An EU investment firm licence is a single legal object with two very different lives. On paper, an authorisation granted by the Hellenic Capital Market Commission in Athens carries the same MiFID II permissions as one granted anywhere else in the European Economic Area. In practice, the name on the certificate changes how quickly a correspondent bank returns your call, how an acquirer prices your card traffic, and whether a liquidity provider asks for extra collateral. Both things are true at once, and founders who only look at the first one get an unpleasant education in the second.
What the HCMC actually supervises
The HCMC is Greece's capital markets authority. Its remit covers investment firms, collective investment schemes, market operators, and the conduct of participants in the Greek securities market. Authorised investment firms in Greece are known by the local abbreviation AEPEY, and the permissions they can hold follow the MiFID II menu: reception and transmission of orders, execution of orders on behalf of clients, dealing on own account, portfolio management, investment advice, and the ancillary services that sit alongside them.
Two points matter for anyone reading the Greek register. First, prudential oversight of financial firms in Greece is split, with the Bank of Greece responsible for credit institutions and certain other supervised entities, so the HCMC is not the only supervisory name a Greek group may sit under. Second, a permission to receive and transmit orders is a narrower thing than a permission to deal on own account. A retail contracts for difference business that internalises client flow needs the dealing permission, and the capital requirement is scaled to the permissions applied for rather than being a single headline figure. If you are reading a firm's register entry to decide whether it can legitimately quote you a price, read the permission list, not the licence number.
The passport is real, and it is narrower than it looks
An AEPEY firm can notify into other member states and serve clients there under the EU passporting regime. That part works. What does not travel is everything a host state keeps for itself: national marketing restrictions, language requirements for disclosures, local complaints handling expectations, and in several countries additional conduct rules layered on top of the EU minimum. The retail leverage limits that came out of the ESMA intervention apply to Greek firms as they do everywhere else in the bloc, and there is no arbitrage between member states on that point.
Greece is also a small home market. That has one underrated consequence: a supervisor with a modest number of authorised investment firms has more attention per firm than a supervisor overseeing hundreds. Founders who expect a quiet regulator because the country is small usually have that backwards.
Nothing here is legal advice. Authorisation requirements change, and the only reliable reading of them for your specific business model comes from Greek counsel and the authority itself.
Who accepts a Greek licence
This is the question that decides whether the business functions, and it splits by counterparty type rather than by country.
Banks and correspondent banking. A euro area investment firm with an EU authorisation clears the first filter at almost every European bank, because the entity type is recognised and the supervisor is a known EU authority. The filter that follows is about your business, not your flag: leveraged retail products, high volumes of small inbound payments, clients in jurisdictions with weak controls, and any exposure to sanctioned regions. De-risking decisions are made on that profile. A Greek licence does not save a file with clients in ten high risk countries, and an offshore registration does not sink a file with clean, domestic, well documented flows as fast as people assume, although it makes everything harder. The realistic reading of banking for trading firms is that the licence gets you into the conversation and the client mix decides the outcome.
Card acquirers and PSPs. Acquirers classify leveraged trading into their higher risk categories regardless of member state. That classification drives pricing, rolling reserves, and chargeback monitoring thresholds. An EU authorisation is usually a prerequisite for a European acquirer to look at the file at all, so a Greek licence moves you from impossible to expensive rather than from expensive to cheap. Read how high risk merchant categories work before you build a revenue model around card deposits.
Liquidity providers and prime brokers. Institutional counterparties care about the regulated entity, the balance sheet behind it, and the credit terms. An EU licence is table stakes for many of them. Collateral terms are then negotiated on your financials, not your postcode.
Platform vendors, app stores and ad platforms. Software vendors will generally contract with any lawfully authorised firm. App stores and the large advertising networks operate their own financial services verification programmes, and those programmes typically ask for proof of authorisation in the countries you intend to target. This is where an offshore registration fails loudly: it is not that the ad network dislikes the jurisdiction, it is that the verification form asks for a regulator and a reference number valid in the target country and there is nothing to type in. Firms serving EU clients from an offshore registration hit that wall constantly.
When Greece is the right answer, and when it is not
An HCMC authorisation makes sense for a firm with genuine Greek or south eastern European operations: local staff, Greek language client service, a management team resident in Athens or Thessaloniki. Substance requirements across the EU have hardened, and a firm that keeps its brains somewhere else while holding a licence somewhere cheaper is a supervisory problem waiting to surface. It makes less sense as a pure passporting vehicle when your team, clients and payment relationships all sit elsewhere, because you take on the cost of a fully supervised entity without the benefit of local presence.
For a firm serving EU retail clients, the offshore route does not work, and that judgement is not close. You cannot market to EU residents from an unauthorised entity, reverse solicitation is far narrower than marketing teams believe, and the payment and advertising infrastructure will not carry the traffic. If the EU is your market, the choice is which member state, not whether to be authorised at all. SINGUARD builds the software those firms run on, including the client portal, CRM and reporting trails a supervisor will eventually ask about. It is a software company and not an adviser, so the licence conversation belongs with your lawyers.
"People pick a member state the way they pick a flight, by price. Then they discover that the regulator is only half the decision and the bank is the other half."
— Alex Onta, Executive Director, SINGUARD
Key Takeaways
- The HCMC authorises and supervises Greek investment firms under MiFID II, with prudential responsibility for credit institutions sitting with the Bank of Greece.
- Read the permission list on a register entry rather than the licence number. Dealing on own account and order transmission are different businesses with different capital.
- Banks, acquirers and liquidity providers treat an EU authorisation as an entry ticket, then price the file on client mix, chargeback profile and sanctions exposure.
- Advertising and app store verification asks for a regulator reference valid in the target country, which is where offshore registrations fail for EU facing firms.
Frequently Asked Questions
Does the HCMC licence retail CFD brokers?
Greek investment firms are authorised under the MiFID II framework, and the permissions a firm holds determine what it may do, including whether it may deal on own account. Retail leveraged product rules that apply across the EU, including the leverage limits introduced through ESMA intervention, apply to Greek firms too. Check the specific permissions on the register entry and take Greek legal advice on your model.
Can a Greek investment firm serve clients in other EU countries?
Yes, through the passporting notification process, either cross border or by establishing a branch. The authorisation travels, but host state marketing rules, language requirements and local conduct expectations do not disappear, so a passport is the start of the compliance work in each new market rather than the end of it.
Will banks and payment providers accept a Greek licence?
An EU authorisation is generally accepted as a valid entity type by European banks and acquirers, which is a meaningful advantage over an offshore registration. The decision then turns on the underlying business: leveraged products, client jurisdictions, chargeback history and sanctions exposure all drive underwriting, and leveraged trading is normally classified in a higher risk category with the pricing that follows.
About the Author
Alex Onta is an Executive Director at SINGUARD. He built eTrader, the terminal, the mobile apps, eTrader Broker, Copytrading, Business and Community, along with the worldwide clustered-server infrastructure it all runs on, with his brother Roman Onta helping on the design, and he leads that division today. Together with Roman he builds the Prop Firm CRM, the Broker CRM, Scalegram and CopySignals, and the two of them carry worldwide compliance, payment processing and international business structuring side by side. He lives and works in Dubai for most of the year. Meet the executive duo leading Singuard's five divisions.