Greece as a regulatory test case: What Athens can teach Israel, Cyprus, and beyond

 If you're trying to understand how Mediterranean gambling law actually works, you'll find that Greece offers the most instructive model. While neighboring jurisdictions to its east grapple with fragmented efforts or outright prohibition, Greece created an 8% annual growth-per-year to 2025-sized €1.3 billion online gaming economy. So what is behind the success of Greece's model, and what can be learned by other jurisdictions?

The answer lies in Greece's balanced approach, closing loopholes for regulators but not its markets. Compared to the strangling models you will find elsewhere in the region, Greece demonstrates how comprehensive regulation actually creates player protection and market growth.

Greece's turnaround didn't occur overnight. After years of blanket prohibition, Law 4002/2011 brought the first licensing regime, although there were never any public tenders held. Instead, operators remained under a transitional regime that left years of uncertainty.

The real breakthrough came, though, with Law 4635/2019, which redesigned the whole system by introducing fixed renewable term licenses that are open to any capable operator. You now have 16 operators holding Type 1 licenses for online betting and 17 for other online games under Type 2 licenses.

What makes this system so powerful? Technical specifications are strict but clear. Anything online is to be connected to the computerized monitoring and control system (CMCS), giving the Hellenic Gaming Commission direct control. And enforcement? It has turned into a serious business. Regulators blacklisted 758 new illegal providers in just three months in 2024.

The financial model is a testament to this seriousness, too. Type 1 licenses cost €3 million for seven years, with operators paying a 35% gross gaming revenue tax. In the end, it ensures only serious players enter the market.

But see how Israel does it, and you'll know why overall regulation is so crucial. Israel has one of the world's strictest gambling prohibitions, with only the National Lottery and sports betting legalized by the state. Everything else is completely banned by the Penal Law.

What is the consequence when you create such restrictive conditions? Players will inevitably resort to black markets and off-shore operators. Despite blocking measures like site blocking, the vast majority of Israeli players access foreign gambling sites with the help of VPNs or proxy servers.

This offers a perfect forum for no KYC casino brands to flourish. When there are no real regulated substitutes, players resort to operators that promise instant entry without requests for verification. Such sites exploit the regulatory loophole, floating in jurisdictional limbo where Israeli law cannot catch up with them.

The twist? Israel's proposal to protect players by banning gambling only makes them more exposed. Without regulatory oversight, there's no guarantee such operators will honor winnings, protect personal data, or prevent child gambling. 

Cyprus is a completely different case. The island's gambling regulation is very scattered, with different activities being regulated by laws and bodies. Only online sports betting is legal; online casino games are completely prohibited.

But here things get interesting: Israelis led cash bets in Cyprus casinos during 2024 with €93 million, trailed by Cypriots with €78 million. This cross-border bet reveals the real mechanism of regulatory arbitrage in practice.

The splintered regulation builds up enforcement blind spots that are vulnerable to being exploited by operators. Where multiple authorities monitor different forms of gambling, coordination is poor. The situation can enable operators with a no verification process for betting, particularly where regulatory boundaries become blurred or create ambiguity.

Cyprus's 13% rate on online gaming is appealing to operators, but the limited definition of what is indeed permissible online pushes operators and players toward less regulated alternatives. It's an ideal example of how partial regulation can be worse than complete regulation.

So why is the strategy in Greece more effective? It's because it has comprehensiveness without prohibition. Greece requires strict Know Your Customer requirements and mandates that all gambling be limited to a minimum age of 21 years. Operators must continue to monitor data for at least a period of 10 years and have all systems connect with the central monitoring system.

Greece enables legitimate business. The licensing is accessible, the technical conditions are specified, and the tax regime, though substantial, supports a viable business model. And this has generated a stable, growing market value of €1.3 billion by 2025.

The enforcement side can't be overlooked either. Recent license revocations show that the Hellenic Gaming Commission does have teeth. When operators know rules will be enforced on a regular basis, they're more likely to stick to them voluntarily. 

What can others learn from Greece's experience? For starters, partial prohibition usually creates more problems than wide-ranging regulation. If you leave regulatory loopholes, there are those operator rogues who will fill them.

Second, technical integration matters. Greece's CMCS system provides real-time monitoring that cannot be replicated through manual audit. This isn't about apprehending bad guys; it's about preventing them before they occur.

Third, enforcement must be credible. Regulations that are not enforced create incentives for non-compliance and provide unfair benefits to bad players.

Greece's experience shows us that protecting players and raising legitimate tax income are not an either-or proposition. By providing transparent channels to respectable operators and closing loopholes for illicit operators, Greece has built a regulatory framework that other Mediterranean countries could benefit from.

This article was written in cooperation with Aris Kladis