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Retail_Trading_Status

Allowed-Regulated High Confidence
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Analysis ID
#669
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Created
2025-12-12 04:19
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Executive Summary

Cryptocurrency trading is legal and comprehensively regulated in Greece under a dual framework of national AML laws and the EU's Markets in Crypto-Assets Regulation (MiCA). The Hellenic Capital Market Commission (HCMC) serves as the primary regulator, maintaining a mandatory registry for Virtual Asset Service Providers (VASPs) and overseeing the transition to full CASP licensing. As of 2025, retail investors are subject to a specific 15% capital gains tax on crypto profits, and service providers must adhere to strict AML/KYC and capital requirements.

Key Pillars

Primary Regulator: Hellenic Capital Market Commission (HCMC) for CASP licensing and AML supervision
Prudential Regulator: Bank of Greece (BoG) for asset-referenced tokens (ARTs) and e-money tokens
Mandatory Registration: VASP Registry (pre-MiCA) transitioning to CASP License (MiCA)
Taxation: Flat 15% Capital Gains Tax on individual crypto profits (effective Jan 1, 2025)
Compliance: Strict AML/KYC obligations under Law 4734/2020 and Law 5193/2025

Landmark Laws

Law 5193/2025 (MiCA Implementation Law) (Law 5193/2025) - Enacted: 2025-04-11
- Adapts Greek national legislation to the EU Markets in Crypto-Assets Regulation (MiCA). Designates the HCMC and Bank of Greece as competent authorities and establishes penalties for unauthorized crypto services.
- Source

HCMC Decision 8/1059/2025 (Decision 8/1059/30.7.2025) - Enacted: 2025-07-30
- Establishes the specific procedural rules and documentation requirements for Crypto-Asset Service Providers (CASPs) to obtain authorization from the HCMC.
- Source

Law 4734/2020 (AML Law Amendment) (Law 4734/2020) - Enacted: 2020-10-08
- Transposed the EU 5th Anti-Money Laundering Directive (AMLD5) into Greek law, creating the initial mandatory registry for crypto exchange and wallet providers.
- Source

Considerations

Taxation: A flat 15% tax applies to capital gains from crypto for individuals starting January 1, 2025.
Transitional Period: Entities registered under the old AML regime have until December 30, 2025, to obtain full MiCA authorization.
Mining Treatment: Mining profits are generally treated as business income and taxed at progressive rates (up to 44%) or the corporate rate (22%).
EU Passporting: CASPs licensed in other EU member states can operate in Greece via the passporting regime.

Notes

The analysis date is December 12, 2025. By this time, the transition to MiCA is in its final stages (deadline Dec 30, 2025). The regulatory status has shifted from a simple AML registration (Gray/Allowed-Unregulated mix) to a fully licensed regime (Allowed-Regulated).

Remaining Uncertainties

  • Specific enforcement actions against non-EU exchanges that have not geoblocked Greek users.
  • Detailed cost-basis accounting guidelines for complex DeFi transactions under the new tax law.

Detailed Explanation

Cryptocurrency trading is legal and comprehensively regulated in Greece as of December 2025. The regulatory framework is dual-layered, consisting of national anti-money laundering (AML) laws and the full implementation of the European Union's Markets in Crypto-Assets Regulation (MiCA). The Hellenic Capital Market Commission (HCMC) serves as the primary regulator, responsible for authorizing and supervising Crypto-Asset Service Providers (CASPs). A mandatory registry for Virtual Asset Service Providers (VASPs) was initially established under national AML law, but entities are now transitioning to a full CASP license under MiCA, with a deadline of December 30, 2025. The Bank of Greece acts as the prudential regulator for specific token types like asset-referenced tokens and e-money tokens. Key legislative pillars include Law 4734/2020, which transposed the EU's 5th Anti-Money Laundering Directive and created the initial VASP registry, and Law 5193/2025, which adapts Greek law to MiCA and designates the competent authorities. Further procedural details for CASP authorization are specified in HCMC Decision 8/1059/2025. From a tax perspective, retail investors are subject to a flat 15% capital gains tax on crypto profits effective January 1, 2025, while mining profits are treated as business income. All service providers must adhere to strict AML/KYC obligations and capital requirements. Notably, CASPs licensed in other EU member states can operate in Greece via the EU passporting regime, facilitating cross-border services.

Summary Points

I. Regulatory Status
* Cryptocurrency trading is Allowed-Regulated.
* The regulatory landscape has shifted from a pre-MiCA AML registration regime to a fully licensed regime under the EU's Markets in Crypto-Assets Regulation (MiCA).

II. Key Regulatory Bodies
* Hellenic Capital Market Commission (HCMC):
* Primary regulator for CASP licensing and AML supervision.
* Maintains the mandatory registry for service providers.
* Bank of Greece (BoG):
* Prudential regulator for asset-referenced tokens (ARTs) and e-money tokens.

III. Important Legislation
1. Law 5193/2025 (MiCA Implementation Law) - Enacted: 2025-04-11
* Adapts Greek national legislation to MiCA.
* Designates the HCMC and Bank of Greece as competent authorities.
* Establishes penalties for unauthorized crypto services.
2. HCMC Decision 8/1059/2025 - Enacted: 2025-07-30
* Establishes specific procedural rules and documentation requirements for CASPs to obtain authorization from the HCMC.
3. Law 4734/2020 (AML Law Amendment) - Enacted: 2020-10-08
* Transposed the EU 5th Anti-Money Laundering Directive (AMLD5).
* Created the initial mandatory registry for crypto exchange and wallet providers (VASPs).

IV. Compliance Requirements
* Licensing: Mandatory registration in the VASP Registry (pre-MiCA) transitioning to a full CASP License under MiCA.
* AML/KYC: Strict obligations under Law 4734/2020 and Law 5193/2025.
* Taxation:
* Individuals: Flat 15% Capital Gains Tax on crypto profits (effective Jan 1, 2025).
* Mining: Profits treated as business income, taxed at progressive rates (up to 44%) or the corporate rate (22%).
* Transition: Entities registered under the old AML regime have until December 30, 2025, to obtain full MiCA authorization.

V. Notable Restrictions or Limitations
* Operating without proper authorization from the HCMC (a CASP license under MiCA) is prohibited and subject to penalties as per Law 5193/2025.

VI. Recent Developments or Notes
* As of the analysis date (December 12, 2025), the transition to the MiCA regime is in its final stages, with the deadline for existing entities being December 30, 2025.
* CASPs licensed in other EU member states can operate in Greece via the EU passporting regime.
* The regulatory status has been formally updated from a Gray/Allowed-Unregulated mix to Allowed-Regulated.

Full Analysis Report

As of late 2025, Greece has established a mature and fully regulated environment for cryptocurrency activities, driven largely by the implementation of the European Union's Markets in Crypto-Assets Regulation (MiCA). The primary regulatory body is the Hellenic Capital Market Commission (HCMC), which oversees the licensing and conduct of Crypto-Asset Service Providers (CASPs). The Bank of Greece plays a complementary role, supervising issuers of asset-referenced tokens and e-money tokens to ensure financial stability. This dual-regulator approach provides legal certainty for both retail investors and institutional players.

The legal foundation rests on Law 5193/2025, enacted in April 2025, which integrated MiCA into the national legal order. This law replaced the previous 'registration-only' regime established by Law 4734/2020 (AMLD5 transposition) with a comprehensive licensing framework. Under HCMC Decision 8/1059 (July 2025), service providers must undergo a rigorous authorization process, demonstrating adequate capital, governance structures, and IT security. A transitional period allows entities previously registered under the AML law to continue operations until December 30, 2025, provided they have applied for a full CASP license.

For retail investors, the landscape is clear but strictly monitored. Trading and holding cryptocurrencies are legal, but users are required to use licensed platforms—either those authorized directly by the HCMC or those passported from other EU jurisdictions. The anonymity previously associated with crypto has been effectively removed through stringent KYC/AML checks enforced at the platform level. The HCMC maintains a public register of authorized providers, and regulators have the power to block IP addresses of non-compliant offshore exchanges targeting Greek residents.

Taxation has also been formalized. Effective January 1, 2025, Greece introduced a specific tax regime for crypto assets. Individual investors are subject to a flat 15% capital gains tax on profits realized from the sale or exchange of cryptocurrencies. This resolves years of ambiguity where crypto gains were often treated under general income provisions. Professional traders and mining operations, however, are taxed as business entities with a corporate tax rate of 22%, or progressive income tax rates for individuals classified as professional traders.

Source Evidence

Primary and secondary sources cited in this analysis

2025-12-12

"Providers licensed by the Hellenic Capital Market Commission... Providers from another Member State passported into Greece."

"Entities intending to operate as Crypto-Asset Service Providers... should notify their intention to the Bank of Greece."

"Incorporates in Greek legislation the Directive (EU) 2018/843... Hellenic Capital Market Commission has been named as the competent authority."

"On 30 July 2025, the Board of Directors of the Hellenic Capital Market Commission... issued its Decision No. 8/1059 pursuant to Article 101(a) of Law 5193/2025."

2024-11-08

"Greece has a flat Capital Gains Tax rate of 15% which you'll pay on any capital gains from crypto from 2025."

Web Sources (10)

Sources discovered via web search grounding

Search queries used (6)
  • Greece cryptocurrency regulation Law 4734/2020
  • Greece crypto tax capital gains 2024 2025
  • Greece MiCA implementation competent authority
  • Bank of Greece cryptocurrency warnings
  • HCMC VASP register Greece
  • Hellenic Capital Market Commission crypto registry list
copla.com

https://copla.com/blog/compliance-regulations/mica-regulation-in-greece-licensing-implementation-and-what-crypto-firms-need-to-know/

tsamichaslaw.gr

https://tsamichaslaw.gr/the-implementation-of-mica-in-greece-legal-analysis-of-law-5193-2025/

souriadakistsibris.gr

https://souriadakistsibris.gr/wp-content/uploads/2022/05/Greece-crypto-guide-2022.pdf

sgklegal.gr

https://sgklegal.gr/en/casp-licensing-in-greece/

ey.com

https://www.ey.com/en_gr/technical/tax/tax-alerts/mica-regulation-authorisation-procedure-for-crypto-asset-service-providers

buycoin.online

https://buycoin.online/news/crypto-taxes-in-greece-2025-guide/

ey.com

https://www.ey.com/content/dam/ey-unified-site/ey-com/en-gr/technical/tax/tax-alerts/2025/09/micar-crypto-assets-law-alert-en-2.pdf

coinfomania.com

https://coinfomania.com/cryptocurrency-regulation-in-greece/

baxity.com

https://baxity.com/guide-to-crypto-tax-in-greece

mondaq.com

https://www.mondaq.com/fin-tech/1519192/greece-to-implement-15-tax-on-cryptocurrencies

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