title: Greece — Enforcement: How hard does the regulator enforce? | advennt.io canonical: https://advennt.io/jurisdictions/greece/enforcement/ [Jurisdictions](https://advennt.io/jurisdictions/) [Greece](https://advennt.io/jurisdictions/greece/) Enforcement Greece · Question 10 of 11 # Enforcement: How hard does the regulator enforce? Mixed · Probable · Expert approved · 5 post-review updates · Not reviewed · In expert review scope · [Back to full Greece report →](https://advennt.io/jurisdictions/greece/) Key section parameters | Jurisdiction | Greece (GR) | |---|---| | Regulator | HGC | | Favourability | Mixed | | Confidence | Probable | | Review status | Expert approved · 5 post-review updates · Not reviewed · In expert review scope | | Last collected | 18 Oct 2026 | Summary answer ## 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… Not reviewed Information added after the 20 Aug 2026 expert review — published for currency and labelled not reviewed. 18 Oct 2026 Not reviewed 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. 12 Oct 2026 Not reviewed 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. 22 Sep 2026 Not reviewed 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. 19 Sep 2026 Not reviewed 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. 6 Sep 2026 Not reviewed 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. ## Full section analysis ## 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.