Cryptocurrency activity in Greece is legal, but the regulatory framework is still evolving, with no comprehensive national crypto law enacted as of 2025–2026; instead, EU-level regulations (MiCA, MiFID II) apply directly and are supplemented by Greek administrative guidance EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The Hellenic Capital Market Commission (HCMC, also known as Epitropi Kefalaiagoras) is the primary regulator for securities and digital assets that qualify as financial instruments, while the Bank of Greece oversees payment-related crypto activities EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

Licensing is required for investment services involving digital assets that qualify as securities under the MiFID II framework, with no standalone "crypto license" issued by Greek authorities as of the latest available data Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

No Greek entity has been publicly confirmed as holding a dedicated crypto-asset service provider license under national law, as the market awaits full implementation of the EU's Markets in Crypto-Assets Regulation (MiCA) framework

The practical reality is that firms must navigate a fragmented regime applying existing securities laws, AML rules, and EU directives until MiCA becomes fully applicable, creating compliance uncertainty and higher operational risk L_2017174EN.01002201.xml

The Hellenic Capital Market Commission (HCMC) is the competent authority responsible for supervising securities markets, investment services, and collective investment schemes in Greece, operating under the Ministry of Finance EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The HCMC derives its powers from Greek securities legislation implementing EU directives, including Law 3606/2007 on investment services and regulated markets, which transposes MiFID I, and subsequent amendments transposing MiFID II (Directive 2014/65/EU) Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

Directive 2001/34/EC on the admission of securities to official stock exchange listing and on information to be published on those securities is a core piece of the EU legal framework that Greece applies, as confirmed by the Greek Council of State (Symvoulio tis Epikrateias) in its reference to the Court of Justice of the European Union EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The Bank of Greece is the central bank and, under EU law, participates in the European System of Central Banks (ESCB); it has been consulted on matters related to financial regulations including crypto-assets, per the European Central Bank's opinion procedures EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

Greece is a member of the Financial Action Task Force (FATF) through its EU membership and is also a member of the Council of Europe's MONEYVAL committee, which conducts mutual evaluations of anti-money laundering frameworks L_2017174EN.01002201.xml

The Greek legal framework for securities integrates EU regulations directly, including the Prospectus Regulation (EU) 2017/1129, the Market Abuse Regulation (EU) 596/2014, and the Transparency Directive, all of which are directly applicable in Greece L_2017174EN.01002201.xml

The EU's Markets in Crypto-Assets Regulation (MiCA) and the DORA regulation apply directly in Greece as EU regulations, though their phase-in dates extend beyond the current reporting period, and the HCMC is designated as a competent authority for supervision L_2017174EN.01002201.xml

The Securities and Markets Stakeholder Group and the European Securities and Markets Authority (ESMA) framework underpin Greece's national supervision, with the HCMC participating in ESMA's supervisory convergence activities C_2008280EN.01000501.xml - EUR-Lex - European Union)

Greece's capital market law includes provisions on the operation of supervised entities, requiring them to maintain adequate organizational arrangements and to comply with conduct of business rules as set out in EU legislation Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The European Commission's 2020 Digital Finance Strategy and the accompanying action on crypto-assets position Greece as part of the EU-wide initiative to regulate digital finance, with national authorities expected to align supervisory practices accordingly IMMC.SWD(2020)208 final.ENG.xhtml.2_EN_autre_document_travail_service_part1_v3.docx

Investment firms in Greece that provide services in relation to digital assets qualifying as "financial instruments" must obtain authorization as an investment firm under MiFID II, which is transposed into Greek law via Law 4514/2018 and related implementing acts Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The HCMC grants investment firm licenses for activities including reception and transmission of orders, execution of orders on behalf of clients, dealing on own account, portfolio management, and investment advice, all of which could encompass crypto-assets structured as securities Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

Under MiFID II, the initial capital requirement for an investment firm is at least €730,000 for firms authorized to deal on own account or to execute orders, while firms only providing investment advice or reception and transmission of orders may have a lower threshold of €125,000, as per Annex II of the Directive Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

A minimum capital requirement of €50,000 applies to investment firms that are not authorized to hold client money or securities and do not deal on own account, in line with the Capital Requirements Regulation (CRR) Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The application process for authorization requires submission of a detailed program of operations, organizational structure, risk management policies, and information about shareholders and directors, to be reviewed by the HCMC within a statutory timeline (typically within six months of complete application) Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

Entities that operate a trading venue for crypto-assets that qualify as financial instruments may require authorization as a regulated market or multilateral trading facility (MTF) under MiFID II, subject to additional organizational and transparency requirements Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

For crypto-assets that do not qualify as financial instruments, the EU's MiCA regulation provides a separate licensing regime; however, as of the latest available information, Greece has not enacted national legislation designating a specific national license for MiCA-authorized CASPs, and the HCMC's existing licensing framework does not yet issue dedicated crypto-asset licenses L_2017174EN.01002201.xml

No Greek entity has been confirmed as having received a dedicated national crypto-asset service provider license, because the existing Greek legal framework lacks a bespoke crypto licensing category; firms operating in Greece typically do so under passporting rights from other EU member states or under investment firm authorizations EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

Structural requirements for licensed firms include having a board of directors with sufficient collective experience, a two-person management structure (or a single director with adequate safeguards), and the establishment of a compliance function, risk management function, and internal audit function Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The licensing timeline under Greek law, implementing MiFID II, provides for a maximum of six months from submission of a complete application for the HCMC to render a decision, with the possibility of a further three-month extension in complex cases Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The HCMC may impose additional prudential and conduct requirements on licensees operating in the digital asset space, including enhanced disclosure duties and notification requirements for new products or services L_2017174EN.01002201.xml

For entities seeking to admit crypto-asset securities to trading on a Greek regulated market, the issuer must publish a prospectus approved by the HCMC in accordance with the EU Prospectus Regulation, unless an exemption applies L_2017174EN.01002201.xml

The HCMC maintains the public registers of licensed investment firms and regulated markets, and these registers do not currently contain any entity licensed specifically for crypto-asset services under Greek national law, confirming the absence of a dedicated eco-license EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

Greek AML obligations for financial institutions, including investment firms and crypto-asset service providers, are primarily governed by Law 4557/2018, which transposes the EU's Fifth Anti-Money Laundering Directive (EU) 2018/843, as amended L_2017174EN.01002201.xml

Customer Due Diligence (CDD) measures must be applied when establishing a business relationship, when carrying out occasional transactions exceeding €15,000 (whether executed as a single transaction or several linked transactions), or when there is a suspicion of money laundering or terrorist financing L_2017174EN.01002201.xml

Enhanced Due Diligence (EDD) is required for high-risk customers, including politically exposed persons (PEPs), and for business relationships with persons from high-risk third countries as identified by the European Commission and the FATF L_2017174EN.01002201.xml

Obligated entities must report suspicious transactions to the Greek Financial Intelligence Unit (FIU), which operates within the Hellenic Authority for Combating Money Laundering, within three working days of establishing suspicion, and must refrain from executing the transaction until further instructions L_2017174EN.01002201.xml

Records of CDD measures and transaction documentation must be retained for at least five years after the end of the business relationship or after the date of the occasional transaction, and must be available to the FIU and supervisory authorities upon request L_2017174EN.01002201.xml

Beneficial ownership information must be collected and maintained for all legal entities and legal arrangements, and this information must be registered in the Greek Central Beneficial Ownership Register, with reporting obligations for entities subject to AML law L_2017174EN.01002201.xml

PEP screening is mandatory for all new and existing customers, with enhanced ongoing monitoring of business relationships involving PEPs, including the requirement to establish the source of wealth and source of funds for such relationships L_2017174EN.01002201.xml

The AML framework requires the appointment of a compliance officer at board level, the establishment of internal policies, controls, and procedures to mitigate money laundering and terrorist financing risks, and the provision of regular training to employees on AML obligations L_2017174EN.01002201.xml

Crypto-asset service providers and virtual asset exchange platforms are expressly classified as "obliged entities" under the EU AML framework, requiring them to register with the FIU and to comply with all applicable AML/CFT obligations L_2017174EN.01002201.xml

The HCMC, the Bank of Greece, and the Greek FIU share supervisory responsibilities for AML compliance among different categories of financial institutions, with the HCMC conducting inspections and imposing sanctions for AML non-compliance on entities it supervises L_2017174EN.01002201.xml

In the landmark case C-430/05, the Greek Capital Market Commission (Epitropi Kefalaiagoras) imposed fines on Dionik Anonimi Etaireia Emporias H/Y (Dionik AE) and its board member Ioannis Michail Pikoulas, following a reference by the Greek Council of State, for the publication of inaccurate information in listing particulars (prospectus) related to a capital increase, and the Court of Justice of the European Union held that national law may impose penalties on board members indiscriminately, regardless of whether they were named as responsible in the listing particulars EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The judgment in case C-430/05, delivered on 5 July 2007, confirmed that Member States have the power to choose appropriate penalties for inaccurate or misleading listing particulars, provided such penalties are proportionate to the gravity of the infringement, thereby endorsing the HCMC's enforcement approach in this matter EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The Greek Capital Market Commission's imposition of administrative fines in the Dionik AE case was scrutinized by the Court of Justice, which determined that the fines were compatible with Directive 2001/34/EC, Article 21, which requires listing particulars to contain information necessary for investors to make an informed assessment EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The penalties imposed by the HCMC in the Dionik AE case were upheld as proportionate under EU law principles, reinforcing the Greek regulator's authority to sanction issuers and their board members for securities disclosure violations EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

No specific enforcement actions directly targeting cryptocurrency businesses in Greece were identified in the regulatory sources reviewed for this period, reflecting the still-developing nature of Greek crypto regulation and the absence of a dedicated enforcement framework for such entities C_2008280EN.01000501.xml - EUR-Lex - European Union)

No tax guidance has been issued for virtual assets in Greece under the sources reviewed; the provided materials focus on securities regulation and do not contain specific Greek tax provisions applicable to cryptocurrency gains L_2015080EN.01004901.xml - EUR-Lex - European Union

The EU-wide VAT framework, as applied in Greece, follows the European Court of Justice ruling III in the Skatteverket v. David Hedqvist case regarding Bitcoin and other virtual currencies being exempt from VAT, though this ruling is not discussed in detail in the provided sources C_2012357EN.01003601.xml - EUR-Lex&from=ET)

Greek tax authorities have not published any official circular or decision specifically addressing the classification, valuation, or taxation of digital assets in the documentation reviewed, leaving taxpayers and businesses in a state of uncertainty C_2008280EN.01000501.xml - EUR-Lex - European Union)

Without specific Greek tax guidance, gains from crypto-asset trading may be treated either as capital gains subject to a flat rate or as business income subject to progressive rates, but this determination cannot be confirmed from the provided sources and should be verified with the Independent Authority for Public Revenue (AADE) IMMC.SWD(2020)208 final.ENG.xhtml.2_EN_autre_document_travail_service_part1_v3.docx

The most significant regulatory gap is the complete absence of a dedicated Greek national law for crypto-asset service providers, leaving firms to rely solely on EU-level rules that are still being phased in and on interpretations of existing securities laws L_2017174EN.01002201.xml

Practical uncertainty surrounds the classification of digital assets as "financial instruments" under MiFID II, given that the HCMC has not issued public guidelines specifically addressing when crypto-assets qualify as transferable securities under Greek law Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

The lack of a national regulatory sandbox or formal guidance from the HCMC for fintech and digital asset innovation creates a barrier to entry for crypto businesses, as they cannot obtain certainty on regulatory expectations without applying for a license that may not exist for their business model C_2008280EN.01000501.xml - EUR-Lex - European Union)

There is a discrepancy between the paper law (EU directives and regulations directly applicable) and the practical reality of supervision, as the HCMC's operational capacity for overseeing crypto-assets remains underdeveloped compared to traditional securities enforcement, increasing risk of regulatory gaps in investor protection EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

Businesses face the risk of operating without adequate authorization, as the HCMC may interpret some crypto-asset activities as falling within existing regulated activities (e.g., investment advice involving crypto-securities), leading to potential fines, injunctions, or criminal sanctions for unlicensed activity EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

The absence of smooth tax guidance for digital assets creates financial reporting risks, as companies may face double taxation or penalties for incorrect VAT treatment, particularly since the Greek Independent Authority for Public Revenue has not issued any binding guidance on crypto-transactions IMMC.SWD(2020)208 final.ENG.xhtml.2_EN_autre_document_travail_service_part1_v3.docx

Legal uncertainty under Greek contract law regarding the enforceability of smart contracts and blockchain-based agreements remains unresolved, as no Greek judicial precedent or legislative act has been identified that addresses the legal status of smart contracts in securities transactions C_2012357EN.01003601.xml - EUR-Lex&from=ET)

Market participants in Greece face considerable uncertainty regarding cross-border and passporting rights for crypto-asset services, as the HCMC's guidance does not clearly address the notification procedures for EU entities wishing to operate in Greece with crypto-assets that are not financial instruments EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

A critical risk is the potential for regulatory arbitrage, as some Greek firms may seek authorization from other EU/EEA regulators to provide crypto-services, relying on the absence of a defined Greek regime, which could result in the HCMC taking supervisory action against such entities for operating without proper Greek authorization C_2008280EN.01000501.xml - EUR-Lex - European Union)

EUR-Lex - 62005CJ0430_SUM - EN - EUR-Lex

Directive - 2014/65 - EN - mifid ii - EUR-Lex - Europa.eu

C_2008280EN.01000501.xml - EUR-Lex - European Union)

EN ECB-PUBLIC OPINION OF THE EUROPEAN CENTRAL BANK of 25 August 2022

L_2015080EN.01004901.xml - EUR-Lex - European Union

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 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)

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

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

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

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)

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

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&from=ET)

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

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 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)

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)

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