Who needs Class 2
A Class 2 authorisation is required for any company supplying gambling-related services into the Romanian regulated market — that is, contracting with a Romanian Class 1 (B2C) licensee to provide any of the activities enumerated in Article 13 of GEO 77/2009 as amended. The scope is broad and includes:
- Game content providers — slot studios (Pragmatic Play, Evolution, NetEnt-equivalent suppliers), table-game developers, live-dealer operators, virtual-sports providers.
- Platform and aggregator providers delivering integrated content via API, RGS, or content-aggregation layer.
- Payment service providers (PSPs) and payment processors routing deposits and withdrawals on behalf of Class 1 operators.
- Affiliate networks and individual affiliates placing player traffic on revenue-share, CPA, or hybrid arrangements.
- Software and infrastructure providers — RGS, RNG, anti-fraud tools, KYC suppliers, CRM platforms, AML SaaS, responsible-gambling platforms.
- Certification labs and testing houses — though these undergo separate accreditation through a dedicated procedure under ONJN Order 145/2018 as updated.
The structural rule: if your revenue from Romanian-licensed Class 1 operators is non-trivial and your activity falls under Article 13's enumerated categories, you need Class 2. Operators serving Romania-licensed Class 1 holders from outside Romania without Class 2 expose both themselves and their Class 1 customers to regulatory action — Class 1 operators are required to source services exclusively from Class 2-authorised suppliers.
Capital and corporate requirements
The Class 2 capital floor is RON 1,562,500 — approximately €312,500 at 2026 exchange rates — under Article 14(2) of GEO 77/2009. Materially below the RON 8.5M Class 1 floor, but still meaningful for many B2B operators. The same structural rules apply:
- Fully paid in at authorisation — no phased capitalisation.
- Held in a Romanian-bank operating account in RON. Foreign-currency capital must be converted.
- Maintained ongoing — falling below triggers suspension after a remediation period.
- Distinct from any client-monies arrangements — payment processors and PSPs that handle player funds have separate segregation requirements under Article 13 of Law 124/2015.
The Romanian entity must be an SRL or SA, registered at the Trade Register, with a Romanian commercial address and (for ongoing operational activity) Romanian commercial presence. Foreign B2B suppliers typically form a Romanian SRL subsidiary specifically to hold the Class 2 — running cross-border directly from an EU-domiciled parent is permitted in principle but creates operational and tax-residency complications that most operators avoid.
Scope distinctions — Class 1 vs Class 2 in practice
The line between Class 1 and Class 2 is conceptually clear but operationally complex when business models combine elements of both. The practical distinctions:
Class 1 = end-user-facing
The entity that operates the player-facing brand, holds player accounts, accepts deposits, pays winnings, and bears AML responsibility for the player relationship. The Class 1 holder appears on the player-facing website and brand.
Class 2 = supplier-to-Class-1
The entity that contracts with Class 1 holders to provide services that support but do not constitute the player-facing gambling activity. Class 2 holders do not operate player accounts directly.
White-label and turnkey arrangements
Where a platform provider offers a turnkey gambling solution including player-account hosting under a partner brand, the Class 1 holder is the entity that signs the player-facing terms and bears AML responsibility — typically the brand operator, not the platform supplier. The platform supplier holds Class 2; the brand operator holds Class 1. Confusion in this dynamic is a common source of regulatory friction.
Payment-processor edge cases
A PSP that only routes transactions holds Class 2. A PSP that holds player funds in segregated accounts on behalf of operators has additional safeguarding obligations but still operates under Class 2 from ONJN's perspective. PSPs whose activity tips into direct gambling-account hosting would need Class 1.
The application timeline — 3 to 6 months
Class 2 applications run materially faster than Class 1 — typically 3–6 months for a clean file, versus 6–12 months for Class 1. The difference is driven by the narrower scope of fit-and-proper review (less consumer-protection scrutiny) and the absence of game-level certification requirements (certification is the Class 1 holder's burden, not the supplier's).
Months 1–2: corporate setup
Form the Romanian SRL or SA, capitalise to RON 1.56M, open the bank account, lease commercial premises (or register an established commercial address). The same banking constraint applies as for Class 1 — most Romanian commercial banks decline gambling-adjacent files; Libra Internet Bank and specialist boutiques are the realistic partners. Detail in our non-resident banking guide.
Months 2–3: dossier compilation
The Class 2 dossier is materially lighter than Class 1 — approximately 15–20 documents versus 30+ for Class 1. Core components: corporate documents, fit-and-proper documentation for shareholders and directors (the same standard as Class 1 but applied to a smaller set of natural persons in most cases), technical description of the service offering, AML programme, business plan, and bank confirmation.
Months 3–5: ONJN review
The regulator's substantive review. Class 2 reviews typically run 1–2 rounds of information requests versus 2–3 for Class 1. ONPCSB beneficial-ownership clearance runs in parallel.
Months 5–6: approval and integration
Authorisation issued, annual fees paid, integration testing with Class 1 client operators completed. Class 2 holders supplying multiple Class 1 operators can begin client integrations immediately upon authorisation issuance.
Fees: the Class 2 cost structure
Class 2 fees are calibrated against the lower regulatory burden:
- Application fee — EUR 2,500, non-refundable, due at submission.
- Authorisation fee — EUR 9,500 annually for most Class 2 activity types, renewed annually.
- Activity-specific fees — some sub-categories carry additional fees; affiliate networks and PSPs have specific tariff schedules under ONJN Order 226/2024.
- ONJN supervision fee — EUR 2,500 annually, fixed.
Total annual fees for a typical Class 2 holder run EUR 12,000–EUR 22,000, exclusive of standard Romanian corporate taxation. Bespoke service fees for the authorisation engagement typically run EUR 18,000–EUR 32,000 depending on scope and complexity.
Integration with Class 1 operators
A Class 2 holder's commercial value is its ability to transact with Romanian Class 1 operators. The integration mechanics post-authorisation:
- Contractual relationships with Class 1 operators are recorded with ONJN — Class 1 holders maintain a register of their authorised Class 2 suppliers.
- Technical integration of game content, platform services, or payment rails into the Class 1 holder's RGS and SAFE-reporting infrastructure.
- Co-monitoring obligations — material incidents (technical failures, AML red flags, player-protection breaches) require coordinated reporting between Class 1 and Class 2 parties.
- Audit cooperation — when ONJN inspects a Class 1 operator, the inspectors may extend the inspection to Class 2 suppliers whose services are implicated. Class 2 holders must maintain audit-ready documentation of all services rendered.
The commercial trade-off for Class 2 holders: meaningful upfront cost in exchange for guaranteed access to the growing Romanian regulated market, which is materially more lucrative per-player than unregulated alternatives and offers stable long-term commercial relationships. Operators with established MGA or UKGC relationships often add Romania as a fourth or fifth jurisdiction; standalone Class 2 holders are increasingly rare.
Frequently asked questions
Can a foreign B2B provider serve Romania without Class 2?
Technically no. Romanian Class 1 operators are required under their licence conditions to source services exclusively from Class 2-authorised suppliers. Foreign suppliers operating without Class 2 either (a) lose access to Romanian Class 1 customers, (b) route through a Romanian intermediary who holds Class 2, or (c) operate in a regulatory grey zone that exposes their Class 1 customers to enforcement action. Most established suppliers obtain Class 2 directly.
What is the difference between Class 2 for platform vs Class 2 for payments?
The authorisation itself is the same Class 2 instrument, but the scope of permitted activities and the supervision requirements differ. Platform providers are scrutinised on game integrity, RGS architecture, and content management. Payment processors are scrutinised on AML, segregated funds (where applicable), and transaction monitoring. The application dossier varies accordingly. ONJN Order 226/2024 distinguishes between several Class 2 sub-categories with specific fee and reporting requirements.
Do I need physical presence in Romania?
Yes — at minimum, a registered Romanian address, a Romanian-resident person of contact (typically the compliance officer or a designated representative), and a Romanian operating bank account. Some Class 2 categories (especially platform providers with material operational footprint) face higher substance expectations including local technical staff. Pure-shell arrangements consistently fail the substance test under the OUG 82/2023 amendments.
Can the same company hold Class 1 and Class 2 simultaneously?
In principle yes — a Romanian SRL can hold both authorisations and operate as a B2C operator while also supplying services to other Class 1 holders. In practice this is rare; most operators separate the two activities into distinct legal entities for regulatory clarity, accounting simplicity, and acquisition optionality. Combined-licence operations face heightened scrutiny on conflict-of-interest issues, especially where the Class 1 operator competes with Class 2 customers.
What is the typical Class 2 renewal cost?
Renewal fees mirror initial annual fees — typically EUR 12,000–22,000 depending on activity scope, paid annually. Bespoke service fees for renewal administration are materially lower than initial authorisation (typically EUR 3,500–6,500), since the dossier is already on file and only updates are required.
Can I start integrating with Class 1 operators before my Class 2 is approved?
No — pre-authorisation integration constitutes operating without a licence under Romanian law. Many operators conduct technical-due-diligence and contract-negotiation work with prospective Class 1 customers during the Class 2 application period (months 1–6) so commercial relationships can launch immediately on authorisation, but operational integration only begins post-approval.
Talk to us
A Class 2 authorisation typically runs 3–6 months and costs materially less than Class 1, but still requires careful structuring around the RON 1.56M capital, fit-and-proper documentation, and Romanian commercial presence. We confirm whether your business model fits Class 2 or whether Class 1 is required, scope the engagement, and quote in writing. Book a 30-minute call.
Related guides
- iGaming licensing under ONJN: the complete 2026 guide — the pillar overview
- ONJN Class 1 (B2C) authorisation in detail — the B2C counterpart
- Romania's iGaming tax stack: the 27% revenue tax — tax exposure for Class 2 holders
- Romania vs Malta, Anjouan, Curaçao for iGaming — where Romania sits in B2B jurisdiction choice
- Substance and inspection regime for ONJN licensees — audit cooperation and substance requirements
- Romanian SRL formation: the complete 2026 guide — the corporate vehicle