A Romanian iGaming license is two decisions before it is a filing: which ONJN class you need, and which vehicle will hold it. Operators that contract with players need a Class 1 license plus an annual operating authorization, at a fixed floor of €1,280,000 a year since Law 141/2025. Suppliers to those operators need a Class 2 license at €35,000 a year with no GGR tax. Both are issued by ONJN under OUG 77/2009 for 10 years. The fees, steps and dossier are set out in our full Romania gambling license guide; this post covers the choices that decide whether a file succeeds.
1. Statutory framework and regulatory scope
Romania uses two instruments:
- License to organize (licența de organizare): admits the company, valid for 10 years, not transferable or sub-licensable.
- Operating authorization (autorizația de exploatare): for Class 1, the annual right to operate that carries the GGR-based fee.
The core texts are OUG 77/2009, Law 124/2015 (the online regime), HG 111/2016 (methodological norms), OUG 82/2023 and Law 107/2024 (eligibility and fees), Law 141/2025 (fees and enforcement), Law 129/2019 (AML) and the Fiscal Code. ONJN Order 33/2025, in force since 21 March 2025, lists the changes a licensee must notify.
There are three classes. Class 3 is the state lottery monopoly and is not open to private applicants. Since the 2025 Court of Accounts audit, ONJN has added blacklist blocking through ISPs, removal requests to platforms and search engines, server access and monthly supply-chain reporting.
2. Class 1 (B2C): scope, eligibility and capital
Class 1 applies to anyone contracting with players in Romania: sports betting, casino, poker, bingo and other remote games. Each activity carries its own share-capital requirement, and the requirements add up.
Who can hold it. Since OUG 82/2023 (art. 1(2) OUG 77/2009), a Romanian SRL or SA, or an EU/EEA/Swiss entity with a Romanian permanent establishment under art. 8 of the Fiscal Code. The permanent establishment must book the Romanian gambling revenue; a branch that sends it to the parent will not pass.
Share capital (Annex, OUG 77/2009). RON 1,000,000 for remote gambling, and RON 1,000,000 each for fixed-odds betting, pool betting and casino games; RON 2,000,000 for lottery games. These amounts are cumulative across activities.
Guarantee. A separate €2,000,000 instrument for betting, poker and bingo, or €5,000,000 for casino (art. 29 OUG 77/2009). It is not share capital.
People. Fit-and-proper files for every administrator, legal representative and holder of 5% or more (HG 111/2016, Annex 6a), plus a working compliance function.
3. Class 2 (B2B): supplier license
Class 2 covers anyone supplying a Class 1 licensee: game studios, platforms and aggregators, live studios, payment processors, hosting, testing laboratories and affiliates. There is no gambling-specific capital floor. A Romanian company or a company established in the EU/EEA may hold the license; a non-resident EU/EEA licensee needs no permanent establishment but must have an authorized representative in Romania. Suppliers from outside the EU/EEA hold it through a Romanian company.
Fees. €10,500 issuance, then €20,000 a year license fee and €15,000 a year responsible-gambling contribution. Affiliates pay the same amounts; the €6,000 and €1,000 figures still quoted in some guides predate OUG 82/2023.
Scope. ONJN licenses activity categories, not individual products. A new category may need a new application. Aggregators carry source-code registration for the studios they distribute.
Duties since Law 141/2025. Software, platform and payment suppliers must locate players independently, block those reaching unlicensed operators, and report to ONJN by the 10th of each month, including nil reports. Serving a blacklisted domain can cost the license. The full supplier route is on our Class 2 (B2B) license page.
4. Class 1 and Class 2 compared
| Class 1 (B2C online) | Class 2 (B2B) | |
|---|---|---|
| Trigger | Contract with players in Romania | Supply to a Class 1 licensee |
| Vehicle | Romanian company or EU/EEA/Swiss permanent establishment | Romanian company, or EU/EEA company with an authorized representative in Romania |
| Share capital | Annex amounts, cumulative | No gambling-specific floor |
| One-off fees | €3,500 file analysis, €10,500 issuance | €10,500 issuance |
| Annual license fee | €300,000 flat | €20,000 |
| GGR-based fee | 30%, minimum €480,000 | None |
| Responsible-gambling contribution | €500,000 | €15,000 |
| Guarantee | €2–5 million | None |
| Typical timeline | 6–9 months to go-live | 2–3 months |
5. The fiscal stack
- Authorization fee. 30% of GGR with a €480,000 minimum since 1 August 2025 (previously 21% and €400,000). Below €1,600,000 GGR the minimum applies, so the effective rate is above 30%.
- Corporate income tax. 16%. The micro-enterprise regime is not available for gambling.
- Dividends. 16% withholding on dividends distributed from 1 January 2026 (previously 10%).
- Advertising. A 5% contribution on the value of advertising contracts.
- Player winnings. Withheld from the first leu: 4% up to RON 10,000; RON 400 plus 20% of the part over RON 10,000 up to RON 66,750; RON 11,750 plus 40% of the part above.
- VAT. Gambling is exempt without deduction, so the 21% standard rate (since 1 August 2025) on supplier invoices is largely a cost.
Our analysis of the October 2023 fee changes explains how the annex was rebuilt before Law 141/2025.
6. Application sequencing and realistic timeline
ONJN must decide within 30 days of a complete file, and silence is not approval. Every clarification round restarts the practical clock. A realistic Class 1 sequence:
- Weeks 1–2: confirm the activity set and the cumulative capital; choose company or permanent establishment; screen every shareholder, director and UBO.
- Weeks 3–5: incorporate, pay up capital, register for tax, open accounts.
- Weeks 5–8: assemble corporate, KYC and financial files; commission laboratory certification; configure Romanian servers; write AML, responsible-gambling and advertising policies.
- Weeks 8–9: file with ONJN and pay the €3,500 file-analysis fee.
- Around week 12: decision; pay issuance and license fees; apply for the operating authorization.
Laboratory certification and the guarantee usually set the go-live date, not ONJN.
7. Substance, hosting and inspection
Where the main gaming server is outside Romania, OUG 77/2009 and HG 111/2016 require a safe server holding a replica of gaming data and a mirror server with daily reports, both in Romania and accessible to ONJN. Backups may sit elsewhere in the EU/EEA. Ongoing duties include segregated player funds, self-exclusion checks under ONJN Order 79/2025, geolocation records and timely notifications. ONJN now uses its server access to cross-check declared GGR.
8. AML/CFT
Gambling operators are reporting entities under Law 129/2019, with sector instructions in ONJN Order 370/2021 and suspicious-transaction reports to ONPCSB. The EU single rulebook, Regulation (EU) 2024/1624, applies from 10 July 2027. Our post on ONJN’s AML instructions covers the controls in detail.
9. Banking and payment rails
Most Romanian retail banks still decline gambling clients; specialist institutions and EU payment providers are the practical route. Start banking in parallel with the application, because it can take three to six months. Payment providers serving Class 1 operators need their own Class 2 license. ONJN has not authorized crypto-only rails for Class 1.
10. How Romania compares
Romania is an EU regulator with a high fixed floor for operators and a low fixed cost for suppliers. For a B2C brand still testing its product, an offshore license such as Anjouan or Curaçao is cheaper and faster, but neither admits you to Romanian players. For a supplier, Romania Class 2 is often the first EU license to take. All jurisdictions side by side are on our jurisdictions page.
11. Where applications fail
- Capital computed for one activity instead of the cumulative total.
- A permanent establishment registered but revenue booked abroad.
- Laboratory certification commissioned after filing.
- A compliance officer who exists only on paper.
- Shareholder, director or UBO changes never notified under Order 33/2025.
- Class 2 customer lists never checked against the ONJN blacklist.
12. Next steps
Start with a feasibility check: which class, which vehicle, and whether your GGR clears the Class 1 floor. Then structure, prepare and file. Contact us for a scoped quote.