Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the Bank of Greece decision, including banking and payment rails.
Get an EMI license in Greece.
The comeback market of the EU: the Bank of Greece authorises e-money institutions under Law 4021/2011 - with a published pre-application procedure, a digitising 10-million consumer base and thirty million tourists a year paying by card.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Greece in brief
A recovering market with a central-bank desk.
Greece authorises e-money institutions through the Bank of Greece under Law 4021/2011 (Articles 9-30) - the EMD2 transposition - with payment institutions under Law 4537/2018 (Article 23) and the supervisory detail in Executive Committee Acts 164/2019 and 142/2018. The central bank runs a published pre-application procedure: the model and file are discussed before formal submission, expectations are set, and the application that follows must be - in the Bank's own words - true, comprehensive, accurate and up to date. Initial capital is the harmonised €350,000 for the EMI, with payment-institution capital set per the Executive Acts, safeguarding, and a three-month window from a complete file.
The market is the story Europe missed: Greece has spent a decade digitising out of the crisis - card acceptance became mandatory economy-wide, IRIS account-to-account payments are scaling fast, and the 10-million domestic base is amplified every summer by more than thirty million tourists transacting at Greek merchants. Add a 22% corporate rate with the EU's lowest-tier 5% dividend withholding, an EU/EEA passport, and Athens operating costs well below Western capitals. Realistic end-to-end: 9-15 months; the file runs in Greek, and we draft it natively with local counsel from our Athens office.
Bank of Greece authorisation under Law 4021/2011 + Law 4537/2018: €350,000 capital, Executive Acts 164/142 detail, published pre-application procedure, Greek file.
The market: a decade of forced digitisation, IRIS scaling, 30M+ tourists a year - with a 22/5 tax combination founders respect.
The two routes
Full EMI - or the payment-institution tier.
One central bank, two entries: the e-money institution under Law 4021/2011, or payment-institution licences under Law 4537/2018. Both preceded by the published pre-application procedure. We fix the scope first, then build once.
EMI at €350,000 - or PI scopes, with tourism acquiring as the standout play.
01 - E-MONEY INSTITUTION
EMI authorisation
The flagship Bank of Greece authorisation: e-money issuance plus the payment-services list, €350,000 initial capital, safeguarding and EU/EEA passporting - from the EU's fastest-digitising market.
The flagship Bank of Greece authorisation: e-money issuance plus the payment-services list, €350,000 initial capital, safeguarding and EU/EEA passporting - from the EU's fastest-digitising market.
- ✓E-money issuance and distribution
- ✓Full PSD2 payment-services list
- ✓€350,000 initial capital · own funds ongoing
- ✓Safeguarding of client funds
- ✓EU/EEA passport on notification
- ✓Pre-application procedure - published
02 - PAYMENT INSTITUTION ROUTES
30M tourists a yearPI routes
Payment-institution licences under Law 4537/2018 run by service scope. With acquiring for the tourism economy the standout use case: thirty million visitors paying at Greek merchants every year.
PI per Executive Act capital; acquiring for 30M tourists; PIS/AIS on IRIS; upgrade path.
- ✓PI licences per Executive Act capital
- ✓Acquiring for the tourism economy
- ✓Money remittance and transfers
- ✓PIS/AIS routes on IRIS rails
- ✓Upgrade path to the EMI
- ✓Same Bank of Greece supervision
Costs and timelines are confirmed for your case before any work begins. Bank of Greece process starts with the pre-application procedure; capital, safeguarding and substance costs are itemised in your quote.
Why Greece
The growth curve Europe already wrote off.
The framework is EMD2/PSD2 under the central bank. Attached to a market compounding out of a decade of under-penetration.
✓
The digitisation wave
Mandatory card acceptance, IRIS instant payments scaling, POS everywhere the law now requires it. Greece compressed a decade of payments adoption into a few years, and the curve is still steep.A decade of adoption, compressed.
✓
Thirty million tourists
Tourist card volumes wash through Greek merchants every season. Acquiring, DCC and travel-money models find their natural home market here.Seasonal volumes, structural play.
✓
A pre-application desk
The Bank of Greece publishes a pre-application procedure. The model is discussed before filing, expectations set face to face, then met on paper.Expectations set face to face.
✓
5% dividend withholding
Among the EU's lowest. With 22% corporate tax, the combined founder outcome beats most Western desks comfortably.Among the EU's lowest.
✓
EU passport
One Bank of Greece authorisation notifies into every EU/EEA state. The single market from Athens, with the home market as proof ground.Single market from Athens.
✓
PSD3-ready files
With PSD3/PSR close to adoption, e-money folds into the unified payment-institution regime. We structure Greek files to convert rather than be rebuilt.Built to convert, not rebuild.
How it compares
How Greece differs from other routes.
Greece trades queue familiarity for a compounding market. The full comparison is below.
Greece vs other jurisdictions
| Feature |  Greece | Other jurisdictions |
|---|---|---|
| Regulatory regime | Laws 4021/2011 & 4537/2018 - BoG | Same directives, other desks |
| Market phase | Compounding digitisation | Mostly saturated |
| Tourism volumes | 30M+ visitors a year | Seasonal at best |
| Timeline | 9-15 months realistic | 6-12 at specialised desks |
Regulatory regime
GreeceLaws 4021/2011 & 4537/2018 - BoG
Other jurisdictionsSame directives, other desks
Market phase
GreeceCompounding digitisation
Other jurisdictionsMostly saturated
Tourism volumes
Greece30M+ visitors a year
Other jurisdictionsSeasonal at best
Timeline
Greece9-15 months realistic
Other jurisdictions6-12 at specialised desks
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Greece | EMI (Bank of Greece) | 22% CIT · 5% div. | Greek file, pre-application |
 Lithuania | EMI (Bank of Lithuania) | 17% CIT (2026) | CENTROlink, specialised desk |
 Cyprus | EMI (CBC) | 15% CIT (2026) | Non-dom founder economics |
 Bulgaria | EMI (BNB) | 10% CIT | Euro area, Bulgarian file |
GreeceLicense typeEMI (Bank of Greece)
Taxation22% CIT · 5% div.
RequirementsGreek file, pre-application
LithuaniaLicense typeEMI (Bank of Lithuania)
Taxation17% CIT (2026)
RequirementsCENTROlink, specialised desk
CyprusLicense typeEMI (CBC)
Taxation15% CIT (2026)
RequirementsNon-dom founder economics
BulgariaLicense typeEMI (BNB)
Taxation10% CIT
RequirementsEuro area, Bulgarian file
Before you apply
Requirements for the Bank of Greece authorisation.Requirements for the authorisation.
The Executive Acts detail the file and the Bank spells out the standard: true, comprehensive, accurate, up to date. The checklist below is what a passing application contains.
01
Greek entity. An A.E. or E.P.E. with its head office and management in Greece.
02
Initial capital - €350,000 for the EMI, evidenced and paid in; PI capital per Executive Act 164/2019.
03
Fit and proper management and holders. Competence, clean records and ownership transparent to UBOs.
04
Programme of operations. Services, volumes and three-year financials the central bank can interrogate.
05
Safeguarding. Segregated client-fund accounts or insurance, with documented reconciliation.
06
AML/CFT framework. KYC, monitoring and Hellenic FIU reporting with a resident compliance officer.
07
IT and security documentation. Architecture, DORA-grade resilience and incident procedures.
08
Internal governance. Control functions, outsourcing register and conflicts procedures.
09
Pre-application discipline. The procedure taken, and the file built to what it established.
10
Greek-language file. The application and annexes drafted and defended in Greek.
01
Greek A.E./E.P.E., managed locally.
02
€350,000 capital (EMI).
03
Fit & proper holders to UBOs.
04
Interrogable programme of operations.
05
Safeguarding with reconciliation.
06
AML with resident officer (FIU).
07
DORA-grade IT documentation.
08
Governance and outsourcing register.
09
Pre-application taken, file built to it.
10
Full file in Greek.
Reflects Law 4021/2011, Law 4537/2018 and Executive Committee Acts 164/2019 & 142/2018 as of 2026.L. 4021/2011 + L. 4537/2018 + Executive Acts, as of 2026.
How it works
From pre-application to the register.
01
Route and strategy
EMI or PI scope, domestic or tourism-weighted. We fix the scope, capital and timeline in writing.EMI or PI; tourism weighting.
02
Pre-application procedure
The Bank of Greece's published procedure taken with the model framed properly. Expectations set before filing.The published procedure, taken.
03
Company, people and file
Greek company formation, capital, resident officers, and the complete file in Greek, delivering what was framed.Formation, capital, Greek file.
04
Bank of Greece review
Three months from complete, question rounds answered - 9-15 months realistic end to end.3 months statutory; 9-15 realistic.
05
Authorisation and launch
The register entry, passport notifications and the reporting calendar. Live in the comeback market.Register, passports, comeback market.
Quick facts
RegulatorBank of Greece
EMI capital€350,000
Legal basisL. 4021/2011 · L. 4537/2018
DetailExecutive Acts 164 & 142
ProcessPre-application first
Statutory review3 months from complete
Realistic timeline9-15 months
PassportEU/EEA on notification
The Bank of Greece states its standard in one line. True, comprehensive, accurate, up to date. Meeting it first time is the entire game, and our job.
On the ground in Greece
Run from our Athens office.
Prifinance - Greece
Athens · Greece
Athens, Greece
01
Greek company formation
A.E. or E.P.E. incorporation, capital placement and the corporate layer the Bank of Greece expects. Structured for the licence from day one.A.E. + capital, structured for the file.
02
The pre-application, prepared
The model presentation and file plan built before the Bank's procedure, because the application that follows must deliver exactly what was framed.Framed right - then delivered.
03
The BoG file - in Greek
Programme of operations, safeguarding design, AML pack and IT documentation drafted natively with Greek counsel, and defended through the central bank's rounds.Drafted natively with counsel.
04
Substance and staffing
Resident directors, compliance officer and MLRO from Athens' financial talent pool. Real substance at Southeast European cost.Athens talent, SE Europe cost.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Greece.
22% corporate with a 5% dividend withholding. One of the EU's best founder combinations - plus VAT-exempt payment services and incentives Greece keeps adding.
Corporate tax 22%
The flat rate on an EMI's fee and float income. Mid-table headline in a bottom-table cost economy.Mid-table rate, low-cost economy.
Dividends 5%
Among the EU's lowest dividend withholding rates. The 22/5 combination lands founder outcomes below most Western desks.EU's low tier - founder maths.
VAT-exempt payment services
Payment and e-money services are VAT-exempt financial services; the 24% standard rate touches only ordinary supplies.24% only on ordinary supplies.
Relocation regimes
Greece runs non-dom and inbound-worker incentives for relocating founders and executives. Personal outcomes we model alongside the corporate plan.Non-dom and inbound incentives.
Athens cost base
Engineering and compliance talent at Southeast European rates in an EU capital people want to live in. The operating base prices sensibly.SE European rates, EU capital.
Treaty network 55+
A functional treaty network across Europe and beyond. Group structures above the Greek entity model cleanly.Functional network.
Tax summary
Corporate tax22%
Dividend withholding5%
VAT on payment servicesExempt
Standard VAT24%
Relocation regimesNon-dom · inbound incentives
Tax treaties55+
*Figures as of 2026 per the AADE. Founder-level and relocation outcomes are modelled per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Greek company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, authorised institution.
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Greece · Bank of Greece
Launch your payment project in Greece with expert support.
Full-service assistance - from company registration to the Bank of Greece authorisation, passporting and ongoing compliance.
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Is Greece the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The Greek EMI licence - the questions we hear.
What licence does an e-money business need in Greece?+
An e-money institution authorisation from the Bank of Greece under Law 4021/2011 (Articles 9-30) - €350,000 initial capital, safeguarding and EU/EEA passporting. Payment-institution licences under Law 4537/2018 sit alongside, with capital per Executive Act 164/2019.
How does the pre-application procedure work?+
The Bank of Greece publishes a pre-application phase: the business model and file plan are discussed with the supervisor before formal submission. We prepare it like a filing, because the application that follows must deliver exactly what was framed.
How long does licensing take?+
Three months from a complete application as the statutory window, after the pre-application phase. Realistic end-to-end: 9-15 months. The Bank's own standard - true, comprehensive, accurate, up to date - is the bar, and meeting it first time is our job.
What substance is expected?+
A Greek company managed locally, resident fit-and-proper officers, AML reporting to the Hellenic FIU, real safeguarding arrangements and DORA-grade systems documentation.
How are payment companies taxed?+
22% corporate tax with a 5% dividend withholding - one of the EU's best founder combinations - plus VAT-exempt payment services and relocation incentives at the personal level.
Why is the Greek market interesting for an EMI?+
A decade of forced digitisation: mandatory card acceptance, IRIS instant payments scaling, and thirty-plus million tourists transacting at Greek merchants every year. Acquiring and travel-money models find volumes here that saturated markets cannot offer.
Does the licence passport across the EU?+
Yes - the Bank of Greece authorisation notifies into every EU/EEA state. Groups run the home market as proof ground and passport outward.
Is the Greek-language file a real obstacle?+
It is the main operational one - the application, annexes and rounds run in Greek. We draft natively with Greek counsel rather than translating afterwards.
What changes under PSD3?+
PSD3 and the PSR - provisionally agreed in November 2025 and close to formal adoption - fold e-money institutions into a unified payment-institution regime. Files we build now are structured to convert.
Why Greece rather than Cyprus or Bulgaria?+
Cyprus wins on founder tax; Bulgaria on the 10% rate. Greece wins on the market itself - ten million digitising consumers plus the tourism wave - with a 22/5 tax combination that keeps the economics respectable. Volume-driven models belong here.
What licence is needed?+
BoG EMI - €350k; PI per Executive Act.
Pre-application?+
Published procedure - model framed first.
How long?+
3 months statutory; 9-15 realistic.
Substance?+
Resident officers, real Greek ops.
Taxes?+
22% CIT; dividends 5%.
The market?+
Digitising fast + 30M tourists.
Greek file?+
Yes - drafted natively with counsel.
Passport?+
EU/EEA on notification.
PSD3?+
Agreed Nov 2025 - files convert.
Vs Cyprus?+
Their founder tax; Greece's volumes.
Client notes
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Founders who wanted it done right.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Bank of Greece or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.