How to Enforce an International Arbitral Award in Greece, Practical Guide for Counsel

To enforce an arbitral award in Greece, counsel must file an application for recognition and enforcement before the competent Single-Member Court of First Instance, attaching the certified award, the underlying arbitration agreement, official Greek translations and any required apostille or legalisation. The process is governed primarily by the 1958 New York Convention as implemented through Greek law, now consolidated under Law 5016/2023 on international commercial arbitration. The civil-procedure reforms introduced by Law 5221/2025, effective in 2026, have materially reshaped the enforcement procedure in Greece by introducing accelerated procedural tracks, tighter evidentiary deadlines and electronic filing requirements that shorten the path from petition to execution.

This guide provides a step-by-step enforcement playbook, document checklists, interim-relief strategies and tactical decision frameworks designed for in-house counsel, arbitration practitioners and creditors looking to convert an award into a collectible judgment on Greek territory.

Legal Framework, Law 5016/2023 and the New York Convention

Greece’s framework for the recognition and enforcement of arbitral awards rests on three interlocking pillars: the 1958 New York Convention, Law 5016/2023 and the Greek Code of Civil Procedure (CCP). Understanding how these instruments interact is the first step for any practitioner seeking to enforce an arbitral award in Greece.

The New York Convention, Greece’s primary enforcement gateway

Greece ratified the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards without the reciprocity reservation. As a result, foreign arbitral awards are recognised and enforced in Greece provided they satisfy the formal requirements set out in the Convention, principally, that the applicant furnish the duly authenticated award and the arbitration agreement. The Convention’s grounds for refusal, enumerated in Article V, remain the exhaustive list of defences available to the respondent in enforcement proceedings.

Law 5016/2023, key provisions affecting enforcement

Law 5016/2023 replaced and consolidated earlier provisions on international commercial arbitration in Greece. It modernised the arbitration statute by aligning domestic rules with the UNCITRAL Model Law and clarifying several points that previously generated satellite litigation:

• Res judicata upon issuance. An international arbitral award rendered under the law becomes res judicata and enforceable upon issuance, without the need for a separate declaration of enforceability, unless a party fails to comply voluntarily.
• Streamlined recognition criteria. The law codifies the recognition and enforcement procedure, removing ambiguities about which CCP provisions still apply and which have been superseded.
• Tribunal-court interface. Law 5016/2023 clarifies the powers of the arbitral tribunal to order interim measures and the mechanism by which those orders can be converted into enforceable court orders, a critical pathway for creditors needing urgent relief.

Where Law 5016/2023 is silent, the CCP fills the gap, particularly on execution measures, service requirements and appeal routes. Industry observers expect that court practice will continue to evolve as the judiciary absorbs the new statute alongside the procedural innovations of Law 5221/2025.

How to Apply for Recognition and Enforcement, Step by Step

The enforcement procedure in Greece follows a structured sequence. Counsel who prepare thoroughly at the front end, assembling a complete document pack and selecting the correct court, can avoid adjournments and accelerate the path to an enforceable order. The following numbered steps reflect current practice under Law 5016/2023 as shaped by the civil procedure reform of Law 5221/2025.

1. Instruct Greek counsel. Foreign award-holders must retain a licensed Greek lawyer (dikigoros) who will sign and file all court documents. A special power of attorney, either notarised or apostilled, is required.
2. Identify the competent court. The application is filed before the regional Single-Member Court of First Instance (see jurisdictional rules below).
3. Assemble the document pack. Prepare and certify every required document (see the checklist below). Missing or defective documents are the most common cause of delay.
4. Obtain certified translations. All non-Greek documents must be officially translated into Greek by a translator certified by the Greek Ministry of Foreign Affairs or the Hellenic Ministry of Justice.
5. File the application. Under the 2026 reforms, electronic filing is available, and in many courts required, through the integrated judicial portal. Paper filing remains possible where electronic systems are unavailable.
6. Serve the respondent. The application and supporting documents must be served on the debtor in accordance with CCP service rules. International service (where the respondent is abroad) must comply with the Hague Service Convention or applicable bilateral treaty.
7. Respondent’s opposition window. The debtor has a prescribed period to file written objections. The time limit runs from valid service.
8. Court hearing (if required). Many enforcement applications are decided on the papers. If the respondent files an opposition, the court schedules a hearing at which both parties submit evidence and arguments.
9. Issuance of enforcement order. If the court grants recognition and enforcement, it issues an executory formula (enforcement clause) appended to the award.
10. Execution. With the enforcement order in hand, counsel instructs a court bailiff to commence execution, seizure of bank accounts, garnishment of receivables, attachment of real property or movable assets.

Competent court and jurisdictional issues

The application for recognition and enforcement of arbitral awards in Greece is filed before the Single-Member Court of First Instance of the district where the debtor is domiciled or has assets. If the debtor has no known domicile in Greece, the court of the district where the assets are located has jurisdiction. For foreign awards, the Athens Court of First Instance is often chosen when assets are spread across multiple districts or their precise location is uncertain. Counsel should verify venue rules against the specific wording of Law 5016/2023 and any applicable bilateral treaty.

Document checklist, translations, apostilles and power of attorney

A complete filing pack reduces the risk of adjournments and requests for supplementary evidence. The following documents are required:

• Original award or certified copy. Authenticated in the manner required by the law of the country where the award was rendered.
• Arbitration agreement. Original or certified copy of the contract containing the arbitration clause (or the separate arbitration agreement).
• Certified Greek translations. Official translations of the award and the arbitration agreement, prepared by a certified translator.
• Apostille or legalisation. For awards issued in Hague Convention countries, an apostille suffices. For non-Hague countries, consular legalisation is required.
• Power of attorney. A special power of attorney authorising Greek counsel to file the application, notarised or apostilled as appropriate.
• Certificate of non-annulment (where available). A certificate from the seat court confirming that the award has not been set aside can strengthen the application, although it is not strictly mandatory under the New York Convention.
• Evidence of service of the award on the respondent. Proof that the debtor received the award (if available).

Typical procedural timeline and costs

Timelines vary depending on court workload, whether the respondent opposes and the complexity of service. The table below reflects estimated durations based on current practice in major Greek courts following the entry into force of the civil procedure reform (Law 5221/2025).

Early indications suggest that courts applying the accelerated tracks introduced by Law 5221/2025 are resolving unopposed applications materially faster than under the previous procedural regime. Counsel should factor in that international service remains the principal bottleneck in cross-border cases.

Interim and Provisional Measures, Tribunal vs Courts

Preserving assets while the enforcement application is pending is often the most commercially critical step. Greek law provides two parallel routes for interim measures in arbitration: orders issued by the arbitral tribunal itself and conservatory measures granted by the Greek courts. Law 5016/2023 explicitly recognises the tribunal’s power to order interim relief, and Law 5221/2025 has tightened the procedural framework for court-ordered measures, reducing waiting times for urgent applications.

Creditors seeking to obtain local court intervention in international arbitration may apply to the Greek courts for conservatory measures regardless of whether the arbitral tribunal has also been asked to act. Available measures include:

• Freezing orders (asfalistika metra). Court-ordered freezes on bank accounts and movable assets, preventing dissipation pending enforcement.
• Provisional attachment of real property. Registration of a pre-notation of mortgage (prosimeiosi ypothikis) against the debtor’s immovable assets.
• Garnishment of receivables. Orders directed at third-party debtors of the respondent, blocking payments due.
• Sequestration of goods. Judicial custody of specific movable property in dispute or at risk of removal.

The applicant must demonstrate a prima facie claim, urgency and a risk of asset dissipation. Greek courts generally apply a proportionality test, balancing the creditor’s interest in securing the award against the debtor’s right to continue business operations.

Emergency ex parte relief and attachment orders

In cases of extreme urgency, where advance notice to the debtor would defeat the purpose of the measure, Greek courts can grant interim relief on an ex parte basis. The applicant files an emergency petition supported by affidavit evidence, and the judge may issue a temporary order within hours. The debtor is subsequently served and afforded the opportunity to oppose the measure at an inter partes hearing scheduled shortly thereafter. Under the 2026 reforms, electronic filing of emergency petitions has further accelerated this process in courts that have adopted the digital portal.

Setting Aside and Annulment, Defences Available to the Debtor

Counsel seeking to enforce an arbitral award in Greece must anticipate the defences that a debtor may raise. The grounds for refusing recognition and enforcement mirror those in Article V of the New York Convention:

• Invalid arbitration agreement. The agreement was invalid under the law to which the parties subjected it, or under the law of the country where the award was made.
• Lack of proper notice. The respondent was not given proper notice of the arbitrator’s appointment or of the arbitral proceedings, or was otherwise unable to present its case.
• Excess of jurisdiction. The award deals with matters beyond the scope of the arbitration agreement.
• Procedural irregularity. The composition of the tribunal or the arbitral procedure did not conform to the parties’ agreement or the law of the seat.
• Award not yet binding or set aside. The award has been set aside or suspended by a court of the country in which it was made.
• 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 have historically construed this ground narrowly.

Where a separate annulment application has been filed at the seat, the Greek court may stay enforcement proceedings, but it is not obliged to do so. The likely practical effect is that the court will require the debtor to post security as a condition of any stay, preserving the creditor’s position. Tactically, creditors should address potential defences proactively in the enforcement application itself, including a brief rebuttal of foreseeable objections to accelerate the court’s analysis.

Strategic Decision, Enforce an Arbitral Award in Greece vs Elsewhere

Not every award should be enforced in Greece. The decision depends on where the debtor’s assets are located, the speed of the local courts and the risk profile of available defences. Counsel should conduct a thorough asset-mapping exercise before committing to a jurisdiction. The table below provides a simplified decision framework for dispute resolution mechanisms in cross-border enforcement.

Where assets are spread across multiple jurisdictions, parallel enforcement applications are common. Industry observers expect that Greece’s updated procedural framework will make it an increasingly attractive enforcement venue for awards with a Mediterranean or Southeast European nexus.

Practical Drafting Tips and Application Checklist

A well-drafted enforcement application maximises the chances of an expeditious, unopposed order. The following drafting principles reflect best practice under the current procedural regime:

• State the relief sought with precision. The prayer should request recognition and enforcement of the award and the issuance of an executory formula, specify the exact monetary amount (including interest and costs) or the non-monetary obligations to be enforced.
• Summarise the award and arbitration agreement. Include a concise factual summary, parties, seat, governing law, tribunal composition and key findings, so the judge can grasp the context without reading the full award.
• Attach a complete document pack. Cross-reference every attachment in the body of the application. Number exhibits sequentially and provide a table of contents for large bundles.
• Pre-empt defences. If there is a risk that the debtor will raise a public-policy or procedural objection, address it proactively in a short section of the application, citing relevant Greek case law where available.
• Request interim enforcement measures simultaneously. Where urgency exists, include a separate section (or a concurrent petition) requesting conservatory measures to prevent asset dissipation before the enforcement order is issued.
• Comply with electronic-filing requirements. Under Law 5221/2025, many courts require digital submission through the judicial portal. Ensure all documents are in the prescribed format and digitally signed by counsel.

These drafting points apply equally to enforcement applications under the New York Convention and to applications for enforcement of domestic international awards rendered under Law 5016/2023. Counsel should consult the preparation and conduct of arbitration hearings guide for upstream procedural considerations that affect the enforceability of the award itself.

Conclusion

Greece offers a robust, Convention-compliant framework for creditors and counsel seeking to enforce an arbitral award. The combined effect of Law 5016/2023 and the 2026 civil-procedure reform under Law 5221/2025 has created one of the more streamlined enforcement environments in Southeast Europe, provided that counsel prepare a complete document pack, select the correct court and deploy interim measures where asset dissipation is a concern. For practitioners navigating enforcement strategy across the commercial litigation landscape, Greece merits serious consideration as a primary or parallel enforcement venue.

Sources

1. Global Law Experts, Enforce Foreign Arbitral Awards Greece
2. Zepos & Yannopoulos, International Arbitration Review (Greece)
3. Global Arbitration Review, Challenging and Enforcing Arbitration Awards: Greece
4. ICLG, International Arbitration Laws and Regulations: Greece
5. New York Convention 1958, Greece Jurisdictions
6. Hellenic Republic Official Gazette (FEK)
7. Oxford Academic, Enforcement of Foreign Arbitral Awards in Greece
8. GreekLawDigest, Enforcement of Foreign Judgments and Arbitral Awards in Greece