Self-custodial wallet / non-custodial software in Greece
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is permitted in Greece with no licensing burden.
Verdict Details
- Permitted
- yes
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No AML obligations attach to the software publisher directly, because the publisher never holds, controls, or has access to user private keys or funds — this does not fall under 'custodian wallet services' as defined in Law 4734/2020 (transposing 5AMLD).
- Only providers that offer 'custodial wallet services' — holding, storing, and transferring virtual assets or private cryptographic keys on behalf of customers — are considered obliged entities under Greek AML law.
- The FATF catch-all reference ('any other virtual asset service provider as defined by FATF') could in theory cover non-custodial tools, but Greek implementing legislation specifically and consistently refers to custody/control, and the HCMC registration framework targets providers that exchange, hold custody, or transfer virtual assets on behalf of customers.
Key Restrictions
- The software publisher must not hold, control, or have access to user private keys at any point — this is the defining boundary that keeps the activity outside VASP classification.
- If the software includes any integrated fiat on-ramp/off-ramp, swap, or transfer facilitation where the publisher touches keys or funds (even transiently), it could trigger VASP registration requirements.
- The publisher should avoid marketing itself as a 'custodian,' 'wallet service provider,' or similar regulated terminology in Greece.
Key Risks
- Regulatory ambiguity: A conservative interpretation by HCMC could classify non-custodial wallet software as a 'virtual asset service' under the FATF catch-all provision, especially if the software generates revenue from transaction fees or offers integrated exchange features.
- FATF Recommendation 15 and subsequent interpretive notes have pushed jurisdictions to consider non-custodial software providers as VASPs in certain circumstances — Greece may adopt a broader interpretation in future guidance.
- EU MiCA regulation (forthcoming full application) may introduce new obligations for non-custodial wallet providers at the EU level, potentially overriding the current classification gap.
- Consumer protection exposure: Greek consumers using the software may bring claims if they lose funds, even if the publisher has no custody — no specific Greek consumer-protection framework exempts non-custodial software from general liability.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Law 4557/2018 (as amended), which transposed the EU's 5th Anti-Money Laundering Directive (AMLD5) and 6th Anti-Money Laundering Directive (AMLD6) into national law. This law defines "providers of services of virtual assets" and mandates their registration.
Custody Providers: Providers that offer custodian wallet services, holding, storing, and transferring virtual assets or private cryptographic keys on behalf of customers.
Providers of custodial wallet services (holding, storing, and transferring virtual currencies on behalf of customers).
Any other virtual asset service providers as defined by the Financial Action Task Force (FATF) recommendations and subsequent EU legislation.
Hellenic Capital Market Commission (HCMC) - Virtual Assets Page:
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Yes — publishing self-custodial wallet software does not trigger Greek VASP registration or AML obligations because the publisher never holds, controls, or accesses user private keys or funds, falling outside the defined categories of 'custodian wallet services' under Law 4734/2020 and Law 4557/2018, though some ambiguity remains under the FATF catch-all provision and future EU MiCA regulation.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?