CSB Group offers a “one-stop-shop” service to online gaming operators by assisting clients in setting up or relocating their gaming operation to Malta. The Group has been involved in the iGaming industry since its inception in Malta – that is since 2000 and assists clients in submitting and pursuing a Gaming Licence application to the Malta Gaming Authority (MGA).
The Malta Online Gaming Licence Application Process
Operators looking to obtain an online gaming licence in Malta are required to undergo a rigorous application process in the course of which applicants are required to submit detailed information and documentation relating to their proposed operations for review and scrutiny by the Malta Gaming Authority (MGA). The process is explained in further detail below.
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Online Gaming Licence – Pre-Application
Prior to submission all applicants are advised to go through a pre-application process with one of the MGA’s Licensing Officers. This will ensure that the application has been correctly compiled and all the key ingredients are present. This process assists in speeding up the licensing process as in the MGA’s experience most applications are slowed down due to missing or incomplete information.
The Application Process
The application process has been harmonised into a singular stage. Applicants can submit all the required
information at one go and the MGA commits itself to the analysis of all information through multiple internal
In the application stage the MGA assesses whether an applicant:
1. Is fit and proper to conduct gaming business.
2. Is correctly prepared from a business strategy perspective.
3. Has the operational and statutory requirements to meet the obligations prescribed by
law and policy.
4. Has correctly implemented what has been applied for, on a technical environment before
Malta Gaming Authority (MGA) Fit & Proper Test
The MGA conducts a fit and proper exercise on the applicant by assessing all information related to all shareholders, UBOs, and persons involved in finance and management; as well as on the business viability of the operation. The MGA conducts probity investigations with other national and international regulatory bodies and law enforcement agencies.
The MGA conducts an in-depth financial analysis of the applicant’s business plan. The applicant’s business plan is expected to have a detailed forecast of the operation, inclusive of marketing and distribution strategies, HR plan and growth targets.
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Operational and Statutory Requirements
The applicant is examined on the instruments required to conduct the business. This process includes examining incorporation documents, the operational policies and procedures, the games and the gaming and control systems, the technical setup, including system, network and application architecture, the rules, terms, conditions and procedures of the games, and other documents which might be required.
Furthermore, a remote gaming licensee is subject to minimum issued and paid-up share capital requirements. Class 1 and Class 2 licence holders are required to retain a minimum share capital of €100,000 whilst Class 3 and Class 4 licensees are required to retain a minimum share capital of €40,000. Companies with multiple licences are required to meet the above share capital requirements cumulatively up to a minimum capping of
The above three components constitute the desk-based audit of the application requirements and is completed within 12 to 16 weeks, assuming all information is complete and correct. Inconsistent and low quality applications will be dropped and the applicant will be subject to re-application.
Malta Online Gaming Licence Systems Review
Once all three areas are successfully completed the MGA will inform the applicant that the application was successful and will invite the applicant to implement onto a technical environment in preparation to going live. The applicant will be allowed 60 days to complete this operation after which the application will be considered as suspended and subject to re-application. At any point within those 60 days the applicant may trigger a request for an external System Review (performed by an independent 3rd party contracted by the MGA against a fixed market price). The System Review will audit the live environment against the proposed application.
At this stage the MGA expects minimal deviation from the application. Significant changes to the gaming system will require the applicant to re-apply through a new application. On successful completion of the certification process, the Authority issues a five year licence.
The MGA mandates that after going live a Licensee shall undergo a number of compliance reviews of its operation, performed by independent 3rd parties contracted by the MGA against a fixed market price.
The MGA will require such reviews to take place on the following schedule:
1. After the first year of operation after being licensed by the MGA.
2. On the third year of operation after being licensed by the MGA.
3. Prior to renewal of the five (5) year licence.
4. At the discretion of the MGA normally arising from suspicion of deviation to:
a) The regulations.
b) Operational nature of the licence.
Failure of a compliance review could lead to suspension or termination of a licence.
*Source – MGA (Malta Gaming Authority)