Interim (provisional) Measures in Greece: Freezing Orders, Injunctions & Cross‑border Interim Relief (2026 Guide)

Last reviewed: 12 August 2026

Interim measures in Greece give claimants the power to freeze assets, halt harmful conduct and preserve the status quo before a final judgment is handed down. The Greek Code of Civil Procedure (Kodikas Politikis Dikonomias, ΚΠολΔ) has long provided a robust framework for provisional relief, and Law 5221/2025 (FEK A΄133/28. 07. 2025) has now introduced material amendments that reshape how courts handle urgency, ex‑parte applications and related procedural routes. For in‑house counsel managing cross‑border commercial disputes, the interaction between Greek domestic interim relief, the Brussels I Recast (Regulation (EU) No 1215/2012) and arbitral provisional orders adds further complexity.

This guide walks practitioners through every stage, from identifying the right remedy and drafting the application, to enforcing orders across borders and converting provisional relief into final enforcement.

Executive Summary: What Interim Measures Are and Why This 2026 Guide Matters

Interim measures in Greece are court orders designed to provide rapid, temporary judicial protection where delay would cause irreparable harm or render a future judgment meaningless. They encompass freezing orders over assets located in Greece, prohibitory and mandatory injunctions, conservatory attachments, and other protective remedies available under the ΚΠολΔ.

The enactment of Law 5221/2025, published in the Government Gazette on 28 July 2025 (FEK A΄133/28.07.2025), introduced amendments to the Code of Civil Procedure that directly affect interim relief proceedings. These changes, with provisions entering into force on staggered dates through 2026, give courts broader discretion on urgency assessments and refine procedural architecture for accelerated hearings. Simultaneously, the growing volume of cross‑border disputes involving Greek‑sited assets means that foreign claimants must understand how Regulation (EU) No 1215/2012 (Brussels I Recast) and the New York Convention interact with Greek domestic procedure.

Practical bottom line: Greek courts can grant interim relief quickly, often within days, but success depends on meticulous preparation, the right evidentiary package and a sound enforcement strategy. The sections below provide the step‑by‑step playbook.

Legal Framework for Interim Measures in Greece

Greek law governing provisional measures is primarily found in the Code of Civil Procedure (ΚΠολΔ), supplemented by special statutes and EU instruments. The core statutory architecture sits in Book IV of the ΚΠολΔ, which establishes the conditions, procedure and types of interim relief available.

Law 5221/2025 (FEK A΄133/28.07.2025) amended several provisions of the ΚΠολΔ relevant to interim relief. Industry observers note that the practical effects include refined rules on accelerated procedural tracks, broadened judicial discretion regarding urgency determinations, and updated provisions affecting payment orders and related fast‑track instruments. Certain provisions entered into force immediately upon publication, while others followed staggered implementation dates, practitioners should check article‑by‑article start dates to confirm which rules apply to their proceedings.

At the EU level, Regulation (EU) No 1215/2012 (the Brussels I Recast) is directly applicable in Greece as an EU Member State. Article 35 of that Regulation permits application to the courts of a Member State for provisional and protective measures available under that state’s law, even where the courts of another Member State have jurisdiction over the substance of the matter. This creates an important pathway for foreign claimants seeking to freeze Greek assets ahead of substantive proceedings elsewhere.

Key Statutory Provisions to Know

• ΚΠολΔ Articles 682–738. These articles form the backbone of interim measures procedure in Greek civil law, covering jurisdiction, types of available orders, hearing procedures, and post‑order obligations.
• ΚΠολΔ Article 691(2). Permits the court to grant interim relief on an ex‑parte basis where urgency or immediate danger justifies dispensing with service on the respondent.
• Law 5221/2025 (FEK A΄133/28.07.2025). The 2025 reform statute amending the ΚΠολΔ, with multiple provisions affecting procedural timelines and judicial discretion in provisional relief applications.
• Regulation (EU) No 1215/2012, Article 35. Enables cross‑border provisional measures within the EU framework.
• New York Convention (1958). Underpins enforcement of foreign arbitral awards in Greece, relevant where provisional orders form part of an arbitral process.

Types of Interim Measures Available in Greece

Greek law offers a range of provisional remedies, each suited to different protective objectives. Selecting the correct measure is a critical tactical decision, an applicant who seeks the wrong remedy wastes time, costs and judicial goodwill.

Freezing Orders (Assets Located in Greece)

A freezing order in Greece (conservatory seizure of assets, συντηρητική κατάσχεση) prevents the respondent from disposing of, encumbering or transferring specified assets. Greek courts can freeze bank accounts, real estate, shares, vehicles, vessels and receivables. The order is territorial in scope: it attaches to assets physically or legally situated within Greek jurisdiction. There is no direct equivalent of a common‑law “worldwide freezing order” under Greek procedural law, securing assets beyond Greek borders requires parallel applications in the relevant foreign jurisdictions or reliance on EU instruments.

A freezing order under the ΚΠολΔ requires the applicant to demonstrate: (a) a probable claim (πιθανολόγηση of the underlying right), (b) urgency or danger that delay would frustrate enforcement, and (c) that the assets targeted are amenable to conservatory seizure.

Injunctions (Prohibitory and Mandatory) and Interim Attachments

Prohibitory injunctions direct a party to refrain from specified conduct, for example, ceasing use of a trademark, halting construction, or refraining from transferring shares. Mandatory injunctions compel positive action, such as delivering goods or granting access. Greek courts grant injunctions under the general interim measures framework where the applicant shows a probable right and the risk that non‑intervention will cause irreparable harm.

Interim attachment (προσωρινή διαταγή) is a separate, faster instrument: a judge can issue a temporary order immediately upon the filing of an interim measures application, often at the same appointment where the application is lodged. This order bridges the gap until the full hearing of the interim application takes place.

Security, Pre‑Judgment Attachment and Other Protective Measures

Courts may order that security be provided by the respondent (or in some circumstances, by the applicant) to safeguard the interests of the other party. Pre‑judgment attachment of specific assets, real property, bank deposits or ships, is available where dissipation risk is demonstrated. Greek law does not recognise an exact equivalent of the common‑law “Anton Piller” order for evidence preservation, but analogous relief may be obtained through interim measures applications requiring production or safeguarding of documents and evidence.

How to Obtain Urgent Interim Relief in Practice, Step by Step

Securing a freezing order or urgent injunction in Greek courts follows a defined procedural sequence. Early preparation is decisive, most applications succeed or fail on the quality of the evidence gathered before the courthouse doors open.

Pre‑Filing Checklist

Before filing, counsel should assemble the following:

1. Evidence of the underlying claim. Contracts, invoices, correspondence, default notices and any documents proving the prima facie right.
2. Evidence of urgency and risk of dissipation. Proof that the respondent is transferring, hiding or encumbering assets, or credible grounds to believe such conduct is imminent.
3. Asset identification. Property registry extracts, bank account details (where available), ship registry records, company filings, sufficient to describe the targeted assets to the court with precision.
4. Witness statements / affidavits. Sworn declarations (ένορκες βεβαιώσεις) from witnesses or parties with direct knowledge of the facts.
5. Translations. Any foreign‑language documents must be accompanied by certified Greek translations; the court will not accept untranslated exhibits.
6. Power of attorney. A duly executed power of attorney authorising Greek counsel to act, apostilled if issued abroad.
7. Draft interim application. The application itself, specifying the measures sought, factual narrative, legal basis and the assets to be restrained.

Drafting the Interim Application (Αίτηση Ασφαλιστικών Μέτρων)

The interim application must include: a clear statement of facts, identification of the legal basis for the claim, a precise description of the measures requested, the reasons establishing urgency, and a summary of the evidence on which the applicant relies. The application is filed with the competent single‑member court of first instance (Monomeles Protodikeio) or, in certain cases, with the court that has jurisdiction over the main proceedings.

Counsel should ensure the application addresses the three elements that Greek judges focus on: probable right, urgency or danger, and proportionality of the measure sought relative to the harm.

Ex‑Parte Emergency Procedure

Where the urgency or danger is immediate, Greek courts can issue an interim order without prior notice to the opposing party. Under ΚΠολΔ Article 691(2), the applicant may request an ex‑parte temporary order (προσωρινή διαταγή) at the time of filing the interim application. The judge may grant a temporary order on the same day, pending the scheduled hearing of the full interim measures application.

The typical timeline for urgent interim relief in Greek courts is as follows: a temporary order can be issued on the day of filing; the full hearing of the interim measures application is usually scheduled within days to a few weeks thereafter, depending on the court calendar and the complexity of the case. The hearing follows an abbreviated evidentiary procedure, with the court reaching a decision on the basis of probability rather than full proof.

What the judge will want to see:

• A credible, documented prima facie case
• Clear evidence that delay would cause irreparable harm or asset dissipation
• Proportionality, the measure sought should not be disproportionately burdensome on the respondent
• Precise identification of the assets or conduct to be targeted
• Willingness to post security if the court requires it

Evidence and Supporting Materials for Interim Measures in Greece

The evidentiary threshold for provisional relief in Greece is probability (πιθανολόγηση), not certainty. The applicant must make the right and the urgency probable to the court’s satisfaction. The quality and organisation of supporting materials significantly influence outcomes.

What Affidavits Should Cover

Sworn declarations supporting an interim measures application should address four core elements: (a) the facts establishing a prima facie case, (b) the balance of convenience, why the harm to the applicant outweighs any inconvenience to the respondent, (c) specific facts demonstrating risk of dissipation or the respondent’s obstructive conduct, and (d) the urgency, why ordinary proceedings would be inadequate.

Financial Evidence and Asset Tracing

Asset identification is critical for freezing order applications. The table below summarises the principal evidence types, their purpose, and where to obtain them:

Cross‑Border Interim Measures and Enforcement

For foreign claimants with exposure to Greek assets, or Greek parties pursuing relief abroad, cross‑border interim measures require careful navigation of overlapping legal regimes. There are four principal routes available.

Route A: Seek Greek interim measures over Greek assets. Any party, regardless of nationality, may apply to the Greek courts for interim measures over assets located in Greece. Jurisdiction for provisional relief exists independently of jurisdiction over the main claim, enabling foreign claimants to obtain orders from Greek courts while substantive proceedings proceed elsewhere.

Route B: Rely on Brussels I Recast (Article 35) for EU cross‑border protection. Article 35 of Regulation (EU) No 1215/2012 permits application to the courts of any EU Member State for provisional and protective measures available under that state’s law, even if the courts of another Member State have jurisdiction over the substance. However, the territorial reach of such measures is generally limited to assets within the granting state’s jurisdiction, and the standard of proof may vary from state to state.

Route C: Emergency arbitration and interaction with Greek courts. Where disputes are subject to arbitration, emergency arbitrator procedures under institutional rules (such as those of the ICC, LCIA or SCC) can produce rapid provisional orders. Industry observers note that the enforceability of emergency arbitrator orders in Greece remains an evolving area: because such orders may not constitute “awards” within the meaning of the New York Convention, their enforcement typically depends on whether the Greek courts will recognise them under the domestic interim measures framework or the applicable arbitration law.

Route D: Enforcement of foreign arbitral awards (New York Convention). Greece is a signatory to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958). Final arbitral awards, including those incorporating provisional relief, can be enforced in Greece through the exequatur procedure. The practical path involves filing the award with the competent Greek court, accompanied by a certified copy of the arbitration agreement, and obtaining a declaration of enforceability.

Enforcement of Foreign Interim Measures

Foreign court‑ordered interim measures (as opposed to arbitral orders) face limitations in Greece. Under the Brussels I Recast, provisional measures granted by a court with jurisdiction on the substance of the matter are generally recognisable in other EU Member States. However, measures granted on an ex‑parte basis that did not afford the respondent an opportunity to be heard before enforcement may face resistance. Early indications from practice suggest that Greek courts apply the recognition framework pragmatically but insist on procedural safeguards for the respondent.

Enforcing Arbitral Provisional Orders and Awards

For arbitral awards, the New York Convention provides the enforcement backbone. Greek courts have generally adopted a pro‑enforcement stance, consistent with Greece’s obligations under the Convention. Where provisional relief has been incorporated into a final award, enforcement through the exequatur procedure is the most reliable route. Stand‑alone emergency arbitrator orders, by contrast, require a case‑by‑case assessment; counsel should consider seeking parallel interim relief from the Greek courts to ensure immediate enforceability over Greek assets.

Tactical Issues: Security, Costs, Appeals and Conversion to Final Relief

Security Requirements and Court Costs

Greek courts have discretion to require the applicant to post security as a condition of granting interim measures. This is particularly common in freezing order cases where the respondent may suffer financial harm from the restraint on its assets. The amount of security is fixed by the court on a case‑by‑case basis. Court filing fees for interim measures applications are generally modest compared to main proceedings, but counsel should factor in costs for certified translations, apostilles, sworn declarations and bailiff service fees.

The duration of interim measures is not unlimited. The ΚΠολΔ requires the applicant to commence main proceedings within a specified period after the interim order is granted; failure to do so results in the order lapsing automatically. Practitioners should diarise this deadline immediately upon obtaining the order.

Opposing Party Strategies: How to Resist or Vary a Freezing Order

A respondent against whom interim measures have been granted may: (a) file an application to revoke or modify the order, presenting new evidence or challenging the urgency finding; (b) request variation of the order to release specific assets needed for ordinary business operations or legal expenses; (c) appeal the interim order to the competent court; or (d) challenge the underlying jurisdiction or the applicant’s standing. Prompt action is essential, delays in challenging an interim order may be interpreted as acquiescence.

Sample Timeline and Legislative Comparison

The table below provides a practical timeline for a typical interim measures application in Greece, followed by a legislative comparison of recent reforms.

Key Legislative Dates

Practical Annexes: Templates and Further Reading

Model Ex‑Parte Interim Application Checklist

• Applicant’s identity and standing. Full legal name, registered address, proof of corporate existence (for entities), power of attorney for Greek counsel.
• Statement of facts. Chronological narrative of the underlying dispute and the events giving rise to urgency.
• Legal basis. Cite the relevant ΚΠολΔ articles (682 et seq.), any applicable EU regulation, and the specific statutory ground for the measure sought.
• Measures requested. Precise description of the freezing order, injunction or other relief, including identification of the target assets or conduct.
• Urgency and risk. Factual basis for the claim that delay would cause irreparable harm or asset dissipation.
• Evidence annexed. Indexed list of all supporting documents, sworn declarations and translations.
• Request for ex‑parte temporary order. Express request under ΚΠολΔ Article 691(2), if urgency justifies dispensing with prior notice.

Sample Wording for a Freezing Order Application (Draft Template)

Note: the following is a draft template for guidance purposes only and does not constitute legal advice. It must be adapted by qualified Greek counsel to the specific facts and legal requirements of each case.

“The Applicant respectfully requests the Court to issue an order of conservatory seizure (συντηρητική κατάσχεση) over the following assets of the Respondent: [describe assets, bank accounts, real property, shares, etc.], prohibiting the Respondent from disposing of, encumbering, transferring or in any way diminishing the said assets, pending the determination of the main action. The Applicant further requests the issuance of a temporary order (προσωρινή διαταγή) under ΚΠολΔ Article 691(2), to take immediate effect pending the hearing of this application.”

Converting Interim Relief into Final Enforcement

1. Commence main proceedings within the statutory deadline set by the interim order.
2. Obtain a final judgment or arbitral award on the merits.
3. Apply for enforcement of the final judgment, at which point the interim order is superseded by the enforcement of the substantive decision.
4. If the respondent has assets abroad, pursue parallel recognition and enforcement proceedings in the relevant jurisdictions.

This article provides general information on interim measures in Greece and does not constitute legal advice. For guidance specific to your situation, engage qualified counsel with experience in Greek dispute resolution and cross‑border enforcement.

Sources

1. Law 5221/2025, FEK A΄133/28.07.2025 (e‑Nomothesia)
2. Hellenic Ministry of Justice, Public Consultations (OpenGov)
3. Regulation (EU) No 1215/2012, Brussels I Recast (EUR‑Lex)
4. Convention on the Recognition and Enforcement of Foreign Arbitral Awards, New York Convention (UNCITRAL)
5. Securing Assets During a Claim in EU Countries (European e‑Justice Portal)