Digital Payments & Fintech · Greece
Fintech & payments regulation in Greece (2026)
Greece shaded by its digital payments & fintech status
Fintech and digital payments in Greece: licensing regime.
FrameworkLaw 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).
What an EMI license in Greece covers
- Issuing electronic money and maintaining payment accounts
- Executing payment transactions: credit transfers, direct debits and card payments
- Issuing and/or acquiring payment instruments
- Money remittance
- Payment initiation services (PIS)
- Account information services (AIS)
How to get an EMI license in Greece: step by step
- 1Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).
- 2Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.
- 3Deposit and evidence the €350,000 initial capital.
- 4Submit the application to the national competent authority.
- 5The authority has three months from a complete application to grant or refuse.
- 6On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.
Documents required in Greece
- Programme of operations listing each payment service you will provide
- Business plan with a three-year budget forecast
- Evidence of the €350,000 initial capital
- Governance arrangements and internal-control mechanisms
- AML/CFT policy and appointment of a compliance officer
- Safeguarding arrangements for client funds (segregated account or insurance)
- Security policy, incident management and ICT resilience procedures
- Fit-and-proper documentation for directors and qualifying shareholders
- Description of any outsourcing, agents or distributors
- Professional indemnity insurance where you provide PIS or AIS
After authorisation: ongoing obligations in Greece
- Maintain own funds under the applicable calculation method (A, B or C)
- Safeguard client funds at all times, segregated or insured
- Apply strong customer authentication (SCA) under PSD2
- Run continuous AML/CFT monitoring and reporting
- Report major operational and security incidents to the regulator
- Submit annual audited accounts and periodic regulatory reporting
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.
The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.
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.
Timeline - major decisions & events
The European Parliament and Council reached provisional political agreement on PSD3 and the Payment Services Regulation (PSR), which will merge Greece's separate Payment Institution and Electronic Money Institution regimes into one unified licence and strengthen open-banking access rights. Final texts are expected in the EU Official Journal in H1 2026, with member-state transposition due ~2027.
European Parliament Legislative Train ↗The Hellenic Capital Market Commission issued Decision 8/1059 specifying application requirements, fit-and-proper criteria, and documentation standards for Crypto-Asset Service Provider authorisations under Law 5193/2025 and MiCA, completing Greece's domestic CASP licensing infrastructure.
Hellenic Capital Market Commission (HCMC) ↗Published in Government Gazette A 56/11.04.2025, Law 5193/2025 designates the HCMC as national competent authority for CASP licensing and the Bank of Greece for e-money token and asset-referenced token issuers. Greece became the third EU member state — and first in Southern Europe — to complete domestic MiCA implementation, with a national transitional period ending 31 December 2025.
Hellenic Capital Market Commission (HCMC) ↗EU Regulation 2023/1114 on Markets in Crypto-Assets became fully applicable, bringing crypto-asset service providers operating in Greece under mandatory authorisation and prudential requirements. Firms relying on a transitional VASP registration must obtain full HCMC authorisation by 31 December 2025 or cease operations.
Bank of Greece ↗Greece enacted Law 4961/2022 on Emerging Information and Communication Technologies, providing the country's first statutory definitions of blockchain and distributed ledger technology (Article 31; Articles 47–51) and laying a legal foundation for DLT applications in financial and public-sector services.
Legal 500 Greece (cites Government Gazette) ↗The Bank of Greece opened its Regulatory Sandbox — co-funded by the EU's DG Reform and implemented with EBRD technical assistance — offering fintech firms a supervised environment to test innovative financial services without immediate full regulatory risk. It is open on an ongoing basis to both licensed institutions and non-authorised entities partnering with a licensed firm.
EBRD ↗The Bank of Greece's Executive Committee adopted Act 189/1, formally defining eligibility criteria, operational terms, and supervisory conditions for the Regulatory Sandbox, enabling both authorised financial institutions and fintech start-ups (via licensed-entity partnerships) to test regulated innovations under BoG oversight.
Bank of Greece ↗The Bank of Greece published Act 164/2019 setting out detailed procedures for authorising Electronic Money Institutions under Law 4021/2011, including capital-adequacy calculations, safeguarding rules, and application documentation, completing the practical licensing framework for e-money issuers.
Bank of Greece ↗Greece transposed the EU's Fourth Anti-Money Laundering Directive via Law 4557/2018, for the first time requiring Virtual Asset Service Providers to register with the Hellenic Capital Market Commission and comply with KYC/AML obligations — the earliest domestic regulation directly targeting crypto businesses.
Greek Government Gazette (English translation hosted by ELTE) ↗Greece enacted Law 4537/2018 transposing Directive 2015/2366/EU (PSD2), establishing the national licensing framework for payment institutions, account-information service providers (AISPs), and payment-initiation service providers (PISPs). The Bank of Greece became the competent authority for payment institution authorisation and strong-customer-authentication (SCA) oversight.
Bank of Greece ↗As a structural reform tied to Greece's ESM bailout, retailers and specified professional categories (physicians, lawyers, tradespeople) were legally required to accept card payments from 1 January 2016. Card transaction values tripled by 2017, and studies found that at least one in nine new digital transactions corresponded to previously undeclared economic activity, improving VAT compliance.
The Paypers ↗Greece imposed capital controls on 28 June 2015, capping daily ATM withdrawals at €60 to arrest a banking-system bank run during the sovereign debt crisis. The restrictions proved the single largest structural catalyst for digital payment adoption in Greece, with card use tripling in value by 2017 and digital penetration remaining elevated long after controls were lifted.
Mondaq (citing Greek government acts) ↗Greece enacted Law 4021/2011, transposing EU Directive 2009/110/EC (the second E-Money Directive) and creating a distinct Electronic Money Institution licence category supervised by the Bank of Greece, with a minimum initial capital of €350,000 and mandatory safeguarding of customer funds.
Bank of Greece ↗Greece - other topics
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