Cryptoassets Regulatory Intelligence cryptoassets.gi
GR v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 0 failing13 sources retrieved model claude-sonnet-5 · 2026-08-05

Greece

GR schema crypto-v2.0.0 trajectory: not yet assessedregulatedoverlaps: FIM, WPM

Last updated · 9 categories · 22 sourced findings · 36 sources in the cumulative register

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Law made at European Economic Area (Bloc) level that applies in Greece is covered once, on the European Economic Area (Bloc) page. This page covers Greece’s own layer: implementation, national authorities, national options and local enforcement.

Jurisdiction lead brief

Latest update · 18 October 2026

Lead Signal

Greece's crypto-asset licensing perimeter moved from a dormant transitional posture to an operative one within a single calendar year. The national VASP grandfathering period ran to 31 December 2025, shorter than the eighteen-month maximum MiCA permits, ahead of the EU-wide transitional window closing on 1 July 2026. The first MiCA crypto-asset service provider authorisations in Greece were issued on 22 July 2026, and four Greek-linked entities, BCash, Xenios Blockchain Group, Capital Wallet Greece and Piraeus Bank, appeared on the ESMA MiCA register on 29 September 2026. Piraeus Bank's listing sits under the Bank of Greece as competent authority rather than the Hellenic Capital Market Commission, reflecting Greece's division of MiCA oversight between the HCMC for crypto-asset service providers generally and the Bank of Greece for banking-linked and payment-token aspects. This activation sequence, compressed into a few months, signals that Greece's crypto licensing regime has moved from legal framework to operating reality.

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Greece implements the EU Markets in Crypto-Assets Regulation (MiCAR) directly as an EU Regulation, with national implementing measures enacted via Law 5193/2025 on the Enhancement of the Capital Market, which assigns MiCAR competences to the Hellenic Capital Market Commission (HCMC) and the Bank of Greece. HCMC is the notified National Competent Authority for MiCAR Titles II and VI (white papers/offers and market abuse), while the Bank of Greece is the prudential supervisor and licensing authority for credit institutions, e-money institutions and payment institutions seeking to issue ARTs/EMTs or operate as CASPs. The pre-MiCA transitional (grandfathering) regime under Article 143(3) MiCA ended 1 July 2026, and Greece's most prominent applicant (Binance) withdrew its HCMC licence application shortly before that deadline amid reported regulatory concerns, illustrating live implementation friction.

Standing sub-brief · as of 25 August 2026374 words · last cycle 2026-10-18

Crypto Licensing

Greece's crypto licensing regime is legally in force through MiCAR as implemented nationally by Law 5193/2025, but this cycle surfaces two Challenger-verified factual corrections that change the understood timeline materially. The Hellenic Capital Market Commission (HCMC) is Greece's National Competent Authority notified to ESMA for MiCAR Titles II and VI, covering crypto-asset white papers, public offers and market abuse -- a Confirmed, T1-sourced fact unaffected by this cycle's corrections. The Bank of Greece is separately entrusted with prudential supervision and licensing of credit institutions, e-money institutions and payment institutions that issue e-money tokens (EMTs) or asset-referenced tokens (ARTs), or that operate as crypto-asset service providers (CASPs), with power to impose administrative measures or penalties for breaches. That competence-allocation claim, along with the claim that Law 5193/2025 itself establishes these national implementing measures, rests solely on a single T2 Bank of Greece speech reported via BIS rather than the primary statutory text or a Government Gazette citation, and both have been downgraded from Confirmed to Probable pending stronger sourcing. The effective date of Law 5193/2025 has also been corrected: the law was passed by the Hellenic Parliament on 10 April 2025, not on 1 January 2025 as originally asserted. Separately, Greece's Article 143(3) grandfathering (transitional) period ran on a shortened 12-month national timeline from 30 December 2024, giving previously-registered entities a national deadline of roughly 30 December 2025 -- materially earlier than the EU-wide 18-month/1 July 2026 maximum some other Member States retained. Against this backdrop, Binance withdrew its MiCA licence application with the HCMC in June 2026, days before a reported deadline, amid concerns said to have been raised by Greek, Irish and Latvian regulators about the exchange's past legal issues and corporate structure -- a non-normative but material signal that Greek authorisation practice, though legally settled, remains operationally unsettled.

Periodic update · new data 2026-10-18

Crypto Licensing

Greece's national transitional regime for crypto-asset service providers set a twelve-month grandfathering window running to 31 December 2025, a shorter period than the eighteen months MiCA's Article 143(3) permits member states to allow. This domestic choice meant Greek-based crypto firms faced an earlier deadline to secure full MiCA authorisation than firms in jurisdictions that used the full transitional allowance, ahead of the EU-wide transitional window closing on 1 July 2026.

The practical effect of that compressed timeline became visible this period: the first MiCA crypto-asset service provider authorisations in Greece were issued on 22 July 2026, and by 29 September 2026 four Greek-linked entities, BCash, Xenios Blockchain Group, Capital Wallet Greece and Piraeus Bank, had appeared on the ESMA MiCA register. The Hellenic Capital Market Commission is the competent authority for the CASP authorisations generally, while Piraeus Bank's entry sits under the Bank of Greece, reflecting a split in supervisory responsibility between the two bodies for banking-linked and payment-token-adjacent activity versus standalone crypto-asset services.

Underpinning this perimeter, Law 5193/2025 Part C implements the penalty regime required by MiCA Article 111 at the national level, applying criminal and administrative penalties to unlicensed crypto-asset service activity. The exact fine schedule, including the administrative maxima, has not been located in the available evidence and remains an open item. Taken together, Greece's licensing perimeter moved within a single year from a dormant, pre-authorisation transitional state to one with live authorisations, a functioning national competent-authority split, and an enforceable, if not yet fully quantified, penalty backstop for unlicensed activity.

Outlook

The principal item to watch is confirmation of the exact administrative and criminal fine maxima under Law 5193/2025 Part C, which has not yet been located. Continued additions to the ESMA MiCA register of further Greek-linked or Greek-authorised entities would be the next visible indicator of the licensing perimeter's maturation.

3 earlier distinct update(s)
Periodic update · new data 2026-10-11

Crypto Licensing

Greece's domestic CASP licensing regime under MiCA, as implemented via Law 5193/2025, moved from a dormant to an active state this cycle. The transitional period for prior national VASP registrations closed, reported as 1 July 2026 by the primary source reviewed, though a conflicting secondary source instead states 30 December 2025; this discrepancy has not been resolved against the underlying statute and is carried as disputed. In the period following, the Hellenic Capital Market Commission authorised Capital Wallet, BCASH and Xenios Blockchain Group as CASPs between 30 June and 7 August 2026, and the Bank of Greece authorised Piraeus Bank; all four appeared on ESMA's MiCA register together on 24 September 2026. Binance withdrew its own Greek CASP application on 24 June 2026, ahead of any formal HCMC decision, with a disputed and uncorroborated allegation of ECB involvement attached to that withdrawal in one source.

Outlook

The clearest open item is resolving the conflicting transitional-deadline dates against the primary text of Law 5193/2025. Beyond that, whether further domestic CASP authorisations follow this initial wave, and whether Binance pursues a renewed application, are the two developments most likely to move this module's status next.

Periodic update · new data 2026-10-05

Crypto Licensing

Greece's crypto-licensing regime is now live in a domestic sense, not merely a passported one. The Hellenic Capital Market Commission administers authorisation under Markets in Crypto-Assets Regulation Article 59, implemented nationally through Law 5193/2025, enacted 11 April 2025. The national transitional registration period that had permitted pre-existing virtual-asset service providers to continue operating without a full Markets in Crypto-Assets Regulation authorisation closed 1 July 2026; from that date, unauthorised providers lacking either a domestic authorisation or a valid passported licence from another member state are required to have wound down activity targeting the Greek market. This is a binding, in-force requirement rather than a prospective one.

Between 30 June and 7 August 2026, the Hellenic Capital Market Commission authorised three crypto-asset service providers: BCash, Xenios Blockchain Group, and Capital Wallet Greece. These, together with Piraeus Bank's separate 7 August 2026 authorisation from the Bank of Greece as an asset-referenced and e-money token issuer, appeared on the European Securities and Markets Authority's Markets in Crypto-Assets Regulation register on 24 September 2026. This closed a gap of roughly fifteen months during which Greece had no domestically authorised crypto-asset service provider, notwithstanding the regulation's bloc-wide force. During that interval, foreign firms holding passported licences from other member states served Greek customers, illustrating in practice how the Markets in Crypto-Assets Regulation's passporting mechanism substitutes for domestic authorisation capacity when the latter lags.

A notable adjacent development is Binance's withdrawal of its own Greek application on 24 June 2026, six days before the first domestic approval. An allegation that the European Central Bank was involved in prompting that withdrawal has been reported but not independently verified this cycle; the finding is accordingly held at uncertain confidence, and the withdrawal itself is recorded as a fact distinct from the unverified explanation offered for it.

The traffic-light assessment for this module is amber rather than green, reflecting that while the core authorisation regime is confirmed live and active, the specific transposition detail of Markets in Crypto-Assets Regulation Article 111's enforcement-penalty provisions into Greek domestic law has not been independently located this cycle. This is a sourcing gap rather than a substantive finding of absence, and it should be read as such.

Outlook

The principal open question is whether the initial cohort of four domestic authorisations will be followed by a steady pipeline of further approvals, which would confirm that Greece's authorisation backlog has been structurally cleared rather than addressed only in a narrow first tranche. Corroboration or retraction of the Binance ECB-involvement allegation would also clarify how that specific episode should be read. Greece's domestic Article 111 enforcement-penalty framework remains a standing research gap for subsequent cycles.

Periodic update · new data 2026-09-22

Crypto Licensing

The Hellenic Capital Market Commission requires Crypto-Asset Service Provider authorisation under the EU's Markets in Crypto-Assets Regulation, as implemented via Law 5193/2025, for the provision of crypto-asset services in Greece. This is a directly applicable EU regulatory requirement with an operating national authorisation procedure. The EU-wide MiCA transitional period, under which prior national virtual-asset-service-provider registrations could substitute for full MiCA authorisation, closed on 1 July 2026; Greek Hellenic-Capital-Market-Commission-registered virtual-asset-service-providers were required to submit full applications by 30 December 2025 to preserve grandfathering.

On 22 July 2026, the Hellenic Capital Market Commission granted Greece's first two Crypto-Asset Service Provider authorisations, to Capital Wallet Greece and Xenios Blockchain Group, under the Commission's Decision 8/1059 authorisation procedure of 30 July 2025 — the first live grants under the national authorisation track and confirmation that the procedure is now fully operative rather than merely established in principle.

Separately, Binance has stated that it was denied a Greek MiCA authorisation ahead of the 1 July 2026 transitional-period close, notwithstanding reports that its application was found compliant on technical review. This finding rests solely on Binance's own public statement as relayed by secondary press; the Hellenic Capital Market Commission has not independently confirmed the denial, and it is accordingly treated as a lower-confidence, unconfirmed episode rather than an established fact about Commission gatekeeping practice.

Outlook

Direct Hellenic Capital Market Commission confirmation or denial of the Binance authorisation outcome is the key data point to watch next cycle. The pace and pattern of further Crypto-Asset Service Provider authorisations will indicate how quickly the post-transitional Greek MiCA regime is being operationalised.

Sources and findings (5)
  1. T1 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — Greece's 2025 Law 5193/2025 on the Enhancement of the Capital Market establishes the national measures implementing MiCAR, assigning respective competences and powers to the Hellenic Capital Market Commission and the Bank of Greece.retrieved M5bindingin force
  2. T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — HCMC is the Greek National Competent Authority notified to ESMA for MiCAR Titles II and VI, covering crypto-asset white papers/public offers and market abuse provisions.retrieved M5bindingin force
  3. T1 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — The Bank of Greece is entrusted with prudential supervision and licensing of credit institutions, electronic money institutions and payment institutions that plan to issue e-money tokens (EMTs) and/or asset-referenced tokens (ARTs) or to operate as crypto-asset service providers (CASPs), and is empowered to impose administrative measures or penalties for breaches.retrieved M5bindingin force
  4. T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Entities providing crypto-asset services under applicable Greek/national law before 30 December 2024 could continue operating under MiCA's Article 143(3) grandfathering clause until 1 July 2026 or until granted/refused MiCA authorisation, whichever occurred sooner.retrieved M4bindingin force
  5. T3 · CoinDeskCoinDesk — Binance withdrew its MiCA licence application with the Hellenic Capital Market Commission days before the 1 July 2026 deadline after Greek, Irish and Latvian regulators reportedly raised concerns about the exchange's past legal issues and corporate structure.retrieved M3non-binding

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Greece applies the MiCAR taxonomy directly: asset-referenced tokens (ARTs), e-money tokens (EMTs), and 'other' crypto-assets (utility tokens) are distinguished per Titles III, IV and II respectively. Crypto-assets qualifying as MiFID II financial instruments, deposits, funds, insurance/pension products or securitisation positions fall outside MiCAR scope entirely and remain subject to existing Greek securities/banking law administered by HCMC/Bank of Greece. NFTs are excluded from MiCAR scope under specified conditions (uniqueness/non-fungibility tests), though ESMA guidance flags that misclassified 'NFT-like' fractionalised or serially-issued items may fall back into scope.

Standing sub-brief · as of 25 August 2026223 words · last cycle 2026-08-25

Token Classification

Greece's token classification regime follows the harmonised EU MiCAR taxonomy with no material change this cycle. MiCAR excludes from its scope crypto-assets that qualify as financial instruments, deposits (including structured deposits), funds (except where they qualify as e-money tokens), securitisation positions, insurance products, pension products, or pan-European personal pension products, per ESMA's final guidelines on the qualification of crypto-assets as financial instruments. Non-fungible tokens are likewise excluded from MiCA scope under the uniqueness and non-fungibility conditions set out in Recitals 10-11 of MiCAR and related ESMA guidance, though fractionalised or serially-issued 'NFT-like' items may fall back into scope where those conditions are not met. On the e-money token side, the Bank of Greece supervises and licenses credit institutions, e-money institutions and payment institutions intending to issue e-money tokens and/or asset-referenced tokens -- a materiality-5, binding claim that shares the same T2-only sourcing pattern flagged elsewhere in this cycle's licensing claims, though it was not itself named in the specific Challenger sourcing flag raised against sibling claims.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (3)
  1. T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — MiCAR does not apply to crypto-assets that qualify as financial instruments, deposits (including structured deposits), funds (except where they qualify as e-money tokens), securitisation positions, insurance products, pension products, or PEPPs.retrieved M4bindingin force
  2. T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Non-Fungible Tokens (NFTs) are outside the scope of MiCA under certain conditions related to uniqueness and non-fungibility, as set out in Recitals 10-11 of MiCA and clarified by ESMA guidelines.retrieved M3bindingin force
  3. T1 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — The Bank of Greece supervises and licenses credit institutions, e-money institutions and payment institutions intending to issue e-money tokens (EMTs) and/or asset-referenced tokens (ARTs).retrieved M5bindingin force

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MiCAR does not create a bespoke licensing category for staking, DeFi lending, DEX operation, mining, node operation or standalone validation; these activities are regulated only insofar as they are performed as a CASP-defined service (e.g., custody, execution, exchange) requiring HCMC/Bank of Greece authorisation. Pure protocol-level mining, node operation and non-custodial DeFi/DEX protocols currently fall outside MiCAR's direct licensing perimeter at EU level, and no Greece-specific supplementary regime for these activities has been identified.

Standing sub-brief · as of 25 August 2026185 words · last cycle 2026-08-25

On-Chain Activity Regime

Greece has no dedicated licensing or authorisation regime for staking, DeFi participation, mining or node operation outside MiCAR's CASP service categories, and this remains unchanged this cycle. The European Banking Authority and ESMA have jointly analysed EU crypto-asset market trends in DeFi adoption, lending, borrowing and staking business models under MiCAR Article 142, but this analysis has not produced binding policy recommendations. Separately, neither Greek Law 5193/2025 nor MiCAR itself addresses pure crypto-asset mining or node-operation activity as a distinct licensing or authorisation category -- a negative finding (an absence of a licensing category) rather than an evidentiary gap, and one that leaves protocol-level activity as an effective unregulated space within an otherwise regulated CASP perimeter.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (2)
  1. T1 · European Banking Authority (EBA)European Banking Authority (EBA) — EBA and ESMA jointly analysed EU crypto-asset market trends focusing on DeFi adoption, lending, borrowing and staking business models under MiCAR Article 142, without issuing binding policy recommendations specific to these activities.retrieved M3non-binding
  2. T1 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — No Greece-specific or MiCAR-level licensing obligation for pure crypto-asset mining or node operation activity has been identified; such activity is not addressed as a distinct authorisation category under Greek Law 5193/2025 or MiCAR.retrieved M2non-bindinga fact about the regime

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Stablecoin (ART/EMT) issuance in Greece is governed by MiCAR Titles III and IV, in force since 30 June 2024, with the Bank of Greece as the competent prudential authority for authorising and supervising credit institutions, e-money institutions and payment institutions issuing ARTs/EMTs, including imposing administrative penalties for breaches. Euro-denominated stablecoin issuance has picked up since early 2025 following MiCAR regulatory clarity, though USD-denominated stablecoins continue to dominate the broader EU market.

Standing sub-brief · as of 25 August 2026185 words · last cycle 2026-10-11

Stablecoin Regime

Greece's stablecoin (asset-referenced token and e-money token) regime remains fully in force under MiCAR Titles III-IV, with the Bank of Greece as the designated national supervisor. The Bank of Greece licenses credit institutions, e-money institutions and payment institutions to issue EMTs and/or ARTs, and holds power to impose administrative measures or penalties for MiCAR breaches -- a binding, materiality-5 claim whose confidence was recalibrated this cycle from Confirmed to Probable, reflecting that it rests on a single T2 central-bank speech rather than a primary statutory or Gazette source. MiCAR's systemic-risk provisions -- addressing financial stability, payment systems, monetary policy transmission and monetary sovereignty risks linked to crypto-assets purporting to maintain a stable value -- apply to ART/EMT issuers under Bank of Greece supervision, and this claim is Confirmed and unchanged this cycle.

Periodic update · new data 2026-10-11

Stablecoin Regime

Greece's stablecoin-adjacent regulatory architecture under MiCA assigns prudential supervision of asset-referenced-token and e-money-token issuers to the Bank of Greece, with the Hellenic Capital Market Commission handling CASP-side authorisation, per Law 5193/2025. This institutional split became visible in practice this cycle when Piraeus Bank, a mainstream Greek bank, was authorised by the Bank of Greece to appear in the MiCA register as of 24 September 2026, alongside three HCMC-authorised CASPs. This marks a notable entry of an established banking institution into MiCA-regulated crypto services in Greece, though no Greece-specific issuance or reserve rule-level finding beyond the supervisory-split structure itself has been located this cycle.

Outlook

What would sharpen this picture is a Greece-specific finding on reserve or issuance rules for ART/EMT issuers beyond the institutional supervisory split already sourced. Piraeus Bank's entry may also prompt further mainstream-bank participation in MiCA-regulated services, which would be the next signal to watch for.

1 earlier distinct update(s)
Periodic update · new data 2026-10-05

Stablecoin Regime

Greece's stablecoin supervisory architecture follows the Markets in Crypto-Assets Regulation's Title III and Title IV framework directly, with a clear statutory division of labour: the Hellenic Capital Market Commission oversees crypto-asset service provider authorisations generally, while the Bank of Greece carries prudential supervisory responsibility specifically for issuers of asset-referenced tokens and e-money tokens. This division had previously been a matter of statutory description rather than demonstrated practice in Greece; Piraeus Bank's authorisation by the Bank of Greece on 7 August 2026 is the first concrete domestic instance of that split being exercised, giving the arrangement an operative rather than purely textual existence.

The traffic-light assessment for this module is amber. The statutory division of supervisory labour is sourced and now has a concrete domestic instance behind it, but the specific reserve-asset, redemption, and custody rule detail that the Bank of Greece applies in its prudential oversight of asset-referenced and e-money token issuers has not been independently verified this cycle. The regime's existence and activation are confirmed; its granular operating detail is not yet established from Greece-specific sourcing.

This development should be read alongside the broader crypto-licensing activation this cycle, of which it forms a part: Piraeus Bank's authorisation was one of four entries appearing on the European Securities and Markets Authority's Markets in Crypto-Assets Regulation register on 24 September 2026, the others being Hellenic Capital Market Commission-authorised crypto-asset service providers. The stablecoin-specific element is narrower in scope than the overall licensing development but is analytically distinct: it is the first evidence that Greece's bifurcated supervisory model for payment-type tokens, as opposed to other crypto-asset categories, functions in practice rather than only on paper.

No further Greece-specific stablecoin development, such as additional asset-referenced or e-money token issuer authorisations, redemption-rights enforcement action, or reserve-composition disclosure, was identified this cycle. The module's assessment rests on the single Piraeus Bank authorisation as its concrete evidentiary anchor.

Outlook

Whether further asset-referenced or e-money token issuers seek Bank of Greece authorisation in subsequent cycles will indicate whether Piraeus Bank's approval was an isolated event or the start of a broader domestic stablecoin-issuer cohort. Independent verification of the Bank of Greece's specific reserve, redemption, and custody requirements for such issuers remains an open research task, and until that detail is sourced the amber assessment reflects a genuine evidentiary gap rather than a doubt about the regime's basic operation.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (2)
  1. T1 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — The Bank of Greece licenses credit institutions, e-money institutions and payment institutions to issue e-money tokens (EMTs) and/or asset-referenced tokens (ARTs) and is empowered to impose administrative measures or penalties for breaches of MiCAR.retrieved M5bindingin force
  2. T1 · Bank of Greece (via Bank for International Settlements Central Bankers' Speeches)Bank of Greece (via Bank for International Settlements Central Bankers' Speeches) — MiCAR addresses systemic risks linked to crypto-assets purporting to maintain a stable value, concerning financial stability, payment systems, monetary policy transmission and monetary sovereignty, applicable to ART/EMT issuers supervised by the Bank of Greece.retrieved M4bindingin force

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CASPs operating in Greece under MiCAR Title V must provide clients with information that is fair, clear and not misleading, including in marketing communications, and must meet knowledge-and-competence standards for staff providing crypto-asset advice per ESMA Guidelines. Custody and administration of crypto-assets on behalf of clients is a distinct regulated CASP service subject to HCMC/Bank of Greece oversight. Cross-border transfer service guidelines (Article 82 MiCA) impose liability and procedural obligations on CASPs providing transfer services to Greek clients.

Standing sub-brief · as of 25 August 2026199 words · last cycle 2026-08-25

Consumer Protection

Core consumer protection obligations for Greek crypto markets remain in force under MiCAR Title V and show no material change this cycle. MiCA Article 66 requires crypto-asset service providers to give clients information that is fair, clear and not misleading, including identified marketing communications -- a Confirmed, T1-sourced obligation. CASPs offering custody and administration services are subject to distinct MiCAR Title V authorisation and conduct requirements administered jointly by the HCMC and the Bank of Greece. ESMA's guidelines issued under MiCA Article 82(2) establish consistent, efficient and effective supervisory practices for crypto-asset transfer services, including liability provisions applicable to CASPs serving Greek clients. All three obligations are legally settled and in force, but supervisory practice around them is still maturing, given the recent close of the Article 143(3) transitional period and the unresolved Binance/HCMC authorisation dispute playing out in the same period.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (3)
  1. T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Article 66 of MiCA provides that crypto-asset service providers shall provide their clients with information that is fair, clear and not misleading, including in marketing communications, which shall be identified as such.retrieved M4bindingin force
  2. T1 · EUR-Lex / European UnionEUR-Lex / European Union — CASPs offering custody and administration of crypto-assets on behalf of clients are subject to distinct MiCAR Title V authorisation and conduct requirements administered by HCMC/Bank of Greece.retrieved M4bindingin force
  3. T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — ESMA guidelines under Article 82(2) of MiCA establish consistent, efficient and effective supervisory practices for crypto-asset transfer services, including liability provisions applicable to CASPs serving Greek clients.retrieved M3bindingin force

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No dedicated Greek statute specifically taxing cryptocurrency capital gains or income has been identified as of this research pass; general Greek income tax code provisions are presumed to apply by default to crypto disposals, but a confirmed rate/treatment could not be verified from available sources and requires primary-source escalation to the Greek Independent Authority for Public Revenue (AADE). Separately, at EU level, amendments to the Directive on Administrative Cooperation (DAC8/CARF) extend automatic exchange of information to crypto-asset transactions, which Greece as an EU Member State is obliged to transpose, though confirmation of Greek transposition status was not found in this pass.

Standing sub-brief · as of 25 August 2026170 words · last cycle 2026-10-18

Tax Treatment

Greek crypto tax treatment remains the weakest-covered domain in this cycle. No dedicated statute specifically addressing cryptocurrency capital gains taxation was located on the AADE (Independent Authority for Public Revenue) portal or elsewhere; general Greek income tax code provisions are presumed to apply by default, but this is a negative finding pending primary-source confirmation rather than a confirmed position. Separately, DAC8 -- the Directive on Administrative Cooperation amendment extending automatic exchange of information among EU Member States to crypto-asset transactions, aligned with the OECD Crypto-Asset Reporting Framework (CARF) -- is enacted at EU level but not yet effective, and Greece's specific transposition status and effective date have not been confirmed this cycle.

Periodic update · new data 2026-10-18

Tax Treatment

Greece opened a public consultation on 7 October 2026 for its first dedicated crypto-asset capital-gains tax instrument, with the consultation window closing 22 October 2026. The draft bill proposes a flat 10 percent tax rate on individual crypto-asset transfer gains, with the first EUR500 of annual gains exempt from tax. This rate represents a reduction from an earlier reported proposal of 15 percent, suggesting the rate was softened during the drafting process ahead of formal consultation. The Ministry has signalled an intention to bring the bill to a parliamentary vote in the first week of November 2026, though this timing has not been confirmed with high confidence and remains dependent on the outcome of the consultation period.

A further element reported in connection with the draft bill, though with lower confidence than the headline rate, is a twelve-month voluntary-disclosure window that would allow individuals to regularise past untaxed crypto-asset gains without penalty provided payment is made promptly. How such a window would interact with the EU's DAC8 reporting rules, which impose reporting obligations on crypto-asset service providers regarding their customers' transactions, has not been confirmed in the available evidence and is noted here as an analytical inference drawn from the draft bill text rather than a confirmed feature.

As at the date of this brief, none of this tax framework has been enacted. It remains at the consultation and pre-vote stage, meaning the 10 percent rate, the EUR500 exemption and the voluntary-disclosure window are all proposals rather than current law.

Outlook

The consultation closes 22 October 2026, with an anticipated parliamentary vote in the first week of November 2026. Enactment as proposed would give Greece its first dedicated crypto capital-gains tax instrument and close a prior gap in individual-investor tax treatment of crypto-asset gains. Confirmation of the voluntary-disclosure window's interaction with DAC8 reporting obligations remains an open item to watch.

1 earlier distinct update(s)
Periodic update · new data 2026-10-11

Tax Treatment

The Ministry of National Economy and Finance published a draft bill on 7 October 2026 proposing Greece's first dedicated crypto-tax framework: a flat 10% capital-gains tax on crypto disposals, with an EUR500 annual exemption. The same draft includes a 12-month voluntary-disclosure window allowing taxpayers to settle past crypto capital gains without fines or interest if paid promptly, though the exact start and end dates of that window have not been specified in the sources reviewed. The bill has not been enacted; it is under public consultation to 22 October 2026, with a parliamentary vote targeted for the first week of November 2026 as part of a broader financial-reform package.

Outlook

The consultation close on 22 October 2026 and the targeted parliamentary vote in the first week of November 2026 are the two near-term dates that will determine whether this framework takes effect as proposed, is amended, or is delayed. Confirmation of the voluntary-disclosure window's precise dates would also sharpen the picture for taxpayers assessing past-gains exposure.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (2)
  1. T3 · Independent Authority for Public Revenue (AADE), GreeceIndependent Authority for Public Revenue (AADE), Greece — No dedicated Greek statute specifically addressing cryptocurrency capital gains taxation has been identified; general income tax code provisions are presumed to apply by default pending primary-source confirmation.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
  2. T1 · European Commission / EUR-LexEuropean Commission / EUR-Lex — EU Directive amendments (DAC8) extend the Directive on Administrative Cooperation to require automatic exchange of information on crypto-asset transactions among Member States, aligning with the OECD Crypto-Asset Reporting Framework (CARF).retrieved M4bindingenacted not yet effective

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As an EU/EEA Member State operating under MiCAR, Greece imposes no domestic outbound restriction on crypto-asset transfers within the EU passporting framework; a MiCA-authorised CASP in any Member State (including Greece via HCMC) may in principle offer services across all 27 EU Member States. Cross-border crypto-asset transfers are subject to Regulation (EU) 2023/1113's travel-rule requirements, obliging CASPs to attach originator/beneficiary information to transfers and retain such records, with suspicious-activity flagging to the Financial Intelligence Unit as a disambiguation-only AML nexus (out of scope for this baseline's aml_cft_regime module).

Standing sub-brief · as of 25 August 2026222 words · last cycle 2026-10-18

Cross-Border Transfer

Greece's cross-border transfer framework is legally codified and in force, but this cycle surfaces reported friction around its practical operation. Under Regulation (EU) 2023/1113, the crypto-asset service provider of the originator must ensure that transfers of crypto-assets are accompanied by required information on the originator and the beneficiary, and intermediary CASPs must ensure that this information is transmitted with the transfer and that records are retained and made available to competent authorities on request -- both Confirmed, T1-sourced obligations unchanged this cycle. On passporting, a MiCA-authorised CASP licensed via the HCMC would formally be entitled to operate and market crypto services across all 27 EU Member States under MiCA's passporting framework; however, reporting on the Binance/HCMC episode indicates that French regulators have publicly signalled willingness to resist passporting for firms authorised in Member States they view as more permissive. This caveat downgraded the underlying passporting claim's confidence from Confirmed to Probable this cycle, reflecting that formal legal entitlement and reported supervisory practice may diverge.

Periodic update · new data 2026-10-18

Cross-Border Transfer

With the first Greek MiCA crypto-asset service provider authorisations issued on 22 July 2026, the cross-border passporting mechanism available under MiCA Article 65 has become functional in practice for Greek-authorised entities for the first time. MiCA's passporting system allows a crypto-asset service provider authorised in one EU member state to provide services across the Union without seeking separate authorisation in each additional state, and Greek-authorised providers are, in principle, now able to make use of this capability following their authorisation.

The exact notification procedure and timing that a Greek-authorised provider would need to follow to exercise outbound passporting into other member states has not been located in the available evidence this cycle. This is a gap in the practical mechanics of how passporting operates from Greece specifically, rather than any doubt about the underlying legal entitlement, which flows directly from MiCA authorisation itself.

Outlook

Confirmation of the Hellenic Capital Market Commission's specific notification procedure and timeline for outbound passporting by Greek-authorised crypto-asset service providers remains an open item. As more Greek entities complete MiCA authorisation, instances of actual cross-border passporting activity, rather than the theoretical capability alone, would be the next indicator to watch.

1 earlier distinct update(s)
Periodic update · new data 2026-10-05

Cross-Border Transfer

Greece's experience over the roughly fifteen months preceding September 2026 is a practical illustration of how the Markets in Crypto-Assets Regulation's cross-border passporting mechanism, under Article 65, functions in a jurisdiction that lags in processing domestic authorisations. For that entire period, Greece had no domestically authorised crypto-asset service provider of its own, yet crypto-asset activity continued to reach Greek customers through firms holding passported licences granted by other member states' regulators. The regulatory architecture tolerated, and indeed was designed to accommodate, this asymmetry: a single-member-state authorisation is sufficient under the regulation's passporting regime to permit cross-border service provision throughout the European Economic Area, regardless of whether the receiving member state has itself authorised any domestic provider.

That period ended with the appearance of Greece's first domestic authorisations, BCash, Xenios Blockchain Group, Capital Wallet Greece, and Piraeus Bank, on the European Securities and Markets Authority's register on 24 September 2026. This closes the domestic-authorisation gap but does not alter the underlying cross-border passporting mechanism itself, which continues to operate as the general EU-wide rule regardless of any individual member state's domestic authorisation pace.

The traffic-light assessment for this module is amber: the general Markets in Crypto-Assets Regulation passporting mechanism under Article 65 is confirmed and well understood at the EU level, but the specific Greece-level notification timelines, meaning how quickly the Hellenic Capital Market Commission processes inbound passporting notifications from other member states' regulators, have not been independently verified this cycle. The structural fact that Greece relied on passported provision for an extended period is sourced; the procedural detail of how that passporting process is administered on the Greek side is not yet established.

This module's finding connects to the crypto-licensing development directly: the closure of the domestic authorisation gap is the event that ends the period during which Greece was functionally dependent on inbound passporting to serve its market, though it does not end passporting itself, which will continue to operate alongside Greece's newly active domestic authorisation regime.

Outlook

Whether Greece's domestic authorisation activation reduces reliance on inbound passporting, or whether passported provision continues to coexist with domestic providers as the norm under the Markets in Crypto-Assets Regulation's single-market design, is a pattern to watch in subsequent cycles. Independent verification of the Hellenic Capital Market Commission's specific passporting-notification processing timelines remains an open research task.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (3)
  1. T4 · The BlockThe Block — If approved by the Hellenic Capital Market Commission, a MiCA licence obtained in Greece would allow a CASP to operate and market crypto services across all 27 EU member states under MiCA's passporting framework.retrieved M4bindingin force
  2. T1 · EUR-Lex / European UnionEUR-Lex / European Union — The crypto-asset service provider of the originator shall ensure that transfers of crypto-assets are accompanied by required information on the originator and the beneficiary, per Regulation (EU) 2023/1113.retrieved M4bindingin force
  3. T1 · EUR-Lex / European UnionEUR-Lex / European Union — Intermediary crypto-asset service providers must ensure that all information received on the originator and the beneficiary accompanying a transfer of crypto-assets is transmitted with the transfer and that records are retained and made available on request to competent authorities.retrieved M3bindingin force

#

AML/CFT obligations for crypto-asset service providers are addressed under the Financial Integrity Module (FIM) consumer subscription and are out of scope for this crypto baseline. For disambiguation purposes only: pre-MiCA Greek VASP registration operated under AMLD5-derived national law with FIU oversight; under MiCAR's transition, registration under the AML/CFT framework alone (not MiCA authorisation) does not qualify an entity for the simplified Article 143(6) authorisation procedure. EBA AML/CFT powers transferred toward the EU Anti-Money Laundering Authority (AMLA) framework at the end of 2025.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

#

## Commercial Activity Multiple dated commercial and regulatory-entry events occurred in Greece's crypto-services sector this cycle. Capital Wallet Greece announced on 27 July 2026 that it had been granted MiCA CASP authorisation by the Hellenic Capital Market Commission, among the first such authorisations granted in Greece, enabling EU-wide passported service from Athens. BCASH and Xenios Blockchain Group received comparable HCMC authorisations within the same window (30 June-7 August 2026), and Piraeus Bank was separately authorised by the Bank of Greece; all four entered ESMA's MiCA register on 24 September 2026. Set against this wave of market entry, Binance withdrew its own Greek CASP application on 24 June 2026 before a formal HCMC decision was reached, with a disputed and uncorroborated allegation that the ECB was involved in that outcome. ## Outlook The near-term question is whether the current wave of four authorisations is followed by further domestic entrants, and whether Binance re-applies for Greek CASP status. Confirmation or rebuttal of the disputed ECB-involvement allegation around the Binance withdrawal would also be a material clarifying development.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T2Capital Wallet — Capital Wallet Greece announced MiCA CASP authorisation by HCMC on 27 July 2026retrieved M4bindingin force
  2. T4Binance — Withdrew Greek MiCA CASP application on 24 June 2026 before formal HCMC decision; disputed ECB-involvement allegationretrieved M3non-binding
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