Greece's Register of Affiliates: How the HGC Regime Works

Does Greece require a gambling affiliate licence? Yes — and it is one of the very few places in the EU where that sentence is literally true. To promote Greek-licensed gambling operators, an affiliate needs an Affiliate Suitability Licence (Άδεια Καταλληλότητας) from the Hellenic Gaming Commission — the HGC, or ΕΕΕΠ in Greek — plus entry in the HGC Register of Affiliates. The entry cost is a €1,000 registration deposit, the application runs through the HGC’s online e-system, and the rule cuts both ways: operators are only allowed to work with affiliates who are on the register. If you just need the suitability licence filed, the Greece affiliate licence service covers it end to end — this guide explains how the regime works.

Why Greece sits on every affiliate’s compliance map

Most of Europe regulates gambling affiliates indirectly. The operator holds the licence, the operator signs the marketing contract, and the operator eats the fine when an affiliate’s landing page crosses a line. The affiliate itself is rarely licensed, registered or even named in the legislation.

Greece breaks that pattern. Together with Romania — whose ONJN Class 2 regime we cover in the Romania affiliate licence guide — it is one of only two EU member states operating a full affiliate registry: a named licence type, a public register, a document file and a fee. If you run traffic into regulated European markets, these are the two jurisdictions where “we don’t need a licence, the operator handles compliance” is simply wrong. For the full country-by-country picture, start with our pillar on whether gambling affiliates need a licence at all.

The other reason Greece matters is enforcement architecture. The regime doesn’t rely on chasing individual affiliates around the internet. It makes the operators police it: a Greek licensee is only permitted to buy traffic from registered affiliates, and it must check its partners against the HGC register and the HGC blacklist. An unregistered affiliate isn’t just non-compliant — it is commercially invisible to every operator in the market.

The requirement: a licence and a register entry

The Greek regime has two components, and you need both.

First, the Affiliate Suitability Licence — in Greek, Άδεια Καταλληλότητας, literally a “suitability” or “fitness” licence. As the name suggests, this is a probity screen: the HGC wants to know who is behind the affiliate business, what domains it operates, and that the people involved have clean records.

Second, entry in the HGC Register of Affiliates. The register is the operational half of the regime — it is what operators actually check before signing a cooperation agreement, alongside the HGC’s blacklist of prohibited websites.

Once licensed and registered, the constraint is symmetrical:

• Affiliates may only promote operators holding a Greek licence. Running Greek traffic to an unlicensed brand puts you outside the regime entirely.
• Operators may only use registered affiliates, and carry an active duty to verify the register and blacklist status of every marketing partner.

Legal basis

The regime rests on HGC Decision 509/1/11.09.2020, published in the Government Gazette (B’ 4140/28.09.2020). The decision was issued under Greece’s core gambling statute, Law 4002/2011, as amended by Law 4635/2019 — the framework that governs the country’s licensed online gambling market. When a lawyer or a compliance officer asks for your Greek legal basis, that decision and those two statutes are the citation.

Here is the regime at a glance:

What it costs

The published entry cost is a €1,000 registration deposit — the Greek paravolo, the standard state fee instrument that accompanies applications to Greek authorities. By affiliate-licensing standards that is remarkably cheap: Romania’s Class 2 regime runs to roughly €35,000 per year all-in, and Tennessee charges revenue-share affiliates $150,000 for a three-year vendor term. Greece’s barrier is administrative, not financial.

One honest caveat. What is not clearly published in secondary sources is the ongoing cost: whether the €1,000 recurs, whether there is a separate annual supervision fee, and what the renewal cycle looks like. Before you budget beyond year one, confirm the current terms directly with the HGC or in the text of Decision 509/1/11.09.2020 itself. We keep the verified figures for this and every other jurisdiction in our affiliate licensing data table, with a review date on each row.

How to apply: the HGC e-system

Applications are filed electronically through the HGC’s online licensing platform at certifications.gamingcommission.gov.gr. The process is genuinely digital — the application is signed with a qualified electronic signature — with one carve-out: where a document requires an Apostille, the file is submitted in hard copy alongside the electronic application.

The document file

The HGC’s suitability review runs on paper, and the file is broader than most affiliates expect:

• CVs for the individuals behind the business — this is a suitability licence, so the regulator screens people, not just entities.
• A complete list of the domains the affiliate operates, supported by WHOIS certificates proving ownership. Every site you will use to promote Greek operators belongs on this list.
• Tax certificates and commercial-registry certificates for the applicant entity.
• Clean-criminal-record declarations for the relevant persons.
• Written cooperation agreements with the Greek-licensed operators you will work with — the HGC wants to see the actual contractual relationship, not a letter of intent.

The cooperation-agreement requirement has a practical consequence: you approach the Greek market operator-first. Line up at least one Greek licensee willing to sign before you file, because the agreement is part of the application, not something you add afterwards.

Foreign affiliates

The regime is open to non-Greek companies, and in practice much of the affiliate market operates cross-border. The additional burden is formal: foreign applicants must submit their supporting documents as notarised Greek translations, and documents needing legalisation take the Apostille-plus-hard-copy route described above. None of this is difficult, but translation and notarisation add real lead time — start collecting corporate certificates early.

Life on the register

Registration is not a one-off filing. Two ongoing obligations matter most:

• Change notifications within 20 days. New domains, changes in the people behind the business, new or terminated operator agreements — the HGC expects the register to reflect reality, and the deadline is short.
• Greek-licensed operators only. The licence authorises you to promote HGC licensees. It is not a general marketing permission, and promoting unlicensed brands to Greek players sits outside — and against — the regime.

Remember that the operators are checking too. Because licensees must verify partners against the register and the blacklist, falling out of good standing doesn’t just create regulatory risk — it switches off your demand side overnight.

Rev-share and CPA: both models allowed

A detail that matters commercially: the Greek framework expressly contemplates both revenue-share and CPA compensation. You do not need to restructure your commercial model to fit the licence — hybrid deals, flat fees and lifetime rev-share all live inside the same registration. Contrast Germany, where variable, revenue-based affiliate remuneration for online casino advertising is banned outright and only fixed fees survive. Greece regulates who the affiliate is, not how it gets paid.

How big is the Greek affiliate register?

Reported figures put the register at around 141 registered affiliates — a number worth treating as indicative rather than official, but a useful signal either way. It tells you the regime is functioning and adopted, not a dead letter; and it tells you the compliant field is still small enough that being on the register is a genuine differentiator when you pitch Greek licensees for deals.

If you are weighing Greece against other markets that require affiliate licensing or registration — Romania, the US state regimes, Gibraltar’s new GOSS licence — our licence finder maps the options against your traffic and commercial model.

Vantegris handles Greek affiliate registrations end-to-end as part of our affiliate licensing service: the HGC e-system filing, the document file with notarised Greek translations, WHOIS certificates for your domain portfolio, and the cooperation-agreement sequencing with Greek licensees. If Greece is on your market list, talk to us and we will scope the file with you.

Bottom line

Greece is one of two EU markets where a gambling affiliate needs its own licence, and the mechanics are refreshingly straightforward: a €1,000 deposit, a documents-heavy but digital application through the HGC e-system, and a register entry that every Greek operator will check before signing you. The regime is enforced through the demand side, both rev-share and CPA fit inside it, and the barrier is diligence rather than money. Get the file right once, keep your changes notified within 20 days, and the register entry becomes exactly what it is designed to be — your commercial passport to the Greek market.

This article is general information, not legal advice. The renewal and fee mechanics of the Greek affiliate regime should be confirmed against HGC Decision 509/1/11.09.2020 and current HGC practice at scoping.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.