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Gambling & iGaming Licensing Last updated:

Gambling & iGaming Licensing for Online Casinos, Sportsbooks & Gaming Operators

Jagelski & Partners scopes gambling and iGaming authorisation in writing for crypto, fintech, and high-risk operators where an operative regime permits the activity. This guide compares nine jurisdiction cases, including corporate-only routes and excluded Anjouan. We map operator activity (B2C casino, sportsbook, B2B platform supply, crypto-denominated gaming) to the licence type and jurisdiction that fit the commercial model, target markets, and banking tolerance, and we introduce independent specialists for corporate substance, RNG certification and player-protection workflows in parallel with the application itself.

RJ
Richard Jagelski · Founder & Managing Director
Author profile · Strategic Infrastructure Advisor for Crypto, Fintech & High-Risk Businesses
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What Is Gambling & iGaming Licensing?

Gambling and iGaming licensing is the regulatory authorisation a business needs to legally offer games of chance, sports betting, or supply gaming software to licensed operators. The licence is granted by a designated gambling authority and prescribes which products are permitted, which markets the operator may serve, and which player-protection, anti-money-laundering, and technical-compliance standards apply.

In short: the licence is jurisdiction-specific and product-specific. There is no EU passport for gambling, and there is no global "gambling licence" that works everywhere. Operators select a licensing tier based on target markets, banking access, and capital tolerance, not on headline fee.

Unlike payments and crypto, where the European Union has built harmonised frameworks (PSD2, EMD2, MiCA), gambling sits outside EU harmonisation under a 1992 Edinburgh European Council carve-out. Each member state licenses separately, the CJEU has consistently confirmed that mutual recognition does not apply, and a recent Advocate General Opinion in Case C-683/24 (delivered ) found the underlying question inadmissible but, addressing substance for completeness, concluded that a Maltese gaming licence is, in the CJEU's own paraphrase, "in principle valid only in Malta".[1] A week earlier, on , the Court held in Case C-440/23 that EU law does not stop a Member State from prohibiting online casino games offered by Malta-licensed operators, or from treating those contracts as void and allowing players to recover lost stakes.[37] The practical consequence is that EU passporting is not available, geo-blocking is mandatory, and operators serving multiple regulated markets often need multiple licences.

The global market the licensing system supervises is large and growing. European gross gambling revenue reached EUR 123.4 bn in 2024, with the online share rising to 39% of total revenue (EUR 47.9 bn), and is forecast to reach EUR 66.8 bn online by 2029.[2] Crypto-denominated gambling is no longer a niche: the Financial Times, citing the anti-online-crime platform Yield Sec, reported USD 81.4 bn of gross gaming revenue from crypto wagers in 2024, an estimate from a single data provider.[3]

Licences split along two axes operators routinely conflate. The first axis is product: a casino licence (RNG slots, live dealer, peer poker), a sports betting licence (fixed-odds, pool, exchange), a lottery licence, and a B2B supplier licence (platform, RNG, aggregator, jackpot system) are each issued separately in most jurisdictions, sometimes by the same regulator and sometimes by different ones. The second axis is regulatory tier: European-regulated jurisdictions price credibility highly, established alternatives price practicality, and emerging jurisdictions price speed.

Buyer profile follows the tier. European regulated suits operators that already have a UK or German customer base and need Tier-1 acquiring access. Established alternative suits LatAm, Asia, and crypto-targeted operators that need a defensible licence without EU substance cost. Emerging suits crypto-native B2C operators willing to operate on grey-market terms and crypto-only payment rails.

Who Needs a Gambling Licence?

The need for a gambling licence depends on the product, operating activity and target market. Games of chance, betting, lotteries, peer-to-peer poker, and paid fantasy sports require classification under local law. Software suppliers need a separate perimeter check: the Isle of Man allows qualifying standalone suppliers to opt into licensing without requiring an OGRA licence merely to design or sell gambling software.

In short: the licence trigger covers B2C casinos, sportsbooks, and poker rooms, B2B platform, RNG, game-studio, and aggregator suppliers, and crypto-native operators (whose licence classification does not change because they accept crypto). Prediction markets, fantasy, and skill games sit in adjacent categories and are covered separately.

The clearest case is the B2C operator. An online casino offering slots, table games, and live dealer products to retail customers needs a casino licence in every jurisdiction where it accepts players. A sportsbook needs a sports betting licence (and in some jurisdictions, a separate casino licence if it offers in-play "casino-style" markets). A peer-to-peer poker room needs a poker-specific authorisation in regimes such as Malta's Type 3. Mixed-vertical operators commonly hold multiple licences from a single regulator.

B2B suppliers need their own authorisations even when they never face a retail customer. Malta's Critical Gaming Supply Licence, Gibraltar's B2B licence, Curacao's B2B Supplier Licence under the new LOK regime, and Kahnawake's Casino Software Provider Authorization each have their own defined perimeter, so whether a platform provider, RNG developer, game studio, aggregator, payment-critical provider, or marketing or CRM firm needs one depends on the activity and the jurisdiction. Gibraltar distinguishes B2B remote-gambling suppliers from holders of its separate GOSS licence.[7]

A B2B supplier serving a Malta-licensed operator typically cannot supply unlicensed; a B2B supplier serving an offshore-licensed operator usually can, though Tier-1 acquirers will not process payments for unlicensed activity in the supply chain.

Accepting crypto does not replace the gambling permission required in the markets served. Payment acceptance alone is not a MiCA crypto-asset service, but an operator that also exchanges or holds crypto-assets for clients needs a separate activity assessment. Its EU on/off-ramp provider must use the appropriate CASP authorisation or eligible Article 60 route.[4]

Prediction markets, fantasy sports, and skill games sit in adjacent regulatory categories. Their classification varies by jurisdiction, and the cleaner the "predominantly skill" or "financial-instrument-like" framing, the more likely the activity escapes gambling licensing. Jagelski & Partners covers the prediction market vertical separately at prediction market licensing; this page covers chance-based gambling.

Where to Get Licensed

Licensing jurisdiction selection depends on three commercial filters:

  1. Which markets the operator targets
  2. What regulatory credibility the operator needs for banking and payment processing
  3. What cost and timeline the business can absorb

Nine jurisdiction cases form the comparison. The recognised licensing regimes, corporate-only routes, and excluded Anjouan case have different legal effects; a row in the comparison is not a promise that a licence is available.

Tier 1: European Regulated (Malta, Gibraltar, Cyprus)

The Tier-1 tier delivers the highest-credibility licence available, anchored in primary legislation, supervised by an established authority, and accepted by Tier-1 acquiring banks and payment processors. The MGA issues a unified 10-year framework covering Type 1 RNG casino, Type 2 fixed-odds betting, Type 3 peer-to-peer, and Type 4 controlled skill games under the Gaming Act 2018; application fee is EUR 5,000 and the annual B2C licence fee is EUR 25,000 (EUR 10,000 for solely Type 4), plus the revenue-based Compliance Contribution paid monthly, with first-financial-year minimum relief for new operators that do not qualify as start-ups and a 12-month compliance-contribution moratorium for qualifying start-ups.[5]

Capital requirements scale with vertical: EUR 100,000 for Type 1 and 2, EUR 40,000 for Type 3 and 4, with a cumulative cap of EUR 240,000 across multi-vertical operators under the Capital Requirements Policy of .[6]

The MGA also tests balance-sheet equity: its policy defines a Positive Equity Position as assets at least equal to liabilities. The restoration rules include separate B2B thresholds, group derogations, and transitional arrangements; nominal share capital alone is insufficient.[6]

Gibraltar's Gambling Act 2025 commenced (except sections 55–77 on regulated functions and regulated individuals) and replaced the long-running 2005 framework with a B2C / B2B / GOSS (Gambling Operator Support Services) structure that for the first time captures affiliate marketing, CRM, and managed-trading firms.[7] Corporate tax rose to 15% on .[8]

Under the new Gambling (Duties and Licence Fees) Regulations 2026 (LN.2026/065), general betting and gaming duty is 0.15% of gross betting or gaming profit with the first GBP 100,000 exempt, betting intermediaries pay 0.15% of gross intermediary profit with no exemption, and B2B licences pay no duty. The same Regulations set a GBP 30,000 application fee for a new B2C betting or gaming operator and put annual licence fees for B2C betting and gaming operators on a yield-tiered schedule per licence: GBP 50,000 below GBP 20 million of annual gross yield, GBP 100,000 from GBP 20 million to GBP 300 million, and GBP 200,000 above that. A betting intermediary pays a GBP 15,000 application fee and a GBP 100,000 annual licence fee. B2B annual fees run from GBP 20,000 to GBP 85,000 by licence type, with GBP 85,000 for a single-vertical aggregator or platform supplier plus GBP 15,000 for each additional vertical.[25] Licences are granted by the Licensing Authority, which is the Minister or an appointee, and the Gambling Commissioner supervises licence holders.[7]

Gibraltar-licensed operators have no automatic access to the British market: UK-facing operators still need a UKGC licence and pay UK Remote Gaming Duty on online casino, slots, and online bingo, which rose from 21% to 40% on under the Finance Act 2026; remote sports betting remains under General Betting Duty at 15% until , when a new 25% remote betting rate takes effect (UK horseracing and SSBTs ring-fenced at 15%).[9]

Cyprus is the EU outlier and merits a specific caution: the National Betting Authority issues sports betting Class A (land-based) and Class B (online) licences only.[10] Online casino games (including slots and poker), betting exchanges, spread betting, and betting on greyhound races are prohibited under the Betting Law, with criminal offences for providers and for players, and online horse-race betting falls outside the Class B licence.[28]

Annual fees are modest (EUR 30,000 for one year, EUR 45,000 for two years) but the Betting Law requires EUR 500,000 of issued and paid-up share capital plus a EUR 550,000 bank guarantee from a credit institution, valid until six months after the licence period ends,[28] making Cyprus one of the highest capital-intensity sports-betting regimes in the EU.[11] The total burden on net betting receipts rose to 15% in , when Law 162(I)/2024 raised the contribution to the National Betting Authority from 3% to 5% alongside the 10% betting tax: 4% goes through the Cyprus Sports Organisation to football (3%) and other team sports (1%), and 1% funds the protection of young people and problem gamblers.[28]

Tier 2: Established Alternative (Curacao, Costa Rica, Canada / Kahnawake)

Tier 2 serves operators that want a defensible licence without EU substance cost. Curacao is the dominant choice and underwent its most significant reform in three decades in late 2024. The Landsverordening op de Kansspelen (LOK) entered into force on , replacing the 1993 master / sub-licence structure with a direct B2C and B2B regime supervised by the CGA.[12]

All four legacy master licences have now expired; applicants whose direct applications under the old ordinance were granted received a provisional LOK licence by operation of law, and the LOK prohibits transferring a licence or assigning its use to anyone else.[12]

As of the CGA had granted 604 provisional licences (551 B2C and 53 B2B) and rejected 139;[13] its online licence register, last updated , lists 665 licence records (571 B2C and 94 B2B), 109 of them marked expired or revoked.[32] Base application fee is EUR 4,592; annual B2C fees total EUR 47,450 (EUR 24,490 licence plus EUR 22,960 supervision), and the annual B2B fee is EUR 24,490. These are the amounts written into the LOK, and a ministerial regulation can adjust the annual fees from 1 January of any year in line with the consumer price index. Owner-related and domain/application charges are additional, and the first annual charge is prorated. Licences are indefinite subject to ongoing supervision.[14]

Experienced operators treat the provisional LOK grant as a starting position rather than the final credibility marker, because Tier-1 acquirers and Tier-1 game studios increasingly require the CGA's transition to a definitive licence with the full substance scaling met (resident managing director, the player-transaction register on a Tier-IV certified server in Curacao, and the local key persons and premises due from ) before extending direct contracts on commercial terms comparable to MGA-licensed counterparties.

The substance bar under LOK has risen materially. Operators need a Curacao NV/BV with statutory seat on the island, at least one resident managing director, full UBO disclosure above 10% and qualified-interest disclosure at or above 10%, a register of the critical data on players, gameplay, and financial transactions held on a server in a Tier-IV certified data centre in Curacao and available to the CGA at all times,[12] and local substance under Article 5.12, which generally requires one full-time key person registered in Curacao other than the director, rising to three from the fifth year after the LOK took effect, plus dedicated business premises on the island; the Minister of Justice has deferred these requirements until .[31] Qualifying new B2C operators may defer the Article 5.12 substance requirements until their fourth financial year after licence issue under Article 5.12(4), subject to its incorporation, ownership, revenue, and half-yearly certification conditions.[12] On the CGA's published figures the rejection rate runs at roughly 19% (139 refusals against 743 determinations to ). Those totals do not establish the causes of refusal.

Costa Rica is the unusual case in this tier because it issues no dedicated gambling licence. Operators register a Sociedad Anónima with a "data-processing" business permit at canton level, and the entire structure rests on the legal theory that the bet is placed where the player sits, not where the operator is based.

Provider quotes put first-year setup at USD 4,000–8,000 and annual upkeep around USD 5,000,[15] but those quotes leave out the annual tax that Ley 9050 levies on companies receiving and processing electronic bets: 57 base salaries for up to 50 employees (CRC 26.3 million in 2026, at a base salary of CRC 462,200), rising to 85 and 113 base salaries for larger staffs.[34] SUGEF’s registration guidance treats casinos, including those operating at a distance, as AML-obliged subjects under Article 15 bis of Ley 7786.[35] The trade-off is that no dedicated gambling regulator and no dispute-resolution body for players means Tier-1 acquirers and game suppliers are increasingly treating Costa Rica-based operators as effectively unlicensed.

Canada's Kahnawake Gaming Commission has operated since 1999 under the Mohawk Council of Kahnawake's asserted s.35(1) Constitution Act 1982 jurisdiction.[16] The Client Provider Authorization costs USD 35,000 to apply, including the first year’s annual fee (USD 40,000 for complete applications filed from ), and USD 20,000 a year,[29] with mandatory hosting at Mohawk Internet Technologies in Kahnawà:ke Territory.[16]

Kahnawake-hosted sites may not serve US residents in states where they are not authorised, under agreements the New Jersey Division of Gaming Enforcement announced on ,[33] and a Kahnawake licence gives no access to Ontario’s regulated market, which iGaming Ontario opened on .

Ontario itself is a provincial conduct-and-manage framework that ran CAD 2.9 bn of gaming revenue across 50 operators in FY 2024–25; it is unavoidable in Canadian strategy but is not an international licensing option in the conventional sense.[17]

Emerging Frameworks and the Excluded Anjouan Case

Anjouan and Mwali, as of August 2026. The Banque Centrale des Comores names both island authorities among fictitious structures issuing licences illegally, and the 2024 GIABA mutual evaluation records gambling as prohibited throughout the Union of the Comoros. Banks, payment providers, and platform counterparties price that in. Anjouan stays in the comparison below so the trade-off is visible; Mwali is not carried in the comparison. Curaçao under the LOK and Malta under its Gaming Act license through a lawfully constituted regulator, which Anjouan cannot show; neither licence replaces the permission each target market requires.

Anjouan is excluded as a recognised gambling licensing route. The Banque Centrale des Comores warning of names AOFA and related bodies as operating without legal authorisation and states that no online betting, gaming or gambling licence has been issued in the Union. Vendor prices and delivery estimates are not official licence fees or statutory processing times.[18]

Payment providers assess the operating entity, its activity, target markets and lawful authorisation individually. A separate EU or EEA payment company does not remedy missing gambling permission, and a private Anjouan certificate does not establish eligibility for fiat or crypto payment rails.

Geo-blocking conditions in a private certificate do not establish the issuer’s legal authority or authorise gambling in the markets left accessible. Confirm the applicable activity permission and customer-country restrictions before designing the payment or distribution structure.[18]

A press release issued in the name of Liberia’s NLA in announced an International Integrated Gaming Licence (IIGL) aimed at the banking problems of conventional offshore licences. As marketed, the package bundles a local business address, a USD or EUR SWIFT-capable corporate bank account, and a dedicated AML and compliance officer.[19]

The NLA’s own revised fee schedule, effective , lists an online casino licence at USD 90,000 and an online sports betting licence at USD 90,000, plus a USD 500 application fee, and has no separate IIGL category,[36] so confirm with the NLA which licence and fee a given package rests on. How Tier-1 payment providers treat the package is not yet evidenced.

Saint Lucia is a caveat case and warrants a specific warning. The country has no functioning online gambling regulator; the 2003/2004 Gaming Control Act is land-based only and the sole domestic casino closed in . A "Saint Lucia Gaming Authority" and a "Digital Gaming and Interactive Entertainment Act 2025" are promoted by one consultancy website but appear in no Saint Lucia government gazette, parliamentary record, Attorney General's Chambers index, Ministry of Finance or FSRA source.

Treat references to either as a likely marketing fabrication. Operators using "Saint Lucia" almost always pair an International Business Company with a gambling licence held elsewhere.

Jurisdiction comparison

TierJurisdictionRegulatorLicence TypesGovernment Fees / Vehicle CostTimelineTax / DutyBest For
European RegulatedMaltaMGAB2C (Type 1–4) / B2B Critical Gaming SupplyB2C: EUR 5k application + EUR 25k annual (EUR 10k solely Type 4), plus compliance contribution; first-year minimum relief / 12-month start-up moratorium, where eligible4–6 months35% company tax; possible 5% combined effective result after a qualifying 6/7 shareholder refund on distributed trading profits; separate 5% gaming tax on Malta-located playersOperators needing Tier-1 acquirer access and EU-tier credibility
European RegulatedGibraltarGambling CommissionerB2C / B2B / GOSSApplication + full annual fee comparison: betting/gaming GBP 30k + GBP 50k–200k by yield band = GBP 80k–230k≈ $110K–300K; betting intermediary GBP 15k + GBP 100k = GBP 115k≈ $150K. B2B annual fee alone: GBP 20k–85k≈ $26K–110K. The first annual fee is apportioned from the start of the grant quarter; confirm the applicable native fee band3–6 months15% CT; betting/gaming duty 0.15%, first GBP 100k exempt; intermediary duty 0.15% of commissions, no exemption; no B2B dutyOperators wanting a British Overseas Territory licence
European RegulatedCyprusNBASports betting Class A and B only (no online casino)EUR 30k annual fee; capital and guarantee listed separately below6–9 months15% CT (from 1 Jan 2026); 15% sector levy (10% betting tax + 5% NBA)Sports betting operators targeting EU
Established AlternativeCuracaoCGA (under LOK)B2C Online Gaming / B2B SupplierB2C base: EUR 4,592 application + EUR 47,450 annual; owner/domain charges extra; first annual charge prorated5–8 months15%/22% CT; no GGR dutyLatAm, Asia, Africa, CIS, crypto-targeted B2C
Established AlternativeCosta RicaNone (no gambling regulator)Data-processing business permit (vehicle only)USD 4–8k vehicle and permit3–6 weeksLey 9050 tax: 57–113 base salaries a year (from CRC 26.3m≈ $57K); territorial CITCrypto operators with minimal regulatory credibility need
Established AlternativeCanada (Kahnawake)KGCCPA (B2C) / CSPA (B2B) / IGL / LDSAUSD 35k application incl. first-year fee (40k from 2027); USD 20k annual thereafter4–6 monthsNo KGC gaming duty; CT where the operator is incorporatedOperators wanting a long-standing offshore licence with non-US, non-Canadian markets
Excluded caseAnjouan (Comoros)No lawfully constituted regulator identifiedNo recognised gambling authorisationNo official licensing fee scheduleNo published statutory clockNo verified gambling-tax or IBC exemptionAuthority warning; excluded from licensing recommendations
EmergingLiberiaNLAOnline casino or online sports betting licence (IIGL as marketed)USD 90k licence + USD 500 applicationNo published clockNot verifiedOperators able to verify licence scope and bundled banking directly with the NLA
EmergingSaint LuciaNone for online gamblingIBC vehicle paired with licence held elsewhereUSD 500–800 IBC government fees plus the registered agent, quoted1–3 weeksTerritorialCorporate-law domicile only; no standalone gambling authority

Cyprus separately requires EUR 500k paid-up capital and a EUR 550k guarantee.

The cost column counts regulator application and annual fees, plus the vehicle where the jurisdiction issues no licence. It is not the launch budget: capital, advisory fees, system certification, RNG certification, banking onboarding, and the AML build give indicative Year-1 budgets of EUR 150,000–350,000 for Malta or Gibraltar and EUR 90,000–180,000 for Curaçao under LOK. These commercial estimates are not official tariffs and require case-specific quotations. Anjouan is excluded from these launch-budget comparisons.

Markets that need a separate domestic licence

Some markets cannot be served from any of the nine jurisdictions above and require a local licence: the United Kingdom (UK Gambling Commission), Germany (GGL under GlüStV 2021), Sweden (Spelinspektionen), the Netherlands (KSA), France (ANJ), Spain (DGOJ), Italy (ADM), Denmark (Spillemyndigheden), and Brazil (SPA under Lei 14.790/2023, live since ).[20]

Brazil generated BRL 37 bn (around USD 7 bn) of regulated online gambling GGR in its first year across 79 licensed operators and is among the largest newly regulated gambling markets. The United States operates state-by-state. As of May 2026, seven states are live for real-money online casino (NJ, PA, MI, WV, CT, DE, RI), and combined 2025 iGaming GGR was USD 10.73 bn (+27.6% year-on-year), with Pennsylvania, Michigan, and New Jersey accounting for roughly 90% of the total.[24]

What the UKGC licence does not cover is acquirer-side eligibility under the card schemes’ own rules: Mastercard’s Security Rules and Procedures (Merchant Edition), which require gambling merchants to be registered, and Visa’s Global Brand Protection Programme apply registration, monitoring, and chargeback- or fraud-ratio tests to gambling merchants regardless of UKGC standing. An operator can hold a valid UKGC remote casino licence and still lose card acquiring if those thresholds are breached, because the scheme tests run on transaction data the UKGC does not see.

Key Requirements

Gambling licence requirements vary by jurisdiction and tier, but five categories appear in every regime:

  1. Corporate substance and key persons
  2. RNG and game certification
  3. Player-protection programmes
  4. AML and KYC compliance
  5. Segregation of player funds

The depth and enforcement of each varies sharply across the three regulatory tiers.

In short: every regulated gambling file turns on five pillars: corporate substance and fit-and-proper key persons, RNG and game certification by an accredited testing lab, player-protection programmes (deposit limits, self-exclusion, ADR), AML and KYC compliance under applicable national law (the EU AMLR generally applies from ), and segregation of player funds. Enforcement is most intensive in the European-regulated tier; the emerging cases publish few or no substance rules.

Corporate substance and key persons

Tier-1 regulators license companies they can supervise, though not always local ones: Malta accepts any company incorporated in the EU or EEA, and Cyprus a company incorporated in Cyprus or registered there as an overseas company.[28] Malta applies a fit-and-proper test, including source of wealth and funds, to shareholders, ultimate beneficial owners, directors, and key persons such as the MLRO.[30]

Tier-2 substance ranges from genuine (Curacao's mandatory resident managing director plus scaling Key Person requirement) to nominal (Costa Rica, which has required no resident agent since Ley 10.597 repealed that requirement).[27]

In the emerging cases, published substance rules are thin or missing: Saint Lucia has no online gambling regime to set them, Anjouan has no recognised one, and no substance rule for Liberia’s online licences was found on the National Lottery Authority’s site.

RNG and game certification

Every regulated jurisdiction requires that random number generators and individual games be certified by an accredited testing lab before they go live. The lab ecosystem is mature: GLI is accepted by all US states, Ontario, MGA, UKGC, Curacao, and Brazil; eCOGRA is accepted by Tier-1 EU and several US states; iTech Labs, BMM Testlabs, SIQ, and QUINEL cover the rest. Practitioner observation: cost per slot game per jurisdiction runs USD 3,000–10,000, multi-jurisdiction packages run USD 15,000–40,000, and lead times stretch from two weeks for a simple single-jurisdiction slot to four months for a complex multi-jurisdiction jackpot system. No comparable certification rule was found for the emerging cases.

Player-protection programmes

Tier-1 jurisdictions mandate the deepest player-protection layer: deposit, loss, and time limits, multi-tier self-exclusion registers, reality checks, ADR entity registration, vulnerable-customer policies, and increasingly, frictionless affordability checks. A statutory gambling levy, collected by the UK Gambling Commission, took effect on at rates of 0.1%–1.1% of the leviable gross gambling yield, allocated to treatment, prevention, and research, and slot stake limits of GBP 5 per spin for players aged 25 and over (in force from ) and GBP 2 per spin for 18–24s (from ).[21]

The CGA issued a mandatory Responsible Gaming Policy for LOK licensees on , with self-exclusion options of 1, 3, 5 and 10 years and lifetime, deposit-limit tools under which loosening a limit waits 24 hours, and a named person responsible for responsible gaming.[22] No equivalent published policy was found for the emerging cases.

AML and KYC compliance

Under EU Regulation 2024/1624 (the AMLR), applicable generally from , providers of gambling services fall within the obliged-entity perimeter, subject to the regulation’s exemption conditions. Customer due diligence is triggered at EUR 2,000 for single or linked transactions involving stakes, winnings or both.[23] National supervisors oversee gambling. AMLA’s direct-supervision selection concerns credit and financial institutions, with the first supervisory cycle expected in 2028; an Anjouan private certificate establishes neither gambling permission nor recognised AML supervision.

Player fund segregation and technical audit

Player fund segregation is the dividing line between regulated and grey, and the three regimes express it differently.

JurisdictionHow player funds are protected
MaltaPlayer Protection Deposit framework
GibraltarSegregation imposed through the operator's licence conditions
Curaçao (LOK)Enough liquid funds to pay expected prizes at once (a statutory refusal ground)

Tier-1 jurisdictions also require an MGA-approved or equivalent system audit before go-live. Editorial position: of the five categories above, the gap between the European-regulated tier and the emerging cases is widest in AML and player-protection enforcement; the gap in nominal substance requirements is narrower than headline rules suggest.

How Jagelski & Partners Helps

An independent specialist introduced by Jagelski & Partners coordinates gambling licensing as a single mandate that runs corporate formation, licence application, banking placement, RNG certification, and AML programme set-up in parallel rather than in sequence. The specialist assesses the operator's commercial model first, then recommends the jurisdiction tier that fits target markets, capital position, and banking tolerance, then sequences the workstreams so that capital, substance, and banking arrive ahead of the regulator asking.

The first work item on every mandate is a written tier and jurisdiction assessment. A B2C casino operator with a LatAm customer base, USD 200,000 of available capital, and a 90-day target to go live needs a different recommendation than a B2B platform supplier targeting Maltese operators with USD 2m of available capital and a 12-month runway.

We do not recommend a jurisdiction before mapping the operator's regulated activities, the markets it actually targets, and the payment rails it needs. Banking is the constraint that disqualifies more jurisdictions than any other variable.

Once the jurisdiction is selected, formation runs in parallel with the licence application. For Malta that means an EU or EEA company, and for Gibraltar an entity the Licensing Authority will accept, with directors and a registered office in place before the licence file goes in. For Curacao under LOK that means a Curacao NV with resident managing director, and a hosting arrangement that keeps the player-transaction register on a Tier-IV certified server on the island.

An independent specialist introduced through our company formation service coordinates formation so that corporate substance is delivered at the depth the licence requires, not the cheapest depth available.

The banking placement runs alongside, not after. Acquirers and EMIs generally treat gambling as a high-risk category, and pre-qualification with institutions that have an active gambling-MCC 7995 programme helps identify suitable counterparties before a formal application. Editorial position: operators seeking a specialist introduction often have a banking expectation calibrated to their previous fintech, not to gambling. The written scope should address that expectation before the introduction. Banking pre-qualification is handled through our high-risk business accounts workflow with 90+ institutions in the pre-qualified network.

RNG and game certification, player-protection programme drafting, AML manual, and KYC tooling are sequenced into the application timeline so that on the day the regulator grants the licence the operator can go live, not start a three-month integration. Post-launch the compliance partner handles ongoing compliance reporting, annual fee renewals, key-person changes, and the jurisdictional reviews that fall due (Curacao’s local-substance deadlines from , MGA licence renewal after the ten-year term, and the rollout of Gibraltar’s 2025 Act).

A licence without banking access is a certificate on the wall. Gambling operators face some of the tightest banking restrictions of any regulated vertical: card transactions carry gambling merchant codes (MCC 7995, and 7800–7802 for US government-licensed gambling) that many issuers restrict or block, and many credit institutions decline gambling deposits outright. Pre-qualified placement with institutions that have an active MCC 7995 programme is the practical path. An independent specialist introduced by Jagelski & Partners coordinates banking placement alongside licensing, with pre-qualification across a network of 90+ banking and payment institutions before any formal application. The institutional rates the client sees are the rates the institution applies, with no markup added. See banking for regulated businesses for the full placement model.

For licensing work, the partner who carries the mandate pays Jagelski & Partners for the introduction, and Jagelski & Partners does not bill the client; independent specialists quote their own professional fees separately, and statutory charges remain payable. For banking introductions, Jagelski & Partners is paid by the institution, not by the client. We do not mark up institutional banking or EMI pricing, and we do not charge a banking onboarding fee. The institutional rates the client sees on banking onboarding documentation are the rates the institution applies.

Frequently Asked Questions

Regulatory landscape

No. Gambling is excluded from EU single-market harmonisation under a 1992 Edinburgh European Council carve-out, and the Court of Justice of the European Union has consistently confirmed that national gambling licences do not benefit from mutual recognition. A recent Advocate General Opinion in Case C-683/24 () found the question referred to be inadmissible and, addressing substance for completeness, concluded that Article 56A of Malta's Gaming Act (which had purported to extend the Maltese licence's protective effect across the EU) is incompatible with Brussels I bis Regulation. The practical consequence is that operators targeting multiple EU markets need either multiple national licences (Malta plus Germany plus France) or one Tier-1 EU licence with geo-blocking for non-licensed markets.[1]

The Landsverordening op de Kansspelen entered into force on and replaced the 1993 master / sub-licence structure with a direct two-tier B2C and B2B regime supervised by the new Curacao Gaming Authority. All four legacy master licences (Antillephone, Cyberluck, Gaming Services Provider, CIL) have now expired, and the LOK prohibits transferring a licence or assigning its use to anyone else, so the sub-licence model has no legal basis.

New requirements include a resident managing director, a register of the critical data on players, gameplay, and financial transactions kept available to the CGA at all times on a server in a Tier-IV certified data centre in Curacao,[12] full UBO disclosure above 10% and qualified-interest disclosure at or above 10%, AML alignment with FATF Recommendations, and local key persons and business premises under Article 5.12, subject to the qualifying-new-operator exemption in Article 5.12(4) and deferred until .[31] At the LOK’s first anniversary in , the CGA reported 604 provisional licences granted and 139 applications rejected;[13] its online licence register of lists 665 licence records, 109 of them marked expired or revoked.[32]

Costs and timelines

By our estimate, Year-1 all-in costs range from around USD 63,000 (a Costa Rica S.A. with its business permit and the Ley 9050 tax on companies that process electronic bets) to EUR 600,000+ for Malta with a full multi-vertical operation including capital, system audit, and RNG certification. Our indicative commercial budgets for Tier-1 European jurisdictions (Malta, Gibraltar) run EUR 150,000–350,000 in Year 1 once capital, advisory fees, certification, banking onboarding, and AML build are included.

Our indicative commercial budget for Curacao under LOK is EUR 90,000–180,000 in Year 1 including formation, data-centre tenancy, key persons, and the full licence stack. ANJOUAN IS NOT PRICED HERE, and that is deliberate. The Banque Centrale des Comores published a signed warning on 8 December 2025 against entities issuing fraudulent authorisations, and states that no online betting, gaming or gambling licence has been issued in the Union of the Comoros. Anjouan is excluded from launch-budget comparisons. Neither a private certificate nor an EU or EEA payment-agent company supplies missing gambling permission; no statutory licensing fee or lawful approval timeline is established. Liberia’s National Lottery Authority sets a USD 90,000 online casino licence fee from 3 August 2026; the corporate bank account bundled into the marketed IIGL package is priced by providers, not in that schedule. Any additional payment-provider arrangement requires its own quotation and permission checks.

On our planning estimates, timelines from formation through licence grant are 4–6 months for Malta, 3–6 months for Gibraltar, 6–9 months for Cyprus, 5–8 months for Curacao under LOK, whose Art. 5.1 clock from a complete file runs eight weeks for phase 1 plus up to four in extension, four for the applicant to file phase 2, and eight more, also extendable by four, for the phase-2 decision, 4–6 months for Kahnawake, and 3–6 weeks for Costa Rica. Liberia’s National Lottery Authority publishes no processing time for online licences. The variance within each band is driven by UBO complexity (multiple jurisdictions, PEP exposure), source-of-funds evidence quality, and whether banking is run in parallel or sequentially.

Run independent preparation steps in parallel where practical; the timing benefit depends on the application and counterparties.

Products and operations

Acceptance depends on the gambling regime and the operator’s approved payment arrangements. UK-licensed operators considering crypto payments must demonstrate compliance with AML and social-responsibility obligations; the UK Gambling Commission does not impose a blanket ban. See its guidance on digital currencies.

Accepting crypto as payment does not by itself make a gambling operator a CASP. Providing exchange, custody, or other MiCA-scope services to clients requires a separate activity assessment. An EU on/off-ramp provider needs the appropriate CASP authorisation or eligible Article 60 route. A gambling licence does not supply that permission.[4]

In most jurisdictions yes, although the rules differ. Malta requires a separate Critical Gaming Supply Licence for platform, RNG, aggregator, and back-office providers serving licensed operators. Gibraltar introduced a new B2B Licence and the GOSS Licence under its 2025 Act, with GOSS covering marketing and affiliate services, holding or managing customer funds, and relevant company ownership, while managed trading and contracted-out CRM services fall within the B2B licence.

Curacao under LOK has a dedicated B2B Supplier Licence at EUR 24,490 per year. Kahnawake's Casino Software Provider Authorization is the equivalent. The economic logic is the same: regulators want certified, fit-and-proper-checked B2B providers in the supply chain to protect licensed operators from compromised platforms.[7]

Banking and payments

A gambling licence is one part of payment-provider due diligence. Acquirers also assess the activity, customer countries, ownership, chargebacks, and reserves. A separate EU or EEA payment company does not grant gambling permission to the operator or guarantee acceptance. Anjouan certificates should not be treated as proof of recognised authorisation.[18]

Crypto on/off-ramp acceptance is assessed individually and does not establish lawful gambling permission. The Banque Centrale des Comores warning prevents treating Anjouan as a recognised licensing route. Curaçao has a statutory gaming framework, but the proposed product and target markets still need separate scope and payment-provider checks.[18]

Lawful authorisation and payment-provider acceptance are separate requirements. Passing an acquirer’s commercial risk review does not validate an unrecognised licence. The Banque Centrale des Comores warning is therefore an authority issue, not merely a reason an otherwise valid Anjouan licence might score poorly in a bank’s risk model.[18]

Liberia's IIGL, announced in , is marketed as bundling a local bank account into the licence package,[19] but the NLA's own fee schedule lists no separate IIGL category,[36] and no public evidence yet shows how Tier-1 payment providers treat it.

Start Your Gambling Licensing Brief

Jagelski & Partners maps operator activity to an operative licensing regime in writing, then introduces the independent specialist who coordinates corporate formation, banking assessment, and the relevant application. The nine jurisdiction cases in this guide include corporate-only routes and excluded Anjouan; they are not nine available gambling authorisations.

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References

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  1. Court of Justice of the European Union, Press Release No 65/26: Advocate General’s Opinion in Case C-683/24, Spielerschutz Sigma, , curia.europa.eu, accessed .
  2. European Gaming and Betting Association / H2 Gambling Capital, European Gambling Market 2025 Edition, , egba.eu, accessed .
  3. Cointelegraph, Crypto casino revenue hit $81B in 2024 despite global restrictions (reporting Yield Sec data published by the Financial Times), 2025, tradingview.com, accessed .
  4. European Union, Regulation (EU) 2023/1114 on Markets in Crypto-assets (MiCA), , eur-lex.europa.eu, accessed .
  5. Malta Gaming Authority, Guidance Note: Licence Fees and Taxation v2, , mga.org.mt, accessed .
  6. Malta Gaming Authority, Capital Requirements Policy, sections 3, 5 and 7, published , mga.org.mt, accessed .
  7. HM Government of Gibraltar, Gambling Act 2025 (Act 2026-04), sections 4–7, 17, 19 and 35, commenced , gibraltarlaws.gov.gi, accessed .
  8. EY, Gibraltar Tax Facts 1 July 2025 to 30 June 2026, 2025, ey.com, accessed .
  9. HM Revenue & Customs, Excise Notice 455a: Remote Gaming Duty, sections 1 and 3, updated 1 April 2026, gov.uk; Gambling duty changes: scope and 2027 remote-betting rate, accessed .
  10. Cyprus National Betting Authority, Frequently Asked Questions, nba.gov.cy, accessed .
  11. Cyprus Bar / Chambers & Co, Sports Betting License in Cyprus, chambersandco.com, accessed .
  12. Landsverordening van de 20ste december 2024 houdende regels betreffende kansspelen (Landsverordening op de kansspelen, LOK), P.B. 2024 no. 157, Articles 1.2(3), 5.1, 5.9(1)(j), 5.12 and 15.1, published by the Curaçao Gaming Authority at cga.cw; overview at Curaçao Gaming Authority, Online Gaming, cga.cw, accessed .
  13. Curacao Chronicle, 1 Year of the LOK: an overview of the first year under the new gambling law, , curacaochronicle.com, accessed .
  14. Landsverordening op de kansspelen (LOK), P.B. 2024 no. 157, Articles 2.1(5) (indefinite term), 5.18(1)–(2) (application fee EUR 4,592) and 5.19(3)–(5) (annual EUR 22,960 supervisory plus EUR 24,490 licence fee for B2C; EUR 24,490 for B2B) and 5.19(7)–(8) (annual amounts adjustable by ministerial regulation to the consumer price index), cga.cw; corroborated by Asia Gaming Brief, Curacao Gaming Authority updates fee policy under new LOK framework, , agbrief.com, accessed .
  15. Altenar, Guide to Gambling Laws and Betting Regulations in Costa Rica, 2024, altenar.com, accessed .
  16. Kahnawake Gaming Commission, About Interactive Gaming, gamingcommission.ca, accessed .
  17. iGaming Ontario, Annual Report 2024-2025, igamingontario.ca, accessed .
  18. Banque Centrale des Comores, Signed warning on unauthorised licensing bodies, 8 December 2025, banque-comores.km, accessed .
  19. PR Newswire, release issued in the name of the National Lottery Authority of Liberia, First International Integrated Online Casino License Gains Growing Recognition, , prnewswire.com, accessed .
  20. iGaming Business, Licensed Brazil online betting generates $7bn in GGR over 2025, , igamingbusiness.com, accessed .
  21. UK Government, The Gambling Levy Regulations 2025 (SI 2025/213), regulations 1 and 4, and The Gambling Act 2005 (Operating Licence Conditions) (Amendment) Regulations 2025 (SI 2025/215), regulations 5 and 6, legislation.gov.uk, accessed ; CMS Lawnow, UK Government's 2025 Statutory Levy on Gambling Operators, , cms-lawnow.com; corroborated by Gambling Insider, Government debates gambling reform: Online slot stake limits and statutory levy introduced, gamblinginsider.com, accessed .
  22. Curacao Gaming Authority, Responsible Gaming Policy for Licensed Operators, Version 1.0, , sections 9.2 and 10.1, cga.cw, accessed .
  23. EU-Lex, Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, , eur-lex.europa.eu, accessed .
  24. American Gaming Association, State of the States 2026: The AGA Survey of the Commercial Casino Industry, May 2026, americangaming.org, accessed .
  25. HM Government of Gibraltar, Gambling (Duties and Licence Fees) Regulations 2026 (LN.2026/065), Schedules 1–3, commenced , gibraltarlaws.gov.gi; corroborated by Lexology, In review: licensing and taxation of gambling activities in Gibraltar, lexology.com, accessed .
  26. Cyprus Mail, MPs approve levy hike to support football clubs, , cyprus-mail.com; corroborated by Yogonet, Cyprus lawmakers approve bill to increase levy on sportsbook winnings to aid football clubs, , yogonet.com, accessed .
  27. Republic of Costa Rica, Ley 10.597, Article 4 (repeals Article 18(13) of the Commercial Code, the resident-agent requirement), La Gaceta, Alcance 195, , imprentanacional.go.cr, accessed .
  28. Republic of Cyprus, Betting Law 37(I)/2019, consolidated, Article 74 (10% betting tax; 5% contribution to the National Betting Authority), as amended by Law 162(I)/2024 (Official Gazette No. 5021, ), cylaw.org, accessed .
  29. Kahnawà:ke Gaming Commission, Increase of Fees (advisory notice of : Client Provider Authorization application fee USD 35,000 including the first-year annual fee, USD 40,000 for complete applications from ; annual fee USD 20,000), gamingcommission.ca, accessed .
  30. Malta Gaming Authority, Guidance Note: Application Process (v1), , sections 1.2–1.4 (any company incorporated in the EU/EEA is eligible; fit-and-proper test on shareholders, UBOs and key persons; source of wealth and funds), mga.org.mt, accessed .
  31. Curaçao Gaming Authority, Postponement of Local Substance Requirement under LOK (Article 5.12), , cga.cw, accessed .
  32. Curaçao Gaming Authority, Online Gaming License Registry, last updated , cga.cw, accessed .
  33. New Jersey Division of Gaming Enforcement, The New Jersey Division of Gaming Enforcement Announces Agreement with Kahnawake Gaming Commission to Combat Unlicensed Internet Gaming Sites, , nj.gov, accessed .
  34. Republic of Costa Rica, Ley N° 9050, Ley de Impuesto a Casinos y Empresas de Enlace de Llamadas a Apuestas Electrónicas, Articles 4, 6 and 10, Alcance 111 to La Gaceta 156, , text published by the Instituto Costarricense de Turismo at ict.go.cr; regulations in Decreto Ejecutivo 39231-MSP-MH, Article 19, ict.go.cr; 2026 base salary CRC 462,200 per Ministerio de Hacienda, Aviso informativo: impuesto a las personas jurídicas 2026, hacienda.go.cr, accessed .
  35. Superintendencia General de Entidades Financieras (SUGEF), Acuerdo SUGEF 11-18: inscripción de sujetos obligados de los artículos 15 y 15 bis de la Ley 7786, training presentation of , Articles 4 and 5 (casinos, including remote), sugef.fi.cr, accessed .
  36. National Lottery Authority of Liberia, Revised Fee Schedule under Resolution No. 005, effective (items 1, 8 and 12), nla.gov.lr, accessed .
  37. Court of Justice of the European Union, Press Release No 53/26: Judgment in Case C-440/23, European Lotto and Betting and Deutsche Lotto- und Sportwetten, , curia.europa.eu, accessed .