Enforcing Foreign IP Judgments and Injunctions in Greece (2026): Recognition, Routes and Practical Steps

Enforcing foreign IP judgments Greece has become a more structured, but also more strategically demanding, exercise in 2026. For rights-holders who have secured a trademark, patent, design or plant-variety decision abroad and now need to make it bite against assets, inventory or infringers located in Greece, the practical question is rarely whether enforcement is possible but which route is fastest, cheapest and least exposed to challenge. The answer depends on where the judgment originates: EU-origin decisions flow through the near-automatic machinery of Brussels I Recast, while non-EU decisions must pass through a national recognition (exequatur) procedure before a Greek court.

This guide sets out the recognition routes, the enforcement of injunctions and provisional measures, the document checklist, indicative timelines and costs, and a comparison table so that in-house counsel and litigators can move from a paper judgment to effective relief on the ground in Greece.

Recognition of foreign IP judgments in Greece, routes and legal tests

The starting point for enforcing foreign IP judgments Greece is to characterise the decision correctly. Recognition is the legal act by which a Greek court (or, for EU judgments, the Greek legal order directly) accepts that a foreign decision has effect; enforcement is the separate step of compelling compliance, seizing assets, stopping sales, recovering damages. A judgment must generally be recognised before it can be enforced, and the recognition route depends on the source of the decision and the instruments connecting that jurisdiction to Greece.

Four principal routes exist. First, the EU route under Regulation (EU) No 1215/2012 (Brussels I Recast), which applies to civil and commercial judgments, including IP infringement judgments, from other EU Member States. Second, the national recognition or exequatur procedure for judgments from third countries, governed principally by Articles 323, 780 and 905 of the Greek Code of Civil Procedure. Third, the Hague Convention on Choice of Court Agreements (2005), relevant where the parties designated an exclusive court. Fourth, any applicable bilateral treaty.

Across all routes, Greek courts retain a narrow set of grounds on which recognition may be refused, most prominently a manifest breach of Greek or EU public policy, defects in service that deprived the defendant of a fair opportunity to defend, and irreconcilability with an existing Greek decision between the same parties.

EU route, Brussels I Recast (Regulation 1215/2012)

For judgments originating in another EU Member State, the Brussels I Recast regime is transformative. A judgment given in one Member State and enforceable there is enforceable in Greece without any declaration of enforceability being required, the exequatur requirement was abolished for judgments falling within its temporal scope. In practice this means a rights-holder who obtains, say, a trademark infringement judgment with an injunction in Germany or France can proceed directly to enforcement in Greece on the strength of the foreign judgment plus a certificate issued by the court of origin.

The creditor presents to the competent Greek enforcement authority a copy of the judgment satisfying the conditions necessary to establish its authenticity, together with the Article 53 certificate issued by the court of origin, which attests to enforceability and summarises the decision. A certified Greek translation will typically be required for enforcement. The debtor retains the right to apply for refusal of enforcement on the limited grounds listed in the Regulation, including manifest contravention of public policy, failure of proper service where judgment was given in default, and irreconcilability with a Greek or earlier judgment. These grounds are construed restrictively; the Greek court does not review the substance of the foreign decision.

For IP practitioners the key advantage is speed: because recognition is automatic, provisional and protective measures can be pursued in parallel, and the enforcement timeline is measured in weeks rather than months when the paperwork is in order.

Non-EU judgments, national recognition (exequatur) under Greek law

Where the judgment originates outside the EU, a US district court patent judgment, a UK High Court trademark injunction following Brexit, or a decision from any third state, the EU regime does not apply and the creditor must obtain recognition and a declaration of enforceability through the Greek courts under the Greek Code of Civil Procedure. This is the exequatur procedure. The applicant files before the competent Greek court, producing an authenticated copy of the foreign judgment, proof that it is final and enforceable in the state of origin, apostille or consular legalisation as required, and a certified Greek translation.

The Greek court examines whether the foreign court had jurisdiction under principles acceptable to the Greek legal order, whether the defendant was duly summoned and able to defend, whether the judgment is final, whether it conflicts with Greek public policy, and whether it is irreconcilable with a Greek decision. The court does not re-try the merits. If these conditions are satisfied, it declares the judgment enforceable, and ordinary domestic enforcement measures then become available. This route is inherently slower and more contestable than the EU route, so for non-EU decisions the sequencing of protective measures, securing assets before the debtor dissipates them, becomes critical.

Choice of court agreements and the Hague Convention

Where the underlying commercial relationship contained an exclusive choice-of-court clause, the Hague Convention on Choice of Court Agreements (2005) may assist. Within its scope, a judgment given by a court designated in an exclusive choice-of-court agreement is, in principle, recognised and enforced in other contracting states on grounds comparable to those under the EU regime, with similarly narrow refusal grounds. Its practical reach in pure IP infringement disputes is limited by exclusions in the Convention, but it can be relevant in contractual IP matters, licence disputes, assignment claims and royalty enforcement, where a forum was agreed. Counsel should verify the contracting-party status of the originating state before relying on it.

Enforcing foreign injunctions and provisional measures in Greece

A final money judgment is one thing; an injunction or freezing order is another. Enforcing foreign injunctions Greece raises distinct questions because injunctive relief often needs to operate urgently, before a defendant can shift stock, move funds or continue infringing sales. The analysis again divides between EU-origin measures, which can travel under EU instruments, and situations where the rights-holder must instead invoke equivalent Greek domestic provisional measures.

Enforcement of EU interim measures, EAPO, injunctions and cross-border recognition

Provisional and protective measures ordered by a court in one Member State can be recognised and enforced in Greece under Brussels I Recast, subject to the conditions the Regulation sets for such measures, notably that they were ordered by a court with jurisdiction over the substance and, where ordered without the defendant being summoned, that they are served before enforcement. This allows a cross-border injunction to be given practical effect against infringers and their assets in Greece.

For asset preservation specifically, Regulation (EU) No 655/2014 established the European Account Preservation Order (EAPO), a self-standing EU procedure that allows a creditor to freeze funds held in a debtor’s bank account in another Member State without the debtor being alerted in advance. The EAPO is particularly valuable in IP enforcement where damages or an account of profits have been or are likely to be awarded and there is a real risk the debtor will move funds. The creditor applies to the court, demonstrates the conditions, including, in most cases, an existing judgment or a demonstrable risk to recovery, and, where granted, the order is transmitted and enforced against the Greek bank.

Because the procedure is designed for cross-border use and preserves the element of surprise, it is often among the most effective tools for a rights-holder facing a dissipation risk in Greece. Note that the EAPO does not apply where the debtor is domiciled in Denmark, and in purely domestic situations it is unavailable.

Domestic provisional measures supporting enforcement

Where EU instruments do not apply, for example where the substantive judgment is from a third country, or where urgent on-the-ground relief is needed pending exequatur, Greek domestic provisional measures (ασφαλιστικά μέτρα) provide the toolkit. These include conservatory seizure of assets, judicial sequestration, orders preserving the factual or legal status, and measures to secure or preserve evidence of infringement. The applicant must generally show a plausible claim on the merits (fumus boni iuris) and urgency or a risk that delay will cause irreparable harm (periculum in mora). The court may require the applicant to provide security, and in cases of exceptional urgency may grant a temporary order (προσωρινή διαταγή) pending a full hearing.

Rights-holders should assemble a robust, well-documented application, infringement evidence, the foreign decision, proof of the dissipation or continuing-harm risk, rather than relying on the existence of a foreign judgment alone. Greek courts expect a credible evidentiary basis and a clear demonstration of urgency before granting provisional relief.

Customs enforcement and border holds

Border measures are an underused but powerful complement when enforcing foreign IP judgments Greece against imported infringing goods. Regulation (EU) No 608/2013 governs customs enforcement of IP rights across the EU. A rights-holder files an application for action (AFA) with the competent Greek customs authority, identifying the protected rights and providing information to help identify suspect consignments. Where customs detect goods suspected of infringing, they may detain them, notify the right-holder, and, under the Regulation’s procedures, including the simplified procedure for destruction, the goods may be destroyed where infringement is confirmed and the conditions are met.

For a company that has already proven infringement abroad, a customs recordal in Greece provides a standing, low-cost interception mechanism that stops goods at the border before they reach the market, working alongside, not in place of, judicial enforcement.

Step-by-step process and required documents, a checklist for rights-holders

Successful enforcement depends on getting the documentary foundation right the first time. Defective translations, missing legalisation or an incomplete power of attorney are among the most common causes of avoidable delay. The following sequence takes a rights-holder from a foreign judgment to effective enforcement in Greece.

Document checklist

• Authenticated copy of the foreign judgment. A complete, certified copy satisfying the authenticity conditions of the enforcement route, for EU judgments, meeting the Brussels I Recast requirements; for non-EU judgments, duly certified by the issuing court.
• Article 53 certificate (EU judgments). The standard certificate issued by the court of origin confirming enforceability, required for the EU route.
• Proof of finality and enforceability (non-EU judgments). Documentation showing the judgment is final and enforceable in the state of origin.
• Apostille or consular legalisation. For judgments and supporting documents from states party to the Apostille Convention, an apostille; otherwise consular legalisation.
• Certified Greek translation. A certified translation of the judgment, certificate and key supporting documents into Greek, prepared to the standard Greek courts accept.
• Power of attorney. A properly executed and, where required, legalised power of attorney authorising Greek counsel to act, including authority to seek provisional measures.
• Evidence of service. Proof that the defendant was duly served in the original proceedings, particularly where judgment was given in default, a frequent battleground on refusal applications.
• Evidence of the infringement and of the enforcement target. Material identifying the infringing goods, the Greek assets or bank accounts, and the risk justifying any protective measure.

Filing procedure and templates

For EU judgments, the creditor proceeds to enforcement by presenting the authenticated judgment and the Article 53 certificate, with translation, to the competent Greek enforcement authority; no prior declaration of enforceability is needed. For non-EU judgments, the applicant files an application for recognition and a declaration of enforceability before the competent Greek court, attaching the full document bundle above. Where urgent protective relief is sought, a domestic freezing order or an EAPO, the provisional-measures application should be prepared in parallel and, where the law permits, lodged first to preserve assets before the debtor is alerted.

Applications must be drafted in Greek, state the legal basis precisely (citing the applicable regulation or statutory provision), and set out the factual grounds and the specific relief sought. Clear identification of the assets or accounts to be frozen materially improves the prospects of swift, effective enforcement.

Service, notification and evidence

Proper service and notification underpin the enforceability of what follows. In the exequatur route, the court scrutinises whether the original defendant was duly summoned; defects here are a recognised refusal ground. Within Greece, enforcement acts and, where applicable, provisional measures must be served in accordance with Greek procedural rules, and for measures ordered without the debtor present, service before enforcement is generally required. Rights-holders should also preserve a clear evidential chain proving the infringement and the enforcement target, since Greek courts, informed by the standards of Directive 2004/48/EC on the enforcement of intellectual property rights, expect a credible evidentiary basis for both substantive and provisional relief.

Timelines, costs and enforcement risks, what to expect when enforcing foreign IP judgments Greece

Realistic expectations on time and cost are essential to any enforcement strategy. The two routes diverge sharply, and the choice of route is a major driver of how quickly a rights-holder sees results.

Indicative timelines and cost factors

The EU route is markedly faster. Because recognition is automatic under Brussels I Recast and no exequatur is required, enforcement steps against identified Greek assets can typically be initiated within weeks of assembling the certificate and translation, with the overall process commonly running from a few weeks to a few months depending on whether the debtor mounts a refusal application and on the complexity of asset tracing. The non-EU exequatur route is slower: obtaining recognition and a declaration of enforceability generally takes several months and, in contested cases, can extend beyond a year before domestic enforcement even begins. These are indicative ranges only; actual timelines depend on court workload and the conduct of the parties.

Costs comprise court fees and applicable stamp duties and taxes, counsel fees, which scale with complexity and the degree of opposition, translation and legalisation costs, and, where provisional measures are sought, potential security that the court may require as a condition of granting protective relief. An EAPO or a domestic freezing order adds its own procedural cost but is frequently justified by the value preserved. Because precise figures turn on case value, the number of assets or accounts targeted, and the intensity of the dispute, rights-holders should budget for a range rather than a fixed sum and factor in the possibility of a security deposit at rates and amounts set by the competent court.

Defences and tactical considerations

Debtors resisting enforcement in Greece deploy a predictable set of defences, and anticipating them is central to risk mitigation:

• Lack of jurisdiction of the originating court. Particularly relevant in the exequatur route, where the Greek court examines whether the foreign court’s jurisdiction is acceptable to the Greek legal order.
• Defective service. Arguments that the defendant was not duly summoned or could not defend, especially against default judgments.
• Public policy. A manifest conflict with Greek or EU public policy, a narrow ground, but one that can be invoked against disproportionate or penal elements.
• Irreconcilable judgments. The existence of a Greek decision, or an earlier qualifying judgment, inconsistent with the foreign decision.
• Lack of finality. Contentions that the foreign judgment is not final or enforceable in the state of origin.

Tactically, the mitigation strategy is to front-load. Secure assets early through EAPO or domestic provisional measures, assemble unimpeachable service and finality evidence, ensure translations are certified to Greek standards, and instruct local counsel before the debtor has notice. The strength of the enforcement position when enforcing foreign IP judgments Greece is set not at the enforcement hearing but in the quality of the preparation that precedes it.

Comparison table, enforcement routes for enforcing foreign IP judgments Greece

Worked examples

Example 1, UK High Court trademark injunction (post-Brexit). A brand owner obtains a final injunction and damages award in the English High Court against a distributor channelling counterfeit goods through Greece. Because the UK is no longer within the EU regime, the brand owner cannot rely on Brussels I Recast. Counsel pursues the national recognition (exequatur) route: an authenticated copy of the judgment, proof of its finality, apostille, a certified Greek translation and a power of attorney are lodged with the competent Greek court. Anticipating delay, the brand owner simultaneously files for domestic provisional measures to preserve the infringing stock and, where a bank account is identified, considers asset preservation.

Outcome: provisional relief secures the goods, while the exequatur process confirms enforceability over the following months.

Example 2, US district court patent judgment. A technology company secures a patent infringement judgment and monetary award in a US federal court against a company with assets and a Greek bank account. As a non-EU judgment, recognition proceeds through exequatur. To protect recovery, counsel moves first on asset preservation, a domestic conservatory measure over the Greek account, supported by evidence of a dissipation risk, and prepares the full exequatur bundle in parallel. Outcome: the account is secured before the debtor reacts, and once the Greek court declares the judgment enforceable, the preserved funds are available to satisfy the award.

Conclusion, immediate next steps for rights-holders enforcing foreign IP judgments Greece

Enforcing foreign IP judgments Greece in 2026 rewards preparation, correct route selection and early protective action. EU-origin judgments move quickly under Brussels I Recast; non-EU decisions demand the more deliberate exequatur route, where securing assets before enforcement is often decisive. Across both, the EAPO and domestic provisional measures turn a paper judgment into real-world leverage, and customs recordals intercept infringing goods at the border. The immediate actions are:

• Assess the judgment type and source. Determine whether the EU, exequatur or Hague route applies.
• Preserve assets. Identify Greek accounts, inventory and assets at risk of dissipation.
• Apply for an EAPO or domestic freezing order if urgent. Move before the debtor has notice.
• Prepare certified translations and legalisation. Apostille or legalise and translate the judgment and supporting documents.
• Instruct local counsel. Engage Greek IP counsel to file and to handle provisional measures.
• Calculate security and budget. Anticipate court fees, counsel costs and any security deposit.
• Begin enforcement filings. Lodge the enforcement or exequatur application with the complete document bundle.

Sources

1. Regulation (EU) No 1215/2012 (Brussels I Recast)
2. Directive 2004/48/EC on the enforcement of intellectual property rights
3. Regulation (EU) No 655/2014 (European Account Preservation Order)
4. Regulation (EU) No 608/2013 on customs enforcement of IP rights
5. Hague Convention on Choice of Court Agreements (2005), HCCH
6. Hellenic Ministry of Justice
7. Areios Pagos (Supreme Court of Greece)
8. Hellenic Industrial Property Organisation (OBI)
9. European Union Intellectual Property Office (EUIPO)
10. European Patent Office (EPO)