Enforcement of Foreign Judgments in Greece (2026): Routes, Exequatur, Deadlines & Public Policy

Last updated: June 7, 2026, Reviewed for Law 5221/2025 & 2026 amendments to the Greek Code of Civil Procedure.

Executive Summary: Can You Enforce a Foreign Judgment in Greece?

Yes, the enforcement of foreign judgments in Greece is available regardless of the country where the judgment was originally issued, provided the applicable procedural route is followed and specific substantive requirements are met. Greece offers multiple pathways depending on the origin of the judgment, and the recent reforms introduced by Law 5221/2025 have materially altered filing mechanics, timelines and case management for all recognition and enforcement proceedings. Whether you are a judgment creditor holding a German court order, a UK High Court award or a US federal judgment, Greek law provides a structured mechanism to convert your foreign title into an enforceable domestic instrument.

The three principal routes for recognition and enforcement in Greece are:

• EU route, Brussels I Recast (Regulation (EU) No 1215/2012). Judgments from EU Member States are automatically enforceable in Greece without any need for an exequatur declaration. The judgment creditor files the required certificate and supporting documents directly with the competent Greek court to commence execution.
• Exequatur procedure (non-EU judgments). Judgments from non-EU states, including the United States, China, the UAE and most other jurisdictions, require a formal petition for a declaration of enforceability before a Greek single-member court of first instance. This is the classic exequatur route governed by Articles 323 and 905 of the Greek Code of Civil Procedure (GCCP).
• Bilateral and multilateral conventions. Greece has concluded bilateral judicial cooperation treaties with several countries, including a number of Balkan states and, historically, the United Kingdom. Where such a convention exists, its terms may simplify or modify the standard exequatur requirements.
• 2026 procedural reforms. Law 5221/2025 and its follow-on 2026 amending provisions have updated deadlines, introduced digital filing capabilities and adjusted case-management rules, all of which affect the practical timeline for enforcement of foreign judgments in Greece.

2026 Reforms: What Changed Under Law 5221/2025 and the 2026 Amendments

The Greek Code of Civil Procedure 2026 landscape looks markedly different from the regime practitioners operated under as recently as 2024. Law 5221/2025, enacted in the second half of 2025, introduced a package of procedural reforms designed to modernise Greek civil litigation, reduce case backlogs and align Greek procedure more closely with EU digital-justice initiatives. Several of these reforms directly affect the enforcement of foreign judgments in Greece.

Key Changes for Enforcement Practitioners

The reforms touch several areas relevant to cross-border judgment creditors:

• Digital filing and electronic service. Law 5221/2025 expanded the mandatory use of the Integrated Judicial Case Management System (OSDDY-PP) to cover petitions for recognition and exequatur. Practitioners can now file enforcement petitions electronically in participating courts, reducing administrative delays associated with physical filing.
• Revised case-management and hearing schedules. The 2026 amendments introduced tighter deadlines for the scheduling of hearings in non-contentious (voluntary jurisdiction) proceedings, which is the procedural category under which most exequatur petitions are heard. Industry observers expect this to compress overall petition-to-decision timelines.
• Updated service-of-process rules. Amendments to the GCCP service provisions affect how and when documents must be served on the judgment debtor in recognition proceedings, including the formal requirements for service on parties domiciled abroad.
• Streamlined translation and authentication requirements. The reforms clarified the acceptable formats for certified translations and the interplay between apostille-authenticated documents and documents legalised through consular channels.

Timeline of Key Legislative Dates

Practitioners should note that while Law 5221/2025 modernises the procedural framework, the substantive requirements for recognition and enforcement of foreign judgments in Greece, the tests in Articles 323 and 905 GCCP, remain unchanged. The reforms affect how you file rather than whether enforcement succeeds. For further context on recent Greek legislative developments, see the Greece Golden Visa 2026 changes guide.

EU Route: Brussels I Recast and Automatic Enforceability in Greece

For judgments issued by courts of EU Member States, the enforcement of foreign judgments in Greece follows a streamlined route under Regulation (EU) No 1215/2012 (the Brussels I Recast). The hallmark of this regime is the abolition of exequatur: a judgment given in one EU Member State that is enforceable in the state of origin is automatically enforceable in Greece without any prior declaration of enforceability.

Under Articles 39 and 41 of the Brussels I Recast, the judgment creditor may proceed directly to enforcement measures, attachment of assets, bank account seizures, property liens, by presenting the judgment and a certificate issued by the court of origin (using the standard form in Annex I to the Regulation) to the competent Greek enforcement authorities.

Step-by-Step: Enforcing an EU Judgment in Greece

1. Obtain the certificate. Request the court that issued the judgment to complete the certificate under Article 53 of the Brussels I Recast (Annex I form). This certificate confirms the enforceability of the judgment and contains essential details (parties, amount, interest, costs).
2. Prepare a certified translation. The judgment and certificate must be translated into Greek by a certified translator. Under Greek practice, translations are typically prepared by a lawyer admitted to a Greek bar or a certified translator accredited by the Hellenic Ministry of Foreign Affairs.
3. Instruct a Greek lawyer. A Greek-qualified attorney must be instructed to serve the enforcement documents on the judgment debtor and liaise with the competent bailiff (dikastikos epimelistis).
4. Serve the judgment debtor. The judgment, certificate and certified translation must be served on the debtor before enforcement measures can commence. Service of process in Greece follows the rules of the GCCP as amended by Law 5221/2025.
5. Commence enforcement. Once service is completed and any applicable waiting period has elapsed, the bailiff may proceed with execution, asset seizure, garnishment of bank accounts, registration of liens on immovable property or other available measures.

Documents Required for EU-Route Enforcement

The judgment debtor may apply to refuse enforcement under Article 45 of the Brussels I Recast, but the grounds are narrow: breach of public policy, failure to serve the defendant in the original proceedings, irreconcilability with a Greek judgment, or irreconcilability with an earlier judgment from another state. Greek courts apply these exceptions restrictively. For a broader discussion of international commercial law frameworks, see our dedicated practice guide.

Non-EU Judgments and the Exequatur Procedure in Greece

Where a judgment originates from a non-EU state, the creditor must obtain a formal declaration of enforceability, the exequatur, from a Greek court before any execution measures can begin. This is the route that applies to judgments from jurisdictions such as the United States, Switzerland (outside the Lugano Convention framework), the United Arab Emirates, China and most other non-EU countries. The exequatur procedure in Greece is governed by Articles 323 and 905 of the GCCP.

Substantive Requirements for Recognition

Under Article 323 GCCP, a foreign judgment will be recognised and declared enforceable in Greece provided it satisfies all of the following requirements:

• Jurisdiction of the foreign court. The court that rendered the judgment must have had jurisdiction under the rules of private international law as accepted by Greek law.
• Finality and enforceability. The judgment must be final and enforceable in the state where it was rendered. Provisional or interlocutory decisions do not qualify.
• Due process. The losing party must have been duly summoned and given a fair opportunity to participate in the proceedings. Any deficiency in service of process in the original proceedings is a common ground for challenge.
• No conflict with Greek public policy. The judgment must not conflict with Greek public policy (ordre public) or with fundamental principles of Greek law, including constitutional guarantees and human rights norms.
• Reciprocity. The state of origin must, at least in principle, recognise and enforce Greek judgments on a reciprocal basis. This requirement is interpreted broadly by Greek courts and is rarely a decisive obstacle in practice.

Step-by-Step: Filing an Exequatur Petition

1. Identify the competent court. The petition is filed before the Single-Member Court of First Instance (Monomeles Protodikeio) of the district where the judgment debtor is domiciled in Greece, or where enforcement is to take place.
2. Prepare the petition. The petition must set out the foreign judgment, the basis for recognition and the enforcement measures sought. It is drafted in Greek and signed by a Greek-qualified lawyer.
3. Assemble supporting documents. These include a certified copy of the foreign judgment, proof of finality and enforceability in the state of origin, proof of proper service on the losing party, certified Greek translation of all documents, and apostille or consular legalisation as appropriate.
4. File and serve. Under the post-Law 5221/2025 regime, the petition may be filed electronically in courts that have adopted the OSDDY-PP system. The petition must be served on the judgment debtor.
5. Hearing and decision. The court examines the petition, typically in a voluntary-jurisdiction hearing. Under the 2026 reforms, hearings are scheduled more promptly. The court does not review the merits of the underlying dispute, it examines only whether the Article 323 conditions are met.
6. Enforcement. If the court grants the declaration of enforceability, the creditor may proceed with execution through a bailiff, following the same enforcement mechanisms available for domestic Greek judgments.

When Bilateral Conventions Change the Route

Greece has entered into bilateral judicial cooperation conventions with several countries, including a number of Balkan states (such as Albania, Bulgaria and Romania, though the latter two now fall under the Brussels I Recast as EU members). These conventions may simplify the documentary requirements, eliminate the reciprocity condition or provide for expedited processing. Practitioners should always verify whether a bilateral instrument is in force between Greece and the judgment-originating state before commencing the standard exequatur procedure. To connect with lawyers in Greece experienced in cross-border enforcement, consult our directory.

Practical Documentary and Procedural Requirements

Regardless of whether enforcement proceeds under the EU route or the exequatur procedure, preparation of a complete and properly authenticated document package is essential. Incomplete filings are one of the most common causes of delay in the enforcement of foreign judgments in Greece.

Complete Document Checklist

Service of Process in Greece

Service of process in Greece follows the rules of the GCCP. Documents are typically served through a bailiff (dikastikos epimelistis). Where the judgment debtor is domiciled abroad, service may be effected through the Hague Service Convention (where applicable) or through bilateral judicial assistance channels. The 2026 reforms under Law 5221/2025 have expanded the scope of electronic service in certain circumstances, though physical service through a bailiff remains the standard method for enforcement-related documents. Local counsel plays an indispensable role in ensuring service is properly effected and documented, as any deficiency can be exploited by the judgment debtor to resist enforcement.

Deadlines, Limitation Periods and Timing for Enforcement of Foreign Judgments in Greece

One of the most critical practical questions for judgment creditors is: how long do you have to commence enforcement proceedings? Greek law applies its own limitation rules to the enforcement of foreign judgments, and these rules interact with the date of the original judgment and the procedural reforms introduced in 2026.

Under Greek law, the general limitation period for the enforcement of a judgment is twenty years from the date the judgment became final. This principle applies to domestic Greek judgments and serves as the baseline for foreign judgment enforcement as well. However, the precise application of limitation rules to foreign judgments involves complex private-international-law analysis.

Limitation Period for UK Judgments in Greece

A question of particular practical significance, especially post-Brexit, is the limitation period for enforcement of a UK judgment in Greece. Greek courts have examined this issue in recent case law. According to analysis published in 2025, a Greek court held that the limitation period for commencing enforcement of a UK judgment in Greece is governed by Greek procedural law, applying the twenty-year limitation period from the date the judgment became final in the UK. The court distinguished between the enforceability of the judgment (which is subject to Greek procedural law) and the conditions of enforcement in the country of origin.

Impact of 2026 Reforms on Timeframes

While the substantive limitation periods remain unchanged, the procedural reforms under Law 5221/2025 affect the practical timeline from filing to decision. The revised case-management rules and tighter hearing schedules are expected to reduce the time between filing an exequatur petition and obtaining a court decision. Industry observers expect the reforms to shorten average processing times, particularly in courts that have fully adopted the digital filing system. For related Greek regulatory updates, see our guide on the 5-year residence permit in Greece.

Common Defences and Public Policy Exceptions

Judgment debtors facing enforcement proceedings in Greece have several grounds on which to resist recognition. Understanding these defences is critical both for creditors (to anticipate and pre-empt challenges) and for debtors (to identify viable objections).

The principal grounds for refusing recognition and enforcement include:

• Lack of jurisdiction. If the court of origin did not have jurisdiction under the rules of private international law recognised by Greek law, the judgment will not be enforced.
• Breach of due process / service defects. The most commonly invoked defence. If the defendant was not properly served with the originating proceedings and was therefore unable to participate, Greek courts will refuse enforcement. This is a defence with a relatively high success rate when service defects can be documented.
• Public policy (ordre public). A judgment that conflicts with fundamental principles of Greek public policy will be refused enforcement. Greek courts interpret this ground narrowly, it applies only to manifest and serious violations of core legal principles, constitutional guarantees or fundamental human rights, not mere disagreement with the foreign court’s legal reasoning.
• Irreconcilability with a Greek judgment. If a Greek court has already rendered a judgment between the same parties on the same cause of action, the foreign judgment cannot be enforced.
• Irreconcilability with an earlier foreign judgment. Where an earlier foreign judgment, already recognised in Greece, conflicts with the judgment sought to be enforced, enforcement will be refused.
• Fraud. Evidence that the judgment was obtained by fraud may support a refusal, though this defence requires substantial proof and is rarely successful on its own.

Preparing to Resist Enforcement

A judgment debtor seeking to resist enforcement should act promptly, gathering evidence of service defects, documenting any public policy concerns, and instructing Greek counsel to file objections within the time limits set by the GCCP. Under the 2026 reforms, the compressed hearing schedules mean that debtors have less time to prepare, making early legal engagement essential.

Practical Timeline and Cost Comparison: EU vs Exequatur vs Bilateral Treaty

The following comparison table provides a high-level overview of the three principal enforcement routes, their typical procedural steps and estimated timelines under the post-reform 2026 regime.

Practitioner Enforcement Checklist

• Step 1: Identify the origin of the judgment (EU Member State / bilateral convention country / other non-EU state).
• Step 2: Obtain certified copies of the judgment and any required certificates (Article 53 certificate for EU; certificate of enforceability for non-EU).
• Step 3: Arrange certified Greek translations of all documents.
• Step 4: Apostille or legalise all documents as appropriate.
• Step 5: Instruct Greek counsel and provide a power of attorney (apostilled if signed abroad).
• Step 6: Consider interim protective measures (freezing orders, asset attachments) to preserve the debtor’s assets pending enforcement.
• Step 7: File the enforcement petition (exequatur route) or serve the enforcement documents (EU route).
• Step 8: Monitor the debtor’s response and prepare for any challenge on public policy or due-process grounds.
• Step 9: Upon obtaining enforcement authority, coordinate with the bailiff to execute against the debtor’s assets in Greece.

Conclusion and Recommended First Steps

Successfully navigating the enforcement of foreign judgments in Greece requires a clear understanding of the applicable route, meticulous preparation of documents and timely engagement of qualified local counsel. Whether you are pursuing the streamlined EU path under the Brussels I Recast or the more demanding exequatur procedure for non-EU judgments, the core steps are consistent: verify the origin and enforceability of your judgment, assemble a complete and authenticated document package, secure certified Greek translations, and instruct a Greek-qualified litigator to guide the process through to execution. With the Greek Code of Civil Procedure 2026 reforms now in effect, practitioners should also factor in the revised filing mechanics and compressed hearing schedules, early preparation pays dividends.

For experienced guidance on enforcement of foreign judgments in Greece, consult our directory of lawyers in Greece.

Sources

1. Regulation (EU) No 1215/2012 (Brussels I Recast), EUR-Lex
2. Potamitis Vekris, Greece: Enforcement of Foreign Judgments
3. Chambers Practice Guides, Enforcement of Judgments 2025: Greece
4. Lexology, Bringing a Claim for Enforcement of a Foreign Judgment in Greece
5. ConflictOfLaws.net, Limitation Period of the Enforcement of a UK Judgment in Greece
6. EVLAW, Enforcement of Foreign Judgments (Greece)
7. Hellenic Ministry of Justice