Buy-side acquisition · Greece
Buy a CASP in Greece — MiCA-authorised crypto licence
If you need an EU crypto-asset passport and want a fresh MiCAR jurisdiction without Cyprus’s MiFID-stack overhead, an authorised Greek CASP is now buyable. Cadena brokers HCMC-supervised CASP and ex-VASP targets to acquirers only. Buy-side mandates, no listings, no double-ending.
Why Greece for a MiCA-CASP
A late-mover jurisdiction that built its rulebook to MiCAR’s exact shape
Greece arrived at crypto supervision later than France, Germany or Cyprus, and that turned out to be an advantage. There was no domestic crypto licensing regime to retrofit. Law 5193/2025, enacted on 11 April 2025, simply implements Regulation (EU) 2023/1114 (MiCA) into Greek law across Articles 95-245 and names the Hellenic Capital Market Commission as the competent authority. The HCMC then issued Decision No. 8/1059 of 30 July 2025, the procedural rulebook for CASP authorisation under Article 101(a) of Law 5193/2025. Clean architecture, no legacy regime to negotiate around.
For an acquirer the practical implications are three. The HCMC drafts and reviews authorisation files in English natively, which removes a layer of translation friction common in southern European jurisdictions. Greek MiCAR sits beside an active capital-markets supervisor with a settled MiFID II file (the HCMC has been the national securities regulator since 1991) rather than a stand-up crypto unit. And the HCMC’s procedural timetable under Decision 8/1059 (5 + 25 + 40 + 5 working days, with a 20-day applicant-cure window) is more determinate than the open-ended timelines several other member states are running while their authorisation pipelines build out.
Scope
What an HCMC-authorised CASP licence permits
The MiCA-CASP authorisation issued by the HCMC covers the ten Title V services: custody and administration of crypto-assets on behalf of clients, operating a trading platform for crypto-assets, exchanging crypto-assets for funds, exchanging crypto-assets for other crypto-assets, executing orders on behalf of clients, placing crypto-assets, reception and transmission of orders, providing advice on crypto-assets, providing portfolio management on crypto-assets, and providing transfer services for crypto-assets. The HCMC authorisation document specifies which combination of services the firm is permitted to perform; scope can be expanded later through an amendment file under MiCA Article 65.
Statutory minimum capital follows MiCA Annex IV tiering: EUR 50,000 for Class 1 (orders, advice, portfolio management), EUR 125,000 for Class 2 (custody, exchange, placement), EUR 150,000 for Class 3 (operation of a trading platform). Safeguarding obligations sit at the centre of HCMC supervision: segregation of client crypto-assets and funds from the firm’s own balance sheet, written custody and key-management policies, and ICT/DORA compliance evidenced at authorisation and re-tested under ongoing supervision. AML obligations under Greek Law 4557/2018 (as updated for MiCA), fit-and-proper assessments of management body and qualifying shareholders (Annex III questionnaires of Decision 8/1059), and Bank-of-Greece consultation on any ART/EMT issuance round out the supervisory perimeter.
The transitional clock
Greek VASPs that missed the 30 December 2025 cutoff are no longer trading legally
Greece chose not to use the full 18-month MiCA transitional regime that some member states extended to legacy virtual-asset firms. Under Greek implementation, VASPs registered with the HCMC under AML Law 4557/2018 had until 30 December 2025 to file a complete MiCA-CASP application. Firms that filed on time can operate during HCMC examination; firms that did not are unable to provide crypto-asset services in Greece and face the criminal exposure that Article 110 of MiCA (combined with Greek penal provisions for unauthorised financial activity) attaches to operating without authorisation.
For acquirers, the relevant population now divides into three. There are firms that filed a clean MiCA-CASP application before 30 December 2025 and are awaiting HCMC decision; these are mid-process targets where the queue position has value. There are firms that already hold a granted CASP authorisation: fewer in number, premium pricing, but the cleanest acquisition file. And there are ex-VASPs that lost the right to operate; these are not buyable as licensed entities (no licence to transfer), only as shell vehicles with a customer book that has nowhere to land. The first two categories are where buy-side mandates concentrate.
Binance’s MiCA-CASP application to the HCMC, filed on 23 January 2026, is the visible signal that Greece is positioning as a passporting hub rather than a backwater. When a flagship applicant chooses Greece over the obvious Cyprus or Malta routes, it tells you something about how the HCMC is being received by the larger crypto operators.
Mandate scope
What we broker on Greek CASP mandates
Our typical buy-side acquirer here is a non-EU exchange or wallet operator that needs an EU passport without the Cyprus CIF/CASP cap-table complexity, a payments group already running an EMI on the Greek or pan-European stack and bolting crypto-asset custody onto it, or a digital-asset infrastructure firm wanting an English-drafting MiCAR base. We pre-vet targets on the diligence gates that decide CASP transactions: HCMC supervisory standing (no open enforcement, clean Annex III shareholder questionnaire history), banking continuity (which Greek or pan-European bank holds operational and segregated client accounts, and whether they survive a change of beneficial owner), AML programme depth (KYC vendor stack, Travel Rule readiness under Recast Funds Transfer Regulation, transaction-monitoring rule coverage), and key-personnel retention through closing. Greece is a small enough market that two or three people often hold the institutional knowledge.
We never list assets. We do not represent sellers. Mandates are exclusive to one acquirer per target file. That alignment is the point of working with a buy-side broker.
Process
How the acquisition runs
We sign your mandate, build the target longlist against your scope (in-process applicants, granted CASPs, defensible ex-VASP shells), run sourced approaches under NDA, and shortlist the two or three names that survive a first-pass diligence. From there we run regulatory diligence in parallel with the HCMC change-of-control submission, so the approval clock under Annex III is moving while the SPA is being negotiated. Expedited closings on regulator-approved targets are the norm when the change-of-control file is filed early. The full step sequence sits at our process page.
Why Cadena
Three reasons acquirers brief us on Greek targets
- We map the HCMC pipeline, not just the published register. A granted CASP authorisation appears on the HCMC website. The mid-process applicants do not, and that is where most of the buyable population sits in 2026. We track which Greek firms filed before 30 December 2025, which queue position they hold, and which are funded for the runway through HCMC decision.
- We file change-of-control early under Annex III. Most Greek deals stall not on commercial terms but on the qualifying-shareholder review, because acquirers treat it as a closing condition rather than the critical-path workstream it is. We file the Annex III questionnaires on the strength of an executed term sheet, before SPA signing, and pull HCMC approval onto the deal calendar.
- Buy-side only. The seller has their own counsel or runs the process directly. We are paid by you, sit on your side of the diligence table, and have no fee tail on the seller closing with someone else.
FAQ
Greek CASP acquisition questions we get asked
Can you buy a CASP licence in Greece rather than apply for one?
Yes. Acquiring an HCMC-authorised CASP (or a target with a complete in-process MiCA-CASP application filed before 30 December 2025) transfers the licence or queue position to your group, subject to HCMC change-of-control approval under the Annex III qualifying-shareholder review. The authorisation does not require re-issuance after closing; the existing licence number persists with the new beneficial owner of record. That is why acquisition runs faster than a de novo application even with the regulatory file added.
What does a MiCA licence in Greece authorise the holder to do?
Provide any of the ten MiCA Title V crypto-asset services within the scope listed on the HCMC authorisation: custody and administration of crypto-assets, operating a trading platform, exchanging crypto-assets for funds or for other crypto-assets, executing orders for clients, placing crypto-assets, reception and transmission of orders, advice, portfolio management, and transfer services. Once authorised the firm can passport into other EU/EEA member states under the MiCA notification procedure, with the HCMC as home regulator.
Are there CASP licences for sale in Greece, and is acquisition faster than de novo authorisation?
The pool is small. Greece’s MiCAR file only opened on 30 July 2025 and the first CASP authorisations are issuing through 2026. A modest cohort of granted CASPs and a larger group of mid-process applicants are reachable through buy-side outreach. Acquisition is faster because the substantive HCMC authorisation work (governance, capital, ICT, AML programme, key personnel) has already been done and reviewed; the change-of-control file is a parallel shareholder review, not a fresh substantive examination. Run early, the two close together.
How does the HCMC handle change-of-control on an authorised CASP?
Through the Annex III questionnaires of Decision 8/1059, which the HCMC uses to assess the proposed acquirer’s qualifying shareholding under the same fit-and-proper standards applied at de novo authorisation: source of funds, beneficial-ownership transparency, integrity, and proposed post-closing governance. The review runs in parallel with any pending substantive licence file and does not reset the authorisation timeline of the target. Filing the questionnaire early on the strength of an executed term sheet, rather than after SPA signing, is the lever that compresses closing.
What happens to Greek VASPs that didn’t transition to a MiCA CASP licence by 30 December 2025?
They are no longer authorised to provide crypto-asset services in Greece. The Greek implementation closed the AML Law 4557/2018 VASP register’s grandfathering window on that date. Firms that did not file a complete MiCA-CASP application by then must cease activity. Operating without HCMC authorisation after the cutoff exposes the firm and its directors to the criminal sanctions that attach to unauthorised financial activity in Greece. For acquirers, ex-VASPs without a filed MiCA-CASP application are not licensed assets and should be priced as shells or customer-book transfers, not as regulated targets.
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