Aggregators and Platform Providers: Who Is Responsible for the Licence in the iGaming Supply Chain?

A modern online casino is assembled from parts: a platform, a game aggregator, dozens of studios, payment gateways and KYC vendors. Each is a business in its own right, and regulators increasingly want to know who is licensed for what. This guide explains how responsibility is allocated across the supply chain and where the gaps most often appear.

The operator remains accountable

In every jurisdiction, the B2C licensee is accountable to the regulator for what its players experience: game fairness, responsible-gambling tools, AML controls and data protection. Outsourcing functions to suppliers does not transfer that accountability. Regulators such as the UK Gambling Commission and the MGA expect operators to conduct due diligence on suppliers, hold contracts that allocate obligations, and monitor performance.

Where suppliers need their own licence

Many jurisdictions now license critical suppliers directly. Malta issues a Critical Gaming Supply licence for platforms and game suppliers. Curaçao licenses B2B suppliers under its reformed framework. Romania’s Class 2 licence covers platforms, aggregators, studios, payment processors and even affiliates. The UK requires software suppliers to hold a gambling software licence, and the Isle of Man, Gibraltar and Alderney all license or certify suppliers. Ontario registers gaming-related suppliers. A supplier serving multiple regulated markets typically holds a portfolio of B2B licences or certifications.

Aggregators in the middle

Game aggregators integrate content from many studios and distribute it to operators through a single API. Regulators treat them as critical suppliers where they influence game outcomes or hold game data, and aggregators must ensure that each studio’s content is certified for each market in which it is offered. An aggregator distributing uncertified or unlicensed content into a regulated market creates exposure for itself, the studio and the operator.

Contractual allocation

Supply agreements should specify which party holds which licence and certification in each market, who is responsible for responsible-gambling and AML functionality within the platform, how data is processed and by whom, what happens if a licence is lost, and how regulatory changes are implemented. Regulators may ask to see these agreements.

The risk of unlicensed links

When a studio, aggregator or platform is unlicensed in a market where its content is live, consequences flow up and down the chain: the operator may breach its licence conditions, the supplier may face enforcement or blacklisting, and licensed partners may terminate. Several licensed suppliers have withdrawn from grey-market operators for exactly this reason.

Practical steps

Map every supplier against every market, verify licences and certificates at onboarding and periodically, and build compliance representations into contracts.

Our licensing practice advises suppliers on B2B licensing strategies and operators on supply-chain due diligence.