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Online Gaming in Greece

Authored by - Paola Menachem (Last updated July 2024)

Overview

Open

Greece Online Gaming Overview

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. the 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.

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.

Competitive landscape
Online gaming is the fastest growing sector in Greece, growing to 36% market share of all gambling in the country in 2021. The full list of operators is set out on the HGC website.

Localisation
Payment to participate and pay-outs must be made by credit institutions, payment institutions or electronic money institutions established in Greece or in any other member state of the EU or EEA. Payment by cryptocurrency is prohibited.

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

Licensing & Regulation

Well-regulated / Unregulated (Open)

Greece Online Gaming Licensing & Regulation

Online Gaming Licensing & Regulation
Greece has recently updated its licensing regime, where Law No. 4635/2019 entered into force in October 2019 to amend the regulatory framework provided under Law No. 4002/2011.

Four detailed technical regulations have also been published including:

The Technical Regulation on the suitability of persons The Technical Regulation on commercial communication The Draft Ministerial Decision on...

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Enforcement

Light touch

Greece Online Gaming Enforcement

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...

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Marketing

Restricted

Greece Online Gaming Marketing

Online Gaming Marketing
The 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.

Law 4002/2011 contains restrictions put in place on the advertising or marketing...

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Fees

High

Greece Online Gaming Fees

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...

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Taxes

High

Greece Online Gaming Taxes

Online Gaming Taxes
Taxes 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. Winnings from EUR 100.01 to EUR 500 will then be taxed at a rate of 15%....

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Future Outlook

Positive

Greece Online Gaming Future Outlook

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...

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Legal Expert

Greece – Paola Menachem

Paola, is founder and owner of Counsel on Demand Ltd, a boutique consultancy firm specializing in Greek and International betting and gaming law and regulatory compliance. Utilising her extensive past experience as legal and compliance counsel at Intralot Group, Zeal Group, Smithfield Partners London and Group Director of Regulatory and Licensing at Maxima Compliance Ltd, Paola has advised some of the worlds’ largest gaming and lottery corporations in multiple jurisdictions. Paola also owns gamingingreece.com and allgamblingcompliance.com

Paola Supports International Clients and delivers legal and business advice, legal due diligence, and opinions in relation to Greek/UK/European and International law with a concentration in:

  • Gaming and Gambling: Serves both B2B and B2C international clients performing online and land-based licensing, compliance, AML, due diligence, platform licensing, taxation worldwide, focusing mainly on the UK, Malta, Greek and US markets
  • Compliance: Translates regulations into action and ensures clients understand and adhere to legislation; provides legal and strategic business advice to ensure agreements are consistent with internal corporate policies and processes; prepares and completes submissions of license variations and renewals to strict deadlines in Europe and US States of NJ and PN USA and other jurisdictions; manages and supervises regulatory projects (pre-compliance assessment for AML, RG, GDPR) and licensing; responsible for the regulatory compliance for Licensees in USA, UK, Malta, Greece and other EU jurisdictions; Checks improvement measures are put in place by licensees; conducts regulatory investigations where required; acts as a key point of contact for regulatory compliance and licensing matters worldwide
  • Policies: Creares and implements policies and practices to ensure regulations are followed
  • Legal: Negotiates, drafts and reviews a range of legal agreements, from commercial, data protection and cloud computing to IT–related matters, including marketing, services, sales, and licensing; advising on suitable jurisdictions for online operators from a tax and technical perspective; advertising, marketing and sponsorship arrangements
  • Intellectual Property and Copyright: Extensive knowledge of copyrights and related rights, IT and AI, intellectual property, trademarks, legal agreements, and related matters. Protecting the Intellectual property of casinos, gaming equipment manufacturers and online gaming websites
  • GDPR compliance

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Contact Greece - Greece – Paola Menachem

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