Malta Gaming Licence: what it permits, costs and requires

Start with the operating model, not the company name

The business plan is nearly ready, but one question changes everything: will the Malta entity operate the games, supply the technology or rely on an existing licence? The answer affects the licence category, application documents, capital planning and launch timetable.

A B2C Gaming Service Licence covers offering, providing or operating a gaming service. A B2B Critical Gaming Supply Licence covers specified supplies, including material elements of a game and software or control systems used to generate, capture, control or process essential regulatory records. A B2C licence should not be assumed to cover software-supply activity, and a B2B licence does not itself permit direct consumer operations.

A Recognition Notice may be relevant where the business already holds an authorisation from an EU or EEA state, or from a jurisdiction considered to provide largely equivalent safeguards. It recognises that authorisation for providing gaming services or supplies in or from Malta, but it is not automatic passporting into every market. The certificate is valid for one year and subject to annual maintenance review.

Choose the game type and channel carefully

For remote gaming, the MGA groups services into four types. Type 1 covers casino and other house games, including live casino and virtual sports games. Type 2 covers fixed-odds betting, including live betting. Type 3 covers pool betting, betting exchange, peer-to-peer and commission-based games. Type 4 covers controlled skill games.

A licensee does not generally need a separate Malta licence for every game type. However, an additional game type or gaming vertical requires prior approval through the MGA process. The application may require updated technical documents, policies, terms and conditions, evidence of increased share capital and relevant provider agreements.

The remote B2C application also distinguishes the channel of delivery. A new online channel or domain can require a further application, with the MGA’s prior-approval page listing a €100 charge per additional domain. A corporate group licence may cover group entities where the parent exercises more than 90% control, but the group’s structure and reporting responsibility still need to be documented.

Eligibility, ownership and governance

For the remote B2C route, the MGA describes the applicant as a Maltese or EU/EEA entity wishing to offer a gaming service from Malta, to a Maltese person or through a Maltese legal entity. Malta incorporation is therefore not the only possible route, but the applicant must satisfy the applicable regulatory requirements for its structure and activity.

The MGA’s process examines fit and proper status, funding, the business plan, operating policies, incorporation documents, technical systems and the applicant’s ability to maintain competent resources and sustainable financing. Owners, directors, key-function holders and other relevant persons should be identified and assessed early, particularly in layered international structures.

The published minimum issued paid-up share capital is €100,000 for Type 1, €100,000 for Type 2, €40,000 for Type 3, €40,000 for Type 4 and €40,000 for a Critical Gaming Supply Licence. Companies with multiple B2C type approvals must meet the requirements cumulatively, up to a maximum cap of €240,000. A corporate group may satisfy the requirement through one entity or jointly through two or more group entities without equal contributions.

Minimum nominal share capital is not the whole capital test. The MGA’s Capital Requirements Policy, effective from 2 July 2025, also requires applicants and licensees within its scope to maintain a Positive Equity Position. Where liabilities exceed assets, the policy provides a process for restoring the equity position, subject to its transitional rules.

Fees, contributions and the cost of being ready

For a remote B2C application, the MGA currently lists a non-refundable €5,000 application fee and a €25,000 non-refundable annual licence fee. The annual fee is listed at €10,000 for an operator providing solely Type 4 gaming services. These are regulatory charges, not the full cost of legal, compliance, technical, audit, staffing, payment and banking preparation.

The MGA’s current remote-services page links a Fact Sheet 2026, while the detailed compliance-contribution and B2B fee figures available in the supplied material come from the 2025 fact sheet. That earlier material lists B2C contribution ranges of €15,000 to €375,000 for Type 1, €25,000 to €600,000 for Type 2, €25,000 to €500,000 for Type 3 and €5,000 to €500,000 for Type 4. Treat those figures as historical planning references until reconciled with the current 2026 fee documents.

The same 2025 fact sheet lists B2B annual fee bands for material game elements and for software or control-system supplies. Because the MGA now points applicants to a 2026 fact sheet, those bands should be checked against the current schedule before they are used in a final budget. The same caution applies to any published minimums, maximums or transitional contribution treatment.

Application sequence and going live

A sensible sequence is to classify the products and channels, map the group and ownership structure, prepare the business plan and funding evidence, identify proposed key functions, document policies and controls, then complete the technical build and audit pathway. The MGA advises applicants to review the System Documentation Checklist and relevant enclosure lists before starting the application through the Licensee Portal.

The MGA’s published material describes a standard gaming licence as valid for ten years. After approval, the applicant implements the systems in a technical environment and completes the applicable system-audit pathway. The technical-environment period described in the fact sheet should be kept separate from the 90-day go-live period.

For remote B2C operations, the MGA requires a Go-Live Declaration stating that the authorised person will go live within 90 days of the original licence date. The declaration must be submitted at least two days before the indicated go-live date. A launch plan should also allow time for player-funds accounts, responsible-gaming journeys, customer support, technical controls, audit evidence and any target-market permissions.

Compliance continues after approval

For B2C operators offering Type 1, Type 2 or Type 3 games, the MGA requires a risk-based AML/CFT framework, including a business-risk assessment, customer-acceptance policy and appropriate procedures. The MLRO must have sufficient seniority, be registered with the FIAU and be approved by the MGA as a key AML function.

Player protection must be designed into the operation, not added to the website at the end. The MGA’s guidance refers to licensee details, an underage-gaming warning, responsible-gaming information, the dynamic seal, safer-gambling tools, help-organisation links and information provided before a first deposit. B2C licensees must also put a written player-dispute procedure in place and appoint an approved alternative-dispute-resolution entity when they go live.

The MGA’s ongoing reporting framework includes interim and annual financial reports, audited financial statements, player-funds and gaming-revenue declarations and an auditor’s management letter. Remote B2C audited accounts must separately show player-funds balances and player funds in the relevant notes.

The MGA can use inspections, supervisory reviews, thematic reviews, mystery shopping and compliance audits. Its published material says a notified compliance audit must be completed within three months, while failure may lead to suspension or termination. The licence is therefore an ongoing supervisory relationship rather than a one-time approval.

Tax, VAT and market access: keep the analyses separate

The MGA says revised VAT and gaming-tax frameworks took effect on 1 October 2026 through Legal Notices 84 and 86 of 2026. The reforms address certain sports-betting and casino VAT treatment, eligible input-VAT recovery and a gaming-tax structure based on game type and mode of offer.

There is a live source conflict that should be disclosed rather than papered over: the current MGA remote-services page still displays legacy wording referring to 5% gaming tax, while the MGA’s 1 October 2026 notice describes a revised framework. The complete post-reform rate table was not established from the sources reviewed here, so new operators should use the amended legislation and current MGA or MTCA implementation guidance rather than copy an older summary.

For existing operators, the MGA identifies a transition in reporting: September 2026 submissions were due on 20 October 2026 under the old regime, while October 2026 submissions were due on 20 November 2026 through the updated portal. That timetable is an implementation point for existing licensees, not a substitute for modelling a new business’s tax position.

A Malta gaming licence does not by itself establish tax residence, prove commercial substance, guarantee banking or payment access, authorise operation in every target market or determine shareholder-level tax outcomes. Those questions require separate company-law, tax, payment-services, immigration and market-by-market analysis.

What to prepare before instructing advisers

Prepare a short licensing brief covering the operator or supplier role, game types, channels, brands and domains, group entities, target countries, payment flows, technology stack, ownership chain, proposed key functions, funding, expected revenues and launch timetable. That gives Maltese legal, tax, regulatory and technical advisers something concrete to test rather than a company name and a hopeful spreadsheet.

Keep adjacent questions in their own workstreams. Company formation and substance, gambling software supply, sports-betting operations, crypto-linked gaming and crypto licensing each add issues that a general licence overview cannot resolve. The licensing decision should be made alongside those analyses, but not confused with them.

If the proposed business is primarily a software supplier, review the separate analysis of a Malta gambling software provider. If it is a sportsbook, crypto-linked casino or wider iGaming group, the relevant operating, technology and crypto questions should be tested separately before the Malta licence application is finalised.

Questions people ask

Can one Malta Gaming Licence cover several brands or domains?

Not automatically. One licence may support multiple approved game types and verticals, but additional verticals, channels, domains and material changes can require prior MGA approval. A corporate group licence may cover qualifying group entities, subject to the MGA’s control and reporting requirements.

Does a B2B licence allow a company to accept players?

No. A B2B Critical Gaming Supply Licence concerns specified business-to-business supplies such as material game elements, software or control systems. Direct consumer operations generally require the relevant B2C authorisation.

Is Malta incorporation required for a Malta Gaming Licence?

The MGA’s remote-services page refers to Maltese or EU/EEA entities. Malta incorporation is therefore not presented as the only route, but the applicant must satisfy the applicable eligibility, governance, funding, technical and reporting requirements.

How much capital does a multi-vertical B2C applicant need?

The published minimums apply cumulatively to multiple B2C game types, subject to a maximum cap of €240,000. The MGA’s Capital Requirements Policy also requires a Positive Equity Position, so nominal share capital alone is not the complete funding test.

Are the published gaming-tax rates current after 1 October 2026?

The framework changed on 1 October 2026, but the sources reviewed do not establish a complete post-reform rate table. The current remote-services page still displays legacy 5% wording, so use the amended legislation and current MGA or MTCA implementation guidance.

Does a Malta licence allow access to all countries?

No. It is a Malta regulatory authorisation. Target-market permissions, advertising rules, local restrictions, payment requirements and any recognition or licensing obligations must be checked separately.