Greece has amended its insolvency legislation with changes effective from early 2025. International creditors with exposure to Greek debtors – and foreign companies operating in Greece – face tightened procedural rules that directly affect debt recovery and participation in insolvency proceedings. Acting promptly matters: deadlines in Greek insolvency proceedings are strict, and missing them can extinguish a creditor's right to participate in any distribution.
The 2025 amendments to Greek insolvency legislation revise the rules governing creditor participation, restructuring plan approval, and the powers of the insolvency administrator. Creditors holding claims against Greek entities must file a formal proof of debt within the court-ordered period – typically 30 to 45 days from the publication of the insolvency opening notice. International companies that fail to comply risk exclusion from the creditors meeting and loss of voting rights on any restructuring plan.
This alert sets out what has changed, which businesses are affected, and the immediate steps that creditors and counterparties should take.
What changed and when it took effect
Greek insolvency legislation was substantively revised through amendments that entered into force in early 2025. The changes implement remaining requirements under the EU Restructuring and Insolvency Directive, bringing Greek law closer to the harmonised European standard.
The key developments are as follows.
- Restructuring plan procedure: A debtor in financial difficulty may now propose a restructuring plan to creditors at an earlier stage, before formal liquidation is opened. The plan requires approval by a defined majority of creditors across separate classes.
- Creditor class voting: Creditors are now grouped into classes – secured, preferential, and unsecured – for voting on a restructuring plan. Each class votes separately. A dissenting class may be bound if the plan meets cross-class cramdown conditions under Greek insolvency legislation.
- Administrator powers: The σύνδικος (administrator or liquidator appointed by the court) now holds broader powers to challenge pre-insolvency transactions. The look-back period for avoidance actions has been extended under the amended legislation.
- Proof of debt requirements: The formal requirements for filing a proof of debt have been tightened. Creditors must now submit documentary evidence with the initial filing. A late or deficient submission may result in exclusion from the distribution, even if the underlying claim is valid.
- Early warning tools: The amendments introduce mandatory early warning mechanisms for companies showing defined indicators of financial distress. Directors who fail to engage with these tools face potential personal liability under Greek insolvency legislation.
The effective date for the core procedural changes is 1 January 2025. Proceedings opened before that date continue under the prior rules, but any new insolvency or pre-insolvency proceedings filed from that date are subject to the amended regime in full.
Which companies are affected and the compliance threshold
The amended rules apply broadly, but their practical impact falls hardest on specific groups.
International creditors with Greek exposures. Any foreign company holding a receivable, loan, or guarantee against a Greek entity is directly affected. The obligation to file a proof of debt – with complete documentary support – within the court-prescribed window applies regardless of the creditor's domicile. A creditor based in Germany, Portugal, or the UAE has no procedural advantage. The deadline is the same. Missing the creditors meeting means losing the vote on whether to approve or reject the restructuring plan.
Foreign companies with Greek subsidiaries or branches. Where a parent company has provided intercompany loans or guarantees to a Greek subsidiary, those claims rank as creditor claims in Greek insolvency proceedings. Under the amended rules, the administrator may scrutinise intercompany transactions more closely. Transactions that transferred value out of the Greek entity in the years before insolvency are now more exposed to challenge.
Secured lenders. The revised class-voting structure means that a secured lender with a mortgage or pledge over Greek assets may be placed in a separate creditor class. The secured class can be crammed down if the plan satisfies the legislative conditions. Secured creditors should model the impact of a cramdown scenario before the creditors meeting, not after.
Trade creditors and suppliers. Unsecured trade creditors are the group most commonly excluded from distributions through procedural default. The stricter proof of debt requirements mean that a creditor submitting an incomplete claim – missing invoices, contracts, or delivery records – risks rejection at the verification stage.
The threshold for entering formal insolvency proceedings in Greece remains tied to a debtor's inability to meet its payment obligations as they fall due. However, the 2025 amendments lower the practical threshold for pre-insolvency restructuring by making that route more accessible and procedurally defined. Companies with Greek counterparties showing signs of financial distress should treat early engagement with insolvency proceedings as a protective measure, not a last resort.
For creditors already involved in Greek insolvency proceedings, specialist support is essential. Engaging a lawyer in Greece with insolvency and restructuring expertise enables creditors to file a compliant proof of debt, participate effectively in the creditors meeting, and respond to any administrator challenges on time.
Immediate actions for international companies
International businesses with exposure to Greek debtors or Greek operations should take the following steps without delay.
- Audit Greek receivables and exposures. Identify all outstanding claims against Greek entities – trade receivables, loan balances, guarantees, and intercompany positions. Determine which, if any, involve debtors showing signs of financial distress or already subject to insolvency proceedings.
- Verify filing deadlines immediately. If a Greek counterparty has entered formal insolvency proceedings, the court will have set a deadline for proof of debt submissions. That deadline is published in the official court record. Do not assume it has not passed. Verify the status through Greek legal counsel without delay.
- Prepare a complete proof of debt file. Gather all documentary evidence supporting each claim: contracts, invoices, delivery records, bank statements, correspondence, and any security documents. Under the amended rules, a filing without adequate documentary support is treated as deficient.
- Review intercompany transactions for avoidance risk. If your company has received payments, assets, or loan repayments from a Greek entity within the extended look-back period, assess whether those transactions are exposed to challenge by the administrator under the revised insolvency legislation.
- Monitor Greek counterparties for early warning signals. The new early warning obligation applies to Greek companies. A Greek counterparty that has entered the early warning process is not yet insolvent – but creditors who engage early have a better position than those who wait for formal proceedings to open.
Companies facing related corporate disputes in Greece should also assess whether those disputes intersect with insolvency risks under the amended regime.
For a preliminary review of your creditor position in Greek insolvency proceedings, email us at info@ferrazwhitmore.com.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our insolvency and restructuring practice covers creditor rights, proof of debt filings, restructuring plan negotiations, and administrator challenges across European and cross-border proceedings. As an international law firm in Greece and across the EU, we work with institutional investors, trade creditors, and in-house legal teams who need results-oriented counsel when insolvency proceedings place their recoveries at risk. The firm's dual tradition – Portuguese civil law and English common law – gives us practical insight into both the Greek civil law insolvency system and the enforcement strategies that common law creditors rely on. Our attorneys have advised on cross-class cramdown scenarios, avoidance action defences, and creditors meeting strategy across multiple European jurisdictions. To discuss your exposure under the 2025 Greek insolvency amendments, contact us at info@ferrazwhitmore.com.
For further context on parallel developments in European insolvency law, see our alert on insolvency law amendments in Portugal and their impact on creditor rights.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.