducing the need for Greek domestic recognition proceedings.

5. Public Policy Test Becoming Narrower

• Though Greek courts have traditionally applied the public policy exception quite carefully (e.g., accepting even punitive damages if not excessive) an increasing reliance on EU and Hague instruments, shall render the scope for refusal on public policy grounds fundamentally narrower, limiting discretion of the courts.

6. Potential Regulation on Cross-Border Debt Recovery

Discussions are underway for a European procedure for the attachment of bank accounts and digital assets, which, if adopted, should provide Greek enforcement officers an access to EU-wide asset registers. This could transform the practical speed and effectiveness of enforcing foreign judgments in Greece.

The Hague Convention of 30 June 2005 on Choice of Court Agreements has been:

• signed by the EU through Council Decision 2009/397/EC on 1 April 2009.
• adopted by the European Union through Council Decision 2014/887/EU on 4 December 2014 (OJ L 353, 10.12.2014).
• entered into force in the EU on 1 October 2015.
• As Greece is an EU Member State, the Convention is directly applicable on Greece since 1 October 2015, without the need for any further national ratification.

The Hague Convention on Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters 2019 has been:

• adopted on 12 July 2022 by EU (excluding Denmark).
• ratified by EU on 29 August 2022 through EU Council Decision 2022/1206.
• As Greece is an EU Member State, the Convention is directly applicable on Greece since 1 September 2023, as provided by the Convention rules.