GREECE Law and Practice Contributed by: Nikos Nikolinakos, Dina Kouvelou and Alexis Spyropoulos, Nikolinakos & Partners Law Firm
dent, so that amusement games can be treated according to their nature and purpose. Games of chance require licensing and HGC supervision. Participation is restricted to indi - viduals aged 21 or older, and their promotion is regulated. Violators face criminal and admin - istrative penalties. The “loot box” mechanism closely resembles games of chance. Key Offences Article 52 of Law 4002/2011 prohibits the organi - sation and conduct of gaming without a licence or certification. Those who do not have the nec - essary licences and certifications face impris - onment and fines ranging from EUR100,000 to EUR700,000. Even if games are only organised and not conducted, they can be punished with imprisonment of at least one year and a fine of between EUR70,000 and EUR150,000. Installing or operating amusement skill games without the appropriate certification can result in imprison - ment of at least two years and a fine of between EUR5,000 and EUR50,000 per gaming machine. Installing or operating games of chance with - out the appropriate certification can result in imprisonment of at least three years and a fine of between EUR150,000 and EUR200,000 per gaming machine. Every electronic technical-amusement game intended for installation or already installed on certified gaming machines and played in cer - tified establishments must be certified by the HGC. Electronic technical-amusement games are considered certified if they have already been certified by other national authorities, rec - ognised international or European organisations, or certification bodies with which the HGC has signed a recognition agreement.
To be certified as an electronic technical-amuse - ment game, the following cumulative conditions must be met: • the game must be a software application embedded in or installed on electronic sup - porting media (hardware), and its execution must be influenced exclusively or primarily by the player’s technical or intellectual abilities, such as knowledge, choices and skills; • it must have a purely technical-amusement character and must not be or transform into a game of chance at any stage of its operation; • it must have obtained an age rating licence under the “Pan-European Game Information” (PEGI) system; • if it does not have an age rating licence, its content must have been reviewed by the manufacturer, importer or lawful owner or operator of the game, concerning descrip - tive indicators related to the game’s content (indicators of violence, offensive language, pornographic content, discrimination, sub - stance abuse, etc); and • it must include all information, instructions and other elements related to its use and operation. 9.2 Regulatory Bodies The HGC is the independent administrative authority responsible for regulating, supervis - ing and controlling games conducted within the Greek territory. Its purpose is to regulate the conduct of fair games, ensure compliance and protect players from addiction, particularly minors and other vulnerable social groups. The HGC has the authority to inspect, classify, cat - egorise and certify all types of games or their software, and to issue or revoke related deci - sions. These actions may be undertaken either upon request or on the HGC’s own initiative.
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