Risks in Entain’s $1.2 billion Novibet acquisition in Greece

Regulatory hurdles and HGC control

The acquisition of Novibet by Entain brings significant exposure to the Greek market, where the Hellenic Gaming Commission (HGC) maintains strict control through a rigid licensing system. Online operators require either a Type A licence for betting or a Type B licence for casino and poker games. Applicants submit their applications and supporting evidence to the HGC, including a €10,000 fee for participation in the procedure. The HGC issues a decision within two months of the submission, and if the HGC fails to issue a decision within this window, the application receives an implicit rejection. These licences last for seven years from the date of award and remain personal, which means they cannot be transferred or assigned. The HGC also requires a Suitability Permit for B2B affiliates under HGC Decision 509/1/11.09.2020/2020.

The HGC maintains strict control over the market by requiring that any transfer of a stake leading to a direct or indirect change in control receive prior approval, otherwise the transfer is null and void. This level of oversight extends to any disposition of a stake equal to or greater than 2% for online gaming or gaming machine operators. License holders must also notify the HGC of any changes related to the approval of suitability of shareholders within 20 days under Ministerial Decision 56580 EX 2022. Additionally, stakeholders must inform the license holder of changes to suitability information within 5 days. The HGC evaluates all stakeholders with over 10% interest, including ultimate beneficial owners. For institutional investors, the HGC only assesses the individuals managing the entity. The HGC holds broad supervisory powers to ensure compliance with gaming regulation.

Taxation and the profit impact

Taxation in Greece affects both the operators and the players, creating a heavy burden on net margins. Licensed operators pay a 35% tax on gross profit from regulated games, though this rate is 30% for horse racing betting. Players also face a progressive tax scale on their winnings, which can impact player retention.

I find the player taxation tiers to be a significant factor in the long-term profitability of the Greek market. All winnings must also align with general Greek income tax regulations. For gaming machines, the law sets a minimum stake of €0.10 and a maximum stake of €2. Using credit for participation is prohibited. The regulatory landscape for casinos further distinguishes between simple casino licences and wide-range casino licences, which involve different hotel and infrastructure requirements. These complexities ensure that operators face constant fiscal and administrative pressure.

Enforcement, AML, and age restrictions

Compliance with anti-money laundering (AML) rules remains a priority under Law 4557/2018. Operators must perform customer due diligence for transactions of €2,000 or more, whether the transaction occurs in one operation or several linked operations. Every licensed entity must appoint a compliance officer to prevent money laundering and report suspicious transactions to the authorities. The HGC also mandates social responsibility through HGC Decision 163/5/09.07.2015. This requires staff training to recognize problem gambling behavior and the provision of risk awareness materials. Operators must prohibit anyone under 21 from participating in online gambling and must provide tools like deposit, loss, and time limits.

Enforcement in Greece is intensifying as the HGC focuses on advertising controls and a strategic review of the market. This intensification follows the evolution of enforcement practice and policy priorities during 2025 and 2026. I see the massive gap between the €562.773 million GGR for licensed operators in 2020 and the estimated €1.6 to €1.7 billion generated by the unlicensed market every year. This illegal market creates a heavy headwind for companies like Entain. The HGC also regulates all commercial communication to ensure marketing does not glamorize gambling or target minors. You should watch the HGC’s power to revoke licences if an operator fails to meet these strict advertising standards.

Market competition and regulatory shifts

The Greek online market grew to a 36% market share of all gambling in 2021, but the industry faces a bifurcated reality. While the licensed sector continues to grow, the scale of the unlicensed market remains a primary driver for HGC enforcement. Regulatory authority over the Greek industry remains concentrated under the HGC, which also maintains a monopoly on VLT operations via OPAP S.A. with a 25,000 machine cap. All online winnings must be deposited in accounts at credit institutions or payment institutions established in Greece or in any other member state of the EU or EEA.

The regulatory environment is in a nascent stage of a modernized regime. The HGC focuses on preventing the use of credit for participation and ensuring that advertising does not imply that gambling is a means of financial success. The growing online market provides opportunity, but the high tax rates and tight wager restrictions temper the enthusiasm of some operators. I see the market as a high-tax, high-regulation zone where the illegal sector competes for the same customer base. Does the current regulatory focus on illegal gambling and advertising enough to protect the margins of licensed operators? The intensification of audits and enforcement suggests the HGC will not ease its grip on the sector.