Commercial Disputes in Greece: Courts, Mandatory Mediation from 2027, Arbitration, Enforcing an Israeli Judgment and Debt Collection

An Israeli company working with a supplier, customer, contractor or partner in Greece needs to know in advance where a dispute will be heard, how long it may take and how collection actually works. 2025 and 2026 were years of major changes in Greek civil procedure: the court map was changed, binding timetables were set for judges, and in October 2026 a new code for arbitration and mediation was published. This guide summarises the position as of November 2026. On the difference between jurisdiction, governing law and enforcement, and on arbitration versus court in real estate transactions, see also the guide to a dispute with a developer abroad.

1How is the Greek court system structured for commercial disputes?

A commercial claim in Greece is filed with the court of first instance (Πρωτοδικείο), sitting as a single judge (Μονομελές Πρωτοδικείο) or as a panel of three judges (Πολυμελές Πρωτοδικείο), depending on the value and type of the claim. Greece has a continental legal system, and according to Chambers' review, following the new court map in Law 5108/2024, in force from 16 September 2024, the magistrates' courts were abolished in civil matters and the jurisdiction of the single-judge court was expanded.

• First instance: the court of first instance sitting as a single judge or as a panel of three.
• Appeal: under Law 5221/2025, appeals against judgments of the single-judge court are divided between the three-judge panel of the court of first instance and the Court of Appeal (Εφετείο), by amount, and the threshold rose from 30,000 to 60,000 euros.
• Supreme Court: the Άρειος Πάγος, which hears questions of law only.
• Interim relief: a fast interim procedure (ασφαλιστικά μέτρα), for example for a provisional attachment or to preserve the status quo, even before the main claim.

2How long do commercial proceedings in Greece take?

Under Law 5221/2025, in 2026 the hearing date is set within six months of filing the claim and judgment is given within eight months in ordinary proceedings. We found no current official figure on the average length of a commercial case, and the statutory deadlines depend in practice on the workload of each court. The law was published in the Government Gazette on 28 July 2025 and most of it entered into force on 1 January 2026; these are the timetables it sets:

• Hearing date: set when the claim is filed, no later than six months and in any case within seven months. When service on a defendant abroad is required, nine to ten months.
• Judgment: within eight months in ordinary and special proceedings, and four months in non-contentious proceedings.
• Appeal: the hearing date is set within five months of filing, and the maximum period for filing an appeal or an application to the Supreme Court has been shortened from two years to one.
• Electronic file: an electronic file is opened for every case in the national case management system.

3What does the new dispute resolution code, Law 5344/2026, change?

Law 5344/2026, the “Alternative Dispute Resolution Code and other provisions”, brings arbitration, mediation and judicial mediation together in a single framework, and from 1 March 2027 requires a preliminary procedure before a large proportion of commercial claims. It was published in the Government Gazette (ΦΕΚ Α' 168) on 16 October 2026, and sets uniform rules for domestic and international arbitration based on the UNCITRAL Model Law. The Code repeals, among other things, the arbitration chapter of the Code of Civil Procedure, Articles 1 to 31 of Mediation Law 4640/2019 and Articles 1 to 48 of International Arbitration Law 5016/2023.

Under the transitional provisions, arbitration proceedings that began before the arbitration chapter entered into force will be completed under the previous law, and arbitration clauses signed earlier remain valid. Mediation proceedings already opened under Law 4640/2019 will be completed under it.

4Is mediation mandatory before a commercial claim in Greece?

Yes, from 1 March 2027 and for a large proportion of commercial claims, under Law 5344/2026. Under Article 15 of the Code, the preliminary procedure obligation applies, among other things, to claims in ordinary proceedings within the jurisdiction of the single-judge court where the value of the claim exceeds 20,000 euros, to all claims within the jurisdiction of the three-judge panel, and to internal disputes in IKE companies and partnerships under Law 4072/2012. Under Article 16, a hearing of such a claim is inadmissible if a preliminary mediation or judicial mediation session has not first taken place.

• The parties choose between mediation and judicial mediation. If they do not agree, the dispute goes to a preliminary mediation session.
• The procedure does not prevent an application for interim relief, and the court can set the deadline for filing the main claim from the end of the mediation.
• A valid mediation or judicial mediation clause in the contract serves as the mandatory preliminary procedure.
• The costs of the preliminary procedure are awarded as part of the legal costs if proceedings follow.

Until 1 March 2027 the regime of Law 4640/2019 applies, which required an initial mediation session in certain types of disputes. Which regime applies to a claim filed during the transitional period should be checked with a Greek lawyer before filing.

5How do you collect a debt from a company in Greece?

For a money debt, the main tool is a payment order (διαταγή πληρωμής), alongside provisional attachment where there is a risk of assets being moved, and an ordinary claim where the debt is disputed. An Israeli creditor that is not resident or registered in the EU usually cannot use the European tools. The tools:

• Payment order (διαταγή πληρωμής): a summary procedure for a monetary debt. Under Law 5221/2025 lawyers may also issue a payment order, and the court registry adds the enforcement formula to it.
• Interim relief: provisional attachment of assets or accounts in interim proceedings, where there is a risk that the debtor will move assets.
• Ordinary claim: when the debt is disputed or there are insufficient documents.
• European tools: the European Payment Order (Regulation 1896/2006) and the European Small Claims Procedure (Regulation 861/2007, up to 5,000 euros) apply only in a cross-border dispute in which at least one party is domiciled in another EU member state. An Israeli creditor that is not resident or registered in the EU usually cannot use them against a Greek debtor.

6What is the limitation period for a contractual claim in Greece?

For many commercial claims it is five years (Article 250 of the Civil Code), and the general period in the Civil Code is 20 years, according to Greek legal sources (as of November 2026). The five years apply, for example, to claims by merchants for goods and services. A tort claim is time-barred five years from the day on which the injured party learned of the damage and the person responsible, and no later than 20 years from the event. The court does not raise limitation of its own motion, but this should not be relied on. The period should be checked for every claim according to the type of claim.

7How does commercial arbitration work in Greece?

Until the end of 2026, international commercial arbitration seated in Greece is subject to Law 5016/2023, which is based on the UNCITRAL Model Law. From 1 January 2027 the arbitration chapter of the new Code applies, with uniform rules for domestic and international arbitration. The parties are free to choose the seat of arbitration, the law, the language and the number of arbitrators.

Institutional arbitration in Greece takes place, among others, at institutions attached to chambers of commerce, such as the Athens Chamber of Commerce and Industry, and at private institutions, such as the Athens Mediation and Arbitration Organisation (EODID). Under Article 65 of the Code, arbitration institutions are entered in a register of the Ministry of Justice, and an arbitration institution lawfully operating abroad may administer arbitrations in Greece. Under the transitional provisions, an existing institution that does not register within 12 months of the chapter's entry into force will cease to operate, so when choosing an institution in an arbitration clause it is worth checking that it is registered.

8Is an Israeli or international arbitral award enforceable in Greece?

Yes, under the 1958 New York Convention. Greece acceded to the Convention on 16 July 1962 by Legislative Decree 4220/1961, and in 1980 declared the reciprocity and commercial-dispute reservations. Israel ratified the Convention in 1959. Under Article 64 of the new Code, a foreign arbitral award is recognised as binding and declared enforceable under the New York Convention “regardless of the country in which it was made”, on a written application to the competent court. The original award or a certified copy is filed, and the court may require an official Greek translation.

9How is a judgment of an Israeli court enforced in Greece?

Through a declaration of enforceability under Article 905 of the Greek Code of Civil Procedure, because an Israeli judgment is not enforced in Greece automatically. The EU regulations on recognition and enforcement apply only to judgments from EU member states, and according to Chambers' review, Greece has bilateral treaties on the subject with countries such as Germany, Tunisia and the former Czechoslovakia, but Israel is not on the list. This domestic procedure therefore applies, together with the conditions in Article 323:

1. The judgment is final and binding in the country where it was given, and enforceable there at the time the application is heard.
2. The Israeli court had jurisdiction under the jurisdictional rules of Greek law.
3. The defendant's right to be heard was respected.
4. The judgment does not conflict with a final Greek judgment between the same parties on the same matter.
5. Recognition does not conflict with Greek international public policy (Article 33 of the Civil Code), which is interpreted narrowly.

Only a judgment that orders an act to be performed, for example payment, can be declared enforceable. The application is filed with the single-judge court of first instance where the debtor has assets, or if that is not possible with the court in Athens, and is heard in non-contentious proceedings. A certified copy of the judgment and confirmation of its enforceability in Israel are attached, both with an official Greek translation. The court does not re-hear the merits of the dispute.

10And how is a Greek judgment enforced in Israel?

Under Israel's Foreign Judgments Enforcement Law, 1958. Section 3 allows a foreign judgment to be declared enforceable if the foreign court had jurisdiction under the laws of its country, the judgment is no longer subject to appeal, the obligation is enforceable in Israel and does not conflict with public policy, and the judgment is enforceable in the country where it was given. Section 4 provides that a judgment will not be declared enforceable if it was given in a country whose laws do not enforce Israeli judgments, so it must be shown that Greece does in practice enforce Israeli judgments, usually through an expert opinion on Greek law. Under section 5, an application is generally filed within five years of the judgment.

11In what language are proceedings conducted, and what about translations?

Proceedings in a Greek court are conducted in Greek. Foreign documents, including contracts in English and Israeli judgments, are filed with an official Greek translation, and Israeli public documents are authenticated with an apostille. In arbitration the parties can choose English, which is one of its advantages for an Israeli company. The cost and time of translation are part of budgeting for the proceedings.

12What should the jurisdiction and governing-law clauses say?

As a rule, a jurisdiction clause in favour of a court in an EU member state and a choice of Israeli law are respected in Greece, but when the other party's assets are in Greece, arbitration or Greek jurisdiction is worth considering. When the other party is a Greek company, a court in Greece applies Regulation 1215/2012 (Brussels I recast): a defendant domiciled in Greece is generally sued in Greece (Article 4), and in a commercial contract it is also possible to sue in the place of performance of the obligation (Article 7(1)). A jurisdiction clause in favour of a court in an EU member state is valid under Article 25. A jurisdiction clause in favour of a court in Israel is not governed by the Regulation, and its validity in Greece is examined under Greek law.

As to governing law, a Greek court applies Regulation 593/2008 (Rome I), which applies even when the chosen law is that of a non-EU country (Article 2). A choice of Israeli law in a commercial contract is therefore generally respected (Article 3), subject to the overriding mandatory provisions of Greek law (Article 9). The practical question is where the other party's assets are located: if they are in Greece, a claim in Israel adds a declaration of enforceability stage, and arbitration with an award enforceable under the New York Convention is sometimes a more direct route.

13What should you do when a dispute with a Greek party begins?

First gather the documents, check the dispute resolution clause and the limitation periods, and find out where the other party's assets are. The steps in order:

1. Gather the contract, orders, invoices, correspondence and delivery confirmations, and translate the key ones.
2. Check the dispute resolution clause: jurisdiction, arbitration, mediation, governing law and language.
3. Check the limitation deadlines and the contractual deadlines for giving notice of breach.
4. Find out where the other party's assets are located, in Greece or elsewhere.
5. Send a proper letter of demand, and consider negotiation or early mediation.
6. Consider interim relief, such as attachment, if there is a risk of assets being moved.
7. Choose the procedure (payment order, claim or arbitration) with a Greek lawyer, and coordinate the Israeli side of enforcement in advance.

More on what to do when something goes wrong in a transaction abroad is in the guide what to do when something goes wrong. This guide is general information, and every dispute requires a review of the contract, the applicable law and the time limits.

More on doing business in Greece: Setting up a company in Greece · Corporate tax and transferring profits to Israel from Greece · An Israeli company operating in Greece · Comparison of 8 countries · All guides for companies and businesses

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