Gaming Law 2024 Comparisons

The key legislation in Greece with respect to gambling has been amended by Law 4635/2019. This Law has introduced a series of innovations to the long-standing regulatory regime, but has also imposed new restrictions. With regard to online gaming, in particular, Greece has achieved remarkable progress in market regulation, reflected in a cohesive legal regime already in force and several provisions governing almost every aspect of the online gaming segment.

The implementation of a whole new legal and regulatory regime in the Greek gambling market within a quite strict timeframe was definitively a success story for the Greek Regulator (the Hellenic Gambling Commission – ‘HGC’), despite its non-deniable drawbacks and shortcomings.

To date, more than 18 B2C online gambling operators have been granted licences, while the B2B market is also booming, since more than 140 online content providers have also acquired the respective licences. Affiliate marketing has also been regulated for the first time and there are currently 141 affiliate companies which are legally operating in the Greek online market.

Lastly, with respect to land-based gambling, the industry is said to be going through a difficult period, especially after the COVID-19 period and the lock-down restrictions, which boosted the online market and have taken a toll on land-based casinos. The HGC in co-operation with the Greek government is considering reforms to boost the industry (see 3.7 Recent or Forthcoming Legislative Changes).

The applicable legal framework provide for two different types of licences:

• The first type of licence is granted for online betting games, including fantasy sports, whereas the second type of licence is granted for online casino-type games. In the latter category, only casino games and poker (in all its variations) are licensable, which means that every other online game of chance is prohibited.
• No restrictions of any kind are imposed on social games with no monetary element in the outcome such as points or rankings, or in a form of virtual currency, which prohibits the player from waging/gaining real-world financial benefits through the redemption of attributes or the conversion of achievement for money or anything of monetary value. As such, social gaming is considered to fall outside the traditional gaming space and is operated freely without the need of being regulated and licensed.

Games such as betting, bingo, casino, lotteries, and poker are considered as games of chance, since the result of the game depends, even partly, on the influence of chance. Consequently, the conduct of these games is permitted only after a proper licence is granted from the HGC.

In this context, it must also be noted that the operation of video lottery terminals (slot machines – VLTs) is restricted to a maximum of 25,000 VLTs, the licences for which are granted to the official monopoly supplier, namely “OPAP SA” (Article 39, Law 4002/2011).

The main legislative act that governs gaming in Greece is Law 4002/2011, as published in Government Gazette 180 on 22 August 2011 and as amended by several consequent Laws.

Moreover, the Minister of Finance and the HGC have issued several Regulations, containing more specific rules with regard to gaming activity, with the most important being as follows:

• Decision No 56580/2022, which specifically regulates online gaming licensing;
• Decision No 509/1/2020, which regulates affiliate marketing;
• Decision No 79292/2020, which regulates marketing and commercial communication;
• Decision No 79835/2020, which regulates the conduct of online games of chance;
• Decision 14/2/2012, which regulates lotteries; and
• Decision 107/5/2014, which regulates video lottery terminal matters.

Pursuant to Article 25 of Law 4002/2011, the following conditions must be met in order for a game to be defined as game of chance:

• the result of the game must depend, even partly, on the influence of luck;
• there must be a wager or bet – ie, the choice of the player to undertake the risk of gambling on the result of the game – of any amount of money or any financial element regardless of its value, in order to seek an economic profit from the outcome of the game, directly or indirectly.

No special definition of land-based gambling is provided by the applicable Greek legal framework. However, it is generally accepted that games of chance are divided into those where the physical presence of the player is necessary (land-based), and those that can be conducted remotely, without the physical presence of the player, using the internet and telecommunication and/or other broadcasting systems.

“Online gambling” is construed to cover any online game conducted through the internet, which requires, in addition to the electronic and other supporting mechanisms (hardware), the presence and operation of a game software program that is incorporated or installed in it and contains all the information, instructions, and other details concerning the use and play of the game.

The provision and/or conduct of games of chance without having the required licence and/or proper certification is prohibited and constitutes a criminal offence under Greek law (Article 52 paragraph 1 of Law 4002/2011).

The participation in a game of chance conducted without a licence is also punishable, although in this case the criminal offence is a misdemeanour (Article 52 paragraph 3 of Law 4002/2011).

Lastly, whoever enters into a commercial communication for games of chance that are conducted or operated without a licence either as an advertiser or as an advertised entity (Article 52 paragraph 2 of Law 4002/2011) is also punishable.

The penalties provided for by the law vary, depending on the way in which the game is conducted.

If the games are conducted via gaming machines, the penalty is imprisonment for a term of at least three years and a monetary fine of between EUR100,000 and EUR200,000 per gaming machine.

If the games are conducted online, the penalty is imprisonment for a term of at least three years and a monetary fine of between EUR200,000 and EUR500,000.

If the game provided is a game of chance, the penalty is imprisonment for a term of at least ten years and a monetary fine of EUR700,000, regardless of the means of conduct of the games.

Whoever provides games without holding the required licence to this effect, if the games are not finally conducted, shall be punishable with imprisonment for a term of at least one year and with a monetary fine of between EUR70,000 and EUR150,000.

It is important to note that Article 52 paragraph 2d of Law 4002/2011 treats the illegal online provision of games of chance (ie, 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.

On August 2023, a draft Regulation was published by the HGC containing provisions regarding land-based casinos. The draft Regulation introduces several innovations, including the provision governing a Live Studio operation with a live dealer for land-based casinos in Greece.

The public consultation was concluded on 15 September 2023, but there has been no update since. It is unknown when and in fact whether the draft Law will be adopted by the Greek Parliament, although this would give the fading land-based casinos a boost, which was the rationale behind this draft piece of legislation.

The HGC is the key regulatory authority supervising the gambling sector.

The HGC was initially established in 2004 through Law 3229/2004, as an administrative authority under the name “Hellenic Gambling Commission”. In 2011, by virtue of Law 4002/2011, the Commission was renamed the “Hellenic Gaming Commission (HGC)”; in February 2012, by virtue of Law 4038/2012, it was converted and has functioned ever since as an independent administrative authority, enjoying full administrative and financial independence and autonomy, as per Law 3051/2002, without prejudice to the special provisions referring to it.

The law sets the prior authorisation (licensing) of all operators offering gaming and betting services as a general rule. As the competent authority, the HGC has issued several regulations concerning almost every type of gaming, in which every detail is laid down. The approach to regulation in Greece could therefore be characterised as prescriptive.

The HGC develops and implements three-year Action Plans, in order to achieve better management of the design, implementation, and evaluation of its work. In doing so, the Authority undertakes in advance the commitment to carry out specific and pre-planned work, so that its effectiveness is assessed on this ground.

Given the recent reform of the gambling market, there are no further changes anticipated in the near future in this respect.

A licence is only required for games of chance, whereas skill games are conducted freely (Articles 25–27 of Law 4002/2011).

The following points are of particular note:

• With regards to online gaming, there are two types of licences available to B2C operators:
1. “Type A” licence, regarding Online Betting; and
2. “Type B” licence, for “Other Online Games”, to which casino and poker games are included.

A Suitability Licence is also required for B2B companies (manufacturers, suppliers, and affiliates). All games and gaming machines, as well as the means used for conducting them, must be certified in accordance with the provisions of Law 4002/2011.

Licences for persons who supply facilities to the providers of games of chance are categorised into the following six certifications (Article 42 paragraph 1, 43):

• Certification “A”, for up to 30 slot machines in exclusively gaming facilities;
• Certification “B”, for up to 50 slot machines in exclusively gaming facilities;
• Certification “C”, for slot machines in mixed facilities;
• Certification “D”, for the installation of technical-recreational game machines on sea-going vessels;
• Certification “E”, for the installation of slot machines on sea-going vessels under the Greek flag, which are engaged in international voyages; and
• Certification “F”, for the installation of up to 15 slot machines in “ΟΠΑΠ Α.Ε.” agencies.

Lastly, casino licences are divided into simple type casino licences and wider range casino licences, depending on the available infrastructure (Article 359 of Law 4512/2018):

• simple-type casino licences include gaming areas and can also offer accommodation establishments of at least 3-stars or 3-keys classification, as well as shops and other facilities; and
• wider-range casino licences are for casinos that combine gaming facilities with accommodation establishments of at least 5-stars classification, as well as shops and other facilities and at least one installation of special tourism infrastructure (such as conference halls or golf course facilities) or one installation of special forms of tourism (eg, healing therapy centres).

Licences are “readily available” in the sense that there is no applicable numerus clausus. All applicants who qualify for a licence, provided they submit the requisite certificates and pay the corresponding fees, will obtain their licence. On average, online licences are granted by the HGC within two months following the filling of the application. If there is no response from the HGC within the two-month period, it can be considered as an implicit dismissal of the application.

Online B2B and B2C licences are valid for seven years and can be renewed following a new application. In case of a renewal, the fees must be paid anew. Affiliate licences have no expiry date.

The duration of casino licences depends on the category in question. Simple-type casino licences are valid for 15 years, while wider-range casino licences are valid for 30 years (Article 359 of Law 4512/2018).

The common application requirement for obtaining a gaming licence of any type is the absence of criminal convictions for felony crimes or financial offences (such as theft, fraud, tax evasion, etc), or sexual, gun, or drug-related offences of the directors and ultimate beneficial owners (UBOs) of the applicant.

With regards to online B2C operators, the following requirements must be met:

• applications shall be made only by capital companies with a paid-up share capital of at least EUR200,000;
• a Letter of Guarantee is required, which shall be equal to EUR500,000 and issued from a bank established and operating lawfully in Greece or another EU member state; and
• in order to receive a licence, the legal entity must maintain a safe server in Greece, which will be connected to the HGC, according to Article 30 of Law 4002/2011.

The applicant entity is also required to have a permanent residence or a registered establishment in Greece or in another member state of the EU or the European Economic Area (EEA). The gambling domain names must have the suffix “.gr”, and, in case the applicant is neither registered nor maintains a branch in Greece, it must appoint a local representative (a process agent).

The timescale for licence applications depends on a series of factors, such as the applicant company’s corporate structure, the translation workload, and the apostille requirements. On average the HGC will conclude the review of the application within one to two months following submission. The preparation of the application, though, may take several months, depending on the level of readiness of each applicant.

Land-Based Market

According to Article 50 paragraph 10 of Law 4002/2011, the application fees to be paid are determined by a Decision of the Minister of Finance upon the recommendation of the HGC. On the basis of said provision, Decision 92/2014 was published in the Government Gazette (Section B, 545/05-03-2014), which provides for a fee amounting to EUR50 per slot machine.

Online Market

As per Article 45 paragraph 4 of Law 4002/2011, the application fee to be paid for an online B2C licence amounts to EUR10,000.

Regarding B2B licences, the application fees depend on the specific category of the B2B licence. Online B2B licence applications also each entail a fee ranging from EUR250 for hardware manufacturers and up to EUR5,000 for online content providers and aggregators.

Land-Based Market

The aforementioned Decision of the Minister of Finance also provides for an annual fee, amounting to EUR50, which must be paid in advance. An annual fee is also applied in the case of B2B providers.

Online Market

The annual fee for the maintenance of an online B2B licence ranges from EUR500 to EUR25,000.

Premises licensing requirements are described in detail in Article 45 of the HGC’s 115/2/2014 Regulation.

One of the basic requirements for granting a premises licence is to provide the name of the company and the beneficial owner, as well as a full list of all slot machines.

Moreover, a qualified engineer’s official document is required, to certify the safety and suitability of the premises, as well as their suitability for hosting gaming activities.

On 3 August 2023 the HGC published a new draft Regulation containing provisions regarding land-based casinos, which introduced several innovations such as:

• the use of an individual player card for participation in games of chance conducted in casinos;
• the redesign of the player exclusion process;
• the new framework of responsible gaming and player protection and the creation of a register of banned players;
• employee training procedures;
• the operation of the Information System of Supervision and Control (PSEE); and
• the provision of online Live Dealer Studio operation within the land-based casino.

The draft Regulation remained under public consultation until 15 September 2023. Following the receipt of the proposals submitted by the stakeholders, it is estimated that the HGC will submit a completed proposal to the Minister of Finance. It is noted that legislative work is the sole responsibility of the Ministry of Economy and Finance and broad consultations are carried out in accordance with the procedure foreseen for all bills. Final decisions and legislative drafting are the responsibility of the Ministry and/or the Greek Parliament, and the HGC can contribute to any area where requested.

There are two types of licences available to online B2C operators:

• “Type A” licence, regarding “Online Betting”, which also includes fantasy sports; and
• “Type B” licence, for “Other Online Games”, including casino and poker games.

B2B licences are available to software providers, suppliers, and hardware manufacturers. More specifically, content providers, aggregators, and other software providers fall under the scope of Category A1 or Category A2 “Manufacturer Suitability Licence”, depending on whether they offer management services to operators or not, while suppliers fall under the scope of a “Suppliers Suitability Licence”. Regarding manufacturers who manufacture hardware used in Live Dealer Studios and other equipment, they fall under the scope of Category D “Manufacturer Suitability Licence”.

Affiliate marketing was regulated for the first time in the recent amendments, which were adopted by the Greek Parliament in 2020. Affiliates should also acquire an “Affiliate Suitability Licence” and be registered in the HGC’s online Register of Affiliates.

White-label providers are not recognised by the current gambling laws.

There are no changes anticipated in the near future.

Pursuant to Article 48 of Law 4002/2011, as amended by Article 173 paragraph 14 of Law 4261/2014, the HGC drafts and revises a list of illegal gaming providers (blacklist) who provide services of land-based games, online games, or by remote gambling. This list is posted on its website, and this post is adequate notification and proof to start proceedings for the imposition of sanctions from all competent bodies, services, or authorities. The list mentions the entities providing illegal services of games of chance and/or their legal representatives, administrators, members of the board of directors, partners, and shareholders, as well as any other proven violation and imposed sanction.

The listed entities cannot be granted a licence, nor can they participate in any other way in a licensed body for providing game services in Greece. The Gaming Operation and Control Regulation regulates the time period of maintenance of the record, as well as the condition for its release.

According to this list, ISPs are obliged to immediately transmit the data of a legal entity or individual that has the ownership, use, and/or responsibility for the operation of these websites to the HGC, so as to start the proceedings for the imposition of sanctions provided by the legislation.

One of the key responsible gaming requirements introduced by Law 4002/2011 is the use of an individual player’s card. The player’s card was provided in order to ascertain the player’s age – through the identification of the registered data (such as tax registration number) – and maximum participation time, and to guarantee that any additional restrictions imposed by the players themselves are observed. It is worth mentioning that the age standard applied in Greece is higher than in most other countries. Significantly, access to minors and persons under 21 years old is not permitted in places where gambling is conducted.

The individual player card may be issued by licence holders pursuant to the procedure and terms and conditions laid down in an HGC decision, published in the Government Gazette. Gaming without an individual player card is strictly prohibited.

Specifically, in order to participate in games of chance conducted by slot machines or via the internet, the publication and the use of a unique card by each player is required, so that the additional restrictions of the player and/or the HGC are ensured. The restriction of use of a unique personal card may be extended by the Gaming Control Regulation, even to games of chance all over Greece. The individual player card may be issued by holders of permits in accordance with the procedure and conditions established by the HGC.

There are no changes anticipated in the near future.

Licensees should provide information about services against addiction, by displaying all the relevant details on every store and screen where gambling is occurring, in a measure aimed at combating gambling addiction. Additionally, the use of a unique card by each player is required, so that the additional restrictions posed by the player (eg, self-exclusion) and/or of the HGC are ensured.

The key AML legislation is included in Law 4557/2018, which was published on 30 July 2018 and incorporated Directive 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing. Law 4557/2018 is divided into two parts. The first part (Articles 1–46) incorporates the provisions of Directive 2015/849:

• scope and definitions of the law;
• the basic offences;
• the obliged entities and the due diligence requirements;
• the beneficial ownership information;
• the responsibilities of the competent authorities; and
• the criminal and administrative sanctions.

The second part (Articles 47–51) includes the organisational provisions for the Anti-Money Laundering Authority.

Furthermore, important AML guidance relevant to the gambling sector is provided by Decision 554/5/2021 of the HGC (see 8.2 Recent or Forthcoming Changes). One of the HGC’s main goals is to safeguard public and social interest, public revenues and the legitimacy of the gambling providers, in the stages of both licensing and operating. In this context, the HGC monitors the implementation of its provisions regarding AML/CTF to casinos, casinos on board vessels under the Greek flag, enterprises/businesses, and organisations and agencies that organise and/or conduct gambling in Greece, plus their land-based agencies.

According to Law 4557/2018, the HGC is the competent authority for monitoring the implementation of its provisions according to AML/CTF, in casinos, casinos on board under Greek flag, enterprises/businesses, organisations, and agencies who organise and/or conduct gambling in Greece, plus their land-based agencies.

On 21 April 2021, the HGC adopted the Decision 554/5/2021, which is a Regulation on the implementation of measures to combat money laundering criminal activities and the financing of terrorism by the Responsible Persons in the gambling market pursuant to point (f) of Article 28(3) of Law 4002/2011. The Regulation outlines a procedure of establishment and operation of an independent internal audit function to verify the implementation of the application of internal policies, preventive controls and procedures, and compliance with the provisions of the AML Law and the AML Regulation via a compliance officer. Moreover, the regulation sets out an authentication and verification process of the identity of the player of games of chance conducted via a Player’s Electronic Account.

Article 4 of Decision 554/5/2021 of the HGC provides for the existence of a compliance officer, who takes every measure necessary in order for money laundering to be avoided, including due diligence measures and the reporting of every suspicious transaction to the competent authorities.

All licensees must implement the procedures and measures suggested by the compliance officer, and also have the duty to monitor themselves on an ongoing basis for the possible conduct of suspicious or unusual transactions.

The Hellenic Gaming Commission is the regulatory/supervisory authority regarding advertising.

“Advertising” or “commercial communication” means any form of communication designed to promote, directly or indirectly, the goods, services, or image of an undertaking, organisation, or person engaged in gaming activities, as well as any information that allows the immediate access to those games and, lastly, the communication about products or services of the company that operates in the gaming sector.

With the purpose of better regulating advertising activities, the HGC has issued the 106/2/2014 Decision, as amended by its 163/4/2015 Decision, where specific rules and restrictions are imposed.

Paragraph 2 of Law 4002/2011 provides that any commercial communication, direct or indirect, regarding entities providing credit to players in order for them to participate in games of chance is prohibited.

Furthermore, restrictions are posed mainly by the HGC’s 163/4/2015 Decision, which provides in Article 3 that advertising “...cannot aim to encourage consumers’ natural propensity to gamble by stimulating their active participation in it, for example, by trivialising gambling, or increasing the attractiveness of gambling by means of enticing advertising messages holding out the prospect of major winnings.”

Anyone who enters into a commercial communication for games of chance that are conducted or operated without a licence either as an advertiser or as an advertised entity (Article 52 paragraph 2 of Law 4002/2011) is punishable with potential imprisonment, ranging from a minimum sentence of two years to a maximum sentence of five years. This offence is considered a misdemeanour.

Decision 9322/2020 of the HGC adopts the EU Directive 2/2020 on the procedure for the management and evaluation of Gambling Commercial Communication Plans (CCPs). Pursuant to the said Decisions, B2C operators are instructed to draft and send their commercial plans to the HGC for approval.

Every licence holder who wishes to proceed with a disposal of shares at the percentage of 2% of the total share capital or more is obliged to report it to the HGC. In the event of inheritance, there is an obligation to report it to the HGC within 15 days of the inheritance (Article 47 of Law 4002/2011, as amended by the adopted omnibus bill).

Acquisitions that lead to a direct or indirect change of corporate control must be approved in advance by the HGC, or will be considered to be null and void. Furthermore, non-observance of the obligation to report the changes of corporate control entails the deprivation of corporate rights and transactions relating thereto (Article 47 of Law 4002/2011, as amended by the adopted omnibus bill).

Under Greek Law the notion of corporate control shall exist in the following cases:

• when a shareholder holds the majority of voting rights in a company;
• when a shareholder has the right to appoint or discharge the majority of the company’s directors/board members;
• when a shareholder has the right to exercise dominant influence over the company, either by virtue of a contract entered into with the company or a provision of the company’s incorporation document or articles of association; or
• when a shareholder has, independently, under an agreement entered into with other shareholders of the company, the majority of the voting rights, or, being the shareholder and the following jointly applying:
1. when the majority of the members of the administrative, management, or supervisory bodies of the company, who have been in office during the current and previous fiscal year, have been appointed only as a result of the exercise of voting rights;
2. when the voting rights held by the parent entity represent at least 20% of the total voting rights in the subsidiary;
3. when no third party has the rights under bullet points one to three above in respect of the company; or
4. when a shareholder has the power to exercise or exercises actual control or dominant influence on the company.

No special requirements for passive investors in acquisitions or changes of control are provided.

There are no further changes anticipated in the near future.

The monitoring of all gambling is the responsibility of the police, if it takes place without a licence. In all other cases, the HGC is the only competent authority and has been equipped by law with broad and important powers in order to efficiently supervise and regulate every gambling activity in the country (Article 52A of Law 4002/2011).

The HGC takes all measures necessary to effectively regulate the gaming market. In serious breaches, criminal and administrative sanctions are the most likely methods of enforcement, due to their direct and onerous character.

The HGC’s activity is rapidly increasing, as the HGC itself points out in its annual reports. In the latest blacklist there are over 6,000 illegal B2C operators and the said list is updated every three months by the HGC.

Law 4002/2011 and HGC Decision 23/3/2012, as amended by HGC Decision 51/3/2013, provide for administrative penalties for the infringers of its provisions.

The administrative penalties pursuant to Article 51 of Law 4022/2011 provide that, in a violation of any provisions of the Law or of its regulatory decisions issued under the motion or conditions of licences, by decision of the HGC, a fine of EUR1,000 to EUR2,000 or a percentage of gross receipts can be imposed, per violation or per game machine, depending on the severity and frequency of the offence, or the licence can be recalled temporarily for up to three months, or permanently.

At its discretion, the HGC may provide instructions, guidelines, and recommendations for the infringers to comply with the law, before imposing any administrative penalty, non-compliance with which constitutes an aggravating factor when imposing the administrative penalty (amendment issued by Law 4261/2014).

There are no further changes anticipated in the near future.

According to Article 50 paragraph 8 of Law 4002/2011 and Decision No 1248/2011 (issued by authorisation of the provision of Article 50 paragraph 12 of Law 4002/2011 and published in the Government Gazette, Section B, 2854/2011) of the Deputy Minister of Finance, the profits deriving from the exploitation of the online gaming market shall be subject to tax, according to the general provision of Income Taxation. Moreover, the Greek state participates in the profits deriving from the exploitation of games of chance in general, at a rate of 35%, 20% of which is consequently spent on social policy and other good causes (Article 50 paragraph 5, 6). On horse race betting, the amount withheld and spent on good causes is 30%.

Customer winnings are also subject to tax. According to Article 60 of law 2961/2001, as replaced by Article 22 paragraph 18 of Law 4141/2013, which pertains to the taxation of customer winnings, the winnings from online chance games played through columns are subject to tax per game column, after the deduction of an exempted amount of EUR100, at a rate of 15% for winnings up to EUR500 and at a rate of 20% for winnings of EUR500.01 or more.

With regard to chance games played through gaming sessions, the winnings are paid or credited to the player at the end of the gaming session, and are subject to tax per gaming session, after the deduction of an exempted amount of EUR100, at a rate of 15% for winnings up to EUR500 and at a rate of 20% for winnings of EUR500.01 or more.

According to the definitions provided by the same law, games played through gaming sessions refers to the chance games played through gaming machines as well as the chance games of a casino type, the result of which is not produced by means of a random number generator, known as live casino games, such as, indicatively, poker tournaments. A gaming session is the time period starting from the moment the player inserts his/her individual playing card into a gaming machine or from the moment the player is connected to the central informative system (KPS per its Greek initials) of an online gaming server (internet provider) by inserting the data of the individual playing card, and ending when the player either extracts the individual playing card from the gaming machine, or is disconnected from the KPS of the internet provider. In any case, each gaming session ends 24 hours after the player inserts their individual playing card into a gaming machine or is connected to the KPS of the internet provider by inserting the data of their individual playing card.

All the above refers to the entities regulated under Article 50 paragraph 12 – ie, holders of interim licences.

There are no further changes anticipated in the near future.

Ministerial Decision 56580/2022 sets out the personal authorisations and licences that are applicable to individuals. These personal licences are known as Suitability Licences and vary depending on the type of gambling activity. The following individuals are required to obtain a Suitability Licence:

• shareholders and managers (CEOs, directors, etc) of online B2C operators;
• persons performing key functions, such as: a) members of the board of directors; b) the CEO, executive directors and administrators; c) the gaming operations officer; d) the regulatory compliance officer; e) the head of finance and accounting; f) the head of commercial policy and commercial communications (marketing/advertising); g) the head of customer service and support; h) the head of information and communication technologies; i) the anti-money laundering/terrorist financing (AML/FT) compliance officer; j) the risk management and fraud prevention officer; k) the head of internal audit; and l) the head of logistics and human resources management.
• in the case of a land-based casinos, the following individuals, who are considered to perform ‘key functions’: a) the head of security, audit and supervision; b) the gaming staff management and supervision officer; and c) the games of chance technical means and materials management and maintenance officer.

Suitability Licences are readily available and have an indefinite duration (ie, they are valid unless they are revoked).

In order to obtain a Suitability Licence, directors and shareholders must meet certain requirements which are laid down in Articles 3, 6 and 9 of Ministerial Decision 56580/2022. These requirements pertain to an individual’s criminal record (which must be clear from specific offences), as well as past professional (or other) involvement in the gambling industry.

The application process is completed exclusively online through the HGC website. There is an application fee of EUR50, an approval fee of EUR50, and an additional annual maintenance fee of EUR50.

There is an annual maintenance fee of EUR50 (see 13.2 Ongoing Annual Fees).

In accordance with Article 9.5, the individuals holding a personal Suitability Licence are subject to the following licence conditions:

• they must not have been convicted by a final court ruling of a felony or have been subject to any penalty for theft, embezzlement, fraud, breach of trust, anti-money laundering, extortion, forgery, active or passive bribery, bodily harm, concealing a crime, currency relates offences, crimes which are commonly considered dangerous, crimes against personal freedom, sexual offences, drug offences, weapons, explosives or tax evasion, crimes related to the wider financial sector and crimes specified in the legislation on games of chance, in Greece or abroad;
• they must not be declared bankrupt or have been forced to wind up their business, be in receivership and/or in any other similar situation.

The HGC has the power to permanently revoke the personal Suitability Licence if the requirements are not met at any stage.

There are no further changes anticipated in the near future.