Gambling licensing
since 2004

CACanada · TGC

Tobique gaming license: TGC costs, rules and limits

The Tobique Gaming Commission has licensed online gambling from Tobique First Nation (Neqotkuk) in New Brunswick since 2024. It is a fast, low-substance offshore license run through a single Isle of Man-based Direct Licensee — and, like Kahnawake, it rests on an asserted right of self-government that Canadian law has never confirmed for online gaming.

By Alex SzilaghiReviewed Compare all jurisdictions

Preliminary review
≈ €2,500non-refundable, at filing
License fee, year 1
≈ €33,500on approval of preliminary review
Compliance subscription
≈ €7,000a year, up to 5 domains
Renewal
≈ €18,000–25,000a year, as reported
Tax on GGR
0%
Time to license
4–8 weeks

Tobique Gaming Act 2023 (v2.0, April 2024) and TGC codes of 5 April 2024. The TGC and DLAG do not publish amounts; fees are as reported by licensing agents in 2025–2026.

Short answer

The Tobique Gaming Commission (TGC) licenses remote gaming under the Tobique Gaming Act 2023, enacted by Tobique First Nation's Chief and Council on 13 October 2023. Applications go only through the sole Direct Licensee, Differentia Licensing Advisory Group (DLAG). Licensing agents consistently report about €36,000 in year 1 (€2,500 preliminary review + €33,500 license fee) plus a €7,000 yearly compliance subscription covering five domains, then roughly €18,000–25,000 a year; the TGC publishes no fee schedule. There is no tax on GGR, licenses run one year, and review takes about 4–8 weeks. The UK, the US and New Brunswick are restricted, and a Tobique license does not open Ontario or any other regulated Canadian province.

Tobique at a glance

Regulator
Tobique Gaming Commission (TGC), created under the Tobique Gaming Act 2023 by the Chief and Council of Tobique First Nation (Neqotkuk), New Brunswick
Primary law
Tobique Gaming Act 2023 (enacted 13 October 2023; v2.0 April 2024), General Code of Practice v2.0, AML/CTF Regulations and Remote Gambling AML Code v3.0
Licensing channel
Differentia Licensing Advisory Group Ltd (DLAG), Douglas, Isle of Man — the sole Direct Licensee; TGC Management Co. is the appointed Management Company
License types
Eleven categories under s.23(1) of the Act; in practice issued as B2C (all verticals) or B2B (gaming software / aggregator)
Track record
First license (B2B) announced 21 March 2024; the public register listed 192 licenses (170 B2C, 22 B2B) in October 2026
Term
One year, renewable; temporary licenses of up to six months possible (s.23(6))
Hosting
No location requirement — cloud hosting accepted; infrastructure and server IPs must be disclosed
Restricted
United Kingdom, United States, New Brunswick and FATF-listed states (per DLAG); agents add Ontario and other locally licensed markets

Is Tobique the right license for you?

A good fit when

  • You need an entry-level offshore license quickly, for open or unregulated markets
  • You want one license covering casino, sports betting, poker, lottery and bingo
  • You prefer no local office, director or server in the licensing territory
  • You are a B2B supplier whose operator clients hold Tobique licenses

Look elsewhere when

  • You want to serve Ontario, other Canadian provinces, the UK, the US or regulated EU markets — those need local licenses (see Canada)
  • You need tier-1 banking and PSP acceptance — consider a regulated EU or provincial route
  • You want a regime whose legal footing has been tested — Kahnawake has licensed since 1999, Tobique since 2024

Tobique license types

LicenseWho needs itNotes
Remote gaming license (B2C)Online casino, sportsbook, poker, lottery and bingo operatorsOne license covers all verticals; up to 5 domains in the base subscription
Gaming software / aggregator license (B2B)Game studios, platforms and aggregatorsNeed assessed case by case by DLAG; register lists 22 B2B holders
Other s.23(1) licensesBookmakers, betting intermediaries, pools, lottery promoters, social and skill gamingAvailable in the Act; agents rarely quote them separately
Approved vendor statusPSPs, hosting, testing, ADR, e-money and crypto providersUnder s.24 of the Act; banking arrangements need prior approval (s.39)
Temporary licenseApplicants in exceptional cases, incl. foreign operatorsUp to six months; not twice in a row

Tobique license costs and tax

Government and statutory charges
ChargeAmountWhenBasis
Preliminary review fee≈ €2,500At filingNon-refundable; paid to DLAG
License fee, year 1≈ €33,500After preliminary review approvalAgent-reported; refunded if the full application fails
Compliance / domain subscription≈ €7,000YearlyCovers up to 5 domains; extra domains priced on request
Annual renewal≈ €18,000–25,000From year 2Agents differ on whether the €7,000 subscription is included
Gaming tax on GGR0%OngoingNo levy in the Act
Year-1 government and DLAG cost≈ €43,000Year 1Excludes company formation, RNG certification and advisory fees

The TGC and DLAG do not publish a fee schedule, and agents quote different figures (from US$17,500 to €43,000 for the license itself). Confirm current amounts with DLAG before filing. Fees can be paid in fiat or crypto.

Tax

Gaming tax
0% on GGR — the Tobique Gaming Act sets no levy; only license and compliance fees apply
Licensee company
Taxed where it is resident and managed; most register holders are Costa Rican S.R.L. / Limitada companies
Payment entity
Groups often run payments through a separate entity (e.g. Cyprus, 15% corporate tax)

Legal framework

InstrumentWhat it does for you
Tobique Gaming Act 2023 (v2.0, April 2024)Creates the TGC, license categories, Direct Licensee model, s.4 paramountcy claim
TGC General Code of Practice v2.0 (5 April 2024)Player protection, funds segregation, RG, reporting, advertising
TGC Regulations concerning AML and CTF (5 April 2024)Risk assessment, CDD, suspicious-matter reporting
TGC Remote Gambling AML Code of Practice v3.0Operational AML guidance for remote gambling
Constitution Act, 1982, s.35Basis of the asserted inherent right of self-government
Criminal Code (Canada) s.207Only provinces may conduct and manage lottery schemes, including online; no First Nations carve-out

Local substance and eligibility

  • Company incorporated anywhere — no Tobique or Canadian entity needed; Costa Rica is the most common choice
  • No local office, staff or director in Tobique or New Brunswick
  • Due diligence on directors, senior managers and 10%+ beneficial owners (ID, address, source of wealth)
  • Senior manager responsible for AML/CTF (MLRO) and a named Responsible Gaming Manager
  • Hosting anywhere, including cloud; full infrastructure disclosure and approved off-site backups
  • Games certified by an approved testing lab (e.g. GLI, BMM, iTech Labs)
  • Banking and PSPs approved by the TGC or DLAG; player funds segregated at 100% plus a margin

How to get a Tobique license

  1. Weeks 1–2

    Company and structure

    Form or adapt the applicant company (often Costa Rica — see company formation) and map ownership down to 10% holders.

  2. Weeks 1–2

    Prepare the file

    Business plan, KYC and source-of-wealth packs, AML/RG policies, platform and RNG certificates or lab letters of intent, infrastructure overview.

  3. Week 2

    Preliminary review

    File through the DLAG portal and pay the preliminary review fee; deficiencies pause the clock.

  4. Weeks 3–6

    Full application and due diligence

    Pay the license fee and complete DLAG's review of the entity, key persons and systems.

  5. Weeks 5–8

    Grant and seal

    The TGC grants the license on DLAG's recommendation and issues the digital seal for each approved domain.

  6. Launch

    Go live

    Install the seal, geo-block restricted markets and start monthly and quarterly reporting.

Document checklist

Corporate
  • Certificate of incorporation and constitutional documents
  • Ownership chart to UBO level
  • Register of directors and shareholders
Key persons
  • Certified passports and proof of address
  • CVs and source-of-wealth evidence for 10%+ UBOs
  • MLRO and Responsible Gaming Manager appointments
Business and policies
  • Three-year business plan
  • AML/CTF risk assessment and policy
  • Responsible-gaming, KYC and complaints policies
  • Terms and conditions
Technical
  • Platform and game certificates or lab letters of intent
  • Infrastructure overview with server IPs and backup provider
  • Business continuity plan
  • Payment flows and PSP agreements

After the license

Renewal

Annual license renewal; agents advise filing about 60 days before expiry.

Reporting

Monthly complaints data; quarterly player-funds, self-exclusion, hardware, game and supplier reports plus audited accounts (Code s.30).

Incidents

Ownership changes, data breaches and serious fraud within 24 hours; suspicious matters within 5 business days, terrorist financing within 24 hours.

Player funds

Segregated at 100% plus a margin; shortfalls cured within 7 days (Code s.8.11–8.12).

Responsible gaming

Deposit/loss/time limits, cross-brand self-exclusion, RG page linked from every home page.

Markets

Geo-block restricted territories at IP and payment level; the list can change during the license term.

Tobique compared

TobiqueKahnawakeAnjouanCuraçao
Annual gov. cost≈ €25,000 (≈ €43,000 yr 1)≈ US$20,000 (US$40,000 yr 1)€17,828≈ €47,450 B2C · €24,500 B2B
Tax on GGR0%0%0%0% intl GGR
Time to license4–8 weeks2–3 months2–4 weeks2–5 months
Local substanceNone local; DLAG due diligenceMIT hostingNoneSeat, MD, office, MLRO, key persons
StatusOffshore (First Nation, New Brunswick)Offshore (Mohawk territory)OffshoreOffshore (Kingdom of NL)

All jurisdictions side by side, with filters: compare gambling license jurisdictions. How we run an application: gambling consulting services.

Written and reviewed by Alex Szilaghi

Founder of Szilaghi Consulting. More than twenty years in gambling licensing and corporate structuring 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.

Last legal review . Current to the TGC framework as of the review date. General information, not legal advice.

Tobique gambling license — FAQs

How much does a Tobique gaming license cost?

Licensing agents consistently report about €36,000 in year 1 (a €2,500 preliminary review fee plus a €33,500 license fee) and a €7,000 yearly compliance subscription covering five domains, then about €18,000–25,000 a year. The TGC publishes no fee schedule, so confirm current figures with DLAG before budgeting.

Is there a gaming tax?

No. The Tobique Gaming Act 2023 sets no tax or levy on GGR. Your company is taxed where it is resident and managed.

Can I accept Canadian players with a Tobique license?

Not in New Brunswick, which DLAG lists as restricted, and not in Ontario, which requires AGCO registration and an iGaming Ontario agreement. Under Criminal Code s.207 only provinces may conduct and manage online gambling, so serving any Canadian province on a Tobique license carries legal risk.

How does Tobique compare with Kahnawake?

Both rest on asserted First Nations self-government rather than Criminal Code s.207, and neither has been upheld by a court for online gaming. Kahnawake has licensed since 1999 and requires hosting at Mohawk Internet Technologies; Tobique started in 2024, has no hosting requirement and is generally faster, at a similar year-1 cost.

How long does it take?

Typically 4–8 weeks from a complete file, with 2–3 weeks commonly reported for clean applications. Incomplete files are returned or paused.

Do I need a company or server in Canada?

No. Applicants can be incorporated anywhere and host anywhere, including in the cloud, but must disclose their infrastructure and use approved backup providers.

Will banks and PSPs accept a Tobique license?

Some will. Gaming-focused EMIs, alternative payment methods and crypto rails accept Tobique licensees, but mainstream banks and card acquirers are cautious with newer sovereignty-based licenses. Every PSP must also be approved by the TGC or DLAG.

Find out if Tobique fits before you pay a fee

We screen the ownership chain, check banking and payment fit for your markets, and price the full year-1 cost before anything is filed. Then we incorporate, prepare the dossier and handle the regulator through to go-live.

Book a 30-minute ONJN feasibility call