PSD2 and payment institution licensing in Greece: where founders get stuck
Authorisation as a payment or e-money institution is a structuring exercise as much as a filing — the questions that decide the timeline.
Payment institution and e-money institution authorisation in Greece sits within the framework transposing PSD2 and the E-Money Directive, supervised by the Bank of Greece. For founders building a payments or e-money product, the authorisation process is often described as a filing exercise. In practice, it is closer to a structuring exercise — the questions that most affect the timeline are decided before the application is drafted, not while it is being reviewed.
Choosing the right authorisation
PSD2 defines several categories of regulated payment service, and E-Money Directive authorisation is a distinct track from payment institution authorisation. Products that combine e-money issuance with payment initiation or account information services need to map their actual functionality against these categories early — under-scoping the authorisation request creates a compliance gap once the product ships; over-scoping adds capital and governance requirements the business does not yet need.
Governance and safeguarding are substantive, not procedural
Applicants are assessed on governance arrangements, internal control mechanisms, and — critically — safeguarding of client funds. This is not a form to complete after the product is built; the safeguarding structure (segregated accounts, insurance, or a guarantee arrangement) has downstream banking-relationship implications that are easier to negotiate before the authorisation application than to retrofit afterward.
Passporting and the cross-border question
A Greek authorisation carries EU passporting rights, which is often the actual commercial reason for choosing Greece as the licensing jurisdiction over a home market with a longer queue. Passporting notifications to host-state regulators are a separate procedural step from the initial authorisation and are worth planning for from the outset if the go-to-market plan is genuinely pan-European rather than domestic.
This article is for general information only and does not constitute legal advice. For advice on a specific matter, please contact us.