The Implementation of MiCA in Greece: Legal Analysis of Law 5193/2025

Introduction

Cryptocurrencies and blockchain technology are rapidly changing the global financial landscape. Until recently, the legal environment in Europe was fragmented, with each country applying its own rules. This changed with the entry into force of the EU Regulation on Markets in Crypto-Assets (MiCA), which introduces a single framework for crypto regulation across the European Union.

In 2025, Greece implemented MiCA through Law 5193/2025, officially designating the Hellenic Capital Market Commission (HCMC) as the main supervisory authority for crypto-asset activities. This marks a significant step toward legal certainty, investor protection, and the development of Greece as a hub for digital finance.

Who Does the Law Apply To?

The new rules apply to:

• Crypto-Asset Service Providers (CASPs): companies offering services such as custody, trading platforms, exchanges, portfolio management, or advice on crypto-assets.

• Issuers of tokens: companies or projects issuing asset-referenced tokens (ARTs), e-money tokens (EMTs), or other crypto-assets to the public.

If your business falls into these categories, you will now need authorization and supervision under MiCA to operate legally in Greece and the EU.

Licensing and Compliance Obligations

To provide crypto-asset services, firms must obtain a license from the HCMC. The licensing process requires:

• Fit and proper assessment of shareholders, directors, and executives.

• Minimum capital requirements and strong governance frameworks.

• Operational safeguards to protect clients’ assets.

• Compliance with anti-money laundering (AML) and cybersecurity (DORA) rules.

Once authorized in Greece, a CASP can use the “EU passport” to operate freely in all Member States, opening the door to cross-border expansion.

Transitional Period

Companies already registered under the previous AML regime (Law 4734/2020) may continue operating until December 2025, provided they apply for authorization under MiCA within the deadline. Businesses that fail to transition will lose the right to offer services.

Stronger Investor Protection

Investor protection is at the heart of the new framework:

• White Papers: Issuers must publish a detailed information document (similar to a prospectus) before launching tokens.

• Transparency: CASPs must disclose fees, risks, and terms clearly to clients.

• Market integrity: Provisions against insider trading and market manipulation now apply to crypto markets.

• Client asset segregation: Firms must separate their own funds from client funds, ensuring protection in case of insolvency.

Sanctions and Enforcement

The HCMC has broad enforcement powers, including:

• Heavy administrative fines.

• Suspension or withdrawal of licenses.

• Public disclosure of violations.

The Bank of Greece will also coordinate with the HCMC, particularly when crypto activities interact with the banking system or payments sector.

What This Means for Businesses

For companies and startups in the blockchain and crypto sector, MiCA brings both opportunities and challenges:

• Opportunities: A single license in Greece now gives access to the entire EU market. This can make Athens an attractive base for innovative crypto and fintech businesses.

• Challenges: Compliance is more demanding, requiring legal, financial, and technical resources. Businesses will need robust internal controls, governance, and risk management.

What This Means for Investors

For investors—whether retail or institutional—the new rules provide greater safety and trust in the crypto market:

• Clearer information on token offerings.

• Better protection of funds and digital wallets.

• Greater accountability from service providers.

Conclusion

The implementation of MiCA in Greece is a landmark development. It sets clear standards for crypto markets, enhances investor protection, and positions Greece within the European digital finance landscape.

At Tsamichas Law Firm, we advise businesses, startups, and investors on how to navigate the new MiCA framework in Greece and across the EU. Our expertise ensures compliance, reduces legal risks, and helps clients take advantage of the opportunities offered by Europe’s unified crypto-asset market.