Recovering a debt in Greece requires navigating a structured civil procedure system that provides creditors with both domestic and EU-level instruments, from the payment order (diatagi pliromis) to cross-border account freezing under EU regulations. The process can be efficient when the underlying documentation is sound, but timelines and enforcement outcomes depend heavily on the debtor's asset profile, the jurisdiction of incorporation, and whether the claim is contested. Ferraz & Whitmore assists international businesses and funds at every stage, from pre-litigation demand strategy through to enforcement of judgment.
When Businesses Typically Need Debt Recovery Services in Greece
International creditors most commonly contact us after a Greek counterparty has stopped responding to payment demands, entered informal insolvency proceedings, or disputed an invoice without substantive legal grounds. The trigger is often a missed payment on a supply, service or loan agreement – an unpaid invoice that has aged past the contractual due date and where internal collection efforts have failed.
Other common scenarios include enforcement of a foreign judgment or arbitral award against assets held in Greece, recovery from a subsidiary or related entity registered in the General Commercial Registry (GEMI), and pre-emptive asset protection where a debtor is suspected of dissipating assets ahead of formal proceedings. In all of these situations, early legal intervention materially affects the range of remedies available.
The Greek Payment Order (Diatagi Pliromis)
The primary domestic instrument for debt collection in Greece is the diatagi pliromis (payment order), issued under the Greek Code of Civil Procedure. It is available for liquidated, undisputed monetary claims supported by documentary evidence – typically a signed contract, acknowledged invoices, promissory notes, or a combination thereof.
The procedure is conducted on a documentary basis before a single judge, without an oral hearing at the initial stage. Once issued, the payment order is served on the debtor, who has a statutory period within which to file an opposition (anakopi). If no valid opposition is lodged, the order becomes enforceable and can ground immediate enforcement measures. If the debtor does oppose, the matter proceeds to full adversarial proceedings, which lengthens the timeline considerably.
Practical considerations when applying for a payment order include:
- Documentation quality: the claim must be evidenced by written instruments; verbal agreements or partially documented transactions complicate the application.
- Correct identification of the debtor entity: verifying the debtor's registered details through GEMI before filing avoids service defects that can delay the process.
- Late payment interest: Greek law and, where applicable, EU Directive 2011/7/EU on combating late payment allow the creditor to claim late payment interest from the due date; specifying the correct rate and calculation period in the application is important for accurate recovery.
- Enforcement stage: obtaining an order is separate from enforcing it; enforcement against bank accounts, movable assets, or immovable property requires additional procedural steps and an up-to-date understanding of the debtor's asset position.
Cross-Border Instruments Available to International Creditors
Where the creditor or the debtor has a cross-border dimension within the EU, two regulations provide powerful supplementary tools.
European Payment Order (EPO)
Regulation (EC) 1896/2006 establishes a procedure for uncontested cross-border monetary claims. The application is made on standard EU forms and, once issued by a court in any Member State, the EPO is enforceable throughout the EU without the need for an exequatur (recognition and enforcement declaration). Denmark is excluded from the regulation's scope. The EPO is particularly useful where a creditor based outside Greece holds a claim against a Greek debtor, or vice versa, and wishes to obtain an enforceable instrument efficiently across borders.
European Account Preservation Order (EAPO)
Regulation (EU) 655/2014 allows creditors domiciled in the EU to apply ex parte – without prior notice to the debtor – for the freezing of the debtor's bank accounts held in another EU Member State (again, Denmark is excluded). The EAPO can be applied for before or during proceedings, or after judgment. Crucially, the regulation includes an account information mechanism that can compel disclosure of the debtor's account details through the court, which is valuable when the creditor does not know the precise bank holding the funds.
Used together, the EPO and EAPO can substantially reduce the debtor's ability to dissipate liquid assets during the pendency of proceedings – a common concern in contested debt recovery matters.
If your business is owed money by a Greek counterparty and you are considering enforcement options, we welcome an initial discussion. Please write to info@ferrazwhitmore.com or visit our contacts page to outline your situation.
Enforcement of Foreign Judgments in Greece
Creditors holding a judgment from a foreign court face a distinct procedural layer before that judgment can ground enforcement in Greece. The applicable regime depends on the origin of the judgment.
For judgments from other EU Member States, Regulation (EU) 1215/2012 (Brussels I Recast) generally provides for direct enforceability without exequatur, subject to limited grounds for refusal. For judgments from non-EU states, the analysis depends on whether a bilateral or multilateral convention applies, or whether Greek national exequatur rules govern.
The Hague Judgments Convention 2019 is an increasingly relevant instrument. It is in force for EU Member States (except Denmark) and Ukraine and Uruguay. For the United Kingdom, it applies from 1 July 2025, covering proceedings instituted after that date. For Albania and Montenegro, it will apply from 1 March 2026; for Andorra, from 1 June 2026. An important limitation: only judgments rendered in proceedings instituted after the Convention's entry into force as between both the rendering and the requested state qualify. Pre-existing UK–EU judgments must rely either on the Hague Convention on Choice of Court Agreements 2005 (where exclusive jurisdiction clauses were operative) or on national exequatur rules in the relevant Member State, which vary.
Creditors from states not covered by any convention rely on the Greek Code of Civil Procedure's general recognition procedure, which involves a substantive application to the Greek courts. Timelines under this route are less predictable and are subject to judicial discretion on specific grounds for refusal, including public policy considerations reviewed ultimately by the Areios Pagos (Supreme Civil and Criminal Court of Greece).
For businesses with exposure across the Eastern Mediterranean and Levant, our separate analysis on contract drafting implications for creditors in reciprocating territories may offer useful comparative context when structuring cross-border agreements.
Asset Freezing and Pre-Judgment Security Measures in Greece
Greek procedural law provides for interim measures (asfalistika metra) that can be granted on an urgent basis to protect the creditor's position before or during main proceedings. The court may order the freezing or sequestration of specific assets if the applicant demonstrates urgency and the likelihood of a valid claim. These measures are provisional and must typically be followed by main proceedings within a prescribed period.
The EAPO, described above, operates alongside national interim measures and may be preferable where the target assets are liquid funds held in bank accounts in another EU state. Coordinating national and EU-level measures requires careful procedural sequencing to avoid duplication or conflict between orders.
Where there are indications that a debtor may be transferring assets to avoid enforcement – including restructuring through affiliated entities – our team can advise on the interaction between debt recovery procedures and insolvency and restructuring frameworks in Greece, including the risk of preference transaction challenges.
Regulated Sectors and Specific Creditor Considerations
Debt recovery against entities supervised by the Hellenic Capital Market Commission (HCMC) – such as investment firms, collective investment undertakings, and regulated intermediaries – may involve additional procedural layers, including notification to the supervisor and potential interaction with resolution or winding-up regimes specific to financial institutions. Creditors of such entities should obtain specialist advice early, as standard civil enforcement tools may be stayed or modified by sectoral rules.
Unsecured trade creditors should also be aware that enforcement measures against regulated entities can be subject to specific priority rules that differ from those applicable to ordinary commercial debtors. Early registration of the claim and preservation of lien rights where available are therefore important steps.
Common Pitfalls in Greek Debt Recovery
Based on the matters we handle, the following issues most frequently undermine recovery prospects or extend timelines:
- Insufficient documentation at the outset: contracts unsigned, invoice acknowledgements absent, or delivery records incomplete. Greek courts expect written evidence for the payment order procedure; gaps must be addressed before filing.
- Incorrect identification of the debtor entity: Greece has a significant number of trading entities registered under variations of similar names; confirming the correct GEMI registration number and current legal status before serving documents prevents costly delays.
- Underestimating the opposition period: a debtor who lodges an opposition – even a weak one – converts a documentary procedure into contested litigation and extends the timeline substantially.
- Deferring enforcement steps: creditors sometimes wait after obtaining a judgment or order before moving to enforcement, during which time the debtor may reduce its accessible assets.
- Ignoring cross-border enforcement options: where the debtor holds assets in other EU states, failing to use the EAPO or EPO in parallel with domestic proceedings is a missed opportunity, particularly given the account information mechanism available under the EAPO.
- Currency and calculation errors in late payment interest claims: specifying the incorrect rate or accrual date in the application can reduce the recoverable amount and, in some cases, generate grounds for partial opposition.
How Ferraz & Whitmore Approaches Debt Recovery in Greece
Our approach integrates legal procedure with a pragmatic assessment of recovery prospects from the outset. Before recommending a procedural route, we review the contractual documentation, assess the debtor's public profile and asset position through available registries including GEMI, and identify the most efficient combination of domestic and cross-border measures.
We work with established local counsel networks in Greece who handle court filings, hearings, and on-the-ground enforcement steps, while our international team manages the strategic coordination, client communication, and cross-border dimensions – including enforcement in other jurisdictions where the debtor holds assets. For matters with a parallel dimension in Cyprus, our debt recovery services in Cyprus can be activated alongside Greek proceedings.
Clients receive a clear written assessment at the outset covering: the strength of the documentary basis, the recommended procedural route, realistic timeframes for each stage, the estimated asset exposure, and the risk profile of debtor opposition. We do not create unrealistic expectations about outcomes; we focus on giving clients the information they need to make sound commercial decisions.
Self-Assessment Checklist for Creditors
Before engaging counsel or filing any proceedings, creditors dealing with a Greek debtor should review the following questions:
- Do you have a signed contract, purchase order, or other written instrument establishing the payment obligation?
- Have the invoices been formally acknowledged or is acknowledgement implicit from course of dealing?
- Is the debtor entity correctly identified through GEMI – including its current registered status (active, under dissolution, in insolvency)?
- Are there assets in Greece and/or in other EU Member States that could be subject to enforcement or freezing?
- Is the claim uncontested in substance, or is there a genuine dispute about the amount or the underlying obligation?
- Has the contractual payment deadline passed, and have you documented your demand for payment in writing?
- Does your contract contain an exclusive jurisdiction clause that triggers the Hague 2005 Convention or an EU court?
- Are there any indications of debtor insolvency, restructuring, or asset transfers that require urgent interim action?
If the answers to these questions reveal gaps or uncertainties, addressing them before filing can significantly improve the outcome of proceedings.
To discuss a specific debt recovery matter in Greece, please contact us at info@ferrazwhitmore.com or use our contacts page. We respond to all enquiries promptly and in confidence.
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.