How to Obtain a Gambling Licence: MGA, UKGC and Curacao Compared

How an operator obtains a gambling licence depends far less on the application form than on what sits behind it: verified ownership, evidenced funding, and written policies that survive scrutiny. Malta, Great Britain and Curaçao all publish their requirements, and all three now expect the same core disclosures. The cost, the timetable and the tolerance for gaps differ sharply.

What Operators Must Have in Place Before Filing a Gambling Licence Application

Gambling licence application processes in Malta, Great Britain and Curaçao differ in sequence and in price, but the underlying evidence pack is close to identical. Each authority wants to know who owns the business, where the money came from, who will run the compliance function, and what the operator has written down before it accepts a first deposit.

Three things cause more delay than everything else combined. Ownership charts that stop short of the ultimate beneficial owner. Funding that cannot be traced to a documented source. Policies lifted from a template with no account of how they will work in the applicant’s own operation. The Gambling Commission is blunt about the last one: submitting an industry trade body toolkit is not by itself evidence of satisfactory policies, and the applicant must demonstrate how those procedures will be implemented in that specific business.

Under GICNT-LS, an operator’s licence is treated as a live object rather than a certificate on a wall, so the documentation an authority requests at application stage is also what certification review expects to find maintained afterwards. Operators building the function from nothing usually sequence the licence file against the broader work of compliance for new operators, rather than assembling documents in whatever order the form asks for them.

Applying to the Malta Gaming Authority Under the Gaming Act 2018

The MGA sets its licence application requirements under the Gaming Act 2018, which replaced the old class system with two licence categories and four game types. A Gaming Service Licence is the B2C authorisation. A Critical Gaming Supply Licence is the B2B one. Game types run from 1 to 4, and a single B2C licence can combine several of them.

The application fee is €5,000, one-off and non-refundable. What follows depends on the game types applied for.

Game type	Minimum share capital	Annual licence fee	Compliance contribution, min to max per year
Type 1	€100,000	€25,000	€15,000 to €375,000
Type 2	€100,000	€25,000	€25,000 to €600,000
Type 3	€40,000	€25,000	€25,000 to €500,000
Type 4	€40,000	€10,000 where Type 4 is the only service	€5,000 to €500,000

Compliance contribution is paid monthly on gaming revenue accrued in the reference month, due before the twentieth day of the month that follows. Gaming revenue from players physically present in Malta attracts gaming tax at 5%.

The Authority runs the file through four stages: fit and proper, business planning, operational and statutory review, then system review. Probity investigations on shareholders, ultimate beneficial owners and key persons are conducted with other national and international regulatory bodies and law enforcement agencies. Once the earlier stages clear, the applicant has 60 days to implement the operation on a technical environment ahead of the system audit. Miss that window and the application is cancelled, with re-application the only route back. Successful certification produces a ten-year licence, followed by a compliance audit after the first year of operation.

The reporting load attached to the licence matters as much as the application itself: audited financial statements within 180 days of the financial year end, management accounts covering the first six months submitted by the end of the eighth month, and monthly gaming tax and player funds reports. Those obligations vary by authorisation, and they sit alongside the MGA licence types an operator actually holds.

How the UK Gambling Commission Assesses an Operating Licence Application

An operating licence application to the UKGC is assessed on suitability, and the Commission publishes exactly what it means by the word. Five areas carry the weight:

• Identity and ownership, including the identity of whoever ultimately owns a parent corporation
• Finances, past and present, and the resources realistically available to carry out the licensed activities
• Integrity, meaning the honesty and trustworthiness of the applicant and of everyone relevant to the application
• Competence, covering experience, expertise, qualifications and history
• Criminality, covering the criminal record of the applicant and of relevant persons

There is no requirement to incorporate in Great Britain. Section 69 of the Gambling Act 2005 does require a UK address at which documents under the Act can be served. That address cannot be a PO Box, needs a consistent staff presence or an official representative such as an accountant, solicitor or auditor, and must be maintained for the life of the licence.

Disclosure thresholds are precise. Anyone holding 3% or more of the equity must be named with the size of the holding. Anyone at 10% or more is a financial controller and must submit an Annex A or, where they hold a key management function, a personal licence application. Source of funds evidence is triggered at £50,000 for private individual investors, at £1,000,000 for unregulated entities incorporated more than twelve months before the investment, and at any amount for entities incorporated less than twelve months before it. Applicants also list every individual compensated more than US$250,000 or £200,000 in the last financial year.

Application fees scale with projected gross gambling yield. For a remote casino operating licence, the current bands are:

Fee category	Projected annual gross gambling yield	Application fee
F1	Below £550,000	£4,224
G1 and G2	£550,000 up to £5.5 million	£10,323
H1	£5.5 million up to £25 million	£16,235
I1	£25 million up to £100 million	£23,834
J1	£100 million up to £250 million	£38,363
K1	£250 million up to £550 million	£54,131
L1 and M1	£550 million and above	£91,686

Those figures change on 1 October 2026, when a 25% headline increase in operating licence fee income takes effect following the DCMS decision on the fees consultation. The remote casino scale is rebanded at the same time: the entry band becomes £8,185 for projected yield below £250,000, and the top band reaches £165,069. First annual fees stay at 75% of the full annual fee, so a new entrant absorbs both changes in year one. Policies submitted with the application are read against the UKGC licensing objectives, and a file that never connects its procedures back to them rarely survives assessment.

Curaçao Applications After the LOK Came Into Force

The cost of a Curaçao gaming licence changed along with the regime that issues it. The National Ordinance on Games of Chance (Landsverordening op de kansspelen, P.B. 2024, no. 157), known across the industry as the LOK, entered into force on 24 December 2024 and ended the master and sub-licence model. The Curaçao Gaming Authority now issues licences directly, and applications are accepted only through its portal. Anything submitted outside it is not processed or considered.

Eligibility is narrow. Only a legal entity established under Curaçao law, with its statutory seat in Curaçao, can apply. It must be managed by at least one natural person resident in Curaçao, or by a Curaçao corporate entity that itself has at least one resident managing director.

Review runs in two phases. Phase one covers the integrity of the applicant and its financial stability. Phase two addresses the remaining regulatory requirements under the LOK. Once complete documentation is in, the CGA aims to close each phase within eight weeks, extendable by up to four weeks per phase. Under the fee schedule published by the Authority, the application fee is €4,592 for both operator and supplier applications, while the annual B2C charge of €47,450 splits into a €24,490 licence fee payable to the National Treasury and a €22,960 supervisory fee payable to the CGA. Supplier licences carry an annual supervisory fee of €24,490.

An applicant that falls short may still be considered for a provisional licence, valid for up to six months and extendable by up to six more depending on progress against the outstanding conditions. A definitive licence is issued for an indefinite period, subject to suspension or revocation. Where an application is refused, objection to the CGA or appeal to the Court of First Instance of Curaçao must generally be filed within six weeks of the decision.

The published grounds for refusal are unusually specific, and they read as a pre-submission checklist:

• Ultimate beneficial owners, holders of a qualified participation, or policy-makers whose identity, existence or involvement cannot be verified
• A key individual convicted within the past eight years of an offence involving unlawful financial gain, such as theft, fraud, money laundering or terrorist financing
• Source of funds that cannot be sufficiently verified, or that traces to criminal activity
• Application fees not paid in full
• Outstanding tax or social security liabilities without an adhered payment plan
• The applicant or a policy-maker involved in an operation under licence suspension or revocation
• Liquid assets insufficient to pay out expected prizes
• No responsible gambling policy
• No approved alternative dispute resolution mechanism where one is required
• A key person in the operation considered vulnerable
• No registration in the goAML reporting system required by the National Decree goAML

The grounds are strict on paper. Establishing that a given licensee has actually cleared them, and continues to, is a separate exercise, which is why enhanced scrutiny for Curaçao licences remains a live requirement rather than a holdover from the pre-LOK era.

Cost, Timing and Capital Across the Three Regimes

Requirements for an online casino licence diverge most sharply on capital and local substance, not on paperwork. Read side by side, the three regimes price entry in visibly different shapes.

	Malta (MGA)	Great Britain (UKGC)	Curaçao (CGA)
Governing law	Gaming Act 2018	Gambling Act 2005	LOK, in force 24 December 2024
Application fee	€5,000	£4,224 to £91,686 by projected yield	€4,592
Recurring government cost	€25,000 annual fee plus monthly compliance contribution	Annual fee by yield band, first year at 75%	€47,450 a year for B2C
Minimum share capital	€40,000 to €100,000 by game type	No fixed figure, resources assessed	No fixed figure, liquidity for prizes assessed
Local substance	Maltese entity, certified key function holders	No incorporation requirement, UK service address under section 69	Curaçao entity, resident managing director
Published review timetable	Staged, with 60 days for technical rollout	Up to 16 weeks for a casino application	8 weeks per phase, extendable by 4
Licence term	10 years	Indefinite, subject to annual fees	Indefinite once definitive

Malta prices the licence low at the door and high across the decade that follows. Curaçao inverts that shape, with a modest filing fee and a heavier annual charge. Great Britain sets the entry price from projected turnover, so a small operator pays little to apply while a large one pays a five-figure sum before a single policy is read. None of that settles the decision. Market access, banking acceptance, payment partnerships and tax weigh into comparing licensing jurisdictions far more heavily than published fee schedules do.

Where Applications Fail, and What GICNT-LS Expects on File

Reasons a gambling licence application is rejected cluster in a small number of places, and most of them are administrative rather than substantive.

• Incomplete submissions. The Gambling Commission rejects applications with missing documents, does not refund the application fee, and requires the full package to be resubmitted with a further fee.
• Unverifiable ownership. Every regime covered here refuses where the ultimate beneficial owner cannot be established to the authority’s satisfaction.
• Untraceable funding. Source of funds is the most common failure point for applicants backed by private individuals or by recently incorporated entities.
• Policies without implementation. Generic AML and responsible gambling documents that describe good practice in the abstract, with no process map, no escalation point and no named decision-maker.
• System deviation. In Malta, significant changes to the gaming system between application and system audit force a fresh application rather than an amendment.
• Conflicted key persons. Compliance-based roles held by the same individuals who carry growth targets, outside the narrow first-year exemption available to recognised start-ups.

For certification purposes, GICNT-LS treats a licence as evidence only where it can be checked against the issuing authority’s own public register on the date of review, with licence status, permitted activities and the licensed entity name matching what the operator publishes to players. That check runs on the annual review cycle, and it is where the licensing and legal status requirements bite hardest for groups holding several licences across related corporate entities.