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New Licensing Procedure for Crypto-Asset Service Providers (CASPs) in Greece

CASPs

Article originally published on Lawspot.gr in Greek.

With Decision 8/1059/30.07.2025, the Hellenic Capital Market Commission (HCMC) established the procedure for submitting applications for the licensing of Crypto-Asset Service Providers (CASPs), in the context of implementing the Regulation (EU) 2023/1114 (MiCA).

1. What is the applicable regulatory framework?

1.1. The European framework (MiCA Regulation)

The MiCA Regulation introduces, for the first time, a unified regulatory framework for crypto-asset markets across the EU, aiming to:

  • protect investors,

  • enhance transparency and supervision,

  • prevent regulatory fragmentation between Member States.

Certain categories are excluded from its scope, such as unique and non-fungible crypto-assets (NFTs), deposits, and insurance products.

1.2. Greek Law 5193/2025

With Law 5193/2025, which adapts Greek legislation to MiCA:

  • the HCMC was designated as the competent authority for CASPs,

  • sanctions were introduced for the professional provision of services without a license (Article 107),

  • measures were provided for the protection of investors and whistleblowers (Articles 102 and 114).

At the same time, CASPs remain subject to compliance obligations under AML/CFT legislation.

2. What changes with HCMC Decision 8/1059/30.07.2025?

For the first time in Greece, a clear and standardized procedure is established for licensing businesses that provide services related to cryptocurrencies and other crypto-assets.

2.1. Key elements of the new procedure

2.1.1. Preliminary assessment

Applicants may request a preliminary meeting with the HCMC to prepare more effectively before filing an official application.

2.1.2. Submission of the application

The application must be accompanied by specific supporting documents and standard forms already published by the HCMC.

2.1.3. Assessment of the file

  • Receipt is acknowledged within 5 business days.

  • Completeness check is concluded within 25 business days.

  • The final licensing decision is issued within 40 business days from acceptance of the complete file.

3. Practical example

A Greek company that already operates a cryptocurrency exchange and wishes to expand into other EU Member States:

  • requests a preliminary meeting with the HCMC,

  • submits a complete licensing file,

  • once licensed, can provide services across the EU through the “European passport” mechanism.

Thus, licensing serves not merely as a regulatory obligation, but as a passport for growth and cross-border expansion.

4. What should interested companies do?

Businesses wishing to operate as CASPs in Greece are advised to:

  1. Assess whether their services fall under MiCA, based on the Regulation and Law 5193/2025.

  2. Prepare the required documentation (corporate structure, business plan, compliance mechanisms).

  3. Consider requesting a preliminary meeting with the HCMC to facilitate the process.

  4. Submit the licensing application following the instructions of Decision 8/1059/2025.

  5. Keep in mind the relevant deadlines (up to 40 business days for the final decision).

5. Conclusion

With the combined application of the MiCA Regulation, Law 5193/2025, and HCMC Decision 8/1059/2025, Greece now has a comprehensive regulatory framework for the crypto-asset market. This framework:

  • enhances legal certainty,

  • protects investors,

  • ensures compliance with European and national standards,

  • and grants CASPs access to the EU passport, enabling further growth and international outreach.