Gaming Manufacturer & Supplier Licensing.

Not every technology vendor touching the gaming sector needs a licence, but many manufacturer/supplier business models do fall within scope of the framework administered by the Hellenic Gaming Commission (HGC) — this typically includes software and platform providers, RNG and GMS providers, live-dealer studios, and hardware/equipment manufacturers whose systems are used by licensed Greek operators. Whether your business is caught depends on factors such as how directly your systems are integrated into a licensed operator's regulated offering. This is a fact-specific assessment, and it is worth getting a clear answer before your systems are deployed with a Greek operator, rather than assuming your model falls outside the regime.

An operator licence authorises a business to offer betting or gaming products directly to Greek consumers, while a manufacturer/supplier licence authorises a business to supply the technology, systems or equipment that operators use to deliver those products — the two are distinct authorisations aimed at different parts of the value chain. A company can hold a supplier licence without ever holding, or needing, an operator licence, and vice versa. Understanding which regime — or both — applies to your business is the starting point for any Greek market entry.

Games, RNG systems and GMS platforms supplied to HGC-licensed operators typically need to be certified or type-approved by accredited independent testing laboratories before deployment, confirming that the systems meet the regulator's technical and integrity requirements. The process generally involves several stages of technical testing and documentation review, and the specific scope required depends on the type of system involved. We coordinate this process with accredited labs and prepare the supporting legal documentation alongside it.

As with operator licensing, manufacturer/supplier applicants are typically subject to a "fit and proper" assessment of their ultimate beneficial owners, directors and other key persons, examining matters such as integrity, financial standing and relevant regulatory history. This due diligence is a standard feature of gaming regulatory licensing and is generally more straightforward to satisfy where the corporate structure is transparent and well-documented from the outset. We help structure the corporate entity and prepare the supporting due diligence documentation before the application is filed.

Whether a local corporate presence is required, and in what form, depends on the specific supply arrangement and how the regulatory framework applies to your structure — this is not a one-size-fits-all answer. Some international suppliers are able to structure their Greek supply relationships without establishing a full local entity, while others find that a Greek or EU-based structure is the more practical route to licensing and ongoing compliance. We can assess the options against your specific business model.

Material changes to a certified game, RNG system or GMS platform typically trigger a change-control process with the regulator, and may require re-certification by an accredited testing lab before the updated system can be deployed to Greek operators. What counts as a material change, and the process for approving it, depends on the nature of the update, so it is worth building regulatory change-control into your development and release process from the outset rather than addressing it after the fact. We advise on managing this ongoing compliance obligation as your systems evolve.