Malta Gaming Licence Types: B2C vs B2B and Game Types 1 to 4

Malta’s 2018 Gaming Act replaced a patchwork of class licences with a simple framework: two licence types, four game types and a handful of certificates and notices. Choosing the right combination at the start determines capital requirements, fees and which products can be launched later. This guide explains each element and how they combine.

B2C Gaming Service licence

The B2C licence authorises a company to offer gaming services directly to players. It is the licence held by online casinos, sportsbooks, poker rooms and bingo operators. A single B2C licence can cover any combination of the four game types, and new game types can be added later by application. B2C licensees pay the compliance contribution on gaming revenue and must meet the player-protection, responsible-gaming and AML obligations in full.

B2B Critical Gaming Supply licence

The B2B licence authorises the supply of critical gaming software and systems to operators: platforms, game content and RNGs, sportsbook engines, aggregation layers that influence outcomes or hold player data, and control systems. B2B licensees do not pay the compliance contribution and face lighter player-facing obligations, but go through the same fit-and-proper and system review. Suppliers of material but non-critical services can obtain a material gaming supply certificate instead.

Type 1: games of chance against the house

Casino games where the player plays against the operator and the outcome is determined by an RNG or a live dealer: slots, roulette, blackjack, baccarat, live casino and virtual sports. Share capital 100,000 euros; compliance contribution from 1.25% of gaming revenue, minimum 15,000 and maximum 375,000 euros a year.

Type 2: fixed-odds betting

Betting on real events at odds set by the operator: sports betting, esports betting and similar. Share capital 40,000 euros; compliance contribution from 4% decreasing to 0.4%, minimum 25,000 and maximum 600,000 euros a year.

Type 3: peer-to-peer games

Games where players play against each other and the operator takes a commission: poker, bingo, betting exchanges, lotteries, secondary lotteries and daily fantasy with a pooled prize. Share capital 100,000 euros; compliance contribution from 4% to 0.4%, minimum 25,000 and maximum 500,000 euros.

Type 4: controlled skill games

Games where skill predominates and that the MGA designates as controlled skill games, principally fantasy sports. Share capital 40,000 euros; a reduced annual licence fee of 10,000 euros for Type 4-only licences; compliance contribution from 0.5%, minimum 5,000 and maximum 500,000 euros.

Combining types

A multi-type licence requires the highest applicable share capital, with total capital capped at 240,000 euros. The compliance contribution is calculated separately for each type. Operators often start with the types they will launch first and add others later, since each addition needs certification and a change application.

Certificates and notices

Beyond the two licences, the MGA issues material gaming supply certificates for non-critical suppliers, key function certificates for approved individuals, and recognition notices that acknowledge licences issued by other EEA regulators in defined situations. Corporate groups may also hold a corporate group licence covering several companies under common control.

Choosing the right combination

The right choice depends on the products in the first-year plan, the capital available, the supply chain and whether the company will also supply others. A platform provider that also runs its own brand, for example, typically needs both a B2B and a B2C licence.

Our licensing practice advises on licence and game-type selection as part of every Maltese application. See also our guides to the Critical Gaming Supply licence and Malta licence costs.