MiCA in Greece
Greece is putting in place the domestic measures required to apply the EU Regulation on Markets in Crypto‑Assets (MiCA – Reg. 2023/1114) and the EU “travel‑rule” Regulation on transfers of funds and certain crypto‑assets (Reg. 2023/1113). The national act therefore determines which Greek authorities will supervise MiCA activities, extends anti‑money‑laundering (AML) coverage to crypto‑asset service providers, and lays down the national enforcement toolkit.
-
Hellenic Capital Market Commission (HCMC) – sole supervisor for:
-
issuers or offerors of crypto‑assets that are not asset‑referenced or e‑money tokens;
-
Greek undertakings that wish to provide MiCA crypto‑asset services and are not already regulated as credit institutions, payment or e‑money institutions.
-
-
Bank of Greece (BoG) – supervisor for:
-
credit institutions, payment institutions and e‑money institutions when they issue e‑money tokens or asset‑referenced tokens, or when they provide crypto‑asset services;
-
the same categories when they issue asset‑referenced tokens or e‑money tokens. opengov.gropengov.gr
-
The HCMC is also designated as Greece’s single point of contact vis‑à‑vis ESMA and peer supervisors for cross‑border cooperation, while the BoG fulfils that role in respect of the European Banking Authority.
-
A start‑up that intends to obtain a Greek crypto‑asset licence must:
-
Incorporate as a Greek société anonyme (Ανώνυμη Εταιρεία) under Law 4548/2018 unless it already falls under sectoral banking/payment legislation; and
-
Maintain its statutory seat in Greece (the rule applies even where operations are cross‑border).
-
-
Determine the business model (crypto‑asset services, issuance of asset‑referenced or e‑money tokens, other issuances).
-
Identify the competent authority (HCMC or BoG – see §2).
-
Prepare the application dossier in line with the MiCA requirements applicable to the chosen activity (organisation, governance, capital, safeguarding and custody arrangements, ICT, outsourcing, complaint handling, etc.).
-
File the dossier with the competent authority; the authority must decide within six months of receiving a complete application; silence beyond that period opens the way to judicial challenge (see §8).
-
Receive the authorisation decision; once granted, the licence covers the whole EU single market under MiCA passporting, subject to notification.
-
Start operations only after the licence enters into force; operating without one is a criminal offence (see §7).
-
Although MiCA itself specifies the detailed content of the application, the national measure confirms that the Greek supervisor will apply those MiCA standards directly and may issue additional guidance where necessary.
-
-
AML/CFT – crypto‑asset service providers become “obliged entities” under Greek AML Law 4557/2018 and must implement customer due diligence, ongoing monitoring, record keeping, internal controls and reporting of suspicious transactions.
-
Supervisory reporting & inspections – licensees must submit whatever information the HCMC or BoG requests and facilitate on‑site and off‑site examinations.
-
White‑paper governance – issuers must cooperate with the supervisor on approval/updates of the crypto‑asset white paper, and supervisors can require supplementary disclosures to protect holders or financial stability.
-
The HCMC and BoG may, inter alia:
-
demand information and documents;
-
suspend or prohibit crypto‑asset services or offers for up to 30 working days (renewable) where they have reasonable grounds for non‑compliance;
-
order immediate cessation of unlicensed business;
-
require transfer of client contracts to another provider in the event of licence withdrawal.
-
Administrative fines – for legal persons, up to € 2.5 million (or 2 % of annual turnover) for general market‑abuse breaches, and up to € 15 million (or 15 % of turnover) for serious breaches such as insider dealing and market manipulation. For individuals, fines range from € 3 000 to € 5 million.
Criminal sanctions – professional provision of crypto‑asset services without the required licence is punishable by at least one year’s imprisonment and/or a pecuniary penalty; managers of legal entities are personally liable.
Supervisory decisions imposing sanctions are published on the authorities’ websites for at least five years, subject to data‑protection considerations
Any decision of the HCMC can be challenged before the Athens Administrative Court of Appeal under the rules governing that body; BoG decisions are subject to annulment proceedings before the Council of State. Applicants may also seek relief if the supervisor fails to issue a licence decision within six months of a complete filing.
Behind Licentium
Our Edge
Licentium is a specialized platform that connects crypto-asset issuers and service providers with an international network of lawyers, regulatory consultants, and former supervisors. Projects can map applicable rules in key jurisdictions through a single interface, obtain jurisdiction-specific launch advice, arrange the drafting of white papers and licensing applications, and schedule ongoing compliance health-checks. The platform’s curated expert pool spans financial services, data protection, and corporate law, enabling founders to address cross-border requirements—from MiCA in the EU to securities, AML, and consumer-protection regimes elsewhere—within coherent project timelines and budgets.
