TL;DR: Romania runs a two-instrument regime under GEO 77/2009: a licence to organise (up to 10 years) and an annual authorisation to operate that carries the tax. Class 1 is B2C and vertical-specific; Class 2 is B2B and granted by generic activity category.
Since Law 141/2025 (in force 1 August 2025), remote operators pay 30% of GGR with a EUR 480,000 annual floor, which makes Romania uneconomic below roughly EUR 1.6m of GGR and efficient above it. Corporate income tax is 16%, dividends 16% from January 2026, and player winnings are withheld at 4% / 20% / 40% from the first leu.
Class 1 capital is set per vertical in the Annex and applies cumulatively across verticals. Class 2 has no gambling-specific capital floor but pays EUR 20,000 plus a EUR 15,000 responsible-gambling contribution annually.
Foreign entities can hold a licence through an art. 8 permanent establishment recognising Romanian gambling revenue in full — the branch must actually book the revenue. Substance is real: safe and mirror servers physically inspectable in Romania, a resident compliance officer, and EU backups only off-site.
Class 2 licences are now enforcement instruments. Suppliers must block unlicensed operators and file monthly reports on player attempts to reach them, which turns a client list into a regulatory exposure.
Timelines run 6–12 months for Class 1 and 3–6 for Class 2, with laboratory certification, not ONJN review, usually setting the critical path.
A practitioner’s analysis of authorization under GEO 77/2009 and Law 124/2015 as amended by OUG 82/2023 and Law 141/2025: license classes, statutory capital, the fiscal stack, application sequencing, substance and AML obligations, and how Romania measures against Malta, Curaçao, Nevis and Anjouan.
Romanian gambling, land-based and remote, is governed by Government Emergency Ordinance no. 77/2009 on the organisation and operation of games of chance, approved with amendments by Law no. 124/2015, given operational content by Government Decision no. 111/2016, restructured by OUG 82/2023, and repriced by Law no. 141/2025 with effect from 1 August 2025. The regulator is the Oficiul Național pentru Jocuri de Noroc (ONJN), constituted under GEO 20/2013 with licensing, inspection and sanctioning powers.
Anyone still modelling a Romanian entry on the pre-2025 numbers is working from a superseded schedule. The authorisation tax moved from 21% to 30% of GGR, the player withholding scale lost its exempt band, and Class 2 suppliers acquired affirmative duties to suppress the black market. The cost of authorisation in Romania is high. The cost of operating outside it, for both operator and supplier, is now materially higher.
1. Statutory Framework and Regulatory Scope
Romanian gambling law separates two instruments that are commonly conflated. The licence to organise (licența de organizare) establishes eligibility and runs up to ten years. The authorisation to operate (autorizația de exploatare) permits activity, is granted annually, and carries the revenue tax. Both are nominal, time-limited, and exploitable only by the holder. There is no sub-licensing.
The instruments in force:
| Instrument | Function |
|---|---|
| GEO 77/2009 (MO 439/26.06.2009) | Primary law. Defines remote gambling at art. 10(1)(h)–(n), licensing conditions at art. 15, sanctions at art. 22 and following, and the fee and capital schedule in its Annex |
| Law 124/2015 | Approved with amendments GEO 92/2014; consolidated the licence/authorisation architecture and the current fiscal-budgetary treatment |
| GD 111/2016 | Methodological norms. The operational rulebook for documentation, technical specification, certification and inspection |
| OUG 82/2023 (in force 06.10.2023) | Required a Romanian company or a registered permanent establishment recognising the full gambling revenue; introduced fixed responsible-gambling contributions; restricted licence transfer |
| Law 141/2025 (MO 699/25.07.2025, in force 01.08.2025) | Raised the authorisation tax, rewrote the player withholding scale, imposed blocking and monthly reporting duties on Class 2 licensees, expanded ONJN takedown powers |
| Law 129/2019 + ONJN AML instructions | Preventive AML/CFT regime, applicable to every licensee irrespective of place of incorporation |
| Law 227/2015 (Fiscal Code) | Corporate income tax, VAT, withholding on winnings, and the art. 8 permanent-establishment definition on which art. 1(2) of GEO 77/2009 now depends |
| Order no. 33/2025 (ONJN President) | Defines “significant changes” triggering mandatory post-issuance notification |
Three statutory classes exist. Class 3 is reserved by law to the state lottery monopoly. Private applicants are concerned with Class 1 and Class 2, addressed below.
ONJN’s posture changed in April 2025 with the leadership reset that followed the Court of Accounts audit covering 2019–2023. What was an episodic enforcement practice is now sustained: blacklisting decisions with DNS-level enforcement, removal orders addressed to platforms and search engines, a digital register of gaming machines hosted in the Government Private Cloud, and monthly supply-chain reporting. Current enforcement activity and market movement are tracked at igaming.express. The regulator’s full legislative index sits at onjn.gov.ro.
2. Class 1 (B2C): Scope, Eligibility and Capital
A Class 1 (B2C) authorisation is required of any entity contracting directly with a player located on Romanian territory. The grant is vertical-specific: online sports betting, online casino, poker, bingo, counterparty betting and fixed-odds betting on virtual events are separately authorised. A single holder may stack verticals, and each carries its own fee and its own capital charge.
Corporate eligibility. The frequently repeated proposition that a foreign entity cannot hold a Romanian Class 1 licence is not what art. 1(2) of GEO 77/2009 says. As amended by OUG 82/2023, the State may grant the right to organise gambling to a company registered in Romania or to a legal person constituted in an EU member state, an EEA signatory state or Switzerland which has registered a permanent establishment in Romania under art. 8 of Law 227/2015, at the level of which gambling revenue is recognised in full.
That last clause is the whole test. A registered branch that books Romanian revenue to a foreign parent does not satisfy art. 1(2). In practice most applicants incorporate a Romanian SRL or SA because the permanent-establishment route requires a revenue-recognition position that must survive both ONJN and ANAF scrutiny. Guidance on Romanian SRL formation, including the fit-and-proper file ONJN expects on shareholders and directors, should be settled before capital is committed.
Minimum share capital. Subscribed and paid-up capital is fixed in point 2 of the Annex to GEO 77/2009, measured at the date the licence application is filed, and set by reference to the categories of gaming means used:
| Vertical | Minimum subscribed and paid-up capital |
|---|---|
| Lottery-type games | RON 2,000,000 |
| Fixed-odds betting | RON 1,000,000 |
| Mutual (pool) betting | RON 1,000,000 |
| Counterparty betting | RON 1,000,000 |
| Casino-type games | RON 1,000,000 |
| Poker club | RON 100,000 |
| Tombola | RON 100,000 |
The cumulation rule in the footnote to point 2 governs the budget: where the same organiser seeks a licence covering several categories of gaming means, the minimum capital condition applies cumulatively. A remote operator launching casino, fixed-odds betting and poker capitalises against the sum, not the highest single line. Applications filed against a single-vertical figure are not corrected on review; they fail.
Capital sits separately from the guarantees securing player balances and state obligations. Euro-denominated guarantees and fees convert at the ECB rate published on the first working day of October in the preceding year, held constant for the following calendar year — the detail that determines what your bank actually blocks.
Other conditions of grant: fit-and-proper clearance of shareholders at or above 10% and of all directors, with beneficial-ownership verification involving the ONPCSB (Romania’s financial intelligence unit); certification of the platform, RNG and per-game RTP by a Class 2 licensed laboratory; the server topology described in section 5; and a Romanian-resident compliance officer.
The licence runs up to ten years subject to annual payment. It is not freely transferable: OUG 82/2023 permits transfer of the licence and its authorisation, with all attaching obligations, only with ONJN approval and within a division, merger or business transfer under Law 31/1990. Change of control is otherwise handled through the notification regime under Order 33/2025, not by assignment.
3. Class 2 (B2B): Supplier Authorisation
A Class 2 (B2B) supplier authorisation is required of any entity supplying gambling-related products or services to a Romanian-licensed Class 1 operator. The perimeter is deliberately wide:
- Game content providers — slot and table studios, live-dealer operators, virtual sports suppliers
- Platform, RGS and aggregation providers delivering content by API
- Payment processors and PSPs routing deposits and withdrawals for operators
- Affiliate networks and performance-marketing partners
- Testing and certification laboratories, separately accredited by ONJN
- Infrastructure and tooling — hosting, RNG, anti-fraud, KYC, CRM
Two features distinguish the Class 2 regime from the Class 1 regime, and both are misunderstood in circulation.
There is no gambling-specific share capital floor for Class 2. Point 2 of the Annex sets capital by reference to the organisation of gambling — a Class 1 function. A supplier is subject to ordinary company law capital and to ONJN’s qualitative assessment of financial standing (audited accounts, forward budget, group consolidation where relevant). What a supplier pays instead is fixed and annual: EUR 20,000 licence fee (EUR 6,000 for affiliates) plus the EUR 15,000 responsible-gambling contribution (EUR 1,000 for affiliates). Administrative fees on the remote file are EUR 3,500 for documentation analysis and EUR 10,500 on issuance.
The licence is now an enforcement instrument. Since Law 141/2025, defined categories of Class 2 supplier — platform, software and payment processing — must block services to operators lacking a Romanian Class 1 licence, and Class 2 holders file monthly reports to ONJN on player attempts to access unlicensed platforms. A supplier’s client list has become a regulatory exposure. Contractual indemnities from an offshore operator are not a defence to a Romanian sanction.
Scope of grant is by generic activity category — “production and distribution of gambling software”, “provision of hosting facilities” — not by product or title. A new category of activity requires a fresh authorisation step. Aggregators carry a further obligation: each third-party studio distributed through the platform must complete its own source-code registration in Romania.
Most foreign suppliers operate through a Romanian SRL rather than a foreign entity with an authorised representative, because Romanian Class 1 operators default to Romanian-domiciled counterparties to simplify their own compliance file. Affiliates sit inside this perimeter, not outside it — see affiliate compliance.
4. Class 1 and Class 2 Compared
| Class 1 — B2C Organiser | Class 2 — B2B Supplier | |
|---|---|---|
| Trigger | Direct contractual relationship with the player | Supply of products or services to a Class 1 licensee |
| Corporate form | Romanian company, or PE under art. 8 Fiscal Code recognising full gambling revenue | Romanian entity, or foreign entity with authorised representative and Romanian address |
| Scope of grant | Per gambling vertical | Per generic activity category |
| Minimum capital | Annex point 2, per vertical, cumulative | No gambling-specific floor; financial standing assessed qualitatively |
| Revenue tax | 30% of GGR, minimum EUR 480,000 per year | None |
| Annual licence fee | Turnover-banded scale under the Annex | EUR 20,000; EUR 6,000 for affiliates |
| Responsible gambling contribution | EUR 500,000 per year | EUR 15,000 per year; EUR 1,000 for affiliates |
| Certification | Full platform, RNG and per-game RTP | Product and system certification for the supplied scope |
| Server obligations | Safe server, mirror server, ONJN terminal reporting | Source-code registration; support of operator obligations |
| Post-Law 141/2025 duties | Geo-blocking, self-exclusion integration, real-time reporting | Blocking of unlicensed operators; monthly attempted-access reporting |
| Validity | Licence to 10 years; authorisation annual | Up to 10 years |
| Realistic timeline | 6–12 months from corporate kickoff | 3–6 months for a clean file |
5. The Fiscal Stack
Four separate levies apply. Modelling them as one number is the most common error in operator financial plans, and it is the error that produces a business case that fails at first authorisation renewal.
Authorisation tax on gross gaming revenue. Law 141/2025 raised the remote rate from 21% to 30% of GGR, subject to a floor of EUR 480,000 per annum (previously EUR 400,000). GGR is defined at art. 1^1 of GEO 77/2009 as stakes less winnings paid. The increase applied to authorisations already in force, the tax for the remaining validity period being recalculated at the new level without grandfathering. Land-based fixed-odds betting moved to 25%.
The floor deserves separate attention. Until roughly EUR 1.6 million of annual GGR, the 30% rate is economically irrelevant — an operator pays EUR 480,000 whatever it earns. Romania is therefore a poor jurisdiction for a low-volume or exploratory B2C launch, and an efficient one at scale.
Corporate income tax. 16% on net taxable profit under Law 227/2015. The micro-enterprise regime is statutorily unavailable to gambling activity. Because the authorisation tax is levied on gross revenue, an operator can be loss-making for CIT purposes while carrying a substantial GGR charge. From 1 January 2026 the dividend withholding rate rose from 10% to 16%, which changes the shareholder-level outcome of every repatriation model built before Law 141/2025.
Withholding on player winnings. Applied at source by the operator from 1 August 2025, from the first leu, with no exempt threshold:
| Gross winnings (RON) | Withholding |
|---|---|
| Up to 10,000 | 4% |
| 10,001 – 66,750 | RON 400 + 20% of the excess over 10,000 |
| Over 66,750 | RON 11,750 + 40% of the excess over 66,750 |
The removal of the tax-free band is an operational problem before it is a fiscal one. Micro-withdrawals now generate withholding, reporting lines and player-facing explanations that legacy cashier stacks were not built to produce.
VAT. Gambling activity is exempt without credit under Law 227/2015. Supplies into that activity are not. A Class 2 supplier invoicing a Romanian operator makes a taxable supply of services; cross-border B2B supplies fall under the general place-of-supply rule with reverse charge in the customer’s state. Because the operator’s output is exempt, input VAT is largely irrecoverable — so every supplier contract carries the standard rate, 21% since 1 August 2025, as a real cost rather than a cash-flow item. This is a negotiating point in supplier agreements and is almost never priced.
Responsible-gambling contribution. Fixed annual amounts, not a percentage of revenue: EUR 500,000 for remote Class 1 organisers, EUR 15,000 for Class 2, EUR 1,000 for affiliates. The proposition that this levy is charged at 2% of revenue appears widely in circulating summaries and has no basis in the Annex.
An all-in effective burden of 35–40% of GGR before operating costs remains a fair planning assumption at scale. Below scale, the EUR 480,000 floor dominates everything else. The comparative modelling sits in our note on the iGaming tax stack.
6. Application Sequencing and Realistic Timeline
GEO 77/2009 provides that applications are resolved within 30 days of submission of complete documentation. ONJN’s power to request further information means the statutory clock and the calendar rarely coincide. A clean Class 1 file runs 6 to 12 months from corporate kickoff; Class 2 runs 3 to 6.
Months 1–2 — Corporate and capital
- Determine vertical mix and compute the cumulative Annex capital requirement
- Decide between Romanian entity and art. 8 permanent establishment, with the revenue-recognition analysis art. 1(2) demands
- Incorporate, capitalise, obtain fiscal registration
- Open the Romanian operating account and constitute the guarantee
- Secure Romanian premises and appoint the resident compliance officer
Months 2–4 — Dossier construction
- Corporate documents, ownership chart to UBO, fit-and-proper declarations and supporting evidence per shareholder and director
- Audited group financials where the applicant sits in a wider structure
- Technical architecture description, AML/CFT programme, responsible-gambling policy, GDPR record of processing, business plan
- Translation and apostille of every foreign-issued document
Months 4–6 — Certification
- Full IT system audit by a laboratory holding a Class 2 licence
- RNG, RTP and per-game certification (GLI, BMM Testlabs, eCOGRA, iTech Labs and equivalents)
- Source-code registration materials: build logs, checksums, release notes, retention and destruction plan
- Sequencing failure here, not regulatory review, is what loses launch dates — see game certification
Months 6–10 — Review
- Documentation-analysis fee paid on filing to the Supervisory Committee
- Clarification requests are routine, each adding four to six weeks
- Beneficial-ownership verification runs in parallel
Months 10–12 — Issuance and go-live
- Licence issuance fee, annual licence fee and responsible-gambling contribution paid
- Annual authorisation to operate granted
- Safe server, mirror server and ONJN terminal reporting interface commissioned and tested
- Publication confirmed on the ONJN public register before any activity commences
Class 2 files compress because there is no capital schedule, no guarantee and no authorisation tax to settle. The binding constraint on a supplier application is laboratory lead time.
7. Substance, Hosting and the Inspection Regime
Article 15(2) of GEO 77/2009 and the norms under GD 111/2016 impose a data-localisation architecture with no close equivalent elsewhere in the Union.
Server topology. Where the primary gaming server sits outside Romania, the operator must establish on Romanian territory, in a location physically inspectable by ONJN representatives:
- a safe server, holding a raw replica of the gaming-server data;
- a mirror server, holding centralised reports summarising daily activity and financial results;
- a reporting interface to the terminal maintained at ONJN, receiving time-stamped session reports in real time on session close.
Off-site backup elsewhere in the EU/EEA is permitted. The primary reporting and inspection layer is not. The distinction is between storage redundancy, which may sit anywhere in the Union, and regulatory reachability, which must sit in Romania. This layer is now the regulator’s priority: the 2025 Court of Accounts audit found ONJN had not properly interrogated mirror and safe server data, and that player and transaction records could be tested for only a fraction of licensees. The remediation is under way. Assume the data will be pulled.
Continuing operational obligations:
- Player-fund segregation. Player balances held in a dedicated Romanian bank account distinct from operating funds, with the account disclosed to ONJN
- Self-exclusion register integration, consulted at account opening and at defined transaction points, with the national register moving to a centralised digital platform
- Geolocation and IP reporting, with records of Romanian access available to ONJN on request
- Source-code registration, minimum one-year retention and a formal destruction procedure; for aggregators, separately per distributed studio
- Notification under Order 33/2025 of any change to name, registered address, shareholders, directors, UBO or share-capital structure
- On-site inspection, typically annually or semi-annually for active operators and more frequently after material change; failures can trigger suspension
The evidentiary file an inspector expects to find is set out in our substance and inspection regime briefing.
8. AML/CFT and Directive (EU) 2018/1673
The preventive regime is Law 129/2019, transposing the Fourth and Fifth AML Directives, with ONJN’s sectoral instructions in force since January 2022. Those instructions apply to every ONJN licensee irrespective of country of incorporation — a point foreign Class 2 holders regularly get wrong. Suspicious transaction reports go to ONPCSB, the national FIU.
Directive (EU) 2018/1673 operates on a different axis and is worth stating precisely. Commonly labelled AMLD6, it harmonises the criminal definition of money laundering: predicate offence categories, criminalisation of self-laundering, liability of legal persons, and minimum maximum penalties. For a licensee this is a director-liability question rather than a manual-drafting question. Where AML controls fail, exposure arises under a harmonised criminal standard and the legal person itself may be sanctioned, including by exclusion from public benefits and judicial supervision.
Two structural points for any 2026 governance design:
- The nomenclature is unstable. Directive (EU) 2018/1673 is widely called AMLD6, but the sixth preventive directive is Directive (EU) 2024/1640, sitting alongside the AML Regulation (EU) 2024/1624 and the AMLA Regulation (EU) 2024/1620. Drafting that cites “AMLD6” without a CELEX number will age badly and has already caused confusion in licence files.
- The single rulebook applies from 10 July 2027, with AMLA supervision phasing in. Gambling remains an obliged sector. Frameworks written now should be built to the Regulation’s standard, because the transposition window closes well inside an ordinary ten-year licence term.
Enhanced due diligence above thresholds, transaction monitoring, record-keeping and documented staff training are the baseline. Our operational compliance note covers the AML, segregation and responsible-gambling stack as a single control environment rather than three separate policies.
9. Banking and Payment Rails
Banking is the practical bottleneck, and it is where the offshore comparison collapses.
- Most Romanian retail banks decline ONJN files on principle. The constraint is prudential rather than commercial: enhanced diligence on a gambling relationship costs more than the account earns at standard margins. A short list of specialist institutions and gambling-experienced boutiques does the work.
- The licence, not the entity, unlocks the rails. An EU member-state authorisation held by a locally incorporated company with local directors and a verifiable compliance function clears institutional onboarding — slowly, but as a normal account rather than a workaround.
- SEPA settlement and European interchange follow. Card acquiring at European rates, rather than high-risk pricing with rolling reserves, is the single largest economic difference between a Romanian licence and an offshore one.
- Player-fund segregation must be demonstrable, with the remittance account disclosed to ONJN.
- PSPs are inside the licensing perimeter. A processor serving Romanian-licensed operators requires its own Class 2 authorisation and, since Law 141/2025, carries blocking duties toward unlicensed operators. Contracting with an unlicensed processor exposes both sides.
- Run banking in parallel, not in sequence. Plan three to six months of banking work alongside the ONJN application. Operators reaching approval without banking in place stall before they can transact.
On crypto. ONJN has issued no guidance permitting crypto-only deposit and withdrawal rails for Class 1 operators. Crypto-adjacent models, where conversion to fiat occurs at the deposit boundary through a regulated PSP and the gambling activity itself is fiat-denominated, are workable but attract enhanced scrutiny. The October 2025 blacklisting of a major blockchain prediction market signals that a crypto settlement layer draws supervision rather than avoids it, and MiCA obligations attach independently.
10. Comparative Jurisdiction Analysis
| Romania (ONJN) | Malta (MGA) | Curaçao (CGA) | Nevis (NOGA) | Anjouan | |
|---|---|---|---|---|---|
| Legal basis | GEO 77/2009, GD 111/2016, Law 141/2025 | Gaming Act 2018 | National Ordinance on Games of Chance (LOK), from Dec 2024 | Nevis gaming ordinance | Computer Gaming Licensing Act |
| Speed to market | 6–12 months (B2C); 3–6 months (B2B) | 4–6 months | 6–12 weeks | 8–12 weeks | 4–8 weeks |
| Capital intensity | High — cumulative Annex capital, guarantees, EUR 480,000 tax floor | Moderate — EUR 100,000 issued capital for Type 1/2 | Low | Low | Very low |
| Recurring state cost | 30% GGR (min EUR 480,000) + EUR 500,000 RG contribution | 5% gaming tax on Maltese-player revenue + compliance contribution | Annual licence fee under LOK | Circa EUR 28,000 annual fee | Circa EUR 18,000 annual fee |
| Direct tax | 16% CIT; 16% dividend WHT from 2026 | 35% CIT with shareholder refund mechanism | Profit tax under LOK | 0% on foreign-source gaming revenue | Nominal |
| EU market access | Full access to the Romanian market; EU-regulator standing for banking and partner diligence | Maltese market plus the strongest EU reputational position | None | None | None |
| Substance required | Local entity or PE, safe and mirror servers in Romania, resident compliance officer | Local entity, key function holders, genuine presence | Local presence and UBO screening, tightened under LOK | Light | Nominal |
| Banking rails | Tier-1 EU banking, SEPA, European interchange | Tier-1 EU banking, mature PSP market | High-risk acquiring; correspondent banking under pressure | High-risk acquiring | High-risk only; frequent account attrition |
| Enforcement exposure | Active — blacklisting, takedown orders, supply-chain liability | Active but predictable | Rising under the new regulator | Low locally | Low locally, high in target markets |
| Best suited to | Operators committed to the Romanian market with capital to deploy | Multi-market European groups building a hub | Non-EU-facing operators needing speed | Cost-controlled offshore operations outside the EU | Early-stage or test launches with no EU exposure |
Romania wins where the Romanian domestic market is a primary commercial focus, or where an EU member-state authorisation is needed for counterparty diligence and payment economics without Malta’s cost and queue. Note the limit: the Romanian licence confers standing, not passporting. There is no EU gambling passport, and no licence permits a Romanian operator to serve German or Dutch players without local authorisation.
Romania does not win where the model targets non-EU markets exclusively, where time-to-market is the binding constraint, or where the operator cannot absorb the EUR 480,000 tax floor before it has volume.
Two propositions that should be tested before any board decision. First, an offshore licence confers nothing in Romania: serving Romanian players from a Curaçao, Nevis or Anjouan licence is unauthorised activity, exposing the operator to blacklisting and its suppliers to sanction, while the player commits a contravention under art. 22(6) of GEO 77/2009 punishable by RON 5,000 to RON 10,000. Second, speed is bought with cost of capital rather than saved: the four-week licence is real, and so are the eighteen months of degraded payment economics that follow it. The full four-way and five-way analysis, including Kahnawake and Isle of Man, sits in our jurisdiction comparison.
11. Where Applications Fail
- Capital computed on a single vertical. The Annex cumulation rule applies at filing. Under-capitalised applications are refused, not corrected.
- Permanent establishment registered but revenue booked elsewhere. Art. 1(2) requires full recognition of gambling revenue at the Romanian level.
- Certification commissioned after filing. Laboratory lead times exceed ONJN’s review window.
- Compliance officer resident on paper. ONJN and ONPCSB both test this. An officer reachable only by email fails.
- Post-issuance silence. An unnotified change of shareholder, director, UBO or capital structure discovered during inspection converts a formality into a suspension risk.
- Supplier client lists unaudited. Since Law 141/2025 a Class 2 licensee servicing an operator without a Romanian Class 1 licence is directly exposed, whatever the contract says.
12. Frequently Asked Questions
A clean Class 1 file runs 6–12 months from corporate kickoff; Class 2 runs 3–6 months. The statutory 30-day period runs only from complete documentation, and ONJN’s power to request further information means it rarely governs the calendar. The slow steps are beneficial-ownership verification and laboratory certification. Applicants holding MGA or UKGC authorizations move faster because much of the compliance file is reusable.
For Class 1, it is set by point 2 of the Annex to GEO 77/2009 by reference to the verticals organised — RON 2,000,000 for lottery games, RON 1,000,000 each for fixed-odds, mutual, counterparty and casino games, RON 100,000 for poker clubs — and it applies cumulatively across verticals. Class 2 carries no gambling-specific capital floor; suppliers pay fixed annual fees instead. Capital must be subscribed and paid up at the filing date and cannot be reduced afterwards without ONJN’s involvement.
Yes, on one condition. Art. 1(2) of GEO 77/2009 as amended by OUG 82/2023 admits companies registered in Romania and legal persons constituted in an EU or EEA state or Switzerland with a permanent establishment registered under art. 8 of Law 227/2015 at which gambling revenue is recognized in full. That is a genuine fiscal presence, not a registration formality, and in most structures the Romanian company is simpler and cheaper to operate.
On gross gaming revenue as defined at art. 1^1 of GEO 77/2009 — stakes less winnings paid. Operating costs are not deductible. The rate is 30% with an annual floor of EUR 480,000, so a low-volume operator pays the floor irrespective of actual GGR. Bonus treatment varies by bonus type and should be confirmed against current ONJN guidance rather than assumed. Corporate income tax at 16% on net profit applies separately.
No. Class 2 holders pay a fixed annual license fee — EUR 20,000, or EUR 6,000 for affiliates — plus the responsible-gambling contribution of EUR 15,000 (EUR 1,000 for affiliates). Their exposure is regulatory rather than fiscal, principally the blocking and monthly reporting duties introduced by Law 141/2025.
The safe server, the mirror server and the ONJN reporting interface must sit in Romania and be physically inspectable. Off-site backup within the EU/EEA is permitted. The test is not where copies exist but whether the regulator can reach the authoritative reporting layer on Romanian territory.
Not as crypto-only operations. There is no ONJN guidance permitting crypto deposit and withdrawal rails for Class 1 licensees. Fiat-denominated gambling with conversion at the deposit boundary through a regulated processor is workable under enhanced AML scrutiny. Formal guidance is likely to follow once the Romanian MiCA framework settles.
ONJN issues a reasoned decision identifying the deficiencies. Most are remediable — incomplete documentation, unclear ownership chains, an inadequate AML program, technical shortcomings — and re-application typically follows within two to four months. Rejection on fit-and-proper grounds is harder to cure and usually requires restructuring of ownership before refiling.
Under Order 33/2025: change of name, registered address, shareholders, directors, ultimate beneficial owner, or the structure of the share capital. Where the position is arguable, notify. An unnecessary notification costs a letter; an omitted one costs a compliance finding.
13. Talk to Us — Next Steps
A Romanian authorisation is a multi-disciplinary engagement running nine to twelve months for Class 1 and three to six for Class 2. Files that clear ONJN in a single review cycle are the ones where capital, certification, banking and substance were sequenced before anything was filed.
What a structured engagement covers:
- Feasibility memorandum — licence class and vertical mix, cumulative capital exposure under the Annex, a three-year tax model including the EUR 480,000 floor and the 16% dividend charge, and a reasoned Romania-versus-alternatives recommendation.
- Structuring decision — Romanian SRL, SA or registered permanent establishment, with the art. 1(2) revenue-recognition analysis in writing.
- Readiness audit — shareholder and UBO pre-screening, gap analysis against GD 111/2016, remediation plan with owners and dates.
- Dossier assembly and filing — full documentation, translation and apostille management, laboratory coordination, and representation before the Supervisory Committee under power of attorney.
- Post-issuance retainer — annual fee calendar, Order 33/2025 notifications, AML review cycle, inspection representation, and renewal preparation opening six months before expiry.
If you are weighing Romania against Malta, Curaçao, Nevis or Anjouan, the useful first conversation is not about application fees. It is about capital deployment, payment economics across three years, and the enforcement exposure your existing supply chain is already carrying.
Szilaghi Consulting has advised on gambling licensing and corporate structuring since 2004 and has taken more than thirty-eight B2B suppliers through ONJN Class 2 authorisation, including internationally recognised content and live casino providers.
📞 +44 7747 224390 | +1 778 819 2518 ✉️ hello@szilaghi.com 🌐 Request a licensing assessment
Related Guides
- ONJN Class 1 (B2C) authorisation in detail — capital, dossier, fees, timeline
- ONJN Class 2 (B2B) supplier authorisation — studios, platforms, payments, affiliates
- Romania’s iGaming tax stack — the 30% authorisation tax, player withholding, effective rate
- Substance and inspection regime for ONJN licensees — what inspectors actually check
- Romania vs Malta, Curaçao, Nevis and Anjouan — the jurisdiction comparison
- Game certification: RNG testing and accredited laboratories
- AML, player segregation and responsible gambling — operational compliance
- Verifying an ONJN licence — reading the public register
- Affiliates and marketing partners — when Class 2 authorisation applies
- Romanian SRL formation — the corporate vehicle for the licence
References
- GEO 77/2009 — consolidated gambling framework
- Law 124/2015 — approving and amending GEO 92/2014
- OUG 82/2023 — permanent establishment, contributions, transfer restrictions
- Law 141/2025 — 2025 fiscal package and B2B obligations
- Law 227/2015 — Romanian Fiscal Code
- Directive (EU) 2018/1673 — criminal-law harmonisation of money laundering
- ONJN — National Gambling Office
- ONJN consolidated regulatory framework
- ONJN public licensees register
