Malta Gaming Licence Requirements: Capital, Key Persons and Documents (B2C)

Malta publishes its licensing requirements in detail, yet applicants are still caught out by how the pieces fit together. This article lists the requirements for a B2C Gaming Service licence in the order the MGA assesses them, with the thresholds and practical notes that matter when you prepare the file.

The licensed entity

The applicant must be a limited liability company established in Malta or elsewhere in the EEA. Shares must be registered, and the ownership chain must be documented up to the ultimate beneficial owners. The MGA does not accept bearer shares or undisclosed nominee arrangements. Most applicants incorporate a Maltese company, which also simplifies the tax refund mechanism available to Maltese trading companies.

Share capital by game type

Malta classifies games into four types. Type 1 covers casino games against the house, including slots and live casino; Type 2 covers fixed-odds betting; Type 3 covers peer-to-peer games such as poker, exchanges and bingo; Type 4 covers controlled skill games. Minimum paid-up share capital is 100,000 euros for Type 1 and Type 3, and 40,000 euros for Type 2 and Type 4. A company offering several types must hold the highest applicable amount, capped at 240,000 euros in total. Share capital must be fully paid up and positive equity maintained throughout the licence term.

Fit-and-proper persons

Every shareholder holding 10% or more, every ultimate beneficial owner, every director and every key function holder undergoes a fit-and-proper assessment. The MGA examines criminal records, regulatory history, insolvencies, litigation and source of wealth. Each person submits a personal declaration, certified identity documents, police conduct certificates and source-of-wealth evidence. Non-disclosure is treated as more serious than the issue itself.

Mandatory key functions

The licensee must appoint approved individuals to the key functions set out in the Gaming Authorisations and Compliance Directive: chief executive, key compliance officer, AML reporting officer, responsible gaming, data protection, technology, information security, legal, finance, internal audit and marketing. Several roles may be combined where there is no conflict, and some may be outsourced to MGA-approved corporate service providers. Each key person holds a personal Key Function Certificate.

Business plan and financial standing

Applicants submit a three-year business plan with marketing strategy, target markets, products, HR plan and detailed financial projections, together with evidence of funding and the source of the invested capital. The MGA checks that the plan is coherent with the policies and the technical setup.

Policies and procedures

Required documents include the AML and CFT policy and risk assessment, responsible gaming policy, player registration and verification procedures, terms and conditions, game rules, data protection documentation, information security policy, business continuity and disaster recovery plans, and outsourcing policy. All must reflect the applicant’s actual operations.

Technical requirements

The gaming system, games and RNGs must be certified by an MGA-approved testing laboratory. The applicant provides a system architecture description, location of the regulatory data with real-time replication where hosted outside Malta, change management and incident procedures. A system audit is conducted before go-live, and the live environment must match the submitted documentation.

Player funds

Player balances must be held in dedicated player-fund accounts segregated from operating funds, with regular reconciliation and reporting. The MGA requires evidence of the banking arrangements and the reconciliation process.

Presence in Malta

The MGA looks for genuine management and control in Malta: a registered office, key persons with meaningful involvement, and regulatory data accessible to the Authority. A brass-plate structure will not pass.

Fees and timeline

A non-refundable application fee, an annual licence fee and a compliance contribution on gaming revenue apply. A complete application typically takes four to six months to approval, after which the licence runs for ten years.

Our licensing practice prepares complete MGA applications. See also our guides on the Critical Gaming Supply licence and the MGA process overview.