GREEK INHERITANCE LAW REFORMS: IMPLICATIONS FOR INTERNATIONAL ESTATES

Recent reforms to Greek inheritance law mark one of the most consequential shifts in the country’s succession framework in decades. While the changes are technical in form, their implications are practical and far-reaching, particularly for internationally mobile families, foreign heirs and fiduciaries administering estates with Greek connections.

Taken together, the reforms move Greek succession law toward greater predictability, economic rationality and alignment with contemporary family and asset-holding realities, while preserving core principles such as forced heirship.

The present article outlines the key themes emerging from the new Greek inheritance law reforms and highlights the considerations that internationally connected families and advisers should now be weighing with care.

A MODERNISATION AGENDA WITH CROSS-BORDER IMPACT

The reforms reflect a broader legislative effort to modernise Greek private law, improve procedural efficiency and align domestic succession rules more closely with broader European practice.

At a high level, the changes seek to:

• reduce inheritance disclaimers, particularly in indebted estates, and reactivating dormant assets, especially real estate
• modernise intestate succession and forced heirship rules, while clarifying heirship rights and obligations
• simplify relations among co-heirs
• eliminate obsolete provisions and resolve long-standing interpretative ambiguities
• upgrade judicial liquidation mechanisms and reduce procedural delay and formalism

For internationally connected families, the significance lies less in any single provision than in the cumulative recalibration of assumptions that underpinned Greek succession planning for decades.

SEPARATION OF ESTATE AND PERSONAL LIABILITY: A FUNDAMENTAL SHIFT

Among the most consequential reforms is the restructuring of heir liability for estate debts.

Greek inheritance law now effectively adopts acceptance with benefit of inventory as the default position. Heirs are no longer exposed to personal liability for the debts of the deceased. Estate obligations are satisfied exclusively from the inherited estate, which is legally segregated from the heir’s personal assets.

This reform addresses a long-standing source of uncertainty that historically drove widespread inheritance renunciations - even in estates of substantial net value. By removing the risk of personal financial exposure, the law encourages acceptance of inheritances and restores economically productive assets to circulation.

For fiduciaries and foreign heirs in particular, this change materially improves the ability to assess risk and make decisions quickly.

INTRODUCTION OF INHERITANCE CONTRACTS

A significant innovation is the introduction of inheritance contracts (agreements causa mortis) and agreements waiving future inheritance rights.

These mechanisms allow:

• advance settlement of succession matters
• rational organisation of post-death asset allocation
• reduction of family disputes and litigation risk

For family businesses, productive real estate and complex asset structures, inheritance contracts provide a tool to ensure continuity, stability and controlled succession to suitable successors—an option previously unavailable under Greek law.

FORCED HEIRSHIP: REFINEMENT RATHER THAN RETREAT

Forced heirship remains a cornerstone of Greek succession law, but its operation has been refined.

One of the most structurally significant reforms concerns the nature of the forced heirship entitlement, as its legal character is fundamentally altered: the forced share is converted from a real (in rem) right into a monetary claim. Mandatory heirs no longer acquire co-ownership in estate assets, particularly real estate. Instead, they hold a financial claim against the heirs.

This shift aims to reduce fragmentation of assets, limit operational deadlock and facilitate the efficient exploitation of estate property - an especially relevant development for real estate and asset-heavy estates.

For internationally structured families, this matters, increasing the importance of early strategic planning. Greek forced heirship rules can conflict sharply with succession outcomes anticipated under common law wills, trusts or foreign succession arrangements. The reforms do not eliminate that tension, but they do affect how and when disputes crystallise and how they are litigated or settled.

MODIFICATION OF INTESTATE SUCCESSION AND ENHANCED PROTECTION OF MODERN FAMILY STRUCTURES

Significant amendments are introduced for cases where no will or inheritance contract exists. The position of the surviving spouse is accordingly reinforced through an increased statutory share.

At the same time, reflecting contemporary social realities, the reforms expand protection beyond traditional family models. Key developments include broader recognition of modern forms of family life and cohabitation, extending protection to individuals who may not qualify as close relatives in the traditional sense but form part of the deceased’s family reality.

This evolution aligns succession outcomes more closely with lived relationships, while introducing new considerations for estate structuring in blended or non-traditional families.

WILLS AND PROCEDURAL STREAMLINING

The institution of the handwritten (holographic) will is preserved, but procedures for its activation and enforcement are modernised.

More broadly, the reforms tighten procedural deadlines, evidentiary standards and administrative steps. While this enhances efficiency, it also narrows margins for error, particularly for foreign heirs and executors unfamiliar with Greek procedural discipline.

Efficiency and enforcement now move in tandem.

CROSS-BORDER ESTATES AND EU SUCCESSION REGULATION ALIGNMENT

The reforms also interact with Greece’s application of the EU Succession Regulation, an area that has long generated uncertainty for families with multinational footprints.

Clarifications around applicable law, habitual residence and the recognition of foreign succession instruments aim to reduce friction between Greek courts and foreign estate planning structures. However, alignment does not mean uniformity. Greek public policy considerations, particularly around forced heirship, continue to assert themselves where foreign arrangements push against domestic boundaries.

LITIGATION DYNAMICS AND RISK SENSITIVITY

With greater clarity comes sharper lines of dispute.

The reforms are likely to concentrate litigation around fewer, more clearly defined issues. Challenges to wills, heirship entitlements and estate administration decisions may become more focused and, in some cases, more aggressively pursued.

For high-value estates, this raises broader considerations around asset visibility, timing of transfers and the management of family expectations. Inheritance disputes in Greece often intersect with allegations of undue influence, asset dissipation or procedural irregularities, exposing families and fiduciaries to reputational risk and, at times, risk of criminal proceedings.

STRATEGIC CONSIDERATIONS FOR INTERNATIONAL FAMILIES

The Greek inheritance law reforms do not demand immediate action from every family with a Greek nexus. They do, however, reinforce the importance of reassessing assumptions.

Among the questions that internationally connected families may wish to reflect on are:

• how existing wills and succession arrangements may be improved given the imminent changes
• how forced heirship exposure is managed across jurisdictions
• how executors and advisers are equipped to meet revised procedural expectations
• how dispute risk is anticipated and contained

These are not matters of form, but of judgement.

Inheritance reform rarely makes headlines. Its true consequences emerge years later, when estates are administered and expectations tested.

The new Greek inheritance framework rewards preparation, precision and international awareness. For families whose personal and economic lives span borders, succession planning must be understood not as a static exercise, but as an evolving strategy. Thoughtful assessment today can reduce uncertainty tomorrow.

At SKANDAMIS AVOCATS, we regularly assist high-net-worth families and fiduciaries in navigating the intersection of international succession law, cross-border disputes and asset protection considerations, with a focus on clarity, discretion and long-term resilience.