Choosing a jurisdiction for an online casino is a trade-off between speed, cost and market access. Curaçao has run on the new LOK law since 24 December 2024, Malta grants a ten-year licence, and Estonia is cutting its remote gambling tax to 4% by 2029. Anjouan and Tobique are cheap and fast options for non-EU markets, each with its own risks. We compare the five jurisdictions by requirements, fees, taxes and timelines, and by how banks and payment providers view them.
Checked on 21 October 2026. Rules and sources are current as of this date.
Curaçao: the new LOK
Legal basis: the National Ordinance on Games of Chance (LOK), PB 2024, no. 157. Regulator: Curaçao Gaming Authority (CGA). The transition year ran from 24 December 2024 to 24 December 2025; licences are now issued by the state regulator rather than master licence holders.
Who can apply
A legal entity under Curaçao law with its seat on the island, managed by at least one director resident in Curaçao.
Vetting
The CGA identifies UBOs, qualified shareholders and policy-makers. It must refuse a licence if a UBO (ultimate beneficial owner) holding over 25% or a policy-maker has a conviction in the past eight years for fraud, money laundering and other serious crimes. goAML registration is mandatory.
Timelines
Up to eight weeks per phase once all documents are in, extendable by four. A provisional licence for six months (plus six) comes first, then an indefinite one.
Cost
B2C application: EUR 4,592 plus EUR 150 per UBO. Annual: EUR 47,450, made up of EUR 24,490 to the Treasury and a EUR 22,960 CGA supervisory fee. Main domain: EUR 250. Annual fees are due by 15 January.
Malta: the MGA and the Gaming Act
Legal basis: the Gaming Act (Cap. 583) and the Gaming Authorisations Regulations (S.L. 583.05). Regulator: Malta Gaming Authority (MGA). Game types: Type 1 casino, including live casino and virtual sports; Type 2 fixed-odds betting; Type 3 pool betting, exchanges, P2P (peer to peer) poker and bingo; Type 4 controlled skill games.
Who can apply
Only a person established in the European Economic Area (reg. 10(1) S.L. 583.05). A group licence is possible where the parent controls more than 90% of the group.
Term and procedure
Ten-year licence (reg. 6(1)). Fit-and-proper, business plan and document reviews run in parallel, followed by a test environment and a systems audit. Malta’s government portal puts the assessment at about three months.
Fees
Application: EUR 5,000. Fixed annual fee: EUR 25,000 (EUR 10,000 for Type 4 only). Type 1 compliance contribution: EUR 15,000 to EUR 375,000 a year depending on revenue.
Tax
Gaming tax of 5% on revenue from players physically present in Malta.
Estonia: licence plus permit
Legal basis: the Gambling Act (Hasartmänguseadus) and the Gambling Tax Act (Hasartmängumaksu seadus). Regulator: the Tax and Customs Board (EMTA). You need two documents: an indefinite activity licence and a remote gambling operating permit for up to five years.
Who can apply
A public or private limited company registered in Estonia or the EU whose only business is gambling. Minimum share capital for games of chance: EUR 1,000,000. A licence from another EEA (European Economic Area) country is not valid in Estonia.
Technical requirements
Connecting the recordkeeping system to the EMTA information system and to the list of restricted persons; software assessed by an independent expert with ISO/IEC 17025 accreditation.
State fees and timelines
Activity licence: EUR 47,940, decision within four months. Remote gambling permit: EUR 3,200, decision within two months.
Tax
5.5% of stakes less winnings in 2026, 5% in 2027, 4.5% in 2028 and 4% from 2029.
EMTA coordinates each licence application with the Financial Intelligence Unit, which has 60 days to decide. Player stakes must come through a credit, payment or e-money institution or a crypto-asset service provider licensed in the EEA. Existing operators must align their documents by 1 January 2027.
Anjouan: Comoros
Legal basis: the Computer Gaming Licensing Act 2005 of the Autonomous Island of Anjouan (Union of the Comoros). Oversight: the Anjouan Offshore Financial Authority (AOFA) and the Anjouan Gaming Board. Licences are administered by a private company, Anjouan Licensing Services Inc., which the Anjouan Gaming site names as the sole authorised administrator.
Licences
B2C for operators and B2B (business to business) for platform and software suppliers. Permitted: casino, sports betting, poker, bingo, prediction markets, blockchain and crypto gaming.
Vetting
Ownership chain up to the UBO, director and key person documents, financial statements, bank references, source of funds, sanctions screening. Nominees, trusts and foundations must be disclosed.
Obligations
Key person authorisation, an approved ADR (alternative dispute resolution) provider for player disputes and regular compliance reports.
Cost
Licence issuance: EUR 17,828; annual renewal: EUR 17,828, the same for B2C and B2B. Each extra domain: EUR 500. No timelines are given.
The text of the law is not publicly available and there is no independent register of acts. The terms above come from the Anjouan Gaming site (anjouangaming.com). Look-alike sites with similar names and different prices exist, so check who you are dealing with first.
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Tobique: a First Nation in Canada
Legal basis: the Tobique Gaming Act 2023, enacted by the Chief and Council of Tobique First Nation (Neqotkuk) on 13 October 2023, plus regulations and codes of practice. Regulator: Tobique Gaming Commission (TGC); the territory is in New Brunswick. Applications are handled by Differentia Licensing Advisory Group (DLAG), the sole appointed Direct Licensee.
Licences
The Act provides for 11 licence types, all for remote gambling only. According to DLAG, the B2C licence covers all verticals, includes five domains and is valid for one year. A temporary licence lasts up to six months and cannot be issued twice in a row.
Restricted markets
The UK, the US, the province of New Brunswick and FATF-sanctioned countries. Players from there must be geo-blocked and blocked at registration.
Requirements
Full due diligence on UBOs holding 10% or more, including source of wealth. Segregated accounts holding at least 100% of player funds. An AML (anti-money laundering) lead, an ADR provider, certified RNG (random number generator), bi-weekly and monthly reports.
Timelines and cost
Two to three weeks after pre-approval, up to eight weeks in some cases. Fees are not published; there is a non-refundable pre-application fee. Fiat and crypto payments accepted.
The TGC derives its authority from Indigenous self-government rights (s. 35 of the Constitution Act, 1982). At the same time, s. 207(1)(a) of Canada’s Criminal Code allows provincial governments to conduct and manage lottery schemes, including online games. The status of such licences under Canadian law is contested, and banks and partners take this into account.
Online casino licence comparison
Figures from the regulators as of October 2026.
| Curaçao | Malta | Estonia | Anjouan | Tobique | |
|---|---|---|---|---|---|
| Regulator | CGA | MGA | EMTA | AOFA, administrator ALSI | TGC, delegate DLAG |
| Who can apply | local company with a resident director | EEA company | Estonian or EU company | place of incorporation not stated | not stated |
| Capital | not stated | not stated in the licence description | EUR 1m for casino | financial standing required | 100% of player funds segregated |
| One-off fees | EUR 4,592 + EUR 150 per UBO | EUR 5,000 | EUR 47,940 + 3,200 | EUR 17,828 | not published |
| Annual | EUR 47,450 | from EUR 25,000 + compliance contribution | tax on GGR (gross gaming revenue) | EUR 17,828 | not published |
| Gaming tax | general Curaçao rules | 5% on players in Malta | 5.5% (2026) → 4% (2029) | not stated | not stated |
| Term | 6-month provisional, then indefinite | 10 years | indefinite + permit up to 5 years | renewed annually | 1 year |
Case analysis
An online casino operator picks a licence looking only at cost and speed. A sensible order of action is to identify the target markets and payment providers, check whether banks and providers accept the licence, compare disclosure requirements, taxes and timelines, and only then decide.
How to choose
Define your markets
If you need EU players, Curaçao, Anjouan and Tobique will not help much: most EU countries require a local licence. For LatAm, Asia and Africa, operators usually look at Curaçao, Anjouan or Tobique. A Tobique licence excludes the UK and the US.
Start hereBudget for year one
Count not only fees but also capital, audits, a local director, an AML officer and software testing.
Check payments
Banks and payment providers look at the licence first, and acquiring is usually harder with an Anjouan licence. In Estonia, using EEA-licensed payment institutions is a legal requirement.
Assess your team
All regulators vet owners and management. A conviction or a past licence revocation can close the door immediately.
Plan for timelines
Tobique from two to three weeks, Curaçao up to eight weeks per phase, Malta and Estonia three to four months or more.
After the reform Curaçao is a full regulator, but it does not open the EU. Malta is an expensive but recognised route into Europe. Estonia has a high capital threshold and a falling tax. Anjouan is a cheap entry with a closed legal base. Tobique is fast and has a published law, but its status in Canada is contested.
Choose a licence not where it is easiest to get, but where it will be accepted by payment providers and in your markets.LegalBit team
FAQ
Are old Curaçao sublicences still valid?
The LOK transition year ended on 24 December 2025, and licences are now issued directly by the CGA. If you held a sublicence from a master licence holder, check your licence status in the CGA portal.
Can a Malta licence be used across Europe?
No. A Maltese licence allows services from Malta, but many EU countries require their own licence. The MGA rules provide for recognising other EEA licences in Malta, not the other way round.
Can an Anjouan licence be trusted?
Check the licence in the public register on the Anjouan Gaming site and make sure you deal with the official administrator, not a look-alike site. The 2005 law is not publicly available, and banks treat such licences more cautiously.
Can a Tobique licensee accept players from Canada?
The licence expressly excludes only New Brunswick. But Canada’s Criminal Code gives provincial governments the power to conduct lottery schemes, including online games. Serving Canadian players without a province-by-province analysis is risky.
How much does an Estonian licence cost including capital?
State fees alone come to EUR 51,140, plus EUR 1 million share capital for games of chance. Tax is charged on stakes less winnings.
See also: Brazil’s Betting Ban: Provisional Measure No. 1,394; An iGaming licence: your key to a legal online business; How to choose a jurisdiction for company registration; Loot boxes with a secondary market. Case: iGaming platform in a regulated market; Responsible gambling and AML for operators. Services: iGaming lawyers.
- CGA: Getting a Gaming License
- CGA: License Fees under the LOK, v2.0 (15.10.2025)
- MGA: Remote Gaming Services (B2C)
- MGA: Guidance Note on Licence Fees and Taxation
- Gaming Authorisations Regulations, S.L. 583.05
- Servizz.gov.mt: Gaming Licence
- EMTA: Applying for permits
- Riigi Teataja: Hasartmängumaksu seadus
- Riigi Teataja: RT I, 30.12.2025, 2
- Anjouan Gaming: Overview
- Anjouan Gaming: Fees
- Anjouan Gaming: Licensing
- Tobique Gaming Act 2023
- TGC General Code of Practice V2.0
- DLAG: Tobique Gaming License FAQ
- Criminal Code of Canada, s. 207
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