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Greece’s Electronic Pledge Registry: Key Developments and Practical Considerations 6 May 2026

"The Hellenic Cadastre designated the 30 June 2025 as the date for the commencement of operation of the unified registry for the Electronic Pledge Registry."

As anticipated by Greek Law no. 5123/2024¹ (“Law 5123”), the Hellenic Cadastre (Ελληνικό Κτηματολόγιο) designated the 30 June 2025 as the date for the commencement of operation of the unified registry for the registration of pledges (the “Electronic Pledge Registry”).² From that date onwards, any pledge agreement governed by Greek law that has been entered into on or after 30 June 2025 is subject to registration to the Electronic Pledge Registry, in line with the requirements set out in Law 5123.

In this article we offer practical insights and recommendations regarding the registration process, drawn from our ongoing experience monitoring the operation of the Electronic Pledge Registry. We also highlight the required documentation for submitting accurate and complete applications.

1. Legal Effects of Registration

The entry into operation of the Electronic Pledge Registry marks a major milestone in the process of establishing security interests under Greek law. Under the new regime, registration with the Electronic Pledge Registry serves as a new perfection requirement for the lawful creation of a pledge. In particular, Law 5123³ provides that a pledge produces legal effects:

  • against the debtor: once the debtor is notified of the pledge (i.e. in practice, by the service of the pledge agreement by a court bailiff); from that point onward, the debtor may no longer validly complete any payment to the pledgor; and
  • against third parties: only upon its registration in the Electronic Pledge Registry.

It should be noted that for the purposes of determining the priority ranking of the pledges, the decisive factor is the exact time of submission of the application to the Electronic Pledge Registry. Therefore, if two applications are submitted on the same date, the pledge whose registration application is submitted earliest will rank first, even if both applications are registered on the same day.

  • Specific provisions for share pledges and account pledges:

With respect to the share pledge and assignment agreements in particular, registration to the Electronic Pledge Registry is not only required for producing legal effects against third parties, but it also serves as a statutory form (συστατικός τύπος) for security creation.

The only type of pledge agreement exempt from the registration requirements in accordance with Law 5123 is the creation of a pledge over accounts held by the same financial institution which is the beneficiary of the security (i.e. the capacities of the pledgee and the account bank are held by the same financial institution).

2. Registration Fees: Recent developments

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"Considerable concern arose in the market regarding the applicable registration fees for pledges created to secure any type of loan (other than bond loans), due to the absence of any statutory provisions establishing a fixed - fee methodology."

With the entry into force of Law 5123 and especially after the commencement of the Electronic Pledge Registry’s operation, considerable concern arose in the market regarding the applicable registration fees for pledges created to secure any type of loan (other than bond loans), due to the absence of any statutory provisions establishing a fixed – fee methodology. This issue was resolved by the recent Ministerial Decision no. 2/12.01.2026⁴ pursuant to which:

  • pledges created to secure bond loans, have registration fees set at a fixed amount of €100 per agreement;
  • for security agreements established to secure any other type of loan, the registration fees are determined based on the secured amount. In particular, Ministerial Decision no. 2/12.01.2026 has introduced a graduated fee structure, pursuant to which registration fees increase progressively in line with the loan amount. The maximum fees that may apply is €3,500 for loans of €100m and above; and
  • for any additional registration securing the same claim, a fixed fee of €150 is payable.

3. Practical Takeaways and Best‑Practice Recommendations

  • The Electronic Pledge Registry only accepts applications between 8:30 and 13:30 on business days. Outside this timeframe, the system allows the application to be saved as a draft but not submit.
  • The registration process requires supporting documents, including a Registration Form,⁵ solemn declarations of the signatories of each contracting party and legalisation documents, which must bear authentication of signature. The recommended and most time-efficient method of authentication is through gr.
  • It is safer to monitor the status of an application directly through the platform rather than waiting for the Registry to notify of any status changes. This is particularly important with respect to the payment stage, as the platform allows only three business days to complete payment following the issuance of an order of payment. Failure to make the payment within this deadline will result in the automatic rejection of the application.
  • Translation costs should be taken into consideration. This is particularly important where a security document has been drafted in English and a certified Greek translation needs to be uploaded. Typically, the Registry accepts translations:
  • certified by lawyers; or
  • certified by a translator registered with the ‘Registry of Certified Translators of the Ministry of Foreign Affairs of the Hellenic Republic’.⁶
  • Decision no. 384/14/03.12.2025 of the Board of Directors of the Hellenic Cadastre (published in the Government Gazette issue ‘B’ no. 6469/03.12.2025) clarified that the uploading of legalisation documents is not required if the lawyer provides a solemn declaration (as mentioned above). However, to avoid any delays, it is advisable to upload all the required legalisation documents, including the solemn declarations, as supporting documents to the initial application.
  • It is also important to ensure the legalisation documents of the contracting parties (e.g. the resolution of the pledgor’s Board of Directors) expressly authorise the designated individuals to sign the Registration Form, as well as any other supporting document that may be required under Law 5123/2024 and to submit applications to the Registry.

4. Activity Overview of the Electronic Pledge Registry since its launch

The Electronic Pledge Registry has now been in operation for around seven months, and, to date, it has received approximately 3,000 applications. In terms of processing times, we have noticed that applications submitted in December began to be processed in early March. This indicates that there is currently a significant waiting period for applications to be reviewed and completed.

"Our team remains closely engaged with the Electronic Pledge Registry’s operation to ensure smooth and timely registrations on behalf of our clients as well as compliance with Law 5123."

5. Conclusion

The introduction of the Electronic Pledge Registry has reshaped the process of creating and perfecting security interests under Greek law, introducing new formalities, documentation and practical considerations. Careful preparation of supporting documents and following the ongoing publication of new related legislation are essential to ensuring timely completion of security documents.

Our team remains closely engaged with the Electronic Pledge Registry’s operation to ensure smooth and timely registrations on behalf of our clients as well as compliance with Law 5123.

Footnotes

[1] Published on the Government Gazette issue A’ no. 109/19.07.2024.
[2] Pursuant to the decision no. 362/13/26.06.2025 of the Board of Directors of the Hellenic Cadastre (in Greek: Ελληνικό Κτηματολόγιο) which was published on the Government Gazette issue Β’ no. 3333/30.06.2025.
[3] Please refer to article 7 of Law 5123/2024.
[4] Published on the Government Gazette issue B’ no. 64/13.01.2026.
[5] The template of the registration form can be found in Template (3) of the Annex of Decision no. 366/10/25.08.2005.
[6] In accordance with the Ministerial Decision no. Π23ΜΕΣ- 34908/2021 which was published on the Government Gazette issue B’ no. 3149/Β/19.07.2021.

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