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HCMC Authorization · Greece

Greece Crypto License — HCMC CASP Registration Guide 2026

Athens skyline — Greece's capital and home of the HCMC, where MiCA CASP crypto licenses are processed for the Mediterranean EU market

Greece is an established EU member state with a dedicated crypto licensing history — the Hellenic Capital Market Commission (HCMC / Επιτροπή Κεφαλαιαγοράς) has regulated crypto businesses since before MiCA, making it Greece's National Competent Authority under MiCA Regulation (EU) 2023/1114 since December 2024. Government fees of €5,000–€12,000, a 4–6 month authorization timeline, and a 22% corporate tax rate position Greece as a strategically attractive Mediterranean EU jurisdiction. Greece's prior mandatory crypto registration regime — which required HCMC registration before MiCA — means the regulator enters the CASP era with institutional knowledge and established oversight processes. A Greece CASP license grants full EU passporting rights to all 27 member states, making Athens an ideal base for businesses targeting Southern European, Balkan, and Eastern Mediterranean markets. The growing Athens fintech ecosystem and real-world crypto payment use cases in a major tourism economy further strengthen Greece's profile.

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HCMC Authorization · Greece

Greece CASP License Requirements

To obtain a Greece CASP authorization, companies must satisfy the HCMC's requirements under MiCA Regulation (EU) 2023/1114 and Greek national implementing legislation. The Hellenic Capital Market Commission's established financial services oversight — combined with its prior crypto registration regime — provides a well-defined framework for CASP applicants. The following are the core requirements for HCMC CASP authorization:

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Greek Legal Entity (AE or EPE)
AE (Ανώνυμη Εταιρεία — SA equivalent, minimum share capital €25,000) or EPE (Εταιρεία Περιορισμένης Ευθύνης — private limited company, minimum share capital €4,500), registered in Greece with a genuine registered office and operational substance. Most CASP applicants use the EPE for its administrative flexibility.
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Own Funds / Capital
Minimum €50,000–€150,000 depending on service type (MiCA Art. 67). Capital must be fully paid-up, freely available, and maintained on an ongoing basis. The HCMC requires evidence of capital adequacy at both the authorization stage and on an ongoing basis as part of prudential supervision.
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Fit & Proper Management
Board members and key function holders must pass the HCMC's fit & proper assessment: professional qualifications in finance, crypto-assets, or law; clean criminal record; financial integrity; no conflicts of interest. The HCMC reviews CVs, certified diplomas, criminal record certificates, and regulatory declarations submitted in Greek.
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AML/KYC Program
Full AML policy compliant with EU AMLA framework and Greek national AML legislation. Includes customer due diligence procedures, beneficial ownership verification, transaction monitoring, PEP/sanctions screening, MLRO appointment, and suspicious transaction reporting to Hellenic authorities (SDOE and FATF reporting chains).
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DORA Compliance
ICT risk management framework, digital operational resilience testing, and third-party ICT provider management policies — mandatory for all MiCA CASPs since January 2025. The HCMC aligns ICT risk supervision with ESMA's joint regulatory technical standards for crypto-asset service providers.
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Business Plan & Documentation
Detailed business plan in Greek with financial projections (3 years), organizational structure, IT infrastructure description, outsourcing agreements, conflict-of-interest policy, and — if issuing crypto-assets — a MiCA-compliant whitepaper under Art. 6. Supporting documents may be submitted in English with certified Greek translation.
Greece: Prior HCMC Crypto Registration Experience

Greece had a mandatory crypto registration regime with the HCMC before MiCA — making the HCMC one of the few EU regulators with pre-MiCA crypto oversight experience. This institutional knowledge facilitates a structured, knowledgeable review process for CASP applications. Companies previously registered with the HCMC benefit from the MiCA transitional arrangements running until 1 July 2026.

MiCA Article 67

Capital Requirements for Greece CASP

Greece follows MiCA Article 67 capital requirements, which are harmonized across all EU member states. The HCMC applies the same minimum own funds tiers as all other EU NCAs — MiCA's direct applicability ensures capital requirements are identical whether you license in Greece, Germany, or any other EU jurisdiction. Capital must be maintained at all times, not only at authorization stage:

CASP Service Type Min. Own Funds MiCA Reference
Advice on crypto-assets; Reception & transmission of orders; Execution of orders on behalf of clients; Placing of crypto-assets €50,000 Art. 67(1)(a)
Exchange against fiat currency; Exchange against other crypto-assets; Portfolio management; Transfer services €125,000 Art. 67(1)(b)
Custody & administration; Operation of a trading platform for crypto-assets €150,000 Art. 67(1)(c)

Under MiCA Art. 67(2), own funds must at all times be at least one-quarter of the fixed overheads of the preceding year — so capital requirements scale with business size. The HCMC may require higher own funds than the MiCA minimums if it assesses that the risk profile of a particular CASP warrants it. Capital must consist of instruments that are fully paid-up, freely available, and free from third-party claims.

The AE or EPE share capital (€25,000 or €4,500 respectively) is a separate legal requirement from the MiCA own funds obligation (€50,000–€150,000). Both must be satisfied: the share capital for Greek company law purposes, and the own funds for MiCA prudential purposes. Greece's 22% corporate income tax applies to profits generated through the Greek entity.

Strategic Advantages

Why Get a Crypto License in Greece?

Greece offers a distinct set of strategic advantages for crypto businesses seeking EU MiCA authorization. While the HCMC is not typically ranked among the lowest-cost EU licensing destinations, it offers a compelling combination of regulatory experience, market positioning, and EU passporting rights that make it a strong choice for businesses targeting Southern European and Mediterranean markets.

Mediterranean EU Gateway

Greece's geographic position at the intersection of Europe, the Middle East, and North Africa makes it a natural gateway for businesses serving these interconnected markets. A Greek CASP license provides full EU passporting rights while Athens serves as a hub for regional expansion. Greece's membership in the EU single market ensures that your HCMC authorization carries the same legal weight as any other EU MiCA CASP license.

Tourism Economy & Real-World Crypto Use Cases

Greece's position as one of Europe's top tourist destinations — with over 30 million visitors annually — creates genuine real-world demand for crypto payment solutions. The tourism economy generates practical use cases for crypto-asset exchange, payment processing, and international money transfer that are directly relevant to CASP service offerings. This market reality, combined with MiCA authorization, positions Greek-licensed CASPs advantageously for payment-oriented crypto services.

Growing Athens Fintech Ecosystem

Athens has emerged as a growing Southern European fintech hub, supported by significant EU structural fund investment in technology infrastructure, a growing pool of finance and technology graduates from Greek universities, and an increasing number of international technology companies establishing Greek operations. The Hellas Fintech Forum and HCMC's Innovation Hub have contributed to a more innovation-oriented regulatory dialogue.

HCMC Prior Crypto Experience

The HCMC's pre-MiCA crypto registration regime — which required crypto businesses to register with the HCMC under Greek national AML legislation before December 2024 — means the regulator has existing institutional knowledge of the crypto sector. This prior experience translates to more informed regulatory dialogue, clearer application expectations, and a supervision approach informed by direct oversight experience rather than theoretical understanding of the sector.

EU Passporting to 27 Member States

A Greece CASP license grants full EU passporting rights under MiCA Article 65. Your Greek entity can provide crypto-asset services across all 27 EU member states following notification to the HCMC. This single-authorization market access is identical in scope to a BaFin, DNB, or any other EU NCA authorization.

Step-by-Step

How to Get a Greece Crypto License

1
Gap Analysis & Jurisdiction Assessment
We assess your business model, target crypto-asset services, and corporate structure against the HCMC's MiCA requirements. We confirm capital needs, identify documentation gaps, assess language requirements, and validate Greece as the optimal NCA given your EU passporting strategy, market focus, and operational footprint in the Mediterranean region. Timeline: 1 week.
2
Greek AE or EPE Formation
We establish a Greek AE or EPE with genuine substance in Athens: registered office address, local directorship or relocation support, and a corporate bank account with a Greek or EU-passporting bank. Company registration is conducted through the Greek General Commercial Registry (ΓΕΜΗ / GEMI). The share capital of an EPE (€4,500) or AE (€25,000) must be paid up at formation. Timeline: 2–3 weeks.
3
Compliance Documentation Package (Greek Language)
We prepare the complete HCMC CASP submission package in Greek: business plan with 3-year financial projections, AML/KYC policy aligned with Greek AML legislation and ESMA guidance, DORA ICT risk framework, internal governance policies, fit & proper materials for all board members with certified Greek translations where required, and any necessary MiCA-compliant whitepaper. Timeline: 4–6 weeks.
4
HCMC Application Submission & Review
We submit the complete CASP authorization application to the HCMC (Επιτροπή Κεφαλαιαγοράς). The HCMC confirms completeness within 25 working days (MiCA Art. 63), then undertakes substantive review within 65 working days of a complete application. We manage all HCMC correspondence in Greek, respond to information requests, and liaise with the HCMC authorization department throughout the review period. Timeline: up to 65 working days.
5
CASP Authorization & EU Passporting Activation
Upon HCMC CASP authorization, your company is entered into ESMA's public register of authorized CASPs. We initiate EU passporting notifications for all target member states, enabling you to provide crypto-asset services across the full EU single market from your Greek AE or EPE. Timeline: 1–2 weeks post-authorization.
Cost Overview

Greece Crypto License Cost

The total cost of a Greece CASP license comprises government fees paid to the HCMC, professional service fees for documentation and legal support, and the MiCA own funds capital requirement. The table below provides a breakdown of typical costs for a Greece HCMC CASP authorization in 2026:

Cost Component Amount Notes
HCMC Government Fee €5,000–€12,000 Statutory fee for CASP authorization application
Greek Company Formation (EPE) €1,500–€3,000 Notary, GEMI registration, share capital
Professional & Legal Fees €10,000–€25,000 Documentation, Greek legal review, HCMC liaison
Translation & Notarization €1,000–€3,000 Certified Greek translations for foreign documents
MiCA Own Funds Capital €50,000–€150,000 Regulatory capital (not a fee — remains in business)
Annual HCMC Supervision Fee €2,000–€5,000 Ongoing annual regulatory fee (estimated)

Compared to Germany (BaFin government fees of €10,000–€50,000+) or the Netherlands (DNB fees of €5,000+), Greece's HCMC fees are positioned in the mid-range among EU licensing jurisdictions. The main differentiator is market positioning: a Greek CASP license offers strategic value for businesses targeting Mediterranean and Balkan markets that a lower-cost Eastern European jurisdiction may not provide. For a full comparison of EU licensing costs, see our MiCA CASP License guide.

MiCA Article 65

EU Passporting from Greece

A Greece CASP license issued by the HCMC carries full MiCA EU passporting rights — a single HCMC authorization grants your company the right to provide crypto-asset services in all 27 EU member states under MiCA Article 65. This is the same passporting right as a BaFin authorization in Germany or a De Nederlandsche Bank authorization in the Netherlands. You gain access to the entire EU single market from one NCA relationship.

How Greece CASP Passporting Works

  • Notification to HCMC: To begin providing services in another EU member state, your Greek AE or EPE submits a passporting notification to the HCMC specifying the target country, service types, and intended start date.
  • 10-working-day forwarding: The HCMC must forward the notification to the host state NCA within 10 working days. You may commence providing services in the host state on the day the notification is forwarded — without waiting for host NCA approval.
  • ESMA register publication: All HCMC-authorized CASPs appear in ESMA's publicly searchable register, providing immediate confirmation of authorization status to institutional counterparties across the EU.
  • Home vs. host supervision: The HCMC is your home-state prudential supervisor. Host-state NCAs supervise conduct-of-business requirements applicable in their territory under MiCA.

For companies serving clients across the EU, Greece provides full single-market access through passporting while offering the strategic positioning of a Mediterranean EU hub. See our guide on EU passporting under MiCA for the complete procedural framework. For other Southern European options, see Ireland CASP License or compare with Germany CASP License and Netherlands CASP License.

Frequently Asked Questions

Greece CASP License FAQ

What is the HCMC CASP license in Greece?
The HCMC CASP license is a crypto-asset service provider authorization issued by the Hellenic Capital Market Commission (HCMC / Επιτροπή Κεφαλαιαγοράς) under MiCA Regulation (EU) 2023/1114. Since December 2024, the HCMC serves as Greece's National Competent Authority for MiCA, responsible for authorizing and supervising all CASPs operating in or from Greece. A HCMC authorization allows companies to provide crypto-asset services — including exchange, custody, portfolio management, and transfer services — across Greece and all 27 EU member states through EU passporting.
Did Greece have crypto regulation before MiCA?
Yes. Greece had a mandatory crypto registration regime with the HCMC prior to MiCA. Companies providing crypto-asset services in Greece were required to register with the Hellenic Capital Market Commission under national legislation implementing EU AML directives. This prior registration experience means the HCMC entered the MiCA era with established crypto oversight processes, making it one of the more experienced EU regulators in the crypto space. Companies previously registered with the HCMC benefit from the MiCA transitional period running until 1 July 2026.
What are Greece's MiCA capital requirements?
Greece follows MiCA Article 67 capital requirements, which are harmonized across all EU member states: €50,000 for lower-risk services (advice, reception and transmission of orders, execution of orders, placing); €125,000 for exchange, portfolio management, and transfer services; and €150,000 for custody and trading platform operations. Capital must be fully paid-up, freely available, and maintained on an ongoing basis. The HCMC applies these requirements uniformly and may require higher own funds if your risk profile warrants it.
What entity type do I need for Greek CASP licensing?
For a Greek CASP license, you need either an AE (Ανώνυμη Εταιρεία) — the Greek SA equivalent, requiring minimum share capital of €25,000 — or an EPE (Εταιρεία Περιορισμένης Ευθύνης) — Greek private limited company, requiring minimum share capital of €4,500. Most CASP applicants use the EPE for its administrative simplicity. Both entity types can hold a HCMC CASP authorization. Genuine business substance in Greece is required in both cases — a registered office, local management presence, and operational infrastructure.
Is English accepted in HCMC applications?
HCMC applications are primarily conducted in Greek. The core application, business plan, AML policies, and governance documents must be in Greek or accompanied by certified Greek translations. The HCMC may accept certain supporting documentation in English — particularly technical specifications, international certifications, and CVs of foreign management. Our Greek regulatory team handles all HCMC correspondence and documentation in Greek while coordinating with international clients in English, ensuring full compliance with HCMC language requirements without placing the translation burden on clients.
Why consider Greece for crypto licensing?
Greece offers strategic Mediterranean positioning for crypto businesses targeting Southern European, Balkan, and Eastern Mediterranean markets. The HCMC's prior crypto registration experience provides a knowledgeable regulatory environment. Greece's major tourism economy creates real-world crypto payment use cases. The growing Athens fintech ecosystem provides talent and infrastructure. A Greek CASP license grants full EU passporting rights to all 27 member states under MiCA Article 65 — providing the same single-market access as any other EU NCA authorization. For businesses where Mediterranean market positioning matters, Greece provides unique strategic value alongside regulatory certainty. Contact us for a free assessment of Greece vs. other EU jurisdictions for your specific business.
Legal and compliance team in Athens working on Greece HCMC CASP license application under MiCA
Regulatory History

Greece Crypto Regulation Background

Greece's regulatory approach to crypto-assets has progressed from early AML-focused national registration to the comprehensive MiCA CASP authorization framework. Before December 2024, the Hellenic Capital Market Commission operated a mandatory crypto registration regime — one of the few EU regulators to have established direct crypto oversight before MiCA entered into force. This regulatory continuity is a meaningful advantage for Greek CASP applications.

Key Regulatory Timeline

  • Pre-2021: Crypto-asset businesses in Greece operated under general financial services oversight. The Bank of Greece and HCMC issued initial guidance on crypto-assets and ICOs, aligning with EBA and ESMA positions.
  • 2021–2023: Greece implemented EU AML directives requiring HCMC registration for crypto businesses. This established the first formal requirement for crypto-asset service providers to engage with a Greek financial regulator, giving the HCMC direct supervisory experience with the sector.
  • 2022–2024: The HCMC actively monitored MiCA's legislative development and began internal preparation for NCA designation. Greece transposed AML Directives 5 and 6, tightening requirements for crypto businesses and aligning Greek standards with FATF recommendations.
  • December 2024: MiCA becomes fully applicable across the EU. The HCMC is formally designated as Greece's MiCA National Competent Authority and begins accepting CASP authorization applications. Greece adopts the standard 18-month VASP transitional period under MiCA Article 143, with the transition window running until 1 July 2026.
  • January 2025: DORA becomes applicable to all MiCA CASPs, adding mandatory ICT operational resilience requirements to every HCMC CASP authorization.
  • 1 July 2026: EU-wide VASP transitional deadline. All crypto businesses operating in Greece must hold a valid CASP authorization under MiCA.

Greece's competitive advantages as a CASP jurisdiction are rooted in its Mediterranean strategic positioning, HCMC's institutional crypto knowledge, and the real-world demand created by a major tourism economy. Athens offers a growing fintech talent pool, EU-standard legal infrastructure, and a regulator that understands the crypto sector from direct supervisory experience. Contact us to discuss your Greece CASP application strategy.

Nikos Papadimitriou — Greek Financial Regulatory Specialist
Greece Expert
Nikos Papadimitriou
Greek Financial Regulatory Specialist · Athens

Athens-based regulatory consultant with 8+ years HCMC licensing experience, specializing in MiCA CASP applications and Greek financial services regulation. Nikos advises international clients on AE/EPE formation, HCMC authorization strategy, Greek AML compliance, and EU passporting from Greece. He maintains active knowledge of HCMC supervisory guidance and ESMA technical standards applicable to Greek CASPs, and has guided companies through Greece's financial services authorization processes since the pre-MiCA crypto registration era. Speak to Nikos →

€5K–€12K
Government Fees
4–6
Months Approval Timeline
10M+
EU Market Access
27
Countries EU Passporting

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