EU iGaming Jurisdictions

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CSB Group can also assist remote gaming companies in the licencing process and support in various other European jurisdictions. Through our network of associates, we can assist clients in establishing their remote gaming business and obtain remote gaming licenses in the following jurisdictions

Malta Gaming Jurisdiction

Is Online Gambling Regulated in Malta?

Yes, online gambling is regulated in Malta and local licensing is available with the Malta Gaming Authority (MGA).

What is regulated in this jurisdiction?

Local licensing is available for B2B suppliers to provide or carry out a critical gaming supply which constitute the following:

  • supply and management of material elements of a game;
  • supply and management of software, to generate, capture, control or process essential regulatory record and/or supply and management of the control system itself on which the software resides

Furthermore, local licensing is available for B2C operators offering, provision or operation of a gaming service.

The following game types are authorised by the MGA:

Type 1: games of chance played against the house, the outcome of which is determined by a random generator, and shall include casino-type games, including roulette, blackjack, baccarat, poker played against the house, lotteries, secondary lotteries and virtual sports games; and/or

Type 2: games of chance played against the house, the outcome of which is not generated randomly, but is determined by the result of an event or competition extraneous to a game of chance, and whereby the operator manages his or her own risk by managing the odds offered to the player; and/or

Type 3: games of chance not played against the house and wherein the operator is not exposed to gaming risk, but generates revenue by taking a commission or other charge based on the stakes or the prize, and shall include player versus player games such as poker, bingo, betting exchange, and other commission-based games; and/or,

Type 4: Controlled skill games as per regulation 8 of the Gaming Authorisations Regulations. Fantasy Sports is considered as a controlled skill game.

Overview of Malta's licensing regime

Below is a snapshot of the application process and ongoing fees in relation to the Maltese gaming licence.

The Application Process

Who can apply?

Any company established in the European Union (EU) or the European Economic Area (EEA) shall be eligible to apply for a licence.

Furthermore, any person offering licensable games in or from Malta without a licence from MGA, but under a licence issued by another member state of the EU or the EEA, or a state which the MGA deems to offer safeguards largely equivalent to those offered by Maltese law, may apply to the MGA for a recognition notice.

What does the Application Process involve?

The application process involves submission of detailed information and documentation relating to the proposed operations, the beneficial owners, and key persons. The MGA conducts fit and proper test, analysis of the business plan, appropriate policies and procedures, an inspection of the applicant’s ability to comply with appropriate legal and compliance requirements, and the testing of the technical environment prior to going live. Additionally, the MGA may request some further verifications as they see fit within the remit of its authority.

Any Key Function/Personnel requirements?

Yes. The following Key Function Personnel are required for B2B suppliers and B2C operators:

  • Chief Executive
  • Chief Operations / Key management
  • Compliance
  • Legal
  • Privacy
  • Money Laundering Reporting Officer (‘MLRO’) – applicable to B2C only
  • Technology
  • Internal Auditor

What are the minimum share capital requirements?

A licensee is subject to have a minimum issued paid-up share capital requirements as follows:

Gaming Service Licence (B2C):

  • Type 1 – Minimum €100,000
  • Type 2 – Minimum €100,000
  • Type 3 – Minimum €40,000
  • Type 4 – Minimum €40,000

Critical Gaming Supply Licence (B2B):

  • Minimum €40,000

Companies with multiple type approvals are required to meet the above share capital requirements cumulatively up to a minimum capping of €240,000.

Server Location and Data Storage, Software Hosting Location Requirements

The architecture must be located in Malta, and/or any EEA member state for the hosting of critical components.

Furthemore, the MGA requires real-time replication of players, financial and game data in which the replication server must be located in Malta.

Ongoing Fees

Taxation

Remote gaming operators must pay a gaming tax.

5% of gross gaming revenue (GGR) generated from Malta-based players. Determination of taxability is whether the player is established, has their permanent address in and/or usually resides in Malta.

Annual Licence Fee

The following annual licence fees and compliance contributions to the MGA are applicable:

Fixed Annual Licence Fee

  • Non-refundable fixed annual licence fee for operators providing Type 1, 2 & 3 gaming services is €25,000
  • Non-refundable fixed annual licence fee for operators providing solely Type 4 gaming services is €10,000

Compliance Contributions

Compliance Contribution is required to be paid monthly, commencing immediately after the month in which the licence period commences, and then on a monthly basis, with payments to be calculated on the gaming revenue accrued during each and every month falling within a licence period (‘the reference month’).

The amount due shall be paid before the expiration of the twentieth (20th) day of the month following the reference month. The compliance contributions vary from one category of licence to another and depend on the gaming activities undertaken. It can range as follows:

  • B2C – Type 1 gaming services compliance contribution ranges from €15,000 to €375,000.
  • B2C – Type 2 gaming services compliance contribution ranges from €25,000 to €600,000.
  • B2C – Type 3 gaming services compliance contribution ranges from €25,000 to €500,000.
  • B2C – Type 4 gaming services compliance contribution ranges from €5,000 to €500,000.

Italy Gaming Jurisdiction

Is Online Gambling Regulated in Italy?

Online gambling is regulated in Italy and local licensing is available with the Agenzia delle Dogane e dei Monopoli (ADM).

What is regulated in this jurisdiction?

Local licensing is available for B2C Operators offering the following:

  • Online betting,
  • Horse race betting,
  • Casino games, and
  • Poker.

There is a private monopoly in place for lottery games.

B2B Supplier licensing is technically considered to be unregulated as there is no local licensing available as such for suppliers/ manufacturers of software and hardware. However, suppliers/ manufacturers of software and hardware are required to obtain the relevant certifications from an ADM approved testing house. This certification must be requested directly by the licensee who must contact an ADM approved testing house.

The gaming platform to be submitted for certification must also be accompanied by a game application on which to perform tests.

Additionally, gambling operators are required to disclose to the authority the names of suppliers/ manufacturers of software and hardware to be used in the offering of gambling services.

Overview of Italy's licensing regime

Below is a snapshot of the application process and ongoing fees in relation to the Italian gaming licence.

The Application Process

Who can apply?

The applying company must be registered and incorporated in a European Union (EU) member state or within the European Economic Area.

What does the Application Process involve?

The application process involves submitting detailed documentation about the company, its owners, financials, technical specifications, and more. The ADM review the application and conducts background checks.

Any Key Function/Personnel Requirements?

No, there are no Key Function/Personnel Requirements

What are the minimum share capital requirements?

The minimum share capital requirements of the company depend on the type of game it offers.

Server Location and Data Storage, Software Hosting Location Requirements

Gambling servers are obliged to be located within an EU/EEA jurisdiction.

Ongoing Fees

Taxation

Italy applies a different tax regime depending on the type of remote game.
Skill games with cash prizes: 25% of gross gaming revenue (GGR),
Fixed-odds games with cash prizes (includes casino games and gaming machines: 25% of GGR,

Fixed-odds sports betting:

Online sports betting: 24% of the difference between the money played and the winnings (apart from online horse race betting which is 47% of GGR),
Totalisator (pool) betting) 20% of gross commissions received by the operator, Bingo 35% of GGR.

Annual Licence Fee

The annual licence fee amounts to 200,000.00 EUR

Germany Gaming Jurisdiction

Is online gambling regulated in Germany?

Online Gambling is regulated in Germany by a regulatory framework consisting of both federal and state laws.

The Federal Level Authority is named the Joint Gambling Authority of the States (GGL)

What is regulated in this jurisdiction?

Local licensing is available for operators for the following at the federal level:

-        Sports betting,

-        Horse race betting,

-        Online slots and

-        Poker.

Online casino games other than online slots and poker are made available at a state/multi-state level. The possibility to obtain a licence for online casino games is thus subject to separate laws of the individual federal states. The Federal States can decide whether they will grant licences for these online casino games to private operators or only allow state operators.

B2B Supplier licensing

There are no licensing requirements for B2B suppliers in Germany. Additionally, there is no list of testing laboratories that operators can use in Germany. Sections 6f(3) and 4d(3) of the Interstate Treaty on Gambling provide that an independent body should test the compliance of games with the technical standards and the security concept on an annual basis.
When applying for a licence, each individual game must be approved by the Joint Gambling Authority of the States (GGL) (Section 22a(1), Interstate Treaty on Gambling).

Overview of Germany's licensing regime

Below is a snapshot of the application process and ongoing fees in relation to the German gaming licence.

The Application Process

Who can apply?

The applying company must be registered and incorporated in a European (EU) member state or within the European Economic Area (EEA).

What does the Application Process involve?

The application process involves submitting detailed documentation about the company, its owners, financial, technical specifications, and more. The GGL reviews the application and conduct background checks in order to ensure that the applicant certainly qualifies for a licence. The GGL will mainly be concerned regarding the applicant's reliability and expertise, along with examination of the applicant's financial capability. It is a characteristic of German licensing processes that applicants will be required to prove their qualifications by submitting 'concepts' which include detailed descriptions of their business and related policies (e.g. responsible gaming, IT security, AML, business, and marketing concepts).

For virtual slots and poker, the applicant must provide security in the form of an unlimited directly enforceable bank guarantee from a credit institution based in the European Union or in a member state party to the Agreement on the European Economic Area to secure payment claims of the players and state payment claims. The security deposit must amount to €5m. It can be increased by the authority that grants the permit up to the amount of the expected average turnover for a month, up to a maximum of €50m.

Any Key Function/Personnel requirements?

It must be demonstrated that certain employees are sufficiently qualified and have the necessary expertise to conduct business reliably and responsibly. Typical requirements include criminal record checks, tax clearance certificates, CVs, and evidence of professional expertise including training certificates. Beyond those requirements, there is no specific licensing process (e.g. for personal licenses) that employees of gambling operators must undergo.

Server Location and Data Storage, Software Hosting Location Requirements

Players' data must be stored for five years after the game account is closed. The organisers of sports betting, online casino games, online poker and virtual slots must set up a technical system, known as the safe-server analysis system (a part of the LUGAS system) at their own expense that contains all the necessary information for the regulatory supervision of the operators and that allows direct access to the supervisory authority.

Ongoing Fees

Taxation

Online sports betting, horse race betting, virtual slots and poker games are taxed at a rate of 5.3 percent of turnover.

Annual fees

Section 91(4) of the Interstate Treaty on Gambling states that licensing fees will rise in correlation with the operator's expected or approved annual turnover:

1) Expected revenues of up to 40 million EUR: 0.2% of turnover but at least 100 EUR

2) Expected revenues of between 40 million EUR and 65 million EUR: a minimum fee of 80,000 EUR and 0.6% of the turnover exceeding 40 million EUR

3) Expected revenues of between 65 million EUR and 130 million EUR: a minimum fee of 120,000 EUR and 0.1 % of the turnover exceeding 65 million EUR

4) Expected revenues of more than 130 million EUR: a minimum fee of 185,000 EUR and 0.06 % of the turnover exceeding 130 million EUR. Fees must be paid annually. However, they can be reduced by 10% in subsequent years.

Sweden Gaming Jurisdiction

Online gambling is regulated in Sweden with local licenses issued by the Swedish Gambling Authority (Spelinspektionen - SGA).

What is regulated in this jurisdiction?

Local licensing is available for B2C operators offering the following:

  • Online casino games
  • Betting,
  • Slot games,
  • Bingo games, and
  • Lotteries.

Additionally, local licensing is required for an online gaming software. Chapter 11, Section 6a of the Gambling Act mandates anyone who “manufactures, supplies, installs or changes” gaming software to apply for an online gaming software licence. According to Chapter 2, Section 3(17) of the Gambling Act, a “gaming system” is defined as an electronic system used by a licensee or on behalf of a licensee to:

1.      Record, store, process, share, transmit or retrieve games, customer information or customer history,

2.     Generate, transmit or process random numbers, and

3.     Determination, storage, or other processing of outcomes in games. According to Chapter 1, Section 1 of the Gambling Act, online games which are not aimed at the Swedish market shall not be considered provided in Sweden.

Overview of Sweden's licensing regime

Below is a snapshot of the application process and ongoing fees in relation to the Swedish gaming licence.

The Application Process

Any company which can demonstrate that they have the proper knowledge, experience and organisation required to organise gambling and can operate in accordance with the laws and regulations can apply for a licence.

A company which is not incorporated or established in a country within the European Economic Area (EEA) must have a physical representative who is a resident in Sweden.

What does the Application Process involve?

The application process involves submitting detailed documentation about the company, its owners, financial, technical specifications, and more. The SGA will review the application and conduct background checks in order to ensure the applicant qualifies for a licence in accordance with Swedish law.

There is an SEK230,000 licence application fee for a commercial online gambling or betting licence.

Are there any minimum share capital requirements?

No, there aren't any minimum share capital requirements.

Server Location and Data Storage, Software Hosting Location Requirements

The licensee’s gaming system must be located in Sweden. According to Chapter 2, Section 3(17) of the Gambling Act, a “gaming system” is defined as an electronic system used by a licensee or on behalf of a licensee to:

1. Record, store, process, share, transmit or retrieve games, customer information or customer history.

2. Generate, transmit or process random numbers.

3.  Determination, storage or other processing of outcomes in games.

However, Chapter 16, Section 2 of the Gambling Act, states that following a specific request from the licence holder, the Swedish Gambling Authority may grant an exemption from this requirement, if the licence holder either:

4.  Has permission to offer gambling in another country where a public authority monitors its gambling offerings and that authority has concluded an agreement with the Swedish Gambling Authority on oversight of the licence holder’s gambling offerings in Sweden

5. Can give the Swedish Gambling Authority the ability to perform adequate controls over the gaming system by means of remote access or the like.

Data Storage: Chapter 16, Section 5 of the Gambling Act mandates a licensee to save all information about the operation of the gaming system for at least five years.

According to Chapter 17, Section 5 of the Gambling Act, a licensee may process the personal data if it is necessary to:

1. Check the player's identity and age.

2. Establish gaming accounts and fulfil the licensee's obligations towards the player in terms of gaming accounts.

3. Check a player’s compliance with the terms and conditions of the game.

4. Review the game to detect cheating, fraud, and other criminal activity.

5. Check and report abnormal playing patterns and suspicions of manipulation of results or match-fixing in sports competitions about betting.

6. Review and analyse data from established player profiles and each player's gaming behaviour to implement gambling responsibility measures.

7. Carry out self-exclusion of players and handle data from the Swedish Gambling Authority regarding the national self-exclusion register (Spelpaus.se).

8. Check and report whether the player have participated in betting in violation of the sport's regulations on match-fixing.

Ongoing Fees

Taxation Fees

The monthly tax required by an online gambling operator amounts to 18% of the difference between total receipts and winnings paid out (gross gaming revenue). Section 7 of the Gambling Tax Law states that: 'when determining the balance, only bets and payouts that relate to the Swedish game participation shall be taken into account' participation in online games where the player is a resident or a permanent resident in Sweden is counted as Swedish game participation.

Annual Fees

There is a SEK230,000 licence application fee for a commercial online gambling or betting licence.

Additionally, the annual supervision fee owed by an online gambling licensee to cover the cost of the supervision exercised by the Swedish Gambling Authority is based on its turnover and amounts to:

SEK30,000 for turnover up to SEK10m.

SEK60,000 for turnover between SEK10m and SEK20m.

SEK120,000 for turnover between SEK20m and SEK50m.

SEK240,000 for turnover between SEK50m and SEK100m.

SEK300,000 for turnover between SEK100m and SEK200m.

SEK400,000 for turnover between SEK200m and SEK500m.

SEK500,000 for turnover above SEK500m.

Denmark Gaming Jurisdiction

Online gambling is fully regulated in Denmark with local licensing available by the Danish Gambling Authority (Spillemyndigheden).

What is regulated in this jurisdiction?

Local licensing is available for operators for online casino and betting.  There is a State monopoly for lottery games. There is no requirement for suppliers to obtain a licence. However, gambling systems and equipment that licensed operators use must be certified.

Overview of Denmark's licensing regime

Below is a snapshot of the application process and ongoing fees in relation to Denmark's gaming licence. 

The Application Process

Who can apply?

An applicant must be established in Denmark or in any other EU or EEA country, or have a representative who has been approved by the regulator and is a resident in Denmark.

What does the Application Process involve?

The application process involves submitting detailed documentation about the company, the owners, financials, technical specifications, and more. The Danish Gambling Authority will review the application and conduct background checks to ensure the applicants certainly qualifies for a licence.

Any Key Function/Personnel requirements?

It is not a requirement for key personnel to obtain personal licences, and subcontractors are generally not obligated to obtain their own licence.

Are there any minimum share capital requirements?

No there aren't any minimum share capital requirements.

Server Location and Data Storage, Software Hosting Location Requirements

According to the Executive Order on Online Betting and the Executive Order on Online Casinos:

-        Online betting and casino operators must keep data about players’ identity and transactions for at least five years after the customer relationship has ended.

-        Information on the player’s gambling behaviour and risk assessment must be stored for five years.

-        All data on the offer of online casino/bets in the gaming system must be stored for at least five years.

Gambling operators must provide the regulator with "access to carry out a satisfactory inspection of the gaming system ... by means of remote access or the like". This requirement may be waived "if the licensee has a licence to offer games in another country where a public authority supervises the licensee's gaming offer, and this supervisory authority has entered into an agreement with the [Danish] Gambling Authority on the supervision of the licensee's offering of games in this country".

A gaming operator’s gaming system, which is considered the IT equipment they use for offering bets and online casinos, must be located in Denmark.

Online betting and casino licence holders must create a data repository (SAFE) and the gambling authority must be able to have online access to the licence holder's data storage.

Ongoing Fees

Taxation

The tax base for online betting and casino gambling operations is gross gaming revenue. The tax rate for 2023/2024 is 28% according to the Gambling Authority’s website. For betting exchanges, the tax base is the amount taken in commission by the licensee.

Application and annual fees

The application fees are as follows:

  • Application fee for betting licence and online casino licence: DKK304,500 each.
  • Application fee for combined betting licence and online casino licence: DKK426,300.
  • Application fee for renewal of betting licence and online casino licence: DKK121,800 each.
  • Application fee for renewal of combined betting licence and online casino licence: DKK152,300.
  • Application fee for a restricted revenue licence: DKK60,900. (Note, half of the fee (DKK30,500) will be refunded if the application is rejected.)

In addition to the application fee, an annual fee calculated on the basis of a gambling operator’s GGR shall be paid.

  • For GGR under DKK5m, the annual fee amounts to DKK60,900.
  • For GGR between DKK5m and DKK10m, the annual fee amounts to DKK152,300.
  • For GGR between DKK10m and DKK25m, the annual fee amounts to DKK274,100.
  • For GGR between DKK25m and DKK50m, the annual fee amounts to DKK548,100.
  • For GGR between DKK50m and DKK100m, the annual fee amounts to DKK974,400.
  • For GGR between DKK100m and DKK200m, the annual fee amounts to DKK1.827m.
  • For GGR between DKK200m and DKK500m, the annual fee amounts to DKK3.045m.
  • For GGR above DKK500m, the annual fee amounts to DKK5.481m.

Both the application fees and the annual fees are regulated according to Section 20 of the Personal Tax Act.

Netherlands Gaming Jurisdiction

Online gambling is regulated. Local licensing is available via Netherlands Gambling Authority (Kansspelautoriteit (KSA)) 

What is regulated in this jurisdiction?

Online gambling operators need to apply for the approval of their gaming systems. Local licences are available and can be issued to operators by the KSA to organise four types of remote games of chance:

  • Casino games in which the players play against the licence holder (roulette and blackjack, for example).
  • Casino games in which the players play against each other (poker, for example).
  • Bets on events occurring during a sporting contest or on the outcome of a sporting contest
  • Bets on the outcome of horse racing and harness racing

Supplier licensing

B2B/Supplier Licensing is currently not regulated in the Netherlands and licenses are therefore not available for online B2B/Suppliers.

Overview of Dutch licensing regime

Below is a snapshot of the application process and ongoing fees in relation to the Dutch gaming license.

The Application Process

Who can apply?

Licensees should be a public limited company or a private limited company and have their registered office in the EU or the European Economic Area (EEA).

However, there is an exception to this rule which may be granted "if the permit holder has its statutory seat, principal place of business or headquarters in a third country, provided that the laws of such country provide adequate safeguards for the interests which the present act aims at protecting".

What does the Application Process involve?

The application process with the KSA involves submitting detailed documentation about the company, its owners, financials, technical specifications, and more. The KSA will review the application and conduct appropriate background checks.

The applications must be submitted digitally and in the Dutch language. An application will cost EUR 48,000.

The application procedure for a licence for online games of chance will atleast comprise of the following subjects:

  • trustworthiness, expertise, continuity, addiction prevention, advertising and marketing, consumer protection, match fixing, Anti-Money Laundering, Outsourcing, Integrity, Payment transactions and Identification & Verification.

In order to assess whether the applicant is suitable for a licence, the KSA will review the applicant's policies in relation to the aforementioned areas so as to ensure that they comply with the local gambling in the Netherlands.

The decision on the application for a permit is reached within six months of the application's receipt.

Any Key Function/Personnel requirements?

No, there aren't any Key Function/Personnel requirements.

What are the minimum share capital requirements?

Under Article 8.1 of the regulator’s policy rule, the financial guarantee that applicants are required to provide at the time of granting the permit is EUR 50,000.

Server Location and Data Storage, Software Hosting Location Requirements

Server location requirements

The applicant must have a control database in the Netherlands which the KSA has access to certain data. According to Section 7 of the regulator’s Specifications for the remote gambling data safe (CDB): “The legislation requires that the CDB final data repository must be located in the Netherlands physically separated from the operator’s gambling system. Both may be located in the same data centre if an operator chooses to do so, however data stored in this main CDB final data repository must be logistically and safely separated from any other data.”

Data retention requirements

According to Section 6 of the specifications: “Minimum retention period of the data in the CDB final data repository is 12 months counting from the moment of the compulsory registration. Operators must guarantee this retention in their control plan and also in their exit plan.”

According to Article 4.41(4) of the Remote Gambling Decree, the licence holder registers every adjustment to the gaming system and keeps this data for at least five years.

Ongoing Fees

Taxation

Gaming Levy: 1.95% of gross gaming revenue (GGR) - payable by online gambling operators.

Gambling tax: 30.5 % (Articles 1(d), 3(1)(a) and Article 5 of the Gambling Tax Act).

Belgium Gaming Jurisdiction

Online gambling is regulated in Belgium and there is local licensing issued by the Belgian Gaming Commission (BGC) for online casinos, as well as gaming machines, sports betting and horse race betting. A state monopoly is in place for online lotteries.

What is regulated in this jurisdiction?

Local licenses are available for both B2C online gambling operators and online B2B/Suppliers. Operators are required to obtain licenses which include the following:

  • casino games (Class A+ licence),
  • slot machines games (Class B+ licence), and
  • bets on sporting events and horse races (Class F1+ licence)

Lottery games may only be offered by Loterie Nationale, which is the state monopoly.

Class E licence

B2B Suppliers are required to obtain licences which a Class E license.

The sale, rental, import, export, manufacture, maintenance and repair of gambling equipment requires a Class E licence (Article 48, Gambling Law).  According to Article 27 of the Gambling Law, Class E licensees cannot also hold, whether directly or indirectly, any other licence (i.e., Class A, A+, B, B+, C, D, F1, F1+, F1P, F2, G1 or G2).

Overview of Belgium’s licensing regime

Below is a snapshot of the application process and ongoing fees in relation to the Belgian gaming licence.

The Application Process

Who can apply?

EU-registered companies can apply for an A (+), B(+), E or F1(+) licence.

What does the Application Process involve?

Applicants are required to fill out an application form which details the company, its owners, financials, technical specifications and more. The application will be required to provide supporting documentation. The BGC shall review the application and conduct background checks appropriately.

Any Key Function/Personnel Requirements?

No, there aren't any Key Function/Personnel Requirements.

What are the minimum share capital requirements?

According to Article 71 of the Gambling Law, an applicant must pay a “guarantee” (deposit fee) before they can obtain one of the following licence types. The deposit fees are as follows:

  • Class A licence: €250,000.
  • Class A+ licence: €250,000.
  • Class B licence: €75,000.
  • Class B+ licence: €75,000.
  • Class F licence: €10,000.
  • Class F1+ licence: €75,000.
  • Class E licence: €12,500 per tranche of 50 machines, or €25,000 if they maintain and repair the machines

Server Location and Data Storage, Software Hosting Location Requirements

Servers must be located in a permanent establishment within the Belgian territory. Data must be stored for five years.

Ongoing Fees

Taxation

The tax structure is set at a regional level in Belgium. Each of the country’s three regions (Flemish, Walloon and Brussels-Capital) impose an online gambling tax of 11% on the gross gaming revenue (GGR).

Annual Licence Fee

B2C Operators must also pay an annual licensing fee for the operational costs of the BGC and the contributions shall be as follows:

  • Class A licence fee: €22,085
  • Class A+ licence fee: €11,042
  • Class B licence fee: €11,042
  • Class B+ licence fee: €11,042
  • Class F1 licence fee: €12,603
  • Class F+ licence fee: €12,603

Suppliers must also pay an annual licensing fee for the operational costs of the BGC - the contribution for a Class E licence is €3,682 for suppliers that maintain and repair the machines. For those responsible for providing gambling services via the information society, the fee is €12,603. For all others, the fee is €1,842 per tranche of 50 machines.

Bulgaria Gaming Jurisdiction

Online gambling is regulated in Bulgaria and the National Revenue Agency is the regulatory body which issues such licences.

What is regulated in this jurisdiction?

Both online B2B/Supplier and B2C gambling operators licenses are available in Bulgaria. The following games are permitted:

  • Sports betting, including horse racing and greyhound racing.
  • Betting on random events or those related to the knowledge of facts (games of chance).
  • Casino games, including poker.
  • Gaming machines.
  • Lottery games.

From a B2B/Supplier perspective, Article 9(7) of the Gambling Act states that it is not permissible to manufacture, produce, distribute and import gaming equipment without a licence. A manufacturer is defined as: “a person who manufactures, assembles, programs, modifies [and] recycles gaming equipment, and is the holder of the rights to use the industrial property of hardware or software in gaming equipment.” (Section 1(14), Additional Provisions in the Gambling Act). An importer or distributor is defined as: “a person who imports and offers for sale or use of gaming equipment for gambling activities.” (Section 1(15), Additional Provisions of the Gambling Act).

Overview of Bulgaria's licensing regime

The Application Process

Who can apply?

Gambling licenses may be issued to Bulgarian companies or companies registered in another EU Member State. If the applicant holds a gambling license issued by a competent authority in another EU Member State or the Swiss Confederation, under certain mandatory documentation and conditions for the issuance of such license may be considered as already approved in the Bulgarian application procedure without the presence of specific documentation to this effect. Each licensee must have a Bulgarian representative, who shall be the contact person between the licensee and the Gambling Commission.

What does the Application Process involve?

To receive an online gambling licence, operators must have at least BGN1m in investments and at least BGN600,000 in financial resources.

The application includes a set of documents (eg, certificates of good standing; criminal record checks; UBO information; various declarations; information on the source of funds; rules for playing the gambling games; internal rules and procedures; KYC and AML internal regulations; website information; information on the gaming equipment; payment documents; etc).

Application review takes between 60 and 90 days. After review, the NRA Director approves or rejects the licence application. If there there is a rejection, it can be appealable before the Sofia Administrative Court.

The licence is valid for 5 or 10 years.  The application review fees range from approx. € 5,000 to € 20,000 (eg, for online sports betting licences, the government fee is BGN 20,000 (approx. € 10,220)).

Any Key Function/Personnel requirements?

Not specifically. However, each licensee must have a Bulgarian representative who shall be the contact person between the licensee and the Gambling Commission.

What are the minimum share capital requirements?

Organisers of online betting games must have a fully paid-up capital of a minimum value with fully paid-up capital of a minimum value of BGN 1,500,000 or the BGN equivalent in another currency;

Server Location and Data Storage, Software Hosting Location Requirements

Servers can be based in Bulgaria, Switzerland, or another country of the EU or EEA.  However, the equipment that stores all the information and data (in relation to offering gambling in Bulgaria) must be kept within Bulgaria. Furthermore, according to the Gambling Act, data shall be stored in its original form for a period of five years.

Ongoing Fees 

Taxation

20% tax on gross gaming revenue (GGR)

Annual licence fee

Licence fees cover a period of 5 years for the following:

Sportsbetting - €20,000

Casino and poker games - €35,000

Lottery games - €20,000

Romania Gaming Jurisdiction

Online gambling is regulated in Romania. Local licensing is available for online gambling. Online lotteries are subject to a state monopoly. The Regulatory body is the National Gambling Office (ONJN).

What is regulated in this jurisdiction?

Local licensing is available for both online B2B/Suppliers (Class 2) and B2C gambling operators (Class 1).

  • Class 1 licences are granted to operators that organise remote games of chance and that have a direct contract with the player (Annex (1)(I)(J), Gambling Act) and
  • Class 2 licences are granted to legal entities involved in traditional and remote gambling and conformity assessment bodies, such as:
    • operators that provide management and hosting facilities on the gaming platform, other than providers of electronic communications networks and services;
    • economic operators that conduct activities provided for in Article 20(1) of the Gambling Act; payment processors; companies producing and/or distributing software specialised in the field of gambling, affiliates, certifiers, auditors and conformity assessment bodies (Annex (1)(I)(J)(i-viii), Gambling Act)..

The following online games are permitted:

  • Lottery (under the state monopoly of Loteria Romana),
  • Casino-type games, including online poker and online slots,
  • Fixed-odds betting, mutual betting and betting exchanges,
  • Bingo and Keno, and

Online gaming machines are not regulated as a separate gaming product but are included in the online casino type category (Article 14(c), Gambling Regulation).

Overview of Romania’s licensing regime

Below is a snapshot of the application process and ongoing fees in relation to the Romanian gaming license.

The Application Process

Who can apply?

Gambling operator licences can only be granted to locally established entities or entities within the EU, EEA or Swiss Confederation that have registered a permanent establishment in Romania for tax purposes (Article 1(2), Gambling Act).

On October 6, 2023, an emergency ordinance came into effect, requiring online gambling operators not based in Romania to either transfer their licence to a Romanian entity, establish a permanent presence in Romania, or apply for a new licence through a Romanian entity within six months of the regulation taking effect (Article III, Emergency Ordinance no. 82 of October 5, 2023).

Therefore, the applicant must be established as a Romanian, EU, EEA or Swiss legal entity.

What does the Application Process involve?

The application process involves submitting detailed documentation about the company, its owners, financial, technical specifications, and more. The ONJN will review the application and conduct the necessary background checks. The administrative taxes for applying and obtaining a Class 1 licence are as follows:

  •  €3,500 for analysis of the file, paid when the documentation for obtaining the licence is filed;
  • €10,500 per year for the issuance of the licence

Any Key Function/Personnel requirements?

Not specifically. However, companies registered in another European Union member state, a signatory state of the European Economic Area or in Switzerland, which operate through a permanent establishment in Romania, must appoint an "authorised representative".

This representative must be a resident of Romania and possess the authority to enter into contracts on behalf of the foreign company. Additionally, this authorised representative should be able to represent the company before Romanian state authorities and courts.

What are the minimum share capital requirements?

The minimum required value of the subscribed and paid-up share capital (the amount of money that a company has received from shareholders in exchange for stock) is RON1m (approx. €201,193).

Server Location and Data Storage, Software Hosting Location Requirements

A system for registration and identification of the participants in the game, a safe server and a mirror server must be located in Romania to provide the regulator with direct access. Data must be stored for at least five years following expiry of the limitation period, for the purposes of public debt recovery associated with this data.

Ongoing Fees

Taxation

Taxes are paid on an annual basis and amount to 21% of the incomes collected from gross gaming revenues (GGR), but no less than €400,000 per year.

A monthly tax of 2% of the total amount of monthly participation fees was introduced starting from January 1, 2019 and Article 1(3) of Order No. 38/2019 defines “the total amount of participation fees” as: “any transfer from the players’ bank account or similar account into their gambling accounts on the gambling platform.”

However, there is no gambling tax regulated for Class 2 licensees.

Annual licence fees

According to Annex 1(I)(J) of the Gambling Act, operators must pay an annual licensing fee for all gambling activities amounting to €300,000 (RON1,489,545).  The annual licensing fee for Class 2 licensees is €20,000.

Estonia Gaming Jurisdiction

Online gambling is regulated in Estonia and the regulatory authority is the Tax and Customs Board.

What is regulated in this jurisdiction?

There is no exhaustive list of online games permitted. However, according to Section 5(1) of the Gambling Act, “[r]emote gambling is the organisation of gambling in a manner where the outcome of the game is determined by an electronic device and the player can participate in the game by electronic means of communication, including telephone, Internet and media services.”

“Gambling is not considered remote gambling where electronic means of communication are used only for receiving bets, informing about the outcome of the game or transferring payments to the account of a player.” (Section 5(2), Gambling Act).

According to Section 3 of the Gambling Act, the types of regulated gambling include:

  • Games of chance
  • Lotteries
  • Totos
  • Games of skill

B2B/suppliers do not need to be licensed in Estonia, i.e., there is no specific licence for suppliers of gaming equipment or software. However, Section 36(5) of the Gambling Act states that “Before starting to organise gambling on a gaming machine used for games of chance or games of skill, the information regarding such gaming machine and its software shall be submitted to the Tax and Customs Board in order to enable identification of the gaming machine and software and verification of their compliance with the requirements of law. The specification of and procedure for submission of the required information shall be established by a regulation of the minister responsible for the area.” Additionally, Section 54(2) of the Gambling Act mandates a remote gambling operator to submit an independent expert assessment to the Tax and Customs Board, regarding the compliance of the used software with the technical requirements.

Overview of Estonia’s licensing regime

Below is a snapshot of the application process and ongoing fees in relation to the Estonian gaming licence.

The Application Process

Who can apply?

A public or a private limited company registered in Estonia or the EU/EEA.

What does the Application Process involve?

A company must firstly apply for an activity licence, upon the issuance of which the company must apply for a separate operating permit.

An activity licence issued by the Tax and Customs Board entitles a person to apply for an operating permit to organise online gambling.

An operating permit, except for organising online lotteries and toto for non-profit associations, can only be issued to the holder of an activity licence. An operating permit to organise remote games of chance, lotteries or games of skill is issued for a period of five years. The following state fee structure shall apply for the reviewing of applications for an activity licence:

  • €47,940 for games of chance.
  • €3,200 for games of skill.
  • €31,960 for toto.

Additionally, the following state fee structure for reviewing applications when it comes to operating permits:

  • €3,200 for gambling games.
  • €640 for lotteries.

Any Key Function/Personnel requirements?

No, there aren't any Key Function/Personnel requirements.

What are the minimum share capital requirements?

A gambling operator shall be a public or a private limited company, with the following minimum share capital specified for different games:

  •  €1m for games of chance
  • €25,000 for games of skill
  • €130,000 for toto

Server Location and Data Storage, Software Hosting Location Requirements

It is not necessary for the server for online gambling to be located in Estonia. However, while applying for the operating permit, the operator has to submit evidence regarding the legal basis and possibilities of the supervisory authority for gambling and of the authority dealing with prevention of money laundering in the country of location of the server to cooperate with the Tax and Customs Board and Financial Intelligence Unit if the server is not located in Estonia or in a state that is a party to the Convention on Cybercrime, and the Tax and Customs Board and the Financial Intelligence Unit do not have a cooperation agreement with the competent authorities of the country of location of the server regarding exchange of information on gambling supervision.

Ongoing Fees

Taxation

Gambling tax is paid monthly.

A 6% tax is imposed on the total amount of bets, less the winnings, when organising games of chance or online games of skill.

The rate will be 7% from January 1, 2026. Additionally, a 6% tax is imposed on the total amount of bets, less the winnings, for organising toto.

Key Contacts

Kyle Scerri

Manager - Gaming & Fintech

Contact
Jan Killips Wright

Senior Advisor - Regulated Industries & Compliance

Contact

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