How to Get a Mica CASP Authorisation in Greece (HCMC) Full Application Guide

Quick Summary What This Page Covers

Obtaining a MiCA CASP authorisation in Greece is now a concrete, actionable process following the implementation of Regulation (EU) 2023/1114 the EU’s harmonised Markets in Crypto-Assets framework and its national transposition through Law 5193/2025 (published FEK A’ 56, 11 April 2025). The Hellenic Capital Market Commission (HCMC) is Greece’s designated national competent authority for most crypto-asset service provider (CASP) matters, and July 2026 marked a watershed moment: Greece’s first MiCA CASP authorisations were granted, signalling an actively licensing regime open for business.

This guide walks you through the complete HCMC application process eligibility, required documents, minimum capital, realistic timelines, costs and ongoing obligations. It is designed for:

• Crypto exchanges and trading venues seeking EU market access through a Greek CASP licence
• Custody and wallet providers preparing their compliance dossiers
• Token projects and issuers needing regulatory clarity before launch
• Founders and compliance officers evaluating Greece as their MiCA domicile
• In-house and external counsel advising crypto clients on Greek regulatory requirements

Why Choose Greece for MiCA CASP Authorisation

HCMC as the National Competent Authority

The HCMC brings decades of capital-markets supervisory experience to its crypto-asset oversight role. As the designated authority under Law 5193/2025, the HCMC has published procedural guidance for CASP applicants and is actively processing submissions. Industry observers note the regulator’s pragmatic approach: proactive engagement with applicants during pre-filing discussions, clear procedural expectations, and a demonstrated willingness to bring dossiers to decision. For firms accustomed to opaque or delayed regulatory processes elsewhere, the HCMC’s institutional rigour and responsiveness represent a practical advantage.

Strategic Location Southern-EU Gateway with Full Passporting

A MiCA CASP licence issued by the HCMC enables passporting across all EU and EEA member states without requiring additional national authorisations. Greece offers a southern-European operational base with competitive cost structures for staffing and infrastructure, direct access to the Euro-zone client base, and a growing fintech ecosystem. Athens is increasingly positioned as a viable alternative to higher-cost western European hubs for crypto businesses seeking EU market entry.

Market Momentum in 2026

The legislative timeline tells a compelling story: Law 5193/2025 was enacted in April 2025, HCMC implementing rules followed, and by July 2026 the first CASP authorisations were publicly confirmed. This regulatory momentum creates a genuine first-mover window. Firms that file complete applications now benefit from an HCMC that is actively staffed and scaled for processing before the regulator’s pipeline becomes congested with later entrants. For businesses evaluating their MiCA CASP Greece strategy, the timing is favourable.

How to Obtain a MiCA CASP Authorisation in Greece Step by Step

The HCMC CASP application process can be understood through seven distinct phases, each with specific decision points and deliverables. While exact procedural timelines are governed by HCMC guidance and Law 5193/2025, the structure below reflects the practical workflow applicants should plan for.

Step 1: Scoping and Regulatory Classification

Begin by mapping your business activities against the crypto-asset services defined in MiCA. The regulation identifies ten categories of regulated service including custody and administration of crypto-assets, exchange services (crypto-to-fiat and crypto-to-crypto), execution of orders, operation of a trading platform, placing, reception and transmission of orders, transfer services, advisory services, portfolio management, and underwriting. Your regulatory classification determines capital requirements, governance obligations, and whether the Bank of Greece has a prudential role particularly relevant if your activities involve asset-referenced tokens (ARTs) or e-money tokens (EMTs). This scoping exercise is foundational: every subsequent step depends on correct classification.

Step 2: Corporate and Operational Structure

CASP applicants must be established as legal entities within the EU. Common options include incorporating a Greek société anonyme (SA) or limited liability company (EPE/IKE), or establishing a branch of an existing EU entity. Decisions at this stage include shareholding structure, qualifying holdings (which trigger fit-and-proper scrutiny), and whether to pursue an establishment-first or passporting-first strategy. Firms seeking to operate from Greece should begin the company formation process early, as corporate registration timelines feed directly into the overall application schedule.

Step 3: Management Suitability and Governance Evidence

HCMC requires robust fit-and-proper evidence for all members of the management body, compliance officers, and AML officers. Prepare detailed CVs, criminal record certificates, bankruptcy declarations, and evidence of relevant professional experience. A key decision is whether to appoint locally resident directors or propose remote management arrangements the HCMC will assess whether the applicant’s governance structure ensures effective oversight, adequate local presence, and compliance with MiCA’s organisational requirements.

Step 4: Build the Documentation Pack

This is typically the most time-intensive phase. The HCMC requires a comprehensive dossier covering the completed application form, a detailed three-year business plan, internal policies (AML/KYC, conflict of interest, outsourcing, complaints handling), IT security and architecture documentation, custody and asset-segregation arrangements, continuity and disaster recovery plans, risk management frameworks, and consumer-protection disclosures. Where applicable, white papers for specific token offerings must also be prepared and included. Translations and apostilles may be required under Law 5193/2025 for documents originating outside Greece.

Step 5: Capital and Funds Proof

Minimum capital requirements under MiCA are calibrated to the risk profile of the services offered. Applicants must demonstrate that capital has been injected, is freely available (not encumbered), and meets or exceeds the applicable threshold. Evidence typically includes bank statements, auditor confirmations, and proof of the origin of funds. Timing is critical: capital must be verifiably in place at submission, not merely promised.

Step 6: Submission, Completeness Check and Substantive Review

Upon submission to the HCMC, the regulator acknowledges receipt and initiates a completeness review typically within approximately 25 business days. An incomplete dossier will be returned with a request for supplementary information, which resets portions of the review clock. Once deemed complete, the HCMC conducts a substantive review examining the applicant’s fitness to operate, the adequacy of its governance, AML controls, capital position, and technical arrangements. During this phase, the HCMC may issue requests for information (RFIs) or schedule in-person meetings with management. Complex cases particularly those involving EMTs/ARTs or cross-authority prudential questions may involve coordination with the Bank of Greece or consultation with ESMA.

Step 7: Decision, Authorisation Conditions and Next Steps

The HCMC may grant authorisation outright, grant authorisation subject to conditions (such as phased service rollouts or enhanced reporting), or refuse the application with stated reasons. Upon authorisation, the CASP is notified to the ESMA register and publicly listed as an authorised provider. Post-authorisation, the firm must operationalise its compliance framework, begin supervisory reporting, and maintain continuous adherence to the conditions of its licence.

Who Needs a CASP Licence and Which CASP Categories Exist

CASP Service Categories Under MiCA

MiCA defines ten categories of crypto-asset services that require authorisation. Any entity providing one or more of these services within the EU must hold a CASP licence from a national competent authority:

• Custody and administration of crypto-assets on behalf of clients
• Operation of a trading platform for crypto-assets
• Exchange of crypto-assets for funds (fiat currency)
• Exchange of crypto-assets for other crypto-assets
• Execution of orders for crypto-assets on behalf of clients
• Placing of crypto-assets
• Reception and transmission of orders for crypto-assets
• Transfer services for crypto-assets on behalf of clients
• Providing advice on crypto-assets
• Portfolio management of crypto-assets

Eligibility Checklist

Before filing, applicants should confirm they meet threshold eligibility criteria:

• EU legal entity: The applicant must be incorporated or established in an EU member state for HCMC authorisation, establishment in Greece
• Adequate governance: A management body with demonstrable competence, experience, and good repute
• AML programme: A documented anti-money-laundering and counter-terrorist-financing framework compliant with EU and Greek requirements
• Minimum capital: Sufficient own funds corresponding to the risk profile of the services to be provided
• Operational readiness: IT infrastructure, security controls, custody arrangements and business continuity plans in place or credibly planned
• Clear business plan: A detailed three-year plan covering commercial strategy, target markets, fee structures and financial projections

HCMC Application Documents Quick Checklist

The following document categories form the core of an HCMC CASP application dossier. Applicants should treat this as a minimum framework the HCMC may request additional exhibits depending on the services and complexity involved.

• Core corporate documents: Completed application form, certificate of incorporation, articles of association and bylaws, shareholder register with identifying information for qualifying holdings, audited financials or pro-forma statements, detailed three-year business plan, and a comprehensive services and fee schedule
• Governance and fit-and-proper pack: CVs for all directors and senior managers, criminal record certificates, bankruptcy clean-record declarations, compliance officer and AML officer appointments, internal policies covering compliance, conflict of interest, and outsourcing
• Operations and security documentation: IT architecture diagrams and technical specifications, custody and asset-segregation arrangements, third-party service contracts, incident response and escalation plans, business continuity and disaster recovery procedures
• AML and KYC framework: AML/CFT policy document, transaction monitoring methodology and system design, outsourced AML vendor agreements, evidence of AML officer qualifications and appointment
• Prudential evidence (where applicable): Capital proof (bank confirmations, auditor letters), escrow or segregation arrangements, evidence of free and liquid assets
• HCMC-specific procedural exhibits: Certified translations, apostilled documents for foreign-origin instruments, and any supplementary forms specified under Law 5193/2025

Minimum Capital and Cost Components Summary

MiCA establishes minimum own-funds requirements that vary by service type and risk profile. Law 5193/2025 and HCMC implementing rules set the specific national parameters. Beyond regulatory capital, applicants must budget for the full cost of application preparation legal advisory, compliance programme design, technology, insurance, and ongoing supervisory obligations. The section below provides illustrative cost ranges.

What You Should Budget For Minimum Capital and Realistic Total Costs

MiCA sets minimum capital thresholds calibrated to the risk and complexity of the crypto-asset services provided. Law 5193/2025 and HCMC implementing rules translate these into binding national requirements applicants must demonstrate both initial adequacy and ongoing solvency. The following illustrative ranges are intended as planning guidance, not guarantees of final costs.

Small custodial or exchange start-up (limited services): Illustrative minimum paid-in capital of EUR 125,000–500,000, plus non-recurring set-up costs (incorporation, legal, compliance build, technology, security audits) of EUR 80,000–250,000.

Mid-sized trading venue or multi-service CASP: Capital requirements in the range of EUR 1,000,000–3,000,000, with set-up costs of EUR 300,000–700,000 reflecting more complex governance, technology and compliance infrastructure.

Large systemic or custody provider with EMT/ART exposure: Bespoke prudential measures apply. Expect significantly higher capital requirements, conditional authorisation terms, and Bank of Greece involvement in the assessment. Costs are highly variable and project-specific.

Key cost components to budget for when planning a MiCA CASP Greece application include:

• Incorporation and corporate services: Greek entity formation, registered office, local representative
• Legal and regulatory advisory: Application preparation, regulatory strategy, fit-and-proper review
• Translation and apostille: Certified translation of foreign-origin documents
• Compliance programme build: AML/KYC policy drafting, transaction monitoring design
• AML tooling subscription: On-chain analytics, screening and monitoring platforms
• Security audits: Penetration testing, SOC 2-style assessments, custody security reviews
• Insurance: Professional indemnity and cyber-risk coverage
• Application and supervisory fees: HCMC filing fees (where applicable) and ongoing annual levies
• External audits: Annual statutory audit and any required special-purpose reports

These figures are illustrative. Applicants should engage with qualified advisors to produce a validated budget based on their specific service profile and scale.

How Long Does a MiCA CASP Authorisation in Greece Take?

The end-to-end timeline from initial scoping to HCMC decision depends heavily on applicant preparedness and the complexity of the services involved. The following illustrative timeline reflects current market experience:

• Scoping and dossier preparation: 4–12 weeks, depending on the applicant’s existing compliance maturity, corporate structure readiness, and availability of governance documentation
• HCMC acknowledgement and completeness check: The HCMC acknowledges receipt within days; the completeness review window is typically within approximately 25 business days
• Substantive review: 6–12 weeks for complete, straightforward dossiers. Complex cases particularly those involving EMTs, ARTs, or cross-authority prudential questions with the Bank of Greece can take significantly longer
• Total realistic end-to-end: 3–6 months for straightforward cases; 6–12+ months for complex or conditional applications

Common reasons for delay include:

• Incomplete or inconsistent documents: Missing AML controls documentation, insufficient governance evidence, or contradictory information across submissions
• Weak fit-and-proper evidence: Gaps in criminal record certificates, unexplained career breaks, or insufficient professional experience for nominated key personnel
• Unclear custody or segregation arrangements: Failure to demonstrate credible asset-segregation mechanisms
• Capital proof issues: Delayed capital injections, inability to evidence free liquid capital, or questions about source of funds
• Cross-authority queries: Bank of Greece involvement for EMT/ART prudential matters, requiring additional coordination and review time

Ongoing Obligations After Authorisation

Securing an HCMC CASP authorisation is the beginning, not the end, of the regulatory journey. Authorised CASPs must maintain continuous compliance across several domains:

• AML/CFT compliance: Maintain an effective AML programme, conduct ongoing customer due diligence, report suspicious transactions to Greek authorities, and submit to periodic independent testing of AML controls
• Governance and fit-and-proper maintenance: Ensure ongoing suitability of board members and senior management; notify the HCMC of material changes; maintain internal controls, segregation of duties, and comprehensive record-keeping
• Regulatory reporting: Submit regular prudential reports (where applicable), report significant incidents to the HCMC and ESMA as required, and fulfil annual disclosure obligations to stakeholders and regulators
• Operational resilience: Maintain and periodically test business continuity plans, cybersecurity measures, and IT controls. Conduct scheduled security audits and provide evidence-based assurance to the regulator

ESMA supervisory guidelines and HCMC decisions set detailed expectations firms must maintain living, documented compliance frameworks that evolve with regulatory developments.

How Greece (HCMC) Compares With Other EU MiCA Domiciles

Choosing the right EU domicile for a MiCA CASP application involves weighing regulatory speed, supervisory culture, cost structures, tax environment, and operational infrastructure. The table below provides a high-level comparison of Greece against three other commonly considered jurisdictions.

Domicile selection is ultimately a multi-factor decision encompassing regulatory speed, prudential exposure, tax optimisation, workforce availability, and outsourcing strategy. Under MiCA, whichever jurisdiction grants the authorisation, the licence passports across the EU making the choice of home regulator a strategic rather than market-access question. Greece vs Malta, Portugal and Estonia comparative analysis is available as a dedicated resource for firms evaluating their options.

Sources

• Regulation (EU) 2023/1114 Markets in Crypto-Assets (MiCA), Official Journal of the European Union (EUR-Lex)
• Hellenic Capital Market Commission Markets in Crypto-Assets, HCMC official portal
• Law 5193/2025 Hellenic Parliament legislative record, Hellenic Parliament
• Bank of Greece MiCA Institutional Framework, Bank of Greece
• ESMA Markets in Crypto-Assets Regulation (MiCA), European Securities and Markets Authority
• ESMA Supervisory Guidelines Market Abuse under MiCA, European Securities and Markets Authority
• Greece Secures Landmark MiCA CASP Authorisation (July 2026), FXStreet