Let’s Tune In To The EU’s Periphery: Greece Makes History While Leaving Italy Behind

Nicholas Zalewski
Rainbow flag flies in Greece. Source: Medium

Last week Greece made history as the first orthodox Christian nation to legalize gay marriage for same sex couples. This leaves behind Italy as the sole nation in western Europe where same sex couples cannot yet marry. For many living in Orthodox nations however, same sex marriage may seem like a distant dream. This is partly due to half of all Orthodox Christians living in Russia. In Greece, Orthodox Christians are more tolerant than in other Orthodox majority nations where many still believe same sex relationships should not be accepted. Similar to same sex marriage legislation in the other EU member states, this new law in Greece does not require the church to perform ceremonies for same sex marriages. The Greek orthodox church voiced its disapproval for the law, yet Greek Prime Minister Kyriakos Mitsotakis made it clear that this was a decision for the nation, not the church. This is drastically different from Italy where the influence of the Catholic Church still maintains a strong grip.

Italian Prime Minister Giorgia Meloni has made it clear she is a Christian woman and puts a strong emphasis on traditional families, despite never marrying her long-term partner who she currently ended her relationship with due to some controversies. While same sex couples cannot yet marry in Italy, they have had the right to a civil union since June 5th, 2016. Civil unions allow same sex couples to enjoy the majority of benefits granted by the Italian government to marriage couples, yet not all. One of the most notable examples is that same-sex couples cannot jointly adopt children. Italy may soon pass legislation which would criminalize people who seek to have children through surrogates abroad as surrogacy has already been illegal in Italy since 2004. Those found guilty may face a fine of 600.000 euros to a million euros and up to two years in jail. This has drawn criticism as the legislation would consider surrogacy to be a crime similar to human trafficking and pedophilia. This penalty is unnecessarily harsh and would likely bankrupt a couple simply looking to become parents. It is also important to remember that this ban is not just for same sex couples but also for heterosexual couples as well. To be fair, it is important to point out that besides Italy, the majority of EU member states are against surrogacy.

Map comparing where same sex marriage is legal in Europe to the historic Iron Curtain division. Source: X

Same Sex Marriage in the European Union

While eastern EU member states are catching up to those in the west, the topic of marriage is one of the noticeable issues where a relatively clear divide still exists. Except for Estonia and now Greece, no other nation that has joined the European Union in 2004 or later has passed legislation permitting same-sex marriage. Cyprus and Montenegro currently do not permit same sex marriage yet allow civil unions. It is very possible that these nations will follow Greece’s lead and allow for same sex marriage as well in the near future, due to already allowing civil unions.

Bulgaria will likely remain the last holdout due to a large majority of the population having a negative opinion of same-sex marriage. Its constitution also explicitly prohibits same-sex marriage, which means two thirds of the parliament would need to vote to amend the constitution. As Bulgaria’s parliament has struggled and has had several elections due to coalition governments collapsing, it is very unlikely that the nation will have two thirds of the parliament willing to amend the constitution in order to allow same-sex marriage within Bulgaria. Last year, the European Court of Human Rights found Bulgaria to be in violation of European human rights law for not recognizing same-sex couples, yet the nation appears to not be willing to make any changes in order to not be in violation.

Map showing portion of each nation’s population which is orthodox Christian. Source: Vivid Maps

Eastern Europe Lags Behind

Outside the European Union, Orthodox majority nations such as Russia, Belarus, Serbia, Ukraine, and Montenegro have yet to pass legislation allowing same-sex marriage and are unlikely to do so anytime soon unfortunately. This is particularly disappointing for supporters in Ukraine who fear people drafted or voluntarily joined to fight Putin’s invasion of the nation may potentially die for their nation without being able to marry their spouse or at least enter into a civil union with their significant partner to protect them legally. Russian President Vladimir Putin is well known to be anti-LGBTQ+ rights which means half of the population of the orthodox world will remain without rights for the time being. As his main political opponent, Navalny died in prison recently, it is unlikely that Russia will see a change in political leadership anytime soon.


It is impossible to view the European Union as a monolith due to how different nations can be despite all being member states. As member states have slowly passed legislation allowing for same-sex marriage, it can be expected that slowly the rest of the member states will allow it as well. At the same time, it is unknown how long this can take which for some nations may very well mean decades before same sex marriage is finally adopted. While Greece made history as the first Orthodox Christian nation to allow same-sex marriage, the majority of people living in Orthodox Christians will not have this right anytime soon, particularly those living in Russia. A lot of this will depend on a shift in the attitude in the society of each nation and whether or not voters choose politicians who are willing to pass legislation that allows for same-sex marriage.

Please Read The Following For More Information:

Smith, Peter., And Litvinova, Dasha.  “Greece just legalized same-sex marriage. Will other Orthodox countries join them any time soon?” The Associated Press. 16 February 2024.

“Punire la surrogazione di maternità commessa dal cittadino anche all’estero?”. ALTALEX. 1 August 2023.

Kajosevic, Samir. “Montenegro Makes history With First Same Sex Marriage”. Balkan Insight. 26 July 2021.

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Let’s Tune In To The EU…

by Nicholas Zalewski time to read: 4 min