Greece gambling affiliate licence: how the HGC suitability licence works
Most gambling markets regulate operators and leave affiliates to contract law. Greece does not: if you promote online gambling to Greek players, the regulator expects you to be licensed and registered yourself. This guide explains how the regime works and what to check before you send a single Greek visitor to a casino or sportsbook.
This article is an overview, not legal advice. Rules change — confirm the current requirements with the Hellenic Gaming Commission or a Greek gaming lawyer before applying.
Who regulates gambling in Greece
Online gambling in Greece is supervised by the Hellenic Gaming Commission (HGC). The framework rests on Law 4002/2011, reformed in 2019 to open a licensed online market. Operators receive one of two licence types: Type A for sports betting and Type B for other online games such as casino. Only brands holding one of these licences may legally accept Greek players.
The affiliates regime: HGC Decision 509/1/11.09.2020
Affiliates got their own rules with HGC Decision 509/1/11.09.2020, published in the Government Gazette B' 4140 on 28 September 2020. The decision defines an affiliate as an individual or a legal entity that holds a suitability (appropriateness) licence issued by the HGC and cooperates with licensed operators to promote online games and attract players.
In practice that means two steps:
- Getting the suitability licence from the HGC.
- Registration in the HGC Affiliates' Register, which requires a €1,000 fee.
Documents the HGC asks for
The application file is closer to a mini due diligence than a simple form. It includes:
- CVs of the affiliate or its representatives;
- the list of domain names you will use, with WHOIS certificates;
- tax and commercial registry certificates;
- solemn declarations that the affiliate and its representatives have not been convicted of the listed crimes;
- corporate and beneficial ownership information for companies.
Affiliates also need a qualified e-signature, because the HGC handles files electronically.
Obligations once you are licensed
- Promote only HGC-licensed operators. Working for unlicensed brands is explicitly prohibited.
- Sign a written cooperation agreement with each operator. It must cover the duration, your domain names, how the agreement is amended and terminated, remuneration, dispute resolution and your consent to HGC regulations.
- Remuneration has to depend on the number, participation and general activity of the players you bring — the usual RevShare or CPA logic.
- Report changes within 20 days — new domains, ownership, representatives.
- Follow the responsible gambling and advertising rules: warnings about underage gambling, helpline details, no content suggesting gambling is a reliable source of income, no targeting of minors or vulnerable groups.
The blacklist and enforcement
The HGC keeps a blacklist of unlicensed gambling domains. Greek internet providers must block them and payment institutions must refuse transactions to them. Unlicensed affiliate activity exposes you to administrative fines and, in serious cases, criminal referral.
What this means for your traffic
Many international affiliate programs — including several in the WhoAff catalog for Greece — accept Greek traffic under Curacao, Malta or Anjouan licences. Under Greek rules, that is not enough: a licensed Greek affiliate may only promote brands that hold an HGC licence. Before you target Greece:
- Check that the brand appears on the HGC list of licensed operators.
- Decide whether Greek traffic justifies your own suitability licence and register entry.
- If it does not, exclude Greek visitors from campaigns for offshore brands rather than risk the blacklist.
For programs and terms by country, see programs by GEO and the full affiliate program catalog.