Foreign wills and Greek assets: which law applies and how a foreign will is recognised in Greece
Many of our clients own Greek property but have made their will abroad. This article sets out how Greek law and the EU Succession Regulation determine the validity of such wills and the steps needed to use them in Greece.
The conflict-of-laws framework
Under the Greek Civil Code a legal act is formally valid if it complies with the law governing its substance, the law of the place where it was made or the national law of the parties (Article 11), and succession is governed by the law of the deceased’s nationality at death (Article 28). For deaths since 17 August 2015, however, these rules are displaced by Regulation (EU) No 650/2012, which applies in Greece with precedence over national law.
Under the Regulation, the succession as a whole is governed by the law of the deceased’s habitual residence at death, unless he or she was manifestly more closely connected with another state (Article 21), and a person may choose the law of his or her nationality to govern the whole succession (Article 22). The admissibility and substantive validity of a will are judged by the law that would have governed the succession had the testator died on the day the will was made (Article 24), while Article 27 saves the formal validity of a written disposition if it complies with the law of the place where it was made, of the testator’s nationality, domicile or habitual residence, or – for immovables – of the place where the property is located. Since 2026 Greek domestic law also allows a choice of law to be made in an inheritance contract (Article 1798 of the Civil Code), the validity of which is governed by Article 25 of the Regulation.
Using a foreign will in Greece
A will published abroad can be used in Greece once a certified copy, with a Greek translation, is deposited with a Greek consular authority, which forwards it to the Register of Wills (Article 808(4) of the Code of Civil Procedure). Wills held by Greek consulates, and holographic wills presented to them by holders living abroad, are published by the consul directly (Articles 1760–1761 of the Civil Code). A foreign grant of probate or letters of administration is not, as such, a title to Greek assets; the heirs will normally also need a Greek certificate of inheritance or a European Certificate of Succession, followed by acceptance of the inheritance before a Greek notary and registration at the Land Registry.
A word of caution on common-law wills
Wills drafted in common-law jurisdictions often appoint executors and trustees and leave the estate on trust. Greek law recognises the appointment of an executor, but the English trust has no direct equivalent; the closest institution is the fideicommissum (successive heirship). The 2026 reform, which converted the Greek forced share into a monetary claim, has removed one traditional obstacle to giving effect to such wills, but their interpretation in a Greek context still calls for specialist advice.
How we can help
We regularly advise foreign executors, trustees and heirs on the recognition of wills, the European Certificate of Succession and the transfer of Greek real estate.
Updated October 2026. This article reflects Law 5303/2026, applicable to successions opening on or after 16 September 2026, and is for general information only; it does not constitute legal advice.
* The information is accurate to the best of our knowledge as at the time of writing. We have no obligation to update it. We accept no responsibility against any third party who is not a client of the firm and has not signed the terms of our engagement.