Author: Sebastian Scheplitz
You’ve got this far along the perilous route of starting an online casino. You’ve breezed past our guide to starting an online casino, encountered countless shareholder orcs, basked in the blissful company of angel investors, and wrestled under a bridge with the odd hump-backed accountancy troll.
You’re now ready to take the next, crucial step in unleashing gaming greatness on global audiences, wow stakeholders with your sheer creative brilliance, and transform players’ perceptions as to the future of online gambling.
But wait. You first need a license.
Luckily, you’re in the right place for all the information you need when applying for an online casino license that will cover you for Europe, the UK (okay, technically still Europe but give the Brits time), and the USA.
What Kind of License Do I Need?
In life, you might need a driving license. You could need a hunting license. If you’re required to support The BBC, you may have a TV license. So, it’s a given that you’ll probably need a license to run an online casino. But what kind?
Firstly, nail down the markets in which you wish to operate (online gambling regulations in Germany causing you to stroke your imaginary beard?). Secondly, find out which licensing body to apply for an online casino license, often called a remote license.
Chances are that it’ll fall into one of three categories:
- A Malta Gambling Authority (MGA) license for Europe
- A United Kingdom Gambling Commission (UKGC) license for the UK
- USA Licenses (state-specific) for the USA
What About Other Licenses?
Some successful iGaming platforms hold licenses issued by other bodies such as:
- A Cyprus gambling license
- A Curaçao gambling license
- A Comoros gambling license
- A Kahnawake gambling license
- A Gibraltar gambling license
The licenses listed above are a) easier to get licensed by and b) only issued to casinos that have physical bases in their relevant jurisdictions.
Operators have wised up to the fact that players will check to see if a casino holds a license before signing up, so, it’s imperative that your operation maintains some kind of legislative seal.
If you want to function with minimal licensing, opt for a Curaçao license. A Curaçao license is also the go-to legislative seal for blockchain-based casinos.
Applying for an MGA License
Viewed by many as having the Goldilocks online casino license requirements – the MGA is a must for operators present in multiple markets.
Denise Coates of bet365 fame was recently burned by the MGA and hot-stepped operations (including metric tons of really bad coffee powder) – and thousands of employees – back to the safety of a Gibraltar license.
Here’s everything you need to do to get your hands on an MGA license.
What You Need to Do
To get an MGA license, applicants need to undergo the following stages:
- Fit and Proper – here, the MGA assesses whether or not you have shady underworld dealings, a rap sheet the length of your arm, or not to be trusted with babysitting.
- Business Planning – this stage is to ensure that the applicant has completed an in-depth business plan and detailed financial forecast.
This must also include:
- Cash Flow, Profit & Loss balance sheet
- Documents relating to marketing
- Distribution strategies
- HR plan
- Growth targets
- Operational and Statutory Requirements – this part of the process involves investigation into the following areas:
- Incorporation documents
- Business processes related to conducting the games
- Terms, conditions, policies, procedures and technical documentation of the gaming and control system
- System Review – stage 4 is concerned with how well your operation runs on a technical level. Applicants are given 60 days for a tech rollout. Should this not be completed within the timeframe, you’ll need to resubmit your application.
After the successful completion of step 4, the MGA will issue a 10-year gambling license. High fives all round.
- Compliance Review – after going live, an operation needs to undergo a number of compliance audits. These need to be completed within 90 days of notice from the MGA. The MGA will require the audit to adhere to the following schedule:
- After the first year of operation after being licensed by the MGA; and
- Any other audit depending on the compliance plan set by the MGA
Failure of a compliance check may lead to immediate suspension or termination of your license.
How Much Does An MGA License Cost?
The MGA license comes in with the following price tags:
Fixed Annual License Fee (B2C)
- Non-refundable Fixed Annual Licence Fee – €25,000
- Non-refundable Fixed Annual Licence Fee for operators providing solely Type 4 gaming services – €10,000
Fixed Annual License Fee (B2B)
- Where annual revenue does not exceed €5,000,000 – €25,000
- Where annual revenue exceeds €5,000,000 but does not exceed €10,000,000 – €30,000
- Where annual revenue exceeds €10,000,000 – €35,000
- Licence Fee for providers supplying solely Type 4 gaming supplies
- Fixed annual licence fee – €10,000
B2B – Critical Gaming Supply (supply & management of software)
- Annual revenue does not exceed €1,000,000 – €3,000
- Annual revenue in excess of €1,000,000 – €5,000
Applying for a UKGC License
Reportedly, the UKGC fines license holders for penalties as seemingly benign as sneezing in work elevators.
While the former scenario may indeed be a little far-fetched, it’s worth noting that the UKGC holds the strictest licensing requirements for licensees.
Is it hard to get a gambling license in the UK? Well, let’s take a look.
What You Need to Do
To obtain a UKGC license, you’re going to need paperwork that makes the Watergate scandal investigation look like child’s play. Namely:
|Ownership structure diagram||All but sole trader|
|Management structure||All but sole trader|
|Group structure||Part of a group only|
|Share certificates||Companies limited by shares|
|Articles of association||Limited company only|
|Certificate of incorporation||Limited company only|
|Constitution||Only if you have one|
|Memorandum of association||Limited company only|
|Trust documents||Trust only|
|Partnership agreement||Partnership only|
|Individual identity documents||Sole trader|
|Policies & procedures – LCCP||All|
|Customer terms & conditions||All|
|Rules of play||All|
|Gambling licences from other jurisdictions||All if licensed elsewhere|
|Remote technical standards||Remote licence applicant only|
|Gambling software supply details||Remote licence applicant only|
|Software supply method||Remote licence applicant only|
|Operational model map||Remote licence applicant only|
|System diagram for end-to-end process||Remote licence applicant only|
|Bank statements for last 6 months||All|
|Audited accounts||All except sole trader if applicable|
|Profit & loss projections for the next 3 years||All|
|Proof of funding||All|
|Credit report||Overseas-based only|
|Annual reports to regulators||All except sole trader if applicable|
|Annual returns||All except sole trader if applicable|
|Details of bonus/profit-sharing schemes||All except sole trader if applicable|
|List of individuals compensated over £200k in last 12 months||All except sole trader if applicable|
|Insolvency/administration/liquidation report||All if applicable|
|Personal Management Licence application and required supporting documents from each person responsible for a specified management office or Annex A personal declaration form if the applicant is a Small Scale Operator||All|
|Annex A personal declaration form and supporting documents from each person who holds 10% or more shares in the applicant||Al|
How Much It Will Cost
Applying for an online casino license from the UK will incur costs dependant on details specified by your application and the operation’s profitability. Here’s a guideline:
|Annual GGY||Application fee (£)||Annual fee (£)|
|550,000 – 2 million||4,693||13,432|
|2 million – 5.5 million||4,693||15,536|
|5.5 million – 15 million||10,323||51,334|
|15 million – 55 million||10,323||72,365|
|55 million – 110 million||13,643||116,602|
|110 million – 220 million||23,435||213,052|
|220 million – 550 million||28,154||435,640|
|550 million – 1 billion||41,243||767,027|
|> 1 billion||41,243||1,077,027 plus 200,000 per additional 500 million GGY|
As the world of iGaming legislation is constantly shifting, be sure to check for the latest UK iGaming legislation updates here.
Applying for US Licenses
The great gambling frontier – the US market. Issued state-by-state rather than on a federal level, US licenses need to be obtained depending on the state you wish to operate in.
If you’re still pondering “How do I get a gambling license in the US?”, read on.
What You Need to Do
Taking it from a New Jersey perspective, we discover that not only is there hardly any information online, but the State of New Jersey website was also seemingly built on dial-up in the early 90s.
Here’s the (very detailed) list of documents you’re required to submit:
1. Basic identity information;
2. Past or other names and addresses used by the applicant;
3. Description of past and present business activity;
4. Description of stocks issued and authorized;
5. List of non-voting shareholders;
6. List of qualifiers;
7. Ownership chart;
8. List of former officers and directors;
9. List of the compensation of officers, directors, and partners;
10. List of all employees receiving $300,000 or more in compensation per year;
11. Description of bonus, profit sharing, retirement, and deferred compensation;
12. Descriptions of the ownership interests held by partners;
13. Description and identity of holders of debt;
14. List of securities options, if applicable;
15. List of financial institutions used;
16. List of contracts with suppliers, top 10 contracts by value;
17. Stock held by the applicant;
18. List of insider transactions, past 5 years;
19. Criminal history;
20. Regulatory and civil action history;
21. Bankruptcy history; and,
22. List of gaming and professional licenses.
The following documents must be submitted in connection with the Business Entity Disclosure Form – Gaming:
1. Organization documents (charter, by-laws, etc.);
2. New Jersey business registration certificate;
3. Description of business presently conducted and business intended to be conducted;
4. Description of former business;
5. Ownership chart;
6. Description of all bonus, profit sharing, pension, retirement, deferred compensation plans;
7. Existing litigation;
8. Financial statements, past five (5) years;
9. Annual reports, past five (5) years;
10. Any quarterly or interim reports filed since the last annual report submitted;
11. Last proxy or information statement issued;
12. Registration statements, past five (5) years;
13. Organizational chart of the enterprise;
14. All reports and correspondence with independent accountants pertaining to financial reporting requirements, past five (5) years;
15. Tax returns, past five (5) years.
Additionally, each applicant should provide proof of valid business registration with the Division of Revenue in the Department of the Treasury.
Each applicant must submit fingerprints and written consent for a criminal history record background check.
Gaming-Related Qualifying Individuals
Certain individuals who are employed by Gaming-Related Casino Service Industry License applicants or licensees must file as qualifying individuals.
These individuals include officers, directors, management employees, sales representatives, signatories on agreements, partners, sole proprietors, and direct or indirect beneficial interest holders holding five percent (5%) or more interest in the applicant.
These individuals must complete a Multi-Jurisdictional Personal History Disclosure Form and New Jersey Supplement Form.
A casino service employee registration is valid indefinitely unless revoked, suspended, or limited by the Commission.
The Multi-Jurisdictional Personal History Disclosure Form is a lengthy application requiring detailed personal information. Information required to be disclosed includes:
1. Basic identity information;
2. Citizenship and passport;
3. Residence information, past fifteen (15) years;
4. Family relationships;
5. Occupation information for family members, including spouses of family members;
6. Military service background;
8. Offices and positions held, including fiduciary, government, and trust relationships;
9. Offices and positions held by spouse, past one (1) year;
10. Employment history, past twenty (20) years;
11. Spouse employment history, past one (1) year;
12. Professional or regulatory licensing;
13. Gaming licenses applied for or held;
14. Business ownership information, five percent (5%) threshold;
15. Civil suit and criminal history;
16. Vehicle operation permits and licenses;
17. Financial schedules and bankruptcy history;
18. Net worth statement and schedules including assets and liabilities; and,
19. Three references over 18 years old who are not related to the applicant.
In addition to the information requested in the application, the following documents need to be attached in order to complete the application.
1. Fingerprint card;
3. Military records, if applicable; and
4. Notarized Statement of Truth.
The New Jersey Supplement Form requires the applicant to disclose the following information:
1. Basic identity information;
2. Enterprise applicant identity information;
3. Citizenship information;
4. Civil or criminal records that have been expunged;
5. Ownership interest in certain business enterprises; and
6. Tax return information
The following documents must be submitted in connection with the New Jersey Supplement Form:
1. IRS 1040 forms, past five (5) years;
2. Tax returns, if applicable;
3. Immigration documents, if applicable; and,
Additionally, some qualifiers may request to waive their obligation to qualify as part of a Casino Service Industry Enterprise License.
An officer may request a waiver in writing, and must establish that he is not significantly involved in and has no authority over the conduct of business with a casino licensee.
A request for waiver must include:
1. A description of his title, duties, and responsibilities with the applicant;
2. The terms of his compensation; and
3. A certification by the officer stating that the officer is not significantly involved in and has no authority over the conduct of business with any casino licensee or applicant.
An owner of the applicant may also request a waiver as an institutional investor by demonstrating compliance with both: 1) the standards for an institutional investor, and 2) the standards for waiver.
An owner may also be granted a waiver if he can demonstrate his inability to control the applicant. In a publicly traded corporation, any person who owns 5% or more of the equity securities is presumed to have the ability to control the corporation, unless the presumption is rebutted by clear and convincing evidence.
Clearly death by documents, a New Jersey license is not for the admin-adverse.
How Much It Will Cost
The cost for a New Jersey remote gambling application stands at $5,000.
I’m Now a Gambling License Holder! What’s Next?
First, you need a pat on the back. A remote gambling license application is not for the faint of heart.
Strong administrative support is required throughout – it’s likely that you’ll need to employ an individual with a legal background and experience in remote gambling applications to have the best possible chance of obtaining a licence.
Gambling license requirements in 2022 are essential for every operator and supplier looking to create an iGaming business. The most obvious negative of not holding a license is that players will seek out a licensed casino as opposed to an operator that does not have a license, and you don’t want that.
Yes, license applications are a) lengthy and b) incredibly dull. Unfortunately, they’re one of the necessary evils of casino operations. Also, gambling license requirements change frequently, so, always check with the body’s website to double-check that information provided is accurate.
Once you’re fully striped up, it’s time to populate your casino with players. Just when you thought the hard work was over.
But that’s what Translation Royale and our sister agency WeGotGame are here for. Let us know when you need help.
How did you like Sebastian Scheplitz’s blog post “How to Get a Gambling License in 2022”? Let us know in the comments if you have anything to add, have another content idea for iGaming blog posts, or just want to say “hello.” 🙂