An MGA B2B Critical Gaming Supply licence authorises an approved business to supply and manage material game elements or specified regulatory-record and control-system software. It does not authorise the holder to take players' deposits or operate a consumer-facing casino under that permission.
This guide is for suppliers, operators, investors, compliance teams and researchers resolving a Malta Gaming Authority licence claim. It focuses on the B2B permission itself: what enters scope, how game-provider supply differs from back-office software, what the application tests and how to verify the public record.
What the MGA B2B Critical Gaming Supply licence covers
The Gaming Authorisations Regulations require a valid licence when a person provides a critical gaming supply from Malta, to a person in Malta or through a Maltese legal entity, unless an exemption applies. The First Schedule identifies two licensable supply categories:
- supply and management of material elements of a game; and
- supply and management of software that generates, captures, controls or processes an essential regulatory record, together with the control system on which that software resides.
The word "management" narrows the boundary. The regulations define it here as ongoing active maintenance and support that is indispensable to the gaming service. A company should therefore map what it supplies, what it continues to operate or support and which regulated records or game functions depend on that service.
The broader Malta B2C vs B2B licence guide explains the customer-facing distinction. A B2C Gaming Service licence covers the approved entity offering the gaming service to players. A B2B licence covers the approved critical supply to another business.
Game-provider supply and back-office software compared
The MGA presents game-provider and back-office software routes separately in its application material. They sit within the same legal concept, but they should not be collapsed into one fee or one system description.
| Role | What it means | Where to verify |
|---|---|---|
| Game provider | Supply and management of material elements of a game. | Approved game types and verticals, game engine or other material elements, ongoing management and customer relationships. |
| Back-office software | Software and control systems that generate, capture, control or process essential regulatory records. | Which records are processed, where the control system resides, operational support, security and audit access. |
| Mixed game and back-office supply | Both categories within the same operating model. | Whether both B2B audit checklists apply and whether the public record and system documentation describe the full scope. |
| B2C gaming service | Offering or carrying out the player-facing service. | Separate B2C entity, approved brands and URLs, game types, player contract and destination-market permission. |
The Gaming Authorisations and Compliance Directive calls a B2B holder supplying the first category a game provider and the second category a back-end service. It also lists essential components such as random-number-generator hosts, jackpot hosts, game hosts, gaming databases, player databases, financial databases and control systems. Whether a particular product falls inside scope still depends on its actual function, not its marketing label.
How game types and verticals work
The MGA groups approved activities into four game types. Type 1 includes casino, live casino, house-banked poker, lotteries, secondary lotteries and virtual sports. Type 2 covers fixed-odds betting, including live betting. Type 3 covers pool betting, betting exchange, peer-to-peer products, lottery messenger services and other commission-based games. Type 4 covers controlled skill games.
A licence holder does not need a separate licence document for every game type. The MGA states that additional types require approval through the Licensee Portal. The game-provider application page also says individual verticals require prior approval because each may need different safeguards.
This distinction matters when checking a supplier. A record showing "B2B Critical Supply" is only the first layer. The researcher should also inspect the approved game type, vertical and service description rather than infer that the holder may supply every casino or betting product.
Who can apply and what the MGA reviews
The MGA's Fact Sheets 2025 state that a company incorporated in the European Union or European Economic Area may apply, subject to the applicable capital and financial-reporting requirements. The application is submitted electronically through the Licensee Portal using the relevant B2B selection and delivery channel.
The published process tests four broad questions: whether the applicant is fit and proper, whether its business strategy is viable, whether it has the operational capacity to meet statutory obligations and whether the technical environment implements the approved design. The review covers shareholders, ultimate beneficial owners, directors and key persons, as well as source of wealth, source of funds, business plans, policies, procedures and technical documentation.
Applicants should use the current System Documentation Checklist before submission. The Fact Sheets say an incomplete application receives one 60-day period for resubmission before closure. A draft in the Licensee Portal is automatically rejected after 90 days of inactivity. These are process controls, not a promised approval timetable.
Technical review, audit and licence term
After the document review, the applicant implements the approved system in a technical environment. The MGA's published process includes a system audit by an approved external provider, testing the staged environment against the submitted policies, procedures and system description.
The Authority maintains separate audit material for B2B and B2B Software. Its system-audit and system-review notice says both sets of checks may be relevant where a supplier manages or controls games and also provides back-end software. A system review normally tests the live environment after licensing and may be required earlier where no system audit was performed before issue.
The Gaming Authorisations Regulations set the ordinary original or renewed licence term at 10 years. Renewal remains conditional on continued compliance. A ten-year document should therefore not be read as ten years without reporting, audit, change-control or enforcement risk.
MGA B2B licence fees and capital requirements
The published one-time, non-refundable application fee is €5,000. The MGA fee guidance separates annual fees by supply model.
For a B2B game-provider or material-game-element supply, the current published annual fee bands are:
- €25,000 where annual revenue does not exceed €5 million;
- €30,000 where annual revenue exceeds €5 million but does not exceed €10 million;
- €35,000 where annual revenue exceeds €10 million; and
- €10,000 for a provider supplying solely Type 4 gaming supplies.
For B2B back-office software, the published annual fee is €3,000 where annual revenue does not exceed €1 million and €5,000 above €1 million. These are licence-fee bands, not a quotation for total establishment, audit, staffing, legal, technical or operating cost.
The MGA's Capital Requirements Policy sets minimum nominal share capital of €40,000 for Critical Gaming Supply. It also requires licensees to maintain a positive equity position throughout the licence term. The Authority says the capital does not have to be locked away and may be used for working-capital needs, but a negative equity position must be restored under the policy.
Corporate group licences
The MGA permits a B2B corporate group licence where the parent exercises more than 90% control over the other corporate bodies in the group through shareholding or voting rights. The whole approved group is treated as the licensee, while the nominal holder carries primary responsibility for dues, information and reporting.
That structure does not remove entity-resolution work. A researcher should identify which corporate entities are covered, which entity is the nominal holder and whether the product or customer relationship being assessed belongs to an approved group entity. A shared group name alone is not proof that an unauthorised subsidiary inherits the licence.
The minimum capital for a corporate group licence may be satisfied by one covered entity or cumulatively by two or more covered entities. Each covered entity must still maintain the equity position required by the capital policy.
Key functions and ongoing reporting
The Gaming Authorisations and Compliance Directive identifies seven key functions for a B2B licensee: chief executive, day-to-day gaming operations, regulatory compliance, legal affairs, data protection and privacy where applicable, technological affairs and internal audit. Approved natural persons perform these functions and must have enough knowledge, access and understanding to discharge them.
The licence also creates ongoing reporting rather than a one-time approval event. The MGA's reporting requirements require monthly B2B Compliance Reports identifying client companies and the type of licensable relationship. The categories distinguish direct game supply, aggregation and back-office or control-system supply to B2C or B2B clients.
Supplier onboarding should therefore test the live licence status and the relationship reported to the regulator. A contract or product page alone does not show whether the licensable relationship is recorded in the expected category.
How to verify an MGA B2B licence
Use the official MGA Licensee Hub and follow the record into the Licensee Register or dynamic seal. The Hub supports searches by licensee name, authorisation status, URL and gaming service.
- Take the legal entity name from the supplier's contract, terms or company disclosure.
- Match that entity to the MGA record rather than searching only the commercial brand.
- Confirm that the record says B2B Critical Supply, B2B Software or an applicable corporate group authorisation.
- Read the licence status, number, covered entities, game types, verticals and approved service-provider relationships.
- Check whether the specific game, platform or control function being purchased fits the approved scope.
- Perform a separate destination-market check for every jurisdiction where an operator plans to use the supply.
The Malta market profile and Malta B2C licence record provide the adjacent jurisdiction and consumer-facing records. A B2B supplier licence should not be substituted for either.
What an MGA B2B licence does not prove
An MGA B2B Critical Gaming Supply licence is evidence that a named entity or approved corporate group has Malta authorisation for the recorded critical supply. It does not establish that every product is approved, that every customer relationship is current, that a B2C operator is licensed or that the supply may be deployed in every destination market.
It also does not prove service quality, uptime, commercial performance or financial strength beyond the regulatory requirements and evidence visible at the observation date. Those claims need separate contracts, technical testing, financial records and destination-country checks.
Frequently asked questions
Is an MGA B2B licence an online casino licence?
No. A Critical Gaming Supply licence authorises an approved B2B supply role. It does not by itself authorise the holder to contract with players, accept deposits or operate player accounts. Those consumer-facing activities fall under a Gaming Service licence and any additional permission required in the destination market.
Does a game studio need a separate MGA licence for every game type?
The MGA does not require a separate licence document for each type. A B2B holder can have several game types or verticals approved under one licence, but adding another type requires prior approval through the Licensee Portal. The public record should be checked for the actual approved scope.
How much does an MGA B2B Critical Gaming Supply licence cost?
The published application fee is €5,000. Annual game-provider fees are €25,000, €30,000 or €35,000 across the published revenue bands, with €10,000 for solely Type 4 supply. Back-office software uses separate €3,000 and €5,000 bands. Other professional and operating costs are outside those figures.
How long is an MGA B2B licence valid?
The ordinary original or renewed licence term under the Gaming Authorisations Regulations is 10 years. Renewal depends on continued compliance, and the holder remains subject to reporting, audits, approved-scope controls and enforcement throughout the term. The date and status in the Licensee Register should still be checked.
Does an MGA B2B licence permit supply into every European market?
No. The licence confirms the recorded Malta authorisation. National rules can require a local supplier approval, product certification, operator permission or other market-access step. A supplier and its operator customer should map the destination-country requirements separately before launching a game, platform or control-system service.