Lead Signal
Bank of Greece supervisory commentary delivered in October 2025 by Deputy Governor Christina Papaconstantinou flags that payment institutions and electronic money institutions are lagging credit institutions on Digital Operational Resilience Act implementation, with ICT third-party mapping and Register-of-Information data quality identified as the primary near-term resilience gap. The finding follows DORA's application in Greece since 17 January 2025, under which the Bank of Greece is designated competent authority for credit institutions, payment institutions and electronic money institutions per Articles 148-152 of Law 5193/2025, while the Hellenic Capital Market Commission covers investment firms and crypto-asset service providers. The asymmetry is notable: it inverts the usual assumption that smaller non-bank payment firms move faster on compliance technology than incumbent banks, and signals a near-term supervisory-scrutiny risk for the payment-institution and e-money population specifically around ICT third-party governance.
Other Developments
Greece's payments infrastructure crossed a structural threshold this cycle. From 1 December 2025, all Greek businesses must accept IRIS instant-payment transactions at zero merchant cost, a mandate that took effect a month later than the government's original 1 November 2025 target following an extension via the tax reform bill. IRIS processed 122.1 million transactions in 2025, up 72.8% year on year, equivalent to roughly 40% of domestic credit transfers and EUR10.9 billion in value, with total DIAS interbank settlement value reaching EUR544.4 billion across the year. This domestic mandate now sits alongside the EU's card-interchange caps under Regulation (EU) 2015/751, fixing interchange at 0.2% for debit and 0.3% for credit transactions since December 2015. Cross-border reach also advanced: DIAS joined the EuroPA network in June 2025, and a first live phase of mobile-number-based instant transfers linking Greece with Spain, Portugal, Italy and Andorra went live from 30 June 2026, though country-count and phasing details in circulating reporting remain inconsistent and require verification.
On digital assets, Greece's MiCA regime is now fully operative: Law 5193/2025 entered into force on 11 April 2025, naming the Hellenic Capital Market Commission as CASP authoriser and the Bank of Greece as prudential supervisor for e-money-token and asset-referenced-token issuers it already authorises. The transitional grandfathering window for pre-existing crypto-asset service providers closed on 31 December 2025, after which HCMC authorisation became mandatory; HCMC Decision 8/1059/30.07.2025 sets a five-business-day acknowledgment, 25-business-day completeness check and 40-business-day final-decision timeline.
Industry structure continued consolidating around international processors. Worldline completed full ownership of its Greek merchant-acquiring venture, buying Eurobank's remaining 20% stake for EUR72 million around May 2026, valuing Worldline Greece at EUR360 million, following its original 2022 purchase of an 80% stake for EUR338 million. CrediaBank separately agreed to sell its merchant-acquiring business to Euronet Worldwide's Greek payment institution, epay, undisclosed amount, expected to close Q3 2026, with Euronet also taking over CrediaBank's ATM network. Viva Wallet/Viva.com remains Greece's sole independent fintech unicorn, holding an EEA payment-institution licence since 2011, an e-money licence since 2014, a banking licence via the 2020 Praxia Bank acquisition, and a 49% JPMorgan investment since January 2022 — a relationship now under litigation, with JPMorgan suing Viva Wallet executives and majority owner Werealize in parallel UK and Greek proceedings over alleged unauthorised asset transfers and attempts to strip its governance consent rights.
Cross-Monitor Connections
Law 5193/2025's extension of Greek AML obligations to crypto-asset service providers, including enhanced due diligence for crypto-asset transfers under the recast Transfer of Funds Regulation, carries illicit-finance and travel-rule significance outside this monitor's payments-instrument scope; that thread is flagged to the Financial Intelligence Monitor rather than pursued here. Within World Payments Monitor scope, the Hellenic Anti-Money Laundering Authority's dual-unit structure — a Financial Intelligence Unit collecting suspicious-transaction reports and a Financial Sanctions Unit identifying terrorism-financing-linked persons — is carried as baseline sentinel-fed context.
Outlook
PSD3/PSR's repeal of EMD2 and folding of electronic money institutions into a payment-institution sub-category is directionally settled but its application date is not: a realistic window runs from late 2027 to mid-2028, contingent on Official Journal publication anticipated in the first half of 2026, an approximately 18-month transposition period, and a 24-month, potentially extendable, EMI re-authorisation window. The Second Consumer Credit Directive must be transposed into Greek law by 20 November 2025, with enforcement expected from late 2026, bringing buy-now-pay-later products under consumer-credit regulation — including affordability checks and repayment-term disclosure — for the first time; Greece's dispute-resolution architecture remains fragmented across the Bank of Greece, the Consumer's Ombudsman and the Hellenic Financial Ombudsman, with no dedicated statutory reimbursement scheme for authorised-push-payment fraud identified to date. The pending CrediaBank-to-Euronet sale is expected to close in the third quarter of 2026, and EuroPA's roadmap points toward extending interoperability beyond peer-to-peer transfers to merchant payments by 2027, a lower-confidence, single-source claim that nonetheless bears watching given the scheme's momentum.