Greece -- Securities Classification Regulatory Overview

Executive Summary

• Crypto assets are legal in Greece, but there is no dedicated national securities framework classifying digital assets; instead, Greece applies EU-level regulations, primarily MiCA (Markets in Crypto-Assets Regulation) and existing financial services law. EUR-Lex — Access to European Union law — choose your language
• The Hellenic Capital Market Commission (HCMC) is the responsible regulator for securities and investment services, operating under Greek transposition of EU directives and regulations. COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014
• No Greek entity has been granted a dedicated crypto-asset license under a national framework, as Greece has not established its own licensing regime separate from EU-level provisions; the practical reality is that firms must rely on MiCA passporting or national investment firm authorisation. EUR-Lex - 62017CC0493 - EN - EUR-Lex
• The ESMA decision (EU) 2019/679 directly binds Greek authorities regarding product intervention measures for contracts for differences (CFDs), which extends to crypto-derivatives marketed to retail investors in Greece. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679
• Practical reality: crypto businesses face regulatory uncertainty at the national level, with no Greek-specific securities treatment guidance for tokens; EU-level frameworks and case law provide the operative legal basis. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex

Regulatory Framework

Regulatory Bodies

• The Hellenic Capital Market Commission (HCMC) is the Greek competent authority for securities markets, investment services, and investor protection, acting under EU regulatory framework. COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014
• The Bank of Greece (Trapeza tis Ellados) serves as the central bank and has historically exercised authority over capital movements and foreign exchange transactions involving securities. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

Primary Legislation

• The First Council Directive of 11 May 1960 for the implementation of Article 67 of the EEC Treaty (OJ, English Special Edition 1959-1962, p. 49) — this foundational instrument classified categories of capital movements, including "securities dealt in on a stock exchange" under List B, Item IV A of Annex I, and remains relevant for interpreting what constitutes a security for capital movement purposes. 62003CC0329_EN
• Commission Decision (EU) 2015/1092 of 23 July 2014 (OJ 2015 L 182) — addresses Greek financial stability measures, demonstrating the EU-level framework within which Greek securities regulation operates. COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014
• ESMA Decision (EU) 2019/679 of 30 April 2019 — product intervention measure restricting the marketing, distribution, and sale of CFDs to retail investors, applicable to all EU member states including Greece. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679
• Case C-329/03 (Trapeza tis Ellados AE v Banque Artesia), Judgment of 27 October 2005 — the European Court of Justice held that bonds issued by a bank, denominated in national currency, with a one-year term, dealt in and quoted on a stock exchange, fall within "securities dealt in on a stock exchange" under List B, Item IV A, not money market instruments under List D, Item VI. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex
• No Greek national legislation has been identified that specifically classifies crypto-assets as securities; the framework is determined by EU-level regulations and their transposition. EUR-Lex — Access to European Union law — choose your language

International Standing

• Greece is an EU member state and subject to the European System of Financial Supervision, including ESMA's binding decisions; Greece is a member of the Financial Action Task Force (FATF) and Moneyval. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679
• Greece's securities treatment framework is shaped by European Court of Justice interpretations that are binding on Greek courts and regulators. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

Licensing Requirements

• No Greek national licensing regime has been identified specifically for crypto-asset service providers; entities must look to EU-level frameworks such as MiCA or the Markets in Financial Instruments Directive (MiFID) as transposed in Greece. EUR-Lex — Access to European Union law — choose your language
• Investment firms providing services in or into Greece require authorisation under MiFID, as implemented through Greek law, with the HCMC as the competent authority. COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014
• No entities have been licensed in Greece under a dedicated crypto-asset securities framework, as such a framework does not exist at the national level. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex
• Capital requirements for investment firms follow EU regulations as applied by the HCMC; the specific minimum capital thresholds are defined by MiFID II and the Capital Requirements Regulation (CRR), but no crypto-specific capital requirements exist in the provided sources. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679
• Application for authorisation as an investment firm must be submitted to the HCMC, which assesses compliance with MiFID requirements; no crypto-specific authorisation pathway has been documented in the provided sources. EUR-Lex - 32015D1092 - EN - EUR-Lex
• The Greek government has engaged in financial sector interventions, such as the recapitalisation of Alpha Bank through the Hellenic Financial Stability Fund (HFSF), which demonstrates the state's role in financial stability oversight but does not constitute a crypto licensing framework. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex

AML/KYC Requirements

• Greece, as an EU member state and FATF member, applies the EU Anti-Money Laundering Directive (AMLD) framework, transposed into Greek law, which requires customer due diligence (CDD), enhanced due diligence (EDD) for high-risk situations, and suspicious transaction reporting (STR) to the Greek Financial Intelligence Unit. EUR-Lex - 52012XC1121(05) - EN - EUR-Lex
• The Bank of Greece has historically exercised authority over capital movements and foreign exchange transactions, including requirements for authorisation of repatriation of proceeds from securities, which may extend to financial monitoring obligations. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex
• Record retention requirements under Greek AML law follow the EU AMLD framework, requiring records of transactions and customer identification to be retained for the statutorily defined period, though the specific duration is not stated in the provided sources. EUR-Lex — Access to European Union law — choose your language
• Beneficial ownership transparency and PEP (politically exposed persons) screening requirements in Greece derive from the EU AMLD framework, though no Greece-specific implementing circular is identified in the provided sources. COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014

Enforcement Actions

• No Greek-specific enforcement actions against crypto-asset businesses under securities laws are documented in the provided sources. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex
• In Case C-329/03, the Bank of Greece was ordered by the Court of Appeal of Athens on 27 July 2001 to indemnify Banque Artesia for damages suffered due to the Bank of Greece's refusal to authorise repatriation of proceeds from liquidation of securities, a refusal that the ECJ found contrary to the First Directive. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex
• The European Commission initiated proceedings under Article 108(2) TFEU (State aid SA.34823 (2012/C)) concerning the recapitalisation of Alpha Bank by the Hellenic Financial Stability Fund, with the Commission expressing doubts about the appropriateness, necessity, and proportionality of the aid, though the measure was temporarily approved as rescue aid. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex
• The European Commission notified Greece on 27 July 2012 of the initiation of the State aid procedure regarding Alpha Bank recapitalisation, inviting comments from interested parties within one month of publication. C_2012357EN.01003601.xml - EUR-Lex

Tax Treatment

• No tax guidance has been issued for virtual assets in the provided sources.
• The provided sources contain no information on how crypto gains are taxed in Greece, whether as income tax, capital gains tax, or VAT treatment. EUR-Lex — Access to European Union law — choose your language
• The securities classification in Case C-329/03 concerned capital movement rules, not tax treatment, and therefore provides no basis for determining Greek tax treatment of crypto gains. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex

Key Gaps & Risks

• Greece lacks a national framework specifically addressing the securities treatment of crypto-assets; no Greek law, regulation, or official guidance has been identified in the provided sources that classifies tokens as securities or establishes a registration pathway. EUR-Lex - 62017CC0493 - EN - EUR-Lex
• The regulatory framework for crypto-assets in Greece is fragmented between EU-level regulations and national financial supervision, creating uncertainty about which authority has jurisdiction for specific token classifications. EUR-Lex - 32015D1092 - EN - EUR-Lex
• The absence of Greek-specific guidance on whether crypto-assets qualify as "securities dealt in on a stock exchange" under the First Directive's classification, as interpreted in Case C-329/03, leaves significant interpretive risk for issuers and investors. Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex
• Businesses face the risk that Greek authorities may apply the existing securities classification framework analogously to crypto-assets, potentially triggering MiFID authorisation requirements without clear transitional provisions. EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679
• The practical reality is that a crypto business operating in Greece faces regulatory ambiguity, with no clear national authority guidance on token classification, no dedicated licensing pathway, and no Greek-specific tax treatment confirmed in the provided sources. EUR-Lex - 52012XC1121(05) - EN - EUR-Lex
• The provided sources are insufficient to establish the current (2026) Greek position on crypto securities treatment; the most recent substantive Greek-specific materials concern state aid and banking recapitalisation, not crypto regulation. EUR-Lex - 52012XC1120(07) - EN - EUR-Lex

Sources

• EUR-Lex — Access to European Union law — choose your language
• EUR-Lex - 52012XC1120(07) - EN - EUR-Lex
• EUR-Lex - 52012XC1121(05) - EN - EUR-Lex
• EUR-Lex - 62017CC0493 - EN - EUR-Lex
• EUROPEAN SECURITIES AND MARKETS AUTHORITY DECISION (EU) 2019/679
• 62003CC0329_EN
• C_2012357EN.01003601.xml - EUR-Lex
• Acquisition of bonds dealt in on a stock exchange ... - EUR-Lex
• EUR-Lex - 32015D1092 - EN - EUR-Lex
• COMMISSION DECISION (EU) 2015/ 1092 - of 23 July 2014