What Class 1 covers
A Class 1 authorisation from the National Gambling Office is the operating licence for any company offering games of chance directly to end-users in Romania over online channels. The licence is product-specific — a single Class 1 holder accumulates separate authorisations for each gambling product it offers:
- Online sports betting — fixed-odds and live betting on real-world sporting events.
- Online casino — slots, table games, video poker, instant-win.
- Online poker — peer-to-peer cash games and tournaments.
- Online bingo — number-draw games with prizes.
- Online lottery games — note: traditional state lottery operations are reserved to Loteria Română under Class 3; private operators offer secondary lottery-style products only.
- Fixed-odds betting on virtual events — virtual sports, RNG-driven simulated events.
This piece covers the structural and procedural mechanics common to all Class 1 authorisations. The strategic context — whether Romania is the right licensing jurisdiction in the first place — sits in our iGaming pillar and our jurisdiction comparison.
The RON 8.5M capital requirement
Romanian Class 1 authorisation requires minimum share capital of RON 8,500,000 — approximately €1.7M at 2026 exchange rates — under Article 14 of GEO 77/2009 as amended. The capital must be:
- Fully paid in at the moment of authorisation. Subscribed-but-unpaid capital does not satisfy the requirement.
- Held in a Romanian-bank operating account, in RON. Foreign-currency capital must be converted before authorisation. EUR-denominated capital held abroad does not count.
- Maintained on an ongoing basis post-authorisation. ONJN monitors solvency annually; falling below the capital floor triggers a suspension procedure under Article 27 of GEO 77/2009 unless the operator remediates within a regulator-set period (typically 30–90 days).
- Distinct from segregated player funds. The RON 8.5M capital is the operator's own equity; player deposits must sit in a separate Romanian-bank segregated account under Article 13 of Law 124/2015.
Capital cannot be reduced post-authorisation without prior ONJN approval, and any reduction below the RON 8.5M floor results in automatic suspension. Operators contemplating M&A or restructuring should engage ONJN early — change-of-control approvals add 2–4 months to typical timelines.
The fit-and-proper test
Every shareholder holding ≥10% of the applicant and every director (including non-executive board members) must clear a fit-and-proper assessment conducted jointly by ONJN and the National Office for the Prevention and Control of Money Laundering (Oficiul Național de Prevenire și Combatere a Spălării Banilor, ONPCSB). The assessment examines:
- Criminal record — clean across all relevant jurisdictions of residence over the last 10 years. Convictions for economic crimes, money laundering, gambling-law violations, or tax fraud are typically disqualifying.
- Insolvency and bankruptcy history — personal and corporate. Recent (within 5 years) insolvencies require detailed documentation and may disqualify.
- Regulatory history — prior gambling licences held, any suspensions, revocations, or sanctions in any jurisdiction. Prior MGA, UKGC, or other reputable-tier licences in good standing accelerate the assessment.
- Source of wealth — documented evidence of how the shareholder accumulated the capital used to fund the Romanian SRL. Vague sources or rapid wealth acquisition without supporting documentation trigger enhanced scrutiny.
- Source of funds — specific to the capital being contributed to the Romanian entity. Bank statements, asset-sale documentation, or financing arrangements covering the RON 8.5M must be provided.
- Political exposure — politically exposed persons (PEPs) and their family members face enhanced due diligence but are not automatically disqualified.
The fit-and-proper process runs 2–4 months for clean files. Files with complex beneficial-ownership chains (trusts, multi-jurisdictional holding companies, foundations) routinely take 4–6 months and require additional documentation rounds.
The application dossier
The full Class 1 application dossier runs to 30+ documents. The core components:
- Romanian SRL or SA formation certificate (certificat constatator) and CUI from the Trade Register.
- Articles of association (act constitutiv) reflecting the gambling-specific CAEN code (CAEN 9200) — see our CAEN codes piece.
- Beneficial-ownership chart showing every natural person controlling ≥25% directly or indirectly, with supporting incorporation documents for every intermediate entity.
- Fit-and-proper declarations and supporting evidence for each ≥10% shareholder and each director (criminal records, insolvency declarations, regulatory history, source of wealth/funds).
- Audited financial statements for the group parent (where the Romanian SRL is a subsidiary) for the prior three years.
- Business plan covering target markets, products, projected revenues, marketing strategy, and operational structure over a 3–5 year horizon.
- Technical platform description — architecture diagram, RGS, RNG, payment integration, KYC suppliers, anti-fraud tools, responsible-gambling integration.
- Certification reports from an accredited testing lab — typically GLI, BMM Testlabs, eCOGRA, or iTech Labs — covering each game and the platform as a whole. Detail in our game certification piece.
- AML programme — written policies, customer due-diligence procedures, transaction-monitoring rules, SAR-filing workflows. Must comply with the Romanian transposition of AMLD6.
- Responsible-gambling policy — self-exclusion integration, deposit limits, reality checks, problem-gambler identification protocols.
- Bank confirmation of the capital deposit and the operating-account opening.
- Commercial premises lease in Romania, sized appropriately for the declared operational footprint.
- Compliance officer registration documents — Romanian residency, gambling-compliance CV, signed declaration of responsibility.
- Application form and state fee receipts.
Document preparation typically runs 2–3 months in parallel with corporate setup. Incorpore's role is the end-to-end coordination of this dossier under the Bespoke tier engagement.
Fees: authorisation, activation, ongoing
The Class 1 fee structure has three layers, all published by ONJN and updated annually:
- Application fee — currently EUR 9,500 (paid in RON equivalent), non-refundable, due at submission.
- Authorisation fee — EUR 120,000–EUR 240,000 annually depending on product mix, paid in advance for the first year and renewed annually.
- Per-product activation fees — separate fees for each game type, ranging from EUR 6,000 (online lottery) to EUR 18,000 (online casino) per product, annually.
- Responsible-gambling contribution — 2% of revenue, channelled to the dedicated state fund. Calculated and remitted monthly.
- ONJN supervision fee — EUR 5,000 annually, fixed.
A typical online sports betting + online casino operator pays approximately EUR 180,000–EUR 280,000 annually in ONJN-direct fees, exclusive of the 27% revenue tax (detail) and corporate income tax. The Bespoke service fee for the application itself is separately quoted and typically runs EUR 45,000–EUR 85,000 depending on operational scope.
The 6–12 month timeline
Realistic sequencing for a clean Class 1 application:
Months 1–2: corporate setup
Form the Romanian SRL or SA, capitalise to RON 8.5M, open the bank account, lease commercial premises, recruit the compliance officer. Banking is the bottleneck — start engagement with Libra Internet Bank or another gambling-friendly partner immediately. See our non-resident banking guide for context.
Months 2–4: dossier compilation
Assemble the 30+ documents above. Fit-and-proper documentation is typically the long-pole task. Technical platform certification runs in parallel with GLI or BMM — book lab slots early as backlogs run 4–8 weeks.
Months 4–6: certification + submission
Final lab reports issued, dossier assembled, application submitted to ONJN with payment of the EUR 9,500 application fee. ONJN issues a receipt and assigns a case officer.
Months 6–10: ONJN review
The regulator's substantive review. Expect 2–3 rounds of information requests — additional documentation, clarifications on beneficial ownership, platform-detail requests. Each round adds 4–6 weeks. ONPCSB beneficial-ownership clearance runs in parallel.
Months 10–12: approval and go-live
Authorisation issued, annual fees paid, SAFE integration completed with ONJN's real-time monitoring system, platform integration certified for go-live, marketing activities launched. First player deposit possible from the day the SAFE handshake is signed off.
Post-approval operational ramp-up
Authorisation is the start, not the finish. The first 90 days post-approval typically cover:
- SAFE integration testing — Romania's real-time gambling-activity monitoring system. Each bet, win, deposit, withdrawal must transmit successfully before live operations.
- Self-exclusion register integration — all player checks consult the national database before account opening and significant transactions.
- AML programme operationalisation — KYC supplier integration, transaction-monitoring rules go live, SAR filing workflow via the SOIIA reporting system.
- Marketing launch — Romanian advertising regulations apply to gambling promotion under Article 22 of GEO 77/2009. Affiliate campaigns must use only ONJN-licensed Class 2 affiliates. See our AML and player-protection piece.
- First responsible-gambling fund contribution — 2% of gross gaming revenue, remitted monthly to the state fund.
- First inspection cycle — operators typically see their first on-site ONJN inspection within 6–9 months of go-live. Preparation detail in our substance piece.
Frequently asked questions
Can I phase the RON 8.5M capital over time?
No. Romanian gambling authorisation requires the full capital paid in at the moment of authorisation. Subscribed-but-unpaid capital does not satisfy the floor. Phased capitalisation works for ordinary SRLs under Law 31/1990, but Class 1 applicants must produce a bank confirmation of the full RON 8.5M before ONJN will issue the authorisation.
What if a shareholder has a prior insolvency?
Recent insolvencies (within 5 years) require detailed documentation explaining circumstances and resolution. Personal insolvencies tied to economic crimes or fraud are typically disqualifying. Corporate insolvencies in unrelated industries are often clearable with documentation showing it was not fraudulent and was properly resolved. Engage ONJN early on borderline cases — pre-screening conversations are permitted and cheaper than a rejected application.
Do I need a Romanian co-shareholder or director?
No. There is no Romanian-nationality requirement for shareholders or directors of a Class 1 entity. The substantive requirement is the Romanian-resident compliance officer with documented gambling-compliance experience, who must be Romanian or have legal residence in Romania. The compliance officer can be an employee or contractor.
Can the same Class 1 licence cover sportsbook, casino, and poker?
A single Class 1 authorisation can stack multiple product-specific sub-authorisations — sportsbook, casino, poker, bingo — each with its own activation fee (EUR 6,000–18,000 annually). Adding products post-initial-authorisation is permitted and faster than adding them at first application; ONJN processes product additions in 6–10 weeks for active licensees.
What is the renewal cadence?
Class 1 authorisations are valid for 10 years, but annual fees must be paid each year and ongoing fit-and-proper monitoring continues. Material changes — ownership, products, technical platform — trigger re-assessment. A clean 10-year run with no material changes is unusual; most operators undergo at least one ownership or platform re-assessment during the licence term.
Can I sell the licence?
The authorisation itself is not transferable. Change of control (acquisition of ≥10% by a new party) triggers a re-assessment that runs 2–4 months and may be refused. Practical M&A in Romanian iGaming therefore happens at the holding-company level, with ONJN approval secured in advance of closing.
Talk to us
A Class 1 application is a 9–12 month, multi-disciplinary engagement with significant upfront capital and document-preparation overhead. The discovery call is where we confirm whether your business model and shareholder structure fit the fit-and-proper test, scope the EUR 45,000–85,000 service fee, and lay out a realistic timeline against your launch target. Book a 30-minute call.
Related guides
- iGaming licensing under ONJN: the complete 2026 guide — the pillar piece anchoring the cluster
- ONJN Class 2 (B2B) supplier authorisation — the B2B counterpart with lower capital and faster timeline
- Romania's iGaming tax stack: the 27% revenue tax — the operational tax cost after authorisation
- Substance and inspection regime for ONJN licensees — what inspectors actually check post-approval
- Game certification: RNG testing and accredited labs — GLI, BMM, eCOGRA, iTech Labs mechanics
- Romanian SRL formation: the complete 2026 guide — the corporate vehicle for the licence