Short answer
Choose Curaçao for an international casino or sportsbook that wants fixed government fees (€47,450 a year B2C, no GGR tax in the LOK) and can staff a Curaçao company. Choose Malta when your acquirers, EMIs or platform partners require an EU regulator and you can carry paid-up share capital of up to €100,000 per game type, approved key functions and a review that typically takes 4–6 months in our practice. Groups that need both hold them in separate companies; the MGA cannot recognize a Curaçao license.
Side by side
| Curaçao | Malta | |
|---|---|---|
| Regulator | Curaçao Gaming Authority (CGA), licensing directly; Ministry of Justice responsible since 19 August 2025 | Malta Gaming Authority (MGA) |
| Legal basis | National Ordinance on Games of Chance (LOK), P.B. 2024 no. 157, in force 24 December 2024 | Gaming Act, Cap. 583; S.L. 583.03 (fees), S.L. 583.05 (authorizations), S.L. 583.10 (gaming tax, as amended by LN 84 of 2026); Directive 3 of 2018 |
| Government cost, year 1 | €4,592 application; €150 per UBO and €150 (B2C) or €128 (B2B) per 10%+ holder; €250 per domain; annual fees pro rata in the year of grant (LOK arts. 5.18–5.19, 6.1) | B2C: €5,000 application + €25,000 annual fee + compliance contribution from €15,000 (Type 1) = €45,000 reference, before relief. B2B: €5,000 + €25,000–35,000 by revenue |
| Government cost, year 2+ | €47,450 B2C (€22,960 supervisory fee + €24,490 license fee) · €24,490 B2B (art. 5.19) | B2C: €25,000 + compliance contribution, paid monthly on revenue (Type 1 €15,000–375,000; Type 2 €25,000–600,000). B2B: €25,000 / €30,000 / €35,000, no compliance contribution |
| GGR or gaming tax | No GGR tax in the LOK, whatever the players' location; profit tax 15% on the first XCG 500,000 and 22% above | Gaming tax only on services to players in Malta: 15% for casino (Type 1) and 10% for other types from 1 October 2026 (LN 84 of 2026). Corporate tax 35% headline, with the imputation and refund system |
| Guarantee or capital | No fixed amount in the fee articles; B2C licensees pay guarantee-fund premiums for player balances (art. 5.7); phase 1 tests financial standing (art. 5.1(2)) | Paid-up share capital: B2C €100,000 (Types 1–2) or €40,000 (Types 3–4), cumulative, capped at €240,000; B2B €40,000; positive equity for the life of the license (Capital Requirements Policy, May 2025) |
| Time to license | Statutory stages of about 22–30 weeks (art. 5.1), plus remedy time; the CGA publishes no overall processing time. Provisional license possible in phase 2. Indefinite term (art. 2.1(5)) | No overall MGA timeline; in our practice the review takes 4–6 months on a complete file, then 60 days to implement in a staged environment with the system audit. 10-year term |
| Local substance required | Curaçao NV or BV with a resident managing director (art. 2.1(4)), own premises (art. 5.12(1)(c)) and compliance officers; a full-time key person from 1 April 2027; Tier-IV hosting in Curaçao for B2C | EU/EEA company (S.L. 583.05 reg. 10(1)), in practice usually Maltese; approved key-function holders (Directive 3/2018 art. 6), with an MLRO for B2C; independent system audit before go-live |
| EU passporting or recognition | None. The CGA is not an EU/EEA regulator, so its license cannot obtain an MGA Recognition Notice. Licensees must comply with each target market's law (conditions art. 3.1) | EU-member-state regulator, but no EU passport: each regulated market needs its own license. The MGA recognizes other EU/EEA authorizations by Recognition Notice (€5,000 a year) |
| Banking and PSP acceptance | The CGA publishes no statement on banking; acceptance is each bank, EMI or PSP's own risk decision. Widely used offshore and accepted by a number of payment providers | An MGA license can make it easier with financial institutions and partners that do not onboard offshore licensees; each institution still makes its own decision |
| Reputation with B2B partners | Direct licensing under a published statute since 24 December 2024, a public register and green (B2C) or blue (B2B) seals; the sub-license system ended and the orange seal lapsed on 15 October 2025 | Established EU regulator; the MGA reports 311 licenses held by 302 companies in 2025 (Annual Report 2025) |
| Best for | International casinos and sportsbooks that want fixed costs and can fund real local substance | Operators and suppliers that need an EU regulator for tier-one payment and platform partners and can carry the capital and key functions |
Year-one total
Curaçao
| Item | Year 1 | Year 2+ |
|---|---|---|
| Application fee (LOK art. 5.18) | €4,592 | — |
| Due diligence (example: two UBOs who are also 10%+ holders) | €600 | — |
| One domain or software application | €250 | — |
| Annual fees, B2C (pro rata in the year of grant) | up to €47,450 | €47,450 |
| Resident managing director (typical market cost) | €10,000–€30,000 | €10,000–€30,000 |
| Compliance officers, one full time in Curaçao as the art. 5.12 key person (typical market cost) | €35,000–€70,000 | €35,000–€70,000 |
| Dedicated office in Curaçao (typical market cost) | €6,000–€15,000 | €6,000–€15,000 |
| Tier-IV data center hosting in Curaçao (typical market cost) | €10,000–€30,000 | €10,000–€30,000 |
| RNG, platform and game testing (typical market cost) | €5,000–€20,000 | €2,000–€8,000 |
| Statutory audit and information-security assessments (typical market cost) | €6,000–€15,000 | €6,000–€15,000 |
| Total | ≈ €125,000–€233,000 | ≈ €116,000–€215,000 |
B2C, assuming a full year of annual fees in year 1; pro rata billing lowers it. Third-party figures are indicative market ranges, not statutory amounts.
Malta
| Item | Year 1 | Year 2+ |
|---|---|---|
| Application fee (S.L. 583.03) | €5,000 | — |
| Annual fixed fee, B2C Types 1–3 | €25,000 | €25,000 |
| Compliance contribution, Type 1 (monthly on revenue) | from €15,000 | from €15,000 |
| Gaming tax (players in Malta only) | 15% / 10% | 15% / 10% |
| Independent system audit (MGA pre-approved auditor) | Auditor quote | On material change |
| Key-function holders, office, company set-up and administration | Not included | Not included |
| Total | €45,000 + third-party items | from €40,000 + third-party items |
B2C Type 1 reference total, before the first-year relief (S.L. 583.03 reg. 9) or the start-up moratorium. Paid-up share capital (€100,000 for Type 1) stays in the company and is not a fee. A B2B critical-supply license costs €5,000 plus €25,000–35,000 a year, with no compliance contribution.
Statutory and typical third-party costs only; plus professional fees, quoted on request.
Choose Curaçao if…
- Your target markets do not require their own license, and you will block the ones that do
- You want fixed government fees of €47,450 a year (B2C) whatever your GGR, with no gaming tax in the LOK
- Your payment providers already onboard Curaçao licensees
- You can fund a Curaçao NV or BV with a resident director, premises, compliance officers and, from 1 April 2027, a full-time key person
- You want the possibility of a provisional license while the second review phase runs
Choose Malta if…
- Your acquirers, EMIs or platform partners will not onboard offshore licensees
- You can carry paid-up share capital (€100,000 for casino or betting) and approved key-function holders
- Most of your players are outside Malta: Malta's gaming tax applies only to players in Malta
- You are a B2B supplier whose operator clients ask for an MGA critical-supply license (€25,000–35,000 a year, no compliance contribution)
- You already hold an EU/EEA license and want to serve MGA licensees through a Recognition Notice
Holding both licenses, and moving between them
Dual licensing means two companies. The CGA licenses only a Curaçao NV or BV with its statutory seat in Curaçao. The MGA licenses only an entity established in the EU/EEA (S.L. 583.05 reg. 10(1)), so one company cannot hold both. A group that holds both typically uses the MGA company for partners and markets that require an EU regulator, and the Curaçao company for international markets whose law allows it. Each license has its own domain list, policies, AML program, reporting and fees.
No recognition between them. An MGA Recognition Notice is available only for an authorization issued by another EU or EEA member state (Gaming Act art. 2(1); S.L. 583.05 reg. 22). A CGA license cannot be recognized in Malta, and an MGA license is not a CGA license: offering games in or from Curaçao needs a CGA B2C license (LOK art. 5.1).
Suppliers. Critical gaming supplies to MGA licensees need an MGA B2B license or a Recognition Notice (Directive 3/2018 art. 27(1)), so a Curaçao-licensed supplier needs a full MGA B2B license. In Curaçao, from 24 December 2026 a B2B supplier license is required only for critical suppliers established in Curaçao, and licensees may obtain critical services or goods only from suppliers on the public supplier register (LOK art. 5.16(4)). The CGA had not published registration rules for foreign suppliers, such as MGA licensees, at our review date.
Moving from Curaçao to Malta. It is a new application to the MGA, by an EU/EEA company, with paid-up share capital, approved key functions and a system audit. Plan the Curaçao license fees on the calendar year: annual fees fall due by 15 January (LOK art. 6.1(3)), and the CGA does not refund fees on rejection or revocation, so time any wind-down of the Curaçao license around that date (see the CGA wind-down instructions of July 2026).
Reviewed by Alex Szilaghi
Founder of Szilaghi Consulting, licensing gambling businesses since 2004 across EU, UK, Canadian and offshore jurisdictions, based in Romania and working before ONJN on Class 1 and Class 2 files. We act as Romanian representative and local director for foreign ONJN licensees and file their monthly regulatory reports, so these guides reflect how the rules are applied in practice, not only how they read. Szilaghi Consulting’s in-house lawyers are Romanian avocați practicing under Law 51/1995.
Last legal review . Current to both regimes as of the review date. General information, not legal advice.
Questions
Is a Malta gaming license more expensive than Curaçao?
Not in government fees at the minimum. A Malta Type 1 B2C license has a €45,000 reference total in year 1 (€5,000 application, €25,000 annual fee, €15,000 minimum compliance contribution); Curaçao charges €4,592 to apply and €47,450 a year. Malta adds paid-up share capital, approved key functions and gaming tax on players in Malta, and its compliance contribution rises with revenue. Curaçao adds mandatory local substance: about €125,000–€233,000 in year one in total.
How long does an MGA license take compared with Curaçao?
Neither regulator publishes an overall timeline. In our practice the MGA review takes 4–6 months on a complete file, followed by a 60-day staged implementation with the system audit. Curaçao's statutory stages add up to about 22–30 weeks, with a provisional license possible in the second phase.
Can a Curaçao license be recognized in Malta?
No. The MGA issues Recognition Notices only for authorizations from another EU or EEA member state (S.L. 583.05 reg. 22). A Curaçao licensee that wants to serve Malta or MGA licensees needs an MGA license.
Do Curaçao and Malta tax GGR?
Curaçao has no GGR tax in the LOK; it charges flat fees, and the company pays profit tax at 15% or 22%. Malta charges gaming tax only on gaming services to players in Malta: since 1 October 2026, 15% for casino and 10% for other game types (LN 84 of 2026). Malta's compliance contribution is a separate license charge on revenue.
Can one company hold both an MGA and a Curaçao license?
No. The CGA licenses only a Curaçao NV or BV, and the MGA only an EU/EEA-established entity. Groups that need both use two companies.
Which is better for banking: Malta or Curaçao?
An MGA license can make it easier with banks, EMIs and partners that do not onboard offshore licensees. Curaçao is widely used offshore and accepted by a number of payment providers. In both cases acceptance is each institution's own decision.
Does an MGA license let me operate across the EU?
No. There is no EU gambling passport; each regulated EU market requires its own license. The same applies, more strictly, to a Curaçao license.
Do I need staff in Malta or Curaçao?
Curaçao requires a resident managing director, your own premises and compliance officers, with a full-time key person from 1 April 2027. Malta requires an EU/EEA company and approved key-function holders who exercise their functions effectively; some roles can be outsourced to approved providers.
Sources
Primary sources only, checked on 10 November 2026: the LOK and CGA publications, MGA guidance and policies, Maltese legislation and the European Commission. Where the LOK and a CGA document differ, the LOK prevails. "In our practice" marks our own experience, not a published rule.
- LOK, National Ordinance on Games of Chance (official English translation)
- CGA, License Fees under the LOK, version 2.0 (15 October 2025)
- CGA, License Reclassification policy (15 October 2025)
- CGA, Local Substance policy v1.0 (10 September 2025)
- CGA, Postponement of local substance requirement under art. 5.12 (23 January 2026)
- CGA portal, FAQ
- CGA, Wind-down of operations and discontinuation of online interfaces (July 2026)
- Belastingdienst Curaçao, Succesvol Ondernemen (profit tax rates)
- Mastercard, Security Rules and Procedures, Merchant Edition (4 August 2026)
- Malta Gaming Authority
- Gaming Act, Cap. 583 — legislation.mt
- MGA — Guidance Note: Licence Fees and Taxation (predates LN 84 of 2026; its 5% gaming tax rate is superseded)
- MGA — B2B Critical Gaming Supply License
- MGA — Recognition Notices
- MGA — Capital Requirements Policy (May 2025)
- MGA — Directive 3 of 2018 (Gaming Authorisations and Compliance Directive)
- MGA — Guidance Note: Application Process
- MGA — Annual Report 2025
- Parliament of Malta — L.N. 84 of 2026, Gaming Tax (Amendment) Regulations
- European Commission — Online gambling in the EU
Not sure which one fits? Ask before you pay a fee
In a free 20-minute fit call we check your business model, ownership and target markets against both regimes and tell you which license fits — and what it really costs in year one.
Book a free fit call