Buy-side acquisition · Greece
Buy an EMI in Greece
Greek e-money authorisation sits with the Bank of Greece, which has approved only a handful of EMIs to date. For acquirers who want a Eurozone foothold without the de novo wait, the supply side is small and well-supervised, and that is exactly the page you are on.
Why Greece
Bank of Greece supervision, EU passporting reach
Greek EMI licences are issued by the Bank of Greece (Τράπεζα της Ελλάδος) under Articles 9 to 30 of Law 4021/2011, the Greek transposition of the second E-Money Directive. The framework was further aligned with PSD2 by Article 107 of Law 4537/2018, and the operational rulebook is set by Bank of Greece Executive Committee Act 164/2/13.12.2019 (with supplementary Act 178/2020 on safeguarding and own-funds calculation).
An EMI authorised in Athens passports across the EEA. That is the structural point: a Greek licence-holder can issue and redeem electronic money, execute payment transactions, and offer an IBAN-bound account into 30 markets without re-authorising in each one. Acquirers using the Greek route are typically wallet operators, B2B settlement platforms, or fintech parents that want a Eurozone-domiciled issuer attached to an existing tech stack, and don’t want a 12-to-18-month BoG file as the critical-path item.
Supply-side context worth knowing: as of late 2024, the Greek EMI roster sat at five: Cosmote Payments, Otro Pay, Tora Wallet, Viva Payment Services and the newly-authorised EveryPay (Skroutz Group). That is a tight market. It also means change-of-control transactions get genuine BoG attention rather than a cursory file-check, which is something Cadena handles upfront in diligence.
What the licence permits
Scope, capital, safeguarding
A Bank of Greece EMI may issue, distribute, and redeem electronic money; execute the full PSD2 payment-services list (account servicing, credit transfers, direct debits, card acquiring, money remittance, payment-initiation); grant short-term credit linked to payment services where permitted; and provide ancillary FX and operational services. The statutory minimum initial capital is EUR 350,000, set in Article 10 of Law 4021/2011. That figure is fixed at law, not a fee schedule.
Two operational obligations matter to an acquirer’s diligence. First, safeguarding: client funds received in exchange for issued e-money must be held separately under ECA 164/2/13.12.2019, typically in a credit-institution segregated account or covered by a qualifying insurance policy. We verify the safeguarding arrangement and the daily reconciliation evidence (not the policy on paper) before any introduction. Second, change-of-control approval: any prospective acquirer of a qualifying holding must apply to the Bank of Greece for prior approval, satisfying the fit-and-proper assessment and the source-of-funds chain. That timeline is the gating item on most Greek EMI deals.
AML supervision sits under Law 4557/2018 (the Greek 4AMLD/5AMLD transposition), with the Bank of Greece as the financial-sector competent authority. We screen each book entry’s existing AML programme, training records, and SAR submission history against current Bank of Greece supervisory expectations.
What we broker here
Pre-vetted Greek EMIs, ready for change of control
Cadena maintains a confidential book of Bank of Greece-authorised EMIs whose owners are open to a change-of-control transaction. We do not name entities publicly. Each book entry has been pre-screened across three diligence gates: (a) regulatory standing, covering authorisation status, recent BoG correspondence, capital adequacy, and the absence of open enforcement; (b) banking continuity, covering the current safeguarding-account provider, indicative confirmation that the relationship survives a UBO change, and a fallback if it doesn’t; (c) AML programme depth, covering KYC tooling, transaction-monitoring rules, MLRO tenure, and the compliance headcount you will inherit.
FTE retention is part of the diligence brief. A Greek EMI without its compliance team is a shell, and the Bank of Greece reads it that way. We mark the key-person risk on every introduction.
Acquisition process
From shortlist to closing
The acquirer signs an NDA, receives a curated shortlist matching scope and capital posture, and selects one or two entities for full diligence. We coordinate the change-of-control filing with Bank of Greece counsel and run the SPA / closing mechanics in parallel with the regulatory file. Expedited closings are the norm for buyers who arrive with funded SPVs and clear UBO documentation.
Why Cadena
Single-mandate, acquirer-only
- Buy-side only. Every conversation we have is with a buyer. No sell-side conflicts, no two-sided fee structures, no “introducing the seller’s broker” theatre. Greek sellers reach us through counsel and intermediaries; you reach us as the principal.
- BoG-literate diligence. Our diligence templates are built around the Bank of Greece change-of-control file specifically: the documentation set, the fit-and-proper questionnaire, and the supervisory-expectations gap list a Greek file gets graded against.
- Banking continuity is a deal gate. A Greek EMI losing its safeguarding bank mid-transaction is a real risk in this market. We sequence diligence to surface that risk before the SPA, not at closing.
FAQ
Acquirer questions, answered
What is the EMI license requirements profile in Greece?
For a Bank of Greece EMI, the statutory minimum initial capital is EUR 350,000 under Article 10 of Law 4021/2011. The applicant entity must have its head office and effective management in Greece, two qualifying directors who pass the fit-and-proper assessment, a safeguarding arrangement compliant with ECA 164/2/13.12.2019, an AML programme aligned with Law 4557/2018, and an IT and operational risk framework adequate for the planned business model. For an acquired entity, those obligations transfer with the licence, but you inherit the existing structure, which is precisely why the diligence has to be honest.
How do you acquire an EMI license in Greece?
Two routes. Apply de novo to the Bank of Greece (typically a 12-to-18-month process from pre-application meeting to authorisation grant), or acquire a qualifying holding in an already-authorised Greek EMI under the BoG’s change-of-control approval regime. The second route is what Cadena handles. The acquirer files a qualifying-holding notification, satisfies the fit-and-proper and source-of-funds tests, and the Bank of Greece either approves, opposes within the statutory window, or requests further information. The licence stays alive throughout. There is no “re-authorisation”.
What is the cost of an EMI license in Greece?
The statutory minimum initial capital of EUR 350,000 is the only fixed-by-law figure that matters at the planning stage; everything else (legal, technical, operational set-up) varies with deal structure. For an acquisition, the relevant economics are the SPA price for the target entity, the post-closing capital top-up if any, and the ongoing operational cost base of the acquired team. Cadena scopes those numbers per shortlist entry rather than quoting a “Greek EMI cost” headline that would be meaningless across different targets.
How long does a change-of-control approval take at the Bank of Greece?
The Bank of Greece works to the EMD2/PSD2 statutory window for qualifying-holding decisions. In practice the clock starts only when the file is complete, and the file is the part acquirers control. With UBO documentation, source-of-funds chain, and the new business plan all front-loaded, expedited closings are achievable. With incomplete files, the BoG will pause the clock and request more. That is the normal failure mode, and the one the acquirer prevents through preparation, not negotiation.
What is EMI licensing under Greek law versus other EU member states?
The substantive scope is harmonised. All EU EMIs operate under EMD2 (Directive 2009/110/EC) and PSD2 (Directive 2015/2366/EU), so the service permissions and passporting rights are essentially identical. Differences sit in the supervisory style: the Bank of Greece is a smaller, hands-on regulator with a tight roster of EMIs (five, late 2024), which means files get individual attention but also genuine scrutiny. For acquirers comparing Greece against, say, Lithuania or Malta, the trade is supervisory depth versus volume of supply: Greece has the depth, less of the supply.
Ready to see the Greek EMI shortlist?
One NDA, one curated shortlist, one principal-to-principal conversation. No seller-side fees.
