GREECE Law and Practice Contributed by: Dimitris Babiniotis, Danae Papadatou and Emmanouil Mavrantonakis, Zepos & Yannopoulos
ECJ Decisions Declaration of enforceability is not required for deci - sions of the ECJ, which are executed according to the provisions of the GrCCP (Article 280 and Article 299 of the Treaty on the Functioning of the European Union (TFEU)). The enforcement clause is affixed by the competent authority of the Ministry of Justice after verifying the authenticity of the title only, without investigating other conditions – particularly whether fundamental constitutional rights of the domestic legal order were violated. ECHR Decisions According to the prevailing view, judgments of the ECHR are enforced in accordance with the provi - sions applicable to the recognition and declaration of enforceability of foreign judgments (Articles 323 and 905 of the GrCCP). Special Reference to UK Judgments Post-Brexit Following Brexit, as of 1 January 2021, Brussels I Recast and the 2007 Lugano Convention no long - er apply to the UK. Brussels I Recast continues to apply with reference to proceedings which have com - menced on or before 31 December 2020. Therefore, UK judgments issued in proceedings which com - menced before 31 December 2020 are binding and enforceable in Greece, in accordance with Brussels I Recast. With reference to proceedings that have commenced/ shall commence on/after 1 January 2021, on 8 April 2020 the UK applied to accede to the Lugano Con - vention, as an independent contracting state. How - ever, this requires the unanimous consent of the other parties to that convention, including the EU member states. On 4 April 2021, the EC rejected – in a com - munication to the European Parliament and the Euro - pean Council – the entry of the UK to the Lugano Convention. As things stand, no unanimous consent has not been given so far. On 1 January 2021, the UK rejoined the 2005 Hague Convention on Choice of Court Agreements, which also regulates the recogni - tion and enforcement of foreign judgments but only in cases in which a foreign judgment has been issued on the basis of a prorogation clause. Therefore, the 2005 Hague Convention on Choice of Court Agree - ments is currently in force between Greece and the
UK, given that the former is an EU member state (the term “judgment” does not include decisions or court orders issued on interim measures requests). On 12 January 2024, the UK signed and on 27 June 2024 ratified the 2019 Hague Convention on the Rec - ognition and Enforcement of Foreign Judgments in Civil or Commercial Matters as an independent con - tracting state with reference to proceedings. The 2019 Hague Convention on the Recognition and Enforce - ment of Foreign Judgments in Civil or Commercial Matters entered into force in the UK on 1 July 2025. No bilateral or any other international treaty on the recognition and enforcement of foreign judgments is currently in force between Greece and the UK. Recognition If a judgment has not been issued by a UK court on the basis of prorogation clause, the recognition of that judgment in Greece shall be regulated by Article 323 of the GrCCP. If a judgment is issued by a UK court on the basis of a prorogation clause, Articles 8 and 9 of the 2005 Hague Convention on Choice of Court Agreements apply to the recognition of that judgment in Greece (and vice versa). In such cases, Article 4 et seq of the 2019 Hague Convention on the Recogni - tion and Enforcement of Foreign Judgments in Civil or Commercial Matters apply as well. Enforcement If a judgment is not issued by a UK court on the basis of a prorogation clause, the declaration of enforce - ability of said judgment in Greece shall be regulated by Article 905 of the GrCCP. If a judgment is issued by a UK court on the basis of a prorogation clause, Articles 8 and 9 of the 2005 Hague Convention on Choice of Court Agreements in conjunction with Articles 4 et seq of the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters apply respectively to the declaration of enforceability of that judgment in Greece (and vice versa).
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