Foreign Wills and Greek Property: The New Rules

April 14th, 2026.

If you own a holiday home in Paros, an apartment in Thessaloniki, or a family olive grove in the Peloponnese, and you have drafted a will somewhere else in the world, you probably haven’t given much thought to the procedural side of Greek inheritance law. Most people don’t – until they have to.

Then the questions start. Will my English will be recognised in Greece? Does it matter that I live in Germany but my house is in Crete? Do my heirs need to fly to Athens and spend a year in a Greek courtroom to sort it all out?
Until very recently, the honest answer was often: yes, and the process could be slow, expensive, and deeply frustrating. But something significant has changed. As of November 2025, Greece has introduced the most far-reaching reform of its inheritance procedures in eight decades – and for anyone with a foreign will affecting Greek assets, the rules of the game have been rewritten.

This post focuses specifically on how foreign wills are treated under the new regime. For a broader overview of how Greek inheritance law affects foreign owners – including forced heirship, inheritance tax, and the full scope of the 2026 reform – see our Greek Inheritance Law page.

The Two Legal Frameworks at a Glance

The validity of a foreign will affecting Greek assets sits at the intersection of two legal frameworks: the Hellenic Civil Code (Articles 11 and 28) and, more importantly for most cross-border cases, EU Regulation 650/2012 (known as Brussels IV), which has been in force since August 2015 and takes precedence over national law.

The Regulation’s default rule is that the law of the deceased’s last habitual residence governs the entire succession. A retired Swedish citizen who has lived in Corfu for the last fifteen years will, by default, have her succession governed by Greek law – even if she drafted her will in Stockholm decades ago.

Crucially, however, Article 22 of the Regulation lets the testator choose the law of their nationality to govern their entire estate. This is an enormously powerful planning tool for expatriates, and it should almost always be exercised explicitly in the will itself. For more on how this choice interacts with Greek forced heirship rules, see our Greek Inheritance Law page.

A practical note: Regulation 650/2012 applies in all EU Member States except Denmark and Ireland (and, of course, the United Kingdom is no longer a Member State). If you are a Danish, Irish, or British national, the rules are more complex and national conflict-of-laws principles remain decisive in your own country’s courts.

The Will-Saving Principle: Why Formal Validity Is Rarely the Problem

One of the most reassuring features of Regulation 650/2012 is Article 27, which goes out of its way to uphold the formal validity of foreign wills. A written disposition of property upon death is formally valid if it complies with the law of any one of the following: the state in which it was drafted, the testator’s nationality at the time of drafting or death, the testator’s domicile at either of those points, the testator’s habitual residence at either of those points, or – for immovable property – the state where the property is located.

In practice, this means that a will validly executed abroad will almost always be recognised as formally valid in Greece. The harder questions are usually not whether the will is valid, but what it actually achieves under the applicable substantive law, and how to get it recognised procedurally so that your heirs can actually use it to claim the Greek assets.

This is where things have changed dramatically.

The European Certificate of Succession: An Underused Tool

Before turning to the Greek procedural reforms, there is one instrument that every cross-border family should know about: the European Certificate of Succession (ECS).
Created by Regulation 650/2012, the ECS is a single document – issued by the competent authority of one EU Member State – that certifies the status of heirs, legatees, executors, and administrators across the entire Union. It is automatically recognised in all participating Member States without any further procedure. If a German court issues an ECS for the estate of a German national who owned property in Greece, Greek banks, land registries, and tax authorities are legally required to accept it as proof of the heirs’ entitlement.
For families dealing with assets in multiple EU jurisdictions, the ECS can collapse what would otherwise be several parallel probate procedures into a single streamlined process. It is under-used in practice, and part of the reason is that many advisers simply don’t know to ask for it.

What Has Changed for Foreign Wills: Law 5221/2025

The biggest recent development is procedural. While our Greek Inheritance Law page covers the full scope of Law 5221/2025 – the most substantial reform of Greek succession law in eighty years – the aspects most relevant to foreign wills are the ones we’ll focus on here.

Two changes matter most for anyone with a will drafted abroad.

First, will publication has moved from the courts to notaries. Until 31 October 2025, the publication of a will – the procedural step that allows it to take legal effect – was carried out by the Court of First Instance. In practice, this often meant waiting more than a year, sometimes close to eighteen months, for what is essentially an administrative act. For deaths occurring from 1 November 2025 onwards, notaries have taken over this function, and the typical timeframe has collapsed to a matter of days.

Second, Greece now has a national digital wills registry. The platform diathikes.gr, operated by the country’s notarial associations, has been live since 1 November 2025. All published wills are now recorded in this electronic register, replacing the previous system of scattered court registries.
Articles 807 and 808 of the Code of Civil Procedure – the provisions that governed the recognition of foreign wills under the old regime – have been substantially rewritten, and a new Article 808A has been added to govern the declaration of holographic wills as formally valid.

What This Means for Wills Drafted Abroad

The good news is that the core principle survives: foreign wills remain recognisable in Greece, and the consular route continues to exist. Under the amended framework, copies of wills published abroad can still be deposited with Greek consular authorities, provided they are certified by the competent foreign authority and accompanied by an official Greek translation (now explicitly permitted when done by a certified translator or a lawyer, not only by the translation services of the Ministry of Foreign Affairs).

For a public will prepared before a Greek consul abroad, or a holographic will presented to one, the consul remains competent to carry out publication, with copies then transmitted into the national digital registry.
The more meaningful change is on the domestic side. Once a foreign will has been recognised or a certified copy deposited in Greece, the subsequent publication and administrative handling now takes place through notaries and the digital platform – dramatically faster than the old court-based route. For heirs living abroad who have been dreading the prospect of a protracted Greek probate, this is genuinely transformative.

A further transitional point is worth noting. From 16 September 2026, once the national database is fully operational, notaries will have exclusive competence for the publication of wills regardless of the date of death. Until then, for deaths that occurred before 1 November 2025, a hybrid regime – partly court-based, partly notarial – requires careful navigation. A December 2025 amendment has already extended notarial competence to some pre-November 2025 deaths, in order to clear roughly 14,000 wills stuck in the court backlog.

One Trap to Watch: Holographic Wills and the New Authentication Rules

If your foreign will is a holographic (handwritten) will and leaves Greek assets to beneficiaries outside the immediate circle of succession – for example, a friend, a charity, or a more distant relative rather than a spouse or child – the new regime requires a handwriting expert’s report to accompany the publication. This is intended to combat forgery, but it has practical implications for international estates.

If your handwritten will is going to be relied on in Greece, your heirs may need to secure original specimens of your handwriting and retain a qualified expert. That process needs to be anticipated during estate planning, not improvised after the fact.