Malta B2B Critical Gaming Supply Licence: The Complete Guide for Suppliers

Malta licenses the supply chain, not only the operator. Under the Gaming Act and the Gaming Authorisations Regulations, companies that provide the software and systems a licensed casino or sportsbook runs on need their own authorisation: the Critical Gaming Supply (CGS) licence. It is the most searched-for B2B gaming licence in Europe and, for suppliers who want to work with tier-one operators, it has become close to mandatory. This guide explains what counts as critical supply, what the MGA requires and how the process runs.

What the MGA classifies as critical gaming supply

The regulations define critical gaming supply as the supply and management of material elements of a game, and the supply and management of software that generates, captures, controls or processes essential regulatory data. In practice this covers gaming platforms, RNG and game content including live casino, sportsbook engines, aggregation layers that influence game outcomes or hold player data, and control systems used for regulatory reporting. Suppliers whose services do not touch game outcomes or regulatory data, such as marketing tools or hosting, may instead need a material supply certificate or no authorisation at all.

Licence types and the material supply certificate

Malta issues two licence types: the B2C Gaming Service licence for operators and the B2B Critical Gaming Supply licence for suppliers. A single company may hold both. Suppliers of material but non-critical services can apply for a material gaming supply certificate, a lighter-touch recognition. Getting the classification right at the outset determines the capital, fees and timeline of the application.

Corporate and fit-and-proper requirements

The applicant must be a company established in Malta or another EEA state, with a transparent ownership structure traceable to natural persons. Shareholders above the threshold, directors and key function holders go through fit-and-proper assessment covering integrity, financial standing and competence. Key functions such as CEO, compliance, AML (where applicable), technology and information security must be filled by approved individuals, several of which may be outsourced to approved service providers.

Share capital and financial standing

Minimum share capital for a B2B licence is forty thousand euros, lower than for casino-type B2C licences. The MGA also assesses the business plan, financial projections and sources of funding, and expects the company to maintain positive equity on an ongoing basis.

Technical requirements

Applicants submit a detailed description of the system architecture, including the location of the regulatory data, security controls, change management and business continuity arrangements. Games and RNGs must be certified by an approved testing laboratory against the MGA’s technical standards. Where regulatory data is hosted outside Malta, the MGA requires real-time replication or equivalent access arrangements.

The application process and timeline

The process runs in stages: fit-and-proper review of the people, business planning review, operational and statutory requirements, and system review. A complete application typically takes four to six months, after which the licence is issued for ten years. Before launching new games or system components, the licensee notifies the MGA and provides the relevant certifications.

Fees

B2B licensees pay a non-refundable application fee and an annual licence fee that scales with annual revenue bands. Unlike B2C licensees, B2B licensees do not pay the compliance contribution on gaming revenue, and Malta’s corporate tax refund system can make the overall position efficient for suppliers with scale.

Ongoing obligations

Licensees must submit audited accounts, periodic compliance reports, incident notifications and change requests, and must undergo system audits when the MGA requires them. Changes in ownership, key persons or critical system components need prior approval or notification.

Why suppliers choose Malta

An MGA B2B licence is recognised by operators, banks and other regulators, and is often the key that opens integrations with operators licensed in Malta and beyond. For studios and platforms planning to serve regulated European markets, it is usually the first B2B licence worth obtaining.

Our licensing practice prepares Critical Gaming Supply applications end to end, from classification and corporate setup to system review. See also our guide to the Malta B2C licence.