Greece crypto license 2026 — HCMC CASP authorisation
Greece is one of the EU's quieter CASP jurisdictions. The HCMC authorises CASPs under MiCA and Law 5193/2025 and is also their AML supervisor. The pipeline is small (four Greek CASPs on the ESMA register in October 2026), and applications can be filed in Greek or English.
Last reviewed by the Crypto Law Index editorial desk
A smaller EU jurisdiction with a serious regulator
Greece is not a high-volume EU CASP jurisdiction. The HCMC has been deliberate in its MiCA implementation, the application pipeline is modest, and the regulator has time to engage closely with applicants. For CASPs that want a smaller-jurisdiction file with a serious-but-accessible regulator, Greece offers a different profile than Lithuania or Cyprus — fewer applications competing for supervisory attention, more direct dialogue with the assigned case team, and a slower-but-thorough process.
The supervisory map is simpler than in many member states. The HCMC is the competent authority for the securities market, Greek investment firms and Greek-authorised CASPs, and Law 5193/2025 also made it the AML supervisor for CASPs by amending Article 6(1) of Law 4557/2018. The Bank of Greece authorises and supervises CASPs only where they are banks, payment institutions or e-money institutions: Piraeus Bank, authorised in August 2026, is the example on the ESMA register.
What the HCMC looks for and the statutory clock
Advisers describe a familiar set of expectations: real local substance (a registered office and effective management in Greece; MiCA itself requires one director resident in the EU); governance sized for the operating model; an AML programme built for HCMC review; consumer-protection materials Greek clients can read; and an ICT and operational-resilience framework consistent with DORA. The HCMC's application procedure (Board Decision 8/1059/30.07.2025) sets out the questionnaire and accepts answers in Greek or English.
The MiCA Article 63 statutory clock starts when the file is deemed complete, and pre-screen typically takes three to five weeks. Once the clock starts, MiCA gives the HCMC 40 working days to decide, and one information request can suspend that for up to 20 working days. Six to nine months end-to-end is a working assumption — simpler files complete faster, while Class 3 trading-platform files use the full statutory period.
Banking access and when Greece is the right home supervisor
The principal operational friction is bank access. Bank appetite for crypto-asset businesses varies, so account opening can take months and may need a non-Greek banking relationship for operating cash flow. Plan the banking workstream in parallel with authorisation, not after — discovering at month five that the planned bank will not open the account is a frustrating outcome.
Greece works well for CASPs with a Greek or wider Eastern Mediterranean customer base, for businesses that want a serious markets regulator without the pipeline congestion of larger EU jurisdictions, and for groups that already have Greek-language operational capacity. It is a poor fit if the goal is the lowest-friction EU authorisation: the pipeline is small, the HCMC reviews licensing and AML together, and the banking workstream adds material risk.
Greece's CASP authorisation is the licence granted by the Hellenic Capital Market Commission (HCMC) under MiCA Regulation (EU) 2023/1114 Articles 59 and 63, supplemented by Law 5193/2025, to crypto-asset service providers established in Greece; the HCMC is also their AML supervisor.
Fast facts
| Parameter | Value |
|---|---|
| Regulator | Hellenic Capital Market Commission (HCMC), Athens |
| Legal basis | MiCA Regulation (EU) 2023/1114 + Law 5193/2025 |
| AML supervisor | HCMC for CASPs (Law 4557/2018 art. 6(1), as replaced by Law 5193/2025); Bank of Greece only for banks, payment and e-money institutions |
| Initial capital | €50,000 / €125,000 / €150,000 by Class 1 / 2 / 3, MiCA Annex IV |
| Statutory clock | 40 working days from a complete file to decision under MiCA Article 63(9); one information request can suspend it for up to 20 working days |
| Transitional regime | Ended 30 June 2026 for firms on the HCMC register by 27 December 2024 (Law 5193/2025 art. 125, extended from 31 December 2025 by Law 5259/2025) |
| Filing language | Greek or English for answers and supporting documents (HCMC Board Decision 8/1059/30.07.2025) |
| Best for | CASPs wanting a serious-but-accessible smaller-jurisdiction supervisor, often with Greek-language capacity |
Top counsel for Greece CASP work
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Frequently asked questions about Greece CASP authorisation
Who supervises CASP authorisation in Greece?
The Hellenic Capital Market Commission (HCMC) is the national competent authority for CASP authorisation, prudential supervision, and conduct supervision under MiCA, and since Law 5193/2025 it is also the AML supervisor for CASPs. The Bank of Greece covers CASPs that are banks, payment or e-money institutions.
Did Greece have a pre-MiCA crypto register?
Yes. The HCMC kept a register of crypto-asset providers for AML purposes. Firms that were on it by 27 December 2024 could continue until 30 June 2026 under Law 5193/2025, as extended in December 2025. That period is over.
Is Greece a fast jurisdiction for CASP authorisation?
Greece is medium-speed — typically six to nine months end-to-end for a clean first-time file. The MiCA Article 63 statutory clock runs 40 working days from a complete file, but the HCMC pre-screen is thorough and the small pipeline shapes timing.
What is the minimum capital for a Greek CASP?
The MiCA Annex IV floors apply: roughly €50,000 for Class 1, €125,000 for Class 2, and €150,000 for Class 3, depending on the service set the CASP is authorised to provide.
Pitfalls and nuances in Greece
1 Assuming English filing removes all Greek-language work
HCMC Board Decision 8/1059/30.07.2025 allows answers and supporting documents in Greek or English. Client-facing material for Greek customers, such as terms, risk warnings and complaints procedures, still has to work in Greek, so plan that translation even if the file itself is in English.
2 Treating AML as a separate regulator's problem
Since Law 5193/2025 the HCMC is both the licensing authority and the AML supervisor for non-bank CASPs. The AML programme, the AML compliance officer and the Travel Rule set-up are reviewed by the same authority that decides the licence, so weaknesses there affect authorisation directly.
3 Assuming Greek bank access for crypto businesses is easy
Bank appetite for crypto-asset businesses varies and account opening can take months, although one Greek bank, Piraeus Bank, is itself authorised as a CASP. Plan banking in parallel with authorisation, not after.
Practitioners in Greece
Named lawyers from the Crypto Law Index practitioners directory whose jurisdictional coverage includes Greece. Editorial picks, sourced from public records.
Regulator and primary sources
The supervisor of CASP authorisations in Greece is Hellenic Capital Market Commission (Επιτροπή Κεφαλαιαγοράς, HCMC). The legal basis is MiCA Regulation (EU) 2023/1114 + Law 5193/2025 (Greek MiCA implementing law). Visit www.hcmc.gr/en_US/web/portal/agores-kryptostoicheion for the regulator's official guidance, application forms, and supervisory expectations.
For where every EU and EEA state stands — its authority, its national act and when its transitional period ended — see the MiCA implementation tracker.