How to get a gambling licence in Greece: 2 months to market

Law 4002/2011 art. 45(2) provides exactly two online licences. One holder may be granted both; each is personal, indivisible and non-transferable.

• Esports and bingo are not among the games the Regulation lists for either licence. An online licence or a game certificate does not allow a game that is, or is a version of, one reserved to OPAP or Hellenic Lotteries, such as ΜΠΙΝΓΚΟ ΛΟΤΤΟ (HGC Instruction 6/2021 paras 3-7).
• Suppliers of technical means hold an HGC suitability licence: a Category A.1 manufacturer pays EUR 5,000 on application and EUR 25,000 a year, A.2 and B EUR 1,000 and EUR 5,000, C EUR 500 and EUR 1,000, D EUR 250 and EUR 500, and an importer-supplier EUR 1,000 and EUR 2,000 a year (Suitability Regulation 9.9, 10.7). Their games, platforms and RNGs are certified before an operator may use them, at EUR 50 on application and a one-off EUR 100 each (Online Gaming Regulation 14.9).
• Affiliates are entered in the HGC’s Register of Affiliates for a EUR 1,000 fee, and licensees may use only registered affiliates (art. 45A).
• State lotteries and land-based betting are exclusive rights of the OPAP group, outside the licence system. Horse-race betting on races IPPODROMIES S.A. organises needs its prior written consent, and on races abroad the consent of their organiser (Instruction 6/2021 para. 5; the concession ratified by Law 4338/2015).
• The licence is personal: it cannot be transferred, leased to a third party or jointly used (Online Gaming Regulation 3.4-3.5), so a white-label or turnkey arrangement is judged by who controls the operation. A Category A.1 manufacturer may provide management and operating services, and the operator tells the HGC at once which one it uses (Suitability Regulation 9.2(a), 9.14).

Laws that apply

• Law 4002/2011, consolidated text (arts. 45-52 on online licensing, tax and sanctions)
• Law 4635/2019 (ΦΕΚ Α΄ 167/2019), which replaced arts. 45-47
• Law 5313/2026 (ΦΕΚ Α΄ 102/2026), which recast arts. 51-52
• HGC Online Gaming Regulation 79835/ΕΞ2020 (ΦΕΚ Β΄ 3265/2020), as amended
• HGC Technical Specifications Regulation 79841/ΕΞ2020 (ΦΕΚ Β΄ 3266/2020)
• Commercial Communication Regulation 79292/ΕΞ2020 (ΦΕΚ Β΄ 3260/2020), HGC Directive 4/2021 and HGC Directive 3/2023 (the mandatory marking)
• HGC Suitability Regulation 56580 ΕΞ 2022 (ΦΕΚ Β΄ 2166/2022), for suppliers
• HGC AML Regulation 554/5/2021, under Law 4557/2018
• Law 5219/2025 arts. 116-122, tax on gambling winnings
• HGC Instructions 1/2021 (the player contract), 2/2021 (self-assessment), 4/2023 (player account and identity), 6/2021 (exclusive rights) and 7/2021 (GGR methodology)
• Law 4779/2021 on audiovisual media services (ΦΕΚ Α΄ 27/2021), arts 14-16
• Joint Ministerial Decision 70330/2015 on consumer ADR, and Law 2251/1994 on consumer protection
• Regulation (EU) 2024/1624 on anti-money laundering, applying from 10 July 2027

Applicants are legal persons with a registered seat or a permanent establishment in Greece or another EU/EEA state (art. 46(1)).

• Board members, partners and managers must have no final conviction for a felony or for listed offences, among them theft, fraud, breach of trust, forgery, bribery, and drugs, weapons and tax-evasion offences (art. 46(2)).
• A company on the HGC’s blacklist of unlicensed providers in the year before applying cannot be licensed (art. 46(3)).
• A non-EU company may apply only through an EU/EEA seat or permanent establishment.

Three sums, all fixed in the Act: an application fee, the licence price, and the same price again on renewal.

• The price is payable at once or in four equal annual instalments, the first before the licence issues (art. 46(6), as replaced by Law 4701/2020 art. 54). The 2019 text said two.
• There is no separate annual operating-licence fee, although instalments of the licence price may still fall due each year (art. 46(6)). The HGC’s own funding, 0.5% of gaming revenue, is carved out of the State’s tax share rather than added to it (art. 28(7)(a)).

• Term: seven years from the HGC’s act granting the licence (art. 45(6)).
• Renewal: requested at least a year before expiry, for another seven years, at a new price equal to the original and with the guarantee intact (art. 45(7)).
• Decision: the HGC must decide within two months of the application; silence is a refusal (art. 45(3)).
• Start of operations: the grant is not permission to start. Operations begin only after a separate HGC decision, taken within 30 days of the application for it, once the statutory, regulatory and licence conditions are met (art. 46(9)).
• Appeal: an HGC decision is challenged before the administrative courts as a dispute on the merits (art. 51).

• Published financial statements for the last three years, tax and social-security clearance certificates, and certificates of no bankruptcy, no liquidation and no pending application for either (art. 46(8)).
• A business plan and model with timetables and milestones (Online Gaming Regulation art. 5.1).
• The documents proving the art. 46 conditions; the Gaming Regulation may require more.

• The Safe, the final data store of the Intermediate Control System, sits in a data centre in Greece; the Central Information System and its backup may be anywhere in the EU/EEA.
• The Intermediate Control System captures, seals and stores the data the HGC supervises; sealing runs in periodic batches, not as real-time reporting.
• Every game needs a Game Certificate and an Integration Certificate; a new version is a new game. Each certification costs EUR 50 on application and a one-off EUR 100 (Online Gaming Regulation 14.9); the conformity certificates behind it come from certification bodies at the applicant’s cost, at prices the rules do not set.
• Equipment and studio certificates are accepted only from bodies holding ISO/IEC 17020, 17025 and 17065 that the HGC has recognised; nine are on its Register of Certification Bodies. Other certificates may come from bodies accredited by the Hellenic Accreditation System (Ε.ΣΥ.Δ.) or by a body with a mutual-recognition agreement with it (Suitability Regulation 16.1-16.2). Equipment sold elsewhere may be certified by mutual recognition for the jurisdictions an HGC decision lists (Online Gaming Regulation 2.5).
• RNG casino games: at most EUR 20 a stake and EUR 140,000 a payout per game cycle, jackpot awards excluded, and at least two seconds from the start of one cycle to the next (ΑΥΟ 67663/ΕΞ2022; peer-to-peer poker is exempt from the two-second rule); jackpots are capped at EUR 500,000.
• ISO/IEC 27001 certification, an external security audit at least every 18 months, a penetration test every year and a vulnerability scan every six months.
• Gaming data, CIS information and player-account records are kept for ten years (Law 4002/2011 art. 47(5); Online Gaming Regulation 32.9, 19.8, 34.1); AML records five years after the relationship with the player ends (AML Regulation 11.3).

• The operator withholds and remits the tax when it pays out; the taxable event is the payment.
• The State’s share is a deductible expense for income tax (art. 50(7)).
• Bonuses follow HGC Instruction 7/2021: bonus-funded stakes count as stakes when placed, and their winnings with the bonus are deducted as a separate payout term; cashback and rakeback are expenses, and an unsuccessful bonus-funded bet leaves GGR unchanged.

• Minimum age 21, shown on every page of the site.
• At the first session a player must set a deposit limit and a loss limit, plus a time limit for casino-type games and RNG virtual events (daily, weekly or monthly); the site warns at 80% and stops play at 100%.
• Self-exclusion: indefinite (reversible after at least a year), temporary (at least a month) or a 24-hour break. The Regulation provides for an HGC Register of Excluded Persons, binding on every licensee and checked before an account opens and before any deposit, from the day after it starts operating; until then each licensee applies the exclusions in its own register (Online Gaming Regulation 35.5). Check with the HGC whether the register has started.
• Responsible-gambling messages that interrupt RNG play, and a cooling-off mechanism that may be activated in view of uninterrupted play, total wagers or a risky pattern of play (TEP 5.7).
• Registration takes at least surname, first name, identity-document number, date of birth, email and an address in Greece with city and postal code, and identity is verified before the account opens (HGC Instruction 4/2023 paras 4.2-4.3; Online Gaming Regulation 19.1).
• Payments only by transfer, debit or credit card, prepaid card or e-wallet through an EU/EEA-authorised provider; no cryptocurrency. A deposit of EUR 5,000 or more per transaction may be used only once the player’s ownership of the payment account is confirmed, and a withdrawal of EUR 800 or more is paid only after the same check (AML Regulation 13.7(c)-(d)).
• The player contract states the period within which a withdrawal’s payment order is issued (HGC Instruction 1/2021 para. 6.5.8); a balance on a closed account is paid within three business days (Online Gaming Regulation 21.2). Unfair standard terms are void (Law 2251/1994 art. 2(6)-(7)).
• Operators assess every player’s activity for the risk of problem gambling and intervene, with restrictions where it is indicated (Instruction 1/2021 paras 6.5.6, 6.5.3.3), and report to the HGC by 31 January each year on the self-assessment tests run on their site in the previous year (Instruction 2/2021).

• HGC Regulation 554/5/2021 under Law 4557/2018: a Compliance Officer holding an HGC suitability licence, customer due diligence, transaction monitoring and suspicious-transaction reports without delay to the Anti-Money Laundering Authority, not to the HGC (Law 4557/2018 arts 22, 47; AML Regulation 10.1).
• A provisional account may take deposits up to EUR 800 and play for 30 days before verification, but nothing is paid out until the player is verified.
• AML Compliance Reports to the HGC twice a year, by 15 July and by 15 January; records kept five years after the relationship ends.
• The EU AML Regulation, Regulation (EU) 2024/1624, applies from 10 July 2027; until then Law 4557/2018 and the HGC AML Regulation apply.

• Every campaign needs a Commercial Communication Plan approved in advance by the HGC, within 30 days (Decision 79292/ΕΞ2020).
• Bonuses may not be advertised to the public; loyalty programmes only, within narrow limits.
• No public figures presented as success models; outdoor adverts at least 200 m from schools; no pop-ups or overlays.
• Every advert names the HGC as regulator, the age limit, the risk of addiction and the helplines (Commercial Communication Regulation art. 8.9), in the form HGC Directive 3/2023 sets: “21+ | HGC | RISK OF ADDICTION & LOSS OF ASSETS | HELPLINE: 210 9237777 | PLAY RESPONSIBLY”, with shorter versions by medium.
• Licensees may post on their own social-media channels but may not promote those posts to users (Directive 4/2021).
• Television and radio: commercial communication for games of chance is lawful only for games lawful under Law 4002/2011 and in line with the HGC Regulation (Law 4779/2021 art. 14; arts 15-16 for sponsorship and product placement). Law 4779/2021 repealed Presidential Decree 109/2010, which the HGC Regulation still cites.
• Every reward offer carries a "Terms and Conditions apply" note pointing to the site, and the material terms must be clear and timely; leaving them out can be a misleading practice (Law 2251/1994 arts 9δ-9ε).

• A 24/7 complaints system on the site; the player complains within 48 hours from the day after the incident, the operator answers within ten days, and the player may then ask the HGC to re-examine within ten days (Online Gaming Regulation 26.4-26.6). These are deadlines of the complaint procedure, not a limitation period.
• An amicable settlement, or referral to an ADR body registered under Joint Ministerial Decision 70330/2015, is notified to the HGC, which may prohibit it if it breaks the rules or the player contract (27.1-27.3). A settlement keeps the courts open to both sides and the HGC’s power to sanction (27.4-27.5).
• The player contract’s clause giving the courts of Athens exclusive jurisdiction (art. 27.6) is read with the EU consumer rules: where they apply, a consumer can sue in the courts where they live, and a choice of law cannot remove mandatory consumer protection (Regulation 1215/2012 arts 17-19; Regulation 593/2008 art. 6).

• Administrative fines of EUR 1,000 to EUR 2,000,000 per violation, or a percentage of gross receipts, and temporary (up to three months) or permanent revocation (art. 51, as recast by Law 5313/2026).
• Offering games of chance without a licence: at least ten years in prison and EUR 50,000 to 700,000 (art. 52).
• Taking part in unlicensed gambling: up to two years in prison and a fine; a repeat offence at least two years and EUR 5,000 to 20,000 (art. 52(3)).
• The HGC publishes a blacklist of unlicensed providers and ISPs must block access (art. 48).
• A supplier that works with or supplies a blacklisted site loses its suitability licence automatically and is fined an amount the Gaming Regulation sets (art. 51(7β)).

The route from company to live operation, in the order the Act imposes it.

1. 01

   Set up the applicant

   EU/EEA seat or establishment · EUR 200,000 paid up

   A legal person seated or established in Greece or another EU/EEA state, with at least EUR 200,000 of paid-up capital.

2. 02

   Clear the principals

   board, partners, managers

   No final conviction for a felony or the listed offences, and no blacklisting in the year before the application.

3. 03

   Arrange the guarantee

   EUR 500,000

   A letter of guarantee from an EU/EEA credit institution.

4. 04

   Choose the licence type

   betting and/or other online games

   EUR 3,000,000 for betting, EUR 2,000,000 for other online games, at once or in four annual instalments.

5. 05

   Build and certify the stack

   certificates · Safe in Greece

   Certified games and platform from suitability-licensed suppliers, the Intermediate Control System, and the Safe in a Greek data centre.

6. 06

   File with the HGC

   EUR 10,000 fee

   The application with the art. 46(8) documents and the business plan; the HGC decides within two months.

7. 07

   Pay and receive the licence

   first instalment

   The licence issues once the price, or its first instalment, is paid.

8. 08

   Approve the advertising plan

   within 30 days

   The Commercial Communication Plan, before any campaign.

9. 09

   Start operations

   second HGC decision

   A start-of-operations decision within 30 days of the request, once every condition is met.

Tier-ordered: official government first, then practitioner, then trade media. Every primary figure was read from the in-force text on 26 Oct 2026.