The international recognition of civil marriages of same-sex couples constitutes a decisive step toward consolidating equality and legal certainty. Now, with the enactment of Law 5089/2024, couples who choose to get married in Greece are called upon to carefully examine the extent to which, and by what process, this marriage is recognized in their country of residence or interest. The existing international and EU law creates a mosaic of different regulations, where recognition is sometimes automatic and other times requires special legal handling. In this article, we present the key points you need to know about the recognition of a lawfully conducted civil marriage in Greece within the framework of the international legal order.
First of all, in all countries where marriage between same-sex couples is permitted by domestic legislation, your marriage in Greece is automatically recognized. These countries include, among others, France, Germany, Spain, Italy, the Netherlands, Belgium, the United Kingdom, the United States, Canada, and Australia. In these countries, married same-sex couples enjoy full equality of rights and obligations with heterosexual married couples.
In certain countries, such as Romania, Bulgaria, and Poland, although same-sex marriage is not permitted by domestic law, any marriage that has been lawfully conducted abroad must be recognized as valid. The obligation to recognize lawfully conducted marriages abroad stems from a ruling of the Court of Justice of the European Union.
There are also countries such as Russia, Turkey, Saudi Arabia, and China, where marriage is not recognized and may even lead to sanctions or restrictions.
The process of recognizing a marriage conducted in Greece abroad depends on the legislation of the country in which recognition is sought. However, the usual procedure includes the following steps: 1) official translation of the marriage certificate into the required language of the country of recognition, 2) authentication either with the apostille stamp from the Greek Decentralized Administration, if the country of recognition has acceded to the Hague Convention, or otherwise consular legalization through the Greek Ministry of Foreign Affairs or via the Embassy/Consulate of the country of recognition, and 3) submission of the translated and authenticated marriage certificate to the competent public authority of the country of recognition, along with the submission of the required supplementary documents, in accordance with the legislation of the country of recognition.
The process of recognizing a civil marriage conducted in Greece abroad may present significant legal and administrative challenges, as each country applies its own regulatory framework. For this reason, it is crucial to consult a reliable and experienced law firm that can safely guide you through each stage.