Any business that offers casino games, sports betting, poker or bingo to players online needs a licence, and so do most of the platforms, game studios and aggregators that supply those operators. The question is not whether to be licensed but where, and that depends on one distinction: whether the target market licenses at the point of consumption or the licence follows the operator's own base.
Most international groups therefore hold more than one licence: a hub licence for the core operation and its suppliers, plus a local licence in each regulated market that produces material revenue. The table below sets out the nine regimes most often compared.
| Jurisdiction and regulator | Operator licence | Typical use |
|---|---|---|
| Great Britain: Gambling Commission | Remote operating licence by activity: casino, general betting, bingo, betting intermediary, game host, software | Serving British players; required wherever the operator is based |
| Malta: Malta Gaming Authority (MGA) | Gaming service licence (B2C) and critical gaming supply licence (B2B) | EU hub for operators and suppliers |
| Isle of Man: Gambling Supervision Commission (GSC) | Full licence covering every vertical, sub-licence, network services and software supplier licences | One licence across verticals, with network and liquidity models |
| Gibraltar: Licensing Authority and Gambling Commissioner | B2C and B2B gambling operator licences under the Gambling Act 2025 | Established groups with a substantive Gibraltar operation |
| Alderney: Alderney Gambling Control Commission (AGCC) | Category 1 (B2C) and Category 2 (platform) eGambling licences | Operators wanting a Crown Dependency licence with fees scaled to yield |
| Curaçao: Curaçao Gaming Authority (CGA) | B2C online gaming licence and B2B supplier licence under the LOK | Operators serving markets without a local licensing regime |
| Kahnawake: Kahnawà:ke Gaming Commission (KGC) | Client Provider Authorization, with Key Person Permits | Operators hosted in North America seeking a short decision period |
| Estonia: Estonian Tax and Customs Board (ETCB) | Activity licence plus operating permit per gambling type | EU groups serving the Estonian market |
| Sweden: Spelinspektionen | Commercial online gambling licence, betting licence, gaming software permit | Serving Swedish players |
Each regime has its own detailed page: the UK remote gambling licence, the Malta gaming licence and the Isle of Man gaming licence are the three most often held together by groups serving regulated European markets.
The regimes differ less in what they assess than in how much of the business they expect to sit inside the jurisdiction. Every regulator reviews ownership, source of funds, the fitness of directors and key staff, and the player protection and anti-money laundering framework. The variables are fixed capital, resident people, hosting and premises.
| Jurisdiction | Capital | People and substance |
|---|---|---|
| Great Britain | No fixed minimum; finances, forecasts and source of funds assessed | A personal management licence for each specified management role, at £463 per application |
| Malta | €100,000 for Type 1 and 2 games; €40,000 for Type 3 and 4 games and for B2B critical supply; cumulative to a cap of €240,000 | An entity established in the EU or EEA; shareholders, owners and key persons assessed as fit and proper |
| Isle of Man | No fixed minimum; forecasts and funding reviewed | A Manx company, two resident natural-person directors, a resident designated official or operations manager, and player registration on Island servers |
| Gibraltar | No fixed figure in the Act | A sufficient substantive presence: equipment, jobs and tax revenue in Gibraltar; approved individuals in regulated functions |
| Alderney | Ratios at all times: cash above player balances, current assets above current liabilities, total assets above total liabilities by at least 25% | An Alderney registered company, with key individual certificates for managers and persons of significant influence |
| Curaçao | Liquid assets sufficient to pay expected prizes immediately | A Curaçao company with a resident managing director; from 1 April 2027, a dedicated local office and at least one full-time key person |
| Kahnawake | No fixed figure | Hosting at Mohawk Internet Technologies in the Territory; a Key Person Permit for each key person |
| Estonia | €1,000,000 for games of chance; €130,000 for betting (toto); €25,000 for games of skill | A public or private limited company registered in Estonia or the EU; non-resident companies first register with the Board as non-resident taxpayers |
| Sweden | No fixed minimum; suitability and organisation assessed | Application in Swedish; a resident representative where the operator has no EEA establishment |
Every regime licenses or approves individuals as well as the company. In Great Britain the Gambling Commission requires a personal management licence for the people responsible for overall management, strategy, finance, marketing, regulatory compliance, gambling IT and security, and the head of anti-money laundering. Malta assesses shareholders, owners and key persons as fit and proper, and Kahnawake issues a Key Person Permit to each key person. The practical result is the same everywhere: the chief executive, finance lead, compliance officer and money laundering reporting officer (the person accountable for anti-money laundering controls) need clean, documented histories and the experience to answer the regulator's questions in their own words.
Substance is the largest cost difference between regimes. The Isle of Man and Gibraltar expect a real operation on the ground, with resident directors, staff and equipment. Curaçao's LOK, the National Ordinance on Games of Chance of 20 December 2024, moves the island from a nominal model to one with a local office and full-time key staff, and the CGA has confirmed that operators need not meet that requirement before 1 April 2027 (CGA postponement notice). Kahnawake's presence requirement is hosting, not people. Malta, Estonia and Sweden accept companies established elsewhere in the EU or EEA, which lets a group run one operating company across several licences.
Every regulator expects a written risk assessment, customer due diligence proportionate to deposit levels, transaction monitoring, sanctions screening, a named money laundering reporting officer and suspicious activity reporting to the local financial intelligence unit. Responsible gambling controls, including self-exclusion, deposit limits and age verification, are assessed at the same time and tested again after launch.
Regulatory fees fall into three groups: a one-off application fee, an annual licence or supervision fee, and in some regimes a charge that scales with revenue. The figures below are the regulators' own published amounts for a B2C operator at the date of this guide.
| Jurisdiction | Application fee | Annual fee |
|---|---|---|
| Great Britain (remote casino) | £8,185 below £250,000 of gross gambling yield, rising by band to £165,069 at £1.6 billion and above | £7,000 at the lowest band, rising to £1,453,949 at the top band |
| Malta | €5,000, non-refundable | €25,000 (€10,000 for Type 4 only), plus a compliance contribution by game type |
| Isle of Man | £5,250 for every licence type | £36,750 for a full licence; £5,250 for a sub-licence; £52,500 for a network services licence |
| Gibraltar | £30,000 for a B2C betting or gaming operator | £50,000 below £20 million of gross yield; £100,000 to £300 million; £200,000 above |
| Alderney | £10,000 investigation deposit, charged against actual costs | £17,500 in the first year for a new Category 1 licensee, then £35,000 to £400,000 by net gaming yield |
| Curaçao | €4,592, plus €150 per beneficial owner and per qualified interest holder | €47,450: €24,490 licence fee and €22,960 supervisory fee |
| Kahnawake | US$35,000, including the first annual fee; US$40,000 for applications from 1 January 2027 | US$20,000, plus US$1,000 per Key Person Permit |
| Estonia | €47,940 activity licence for games of chance, plus €3,200 per operating permit | None; the ongoing cost is gambling tax |
| Sweden | SEK 230,000 per licence | SEK 240,000 supervision fee per licence |
Sources for each figure are the Gambling Commission's fee pages (fees in force from 1 October 2026), the MGA's guidance note on licence fees and taxation, the GSC's fee schedule, Gibraltar's Gambling (Duties and Licence Fees) Regulations 2026, the AGCC fee schedule, the LOK, the KGC fee notice, the ETCB's permit guidance and Sweden's Gambling Ordinance and SIFS 2026:1.
Platforms, aggregators and game studios hold their own licences in most regimes, and regulated operators may only use licensed suppliers.
| Jurisdiction | Supplier licence | Fees |
|---|---|---|
| Great Britain | Gambling software or game host operating licence | Banded by gross gambling yield |
| Malta | Critical gaming supply licence | €5,000 application; €25,000 to €35,000 a year by revenue |
| Isle of Man | Software supplier licence | £5,250 application; £36,750 a year |
| Gibraltar | B2B gambling operator licence (aggregator or platform) | £20,000 application; £85,000 a year for one vertical, plus £15,000 per additional vertical |
| Curaçao | Supplier licence | €4,592 application; €24,490 a year |
| Sweden | Gaming software permit | SEK 120,000 application; SEK 16,500 a year |
For a growing operator, tax outweighs licence fees within the first year of trading. Point-of-consumption markets tax revenue from their own residents at high rates; hub jurisdictions charge low rates or fixed fees and compete on stability and substance instead.
| Jurisdiction | Rate | Basis |
|---|---|---|
| Great Britain | Remote Gaming Duty 40% from 1 April 2026; remote general betting 15%, rising to 25% from 1 April 2027 | Remote gaming profits; net betting receipts |
| Malta | 5% gaming tax, plus a compliance contribution of 0.40% to 4.00% by game type within published minimums and maximums | Gaming tax on gaming revenue from players physically in Malta; the contribution is paid monthly |
| Gibraltar | 0.15%, with the first £100,000 exempt | Gross betting profit and gross gaming profit, paid quarterly |
| Curaçao | No percentage levy in the LOK | Fixed annual licence and supervisory fees |
| Kahnawake | No percentage levy published by the KGC | Fixed annual fees |
| Alderney | No gaming duty in the AGCC schedule | Annual fees banded by net gaming yield |
| Estonia | 5.5% in 2026 | Bets received less prizes, monthly |
| Sweden | 22% since 1 July 2024 | Stakes less payouts on Swedish participation, monthly |
The UK rates are set out in HM Revenue and Customs' gambling duty changes. Isle of Man gambling duty is charged under Manx law separately from the GSC's licence fees; the GSC's fee schedule publishes no duty rates, so the current bands are confirmed at scoping. Estonia's Parliament amended the Gambling Tax Act so that the 5.5% rate applies to remote games of chance as well as games of skill from 1 March 2026 (Riigikogu). Corporate income tax is assessed separately from gaming duty in every jurisdiction, and the group's overall position depends on where management and control sit.
Published timescales run from a complete application, so preparation time, typically six to ten weeks for a well-organised group, comes first. The regulator figures below are the authorities' own; the planning column is the range BCC works to from submission.
| Jurisdiction | Regulator's published period | Planning range from submission |
|---|---|---|
| Great Britain | 16 weeks for an operating licence and 8 weeks for a personal licence; the Commission states these are not guaranteed | 4 to 6 months |
| Malta | 19 days of vetting, then about 3 months of assessment, then a systems audit before the licence issues | 4 to 6 months to go-live |
| Isle of Man | Typically 10 to 16 weeks from a complete application | 3 to 4 months |
| Gibraltar | No fixed period in the Gambling Act 2025 | 3 to 5 months |
| Alderney | About 60 days on average to licence approval; live activation routinely within 6 months of the initial application | 2 to 3 months to the licence |
| Curaçao | Two review phases of 8 weeks each from complete information, each extendable by 4 weeks | 4 to 5 months |
| Kahnawake | 4 to 8 weeks for the first phase, then a 6-month preliminary authorization | 1 to 2 months to the preliminary authorization |
| Estonia | Activity licence within 4 months of complete documents (6 at most); operating permit within 2 months (4 at most) | 6 to 8 months across both stages |
| Sweden | No statutory period; processing starts when the fee is paid | 3 to 6 months |
The Malta stages are those published on the Government of Malta's gaming licence service page. The fastest route to a live licence is a complete first submission: ownership charts that reach every beneficial owner, source of funds evidence for each investor, finished policies written for the firm's own model, and a technical environment ready for testing. Every regulator in this guide either stops its clock or extends it when information is outstanding.
A licence is only commercially useful once players can deposit and withdraw. Payment infrastructure for a gaming operator has four parts, and each is planned alongside the application rather than after it.
Banks and acquirers treat the licence as the starting point and the regulator's reputation as a factor in their own risk assessment. A licence from a regulator with published supervision, enforcement and player protection standards widens the range of banking partners and lowers processing costs. Groups operating under a Curaçao or Kahnawake licence typically pair it with acquiring arranged in the markets they serve. Acquiring and player funds accounts are opened in parallel with the application, so the operator can launch on approval. See the Curaçao gaming licence page for the CGA's position on player balances.
Approval starts the supervisory relationship. The obligations that follow are broadly similar across the nine regimes.
Groups entering a new market after approval add local licences rather than extending the first. A hub licence holder entering Sweden applies to Spelinspektionen in Swedish; see the Sweden online gambling licence page.
The right licence follows from where the players are, what the business supplies and how much of the operation the group is prepared to locate in the jurisdiction. Five questions settle most decisions.
In practice, groups targeting regulated European markets commonly combine Malta with Great Britain, adding Sweden and other national licences as revenue grows. Groups seeking a Crown Dependency base with a single licence across verticals choose the Isle of Man or Alderney. Established operators with a Gibraltar presence use the new Gambling Act 2025 regime, described on the Gibraltar remote gambling licence page. Operators focused on markets without a local regime use Curaçao or Kahnawake, with the LOK's substance requirements now part of the Curaçao decision.
It depends on where the players are. Revenue from Great Britain or Sweden requires those local licences. For an EU hub, Malta is the most widely held; for a single licence across verticals, the Isle of Man; for markets without a local regime, Curaçao or Kahnawake.
On regulatory fees alone, Kahnawake (US$35,000 including the first year, then US$20,000), the Isle of Man (£5,250, then £36,750 a year) and Curaçao (€4,592, then €47,450 a year) are the lowest. Total cost also includes substance, staff, hosting, tax and banking, which differ more than the fees.
No. Great Britain and Sweden license at the point of consumption, so an operator serving their residents needs a Gambling Commission or Spelinspektionen licence alongside its MGA licence. There is no EU passport for gambling.
Regulator figures range from 4 to 8 weeks for Kahnawake's first phase to 16 weeks for the Gambling Commission and two eight-week phases in Curaçao. Estonia allows up to four months for the activity licence and two for the operating permit. Preparation adds six to ten weeks.
UK Remote Gaming Duty is 40% from 1 April 2026 and Sweden's gambling tax 22%. Malta charges 5% on Maltese players plus a compliance contribution, Estonia 5.5% in 2026 and Gibraltar 0.15%. Curaçao and Kahnawake charge fixed annual fees.
In the Isle of Man, yes: two resident directors and a resident designated official or operations manager. Gibraltar requires a substantive presence, and Curaçao requires a local office and full-time key staff from 1 April 2027. Malta, Estonia and Sweden accept EU or EEA companies.
In most regimes, yes. Malta issues a critical gaming supply licence, the Isle of Man a software supplier licence, Gibraltar a B2B licence, Curaçao a supplier licence, Sweden a gaming software permit and Great Britain a gambling software or game host licence.
Buckingham Capital Consulting obtains online gaming licences for operators and suppliers in the United Kingdom, Malta, the Isle of Man, Gibraltar, Alderney, Curaçao, Kahnawake, Estonia and Sweden, and arranges the banking, payment processing and technology that each licence requires.
Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or [email protected].
This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.