Gaming Licence Application Checklist: Every Document You Will Need

Every regulator has its own forms, but the documents behind them are remarkably similar. Assembling them before you engage with a regulator is the single most effective way to shorten a licence application. This checklist covers what almost every jurisdiction asks for, grouped by category, with notes on the items that most often cause delay.

Corporate documents

Certificate of incorporation, articles of association, register of shareholders and directors, group structure chart showing every entity up to the ultimate beneficial owners with percentages, board resolutions authorising the application, and evidence of registered office and any local presence. For branch structures, the parent’s documents and the branch registration. Regulators want to follow the chain of ownership without gaps, so include intermediate holding companies and trusts with their beneficiaries.

Personal vetting files

For each director, key person and significant shareholder: certified passport copy, proof of address, detailed CV, personal declaration or questionnaire in the regulator’s format, police clearance certificates from each country of residence in recent years, credit or bankruptcy search results, and, for shareholders, source of wealth evidence such as tax returns, bank statements and asset sale documents. Foreign police certificates are the slowest item; order them first.

Financial evidence

Audited or management accounts of the applicant and parent, proof of paid-up share capital, bank reference letters, source of funds for the investment in the applicant, three-to-five-year financial projections with assumptions, and evidence of arrangements for player-fund protection. Where a bank guarantee or security deposit is required, a draft or issued guarantee.

Business plan

A description of products, target markets, marketing strategy, customer acquisition, suppliers, staffing and governance, with a realistic explanation of how the business will be funded through to profitability. Regulators compare the plan to the projections and to the policies.

Policies and procedures

AML and counter-terrorist financing policy and risk assessment, KYC and customer due diligence procedures, responsible-gambling policy, data-protection and privacy policy, information-security policy, complaints procedure, terms and conditions and game rules, outsourcing policy, business-continuity plan and, where required, a compliance monitoring plan. Each must reflect the actual business.

Technical documentation

System architecture, description of the gaming platform and its components, hosting and server locations, data-flow diagrams, security controls, RNG and game certifications from accredited labs, platform certification or audit reports, and details of third-party suppliers. Several regulators require a system audit before go-live.

Agreements

Platform, game content, payment processing, hosting and key outsourcing agreements, typically in signed or agreed-form drafts, plus white-label or B2B agreements where relevant.

Jurisdiction-specific extras

Examples include the Polish archiving device description and responsible-gambling regulations, Malta’s key function applications, the UK’s personal licence applications, Estonia’s operating permit documentation and Brazil’s local shareholder evidence.

Our licensing practice provides jurisdiction-specific checklists and prepares complete application files for operators and suppliers.