Greece crypto license 2026 — HCMC CASP authorisation
Greece is one of the EU's quieter CASP jurisdictions. The HCMC authorises and supervises CASPs under MiCA and Law 5193/2025, with the Bank of Greece running AML supervision. The pipeline is small and the supervisor engages closely, but Greek-language filing and limited bank access are the main frictions.
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 two-headed but coordinated. The HCMC is the national competent authority for the securities market, Greek investment firms, and now Greek-authorised CASPs; the Bank of Greece is the AML supervisor, extending its existing financial-institutions AML framework to crypto firms. The two have a long working relationship on Greek financial institutions, and that relationship carries through to MiCA implementation.
What the HCMC looks for and the five-month clock
Observed application patterns point to a familiar set of substantive expectations: local substance (a registered office in Greece, a senior manager resident in Greece, a Greek-speaking compliance contact); governance sized for the operating model; an AML programme aligned with Bank of Greece expectations; consumer-protection materials in Greek; and an ICT and operational-resilience framework consistent with DORA. The Greek market is small enough that the regulator notices thin local presence.
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, the HCMC tends to use most of the five-month period, engaging through structured information requests and follow-up meetings. 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. Greek tier-1 banks remain cautious about banking crypto-asset businesses, so account opening can be a six-to-twelve-month workstream that may require a non-Greek correspondent banking relationship for operating cash flow alongside a Greek account for regulatory deposits. Plan the banking workstream in parallel with authorisation, not after — discovering at month five of a nine-month application 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 Greek-language requirement is real, the Bank of Greece AML overlay is substantive, 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, transposed into Greek law by Law 5193/2025, to crypto-asset service providers established in Greece, with the Bank of Greece acting as the 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 | Bank of Greece, via its financial-institutions AML framework |
| Initial capital | €50,000 / €125,000 / €150,000 by Class 1 / 2 / 3, MiCA Annex IV |
| Statutory clock | Five months from a complete file under MiCA Article 63 |
| Transitional regime | None — Greece kept no pre-MiCA crypto register, so all CASPs file fresh |
| Filing language | Greek required for the formal application; English working translations accepted for supporting documents |
| Best for | CASPs wanting a serious-but-accessible smaller-jurisdiction supervisor, often with Greek-language capacity |
Top counsel for Greece CASP work
Firms below are ranked according to the published CLPAI methodology. Featured selections cover firms with documented Greece engagement, regardless of where they are headquartered.
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. The Bank of Greece is the AML supervisor.
Did Greece have a pre-MiCA crypto register?
No. Greece did not establish a pre-MiCA crypto-asset service-provider register under 5AMLD — only an AML obligation through the general anti-money-laundering rulebook. New CASPs file directly under MiCA without any transitional grandfathering.
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 five months 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 Underestimating the Greek-language file requirement
The HCMC application form, articles of association, internal policies, AML manual, ICT risk-management framework, and consumer-protection documentation must all be filed in Greek. The Greek certified-translation market is small and lead times for substantial files can exceed six weeks. Build the translation workflow into the pre-filing timeline.
2 Treating Bank of Greece AML as a formality
The Bank of Greece applies its financial-institution AML rulebook to CASPs — the same framework it applies to banks. That includes formal MLRO appointment, BoG dialogue on the AML programme before authorisation, and ongoing supervisory reporting. The AML workstream is substantive even where the HCMC licensing review is the headline.
3 Assuming Greek bank access for crypto businesses is easy
Greek tier-1 banks remain cautious about banking crypto-asset businesses. Account opening for a CASP can be a six-to-twelve-month workstream and may require a non-Greek correspondent banking relationship to bridge operating cash flow. 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, transposed in Greece via Law 5193/2025. Visit www.hcmc.gr/en/mica for the regulator's official guidance, application forms, and supervisory expectations.