GREECE Trends and Developments Contributed by: John C Dryllerakis, Claire Sergaki and Vasileios Plakoulas, Dryllerakis Law Firm
tional parties and the consolidation of proceedings. The extent and practical implications of these pro - posed reforms, however, remain to be seen once the
this regime may lead to restrictive conditions, reversal of the investment transaction or even its prohibition, whilst administrative penalties may also apply. The FDI Screening Law is likely to trigger disputes in both the investment and commercial arbitration sphere. On the investment side, the screening mech - anism may conflict with protections granted under Greece’s Bilateral Investment Treaties (BITs), poten - tially leading foreign investors to initiate claims against the Hellenic Republic. On the commercial side, the notification and approval requirements set by the FDI Screening Law will become conditions precedent in many M&A transactions. Failure to meet these condi - tions or any subsequent reversal of the investment transactions may give rise to claims, which will likely be resolved through commercial arbitration proceed - ings. Energy Arbitration In recent years, Greek energy companies have been steadily shifting towards renewable sources, investing heavily in green technologies and infrastructure. This green transition is reflected in the growing number of acquisitions of photovoltaic parks and wind farms, which involve substantial capital and complex con - tractual commitments. However, regulatory changes worldwide (and par - ticularly in the United States) evidence a renewed emphasis on traditional energy resources and have threatened the further development of green energy portfolios. In Greece, renewable energy investors are also facing new challenges, including unexpected licensing delays, rising costs and legal unpredictabil - ity, which may, in some cases, lead to project cancel - lations. This environment of uncertainty has increased the risk of disputes, particularly over delayed performance, financial losses or breach of contract. Contractual obligations under Development Services Agreements (DSAs) or Power Purchase Agreements (PPAs) that are tied to strict project timelines and financing con - ditions are proving increasingly difficult to fulfil. As a result, parties are turning to arbitration to resolve com - pensation claims. Consequently, energy arbitration in Greece is steadily on the rise.
draft text is released for consultation. The New 2026 ICC Arbitration Rules
The 2026 ICC Arbitration Rules introduce a series of amendments aimed at modernising ICC arbitration and aligning it more closely with current arbitral prac - tice and users’ expectations. Several of the new pro - visions also draw on procedural approaches already developed within other leading arbitral institutions. Overall, the revised Rules reinforce the ICC’s contin - ued focus on efficiency, flexibility and cost-effective - ness, while further streamlining the arbitral process in line with evolving user expectations. The most significant amendments include, inter alia, the introduction of an express early determination mechanism allowing parties to seek the early dismissal of claims or defences that are manifestly without merit or fall manifestly outside the arbitral tribunal’s jurisdic - tion (Article 30), the opt-in High Expedited Arbitration Provisions (Article 33 and Appendix VI), as well as the expanded powers of emergency arbitrators to issue preliminary orders. Foreign Direct Investments & Arbitral Disputes Foreign direct investment (FDI) is a crucial pillar of Greece’s economy. Greece’s FDI inflows have surged dramatically, leaping from EUR2.5 billion in 2016 to an impressive EUR11.3 billion in 2025. Greece recently adopted Law 5202/2025 to align with EU Regulation 2019/452 on the screening of FDIs for the protection of national security and public order (“FDI Screening Law”). The screening regime applies to all FDIs in sensitive sectors (eg, energy, transport, health, information and communication technology) and highly sensitive sectors (eg, national security, cybersecurity, AI, port and critical submarine infra - structure) when certain ownership thresholds are sur - passed. The FDI Screening Law regulates investments by non-EU individuals or entities, as well as EU-based entities that are controlled, directly or indirectly, by non-EU parties, including governments or armed forc - es. All qualifying FDIs must be notified to the Ministry of Foreign Affairs for approval. Non-compliance with
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