Andreas Papachristodoulou
Partner

Andreas has significant experience advising on a broad range of finance transactions, including bilateral and syndicated facilities (secured, structured and unsecured), international and cross-border transactions, ECA-backed financings, sale and leasebacks, loan portfolio sales, intercreditor and subordination arrangements, accession deeds, restructurings, work-out arrangements, securitisations and structured and complex banking products.

He regularly acts on financings for both newbuilding and second-hand vessels and yachts, advising on a range of finance documentation from plain vanilla term loan facilities to more complex and structured arrangements, including bonds and finance leases, across all types of commercial vessels and yachts.

Andreas’ expertise also includes representing shipowners in a variety of matters such as the sale and purchase of vessels and yachts, review of delivery documentation, charterparty contracts, escrow agreements, conditional payments, shipbuilding contracts and refund guarantees, preparation of corporate documentation and negotiation of finance documentation.

Georgia Asimakopoulos
Partner

Georgia Asimakopoulos is a very skilled maritime finance lawyer with over twenty years of experience advising leading European, Asian, and U.S. banks and financial institutions and shipowners on a broad range of complex and high-value, multi-jurisdictional shipping transactions.

A Greek-American bilingual lawyer qualified in Massachusetts, England & Wales and Greece whose initial practice began with U.S. insolvency law in Boston and later developed into two decades of maritime law in Athens, Greece, Georgia brings a truly international perspective to her practice.

As a Partner in the Maritime, Trade & Offshore practice at Stephenson Harwood LLP in Athens, she works closely with clients guiding them on vessel acquisition sale and purchase contracts, sale and leaseback arrangements, cross-border asset-finance (including syndicated, bilateral and mezzanine loan facilities), loan restructurings, banking portfolio transfers, as well as shipbuilding contracts and refund guarantees.

Navigating Change: Key Legal Developments and Emerging Trends in the Greek Shipping Market

Greece remains a leader in the global shipping industry, owning and operating one of the largest merchant fleets in the world. With a proud maritime heritage, a strategic geographic position and a substantial portion of the world’s shipping capacity, Greek shipowners play a pivotal role in influencing global trade.

However, the landscape in which Greek shipowners operate is rapidly evolving due to increasing regulatory complexity, environmental pressures and profound changes in financing and digital infrastructure. Navigating this transformation requires close collaboration between legal, commercial and technical stakeholders. The Greek legal community is instrumental in interpreting and responding to new requirements, ensuring compliance while helping clients seize emerging opportunities.

This chapter outlines the most consequential legal trends affecting Greek shipping in 2025 and outlines how they are likely to shape the industry’s trajectory into 2026 and beyond.

Environmental Compliance and Regulatory Transition

A primary area of focus for Greek shipping companies is the implementation of the European Union’s climate agenda, particularly the inclusion of shipping in the EU Emissions Trading System (“EU ETS”). Since 2024, maritime voyages involving EU ports incur costs on emissions, paid by way of the purchase and surrender of EU carbon allowances (“EUAs”). In 2025, the proportion of in-scope emissions on which costs are payable leaped from 40% to 70% of voyage emissions, ahead of a further increase to full compliance (100% of in-scope emissions) by 2026.

These new obligations represent a structural cost increase, with industry forecasts suggesting potential annual liabilities of over €1 billion for the Greek fleet alone. The liability to pay these costs falls by default upon registered owners (including bank and financier owners) with an option to transfer the obligation to the Document of Compliance holder if mandatory criteria are satisfied. The penalties for non-compliance are both financial and reputational and include the payment of excess emissions penalties and publication of the names of non-compliant entities.

This development has prompted a wave of contract renegotiations, particularly concerning ship management agreements and charterparties, where the allocation of emissions costs is a critical issue. Although the EU ETS Directive contains provisions requiring Member States to take measures ensuring charterers reimburse shipowners/managers the costs of compliance, the implementation of such measures is incomplete and difficulties may arise where claims are made by managers with no contractual link with charterers or by owners or managers pursuant to charterparties. Furthermore, there has been widespread response to the changes as a commercial trading opportunity with both charterers and shipowners able to participate in the market for the sale and purchase of EUAs, generating additional need for new and revised contractual arrangements.

Additionally, the FuelEU Maritime Regulation (Regulation (EU) 2023/1805) which entered into force on 1 January 2025 introduces binding targets for reducing the greenhouse gas intensity of energy used onboard ships trading within the EU from 2025 onwards. FuelEU complements EU ETS by driving the adoption of cleaner fuels and vessel efficiency improvements. Pursuant to FuelEU, GHG emissions are calculated on a well-to-wake basis taking into account emissions related to extraction, cultivation, production and transportation of fuel, in addition to emissions produced by consumption.

As a result, Greek shipowners are exploring a range of technical solutions, from installing energy-saving devices to transitioning toward methanol, ammonia or biofuels. These shifts present both technical and legal challenges and raise a spectrum of contractual issues relating to regulatory compliance, the valuation of compliance deficits and surpluses, trading of surpluses by way of ‘pooling’ and in connection with retrofitting warranties, performance clauses and fuel specifications

IMO’s Net Zero Framework and Global Emissions Strategy

Beyond the European context, international regulation is also accelerating. The International Maritime Organization (“IMO”) has approved a new framework, the Net-Zero Framework (“NZF”), designed to decrease the GHG intensity of shipping and drive the uptake of alternative fuels. If adopted, the new rules will take effect as amendments to MARPOL Annex VI and will impose further significant costs on shipping for energy use from 2028 onwards. NZF will need to be accommodated by new provisions within a wide range of contracts, including charterparties and ship management agreements. However, its adoption in October 2025 has become uncertain after the United States exited the talks in August 2025 and urged other IMO member states to reject their support to the framework.

For Greek operators with global fleets, the adoption of NZF will add a new layer of compliance complexity as they will need to find solutions that allow them to comply with both EU and IMO regimes. Greek operators are therefore likely to seek multi-jurisdictional advice from specialist maritime decarbonisation lawyers on emissions-related liabilities and the integration of evolving regulations into shipping documents, from loan agreements to shipbuilding contracts.

ESG and Sustainability Integration

As regulatory frameworks continue to evolve, Environmental, Social and Governance (“ESG”) considerations are becoming an integral part of maritime operations and legal strategy. Regulatory pressure, investor scrutiny and commercial imperatives are aligning to make ESG integration a core business priority for shipowners and operators.

At the regulatory level, the EU’s Corporate Sustainability Reporting Directive mandates enhanced sustainability disclosures from large companies, including many in the maritime sector. While these obligations are introduced in stages, in 2025, Greek shipping companies with European operations should have already started to prepare detailed ESG reports that meet the new requirements. Legal teams often assist in aligning corporate governance with ESG benchmarks, which is increasingly necessary to access institutional capital. The focus areas include emissions, energy usage, diversity,

governance policies and social impact.

From a legal perspective, ESG is now a core component of shipping finance transactions involving Greek financiers and borrowers. Sustainability-linked loans are becoming more common, requiring Greek borrowers to meet emissions or efficiency targets in return for more favourable terms. Green bonds and other ESG-labelled instruments are also growing in popularity, though they require robust legal frameworks to ensure transparency and credibility.

Lawyers are playing a central role in documenting these products and in drafting performance-related covenants and helping their clients understand the implications of sustainability-linked penalties and disclosures. ESG-related due diligence is also becoming standard in M&A, refinancing and fleet renewal projects.

Maritime Legal Reform

In May 2023, a modernised Greek maritime legislative framework came into force. The enactment of the new Code of Private Maritime Law (the “New Code”) is the most substantial since the 1950s and addresses inconsistencies, streamlining procedures and aligning national legislation with international conventions in force. It covers key areas such as vessel registration, maritime mortgages, enforcement rights and limitations of liability.

It is hoped that shipowners and operators will increasingly choose Greek law to govern their international shipping and ship finance contracts as the New Code reduces uncertainty in maritime litigation, strengthens seafarer’s rights and protections and aligns dispute resolution mechanisms with international best practices (including provisions around arbitration and mediation).

Whether or not the New Code has strengthened Greece’s position as a ship finance centre will need to be determined over time. While a step in the right direction, the number of Greek ships and gross tonnage has not increased since 2023.

Digitalisation of the Greek Shipping Sector

Digital transformation is also reshaping the Greek shipping sector in both the public and private spheres. A prominent initiative introduced by the New Code is the digitalisation of the Greek nautical register, which will bring greater transparency and efficiency to vessel registration. This reform, which is expected to come into force in 2026, should reduce bureaucratic delays and improve Greece’s competitiveness as a flag state. New services include digital issuance of Tonnage Certificates and Telecommunication Station Permits, digital vessel sale applications, digital registration and mortgage discharges, the electronic keeping of register books and automatized vessel record updates.

In addition, the Greek tax administration is enforcing the transition to digital reporting through the myDATA e-transport platform. From December 2025, electronic submission of transport documents will become mandatory for most businesses. This requirement reflects broader European efforts to modernise tax compliance and impose financial transparency across supply chains. This has significant implications for Greek shipping companies who need to overhaul their internal reporting systems, train their employees, and coordinate the transition with the help of their legal counsel to ensure full compliance.

This digital modernisation, coupled with increased regulation, presents both opportunities and challenges for lawyers having to advise not only on the implementation of legal tech solutions but also on data protection, system integrity and audit preparedness. Cybersecurity concerns are also on the rise, and legal teams are increasingly involved in preparing digital risk mitigation policies and incident response protocols.

Additionally, the rise of digital platforms for trade and finance is beginning to influence maritime lending. Legal frameworks are evolving to accommodate blockchain-backed registries, electronic bills of lading and tokenised finance instruments.

Greek ship-owning companies are also revolutionising the world fleet by exploring the implementation of technological advancements on their ships including potentially autonomous vessels, big data to analyse substantial amounts of data from ports, vessels and supply chains to enhance their decision making in respect of fuel consumption, maintenance and trading routes and artificial intelligence which can help predict maintenance needs.

Global Trade Policy and Geopolitical Risks

The impact of international policy shifts and geopolitical tensions is increasingly felt among Greek shipowners. In April 2025, the United States introduced a new fee structure affecting vessels built in, or operated by, certain countries, particularly China. These measures include phased charges on Chinese-built vessels entering US ports and restrictions on future LNG and vehicle carrier deployments and carry strategic and legal implications.

The initial announcement created significant concern as 35% of the Greek fleet is composed by Chinese-built ships, with 400 of the 600 newbuildings on order in Greece being constructed in China. Despite the uncertainty, shipowners in Greece appeared to remain positive overall on the severity of how shipping and the Greek global fleet will be affected.

Nevertheless, Greek owners are reassessing their fleet construction plans and route planning strategies to mitigate potential cost exposures. Legal guidance is critical in assessing whether existing vessels fall under the scope of the new regulations, revising charterparties to account for new cost burdens and evaluating resulting contractual risks.

Greek owners, many of whom operate mixed-nationality fleets, must also consider the implications for existing financings, particularly where vessels constructed in targeted jurisdictions are pledged as collateral. The role of legal counsel is essential in monitoring compliance, renegotiating financing agreements and assisting with due diligence on newbuild and acquisition projects.

Basel IV and Market Shifts

Over the decades since 1988, the Basel Committee on Banking Supervision has been continuously adapting capital adequacy requirements for banks to address expanding financial risks. Most of the latest measures, known as Basel IV, were implemented in Greece on 1 January 2025.

In 2025 and 2026, such fundamental changes in the global financial regulatory landscape will reshape the dynamics of ship finance. Stricter capital adequacy standards and risk weightings have made traditional bank lending more selective and expensive and, particularly for non-investment grade borrowers and those operating older or higher-emissions tonnage, less accessible.

This shift is prompting Greek shipowners to explore new sources of funding. Export credit agencies, private debt funds, leasing houses and capital markets are filling the gap, offering bespoke structures often tied to sustainability or technological innovation. Sale-and-leaseback transactions, mezzanine financing and hybrid instruments are now part of the ship finance toolkit.

Legal advisors are increasingly involved in negotiating these complex structures, ensuring compliance with local and international regulatory regimes and drafting documentation that balances lender protections with operational flexibility.

Conclusion

Greek shipping stands at the nexus of tradition and transformation. Long celebrated for its resilience and entrepreneurialism, the sector now faces a confluence of global legal, regulatory and financial developments that demand adaptive thinking and strategic planning. From environmental regulation and digital innovation to legal modernisation and geopolitical uncertainty, shipowners and their advisors must manage growing complexity while seizing new opportunities.

As 2026 approaches, the Greek maritime sector is not only navigating change quickly and efficiently – it is helping to define the future of global shipping law and finance.