Short answer
The Tobique Gaming Commission (TGC) was created by the leadership of Tobique First Nation under the Tobique Gaming Act 2023, adopted on 13 October 2023, to run an online gambling licensing regime. TGC relies on the community's right of self-government; the legal status of that authority must be assessed separately under Canadian federal law, including Criminal Code s.207. Bill S-241, introduced in the Senate on 20 November 2025 to expressly recognize certain First Nations powers, was in Senate committee in October 2026 and had not become law.
The regime covers B2C operators, B2B suppliers and other activity categories in the TGC rules. Applications go through Differentia Licensing Advisory Group (DLAG), presented as the designated Direct Licensee in the TGC structure.
Main estimated costs for 2026, based on available commercial quotes (TGC publishes no complete official fee schedule):
- €2,500 – preliminary review;
- €33,500 – first-year license fee;
- €7,000 a year – compliance subscription for up to five domains;
- €18,000–25,000 a year – renewal costs reported by agents; check whether the compliance subscription is included.
The indicative first-year total is about €43,000, excluding company formation, technical certification, hosting and advisory costs. No percentage TGC levy on gross gaming revenue (GGR) is shown, but the company may owe tax where it is resident or in other relevant states. A complete file takes an estimated 4–8 weeks, and the license is valid for one year.
Under the published conditions there is no requirement to incorporate, keep an office or host servers in Tobique. Operators must still meet transparency, technical-infrastructure and player-protection requirements.
Important: The reach of TGC licensing authority must be assessed under Canadian law. The license does not by itself allow you to operate in Ontario, Alberta, New Brunswick or other regulated markets.
Tobique at a glance
- Licensing authority
- 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 (adopted 13 October 2023; v2.0 April 2024), General Code of Practice v2.0, AML/CTF Regulations and Remote Gambling AML Code v3.0
- Status under Canadian law
- TGC relies on Tobique First Nation's right of self-government. Criminal Code s.207 reserves conducting and managing gambling mainly to provincial governments; Bill S-241 (introduced 20 November 2025), which would expressly recognize First Nations powers, was in Senate committee in October 2026
- Licensing channel
- Differentia Licensing Advisory Group Ltd (DLAG), Douglas, Isle of Man — the Direct Licensee through which applications are filed and managed; TGC Management Co. is the designated management company
- License types
- Eleven categories under s.23(1) of the Act; a B2C license can cover several online gambling categories, depending on the activities declared and approved in the licensing file
- Register
- First license (B2B) announced 21 March 2024. The TGC register listed 192 license entries (170 B2C, 22 B2B) on 10 October 2026; entries are not the same as active operators
- Validity
- One year, renewable; temporary licenses of up to six months are possible (s.23(6))
- Hosting
- No requirement to host in Tobique — cloud hosting is accepted; technical infrastructure and server IPs must be declared
- Restricted markets
- Set by reference to the TGC license conditions, DLAG requirements and each target market's law. DLAG lists the UK, US, New Brunswick and FATF-listed states; separately, locally licensed markets (such as Canadian provinces) require their own authorization, which a Tobique license does not replace
Is Tobique the right license for you?
A good fit when
- You need an entry-level license quickly, from an international licensing regime, for markets whose law allows it
- You want one B2C license to cover several gambling categories (casino, sports betting, poker, lottery, bingo), depending on what is approved
- You prefer no office, director or servers in Tobique
- 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 — they need local authorization (see Canada)
- You need tier-one bank and payment service provider (PSP) acceptance — consider an EU or provincial regulated route
- You prefer a regime with a longer operating history and more public information on enforcement — Kahnawake has run an authorization system since 1999, while Tobique became operational in 2024
TGC license categories and approvals
| License | Who needs it | Notes |
|---|---|---|
| Remote gambling license (B2C) | Online casino, sports betting, poker, lottery and bingo operators | Can cover several online gambling categories, depending on the activities declared and approved; up to 5 domains in the base subscription |
| License for software, platform and aggregation suppliers (B2B) | Game developers, platforms and aggregators | Need assessed case by case by DLAG; the register lists 22 B2B entries (10 October 2026) |
| Other s.23(1) licenses | Bookmakers, betting intermediaries, pool betting, lottery operators, social and skill gaming | Provided for in the Act; rarely quoted separately by agents |
| Approved vendor status | Payment, hosting, testing, ADR, e-money and crypto providers | Separate from a B2B license (s.24 of the Act): lets the vendor work with licensees in the approved service categories; suppliers that themselves offer games or platforms need their own authorization. Banking arrangements need prior approval (s.39) |
| Temporary license | Exceptional cases, including foreign operators | Up to six months; not twice in a row |
Estimated fees, renewal and tax obligations
| Charge | Amount | When | Basis |
|---|---|---|---|
| Preliminary review fee | ≈ €2,500 | On filing | Non-refundable; paid to DLAG (commercial quote) |
| First-year license fee | ≈ €33,500 | After preliminary approval | Agent-reported; refundable if the full application is refused under the agent's commercial terms — not a general legal rule |
| Annual compliance / domain subscription | ≈ €7,000 | Yearly | Covers up to 5 domains; extra domains on request |
| Renewal — subscription included in the renewal quote | ≈ €18,000–25,000 a year | From year 2 | Indicative scenario, not an official schedule |
| Renewal — €7,000 subscription billed separately | ≈ €25,000–32,000 a year | From year 2 | Indicative scenario, not an official schedule |
| Estimated first-year costs, per available commercial quotes | ≈ €43,000 | Year 1 | Excludes company formation, technical certification, hosting and advisory fees |
TGC and DLAG publish no complete official fee schedule, and commercial sources vary widely (from US$17,500 to €43,000 for the license itself). Confirm the renewal cost in DLAG's written quote, including whether the annual compliance subscription is included or billed separately. Fees can be paid in fiat or crypto.
Tax
- TGC levy on GGR
- The fees TGC presents show no percentage tax on gross gaming revenue (GGR).
- Company tax obligations
- This does not remove the company's tax obligations where it is resident, effectively managed or active; many register entries are Costa Rican S.R.L. / Limitada companies.
- Payments entity
- Groups often process payments through a separate entity (e.g. Cyprus, 15% corporate tax), with its own tax obligations.
Legal framework
| Instrument | What 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 v3.0 | Operational AML guidance for remote gambling |
| Constitution Act, 1982, s.35 | Basis of the asserted inherent right of self-government |
| Bill S-241 (Senate, introduced 20 November 2025) | Would amend the Criminal Code and Indian Act to expressly recognize First Nations powers; in Senate committee (October 2026), not law |
| Criminal Code (Canada) s.207 | Reserves conducting and managing gambling, including online, mainly to provincial governments; no express First Nations carve-out |
Company and technical infrastructure requirements
- Under the published conditions there is no general requirement to incorporate, keep an office or host servers in Tobique or New Brunswick; the applicant must still declare its infrastructure and meet the applicable compliance obligations
- Company incorporated in an acceptable jurisdiction, with the full ownership and control structure up to the beneficial owners disclosed and documented; structures that prevent identifying and verifying beneficial owners may be rejected (Costa Rica is the most common choice)
- Due diligence on directors, senior managers and 10%+ beneficial owners (identity, address, source of wealth)
- Designated AML/CTF reporting officer (MLRO) and Responsible Gaming Manager
- Hosting anywhere, including cloud; full infrastructure disclosure and off-site backups with approved providers
- Games and random number generator (RNG) certified by an approved testing lab (e.g. GLI, BMM, iTech Labs)
- Banks and PSPs approved by TGC or DLAG; player funds segregated at 100% plus a margin
Setting up the licensee: company formation for gambling licenses.
How to apply for a license through DLAG
- Week 1
Legal framework and eligibility review
We review the legal basis of the TGC regime, the applicant's structure, beneficial owners and the markets the operator intends to serve.
- Weeks 1–2
Company formation and ownership check
We check the applicant's legal form (often a Costa Rican company — see company formation) and the shareholding, management and source-of-funds documents, and set the requirements for the license category.
- Weeks 1–2
Technical and compliance documentation
Business plan, AML and KYC policies, responsible-gambling procedures, player-funds protection documents and information on the technical platform and relevant suppliers.
- Week 2
Preliminary review through DLAG
The request goes through the DLAG portal with the documents and the preliminary review fee. Requests for further information can extend the review.
- Weeks 3–4
File the complete application
After the preliminary review, the applicant files the complete documentation and pays the applicable fees under the terms communicated in writing.
- Weeks 3–6
Applicant due diligence
Review of the company structure, relevant individuals, financial capacity, technical systems and compliance policies.
- Weeks 5–8
License grant and digital seal
If approved, the license documents and the seals for the authorized domains are issued under the TGC procedure.
- Ongoing
Start operating and stay compliant
The operator must check legality in each target market and meet reporting, player-protection, data-security, geographic-restriction and renewal obligations. The 4–8 week timeline is a commercial estimate, not a guaranteed legal deadline.
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
Ongoing obligations for license holders
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
Restrict access from jurisdictions where operation is not permitted, at IP and payment level; the list can change during the license term.
Tobique compared with other licensing regimes
| Tobique | Kahnawake | Anjouan | Curaçao | Kunaisa | |
|---|---|---|---|---|---|
| Annual license fees | ≈ €25,000 | US$20,000 | €17,828 | €47,450 B2C · €24,490 B2B | €19,500 (communicated, Aug 2026) |
| Tax on GGR | 0% (no TGC GGR levy shown) | 0% stated KGC levy on GGR | 0% | 0% intl GGR | 0% declared (Kunaisa levy) |
| Time to license | 4–8 weeks | 2–3 months | 2–4 weeks | 2–5 months | 6–10 weeks (estimate) |
| Local substance | No mandatory local presence; Differentia Licensing Advisory Group (DLAG) due diligence | MIT hosting | None | Seat, MD, office, MLRO, key persons | Non-Panama company; agent |
| Status | International licensing regime (Tobique First Nation, New Brunswick); authority under Canadian law unsettled | Separate authorization regime (Kahnawake Gaming Commission) | Offshore | Offshore (Kingdom of NL) | Offshore (indigenous territory, Panama), authority unverified |
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, 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.
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?
Based on available 2026 commercial quotes, the preliminary review costs about €2,500, the first-year license fee about €33,500 and the annual compliance subscription for up to five domains about €7,000 — roughly €43,000 in year 1, excluding company formation, technical certification, hosting and advisory fees. Renewal is reported at €18,000–25,000 a year if the subscription is included, or €25,000–32,000 if billed separately. TGC publishes no complete official schedule, so confirm amounts in writing with DLAG.
Is there a gaming tax?
The fees TGC presents show no percentage tax on GGR. That does not remove the company's tax obligations where it is resident, effectively managed or active.
Can I accept Canadian players with a Tobique license?
The license does not by itself allow operation in Ontario, Alberta, New Brunswick or other regulated markets. DLAG lists New Brunswick as restricted, and Ontario and Alberta require their own registrations (AGCO with an iGaming Ontario agreement; AGLC with an AiGC agreement). Because Criminal Code s.207 reserves gambling mainly to the provinces, serving any Canadian province on a Tobique license carries legal risk.
How does Tobique compare with Kahnawake?
Both rely on asserted First Nations self-government rather than an express Criminal Code s.207 exception. Kahnawake has run an authorization system since 1999, with a longer operating record, and requires hosting through Mohawk Internet Technologies; Tobique became operational in 2024, has no hosting-location requirement and is generally faster, at a comparable first-year cost.
How long does it take?
Typically 4–8 weeks from a complete file; 2–3 weeks is sometimes reported for clean applications. Requests for further information can extend the review. The timeline is a commercial estimate, not a guaranteed legal deadline.
Do I need a company or server in Canada?
Under the published conditions there is no general requirement to incorporate, keep an office or host servers in Tobique. The applicant must still disclose and document the full ownership and control structure up to the beneficial owners, declare its 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 self-government-based licenses. Each provider must also be approved by TGC or DLAG.
Sources
Fees shown come from commercial sources (licensing agents' quotes) and are not an official TGC fee schedule. The legal framework was checked on 13 October 2026; get written confirmation of the amounts from DLAG before you commit capital.
- Tobique Gaming Commission (accessed 10 October 2026)
- TGC — Regulatory documents (updated 15 September 2026)
- TGC — License holders register (consulted 10 October 2026)
- DLAG — Tobique Gaming License FAQ
- DLAG — TGC first license press release (21 March 2024)
- DLAG — Creation of the TGC and Direct Licensee platform (5 February 2024)
- Criminal Code (Canada), s.207
- Parliament of Canada — Bill S-241 (LEGISinfo)
Find out if Tobique fits before you pay a fee
We assess eligibility, structure the company, prepare the documentation and check whether the license fits your target markets. Ask for a preliminary assessment before taking on licensing costs.
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