Your Italian customer has stopped paying. Because Greece and Italy are both EU Member States, you do not need to start from scratch in a foreign legal system: EU law gives you a standard payment order and, if there is a risk the money disappears, a way to freeze the debtor's Italian bank accounts by surprise.
This article explains the two EU instruments that matter most to Greek businesses chasing money in Italy, and when an Italian national procedure is the better choice.
First, the legal framework
Between Greece and Italy, three EU Regulations do most of the work:
- 01Brussels I bis (Reg. 1215/2012) decides which court has jurisdiction and lets a Greek judgment be enforced in Italy without any declaration of enforceability (exequatur).
- 02The European Order for Payment, EPO (Reg. 1896/2006) gives you a standard, form-based procedure for uncontested money claims.
- 03The European Account Preservation Order, EAPO (Reg. 655/2014) lets a court freeze funds in the debtor's bank accounts in another Member State before the debtor is warned.
Route 1: the European Order for Payment
The EPO is designed for claims the debtor is unlikely to dispute — typically unpaid invoices for goods or services that were delivered and never contested.
- 01You file standard Form A with the competent court, describing the claim, the amount, the interest and the evidence. No hearing is held.
- 02If the application is in order, the court issues the order and serves it on the debtor.
- 03The debtor has 30 days to file a statement of opposition.
- 04If no opposition is filed, the court declares the order enforceable. It can then be enforced in any Member State, including Italy, without further formalities.
If the debtor opposes, the case continues as an ordinary civil action. In practice, this is the main limit of the EPO: a debtor who wants to buy time can do so with a one-page opposition.
Route 2: the Italian decreto ingiuntivo
If your documentation is strong — signed contract, delivery notes, invoices, an acknowledgment of debt — the Italian domestic payment order is often faster and more powerful than the EPO. It can be declared provisionally enforceable from the start in specific cases, for example when the claim is based on cheques, promissory notes or a written acknowledgment of debt, or when delay would cause serious harm. We explain this procedure in detail in our article on the decreto ingiuntivo.
Route 3: freezing the debtor's Italian bank accounts (EAPO)
The EAPO is the tool that changes the balance of power. It is granted ex parte: the debtor is not informed of the application, so the funds cannot be moved before the freeze takes effect. It is available in three situations:
- 01before you start proceedings on the merits;
- 02during proceedings in Greece or Italy;
- 03after you have obtained a judgment or another enforceable title.
What you must show depends on your position:
| Your position | What the court needs to see | Typical deadline for the decision |
|---|---|---|
| No judgment yet | That your claim is likely to succeed, and a real risk that enforcement will be impeded or made substantially more difficult | 10 working days |
| Judgment or other enforceable title already obtained | The real risk only | 5 working days |
Without a judgment, the court will usually ask you to provide security to cover the damage the debtor could suffer if the order proves unjustified.
Don't know where the debtor banks? If you already hold a judgment or enforceable title, you can ask the court to obtain account information through the Italian authorities. Italy has designated the president of the court of the district where the debtor is domiciled (or the Court of Rome, if the debtor has no Italian domicile) for this purpose.
Two practical points for Italy:
- 01The order is enforced against the bank as a third party, under the Italian rules on attachment of funds held by third parties.
- 02Italy accepts documents for EAPO purposes only in Italian. Forms and supporting documents must be translated.
Which route should you choose?
| Your situation | Usually the better route |
|---|---|
| Undisputed invoices, solid paperwork, solvent debtor | Italian decreto ingiuntivo or EPO |
| Signs that the debtor is emptying its accounts or closing down | EAPO first, then the payment order |
| You already have a Greek judgment | Direct enforcement in Italy under Brussels I bis, combined with an EAPO |
| The debtor disputes the quality or quantity of the goods | Ordinary proceedings — talk to us before filing |
Before you file
- 01Check the debtor. An Italian company search (visura camerale) shows whether the company is active, in liquidation or already in insolvency proceedings.
- 02Check the jurisdiction clause. If your contract names the Greek courts, you can sue in Greece and enforce in Italy. If it names the Italian courts, or says nothing and the debtor is Italian, you will normally sue in Italy.
- 03Add statutory interest. EU late-payment rules let you claim interest well above the invoice amount. See our guide to late-payment interest in Italy.
- 04Send a formal demand. A letter from an Italian lawyer, sent by certified email (PEC), often resolves the matter without court proceedings and interrupts the limitation period.
How we work with Greek clients
We review your documents free of charge, tell you which route fits your case and what it will cost, and handle the procedure in Italy from the formal demand to enforcement. We work in English and coordinate with your Greek lawyer where needed.
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