Banking and Finance 2025

GREECE Trends and Developments Contributed by: Ioannis Charalampopoulos, Daphne Kasimati, Afroditi Kazani and Ioanna Exarchou, Machas & Partners

marily through low-interest loans, promoting growth, innovation, and the transition to sustainable entrepre- neurship across all sectors of the Greek economy. A total of EUR16.4 billion has been channelled into the private economy through three key programmes. The RRF loans cover up to 50% of total eligible invest- ment costs, while at least 30% of the investment must be co-financed through funds from eligible commer- cial banks, ensuring a blend of public and private financing. Additionally, businesses must contribute a minimum of 20% of the investment through their own funds, which can include equity, subordinated loans, or in-kind contributions, subject to certain conditions. The minimum interest rate for small businesses is set at a fixed 0.35%, while for larger businesses, it is set at 1%. This low-cost financing is designed to stimu- late investment by reducing the burden of borrowing, making capital accessible for a broad range of eligible projects. The financing terms offered by the RRF are fur- ther supported by flexible repayment periods of up to 15 years. Disbursement must be concluded by 31/08/2026, with the 2025 country report noting that implementation is underway, but increased efforts are needed to complete all measures by 31 August 2026. Greece has so far received €21.3 billion (59.3% of its total allocation) in the form of pre-financing and pay- ments, with another four disbursements for grants and loans envisaged up to 2026 on fulfilment of the agreed milestones and targets. This long-term financing structure, combined with low interest rates and the RRF’s focus on key eco- nomic sectors, positions it as a critical tool for driv- ing Greece’s economic recovery, enabling sustainable investments in the green and digital transitions while providing a solid foundation for long-term growth. Regulatory Developments Launch of the Unified Electronic Registry of Pledges The introduction of Law 5123/2024 marked a signifi- cant regulatory development in Greece’s framework regarding the taking of security in the form of a pledge over rights and claims, movable assets (notional pledge) and shares. The law has repealed certain pro-

visions of the previous applicable framework, namely provisions of the Greek Civil Code, Legislative Decree 17.7.1923, and Law 2844/2000 regarding notional pledge and a floating charge. The law’s primary aim is the unification and modernisation of the process of creating, registering, and enforcing pledges and establishing the Unified Central Electronic Register of Pledges (the “Register”) managed by the Hellenic Cadastre. The Register is a public database that enhances transparency and legal certainty, ensuring that pledge agreements are enforceable against third parties. The Register commenced operation as of 30 June 2025 upon the issuance of a relevant decision by the Hel- lenic Cadastre, but certain operational matters are still pending resolution. One of the key changes introduced by the law is the flexibility in how pledges are created, as pledge agree- ments may now be formalised through electronic means, including digital signatures and the use of government-certified electronic platforms like gov.gr. This shift away from traditional formalities speeds up the process and aligns it with modern digital practices. The registration requirement with the Register of all the pledge agreements extends to the securitisation transactions and securitisation servicing agreements under Laws 3156/2003 and 5072/2023. Moreover, the Law reiterates and specifies the concept of a notional pledge on movable assets introduced by the Greek Civil Code and repeals certain provisions of Law 2844/2000 governing the creation and operation of the floating charge on business receivables. Similar to the other forms of a pledge, notional pledges may now be digitally formalised and must be registered in the Register to ensure their validity. Registration is not required for pledges on claims arising from the pledgor’s bank accounts maintained with the lending bank when the bank is also the pledgee. With respect to the establishment of a pledge for shares listed on the Athens Stock Exchange or for those held in book- entry form following dematerialisation or immobili- sation, provisions of Law 4569/2018 should remain applicable.

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