How to Enforce Foreign Arbitral Awards and Obtain Provisional Relief in Greece After the 2025 Civil‑procedure Reforms

If you need to enforce foreign arbitral awards in Greece, the procedural landscape has shifted significantly since July 28, 2025, when Law 5221/2025 (FEK A 133/28. 07. 2025) overhauled the Greek Code of Civil Procedure. The reform introduced accelerated hearing tracks, tightened evidentiary deadlines, and modernised the provisional measures framework, changes that directly affect how creditors, arbitration counsel and recovery teams pursue recognition and execution of foreign awards. This guide provides a step‑by‑step enforcement workflow, a document‑filing checklist, provisional relief options and practical court practice notes updated for proceedings commenced in 2026.

Whether you hold an ICC, LCIA, SIAC or ad hoc award, the decision pathway below will help you move from award to recovery as efficiently as the reformed Greek system now allows.

Quick‑take decision checklist

• Identify your instrument. Is it a foreign arbitral award, a foreign court judgment, or a domestic Greek award? The enforcement route differs for each.
• Confirm treaty coverage. Is the award from a New York Convention contracting state? If yes, proceed via the NYC recognition route under the Greek Code of Civil Procedure (CCP).
• Assess urgency. Do you need interim relief in Greece to prevent asset dissipation before the enforcement hearing? If so, file for provisional measures concurrently.
• Assemble the document pack. Certified award, arbitration agreement, Greek translations, apostille/legalisation, power of attorney, and court‑fee receipts, all required at filing.
• Engage local counsel early. Post‑reform accelerated timelines mean missing a procedural window can delay enforcement by months. Find a Greek enforcement counsel through the Global Law Experts directory.

Greek Code of Civil Procedure Reform 5221/2025, What Changed for Enforcement and Provisional Relief

Law 5221/2025 was published in the Government Gazette (FEK A 133) on July 28, 2025, and its provisions apply to proceedings filed after that date. The reform’s full title, “Interventions in the Code of Civil Procedure”, understates its scope: it touches procedural acceleration, evidence handling, interim measures and enforcement execution across dozens of CCP articles.

Key provisions affecting enforcement proceedings

• Accelerated hearing tracks. New scheduling rules compress the period between filing and first hearing for recognition/enforcement applications, particularly in the single‑member Court of First Instance.
• Expedited evidence and submissions. Tighter deadlines for the exchange of written submissions and documentary evidence reduce the risk of tactical delay by respondents.
• Provisional measures modernisation. Revised interim relief provisions clarify the standards for granting conservatory attachment and freezing orders, and expand the court’s discretion to act ex parte where dissipation risk is shown.
• Transitional rules. Proceedings commenced before July 28, 2025, continue under the prior procedural regime. Mixed situations, where an award was filed before the reform but the hearing falls afterwards, are governed by specific transitional articles in Law 5221/2025.

Practical implications for claimants and respondents

For award‑holders, the reform is broadly favourable: shorter timelines, tighter procedural discipline, and improved provisional relief tools. Respondents, meanwhile, face narrower windows to organise defences. Industry observers expect that the combined effect of these changes will reduce the typical enforcement timeline in the Athens courts by several weeks compared to pre‑reform practice.

Which Enforcement Route to Use, Decision Checklist for Foreign Arbitral Awards in Greece

Before filing, practitioners must determine the correct legal basis for recognition and enforcement. For most cross‑border enforcement in Greece, the New York Convention (NYC) route is the default. However, bilateral treaties and, in limited cases, EU instruments may also apply.

When to use the NYC route vs treaty vs domestic CCP registration

Greece ratified the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards and applies it on a reciprocity basis for awards rendered in other contracting states. Where the seat of arbitration is in a country that has a bilateral enforcement treaty with Greece, the treaty may provide a more direct, or occasionally more restrictive, pathway. EU regulations (such as the Brussels I Recast) do not directly apply to arbitral awards, but they govern the enforcement of foreign judgments in Greece and may become relevant where a related court judgment accompanies an award.

Enforcement of foreign judgments vs arbitral awards, recognition without retrial

A frequent question is whether a foreign judgment can be enforced in Greece without a fresh trial. The answer is yes, under both the New York Convention (for awards) and the Brussels I Recast Regulation (for EU judgments), Greek courts recognise and enforce foreign titles without re‑examining the merits. The court’s review is limited to verifying procedural regularity, proper service, and the absence of public‑policy violations. This principle remains unchanged by Law 5221/2025 and is well established in Greek jurisprudence.

Step‑by‑Step: How to Enforce Foreign Arbitral Awards in Greece, Practical Filing Checklist and Timeline

The following numbered steps trace the complete lifecycle of a New York Convention enforcement application under the reformed CCP. While the exact procedural articles referenced here reflect the post‑5221/2025 framework, the core sequence, file, serve, hearing, judgment, execution, remains structurally consistent with prior practice.

Enforce arbitral award steps: the 10‑stage process

1. Instruct Greek counsel. Appoint a lawyer admitted to practice before the competent Court of First Instance. Issue a notarised power of attorney (apostilled if signed abroad).
2. Assemble the document pack. See the full checklist below.
3. Obtain certified translations. All non‑Greek documents must be translated into Greek by an official translator and certified by the Greek Ministry of Foreign Affairs or a Greek consulate.
4. Apostille or legalise the award. If the seat state is a Hague Apostille Convention member, obtain an apostille; otherwise, arrange full consular legalisation.
5. Draft the recognition and enforcement application. The application is addressed to the competent single‑member Court of First Instance at the place of enforcement (typically the debtor’s domicile or registered office in Greece, or the location of assets).
6. Pay court fees. Court fees are calculated as a percentage of the award amount. Obtain and attach the fee receipt to the filing.
7. File the application. Submit electronically or in person at the court registry. Under post‑5221/2025 practice, electronic filing is increasingly the norm in larger courts.
8. Serve the debtor. Service of the application and supporting documents on the respondent must comply with CCP requirements. If the debtor is abroad, service may be effected through the Hague Service Convention, bilateral treaty, or consular channels, factor in additional time.
9. Attend the hearing. The court examines whether the NYC grounds for refusal apply. No retrial of the merits takes place. Under the accelerated tracks introduced by Law 5221/2025, hearings are scheduled more promptly than under the prior regime.
10. Obtain the enforcement judgment and writ of execution. Once the court declares the award enforceable, the clerk issues a writ of execution (apógramma), which authorises seizure, garnishment and other enforcement measures against the debtor’s Greek assets.

How to register a foreign award in Greece, document checklist

• Original or certified copy of the arbitral award.
• Original or certified copy of the arbitration agreement (or the arbitration clause within the contract).
• Certified Greek translations of both documents.
• Apostille or consular legalisation for the award and arbitration agreement.
• Power of attorney in favour of Greek counsel, notarised and apostilled.
• Statement of claim / application for recognition and enforcement.
• Evidence of service of the arbitration proceedings on the respondent (to counter a potential “no proper notice” defence).
• Court fee receipt.
• Affidavit or declaration confirming enforceability, that the award is final and binding and has not been set aside at the seat.

Sample application structure

While Greek courts do not prescribe a rigid template, a well‑organised application typically includes the following sections:

1. Parties and their particulars (including addresses for service).
2. The arbitral award, date, seat, arbitral institution, and the tribunal’s composition.
3. Summary of the dispute and the relief granted.
4. Legal basis for recognition: New York Convention, Articles of the CCP.
5. Verification that none of the NYC Article V refusal grounds apply.
6. Prayer for relief: declaration of enforceability and issuance of a writ of execution.

Timeline, expected enforcement duration under Law 5221/2025

Practical filing tips

• Translations. Use a translator familiar with legal terminology; errors or ambiguities in translations are a common ground for adjournment requests by respondents.
• Electronic filing. In Athens and Thessaloniki, electronic filing through the Integrated Judicial Case Management System (OSDDY-PP) is standard. Ensure your counsel has active e‑filing credentials.
• Service abroad. When the debtor is outside Greece, start the service process early. Hague Service Convention channels can take months in certain jurisdictions.
• Forum selection. If the debtor has assets in multiple Greek locations, choose the court at the place where the most valuable assets are situated to streamline execution.

Obtaining Provisional Measures in Greece, Forms, Evidence and Timing

A successful enforcement judgment is meaningless if the debtor’s assets have been dissipated in the interim. Provisional measures in Greece, available both before and during recognition proceedings, are a critical tool for creditors seeking to enforce foreign arbitral awards in Greece. Law 5221/2025 refined the interim relief framework, giving courts broader discretion to act quickly where dissipation risk is demonstrated.

Legal bases and procedural route

Greek law provides for several categories of interim relief in Greece under the CCP. The most common in the enforcement context are:

• Conservatory attachment (syntiritiki katáschesi). A pre‑judgment seizure of the debtor’s movable or immovable property, bank accounts, or receivables. This is the closest Greek equivalent to a Mareva‑style freezing order.
• Interim injunction (prosorinó métra). An order restraining the debtor from specific acts, for example, transferring shares, encumbering real estate or removing goods from Greece.
• Security deposit order. The court may require the debtor to deposit funds or furnish a bank guarantee as security pending enforcement.

Applications for provisional measures are heard by the single‑member Court of First Instance sitting in urgent‑procedure (asfalistiká métra) proceedings. In cases of exceptional urgency, the court can grant relief ex parte, without prior notice to the respondent, on the basis of an affidavit demonstrating imminent risk of irreparable harm or asset dissipation.

Practical evidence checklist for interim relief

• Affidavit of urgency. A sworn statement setting out the factual basis for urgency, the nature of the underlying claim (the arbitral award), and specific evidence of dissipation risk.
• Proof of the underlying claim. A certified copy of the arbitral award (with translation), this establishes the fumus boni iuris (prima facie case).
• Evidence of likely dissipation. Concrete facts: recent asset transfers, sale of property, closure of bank accounts, corporate restructurings designed to hollow out the debtor entity, or statements by the debtor indicating intent not to pay.
• Asset identification. Bank account details, property registry extracts, vehicle registrations, share registers, as much specificity as possible to enable the court to craft a targeted order.
• Balance of convenience. An explanation of why the harm to the creditor from non‑intervention outweighs any potential harm to the debtor from the interim order.

How provisional relief interacts with enforcement

Critically, a creditor does not need to wait for the enforcement judgment before seeking provisional measures. The application for conservatory attachment or an interim injunction can be filed simultaneously with, or even before, the enforcement application. This parallel filing strategy is especially important when cross‑border enforcement in Greece involves a debtor known to be restructuring or liquidating assets. Once the enforcement judgment is obtained, the conservatory attachment converts into a definitive seizure, and execution proceeds directly against the secured assets.

Practical Court Practice Notes, Costs and Likely Defences

Greek courts have a well‑established and generally pro‑enforcement approach to New York Convention awards. The grounds for refusing recognition are narrowly construed and mirror Article V of the NYC. Respondents most commonly raise:

• Public policy (ordre public). The award allegedly violates fundamental principles of Greek law. Greek courts interpret this restrictively, mere disagreement with the tribunal’s reasoning does not suffice.
• Lack of proper notice. The respondent claims it was not given proper notice of the arbitral proceedings. Countered by filing comprehensive evidence of service at the arbitration stage.
• Excess of jurisdiction. The tribunal allegedly exceeded the scope of the arbitration agreement. Detailed review of the arbitration clause and the award’s dispositif neutralises this defence.
• Irregularity of the tribunal. Composition or appointment of arbitrators allegedly departed from the parties’ agreement or applicable rules.

Court fees, security and bond practice

Court fees for enforcement applications are proportional to the value of the award and are generally modest compared to other European jurisdictions. Legal counsel fees are not regulated by a fixed tariff for enforcement proceedings, but practitioners typically charge on a combination of fixed and success‑based fees. The court may, in certain interim relief applications, require the applicant to post a security bond to compensate the respondent if the interim measure proves unjustified, early indications suggest that post‑5221/2025 courts are exercising this power more frequently.

Common judicial attitudes, practical insights

Industry observers note that Greek judges in 2026 are increasingly familiar with international arbitration and the NYC framework. Enforcement applications supported by a complete document pack and clear translations face minimal judicial resistance. The likely practical effect of the accelerated tracks under Law 5221/2025 is that respondents have fewer opportunities for procedural delay, and courts are less tolerant of adjournment requests unsupported by genuine procedural need.

Choosing Counsel, Jurisdictional Traps and Cross‑Border Execution

Selecting the right local counsel is the single most important tactical decision when seeking to enforce foreign arbitral awards in Greece. Key criteria include experience with New York Convention enforcement, familiarity with the post‑5221/2025 procedural regime, and the ability to move quickly on provisional relief applications.

When to seek provisional relief in parallel with enforcement abroad

Where the debtor holds assets in multiple jurisdictions, consider filing for provisional measures in Greece simultaneously with enforcement applications in other countries. Greek provisional measures protect Greek‑situs assets, real estate, bank accounts held with Greek banks, receivables owed by Greek entities, while parallel proceedings abroad secure assets elsewhere. Coordinating multi‑jurisdictional enforcement requires counsel experienced in cross‑border enforcement in Greece and the interaction between different national procedural regimes.

Operational checklist for insurance and credit recovery teams

• Obtain asset intelligence on the debtor’s Greek holdings before filing.
• Instruct Greek counsel with a clear enforcement mandate and authority to apply for provisional measures without delay.
• Prepare the full document pack (translations, apostilles) in advance, do not wait for filing deadlines.
• Monitor the debtor’s corporate registry filings and property records for signs of asset restructuring.
• Coordinate with enforcement counsel in other relevant jurisdictions to avoid conflicting proceedings.

Conclusion

The Greek Code of Civil Procedure reform under Law 5221/2025 has made it faster and more predictable to enforce foreign arbitral awards in Greece, while strengthening the provisional relief toolkit available to creditors. Success depends on early preparation, assembling a complete document pack, engaging experienced local counsel, and filing for interim measures in parallel where asset dissipation is a risk. For guidance tailored to your specific award and enforcement target, connect with a specialist Greek enforcement lawyer through the Global Law Experts directory.

Sources

1. FEK / Government publication of Law 5221/2025 (FEK A 133/28.07.2025)
2. Kodiko, Nomos 5221/2025 (compiled text)
3. Global Arbitration Review, Greece enforcement guide
4. ICLG, International Arbitration (Greece)
5. Zepos & Yannopoulos, International Arbitration Review
6. Global Law Experts, Enforcing foreign arbitral awards & judgments (Greece)
7. Oxford Academic, The Enforcement of Foreign Arbitral Awards in Greece
8. Hellenic Parliament, Legislative entry for Law 5221/2025
9. GreekLawDigest, Enforcement overview
10. UNCITRAL, New York Convention contracting states