EU/EEA PassportingMiCA CASP authorisation

MiCA Crypto Licence in Greece

Greece is an HCMC-supervised MiCA CASP authorisation route for teams that want an EU home member state with Greek or Eastern Mediterranean positioning. It supports EU/EEA passporting planning, but the file still needs real substance, governance, AML, audit and banking readiness.

Processing time
From 6 months
Service price
19 700 EUR
Required share capital
From 50 000 EUR
State fee
Approx. 5,000 EUR
Annual supervision fee
Approx. 3,000 EUR
Banking difficulty
Medium to high
RegulatorHellenic Capital Market Commission (HCMC)

This page uses the supplied CSV facts only; current HCMC MiCA application requirements, local implementation, forms, fees and supervisory practice must be checked before client advice.

Regulatory status should be confirmed by local counsel before relying on this route.

What is Greece MiCA CASP authorisation?

Greece MiCA CASP authorisation is the HCMC-supervised route for crypto-asset service providers under the EU MiCA framework. It is a regulated EU operating route, not a fast offshore registration or a low-substance setup.

MICA
Jurisdiction
Greece
Regulator
Hellenic Capital Market Commission (HCMC)
Regime
MICA
Legal basis
Regime: MiCA CASP authorisation for crypto-asset service providers.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

EU/EEA passporting from Greece

Greece can support EU/EEA passporting for approved MiCA CASP services, but passporting is not a blanket claim. The applicant should connect target markets, services and notification steps to the authorised service scope.

  • Exchange

    Included

    Exchange operations fit within the permitted activities of this route.

  • Custody

    Included

    Custody is within scope; review controls requirements.

  • Brokerage

    Included

    Brokerage or OTC activity typically fits within scope.

  • Wallet provider

    Included

    Exchange operations fit within the permitted activities of this route.

  • EU market

    Included

    EU/EEA passporting available.

  • Startups

    Excluded

    High setup complexity means significant budget is needed.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Greece as a MiCA home member state

Greece fits teams that value an EU authorisation route with HCMC supervision, high regulatory reputation in the CSV snapshot and Greek or Eastern Mediterranean positioning. It is a high-complexity route, so the country choice should be justified by market access and operating substance rather than speed.

  • Regulatory track record

    Positive

    High

  • Banking access for crypto firms

    Negative

    Medium to high

  • Regulatory risk

    Caution

    Low to medium

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Greece MiCA application bottlenecks

The main bottlenecks are usually operating-model issues, not only document collection. Greece becomes harder when the applicant cannot defend service scope, substance, safeguarding, AML, governance, costs, timeline or banking assumptions.

  • Unclear CASP service perimeter or EU/EEA passporting plan

    High

  • Local staff or office model that does not support real operational control

    High

  • Weak custody, wallet, safeguarding, reconciliation or technology-resilience evidence

    High

  • Template AML, sanctions or travel-rule policies that do not match clients, tokens and fiat flows

    High

  • Banking, EMI, PI or PSP package prepared too late

    High

  • Payment, staking, DeFi or securities-like features added without perimeter analysis

    High

  • Timeline sold as exactly 6 months instead of from 6 months with regulator-question buffers

    High

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Activity fit for this route

Review which crypto activities fit within the scope of this route.

Exchange
Suitable

Exchange operations fit within the permitted activities of this route.

Custody
Suitable

Custody is within scope; review controls requirements.

Brokerage
Suitable

Brokerage or OTC activity typically fits within scope.

Wallet provider
Suitable

Exchange operations fit within the permitted activities of this route.

EU market
Suitable

EU/EEA passporting available.

Startups
Not suitable

High setup complexity means significant budget is needed.

Not sure if your model fits? Request a licensing assessment

Is Greece MiCA authorisation right for your project?

Best for

  • EU passporting and regulated CASP operations
  • EU/EEA market access

Not suitable for

  • Low-budget or fast offshore setup
  • Projects without a prepared banking strategy

Banking difficulty is high for this route. Prepare a banking strategy before committing to the Greece route.

Core requirements

Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.

Required share capitalFrom 50 000 EUR
Required
Local staffRequired
Required
Physical officeRequired
Required
AuditRequired
Required

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Local substance, office, audit and governance

The CSV facts mark local staff, physical office and audit as required. Treat these as operating obligations that affect HCMC confidence, banking readiness and maintenance cost, not as simple incorporation checklist items.

Local staff

Required

Required

At least one locally-accountable staff member or director is expected.

Physical office

Required

Required

A genuine office presence is expected, not a nominal registered address.

Audit

Required

Required

External audit is required for ongoing supervision compliance.

Planning notes

  • Define Greece-based decision-making, compliance ownership and reporting lines before submission.
  • Document outsourced group functions, board oversight, technology providers and incident escalation.
  • Budget share capital, state fee, annual supervision, audit, office, staff and ongoing compliance separately from the application service fee.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Service price (professional fees)Application preparation and professional services.
19 700 EUR EURFixed
State fee
Approx. 5,000 EURFrom
Annual supervision feeRecurring annual cost after authorisation.
Approx. 3,000 EURFrom
Required share capitalMust be held, not an expenditure.
From 50 000 EURFrom
High ongoing cost

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown — Greece

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Cost itemAmount
Service priceApplication preparation and professional services.€19,700
State fee€1
Required share capitalMust be held, not an expenditure.€50,000

Summary

One-off costs
€69,701
Annual (year 1)
€0
Total year 1
€69,701

Adjust to convert to your base currency.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Application process

The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Greece — From 6 months.

Total timelineFrom 6 months

  1. Pre-assessment and scope review

    1–3 weeks

    Define the activity scope, governance model and target markets before formal preparation.

  2. Company setup in Greece

    2–6 weeks

    Establish legal entity, appoint local staff and set up local operating structure.

  3. Documentation and compliance packBottleneck risk

    3–8 weeks

    Prepare AML/CFT policies, governance documents, controls framework and application materials.

  4. Application submission to Hellenic Capital Market Commission

    1–2 weeks

    Submit complete application with all required documentation.

  5. Regulator reviewBottleneck risk

    From 6 months

    Regulator reviews the application. May request clarifications. Incomplete files extend this phase.

    Depends on: File quality and completeness

  6. Authorisation or registration confirmation

    1–4 weeks

    Regulator confirms authorisation or registration. Commence operations.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

What can delay or increase cost

These factors are most likely to affect timelines and budgets for this route.

High setup complexity
High

Setup complexity is rated high for Greece. Company setup, governance and documentation take longer than average.

Likely impactAdd 4–8 weeks to the preparation phase.
MitigationStart company setup and governance planning immediately after scope confirmation.
Banking difficulty
High

Banking difficulty is rated high. Opening accounts for crypto businesses in Greece requires extensive documentation.

Likely impactBanking can delay or block operations for 3–6 months after authorisation.
MitigationIdentify and pre-qualify banking partners before submitting the application.
High maintenance cost
Medium

Ongoing supervision, audit and compliance costs are above average. Budget for these separately from the application fee.

Likely impactRecurring annual cost significantly above the one-time service price.
MitigationModel annual compliance costs before committing to this route.
Application completeness
Medium

Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.

Likely impactEach regulator query adds 2–6 weeks to the review phase.
MitigationUse a structured compliance pack. Review file completeness before submission.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Banking and PSP readiness in Greece

The CSV profile rates crypto banking as medium to high and PSP availability as medium. Greece can support a regulated EU narrative, but banks, EMIs, PIs and PSPs will still run their own onboarding and risk reviews.

Banking difficulty
High

Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.

Medium PSP availability
Medium

Reflects availability of payment service providers willing to onboard crypto-licensed entities.

A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.

Preparation checklist

  • Prepare ownership, source-of-funds, flow-of-funds, client geography, token admission and transaction monitoring evidence early.
  • Explain fiat settlement, safeguarding, reconciliation and custody flows before approaching banks or PSPs.
  • Expect stronger due diligence for exchange, custody, cross-border fiat flows and higher-risk client geographies.

When Greece MiCA is not the right route

Greece should not be selected only because it provides an EU MiCA route. It is a high-complexity CASP authorisation path with local substance, audit, capital and ongoing maintenance expectations.

  • The project primarily wants a low-budget or fast offshore setup.

  • The team cannot fund local staff, physical office, audit, share capital and recurring supervision fees.

  • The target customers are outside the EU/EEA and passporting has limited commercial value.

  • The product is mainly DeFi, staking, payment, e-money token or securities-token related and needs a different regulatory analysis first.

Consider instead

  • Cyprus MICA — Nearby EU financial-services route with CySEC supervision.
  • Bulgaria MICA — Regional EU comparison route with a similar service-fee profile.
  • Malta MICA — Established EU crypto supervision profile with MFSA experience.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Business model fit — Greece

Assess how well this route covers your planned activities.

Fit score

Good fit
4/6
Partial fit
2/6
Poor fit
0/6

Greece is a strong fit for your activity profile

This route covers your key activities. Proceed with detailed legal review.

HCMC profile for crypto firms

Regulatory authority · Greece

Hellenic Capital Market Commission (HCMC)

HCMC should be approached as a financial-services supervisor reviewing a regulated operating model. A credible Greece MiCA file needs precise service scope, accountable management, local substance, AML and sanctions controls, safeguarding logic, technology resilience and banking preparation.

Likely areas of scrutiny
  • The application should show who controls Greek compliance, risk, AML, technology oversight and regulator-facing decisions.
  • Exchange and custody models need stronger evidence than a narrow brokerage, wallet or advisory model.
  • Current HCMC practice and Greek MiCA implementation should be checked before relying on filing mechanics, fees or timing.
Regulatory reputation
High

Strong international recognition and established supervision track record.

Setup complexity
High

Reflects documentation depth, governance requirements and expected review friction.

Regulatory risk
Medium

Reflects likelihood of delays, additional information requests or policy uncertainty.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Compliance documentation

Most crypto licensing routes require a documented compliance framework before submission, not only after approval.

  • Required
    AML/CFT policy and risk assessmentDocument your customer risk model and control framework.
  • Required
    Customer due diligence (CDD) procedures
  • Required
    Enhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
  • Required
    Transaction monitoring system and rules
  • Required
    Sanctions screening procedures
  • Required
    Suspicious activity reporting (SAR) process
  • Required
    MLRO / Compliance officer appointmentLocal accountability may be required.
  • Recommended
    Board-approved governance charter
  • Conditional
    Outsourcing policy and monitoringRequired if functions are outsourced.
  • Recommended
    ICT / cybersecurity policy
  • Required
    Complaints handling procedure
  • Required
    Annual external audit engagementRequired for ongoing supervision compliance.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Documents to prepare

Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.

0 / 12 required
Required
Recommended
Depends on scope

Corporate documents

AML and compliance

Operational

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Risk assessment

Main risk dimensions for the Greece route.

Banking difficulty
High

Route risk rating — banking difficulty: Medium to high. Authorisation does not guarantee bank account opening.

Mitigation: Start banking outreach and compliance preparation before the application.

Setup complexity
High

Route risk rating — setup complexity: High.

Maintenance cost
High

Route risk rating — maintenance cost: High. Budget for ongoing compliance, fees and supervision separately.

Regulatory reputation
High

Route risk rating — regulatory reputation: High.

Regulatory risk
Medium

Route risk rating — regulatory risk: Low to medium. Weak compliance, vague scope or insufficient controls increase review risk.

Mitigation: Prepare an evidence-based compliance file before submission.

This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.

Greece vs other MiCA countries

Compare Greece with Cyprus for a nearby EU financial-services route, Bulgaria for a regional EU cost comparison, Malta for a more established crypto supervision profile, and Germany when premium regulator reputation matters more than cost.

Current

Greece

MICA

Price
19 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium to high
Reputation
High

Cyprus

MICA

Price
17 000 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium to high
Reputation
Medium

+ Nearby EU financial-services route with CySEC supervision.

− Still requires local substance, audit, governance, AML and banking readiness.

View route

Bulgaria

MICA

Price
19 600 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium to high
Reputation
Medium

+ Regional EU comparison route with a similar service-fee profile.

− Current FSC implementation and filing practice still need source checking.

View route

Malta

MICA

Price
20 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium to high
Reputation
High

+ Established EU crypto supervision profile with MFSA experience.

− Usually a heavier route and not a low-substance alternative.

View route

Germany

MICA

Price
28 200 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
High
Reputation
Very high

+ Premium reputation route for teams prioritising BaFin signalling.

− Higher cost, banking difficulty and application burden than Greece in the CSV snapshot.

View route

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Greece vs other MiCA jurisdictions

Compare key parameters across MiCA-authorised jurisdictions.

Sort by:
GreeceCurrent
Price19 700 EUR
TimelineFrom 6 months
BankingMedium to high
ReputationHigh
Cyprus
Price17 000 EUR
TimelineFrom 6 months
BankingMedium to high
ReputationMedium
Bulgaria
Price19 600 EUR
TimelineFrom 6 months
BankingMedium to high
ReputationMedium
Malta
Price20 700 EUR
TimelineFrom 6 months
BankingMedium to high
ReputationHigh

Check your readiness for Greece MiCA authorisation

Documented AML/CFT policies, risk assessment, compliance officer.

Share capital

From 50 000 EUR minimum capital required.

AML/CFT framework

Documented AML/CFT policies, risk assessment, compliance officer.

Governance structure

Board, management, accountability chain defined.

Banking preparation

Banking strategy and identified partners.

Local substance plan

Local staff and office in Greece.

Readiness status

Answer the criteria on the left to see your readiness status.

Frequently asked questions

No. Greece is positioned in the CSV snapshot as a high-complexity route with local staff, physical office, audit, share capital from 50 000 EUR, an approximate 5,000 EUR state fee and an approximate 3,000 EUR annual supervision fee.

It can support EU/EEA passporting for approved CASP services, subject to the required notification process. Passporting should be tied to the authorised service scope, target markets and operating model, not treated as automatic coverage for every future activity.

Exchange, custody, brokerage and wallet services can fit the MiCA CASP route when the operating model and controls are properly documented. Advisory, staking and payment-adjacent models need scope review, while DeFi is not a clean standard CASP fit without separate legal analysis.

The main friction points are unclear CASP service scope, weak local substance, generic AML policies, underdeveloped safeguarding or custody controls, late banking preparation and payment, staking or DeFi features that have not been scoped legally.

No. Banks, EMIs, PIs and PSPs still assess ownership, source of funds, client geography, fiat flows, token policy, AML controls, safeguarding and risk appetite. Banking and PSP preparation should start before submission.

The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.

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