MiCA Regulation – Authorisation Procedure for Crypto-Asset Service Providers

In its Decision No. 8/1059 of 30 July 2025, the Hellenic Capital Market Commission (HCMC) establishes the rules for the authorization procedure of crypto-asset service providers under its supervision under Regulation (EU) 2023/1114 (MiCAR).

On 30 July 2025, the Board of Directors of the Hellenic Capital Market Commission (“Authority”), the competent body for supervising the implementation of the MiCA Regulation in Greece in entities fall within its supervisory scope, has issued its Decision No. 8/1059 pursuant to Article 101(a) of Law 5193/2025. This Decision sets out the authorisation procedure for crypto-asset service providers ("Applicants”) that fall under its oversight.

The Decision establishes the rules regarding the method, procedures, and timeframes according to which an applicant for a crypto-asset service provider authorization will have the opportunity to successfully submit the application dossier to the Authority, in accordance with Article 62 of the MiCA Regulation.

It is noted that the Markets in Crypto-Assets Regulation (“MiCAR”) constitutes the EU’s first comprehensive regulatory framework for cryptocurrencies and related services. MiCAR introduces harmonised rules at the EU level for: (a) the issuance and offering of crypto-assets; (b) the operation and supervision of crypto-asset service providers (“CASPs”); and (c) consumer protection and market transparency.

The MiCAR entered into force in June 2023, and its provisions have been phased in gradually. Coming into full effect on 30 December 2024, thus encompassing crypto-asset issuers and service providers within its scope.

Under Articles 95 - 245 of Law 5193/2025, Greece has adapted its national legislation to align with the MiCAR framework, designating the respective supervisory authorities and authorization procedures.

Businesses operating in the cryptoasset markets must thus comply with the new requirements by 30 December 2025.

1. Preliminary Completeness Assessment

In its Decision, the Authority (Hellenic Capital Market Commission) has introduced a pre-application stage focused on assessing the applicant’s readiness and completeness of the authorization dossier, before formally submitting a  authorisation request.

In this early phase, a meeting is held between the applicant’s representatives and the Authority.

Prior to this meeting, the applicant must complete a relevant questionnaire, providing all necessary information concerning its activities and operations.

Through this process, the applicant receives an initial evaluation from the Authority, which facilitates the formal completeness check following the application submission—thereby making the  authorisation process more streamlined. However, the outcome of this preliminary assessment is non-binding on the Authority.

In addition, throughout this preliminary stage, the Authority may support the applicant in preparing its application, particularly in its alignment with MiCAR provisions.

To arrange this preliminary meeting, the applicant must submit a request via email to crypto@cmc.gov.gr.

2. Application, Evaluation and Authorisation

To initiate the formal  authorisation procedure before the Authority, the applicant must submit its application to be authorized, along with the dossier of supporting documents, as required by Article 62 of the MiCA Regulation, as well as by the Delegated Regulation (EU) 2025/305 and the Implementing Regulation (EU) 2025/306.

All feedback and documents may be submitted in either Greek or English.

The application form and the required supporting documentation, listed in Annex II of Decision No 8/1059, must be submitted in both hard copy and electronic form.

Following submission, the Authority's competent department issues an acknowledgement of receipt, which is recorded both electronically and in printed form.

Required Contents of the Application Dossier are as follows (Annex II of Decision No 8/1059):

• General Information
• Business Plan (program of activities)
• Capital Requirements
• Governance Framework, internal control mechanisms, conflict-of-interest management
• Business Continuity
• Plan AML/CFT Compliance (identification, anti-money laundering, combating terrorism financing)
• Verification of Integrity,
• Expertise, and Commitment of board members (identity, qualifications, dedication of sufficient time)
• Information on Shareholders or Members with Significant Stakes
• ICT Systems and Security
• Arrangements Client Asset and Crypto-Asset Segregation and Safe Custody Complaints
• Handling Procedures
• Trading Platform Rules and Market Abuse Monitoring
• Custody and Management Policies
• Crypto-Asset Exchange Procedures (with funds or other assets)
• Order Execution Policy
• Provision of Crypto-Asset Advice or Portfolio Management Services
• Cryptoasset Transfer Services
• Cross-Border Provision of Crypto-Asset Services (Article 65 MiCA).

Within five (5) working days from the date that the application is submitted, the Authority shall issue a written acknowledgment of receipt, for the purposes of Article 63(1) of MiCA.

Within twenty-five (25) working days of receipt, the Authority examines the completeness of the application and its dossier in accordance with Article 63(2) of MiCA.

If the application is deemed incomplete, the Authority informs the applicant accordingly and sets a deadline for completion, which shall not exceed twenty (20) days.

If a complete application is submitted, the Authority shall immediately inform the applicant. Thereafter, the Authority undertakes a substantive evaluation of the application within forty (40) working days from the date on which completeness is confirmed.

Upon completion of the evaluation, the Authority shall issue a decision approving or rejecting the authorisation. This decision is communicated to the applicant within five (5) working days of its issuance, in accordance with Article 63(9) of MiCA.

Otherwise, the provisions of Article 63 of the MiCA Regulation shall apply.