This article was featured in Jus Mundi‘s 2025 Arbitration Year in Review, an annual publication analyzing arbitration developments across 40+ jurisdictions on 6 continents. This edition brings together young practitioners and senior experts to capture the year’s most significant legislative reforms, enforcement trends, and institutional innovations.
THE AUTHORS:
Stefanie G. Efstathiou, Legal Counsel, DENIC eG
Spyridon Batzios, Greek Qualified Lawyer, Independent Practice
Angeliki Giannakli, Associate, Ioannis Vassardanis & Partners
This article provides an overview of key developments in international arbitration in Greece in 2025, with a particular focus on important arbitration-related decisions issued by Greek courts and governmental initiatives promoting arbitration in Greece.
In Greece, the longstanding dual system (opposed to the monistic system), under which domestic arbitration continues to be governed by the Greek Code of Civil Procedure (“GCCP”), while international commercial arbitration is governed exclusively by Greek Law 5016/2023, remains in place. This bifurcated framework is increasingly regarded as outdated and structurally inefficient. A growing body of scholars and practitioners has called upon the legislature to abolish this dualism and to adopt Law 5016/2023 as a unified statutory regime applicable to all arbitrations seated in Greece. Such reform would bring Greek arbitration law fully in line with prevailing international practice, enhance legal coherence, and promote greater predictability for the users of arbitration.
Pending such legislative consolidation, Law 5016/2023 continues to govern international commercial arbitration. Although minor amendments were introduced by Law 5197/2025, said amendments did not modify any of the statute’s substantive or innovative features – most of which deriving from the UNCITRAL Model Law on International Commercial Arbitration 2006 – but rather concerned initiatives aimed at strengthening the institutional framework for mediation in Greece. The following section presents key judicial decisions reflecting the Greek courts’ pro-arbitration stance in 2025.
Case Law Highlights
Decision 551/2025 (Supreme Court of Greece)
Decision 551/2025 addressed the issue of annulment of an arbitral award on the grounds of alleged violation of public policy. The case involved a dispute between the Hellenic Republic and a private concessionaire, focusing on the enforceability of an arbitral award awarding compensation for lost toll revenues.
Definition of Public Policy: The Court clarified that violations of public policy justify annulment of an arbitral award only when the award contravenes mandatory rules intended primarily to protect the public interest, reflecting the fundamental political, cultural, social, or economic foundations of Greek law. It emphasized that rules established to protect private interests, including errors of law or insufficient reasoning by arbitrators, do not constitute public policy violations. In this context, the Court held that statutory limitation rules governing claims against the State do not fall within the scope of public policy, as they regulate private-law relationships between the State and private parties rather than serving the public interest. Accordingly, partial enforcement of claims otherwise barred by limitation periods is permissible if refusal would contravene principles of good faith. Furthermore, the Court distinguished between rules of mandatory law and rules of public policy, concluding that the provisions of the Greek Civil Code (“GCC”) on good faith and fair dealing, i.e., Articles 281 and 288 GCC, are mandatory private-law norms but do not constitute rules of public policy, insofar as their purpose is to protect private interests rather than safeguard the public order.
Scope of Review: The Supreme Court dismissed the appeal, affirming the arbitral award. It concluded that the tribunal did not violate public policy and that partial enforcement of the claims, even if they were subject to statutory limitation, did not contravene fundamental legal principles or rules of public order.
This decision highlights the Greek judiciary’s support for arbitration as a flexible and autonomous mechanism, while outlining the narrow circumstances under which arbitral awards may be annulled on public policy grounds. It underscores the distinction between private-law mandatory rules and rules of public policy and showcases the careful balance between party autonomy and the protection of public policy, thereby reinforcing the finality and effectiveness of arbitral awards, even in disputes involving the State.
Decision No. 503/2025 (Single-Member Court of First Instance of Piraeus)
The Decision No. 503/2025 examined the revocation of interim measures in light of a final foreign arbitral award. The case arose from a Removal of Shipwrecks and Maritime Services Contract involving oil transfer and transshipment, governed by English law with arbitration held in London.
Effect of Arbitral Awards: The Court confirmed that arbitral awards, final and binding in the place of issuance (in this case, in the United Kingdom), which are not subject to judicial remedies, have a res judicata effect (pursuant to Article 903 of the GCCP), which had been recognized by a prior decision of the Court. In addition, the Court emphasized that appeals against the recognition of such awards do not automatically suspend their enforceability (Article 763 para. 1, GCCP). Furthermore, the Court examined Articles 696(3) and 698(1) – (2) of the GCCP, emphasizing that interim measures may be revoked if circumstances change or once the underlying dispute is resolved by a final judgment, with an arbitral award being treated as equivalent to such a final judgment.
Scope of Review: The Court determined that it was competent to hear the present application, holding that international jurisdiction was established under the applicable procedural rules of the GCCP (lex fori). Then, the Court proceeded with revoking its prior interim measures under article 698 § 1(a) of the GCCP, since it held that an arbitral award resolving the dispute constitutes a “change of circumstances” within the meaning of Article 696 § 3 of the GCCP and that these circumstances result in the automatic cessation of the respondents’ need for extraordinary judicial protection and, consequently, constitute a lawful basis for the revocation of the imposed interim measure.
This decision underscores the Greek judiciary’s recognition of arbitration as a binding, effective, and internationally respected dispute-resolution mechanism, and it also establishes a precedent for the mandatory revocation of interim measures once an arbitral award is rendered.
Decision 1913/2025 (Court of Appeals of Athens)
Decision 1913/2025 examined the scope and interpretation of an arbitral clause in a consulting contract (“TSAA”) between a Greek technical‑advisory company and a German parent/supplier company, and whether all their disputes fell under that clause.
Broad Interpretation of Arbitral Clause: The Court rejected the argument that the arbitral clause applied only to disputes concerning the validity or interpretation of the TSAA. Instead, applying Greek contract‑interpretation rules (Articles 173 and 200 of the GCC), the Court held that all disputes arising out of the TSAA (and even earlier oral agreements) fall under arbitration. This included not just interpretative issues but also business substantive claims.
The Court inferred the parties’ genuine mutual will, based on their conduct, good faith, and trade usage, to have submitted all their disputes to arbitration, not just narrow legal issues. It noted that if they had intended a narrow clause, they would have omitted the broader term “any disputes” from the clause. The Court reasoned that limiting arbitration to interpretative disputes would risk procedural fragmentation, litigation delays, and increased costs, especially when validity, interpretation, and substantive claims are at issue. By contrast, a broad arbitration clause serves procedural efficiency.
Party autonomy: Given that the parties are based in different countries (Greece and Germany) and agreed to arbitrate in Zurich, the Court considered this further evidence that they did not want the courts of either country to have jurisdiction over all their disputes. The tribunal in Zurich was a neutral forum.
Scope of Review: The Court dismissed the appeal and upheld the decision of the lower court, which had found that it lacked jurisdiction due to the dispute being subject to arbitration and had referred the action for adjudication to the Arbitral Tribunal in Zurich, Switzerland. The Court concluded that the lower court’s decision was not erroneous in its interpretation or application of the law, nor in its assessment of the evidence, although its reasoning was partially different and was replaced and supplemented by that of the decision of the Court.
This decision underlines the willingness of Greek courts to interpret arbitration clauses very broadly, especially in international commercial contexts. It emphasizes that parties’ real intentions, good faith, and commercial reality should guide the interpretation of arbitration agreements, not just literal wording.
Procedural Reforms
In 2025, Article 947(1) of the GCCP underwent an important amendment introducing a targeted clarification with respect to the enforcement of non-monetary obligations imposed by arbitral awards. Under the revised text, where an arbitral tribunal orders a party to refrain from, or to tolerate, a particular act, the power to issue the corresponding threat of a monetary penalty or personal detention (traditional enforcement measures aimed at ensuring compliance) is vested explicitly in the Single-Member Court of First Instance. The same court is designated as the competent authority both to determine whether a breach has occurred and to impose the relevant sanction. This legislative intervention enhances procedural certainty at the enforcement phase, strengthens the practical effectiveness of arbitral injunctive relief, and harmonises the enforcement regime of arbitral awards with that applicable to judicial decisions, thereby reinforcing Greece’s overall pro-enforcement approach to arbitration.
Within this broader reform context, additional initiatives have been adopted to promote arbitration and other forms of alternative dispute resolution. Notably, a Special Secretariat for Alternative Dispute Resolution was established within the Ministry of Justice, reporting directly to the Minister, with a mandate to reform the legislative framework governing arbitration, mediation, judicial mediation, and other ADR mechanisms. Moreover, work is underway on a new comprehensive Code on Arbitration and ADR, which is expected to further streamline and modernise the relevant procedures.
These measures underscore Greece’s commitment to the modernisation and institutional strengthening of dispute resolution, including arbitration. This commitment is further reflected in the establishment of the Chalcis Bar Association Arbitration Mechanism under Presidential Decree 46/2025. The mechanism creates a permanent arbitral institution for private-law disputes, supervised by a three-member Arbitration Committee responsible for overseeing proceedings and maintaining the register of arbitrators.
Conclusion
In 2025, developments in Greek arbitration emphasized the finality of awards, expansive interpretation of arbitral clauses, and narrow public policy grounds for challenge of arbitral awards. Legislative and procedural reforms, along with strengthened ADR frameworks, further enhanced enforcement, efficiency, and alignment with international arbitration standards.
Discover more insights into the latest developments in arbitration in 2025 from around the world now
ABOUT THE AUTHORS
Stefanie G. Efstathiou is one of Greece VYAP’s Co-Chairs. She is an IP and ADR lawyer with a particular focus on domain name disputes. She is dual-qualified in Greece and in Germany and an in-house legal counsel at DENIC eG, the registry for .de domain names based in Frankfurt. She also serves frequently as Domain Name Panelist for various dispute resolution providers in domain name disputes. Before becoming an in-house counsel, Stefanie worked at top tier law firms in Munich in the fields of IP, domain name disputes and international arbitration. Stefanie’s interests have always been in the intersection of technology and ADR; therefore, her PhD research focuses on the topic of AI in Arbitration (LMU, Munich). Stefanie is also advising or representing clients in her private practice and is a frequent speaker at conferences on AI and Dispute Resolution. Finally, she is part of the IBA Task Force on AI, which is working on the upcoming IBA Guidelines on the use of AI in Arbitration.
Spyridon Batzios is a Greek lawyer and one of the Co-Chairs of Greece VYAP. He has acquired multidimensional work experience and has worked at top-tier law firms in Germany and Greece, where he handled litigation and arbitration cases under different laws and rules pertaining inter alia to international sales of goods, agency and distribution agreements, banking and construction disputes. Spyridon holds an LL.B. from the Aristotle University of Thessaloniki, an LL.M. in German business law and arbitration from the Ludwig Maximilian University of Munich, an LL.M. in Private international law from the Democritus University of Thrace from which he graduated as valedictorian and an LL.M. in international dispute settlement from the University of Geneva which he attended as a double scholar. He has also attended further ADR training courses in various European cities, including Athens, Paris, Rome and the Hague.
Angeliki Giannakli is an associate at Ioannis Vassardanis & Partners Law Firm, focusing on international commercial and investment arbitration under institutional rules, including ICSID and LCIA. She advises on complex disputes in the construction, energy and infrastructure sectors and has significant experience with construction contracts (including FIDIC contracts) and cross-border commercial agreements. Beyond dispute resolution, Angeliki supports clients on day-to-day contractual matters, M&A transactions, and tender procedures, and has contributed to the drafting and preparation of private tender documents for major construction projects. She serves as one of the Reporters for Greece in the ITA Arbitration Report, acts as Events Coordinator of Greece VYAP, and is a certified mediator accredited by the Greek Ministry of Justice. Angeliki holds an LL.M. in Arbitration Law and International Procedural Law from the Democritus University of Thrace, graduating with distinction.
*The views and opinions expressed by authors are theirs and do not necessarily reflect those of their organizations, employers, or Daily Jus, Jus Mundi, or Jus Connect.
