Disputes that cross
borders need counsel
who work across them.

It depends on where the judgment comes from. Judgments from other EU member states benefit from the streamlined regime under Brussels I Recast, which provides for recognition and enforcement without a separate declaration of enforceability in most cases, subject to limited grounds for refusal. Judgments from non-EU states are recognised and enforced under Greek private international law rules, or under a bilateral treaty where one exists, and generally require a formal exequatur proceeding before a Greek court before enforcement can proceed.

An EU judgment travels under Brussels I Recast, which was designed to make enforcement across member states close to automatic — the judgment creditor does not need a separate Greek court declaration before taking enforcement steps, though the debtor retains limited grounds to resist, such as public policy or a conflicting earlier judgment. A non-EU judgment has no equivalent automatic regime. It must go through exequatur proceedings before a competent Greek court, which will examine matters such as the jurisdiction of the foreign court, proper service, and compatibility with Greek public policy before declaring the judgment enforceable in Greece.

Greece is a signatory to the 1958 New York Convention, so a foreign arbitral award can be recognised and enforced in Greek courts on an application supported by the award and the arbitration agreement. The Greek court's review is narrow — it does not re-examine the merits of the award, and can refuse recognition only on the limited grounds set out in Article V of the Convention, such as an invalid arbitration agreement, a party's inability to present its case, an award exceeding the scope of the arbitration agreement, or incompatibility with Greek public policy. The same Convention works in reverse — a Greek-seated award can be enforced in any of its 170-plus signatory states.

This is the parallel proceedings, or lis pendens, problem, and it needs to be managed early rather than left to resolve itself. Depending on which jurisdictions are involved and which rules apply, a court seised second in time may be required, or may choose, to stay its own proceedings in favour of the court seised first, or the parties may need to argue over which forum should properly take precedence. Left unmanaged, parallel proceedings can produce inconsistent judgments, wasted cost, and a genuine risk that a hard-won result in one country cannot be enforced because of what happened in the other.

For contractual disputes with an EU dimension, the Rome I Regulation generally governs — respecting the parties' own choice of law where one was made, and applying default connecting factors where it was not. For non-contractual disputes, such as tort or unjust enrichment claims, the Rome II Regulation performs the equivalent role. Where neither EU regulation applies — for example because the dispute falls outside their scope, or involves a non-EU element they do not reach — Greek private international law rules determine the applicable law instead. Identifying the right regime early shapes both the substantive arguments available and the litigation strategy.

Yes. A Greek judgment can be enforced in England & Wales and other jurisdictions, though the applicable route depends on the country in question and, since Brexit, Greek judgments no longer benefit from the Brussels I Recast regime when enforced in England — a common law or treaty-based recognition process typically applies instead. Because we are dual-qualified in both Greece and England & Wales, we advise on the English-law aspects of that process directly and coordinate the enforcement strategy through instructed English correspondent counsel, including tracing the debtor's assets across both jurisdictions.