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Fintech Licensing Hub

Greece

Greece regulates crypto under MiCA through Law 5193/2025, with the Hellenic Capital Market Commission (HCMC) as competent authority for CASPs and the Bank of Greece for e-money tokens and banking; an early mover, Greece took a 12-month transition that ended 31 December 2025, with HCMC Decision 8/1059 setting the authorisation procedure. Payments and e-money run under Law 4537/2018 (PSD2) and Law 4021/2011 (EMD2), supervised by the Bank of Greece, with the Instant Payments Regulation and DORA in force and PSD3/PSR moving toward adoption. Gambling is regulated by the Hellenic Gaming Commission under Law 4002/2011 as amended by Law 4635/2019: online betting (Type 1) and other online games of chance (Type 2) are licensed, OPAP retains a monopoly on VLTs and lotteries, and GGR is taxed at 35% — and Greece is in the euro area and banking union, taxes individual crypto gains at a flat 15%, and prohibits gambling payments in cryptocurrency.

Available licences

Crypto-Asset Service Provider authorisation (HCMC under MiCAR and Law 5193/2025)

Custody, operation of a trading platform, exchange of crypto-assets for funds or other crypto-assets, execution, placing, reception and transmission of orders, advice, portfolio management and transfer services require HCMC authorisation under Article 63 MiCAR; an authorisation passports across the EEA.

Asset-Referenced Token (ART) issuer authorisation (HCMC)

Public offering or admission to trading of a token referencing a basket of values, rights or currencies requires authorisation as an ART issuer under Title III MiCAR, with reserve, custody and disclosure requirements.

E-Money Token (EMT) issuer (credit institution or EMI; Bank of Greece)

EMTs (including fiat-backed stablecoins) may be issued only by an authorised credit institution or e-money institution, with redemption at par; the Bank of Greece is the prudential supervisor (with the SSM for significant banks).

Article 60 MiCAR notification route (existing financial entities)

Credit institutions, investment firms, e-money and payment institutions, UCITS management companies, AIFMs and market operators already authorised under EU law may provide specified crypto-asset services by notifying the competent authority at least 40 working days before starting.

Payment Institution authorisation (Bank of Greece under Law 4537/2018)

A licence to provide payment services under the Greek PSD2 transposition, supervised by the Bank of Greece and passportable across the EEA.

E-Money Institution authorisation (Bank of Greece under Law 4021/2011)

A licence to issue electronic money and provide related payment services, with EUR 350,000 minimum initial capital, supervised by the Bank of Greece.

Account Information and Payment Initiation Services (Bank of Greece)

Open-banking providers — account information and payment initiation service providers — fall within Law 4537/2018, supervised by the Bank of Greece, with strong customer authentication.

Banking authorisation (Bank of Greece and the ECB/SSM)

Deposit-taking and lending require a banking licence; in the banking union the European Central Bank grants the licence and directly supervises significant institutions, with the Bank of Greece supervising less-significant ones.

Investment firm authorisation (HCMC — MiFID II)

Investment services in financial instruments require authorisation under Law 4514/2018 transposing MiFID II, supervised by the HCMC.

Online betting licence — Type 1 (HGC)

A seven-year HGC licence (fee EUR 3 million, renewable) to offer online betting — sports betting, fantasy sports and RNG-based virtual events — to players in Greece, subject to localisation, player-protection and technical requirements.

Online games of chance licence — Type 2 (HGC)

A seven-year HGC licence (fee EUR 2 million, renewable) to offer other online games of chance, including online casino games, poker and slots, subject to the same localisation, player-protection and technical requirements.

Land-based casino licence (HGC under Law 2206/1994 and Law 4512/2018)

Physical casinos operate under a separate licensing regime; VLTs (video lottery terminals) and lotteries are reserved to OPAP under exclusive concessions.

Detailed overview

Greece at a glance

Greece combines an early MiCA transposition, a liberalised online-gambling market and a new dedicated crypto-tax regime. Crypto is supervised by the HCMC (CASPs and ARTs) and the Bank of Greece (EMTs and banking) under Law 5193/2025; the 12-month transition ended 31 December 2025. Payments run under Law 4537/2018 and Law 4021/2011 with the Bank of Greece as supervisor and the Instant Payments Regulation and DORA in force. Gambling runs under Law 4002/2011 as amended by Law 4635/2019, with the HGC issuing Type 1 and Type 2 online licences and OPAP retaining a monopoly on VLTs and lotteries. The euro is the currency, and Greece sits inside the euro area and banking union.

Crypto regime under MiCA — HCMC-led, early transposition:

  • MiCA + national implementing law — Regulation (EU) 2023/1114 (MiCAR); Law 5193/2025 (the MiCA Law), which designates the authorities and sets the authorisation, enforcement and sanctions framework, supplemented by HCMC Decision 8/1059 (30 July 2025)
  • Competent authorities — the HCMC for CASP authorisation and ART issuers; the Bank of Greece for EMT issuers, prudential supervision and banking
  • Grandfathering — closed. Greece adopted a 12-month transition: VASPs registered under AML Law 4557/2018 before 30 December 2024 could continue until 31 December 2025, by which date they had to obtain (or apply for) MiCA authorisation; that window has expired
  • Pre-MiCA heritage — the prior regime was a light AML registration with the HCMC, so MiCA is a substantial step up in obligations
  • Authorisation procedure — Decision 8/1059 introduces a pre-application stage assessing readiness, then a formal Article 62 dossier; the HCMC decides within 40 business days, with applications accepted in Greek or English
  • AML/CFT — AML Law 4557/2018 applies, with STRs to the Hellenic FIU; the EU AML package (Regulation (EU) 2024/1624 / AMLR, with AMLA in Frankfurt) applies from 10 July 2027
  • TFR / DORA — the Travel Rule (Regulation (EU) 2023/1113) applies from 30 December 2024 and DORA from 17 January 2025
  • Tax — Greece introduced a dedicated crypto-tax framework from the 2025 tax year: individual capital gains on crypto are taxed at a flat 15%, with losses offset and carried forward up to five years, and crypto received as income (mining, staking, wages) taxed at progressive rates; reporting is to AADE, aligned with DAC8. Confirm current treatment with AADE, as the framework is recent. Corporate income tax is 22%

Payments and e-money regime (Bank of Greece-led):

  • PSD2 — Directive (EU) 2015/2366; transposed by Law 4537/2018, supervised by the Bank of Greece
  • Payment Institution licensing — initial capital EUR 20,000 (money remittance), EUR 50,000 (payment initiation) and EUR 125,000 (other payment services)
  • EMD2 / E-Money Institution — Directive 2009/110/EC, transposed by Law 4021/2011; EUR 350,000 initial capital; stablecoin (EMT) issuers must be EMIs or credit institutions
  • Instant Payments Regulation (Regulation (EU) 2024/886) — euro instant payments: receiving applicable from 9 January 2025 and sending from 9 October 2025
  • DORA (Regulation (EU) 2022/2554) — applicable from 17 January 2025
  • PSD3 / PSR — Commission proposals of 28 June 2023; provisional political agreement reached 27 November 2025, with final compromise texts published 23 April 2026 and formal adoption expected during 2026; the package will repeal PSD2 and EMD2 and fold e-money institutions into payment institutions, with PSD3 transposed nationally and the PSR directly applicable after a phased timeline
  • Banking — in the banking union the ECB grants banking licences and directly supervises significant institutions, with the Bank of Greece supervising less-significant ones
  • Currency: euro (since 2001); no exchange controls

Gambling regime — HGC-licensed, liberalised online, crypto payments banned:

  • Law 4002/2011 ("Regulating the gaming market") as amended by Law 4635/2019 — the framework; Law 2206/1994 and Law 4512/2018 govern land-based casinos
  • Regulator — the Hellenic Gaming Commission (HGC/EEEP)
  • Online licences — Type 1 (online betting; EUR 3 million) and Type 2 (other online games of chance, including casino, poker and slots; EUR 2 million), each granted for seven years on an open-ended application basis
  • OPAP — retains exclusive rights over VLTs (capped at 25,000 nationwide) and over lotteries and certain numerical games; land-based casinos are separately licensed
  • Tax — 35% of gross gaming revenue (30% for horse-race betting); players' winnings taxed on a progressive scale
  • Localisation and crypto ban — player deposits and payouts must run through EU/EEA-established credit, payment or e-money institutions, and payment by cryptocurrency is prohibited
  • Player protection — minimum age 21 for online gambling; mandatory player cards, KYC, self-exclusion register and deposit/loss/time limits; unlicensed operation is a criminal offence
  • No EU passport — gambling is licensed nationally

Last verified: July 2026. Reference rate: USD 1 = EUR 0.87 (EUR 1 = USD 1.15).

Greece is an early-moving, euro-area jurisdiction: crypto runs under MiCAR with the HCMC for CASPs and the Bank of Greece for stablecoins, payments sit under Law 4537/2018, and gambling is a liberalised HGC market that licenses online betting and games of chance but bans crypto as a payment method.

Is there a crypto licence in Greece?

Yes. Greece applies MiCAR through Law 5193/2025, with the HCMC authorising CASPs and ART issuers and the Bank of Greece authorising EMT issuers. The 12-month transition ended 31 December 2025, so operating now requires an HCMC authorisation, a valid MiCA passport, or an Article 60 notification.

The legal foundation:

  • Regulation (EU) 2023/1114 (MiCAR) — the directly applicable EU framework for offerings, admission and crypto-asset services
  • Law 5193/2025 and HCMC Decision 8/1059 — implement MiCAR in Greek law, designate the HCMC and Bank of Greece, and set the authorisation and enforcement mechanics
  • AML Law 4557/2018 — AML/CFT obligations and FIU reporting
  • Regulation (EU) 2023/1113 — Travel Rule for crypto-asset transfers

Structure:

  • A Greek entity with fit-and-proper management and qualifying shareholders
  • MiCAR own-funds floors by class — EUR 50,000 (Class 1), EUR 125,000 (Class 2), EUR 150,000 (Class 3) — with the higher of the floor or a fixed-overheads measure
  • AML systems, a white paper for in-scope offerings, custody and client-asset segregation, ICT and governance documentation, and a business plan — submitted to the HCMC after a pre-application stage

Operational reality:

  • Greece moved early on MiCA and offers a structured, two-stage HCMC process, though the authorised-CASP base is still developing
  • The new 15% flat crypto-tax regime brings clarity after years of ambiguity, with AADE reporting obligations
  • New activity should be structured through an HCMC authorisation, a valid passport or an Article 60 notification — not the closed transitional regime

Official CASP roadmap: The HCMC maintains a MiCA section and, through Decision 8/1059 (30 July 2025), sets out the CASP authorisation procedure — a pre-application readiness stage followed by an Article 62 dossier, with a 40-business-day decision and an English application summary; the 12-month transition ended 31 December 2025.

Payments & E-money (Bank of Greece — PSD2 / EMD2)

Best for payment, remittance, acquiring, wallet and open-banking operators that want a euro-area base at a gateway between Europe, the Middle East and North Africa.

What it is: Authorisation as a payment institution (Law 4537/2018) or e-money institution (Law 4021/2011), supervised by the Bank of Greece and passportable across the EEA.

Who it suits: Money-remittance and transfer providers, acquirers, card and wallet issuers, payment-initiation and account-information providers, and e-money issuers (including stablecoin issuers, who must be EMIs or credit institutions).

Covers: The payment services under Law 4537/2018 — incoming and outgoing transactions, transfers, card and instrument-based payments, money remittance, payment initiation and account information — plus issuance of electronic money.

Operational requirement: A Greek entity; minimum initial capital by service type; ongoing own-funds and safeguarding of client funds; strong customer authentication; AML/CFT; DORA operational-resilience obligations; and fit-and-proper management.

Headline figures

  • Primary instruments: Law 4537/2018 (PSD2); Law 4021/2011 (EMD2); Instant Payments Regulation (EU) 2024/886; DORA (Regulation (EU) 2022/2554)
  • Regulator: Bank of Greece (authorisation and supervision)
  • Entry capital: payment institutions EUR 20,000 / 50,000 / 125,000 by service type; e-money institutions EUR 350,000
  • Instant payments: euro instant payments receiving from 9 January 2025 and sending from 9 October 2025
  • Reform pipeline: PSD3 / PSR — political agreement November 2025, compromise texts April 2026, adoption expected during 2026; EMD2 to be repealed and EMIs folded into payment institutions
  • Currency: euro (euro-area member); no exchange controls

Is there a gambling licence in Greece?

Yes. The HGC licenses online betting (Type 1) and other online games of chance (Type 2) under Law 4002/2011 as amended by Law 4635/2019, while OPAP retains a monopoly on VLTs and lotteries and land-based casinos are separately licensed.

The legal foundation:

  • Law 4002/2011 as amended by Law 4635/2019 — the framework that liberalised the online market
  • Law 2206/1994 and Law 4512/2018 — land-based casinos
  • HGC/EEEP — licensing and supervision of all gambling

Structure:

  • Type 1 (online betting) and Type 2 (other online games of chance) licences, granted for seven years on an open-ended basis
  • Deposits and payouts must run through EU/EEA-established institutions; payment by cryptocurrency is prohibited
  • OPAP holds exclusive rights over VLTs (capped at 25,000) and lotteries

Gambling — Online licences Type 1 and Type 2 (HGC)

Best for established online betting and gaming operators able to meet Greece's localisation, taxation and player-protection requirements.

What it is: Seven-year HGC licences — Type 1 (online betting, EUR 3 million) and Type 2 (other online games of chance, EUR 2 million).

Who it suits: Operators able to meet the fee, technical and localisation requirements and the 35% GGR tax.

Covers: Type 1 covers betting (sports, fantasy, RNG virtual events); Type 2 covers casino games, poker and slots.

Operational requirement: Greek/EU-localised payments (no crypto), player cards and KYC, self-exclusion and limit-setting tools, AML/CFT and responsible-gambling and advertising compliance.

Headline figures

  • Primary instruments: Law 4002/2011 as amended by Law 4635/2019; Law 2206/1994 and Law 4512/2018 (casinos)
  • Regulator: Hellenic Gaming Commission (HGC/EEEP)
  • Licence fees: EUR 3 million (Type 1) and EUR 2 million (Type 2), each for seven years
  • Tax: 35% of GGR (30% for horse-race betting); progressive tax on players' winnings
  • OPAP: exclusive rights over VLTs (capped at 25,000) and lotteries
  • Player protection: minimum age 21 for online gambling; player cards, self-exclusion, deposit limits; crypto payments prohibited

Costs and timelines at a glance

  • Crypto: MiCAR via Law 5193/2025 and HCMC Decision 8/1059, HCMC for CASPs/ARTs and Bank of Greece for EMTs; own-funds floors EUR 50,000 / 125,000 / 150,000 by class; pre-application stage plus a 40-business-day decision; transitional regime closed 31 December 2025
  • Payments primary instruments: Law 4537/2018 (PSD2); Law 4021/2011 (EMD2); Instant Payments Regulation (EU) 2024/886; DORA
  • Payments regulator: Bank of Greece; banking licences via the ECB/SSM (banking-union member)
  • Reform pipeline: PSD3 / PSR — agreement November 2025, compromise texts April 2026, adoption expected during 2026
  • Gambling: HGC Type 1 (EUR 3m) and Type 2 (EUR 2m) seven-year online licences; 35% GGR tax; OPAP VLT/lottery monopoly; crypto payments banned
  • Tax: corporate income tax 22%; individual crypto gains taxed at a flat 15% from the 2025 tax year
  • Currency: euro (euro-area and banking-union member); no exchange controls
  • FX: USD 1 = EUR 0.87 (EUR 1 = USD 1.15)

Who Greece suits and who it does not

Suitable for

  • Crypto exchanges, custodians and token issuers wanting a MiCAR CASP authorisation from an early-moving supervisor with a structured two-stage process, and EEA passporting
  • Stablecoin issuers seeking an EMT/EMI route via the Bank of Greece
  • Already-licensed banks, investment firms, payment and e-money institutions that can add crypto-asset services through the Article 60 notification route
  • Payment, remittance, acquiring, wallet and open-banking operators wanting a euro-area base at a Europe-MENA gateway
  • Crypto investors who value the new, clear 15% flat capital-gains regime
  • Established online betting and gaming operators able to meet the HGC fee, tax and localisation requirements

Not suitable for

  • Firms wanting to rely on a former VASP registration — the transition closed on 31 December 2025
  • Operators expecting a deep, mature authorised-CASP ecosystem — Greece's base is still developing
  • Gambling operators wanting to settle in cryptocurrency — crypto payments are prohibited, and payments must run through EU/EEA institutions
  • Operators unwilling to accept the 35% GGR tax and multi-million-euro licence fees
  • Payment or e-money firms expecting to avoid EU prudential, safeguarding, DORA or AML obligations

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