Buy-side acquisition · Greek PI
What an acquirer is actually buying
Most acquirers come to Greece for one of two reasons. They want a Eurozone payments perimeter without the Lithuanian queue, or they want a southern-EU corridor into the Balkans, Cyprus and the wider eastern Mediterranean. A Greek payment institution gives both. The licence sits squarely inside the PSD2 framework, the regulator is well staffed for fintech files, and the entity carries fewer of the historical tax-loss complications that affect carve-outs in some neighbouring jurisdictions.
Cadena Brokers represents the buyer only. We do not split fees with sellers and we do not carry sell-side mandates. Every Greek PI that reaches your desk through us has been pre-vetted on three dimensions: regulatory standing with the Bank of Greece, banking continuity (whether the entity’s correspondent and operating banking will survive the change of control), and AML / sanctions exposure. The seller’s broker, if any, sits on the other side of the table.
Why Greece
Bank of Greece, PSD2, and a passportable EU perimeter
Authorisation and prudential supervision of Greek payment institutions sits with the Bank of Greece (Τράπεζα της Ελλάδος) under Law 4537/2018, which transposes Directive (EU) 2015/2366 (PSD2) into Greek law. The licensing regime is fleshed out by Bank of Greece Executive Committee Act 164/13.12.2019, which sets out the application form, supporting-document specification, and the supervisory expectations the Bank applies on file scrutiny.
Once authorised, a Greek PI can passport into all 26 other EU member states under PSD2 Title II, Chapter 2. In practice, the passport is exercised through notification to the Bank of Greece, which forwards the file to host-state competent authorities. The reach is uniform on paper. It is asymmetric in correspondent banking, since northern-EU receiving banks apply enhanced diligence on funds originated through Greek-supervised PIs, so the practical value of the passport depends on the acquirer’s banking corridors. We screen for that during diligence.
One use-case that recurs: a stablecoin issuer or non-EU PSP that needs a Eurozone payments leg without standing up a parallel EMI. A Greek PI bolted to a MiCA-authorised CASP elsewhere in the EU is a clean structure, with the PI handling fiat on/off-ramps and the CASP handling the crypto-asset services side. The Greek licence is not exotic; it is the exact tool the structure calls for.
Scope
What the licence permits
A Greek payment institution may provide any of the services in PSD2 Annex I: maintaining payment accounts, executing payment transactions (direct debits, credit transfers, card-based payments), issuing payment instruments and acquiring payment transactions for merchants, money remittance, payment-initiation services (PISP) and account-information services (AISP). The application defines the scope; the authorisation tracks it.
Statutory minimum initial capital is set by Article 7 of PSD2 and applied directly through Law 4537/2018. €20,000 covers money-remittance only. €50,000 covers PISP only. €125,000 is the threshold for the full perimeter (account services, payment instrument issuing, merchant acquiring, execution of payment transactions). The Bank of Greece may require own funds above the statutory floor where the Bank’s risk-based methodology indicates it. We surface that risk-loading expectation early in our diligence.
Safeguarding under Article 10 of PSD2 takes one of two forms: segregation of users’ funds in a credit institution that is not part of the same group, or a comparable insurance / guarantee mechanism. The choice the seller has made affects banking-continuity risk at the change of control. A safeguarding bank that is willing to keep the segregated account live under new ownership is the difference between a clean closing and a forced re-papering of the entire operating posture.
Acquiring a qualifying holding (≥ 10%) in a Greek PI requires prior approval from the Bank of Greece. The Bank assesses the acquirer’s financial soundness, fitness and propriety, AML history and the impact of the change on the institution’s continuing compliance with the licence conditions. The dossier covers ultimate beneficial ownership, source of funds, governance after closing, and the acquirer’s prudential profile. This is the gate. If any acquirer’s brief mentions that the licence “transfers automatically”, the brief is wrong.
What we broker
The Greek PI book
The Greek PI entities we present to acquirers are typically smaller than their Lithuanian or Irish counterparts but carry cleaner regulatory histories. Profile-level (no entity disclosure):
- Authorised under Law 4537/2018, holding a service scope that lines up with the acquirer’s brief — generally execution of payment transactions plus money remittance, sometimes PISP.
- Operating banking with a Greek systemic credit institution, plus at least one EU correspondent bank with a documented willingness to remain through change of control.
- AML programme aligned to Bank of Greece Executive Committee Acts and the Hellenic FIU’s typology guidance, with the manual, training records, and transaction-monitoring rule set ready for handover.
- Compliance and finance heads who will stay through transition (FTE retention is a material diligence gate; we screen for it).
- No active enforcement actions, supervisory letters or open AML findings as of the most recent regulatory standing letter.
Profiles vary. Some entities have unused passporting; some have already notified into 4–5 host states. Some carry a tax-loss carry-forward; some have never been profitable enough to generate one. The brief drives the screen.
Acquisition process
From brief to closing
You send us an acquisition brief — service scope, banking corridors, deal size envelope, target closing window. We match against the Greek PI book and present pre-vetted profiles inside a workable shortlist. Diligence runs against regulatory standing, banking continuity, AML programme, FTE retention and material contracts in parallel. The change-of-control file goes to the Bank of Greece while transactional terms are negotiated. See the full four-step process.
Why Cadena
Buy-side mandate, Greek-PI fluency
- Single-side fees. We are paid by the acquirer. There is no seller’s commission silently embedded in the headline price; the seller has its own counsel.
- Bank of Greece file fluency. The Executive Committee Act 164/2019 dossier is the document Greek transactions stall on. Acquirers who arrive with a half-built file lose months. We arrive with the file.
- Banking continuity is in scope from day one. Greek correspondent banking under change of control is the single most common reason a Greek PI deal slips. We screen for it before the licensee enters your shortlist.
- PSD3-aware diligence. The 2026 transition is rewriting the e-money / payment-institution boundary, the safeguarding rules, and the operational-resilience documentation acquirers inherit. Our diligence packs reflect that, not the 2018 statute alone.
FAQ
Greek payment institution acquisitions
How do I buy a payment institution in Greece?
You acquire the share capital of a Greek company that already holds a payment institution authorisation from the Bank of Greece under Law 4537/2018. The acquirer signs an SPA with the seller, and in parallel files a change-of-control request with the Bank of Greece for prior approval of the qualifying holding. Closing is conditional on the Bank’s no-objection. Cadena runs the process from brief through closing on the buyer side; we never represent the seller.
What is the minimum capital for a Greek payment institution?
Statutory minimum initial capital under PSD2 Article 7, transposed by Law 4537/2018, is €20,000 for money-remittance only, €50,000 for payment-initiation services only, and €125,000 for the full payment-services perimeter. The Bank of Greece may require own funds above the statutory floor where its risk-based methodology indicates it; we surface that during diligence so the acquirer is not surprised post-closing.
Do I need Bank of Greece approval to acquire a Greek payment institution?
Yes. Acquiring a qualifying holding (≥ 10% of capital or voting rights) in a Greek PI requires prior approval from the Bank of Greece under the change-of-control provisions implementing PSD2 Article 6. The Bank assesses the acquirer’s fitness and propriety, financial soundness, AML history and the impact of the transaction on the licensee’s continuing compliance. Approval is a condition precedent to closing in every Greek PI deal we run.
Can a Greek payment institution passport into other EU member states?
Yes. Once authorised, a Greek PI may passport its services into the other 26 EU member states under PSD2 Title II, Chapter 2 — either by establishment of a branch, by appointment of an agent, or by direct cross-border provision of services. The passport is exercised through notification to the Bank of Greece, which forwards the file to the host-state competent authority. Practical reach in northern-EU correspondent banking varies; we screen the existing passport posture and corridor receptivity during diligence.
What is the difference between a Greek PI and an EMI?
A Greek payment institution provides payment services under PSD2: moving money on behalf of users. A Greek e-money institution issues electronic money, a stored-value claim against the issuer that users can spend. The two regimes overlap in practice (most EMIs also provide payment services), but the licensing thresholds, safeguarding rules and prudential capital are different. PSD3, expected to apply through 2026, folds e-money institutions into the payment-institution category as a sub-class. Acquirers comparing PI vs EMI should also weigh that consolidation in the medium term.
What changes under PSD3 for Greek payment institutions?
PSD3 (provisional EU agreement reached in 2024–2025, transition through 2026) folds e-money institutions into the payment-institution category as a sub-class, harmonises the authorisation timeline at three months from a complete application, updates statutory minimum initial capital for inflation, and aligns safeguarding rules across member states. The accompanying Payment Services Regulation (PSR) places greater operational-resilience and incident-reporting demands on national competent authorities, which translates into tighter supervisory expectations on licensees. Cadena’s diligence packs reflect the PSD3 baseline as well as the current Law 4537/2018 framework.
Acquisition mandate
Open a Greek PI brief with Cadena
Send a one-page acquisition brief — service scope under PSD2 Annex I, banking corridors, deal-size envelope, target closing window. We match it against the Greek PI book and revert with a pre-vetted shortlist. The Bank of Greece change-of-control file is the document deals stall on; we arrive with it.
Open a Greek PI mandate See extended licence coverage
Sibling jurisdictions: Cypriot PI · Irish PI · Lithuanian EMI · PI / API family hub
