Choosing a Licensing Jurisdiction: A Comparison for Operators

Operators choosing between licensing jurisdictions rarely fail on the application itself. They fail on what comes after: a duty rate that doubles, a substance requirement they cannot staff, an acquiring bank that declines onboarding. Between April and October 2026 alone, three regimes rewrote their fiscal terms. What follows sets out what each authority charges, what it demands and what it actually opens.

How GICNT-LS Frames the Licensing Jurisdiction Decision

GICNT-LS treats a licence as a verifiable fact rather than a claim. An operator seeking certification has to hold a current authorisation from a body the framework recognises, and that authorisation has to be traceable to the issuing body’s own public register. The recognised set covers the Malta Gaming Authority, the Gambling Commission in Great Britain, the Kahnawake Gaming Commission, the Alcohol and Gaming Commission of Ontario and the New Jersey Division of Gaming Enforcement.

Two jurisdictions sit outside that set without being excluded from it. Curaçao and Anjouan trigger enhanced scrutiny, meaning the licence on its own does not satisfy the domain. The licensing and legal status requirements set out what an operator has to produce instead: evidence that the issuing body exists in law, a working complaints mechanism, and confirmation that a third party can check the licence without going through the operator.

Read commercially, the framework asks the same question a payment provider asks. Who stands behind this authorisation, and what happens when a player disputes a withdrawal?

Licensing Jurisdictions Compared on Fees, Tax and Local Substance

Across the gambling licence jurisdictions compared below, the published government charge is the smallest and most predictable part of the bill. Incorporation, advisory work, technical certification and compliance salaries usually exceed it. The MGA licence types drive both the compliance contribution band and the share capital floor, which is why the Maltese figures vary by game type more than any other regime here.

Jurisdiction and body	Published government fees	Tax on gaming revenue	Local substance required
Malta, Malta Gaming Authority	€5,000 application; €25,000 annual fixed fee for a B2C gaming service licence; compliance contribution from €15,000 to €375,000 for Type 1	5% on revenue from Maltese players, rising to 15% for Type 1 and 10% for Types 2 to 4 on 1 October 2026	Maltese company; player and transaction database hosted in Malta
Great Britain, Gambling Commission	Remote casino application from £4,224, rising to £8,185 on 1 October 2026; annual fee from £4,199, rising to £7,000	40% remote gaming duty from 1 April 2026, plus a statutory levy of 1.1% of gross gambling yield	None; the licence follows the location of the customer
Isle of Man, Gambling Supervision Commission	£5,250 application; £36,750 annual fee	Gambling duty of 1.5% of yield to £20 million, 0.5% to £40 million, 0.1% above that; 0% corporate tax	Player registration and gameplay must run on servers located on the island
Gibraltar, Licensing Authority and Gambling Commissioner	Set by regulations made under the Gambling Act 2025, in force from 1 April 2026	Gaming duty of about 0.15% of gaming yield; corporation tax at 15%	A substantive presence test replaces the former server location test
Ontario, AGCO with iGaming Ontario	CAD 100,000 per gaming site per year	No gaming tax; a revenue share reported at around 20% of gaming revenue is paid to iGaming Ontario under the operating agreement	Registration of the operating entity and of named key persons
Curaçao, Curaçao Gaming Authority	€4,592 application; €47,450 annual for B2C, split between the National Treasury and the authority; €24,490 for B2B	No tax on gaming revenue; 2% corporate profit tax	Curaçao company and a resident managing director, with local staffing phasing in
Anjouan, bodies presenting themselves as the island gaming authority	Roughly €17,000, marketed as an all-in first year figure	None levied	None required

Licence terms differ as sharply as the fees. Malta issues for ten years, the Isle of Man for five, and Curaçao for an indefinite period contingent on the annual fee being settled by 15 January each year. Great Britain attaches no fixed term at all, and revokes for non-payment of the annual fee.

Three Gaming Tax Rates Changed Between April and October 2026

The cost of an online gambling licence is dominated by tax, and tax moved three times in the space of six months.

• Great Britain. Remote gaming duty rose from 21% to 40% for accounting periods beginning on or after 1 April 2026, announced at the Autumn Budget 2025. Bingo duty was abolished on the same date. A separate 25% rate for remote betting enters general betting duty on 1 April 2027, with remote bets on British horse racing staying at 15%. Duty attaches to the location of the customer, so an overseas licence gives no relief. The licence itself is granted against the three licensing objectives in the Gambling Act 2005.
• Malta. Legal Notices 84 and 86 of 2026, published on 1 April 2026, replace the single 5% gaming tax with 15% for Type 1 services and 10% for Types 2, 3 and 4 from 1 October 2026. The levy on gaming devices disappears. The base is unchanged in principle, since only revenue from players established or resident in Malta is caught, so an operator serving other markets from a Maltese licence feels little of it. The VAT exemption for gambling narrows on the same date.
• Netherlands. Gaming tax reached 37.8% of gross gaming revenue on 1 January 2026, the third rise in three years, after 30.5% in 2024 and 34.2% in 2025. Licensed operators carry an additional levy on top.

Minimum Share Capital and Local Presence Requirements Diverge

A minimum share capital for a gambling licence is a Maltese feature more than a general one. The MGA sets €100,000 for Type 1 and Type 2 B2C services and €40,000 for Types 3 and 4, issued and paid up. Great Britain publishes no equivalent floor, and tests the source of funding, the financial position of the applicant and the competence of named individuals instead.

Substance has become the harder constraint. Malta expects a Maltese company with the player and transaction database hosted on the island and accessible to the authority. The Isle of Man goes further on the technical side, requiring player registration and gameplay to run on servers physically located there. Curaçao’s post-LOK licensing regime added a resident managing director from the outset, with local key staff phasing in behind it and the authority deferring enforcement of the headcount rather than dropping it.

The practical test is whether a requirement can be staffed at all. A regime demanding a resident director in a small professional market prices that role accordingly, and the recurring cost lands in the same budget line as the licence fee.

Point of Consumption Rules Decide the Market Access a Licence Delivers

Whatever market access a licensing jurisdiction appears to deliver, the operative rule in every mature market is the location of the player.

• Great Britain. Since the Gambling (Licensing and Advertising) Act 2014, any operator transacting with or advertising to consumers in Great Britain needs a Commission licence, wherever the business is based. A Maltese or Manx licence is not a substitute.
• Netherlands and Germany. Both run national authorisation with active enforcement against unlicensed supply. Curaçao’s own licence conditions prohibit its licensees from serving several such markets, the Netherlands, Germany, France and the United Kingdom among them.
• Canada. There is no federal online gambling licence. Entry means Ontario first, under the AGCO Registrar’s Standards together with an operating agreement with iGaming Ontario, while other provinces are served by their own corporations and Alberta opens a comparable market.
• Everywhere else. An offshore licence authorises the operator in its own jurisdiction. It does not authorise supply into a market that requires local licensing, and it is no defence against enforcement there.

Why the Anjouan Licence Fails at the Verification Step

Risks attached to offshore gambling licences are usually described in terms of thin supervision. Anjouan raises a prior question, which is whether the issuing body has legal standing at all.

The Central Bank of the Comoros has repeatedly described Anjouan-based licensing authorities as fictitious structures with no physical or legal existence in the territory of the Union of the Comoros. The 2024 FATF mutual evaluation of the Union of the Comoros records gambling as prohibited under the Comorian Penal Code, and no sector assessment was carried out on that basis. An Australian Broadcasting Corporation investigation published at the end of December 2025 traced the licence-selling network, and Comorian officials repeated their warnings in January 2026. The Anjouan side answered publicly in June 2026, arguing that its internet gaming licence had never been presented as a universal authorisation to operate in every country, and that no licensing authority can exempt an operator from local law.

Both positions can be quoted. Neither helps an operator whose acquiring bank asks to see the instrument that created the regulator. The failure point is verification rather than supervision, and verification is exactly where payment providers, tier-one game suppliers and affiliate networks make their decision. The licence is priced to match, at roughly €17,000 with a turnaround measured in weeks, and the commercial ceiling arrives quickly. A framework for emerging offshore licence due diligence therefore starts from supervisory practice and verifiability, not from headline cost.

Sequencing the Decision Before an Application Is Filed

Application timelines for a gaming licence run from two to four weeks in Anjouan, to a 16-week target for a complete remote file in Great Britain, to two review phases of roughly eight weeks each in Curaçao, to six to nine months in Malta once technical audit and banking are counted. Sequencing matters more than speed.

1. Fix the target markets first. The licence follows the market, never the reverse. A jurisdiction that cannot lawfully serve the intended player base is the wrong answer at any price.
2. Model three years, not one. Year one flatters low-fee regimes. Year three is decided by the duty rate and the substance bill, and both of those move.
3. Confirm the compliance stack can be staffed. A resident director, an MLRO and a designated key official are recurring salaries, not filing costs.
4. Get payment and supply acceptance in writing. Acquirers and tier-one game studios keep their own jurisdiction lists, and those lists change faster than legislation.
5. Verify the register before committing. If a third party cannot confirm the licence from the issuing body’s own public register, the authorisation will not survive a certification review either.
6. Build the document package for the specific regime. Financial disclosure is where the gambling licence application steps for Malta, Great Britain and Curaçao diverge most, and a file assembled for one authority will not pass at another.