At a time when competition over energy resources in the Eastern Mediterranean is intensifying, the signing of a new memorandum of understanding between the Turkish Petroleum Corporation (TPAO) and Libya’s National Oil Corporation (NOC), which includes seismic exploration activities, has become a significant development in terms of regional power balances. This cooperation between Turkey and Libya is considered a natural extension of the 2019 maritime jurisdiction agreement between the two countries, and, as expected, it has elicited a strong reaction from Greece. The Greek government argues that the agreement disregards the maritime jurisdiction of the island of Crete, thus violating Greece’s sovereign rights. As a result, Greece has portrayed the issue not as a bilateral dispute between Turkey and Libya, but as a multilateral crisis that should be addressed at the level of the European Union (EU). In this context, Greek Prime Minister Kyriakos Mitsotakis once again brought the matter to the EU summit agenda in Brussels, aiming to position Turkey as an “unlawful actor.”
Why, then, has Greece felt the need to elevate this memorandum beyond a bilateral issue and place it on the EU’s common foreign policy agenda? One of the key reasons for Athens’ move is the possibility that Libya’s House of Representatives based in Tobruk may approve the memorandum. Such approval would grant the agreement not only technical but also political legitimacy, thereby weakening Greece’s arguments regarding maritime jurisdiction in the region. Furthermore, Greece is acting with the concern that regional power balances in the Eastern Mediterranean may shift against its favor and seeks to limit Turkey’s growing influence in the region. In this regard, Greece prefers to use the EU’s multilateral and institutional support mechanisms to exert collective diplomatic pressure on Turkey. Moreover, by raising claims of the agreement’s invalidity under international law in official EU forums, Greece aims to strengthen its position in the international arena.
Simultaneously, Greece seeks to consolidate its regional alliances by increasing cooperation with actors such as Southern Cyprus and Egypt. Given that the vast maritime zones covered by the Turkey–Libya memorandum directly conflict with the interests of both Greece and the EU, Athens’ sense of urgency in preserving its sovereign claims and regional dominance has further motivated its efforts to internationalize the issue. These factors reveal the underlying concerns and strategic calculations driving Greece’s strategy to involve the EU, thereby creating diplomatic and political pressure on Turkey. However, this situation not only highlights how Greece uses its foreign policy tools, but also demonstrates the extent to which the EU has deviated from the principle of neutrality in its approach to the Eastern Mediterranean.
The memorandum on the delimitation of maritime jurisdictions signed between Turkey and Libya, along with the recent seismic research agreement under its framework, has further complicated the already fragile geopolitical equilibrium in the Eastern Mediterranean. Greece responded strongly to Turkey’s cooperation with the NOC, escalating the matter to the EU level as a political pressure tool. Yet, these developments should be assessed not only in diplomatic terms, but also from the perspective of international law.
It is important to emphasize that the memorandum signed between Turkey and Libya constitutes an international agreement based on mutual consent between two sovereign states. Under international law, particularly with respect to maritime jurisdiction delimitation, such mutual agreements between coastal states are considered legitimate and standard practice. Although Turkey is not a party to the United Nations Convention on the Law of the Sea (UNCLOS), this does not prevent it from exercising rights derived from international maritime law. Articles 74 and 83 of UNCLOS stipulate that delimitation of the continental shelf and exclusive economic zones must be based on mutual consent and principles of equity. Therefore, it is legally difficult to argue that the Turkey–Libya memorandum is invalid from a technical standpoint. Its validity rests on the preservation of sovereign rights and delimitation through mutual agreement, making it compatible with international legal norms. Consequently, objections by other regional states should be viewed as reflections of political and geopolitical concerns rather than legal deficiencies. Within this framework, the Turkey–Libya memorandum should be recognized as a legitimate agreement under international law.
Greece’s primary objection to the agreement lies in its claim that the maritime jurisdiction of Crete was disregarded, thereby infringing upon its sovereign rights. However, under international law, islands are not automatically entitled to generate full maritime zones. On the contrary, international jurisprudence, including decisions of the International Court of Justice (ICJ), has acknowledged that factors such as an island’s geographical location, size, and the proximity of the mainland of the opposing coastal state may lead to limited maritime entitlements. Thus, Turkey’s legal argument that “islands far from the mainland have limited capacity to generate continental shelves” is grounded in strong legal precedents and is not merely a political stance. Accordingly, any assessment of Crete’s maritime jurisdiction must take into account its geographic context and the sovereign rights of other states in a balanced manner.
Greece’s attempt to involve the EU in this process indicates that the issue has been transformed from a legal-technical matter into a political campaign. The Turkey–Libya memorandum was explicitly rejected at the 2019 EU Summit and reaffirmed in similar terms in 2022. However, such EU positions carry no legal binding force. The EU lacks jurisdiction and decision-making authority in matters concerning maritime jurisdiction and state sovereignty under international law. Therefore, the EU’s stance essentially reflects political support for one of its member states—Greece—rather than a neutral legal judgment. Hence, Greece seeks to amplify pressure on Turkey by leveraging the EU’s institutional weight, despite lacking firm legal grounds. This reflects the EU’s increasing tendency to shape its Eastern Mediterranean policy in line with the narrow interests of its member states, deviating from its principle of neutrality.
At this point, the following question arises: “Can Turkey, as a sovereign state, enter into an agreement with Libya?” The answer is unequivocally yes. According to the Vienna Convention on the Law of Treaties, an agreement binds only its signatory parties and does not confer rights or obligations on third states. The Turkey–Libya memorandum fully complies with this rule. So, why is Greece reacting so vehemently? The answer lies not in the legal content of the agreement, but in its strategic implications. The memorandum allows Turkey to clearly define its maritime jurisdiction in the Eastern Mediterranean and enhances its capacity to preempt unilateral actions in the region. Greece, on the other hand, sees this move as a restriction on its maneuvering space in the regional energy equation.
Parallel to this, Greece’s efforts to block Turkey’s participation in EU defense initiatives such as SAFE (Security Action for Europe) are particularly noteworthy. Although the SAFE Fund can technically be extended to third countries, such participation requires unanimous approval from all EU member states. This gives Greece, as a member state, the ability to veto Turkey’s integration into the EU’s defense architecture. Thus, Greece is not only seeking to curb Turkey’s influence in matters of maritime boundaries and energy, but also within the broader context of the EU’s Common Security and Defence Policy (CSDP). This strategic stance underscores the expanding scope of geopolitical competition in the Eastern Mediterranean. The struggle over energy and maritime borders is increasingly intertwined with regional security and defense policies. Turkey’s participation in EU defense projects like SAFE would enhance its regional military cooperation and global standing—an outcome that raises concerns in Athens over a potential shift in the regional balance of power in Turkey’s favor. Therefore, Greece’s veto efforts represent not just legal or diplomatic opposition but a concrete manifestation of regional power rivalry in the defense and security domain.
In conclusion, the memorandum signed between Turkey and Libya rests on a solid legal foundation and reflects the principle of mutual consent between coastal states, consistent with the provisions of UNCLOS and relevant international jurisprudence. The memorandum demonstrates Turkey’s commitment to protecting its strategic interests in the Eastern Mediterranean and to establishing a legal and diplomatic counterbalance to unilateral efforts to impose a regional status quo. Greece’s objections to this memorandum are driven more by geopolitical and strategic concerns than by legal arguments. Greece’s claims regarding its maritime jurisdiction and sovereignty are not fully supported by international law but should be viewed as a reflection of regional competition and security policies.
The EU’s position on the matter, rather than representing a neutral legal assessment, is shaped by political solidarity among its member states and their shared strategic interests. The EU lacks jurisdiction in matters involving sovereignty and international maritime law, and thus acts as a political platform reflecting the interests of its member states—particularly Greece. Accordingly, the EU’s criticism of the Turkey–Libya memorandum should be interpreted as an expression of political concerns shared by Greece and other member states.
Turkey is pursuing a multi-dimensional strategy in the Eastern Mediterranean that is both legally sound and diplomatically effective. While such a strategy inevitably provokes political reactions, these responses do not undermine the legal legitimacy of Turkey’s actions. On the contrary, they affirm Turkey’s status as an influential actor in the region and a legitimate stakeholder in the delimitation of maritime jurisdictions. For a lasting solution, it is crucial that all parties engage in dialogue and negotiations based on international legal principles and mutual consent.
