GREECE Trends and Developments Contributed by: Ioannis Charalampopoulos, Daphne Kasimati, Afroditi Kazani and Ioanna Exarchou, Machas & Partners
The law also grants parties the option to initiate enforcement through the service of a payment order, further simplifying the process. A significant change in pledge enforcement entitles the pledgee to col- lect the pledged claim without any further require- ment after the lapse of a 10-day grace period once the secured claim becomes due. In case the pledged claim becomes due before the secured claim, the pro- visions of the Greek Civil Code apply. Seemingly, the purpose of such a provision is the streamlining of the enforcement process by aligning the interests of the pledgees and the pledgors. Digital Operational Resilience Act (DORA) A key regulatory development in 2025 was the adop- tion of Law 5193/2025, which aligns Greek legislation with important EU Regulations and Directives. The framework establishes uniform requirements for the governance and security of information and commu- nication technology (ICT) systems utilised by financial institutions and their critical third-party service pro- viders. It aims to enhance the capacity of financial entities to withstand, respond to and recover from cyber threats and ICT disruptions, reflecting the EU’s focus on operational resilience as a core component of financial stability. To align national legislation with the new framework, amendments were made to Law 4261/2014, provid- ing for the implementation by credit institutions of an ICT business continuity plan, as well as a response and recovery plan pertaining to the ICT systems used by them, enhanced oversight of outsourcing arrange- ments, and reporting obligations regarding third-party ICT providers. The law designates the Bank of Greece (BoG) as the competent authority for credit institutions, payment and e-money institutions and insurers. The BoG has been vested with broad supervisory and enforcement powers, including on-site inspections, public disclo- sure of breaches, administrative fines, license with- drawals and, in severe cases, the removal of senior management. Alternative financing Traditional banking remains the dominant source of credit in Greece. However, there has been a marked
evolution towards alternative lending solutions driven by the growing demand for diverse financing options among small and medium-sized enterprises (SMEs). This shift has highlighted the need for a robust institu- tional framework to facilitate lending by non-banking financial institutions. The trend has been significantly shaped by the regulatory framework overhaul with Law 5072/2023, which established a new framework for credit purchasers and credit servicers and expand- ed the scope of alternative lending, as well as Law 5193/2025. Credit Companies have emerged as a dynamic and attractive option for investors interested in the alter- native lending market. Traditionally focused on pro- viding credit to natural persons, recent amendments under Law 5072/2023 have significantly expanded their operational scope to include legal entities. For natural persons, credit companies offer mortgage and consumer credits and can facilitate the restructuring of existing loans from the same or other credit institu- tions. By accommodating the varied financial needs of businesses, credit companies play a crucial role in promoting economic stability and growth, particularly in a climate where affordable credit is essential. The inclusion of servicing companies as credit provid- ers not only enhances the options available to bor- rowers but also contributes to reducing the overall non-performing loan (NPL) ratio within the financial system. Greek banks have recorded the lowest NPL ratio to date, even lower than in the pre-crisis period. However, the significant reduction in NPEs on bank balance sheets does not automatically mean a remov- al of debt from Greek companies, as the largest part of overdue liabilities by non-financial corporations has been transferred to non-bank credit-acquiring compa- nies and is currently managed by “servicers”. BoG Act on Internal Governance In July 2025, the Bank of Greece issued Act 243/2/07.07.2025, which introduced a new internal governance framework for credit institutions, aligning national rules with the European Banking Authority’s Guidelines on Internal Governance (EBA/GL/2021/05). The Act replaces the long-standing Governor’s Act 2577/09.03.2006 and applies to credit institutions established and operating in Greece and branches of
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