GREECE Law and Practice Contributed by: Nikos Nikolinakos, Dina Kouvelou and Alexis Spyropoulos, Nikolinakos & Partners Law Firm
the Greek territory, but are not international trav- el documents. Furthermore, the Greek government has announced the development of “Kids Wallet”, a mobile application designed to enhance online safety for minors by regulating their internet access. Scheduled for launch in March 2025, the app will enable automatic age verification and provide parental controls to manage chil - dren's screen time and application usage. It will integrate with the existing Gov.gr Wallet used by adults for digital identification. The gaming industry in Greece is mainly regu - lated by Law 4002/2011, which establishes the legal framework for the operation, management, supervision and control of gaming activities. Law 4002/2011 distinguishes between the fol - lowing • “Amusement-skill games”, where the out - come depends exclusively or mainly on the technical or intellectual skills of the player, and they are conducted at a public place, solely for amusement purposes. The outcome of such games may not be considered as a wager placed between any persons, and the player cannot be given any form of financial gain. • “Games of chance”, which meet the following cumulative conditions: (a) chance must be one of the factors influ - encing the outcome, even partially; and (b) there must be a financial wager, irrespec - tive of its value, in order to seek a direct 9. Gaming Industry 9.1 Regulations
or indirect financial gain from the outcome of the game. Responsible Gaming Responsible gaming regulations aim to prevent the harm of excessive gaming and promote responsible decision-making. The Hellenic Gam - ing Commission (HGC) has issued guidelines to ensure gaming is conducted responsibly and to minimise risks from careless participation. The HGC has recently identified critical gaps in Greece’s gaming regulations, calling for reforms to better protect players and highlighting the rapid growth of the sector as a weakness in the regulatory framework. Citing the Betshop case, which involved a EUR25 million penalty from tax audits, the HGC emphasised the need for stronger legal protections to prevent player funds from being treated as company assets. After revoking Betshop’s licence, the HGC began efforts to return funds to affected players. On 23 September 2024, the liquidation of guar - antee letters deposited by the provider with the HGC was offered to cover the amounts owed. An online application allowing players to submit claims and the organisation of the refund pro - cess is anticipated in the coming months. Another key challenge is the fact that the Greek legal framework focuses almost exclusively on games of chance, leaving amusement games in a grey area. The meaning of “amusement games” has changed over the years, and the HGC acknowledges that energy is now being expended without any benefit to the public interest, and that unnecessary bureaucratic and financial burdens are being imposed on busi - nesses not involved in the organisation and con - duct of games of chance. The need for a more modern and clearer regulatory framework is evi -
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