Jurisdictions › Greece

Greece

National jurisdiction

Enter only at scale: an open EEA market with strong growth but punishing tax and capital requirements.

7 open · 1 restricted · 2 closed · 3 uncertain · 7 not yet assessed → 20 classes
Regulator: HGC · Collected 25 Oct 2026 · Published 25 Oct 2026 · Changed 25 Oct 2026 PDF Sign in for PDF Compare

Can we offer our product?

Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product.

Player products

  • Casino
    Open
  • Poker
    Open
  • Bingo
    Open
  • LotteryState monopoly
    Closed
  • Sports betting
    Open
  • Other event betting
    Not yet assessed
  • Horse and greyhound racing betting
    Not yet assessed
  • Esports betting
    Open
  • Exchange betting
    Not yet assessed
  • Pool betting
    Not yet assessed
  • Virtual event betting
    Not yet assessed
  • Fantasy sports
    Open
  • Skill gamesNot yet regulated
    Uncertain
  • Prediction markets
    Not yet assessed
  • Sweepstakes
    Open
  • Free play
    Not yet assessed

Supply roles

  • Software / B2BNot yet regulated
    Uncertain
  • Affiliate marketingGrey zone
    Uncertain
  • Payments for gambling
    Restricted

Settlement rail

  • Crypto gamblingProhibited
    Closed

No class-level certainty grade is recorded for this jurisdiction yet; confidence is carried per section below.

Board briefing

Greece is an open but expensive EEA-only online market with a punishing 35% GGR tax and aggressive offshore enforcement.

What has changed

  • December 2025 saw the HGC block ~11,000 offshore sites, and a 2026 decree escalated illegal-operation penalties to 10-year imprisonment and EUR 100,000 fines, alongside municipal permit-revocation powers.

What to do now

  • Model the 35% GGR tax plus 22% corporate tax against expected GGR before committing; budget EUR 2-3m licence fee, EUR 500k guarantee and Greek server hosting; ensure EU/EEA establishment and HGC game certification.

What to watch

  • Industry pressure to cut the 35% tax, the revised land-based casino framework consultation, and any expansion of advertising/affiliate controls in 2026.

11 answers, each dated and graded

The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain.

01 · What kind of market is this?

Overview

Mixed

Greece's gambling market combines steady commercial growth with a tightening enforcement posture aimed at the unlicensed sector's promotional layer. The EEEP reported 2025 licensed-market gross gaming revenue of EUR 3.07 billion, up 6.7% year-on-year, against a standing unlicensed shadow market. The…

Full analysis · 118 words

Greece's gambling market combines steady commercial growth with a tightening enforcement posture aimed at the unlicensed sector's promotional layer. The EEEP reported 2025 licensed-market gross gaming revenue of EUR 3.07 billion, up 6.7% year-on-year, against a standing unlicensed shadow market. The Hellenic Gaming Commission, under the Ministry of Finance, has moved from statutory enactment of Law 5313/2026 to active enforcement, filing legal complaints against 18 social-media influencers with a combined 3.6 million followers for promoting unlicensed gambling. The Finance Minister has stated illegal gambling is now designated a criminal and economic threat, with Law 5313/2026 already being actively implemented. This combination of market growth alongside enforcement intensity characterises the current regulatory disposition toward operators and their promotional intermediaries.

  • High 35% GGR tax relative to MT/EE/CY peers
  • High EUR 2–3m licence fees plus EUR 500k guarantee
  • Local server-hosting and Greek-language requirements
Not reviewed Information added after the 20 Aug 2026 expert review — published for currency and labelled not reviewed.
Not reviewedRead update

Greece's gambling market operates under the established Law 4002/2011 licensing framework, supervised by the Hellenic Gaming Commission (HGC/EEEP), with no change to that core structure this cycle. The dominant development is a tightening of enforcement and liability exposure: Law 5313/2026 introduces a standalone advertising-liability offence reaching affiliates and media promoting unlicensed gambling, while an omnibus reform bill covering illegal-gambling enforcement, HGC staffing expansion, and winnings-tax changes has cleared public consultation and moved to the parliamentary process. The HGC continues active blacklist enforcement, having blocked approximately 11,000 unlicensed domains as of December 2025. Taken together, these signals place Greece in the civil-law family pattern of a statutory licensing stack backed by administrative and blocking enforcement, currently on a tightening trajectory this cycle.

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02 · Can we get a licence?

Licensing and regulation

Mixed

## Licence Triggers Any targeted online advertising to Greece located persons will trigger a requirement to be licenced or face enforcement. ## Type of licence needed The Greek regime now provides for two types of online-focused licences (which includes online casino and poker games): Type 1 – On…

Full analysis · 620 words

## Licence Triggers Any targeted online advertising to Greece located persons will trigger a requirement to be licenced or face enforcement. ## Type of licence needed The Greek regime now provides for two types of online-focused licences (which includes online casino and poker games): Type 1 – Online Betting Licence and Type 2 – Licence of Other Online Games. Affiliate marketing is also regulated. Affiliates are subject to their own licence (Affiliate Suitability Licence) – Minimum requirements and low cost EUR 1.000 – one-off approval fee. Ministerial Decision 509/2020 (Government Gazette B 4140/2020) governs the terms and conditions for the application and the registration on the affiliates system. ## Period of licence & renewal process Type 1 and 2 licences are valid for 7 years. Both Licenses are personal and may not be transferred in whole or in part to any other person or entity. Licensing to third parties or sharing the License in any way is prohibited. An application for renewal for a period equal to the original application must be submitted at least 1 year before expiration of the licence. Under Article 359 of Law No. 4512/2018 land-based casino licences are classified into Simple Licences, which are issued for 15 years and must include a three or four star hotel and Wide-Range Licences, which are issued for 30 years and must include a five star hotel. Casino licences are awarded through public tenders (Article 1(7), Law 2206/1994), and casinos may only operate in the locations specified in Article 1 of Law 2206/1994. A casino that does not hold a licence under Law 2206/1994 or Law 3139/2003 must be licensed under Law 4512/2018 (Article 357(1), Law 4512/2018). The games permitted in casinos are listed in Article 3(7) of Law 2206/1994: blackjack, French roulette, American roulette, baccarat, punto banco, dice, chemin de fer, and coin-operated machines with or without screens. Casinos licensed under Law 4512/2018 may extend credit to players, including amounts above EUR 50,000, subject to the conditions in Article 378(26) of Law 4512/2018. Land-based poker is regulated under Ministerial Decision 9501/2010. ## Online licence application regulation and procedure Details of the application procedure and required paperwork for online gaming licences type 1 and 2 can be found in Ministerial Decision No. 79835 (Government Gazette b 3265/5.8.2020). A decision will be made by HGC within 2 months of the submission of an application. Conditions for applying for Online Licence type 1 and 2: The terms and conditions for the application may be found in article 4 of the Ministerial Decision No. 79835 (Government Gazette b 3265/5.8.2020). A full list of documents and related information needed to support application may be found in article 5 of the Ministerial Decision No. 79835 (Government Gazette b 3265/5.8.2020). ## Geographical cover Online gaming licences are limited to supply to Greek located persons only and must use a “.gr” domain for their online offering. ## Mechanics of the licence process There is no limit to the amount of operating licences which can be granted by the HGC, nor is there a tie to having a land based licence ## Bad Actor / Cooling off periods Operators blacklisted must first be removed from the black list and wait for one year before applying for online licence, provided that they are not blacklisted again. In the latter case they will have to wait 5 years before applying. ## Applicant considerations Applicants for online gaming licences must be registered in Greece or another EU or EEA members state. If the applicant company is not registered or situated in Greece, applicant must appoint a local representative - (process agent). ## Localisation Online gambling websites made available for use of players based in Greece must maintain a “.gr” domain.

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03 · How hard is entry, really?

Market entry in practice

Mixed

## Regulated Greece has a regulated gambling market and has recently rolled out a new, modernised licensing regime. Online gambling is generally permitted and regulated, where licensees are able to operate online casinos, poker games and offer betting services on sporting and other events. Regulato…

Full analysis · 585 words

## Regulated Greece has a regulated gambling market and has recently rolled out a new, modernised licensing regime. Online gambling is generally permitted and regulated, where licensees are able to operate online casinos, poker games and offer betting services on sporting and other events. Regulatory authority over the Greek gambling industry is held by the Hellenic Gaming Commission (the HGC). Whilst the new regime appears to still be in nascent stage, recently implemented regulations have a high degree of sophistication where compared to many other jurisdictions. Whilst Greece may present an attractive opportunity for some established international operators, (particularly given its moderate population size and fair appetite for gambling services), high fees and taxation as well as tight wager restrictions in respect of some games may temper enthusiasm. There are currently 16 online operators holding licences for online betting (type 1) and 17 online operators holding licences for online games (other than betting – type 2). The licensing procedure is open and anyone meeting the legal requirements may apply for online licence type 1, type 2 or both. Gambling (or “Games of Chance”) are defined in Greek law as “games whose results depend on chance, at least in part, and involve a financial risk from the player” via Article 25(b) of Law No. 4002/2011. Laws 4141/2013 and 4635/2019 amended Law No. 4002/2011, adding to the definition of Games of Chance the “Mixed Games”, i.e te combination of skill and chance, and the Online Games of Chance. Gambling games are therefore differentiated from skill games where the outcome is deemed to be based in any way on an element of chance. The full definition for skill games is provided in Article 25(a) of Law No. 4002/2011 as being “games whose outcome depends solely or primarily on the skills and mental abilities of the player and performed in public for recreational purposes, without allowing players to place a bet and without any form of financial benefit to the player.” Greek law does not permit persons under 18 years of age to take part in gambling activities and under 21 years to take part in online gambling activities deeming such individuals to be minors. 2025–2026 Update: Since the last update of this report (01.07.2025), the core licensing and regulatory framework for online gambling in Greece remains unchanged. However, enforcement practice, policy priorities and announced reforms have evolved significantly, particularly in relation to illegal online gambling, advertising controls and a broader strategic review of the gambling market. These developments are expected to shape regulatory risk and compliance expectations during 2026. ## Market size 2020 saw a strong performance for the online gambling sector in Greece, with total GGR for relevant operators reaching EUR 562.773 million. This haul represents an increase of 28% where compared to the corresponding 2019 figure. Some report that online gambling is expected to reach EUR 1B in annual turnover by 2024. In parallel, recent public estimates place the size of the illegal online gambling market in Greece at approximately €1.6–1.7 billion annually (figures reported variously as market value or GGR depending on source). The scale of the unlicensed market has become a key policy driver behind intensified enforcement and announced legislative reform. ## Top Key Attractions and Challenges ## Attractions Fast growing market with relatively light touch compliance Greeks have one of the highest propensities for gambling in the world All forms of Casino and Betting are licensable ## Challenges Relatively high taxes High minimum guarantee and capitalisation requirements Some wagering limits are in place

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04 · What do the licences cost?

Licence fees

Unfavourable

Type 1 online betting licence costs EUR 3 million and Type 2 (casino/poker) EUR 2 million, each valid for 7 years with renewal at the same cost and no annual renewal charge cited in primary sources. A non-refundable EUR 10,000 application fee applies (Art. 45(4) Law 4002/2011 / MD 79835/2020). Opera…

Full analysis · 62 words

Type 1 online betting licence costs EUR 3 million and Type 2 (casino/poker) EUR 2 million, each valid for 7 years with renewal at the same cost and no annual renewal charge cited in primary sources. A non-refundable EUR 10,000 application fee applies (Art. 45(4) Law 4002/2011 / MD 79835/2020). Operators must lodge a EUR 500,000 letter of guarantee as financial security.

Not reviewed Information added after the 20 Aug 2026 expert review — published for currency and labelled not reviewed.
Not reviewedRead update

The draft omnibus bill is reported to raise EEEP licensing fees, though the exact fee schedule has not been confirmed via a Tier-1 source this cycle and is carried at Uncertain confidence. Separately, and with firmer Probable confidence, the bill proposes a new tiered per-session tax on online casino and poker winnings: 0% up to EUR100, 20% between EUR100 and EUR500, and 30% above EUR500, with a proposed effective date of 1 July 2026. Together these proposals signal a rising cost-to-operate trajectory for licensed operators, though the fee component in particular should be treated as unconfirmed pending Tier-1 sourcing.

Not reviewedRead update

No confirmed change to Greece's headline or effective tax rate, deduction structure, or AML/CFT and responsible-gambling compliance-lift figures was identified this cycle. A single T4 source reports that online casino winnings over EUR 500 are taxed at 30 percent from 1 July 2026, which would represent a material new cost input if confirmed, but this claim is rated Uncertain and carries mixed durability pending corroboration by a Ministry of Finance or Government Gazette publication. The interpreter's gaps register records this explicitly as an unresolved sourcing gap. Operators should treat the reported winnings-tax figure as a signal to monitor rather than an operative cost assumption until a Tier-1 or Tier-2 source confirms it.

ConfirmedNot reviewed2 post-review updates · Not reviewedRead full analysis & tables →
05 · What is the tax take?

Tax

Unfavourable

## Application fees An application for both Type 1 and Type 2 licences is also prescribed, where operators will need to pay a sum of EUR 10,000. Where an application for a licence is rejected or withdrawn, any fees paid in pursuing the application are non-refundable. Affiliate marketing has been …

Full analysis · 777 words

## Application fees An application for both Type 1 and Type 2 licences is also prescribed, where operators will need to pay a sum of EUR 10,000. Where an application for a licence is rejected or withdrawn, any fees paid in pursuing the application are non-refundable. Affiliate marketing has been recently regulated. Affiliates are subject to their own licence (Affiliate Suitability Licence) – Minimum requirements and low cost EUR 1.000 – one-off approval fee. ## Ongoing fees Online Betting Licence (Type 1) – To offer online betting to players in Greece, an operator is required to pay a fee of EUR 3,000,000 for the licence period of 7 years. Licence of Other Online Games (Type 2) – To offer other, permitted, online gambling products, an operator is required to pay a fee of EUR 2M for the licence period of 7 years. In light of the announced reform agenda, affiliates are expected to be a particular enforcement focus going forward, with public statements indicating that intermediary activity facilitating illegal gambling will be addressed directly, rather than solely through action against the underlying unlicensed operators. ## Any required minimum guarantee The Greek regime requires operators of Type 1 and Type 2 licences to secure a bank guarantee amounting to EUR 500,000 in order to secure a licence. ## Capitalisation requirement Applicants for Type 1 and Type 2 licences must have paid-in capital of at least EUR 200,000. Simple casino licence holders must have a minimum initial capital of EUR 500,000 and EUR 5M after 5 years of operation. Wide-Range casino licence holders must have a minimum initial capital of EUR 1M and EUR 10M after 5 years of operation. Online Gaming TaxesTaxes are levied across all regulated online gambling products at a rate of 35% on GGR. Taxes are also levied on player winnings in Greece using progressive rates. Winnings are tax free as far as they amount to EUR 100. Under Articles 116 to 122 of Law 5219/2025, winnings from other online games, including online casino, are taxed per gaming session after the EUR 100 tax-free allowance, at 20% up to EUR 500 and 30% above EUR 500. Betting winnings are taxed per betting slip at 0% up to EUR 100, 2.5% from EUR 100.01 to EUR 200, 5% from EUR 200.01 to EUR 500 and 7.5% above EUR 500 (Articles 116(1)(b) and 120(b), Law 5219/2025). Lottery winnings are taxed per ticket, after a EUR 100 tax-free allowance, at 10% up to EUR 1,000 and 15% above EUR 1,000 (Articles 116(1)(a) and 120(a), Law 5219/2025). Winnings from gaming machines are taxed per gaming session, after a EUR 100 tax-free allowance, at 15% up to EUR 500 and 20% above EUR 500 (Article 120(c), Law 5219/2025, as amended by Article 69 of Law 5313/2026). Corporation tax is charged in Greece at 24%. ## Capitalisation / Bank guarantees Applicants for Type 1 and Type 2 licences must have paid-in capital of at least EUR 200,000 and must secure a bank guarantee of at least EUR 500,000. Simple casino licence holders must have a minimum initial capital of EUR 500,000 and EUR 5,000,000 after 5 years of operation. Wide-Range casino licence holders must have a minimum initial capital of EUR 1,000,000 and EUR 10,000,000 after 5 years of operation. Casino gross gaming revenue (GGR) is subject to state participation on a sliding scale: 20% up to EUR 100 million, 15% from EUR 100,000,001 to EUR 200 million, 12% from EUR 200,000,001 to EUR 500 million and 8% above EUR 500 million (Articles 372 and 374, Law 4512/2018). A municipal fee of 2% of GGR is payable to the municipality where the casino is located (Article 372(3), Law 4512/2018), and a special annual licence fee of 1% of GGR applies (Article 374(6), Law 4512/2018). From 1 July 2026, the tax on online-casino player winnings rose on a permanent basis: the EUR100 to EUR500 band moved from 15 percent to 20 percent, and the above-EUR500 band moved from 20 percent to 30 percent. The change is confined to online casino games; sports betting winnings are unaffected. The operator-side gross-gaming-revenue tax rate of 35 percent was not altered by this reform, so the immediate compliance lift falls on player-facing product economics for online casino verticals rather than on operator margin directly. Separately, the Hellenic Gaming Commission issued an official letter to supervised gambling providers on the incoming EU AML framework, referencing the February 2026 and October 2025 FATF Plenary statements on monitored and high-risk jurisdictions. This is regulator guidance rather than statute, so it could change more readily, but it signals that AML-alignment compliance work is beginning ahead of any formal enforcement deadline.

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06 · Can we move player money?

Payments and banking

Mixed

Payment to participate and pay-outs must be made by credit institutions, payment institutions or electronic money institutions established in Greece or another member state of the EU or EEA. Payment by cryptocurrency is prohibited and HGC has previously blacklisted websites permitting payment by cr…

Full analysis · 249 words

Payment to participate and pay-outs must be made by credit institutions, payment institutions or electronic money institutions established in Greece or another member state of the EU or EEA. Payment by cryptocurrency is prohibited and HGC has previously blacklisted websites permitting payment by cryptocurrency. Credit betting is also forbidden in relation to slot machines. Cryptoassets are not among the permitted deposit and withdrawal methods listed in Article 25.3 of Ministerial Decision 79835/2020. The active Hellenic AML Authority investigation centres on cash deposits via affiliate retailers credited to player accounts, directly implicating deposit-channel and funding-method integrity as live enforcement priorities. This affiliate-retailer cash-deposit vector is the primary payments risk identified recently: operators maintaining retail distribution networks or affiliate-retailer deposit arrangements must ensure these channels are subject to full KYC and transaction-monitoring controls equivalent to direct player deposits. The draft EEEP reform bill's facilitation-sanction regime — administrative financial sanctions of EUR 1,000 to EUR 2m per violation for ISPs, advertisers and third parties facilitating illegal gambling — can reach payment-adjacent intermediaries handling illegal gambling flows, extending the enforcement perimeter to payment processors and financial intermediaries. No standalone payments instrument or cross-border capital control specific to gambling has been identified beyond the AML scrutiny and facilitation-liability provisions. Greece operates within the EU single market payments framework, and no gambling-specific payment blocking regime analogous to those of prohibition jurisdictions has been identified. Permitted withdrawal methods and withdrawal timeline obligations are not covered here; operators should verify current EEEP technical standards for withdrawal processing.

Not reviewed Information added after the 20 Aug 2026 expert review — published for currency and labelled not reviewed.
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The draft omnibus bill proposes granting EEEP the power to compel banks to block transactions linked to unlicensed gambling operators. This would introduce a bank-level enforcement mechanism into the payments environment, targeting the unlicensed segment specifically rather than altering payment arrangements available to licensed operators. The provision remains unenacted as of this cycle, carried at Probable confidence, with no Tier-1 confirmation of passage into force.

Not reviewedRead update

The pending New Gambling Framework bill would require banks to block transactions linked to unlicensed gambling operators, extending enforcement directly into the payments rail. This is a confirmed, Tier-2 sourced provision, though it carries fragile durability pending the bill's parliamentary enactment. If passed as reported, this would materially narrow unlicensed operators' access to Greek banking infrastructure, reinforcing the DNS-blocking and platform-takedown measures being advanced under the same legislative package. No change to existing permitted payment methods for licensed operators was evidenced this cycle.

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07 · Can we advertise?

Marketing

Mixed

Online Gaming MarketingThe Hellenic Gaming Commission has regulatory oversight for gambling advertisements. Only licensed operators are permitted to advertise gambling products or services. The advertising of unlicensed gambling products can be sanctioned via a minimum two-year prison sentence and a…

Full analysis · 1107 words

Online Gaming MarketingThe Hellenic Gaming Commission has regulatory oversight for gambling advertisements. Only licensed operators are permitted to advertise gambling products or services. The advertising of unlicensed gambling products can be sanctioned via a minimum two-year prison sentence and a fine of up to EUR 200,000. Forthcoming reform (announced):The regulator has publicly indicated that a new legislative package planned for 2026 will introduce enhanced powers to immediately suspend or prohibit advertising for illegal gambling services, including action against affiliates, media outlets, influencers and advertising networks that promote unlicensed operators. This would mark a shift from reliance on post-factum criminal sanctions to faster administrative intervention. Law 4002/2011 contains restrictions put in place on the advertising or marketing of gambling products to consumers located in Greece. Prominently, Article 35 dictates that all forms of advertising must feature information concerning player age restrictions and the prohibition of self-excluded players from gambling. Article 35 also requires advertisements to feature the names and contact information of organisations which provide support and treatment to persons which suffer from problem gambling. The former Regulation on Commercial Communications (Decision No, 163/4C/2015, as amended by Decision No. 184/3/2015) was repealed by Article 13 of Decision No. 79292/2020. Article 8.3 of Decision No. 79292/2020 amongst other things prohibits gambling advertisements from: Adopting unfair commercial practices, such as containing misleading information or omitting information with the intention to mislead. Taking advantage of a lack of general knowledge on the part of consumers in relation to the chances of them winning. Giving the impression that the outcome of any gambling games played can be controlled or influenced through the use of superstitions, or that such superstitions can lead to positive outcomes. Implying that the skills of a player or the frequency at which they play can have an effect on the player’s chance of winning. Suggesting gambling can enhance a consumer’s personal qualities or be used as a way to obtain recognition or admiration from others. Recently, Greece has adopted Decision No. 79292/2020 into the gambling industry’s regulatory framework. This decision has imposed an obligation on operators to secure approval from the regulator for all gambling advertisements before publication, as well as banning gambling advertisements on the internet “either in the form of a pop-up window, such as pop-up, pop-under, overlays, or in any other form that restricts and/or obstructs browsing. Decision No. 79292/2020 is also comprehensive in setting out advertising restrictions designed to protect minors (in Greece, those aged under 21). In particular, commercial communications are prohibited from: Referring to or containing elements of minors’ mentality, habits and behaviour and/or use of phrases identified as being prevalent in the vernacular of minors. Presenting gambling as an activity which marks transition from adolescence to adulthood. Featuring real or fictional characters which are or seem to be under the age (21) at which participation in gambling is permissible. Being displayed before, during or right after the conducting or broadcasting of youth sporting events. Being displayed before, during or right after a radio / television programme targeted at minors. ## Demo games (play for fun): HGC Instruction 1/2026 HGC Instruction 1/2026 (HGC Decision 32/4/22.07.2026, Government Gazette B’ 4900/05.08.2026) implements paragraph 8.12 of Decision No. 79292/2020 and sets binding rules for demo or “play for fun” games offered online by licensed operators. The display and provision of a demo game by the operator is itself a commercial communication and is governed by Decision No. 79292/2020. Under the Instruction: a demo must be an accurate simulation of an HGC-certified game, must not involve any financial risk and must not allow real winnings or any other prize or reward, including entries for use in gambling; demos may be promoted only within the operator’s online gaming environment and may be played only after the player has logged into their player account; any third party, including affiliates, is prohibited from displaying or otherwise presenting demo games; each demo must follow the corresponding real-money game as to symbols and graphics, participation limits (max bet, max win), the prize distribution system, the paytable in force at any given time and the game guide information; a player’s total time on demo games may not exceed 20 minutes per calendar day; and the operator must notify the HGC of the demo games it intends to offer. Breaches are subject to administrative measures and sanctions under Ministerial Decision 125944/2020 (Government Gazette B’ 4884/2020). The Instruction formally applies from 1 September 2026. In September 2026 the HGC informally confirmed that the implementation deadline has been extended to 31 December 2026. The extension has not been published and, according to the HGC, was communicated only to licensed B2C operators. Although the Instruction is addressed to licensed B2C operators, it affects B2B game suppliers and platform providers in practice. Suppliers must keep demo and real-money versions aligned, and the safer reading is that playable demos should not be made available to users in Greece outside the operator’s logged-in environment, including through suppliers’ own websites or public demo libraries. Affiliate marketing has been recently regulated. Affiliates are subject to their own licence (Affiliate Suitability Licence) – Minimum requirements and low cost EUR 1.000 – one-off approval fee. Licence holders must ensure that commercial communication through affiliates follows the same terms, restrictions and safeguards that apply to the licence holder. Affiliates may not carry out the operator’s commercial communication directly with players or the public, for example through newsletters or RSS feeds (Part 5, HGC Directive 4/2021). Advertising service providers and affiliates may not provide services to illegal gambling operators (Article 11.2, Decision No. 79292/2020). Part 8 of HGC Directive 4/2021 distinguishes sponsorship from product placement and corporate social responsibility. It limits sponsored announcements to identity-type messages that are not linked to services, purchases, benefits or offers, and requires the +21 age limit to be shown with the brand in all sponsorship actions. Jerseys of sponsored teams are exempt, but individual athletes’ outfits and artistic outfits are not. Outdoor advertising must be located at least 200 metres from primary and secondary schools and boarding houses (Article 3.9, Decision No. 79292/2020). Commercial announcements may not promote bonuses, gifts, benefits or discounts linked to the cost of participation, except within loyalty programmes under Article 8.6 (Article 8.5, Decision No. 79292/2020). Advertising is overseen by the HGC under the Regulation on Commercial Communication (MD 79292/2020). Only licensed operators may advertise. Marketing must reference prohibitions for minors and self-excluded persons, include addiction-helpline information, avoid glamorising gambling or implying financial success, and must not promote credit for gambling. Advertising of unlicensed products is criminally sanctioned (minimum two-year prison sentence plus fines up to EUR 200,000). The NCRTV monitors broadcast gambling advertising.

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08 · What must the platform meet?

Technical compliance

Mixed

The EEEP-EETT DNS Response Policy Zone (RPZ) integration represents a new technical enforcement layer for domain-level blocking of unlicensed gambling sites, moving beyond the prior public blacklist model to active DNS infrastructure blocking. This confirmed development is sourced at Tier-2 and carr…

Full analysis · 107 words

The EEEP-EETT DNS Response Policy Zone (RPZ) integration represents a new technical enforcement layer for domain-level blocking of unlicensed gambling sites, moving beyond the prior public blacklist model to active DNS infrastructure blocking. This confirmed development is sourced at Tier-2 and carries fragile durability, as it rests on an inter-agency technical arrangement between EEEP and EETT rather than a codified statutory mandate. The mechanism integrates blocked domains directly into a dedicated Response Policy Zone within DNS infrastructure, giving the regulator a materially faster and more durable blocking capability than the previous blacklist-publication model. No other technical-compliance evidence, such as RNG certification or server-location rules, surfaced this cycle.

09 · Can we ship through apps and platforms?

Distribution and platforms

Mixed

## Infrastructure Operators must locate a server in the territory of Greece. Operators must grant the HGC access to stored data on the server for a period of at least ten years. Alternative safe storage devices must also be located within a member state of the EU or the EEA which acts as a form of …

Full analysis · 591 words

## Infrastructure Operators must locate a server in the territory of Greece. Operators must grant the HGC access to stored data on the server for a period of at least ten years. Alternative safe storage devices must also be located within a member state of the EU or the EEA which acts as a form of disaster recovery system where synchronisation will need to occur at least every 30 mins. The regulator has also signaled closer cooperation with telecommunications and domain-registration authorities, including the Hellenic Telecommunications and Post Commission (EETT), with the stated objective of accelerating the identification of gambling-related domains at or shortly after registration, thereby reducing the window during which illegal sites can access Greek consumers. The server requirement derives from Article 198(5) of Law 4635/2019. The electronic files and registers listed in Article 34.1 of Ministerial Decision 79835/2020 must be kept for at least ten years from the day after they are created, in a form that shows any corrections and gives the HGC immediate and easy access (Articles 34.2 and 34.4, Ministerial Decision 79835/2020). Personal data breaches must be notified to the Hellenic Data Protection Authority without undue delay and, where feasible, within 72 hours. Affected players must be notified without undue delay where the breach is likely to result in a high risk to them (Articles 33 and 34, Regulation (EU) 2016/679; Law 4624/2019). ## Integrations There is no requirement for integration with local regulatory or monitoring systems ## Software certification Holder of Type 1 and Type 2 licences must comply with the technical standards laid out in Law No. 4002/2011. Gaming machine technical standards can be also be found in Law No. 4002/2011. A list of technicians and testing laboratories approved by the HGC is linked here. The conditions that independent testing laboratories and certification bodies must meet for their reports and certificates to be accepted are set by HGC Decision 106/6/23.05.2014 (Government Gazette B’ 1432/04.06.2014). The HGC accepts laboratories that meet the applicable European or international standards and are accredited by the Hellenic Accreditation System (ESYD) or by a body with which ESYD has signed a mutual recognition agreement. Technical specifications for online gaming are set out in Ministerial Decision 79841/2020 (Government Gazette B’ 3266/2020). Quality management standards are based on ISO 9001 (Article 5.1(b)(kk), Ministerial Decision 79835/2020). Information security standards are based on ISO/IEC 27001, which applies to all systems, subsystems and software used for online gaming and to the intermediate control system under Articles 32 and 33 of Ministerial Decision 79835/2020. Licensed operators in Greece are subject to reporting and operational obligations administered by the EEEP under the Law 4002/2011 framework. The draft EEEP reform bill broadens EEEP's responsible-gambling coordination mandate, enabling it to commission research, develop national strategies to reduce unlicensed participation, and coordinate programmes across the sector. The EEEP-OHQA memorandum reinforces the responsible-gambling operational framework, and the planned Gambling Observatory will introduce Big Data and AI-based supervisory monitoring that operators will need to interface with. The government is signalling integration of betting age verification with secure government ID infrastructure, which will impose new technical obligations on operators' onboarding and age-verification systems once enacted. The active Hellenic AML Authority investigation into affiliate-retailer cash-deposit schemes highlights that existing KYC and deposit-channel monitoring obligations are under active scrutiny; operators must maintain robust controls over third-party deposit channels and affiliate-retailer arrangements. New operational obligations under the draft bill are anticipated but not yet enacted, and the precise scope of reporting, technical certification and RG operational requirements post-enactment will depend on the final gazetted text.

Not reviewed Information added after the 20 Aug 2026 expert review — published for currency and labelled not reviewed.
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Social-media promotion of unlicensed gambling by influencers and affiliates has become a live enforcement target in Greece. The Hellenic Gaming Commission filed legal complaints against 18 social-media influencers, with a combined 3.6 million followers, for promoting unlicensed gambling, and the Finance Minister has stated that popularity offers no immunity from the sanctions regime expanded under Law 5313/2026. This signals that affiliate-marketing and sponsorship-intermediary channels carrying unlicensed-operator promotion now face direct accessory-liability exposure under the Law 5313/2026 enforcement framework the HGC is actively implementing, rather than facing exposure confined to the unlicensed operators themselves.

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The draft omnibus bill proposes to grant EEEP the power to order internet service providers, platforms and search engines to remove or disable illegal gambling content, sites and accounts operated by unlicensed gambling businesses. This represents a new platform-level enforcement mechanism targeting distribution channels used by unlicensed operators, consistent with the civil-law pattern of statutory blocking regimes seen elsewhere in the family. The provision has cleared public consultation as of 15 June 2026 but remains unenacted, so no current legal obligation binds ISPs, platforms or search engines in Greece under this mechanism at this time.

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The most significant distribution-and-platform development this cycle is the new standalone advertising-liability offence created by Law 5313/2026, Article 66, amending Article 51 of Law 4002/2011. This durable statutory change establishes liability of EUR 5,000 to 50,000 for advertising or promoting unlicensed gambling, extending the enforcement perimeter beyond operators to affiliates, advertising networks, and media outlets that carry promotion for unlicensed sites. This is a material expansion of the distribution-liability perimeter compared with the prior operator-only enforcement focus, and it sits alongside the Hellenic Gaming Commission's continued blocking of unlicensed domains (approximately 11,000 blocked as of December 2025) as part of the broader platform-enforcement toolkit. No other distribution or platform-rule development — app-store, ISP-blocking-mechanism, or payment-provider-restriction change — was identified this cycle.

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This cycle's sole distribution-and-platform development concerns domain-level enforcement rather than app-store or advertising-platform rules. The Hellenic Gaming Commission is reported to be pursuing closer integration with EETT, the national telecoms regulator, with the aim of achieving near-real-time flagging of newly registered illegal-gambling domains, as part of the Commission's broader 2026-2030 strategic plan. This would mark a shift from the current post-complaint blocking model, under which approximately 11,000 cumulative domain blocks had been recorded by December 2025, toward a more proactive detection posture at the point of domain registration. The initiative is evidenced by a single tier-three source, with no regulator-published technical specification or implementation timeline located this cycle, and should accordingly be treated as an uncertain, forward-looking development rather than an implemented instrument.

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10 · How hard does the regulator enforce?

Enforcement

Mixed

## Regulating bodies The HGC has authority to review, suspend, and revoke operating licences where operator failings are identified. Law No. 4002/2011 prescribes both administrative and criminal sanctions for the provision of gambling services by unlicensed operators. The law makes provision for fi…

Full analysis · 1148 words

## Regulating bodies The HGC has authority to review, suspend, and revoke operating licences where operator failings are identified. Law No. 4002/2011 prescribes both administrative and criminal sanctions for the provision of gambling services by unlicensed operators. The law makes provision for findings of criminal liability against directors and controllers of offending companies. Article 52(3) of Law No. 4002/2011 deals with criminal sanctions for players who engage in unauthorised gambling. Under the law, anyone participating in unlicensed gambling as a player is liable for a prison sentence of up to three months, as well as a fine ranging from EUR 5,000 to EUR 20,000. ## Supervision by Regulator In January 2022, the HGC launched a whistle-blowing website to combat illegal gambling. Members of the public are now able to anonymously report illegal gambling activities, such as illegal betting sites, unlicensed affiliates, illegal revenue or revenue derived from suspected illegal gambling operations. ## Enforcement against licensed operators HGC took enforcement action against two casino licensees in January 2020, suspending the licences of Casinos Xhanti and Rio for a period of 2 months due to failure to pay social security bills. Article 51 of Law No. 4002/2011 sets out administrative sanctions which can be imposed against operators which act in contravention of Greek gambling laws and regulations. Under Article 51, fines of up to €2,000,000 can be imposed for infringements of the law. Under Article 52(1) of Law No. 4002/2011, anyone who offers online gambling services without authorisation will be liable for a prison sentence of up to three years and /or a fine of between EUR 200,000 and EUR 500,000. Anyone (including those that hold a license for games of chance) who convert an amusement skill gaming machine into a games of chance machine, shall be liable for a minimum 10-year prison sentence and a fine of EUR 200,000 to EUR 300,000. ## Typical triggers for enforcement against unlicensed operators No comment ## Enforcement action taken against unlicensed operators Update (Q4 2025):Enforcement against unlicensed online gambling has intensified markedly. By December 2025, the Hellenic Gaming Commission (HGC) reported that approximately 11,000 domains associated with illegal betting and gaming had been identified and blocked via the national blacklist, enforced through internet service providers and payment service providers. This represents a substantial escalation compared to earlier reporting periods. The HGC actively uses its power to blacklist, and therefore requiring ISPs to block, unauthorised websites. The 2021 HGC Activity Report saw 2,525 registered websites blacklisted. As mentioned below payment blocking is also imposed. Article 52(2) of Law No. 4002/2011 prescribes criminal sanctions for the advertising of unlicensed online gambling services to players in Greece. Under the law, anyone who engages in such advertisement will be liable for a prison sentence of at least two years with a fine ranging from EUR 100,000 to EUR 200,000. Article 52 par. 2d of Law 4002/2011 treats the illegal online provision of games of chance (i.e., non-recreational/ skill games) as a felony offence, in which case potential infringers may be sentenced to imprisonment ranging from a minimum of ten years to a maximum of 15 years. The HGC is empowered to operate a blacklist of unauthorised gambling operators whose services are made available to players based in Greece. Article 51(5) of Law No. 4002/2011 obliges internet service providers (ISPs) to block the websites of unauthorised operators which appear on the blacklist. ISPs which violate the law under Article 51(5) will be liable for a prison sentence of a minimum of two years and a fine of between EUR 100,000 and EUR 500,000. Notably, operators which have appeared on the HGC-maintained blacklist within the previous year are not eligible to apply for an operating licence. Similarly, Article 52(9) of Law No. 4002/2011 requires payment service providers (PSPs) and financial institutions to not permit financial transactions with operators which feature on the blacklist. Such PSPs or financial institutions which are found to have breached the provisions of Article 52(9) will be liable for a minimum term of imprisonment of two years and a fine of at least EUR 100,000. Regulatory commentary highlights that illegal operators routinely re-enter the market using newly registered or mirror domains, often shortly after blocking measures are applied. Public statements have noted the high volume of new gambling-related domain registrations globally, underlining the limits of domain blocking as a standalone enforcement tool and the need for more preventive mechanisms. Article 52(3) of Law No. 4002/2011 deals with criminal sanctions for players who engage in unauthorised gambling. Under the law, anyone participating in unlicensed gambling as a player is liable for a prison sentence of up to three months, as well as a fine ranging from EUR 5,000 to EUR 20,000. ## MoU Between Cyprus & Greece Regulators ## Date: 26 May 2025 What happened: CGCA (Cyprus) and HGC (Greece) signed a Memorandum of Cooperation during GREF 2025. Key areas: Exchange of best practices Joint initiatives against illegal betting Collaboration in training and capacity building Enhancement of compliance & transparency mechanisms ## Proposal for National Strategy Against Illegal Gambling ## Date: 2 April 2025 What happened: EEEP completed a study proposing the formation of a national strategy to fight illegal gambling (especially online). Key proposals: New unit or independent structure under HGC National framework involving public/private/academic stakeholders Empowered enforcement capability Urgent stakeholder consultation The enforcement posture in Greece has escalated materially in 2025-2026. The draft EEEP reform bill — not yet enacted — proposes a comprehensive expansion of enforcement powers: EEEP gains the ability to order immediate removal or disabling of illegal gambling content via rapid administrative procedure without prior police authorisation, with maximum sanctions including content and domain takedown and blacklist listing; Gaming Inspectors receive special investigative officer status enabling initiation of criminal pre-investigations and direct submission of case files to prosecutors; and EEEP and Inspectors are empowered to order immediate closure and sealing of premises for up to one year with licence revocation. The criminal sanction structure under a rationalised Article 52 of Law 4002/2011 establishes a two-tier system: organising illegal gambling carries a minimum of three years' imprisonment and fines of EUR 10,000 to EUR 500,000; gambling-related offences carry up to a minimum of ten years' imprisonment and fines of EUR 50,000 to EUR 700,000, with aggravated circumstances reaching EUR 800,000. Administrative financial sanctions of EUR 1,000 to EUR 2m per violation apply to facilitating third parties including ISPs, advertisers and intermediaries. For licensed operators, the most immediate enforcement risk is the active Hellenic AML Authority investigation reportedly scrutinising at least ten licensed operators over affiliate-retailer cash-deposit schemes, which operates under the existing EU AML framework and is not contingent on the draft bill's enactment. The unregulated sector enforcement theory follows the civil-law stack: primary licensing offence under the enabling statute, DNS and IP blocking, payment blocking and advertising prohibition, with the new facilitation-sanction regime adding a EUR 2m-per-violation ceiling for intermediaries.

Not reviewed Information added after the 20 Aug 2026 expert review — published for currency and labelled not reviewed.
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The Hellenic Gaming Commission has opened forty secondment positions within its Gaming Controllers' Corps, application deadline 6 November 2026, a staffing expansion explicitly aimed at operationalising the sanctioning powers granted by Law 5313/2026, enacted in June 2026. That statute allows the Commission to impose direct administrative sanctions, including fines of up to fifty thousand euro per violation, on any person promoting or facilitating illegal gambling, including through digital marketing channels and influencers. As a first visible outcome under this expanded regime, eighteen individuals are under investigation as of October 2026 for promoting illegal online gambling via social media. Taken together, the staffing build-out and the influencer-directed investigations mark a shift from a legislative posture, in which the June 2026 law sat largely unused, to an active operational enforcement posture targeting the promotional ecosystem around unlicensed gambling. The pinpoint statutory articles underpinning the advertising sanctions and any criminal-penalty provisions have not yet been confirmed against a primary gazette publication of Law 5313/2026.

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Greece's enforcement posture against unlicensed-gambling promotion tightened materially in this reporting window. The Hellenic Gaming Commission filed eighteen legal complaints against online influencers, whose combined audience reaches 3.6 million followers, for promoting unlicensed gambling under Law 5313/2026. Greece's Finance Minister publicly confirmed that the law is being actively implemented, a ministerial-level endorsement of an enforcement programme that reaches advertisers, internet service providers and third parties linked to illegal gambling alongside the influencers themselves. Penalties available under this framework span EUR1,000 to EUR2,000,000 per violation for advertisers, ISPs and other third parties, and EUR5,000 to EUR50,000 for influencers who promote or facilitate illegal gambling. As at 9 October 2026, this is an active and ongoing enforcement programme rather than an isolated action, and it represents an extension of Law 5313/2026's reach into the marketing and influencer channels through which unlicensed gambling is promoted to Greek consumers, rather than against unlicensed operators alone.

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The Hellenic Gaming Commission, operating under the Ministry of Finance, filed legal complaints against 18 social-media influencers with a combined audience of 3.6 million followers for promoting unlicensed gambling, following a ministerial briefing reported between 6 and 8 October 2026. The complaints are understood to be at a preliminary investigation stage. The accessory-liability basis cited is Law 5313/2026, which reportedly empowers the HGC to pursue promoters of unlicensed operators, including influencers and affiliates, and not only the operators themselves; the precise statutory pinpoint underlying this basis has not been independently confirmed. The Greek Finance Minister stated around 9 October 2026 that illegal gambling is now designated a criminal and economic threat and that Law 5313/2026, enacted in June 2026, is already being actively implemented. No HGC primary press release has been directly located confirming the complaints; the reporting rests on press coverage of the ministerial briefing. The clear risk driver for operators and their affiliate networks is that promotional reach confers no protection under this enforcement theory: sponsorship-intermediary and affiliate-marketing channels promoting unlicensed gambling are now a demonstrated target rather than a theoretical one.

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The draft omnibus reform bill, past public consultation as of 15 June 2026 but not yet enacted, would substantially expand EEEP's enforcement architecture. Proposed powers include ordering ISPs, platforms and search engines to remove or disable illegal gambling content, sites and accounts; compelling banks to block transactions linked to unlicensed operators; granting Gaming Inspectors special-investigative-officer status; and administratively sealing premises for up to one year. EEEP staffing is proposed to expand from 80 to 110 positions, materially increasing investigative capacity. These powers, framed against the civil-law statutory-licensing-stack theory, would sit atop the existing enabling-Act framework rather than replace it. As drafted, none of these powers is in force; the durability of the underlying instrument is not yet assessable because the bill has not reached enactment, and the Interpreter carries this at Probable confidence with no Tier-1 confirmation of Gazette publication or parliamentary passage this cycle.

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Greece's enforcement architecture rests on the Law 4002/2011 statutory licensing stack, with Article 51 as its central sanctions provision. This cycle, Law 5313/2026 (Government Gazette A' 102/25.06.2026), Article 66, amended Article 51 to create a standalone administrative offence for advertising or promoting unlicensed gambling, with fines of EUR 5,000 to 50,000 — a durable, primary-legislation change that materially expands liability to affiliates and media, distinct from the operator-focused offence. The pre-existing Article 51 fine band for unlawful operation or facilitation, EUR 1,000 to 2,000,000, remains in force and is durable. Active enforcement continuity is evidenced by the Hellenic Gaming Commission's reported blocking of approximately 11,000 unlicensed gambling domains as of December 2025, a Probable-confidence enforcement-volume metric. A further, T4-sourced and Uncertain signal reports a February 2026 draft bill proposing criminal penalties of up to ten years' imprisonment and fines up to EUR 800,000 for illegal-gambling organisers, which would represent a fragile-durability escalation toward criminal liability pending confirmation of primary legislative text.

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EEEP and EETT have established a DNS Response Policy Zone (RPZ) mechanism, moving beyond the prior public-blacklist model to active domain-level blocking of unlicensed gambling sites through direct DNS infrastructure integration. This confirmed development carries fragile durability, resting on an inter-agency technical arrangement rather than a settled statutory footing. The pending New Gambling Framework bill would grant EEEP rapid takedown powers over ISPs, search engines, social platforms and ad networks, a confirmed but not-yet-enacted expansion of accessory-liability enforcement reach. The same bill would additionally mandate that banks block transactions linked to unlicensed gambling operators, extending enforcement into the payments rail. All three developments are confirmed at Tier-2 sourcing but remain fragile pending the bill's parliamentary enactment. Together they represent a coordinated, multi-front enforcement escalation against the unregulated sector, spanning technical infrastructure, platform intermediaries and banking rails simultaneously.

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11 · What is coming?

Outlook

Mixed

Greece has recently implemented a broad range of regulations to apply to its gambling market. Such changes have served to substantially modernise the Greek regime, which on paper is now analogous to other established regimes in terms of its sophistication. The Greek gambling market and its regulator…

Full analysis · 139 words

Greece has recently implemented a broad range of regulations to apply to its gambling market. Such changes have served to substantially modernise the Greek regime, which on paper is now analogous to other established regimes in terms of its sophistication. The Greek gambling market and its regulator, the HGC, will likely now undergo a transitional period on the road to reaching full maturity as it reacts and assesses opportunities and challenges posed by market operators. For 2026 Greece is expected to maintain its existing licensing structure while adopting a more interventionist enforcement posture: intensified action against illegal online gambling, expanded advertising controls and a revised framework for land-based casinos. No liberalisation is signalled. Industry pressure to reduce the 35% GGR tax persists but no statutory change is in train; reform focus remains enforcement, possible affiliate tightening and digital monitoring.

Not reviewed Information added after the 20 Aug 2026 expert review — published for currency and labelled not reviewed.
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The principal item on Greece's reform horizon is the Hellenic Gaming Commission's exploration of a unified cross-platform player-identity verification system targeted at VIP and high-value customers, intended to close a loophole allowing multiple registrations across licensed operators. As at 13 October 2026, this remains an early, pre-consultation, regulator-led initiative: it is known only through trade-press reporting of an EEEP-hosted discussion, and no draft legislation or HGC notice has yet been located setting out its scope, timeline or legal basis. The initiative sits alongside Greece's existing licensing and enforcement framework under Law 5313/2026 rather than replacing or amending it, and its eventual form, whether a Hellenic Gaming Commission regulation or a legislative amendment, is not yet determinable from the available evidence. What would move this item forward is the publication of an HGC primary notice or consultation document defining the initiative's scope and the obligations it would place on operators handling high-value customers.

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The EEEP omnibus reform bill, "Regulations for the Hellenic Gaming Commission and Improvements to the Gaming Framework," completed public consultation on 15 June 2026 and remains pending parliamentary submission. As drafted it would expand EEEP enforcement powers substantially — site and account blocking, bank transaction blocking, premises sealing, expanded Gaming Inspector authority, and increased EEEP staffing from 80 to 110 positions — and would introduce a new tiered tax on online casino and poker winnings effective 1 July 2026 as proposed. No Tier-1 confirmation of Government Gazette publication or final parliamentary passage was found this cycle, so the bill's ultimate enacted form and timing remain open questions for the next cycle to resolve.

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An omnibus gambling-framework reform bill, titled "Regulations for the Hellenic Gaming Commission (EEEP) and Improvements to the Gaming Framework," closed public consultation in mid-June 2026 and is proceeding to the parliamentary process, at Probable confidence with fragile durability pending enactment. The bill covers illegal-gambling enforcement, HGC expansion, and winnings-tax changes, and proposes expanding HGC staffing from 80 to 110 — a durable increase in regulator capacity if enacted. Separately, a reported February 2026 draft bill would introduce prison sentences of up to ten years and fines of up to EUR 800,000 for illegal-gambling organisers; this is sourced only to a single T4 aggregator, rated Uncertain, and its primary legislative text has not been located this cycle. Together these signal a reform pipeline moving toward materially tighter enforcement and regulator capacity, though the most consequential elements — the criminalisation proposal and the winnings-tax change — remain unconfirmed by primary sources.

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The omnibus EEEP New Gambling Framework bill was submitted to the Greek Parliament in June 2026, with public consultation concluding 15 June 2026; it now awaits parliamentary enactment, with the final vote date not yet confirmed. Separately, EEEP is conducting a comprehensive review of the land-based casino licensing regime, with findings to be presented to the Ministry of Finance and a new framework targeted for spring 2026 implementation, though this rests on a single Tier-3 source and carries uncertain confidence. Together these two concurrent reform tracks, one online-enforcement-focused and one land-based-licensing-focused, indicate a broad structural overhaul of Greece's gambling regulatory architecture in 2026 rather than incremental adjustment. Confirmation of either the bill's enactment date or the casino review's final report would materially sharpen this outlook.

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The dominant reform-horizon item this cycle is the EEEP reform bill, formally titled Regulations for the Hellenic Gaming Commission and Improvements to the Gaming Framework. Public consultation on the bill closed on 15 June 2026, and it now awaits submission to Parliament. As drafted, it proposes increasing Hellenic Gaming Commission staffing from 80 to 110 full-time-equivalent posts and would grant Gaming Inspectors special investigative officer status, including criminal pre-investigation powers, sitting within the Commission's broader 2026-2030 strategic plan. As a consultation-stage instrument, the bill is fragile rather than durable pending enactment as primary legislation, and no primary-source statutory text has yet been retrieved; citation is expected to follow publication in the Government Gazette. Parliamentary submission and passage are the key events that would convert this from a proposal into binding law.

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Evidential record & source register 1 enforcement · 26 red flags · 13 sources · Expand full record

Enforcement record

What the regulator has actually done, newest first. 1 recorded event.

  1. 1 Dec 2025
    Hellenic Gaming Commission · ~11,000 foreign gambling sites
    Probable
    Sources

What gets operators fined

26 red flags (5 high, 16 medium, 4 low) and 5 controls that address them.

Controls

Worked scenarios

5 entry scenarios, each with the move we would make.

MT-licensed operator wants to serve GR players without GR licence.

Unlicensed activity is a felony; HGC blacklists and blocks via ISP/payment; directors face criminal liability.

Do this: Do not serve GR without an HGC licence; pursue Type 1/Type 2 application.

Sources

Operator seeks betting + casino in GR.

Must hold both Type 1 (EUR 3m) and Type 2 (EUR 2m) licences; both available to one entity.

Do this: Budget EUR 5m+ in fees plus guarantee; one entity may hold both.

Sources

Game studio wants to supply GR-licensed operators.

No operator licence needed; obtain HGC game certification (Decision 130/2).

Do this: Pursue HGC game certification; supply only licensed operators.

Sources

Operator evaluates GR P&L vs Malta.

35% GGR + 22% corporate vs ~5% Malta materially compresses margin.

Do this: Stress-test margins; GR viable only at scale.

Sources

Affiliate promoting offshore operator to GR players.

Advertising unlicensed products is criminal (min 2-yr prison + EUR 200k fine).

Do this: Promote only HGC-licensed operators.

Sources

What we looked for and could not find

Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall.

Competitive landscape. precise licensed-operator count and unlicensed-market-share % not published by HGC in retrieved sources.
Market opportunity. no single authoritative GGR point estimate in EUR from HGC in retrieved sources; figures conflict across market studies.

Source register

Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites.