Digital Payments & Fintech · Greece
EMI license in Greece: e-money institution (EMI) requirements (2026)
Greece shaded by its digital payments & fintech status
Fintech and digital payments in Greece: licensing regime, under Law 4537/2018 (PSD2 transposition); Bank of Greece Executive Committee Acts 164/2019, 178/2020, 189/2021; supervised by the Bank of Greece (BoG).
Greece operates a full licensing regime for payment institutions and electronic money institutions under Law 4537/2018, which transposed PSD2 (Directive 2015/2366/EU) into national law, with the Bank of Greece as the sole competent authority for authorisation and prudential supervision. The IRIS instant-payment rail became mandatory for all businesses on 1 December 2025, and the per-transaction daily limit was raised to €1,000 in January 2026. Greece aligns with all applicable EU-wide frameworks, PSD2, CCD2 (BNPL), and MiCA, with national implementing legislation in force or in transposition.
How to get an EMI license in Greece
To provide electronic-money or payment services in Greece you need authorisation as an Electronic Money Institution (EMI), supervised by the Bank of Greece, under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
- Authority
- the Bank of Greece
- License required
- authorisation as an Electronic Money Institution (EMI)
- Framework / law
- the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
- Minimum capital
- €350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
- Timeline
- roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
- Cost
- application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
- Passporting
- Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
EMI license in Greece: FAQ
Yes. To provide electronic-money or payment services in Greece you need authorisation as an Electronic Money Institution (EMI), supervised by the Bank of Greece, under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
The Bank of Greece.
Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.
Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.
Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Key points
The Bank of Greece authorises and supervises Payment Institutions (PIs) and Authorised Electronic Money Institutions (AEMIs) under Law 4537/2018 and part A of Law 4021/2012. EMIs require minimum starting capital of €350,000 and at least three natural-person directors. BoG Act 164/2019 sets out detailed operational, governance and registration requirements; BoG Act 243/2025 introduced an updated corporate governance framework aligned with EBA Guidelines.
Greece enacted PSD2 via Law 4537/2018; banks must provide secure API access to licensed AISPs and PISPs using the Berlin Group NextGen PSD2 standard, with sandbox environments and strong-customer-authentication (SCA) flows overseen by the Bank of Greece. BoG Act 189/2021 established a formal regulatory sandbox to test emerging fintech products within the financial sector.
IRIS, Greece's national instant-payment system, was made mandatory for all businesses from 1 December 2025; non-compliance carries fines starting at €1,500. The daily transfer limit was doubled to €1,000 in January 2026. IRIS volumes grew 70.8% year-on-year in 2025, reaching approximately 120 million transactions worth €11 billion. Cross-border expansion via the EuroPA/EPI network is planned for mid-2026.
BNPL services in Greece are being brought within the consumer-credit perimeter through the EU Second Consumer Credit Directive (CCD2), which Greece was required to transpose by 20 November 2025. CCD2 removes the €200 minimum threshold and most interest-free BNPL exemptions, requiring mandatory affordability checks and clearer fee disclosure. Enforcement is expected to begin in late 2026.
Greece enacted Law 5193/2025 to implement the EU Markets in Crypto-Assets Regulation (MiCA). The Hellenic Capital Market Commission (HCMC) is designated as the primary competent authority for authorising Crypto-Asset Service Providers (CASPs). The Bank of Greece retains prudential oversight for asset-referenced tokens (ARTs), e-money tokens (EMTs), and credit institutions offering crypto services.
The Bank of Greece operates a formal regulatory sandbox (BoG Executive Committee Act 189/2021) to facilitate testing of innovative financial products. Law 4961/2022 created a broader technology sandbox. EU-backed EquiFund investment supports over 90 Greek fintechs. Greece is preparing for PSD3 and DORA alignment, expected 2026-2028.
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