Digital asset regulation and tokenization in Greece

In Greece, a specialist platform and a bank may supply crypto-asset services through different procedures and supervisory arrangements. European MiCA is supplemented by national laws and Hellenic Capital Market Commission, HCMC, decisions governing applications.

Preparation requires separating issuer, provider and asset and identifying when the Bank of Greece is also involved. This guide explains that sequence and the end of transition without treating a preliminary meeting or procedural deadline as permission to operate.

How Greek legislation connects with MiCA

MiCA establishes the EU framework for crypto-assets within its perimeter. Act 5193/2025 on strengthening the capital market, published in the Government Gazette on 11 April 2025, adds in its Part C the domestic measures, including supervisory powers and procedures. HCMC's authorization documentation relies on that supplement. Publication of the Greek law must not be confused with the EU regulation's application timetable.

Article 204 of Act 5259/2025 amended the transitional regime in Article 125 of Act 5193/2025. Continued operation was extended until 30 June 2026, unless a decision was issued earlier. Its scope was narrow: the domestic transitional regime only covered providers of exchange services between virtual currencies and fiat currencies and custodian wallet providers registered in the special register by 27 December 2024, for the services they were already providing. Providers established in another Member State followed that State's transitional period. For the other services within MiCA there was no domestic regime and the general rules applied. That transitional regime has ended and does not provide a current route into the market.

What HCMC and the Bank of Greece supervise

The allocation notified to ESMA distinguishes specialist CASPs from banks, electronic money institutions and payment institutions. HCMC supervises specialist providers. For the specified financial institutions, the Bank of Greece performs certain prudential and authorization functions while HCMC retains other responsibilities. A firm's services and obligations should not all be assigned to one supervisor without examining its status.

Issuance responsibilities also differ. For EMTs, the Bank of Greece handles issuer requirements while HCMC handles allocated document and liability provisions. ART assessment requires consideration of issuer type and each particular responsibility. Issuance entitlement, offering documentation and service provider authorization are separate checks.

How a prepared application is assessed

Decision 8/1059/2025 governs HCMC applications and provides a preliminary meeting for sufficiently prepared applicants. The meeting does not replace formal assessment or bind the outcome. Applications must demonstrate the business, corporate structure, responsible officers and appropriate controls. An announced application or preliminary contact with the supervisor does not establish authorization.

Decision 9/1079 of January 2026 removed the domestic twenty-day limit for completing documentation in the case covered by the amendment. Completeness checks and substantive assessment of a complete file remain distinct stages. Their periods should not be combined into a promised launch date: preparation, corrections and additional information affect each applicant's actual timetable. The route is operating: according to the ESMA register, HCMC granted the first CASP authorization on 30 June 2026 and two more in July; in August a credit institution was added to that register for crypto-asset custody.

What supports tokenized security rights

MiCA excludes financial instruments. Tokenized equity, debt or derivatives require assessment of securities rules governing issuance and related services. The DLT Pilot Regime allows certain infrastructure and exemptions subject to specific permissions and conditions. It does not provide a blanket waiver for platforms using distributed ledgers.

Project documentation should identify the holder's right, counterparty and transfer rules. Technical control of an address does not independently establish property ownership or shareholder status. Contracts, legal registers and technology entries must be connected, including arrangements for resolving discrepancies and the consequences of insolvency.

Which controls authorized services need

DORA requires ICT risk, continuity, incident and external provider controls within its scope. Custody services should coordinate these with position segregation, reconciliation and key protection. Outsourcing infrastructure does not remove the need to identify who is responsible to customers or how critical functions are maintained and recovered.

The Transfer of Funds Regulation requires originator and beneficiary information for covered transfers, alongside anti-money-laundering and sanctions controls. Before entering into a contract, the entity and its authorization should be verified in the MiCA register and with the relevant supervisor. An authorization does not automatically cover companies in the same group, additional activities or every marketed token. For tax purposes, Law 5301/2026, which transposes the EU directive on administrative cooperation applicable to crypto-assets (DAC8) with effect from 1 January 2026, requires providers to identify their customers' tax residence and report their transactions to the tax authority. The first report, covering 2026, is filed in 2027 within the deadline set by the Independent Authority for Public Revenue (AADE).

How to organize a Greek application

Begin with each entity’s legal status and intended functions. That information supports checking the allocation notified to ESMA and the applicable HCMC or Bank of Greece procedure. Define the model, shareholders, responsible personnel and controls before requesting a preliminary meeting.

Build the timetable around preparation, completeness and decision, applying the January 2026 amendment to the relevant stage. Tokenized issuance also needs contracts and registers supporting holder rights. Where a source is available only as a copy of an official decision, confirm the operative version with the supervisor before filing.

To understand how this framework applies to your project, discuss your case with our team.