Payment and e-money institution licensing in Greece: where founders get stuck

Authorisation as a payment institution or e-money institution in Greece sits within the Greek legal framework established by Law 4537/2018, which transposes PSD2, and Law 4021/2011, which transposes the E-Money Directive, and is supervised by the Bank of Greece.

For founders building a payments or e-money business, the authorisation process is often described as a filing exercise. In practice, it is closer to a structuring exercise — the questions that most affect the timeline are usually resolved before the application is drafted, rather than during the review process.

Choosing the right authorisation

PSD2 defines several categories of regulated payment service, while authorisation as an electronic money institution follows a distinct regulatory track from authorisation as a payment institution. Businesses that combine e-money issuance with payment initiation or account information services therefore need to map their actual activities against the relevant regulatory categories at an early stage. Under-scoping the authorisation application can create a regulatory gap once the business begins providing the relevant services; over-scoping, by contrast, may result in additional capital, governance and compliance requirements that are not yet necessary for the business.

Governance and safeguarding are substantive, not procedural

Applicants are assessed on their governance arrangements, internal control mechanisms and — critically — their arrangements for safeguarding users’ funds. The safeguarding structure can have practical implications for the institution’s relationships with banks, insurers or guarantors, making it important to address those arrangements before the authorisation application is submitted rather than having to put them in place later.

Passporting and the cross-border question

A Greek authorisation carries EU passporting rights, allowing payment and e-money institutions to provide authorised services in other EEA Member States, subject to the applicable notification procedures. For businesses planning a pan-European go-to-market strategy, this can be an important consideration when choosing Greece as the licensing jurisdiction. Passporting notifications to the relevant authorities in the host Member States are a separate procedural step from the initial authorisation and should therefore be factored into the planning from the outset.

This article is for general information only and does not constitute legal advice. For advice on a specific matter, please contact us.