The four jurisdictions at a glance
In 2026, the iGaming licensing decision for most internationally-mobile operators narrows to four candidates: Romania under ONJN, Malta under the Malta Gaming Authority (MGA), Anjouan under Anjouan Gaming, and Curaçao under the Gaming Control Board (transitioning to the LOK framework). Each occupies a distinct position on the cost–prestige–access spectrum.
Choose the licence that matches your business model, not the licence that sounds most prestigious. Operators who licence in Malta when their economics need Curaçao stall; operators who licence in Curaçao when their brand needs Malta lose enterprise customers.
This piece compares the four on the dimensions that actually drive the decision: cost, timeline, tax burden, banking access, reputational tier, EU market access, and regulatory rigour. Romania-specific deep dives sit in our iGaming pillar; the comparison here is strictly head-to-head.
Cost and timeline
The headline numbers in 2026:
Romania (ONJN)
Application timeline: 6–12 months for Class 1, 3–6 months for Class 2. Minimum capital: RON 8.5M (~€1.7M) for Class 1, RON 1.56M (~€312.5K) for Class 2. Application fee: €9,500 Class 1, €2,500 Class 2. Annual licence fees: €180K–€280K Class 1 (including product activations), €12K–€22K Class 2. Bespoke service fees: €45K–€85K Class 1, €18K–€32K Class 2.
Malta (MGA)
Application timeline: 4–6 months. Minimum capital: €100,000 (B2C) or €40,000 (B2B). Application fee: €5,000. Annual licence fees: ~€25,000 (B2C) plus compliance contributions; ~€10,000 (B2B). Service fees through a Maltese law firm or corporate service provider: typically €60K–€120K for B2C, €30K–€60K for B2B.
Anjouan
Application timeline: 6–10 weeks. Minimum capital: typically not enforced beyond minimal formation. Application fee: ~$2,000. Annual licence fees: ~$8,000–$15,000. Service fees: $8K–$25K typical via specialist providers.
Curaçao
Application timeline: 2–8 weeks (LOK framework), longer under transition. Minimum capital: minimal. Application fee: ~$5,000. Annual licence fees: ~$25,000–$45,000 under LOK. Service fees: $15K–$45K typical.
Romania sits above Malta on time-to-market and capital, above Anjouan and Curaçao on every cost metric. The cost-time disadvantage versus offshore is real and consequential; the comparison to Malta is closer than it appears on capital alone.
Tax burden, head to head
Tax is where the comparison shifts:
Romania
27% special tax on GGR + 16% CIT on net profit + 2% responsible-gambling fund + 8% dividend withholding. All-in effective burden ~30–32% of GGR for typical operators. Full detail in our tax stack piece.
Malta
5% gaming tax on GGR + corporate income tax with significant Maltese refundable-tax-credit mechanism reducing effective CIT to 5–7% for non-Maltese shareholders + treaty network. All-in effective burden ~10–15% of GGR — the lowest of the four for sophisticated operators using the Maltese tax structure properly.
Anjouan
Tax burden ~2% of GGR, primarily through modest annual fees rather than a transaction tax. Effective tax burden is among the lowest globally.
Curaçao
2% gaming tax (or fixed annual fees under LOK) + minimal corporate tax for non-Curaçao operations. All-in burden ~4–6% of GGR.
The conclusion: on tax alone, Malta wins among regulated jurisdictions; Anjouan/Curaçao win overall but with significant trade-offs elsewhere. Romania is the most-taxed of the four — operators choosing Romania accept this in exchange for non-tax advantages.
Banking access
Banking is the most underappreciated dimension in jurisdiction selection. Operators who choose a cheap licence and cannot bank are worse off than operators who pay more for a licence that opens commercial banking.
Romania
Materially constrained. Most retail banks decline gambling files; Libra Internet Bank and a small specialist set are the realistic options. PSP infrastructure has developed but commercial banking remains slow. See our non-resident banking guide.
Malta
The strongest banking ecosystem of the four for gambling operators. BOV (Bank of Valletta) and several specialist Maltese banks routinely bank MGA licensees. Cross-border SEPA infrastructure is mature; correspondent banking is more accessible than at any other jurisdiction.
Anjouan
Banking is the weakest dimension. Most international banks refuse Anjouan-licensed operators; offshore banking arrangements (typically via Mauritius, Comoros, or specialist payment institutions) are required. Significant ongoing friction for any operator processing EUR or USD volumes.
Curaçao
Better than Anjouan but materially worse than Malta. Some Curaçao operators bank locally; many bank via specialist EU PSPs or via Maltese or Estonian intermediaries. Recent LOK transition is improving banking gradually.
Reputational tier and EU market access
Brand prestige and regulatory recognition vary materially across the four:
Malta
Premier reputational tier alongside the UK. Maltese MGA licences are recognised across EU member states under various services-framework arrangements and confer significant brand credibility with B2B partners, payment processors, and content suppliers. For operators serving multiple EU markets, an MGA licence often suffices as a passport.
Romania
Second-tier reputational standing, comparable to Spanish, Italian, or Swedish licences. Recognised within the EU but not used as a passporting instrument — Romania is best understood as a per-country licence for the Romanian market, with secondary brand value for marketing in adjacent CEE markets.
Curaçao
Mid-tier reputation post-LOK. The 2024 LOK transition has improved Curaçao's reputational standing, but it remains an offshore licence with limited recognition by EU regulators and reputational headwinds among premium B2B partners.
Anjouan
Lowest reputational tier of the four. Useful for low-cost operations targeting non-EU markets but creates significant brand and partner friction for any operator with European ambitions.
Regulatory rigour and operational burden
The operational compliance burden across the four:
Romania
High operational burden — Romanian-territory hosting, dedicated compliance officer, annual on-site inspections, real-time SAFE integration, monthly tax remittance with reconciliation, AMLD6-aligned AML programme. See our substance piece.
Malta
High operational burden — MGA inspections, robust AML expectations, ongoing reporting, but the Maltese ecosystem (corporate service providers, specialist compliance firms, banking infrastructure) absorbs much of the friction for operators willing to pay for it.
Curaçao
Moderate operational burden post-LOK — increasing requirements but still materially lighter than Malta or Romania.
Anjouan
Low operational burden — minimal substance, light inspections, minimal reporting. The trade-off is reputational and banking access, not operational complexity.
Choosing for your business model
Practical guidance based on common operator profiles:
- Pick Romania when your business model targets the Romanian domestic market primarily or as a meaningful share of revenue; the Romanian licence is then non-discretionary regardless of cost. Also when you want an EU-recognised licence in a tier below MGA but materially above offshore alternatives.
- Pick Malta when your business targets multiple EU markets, brand prestige is commercially valuable, banking access is critical, and you can absorb the higher upfront cost and slower timeline. Malta remains the strongest all-round EU regulated licence.
- Pick Curaçao (LOK) when you target non-EU markets primarily, time-to-market is critical, and you can manage offshore banking arrangements. The LOK transition improves the proposition meaningfully versus pre-2024 Curaçao.
- Pick Anjouan when cost is decisive, you serve non-EU markets exclusively, and you have established banking arrangements that don't depend on licence prestige. Niche but commercially viable.
The most common multi-jurisdiction pattern in 2026: Malta as primary EU licence, Anjouan or Curaçao as secondary for non-EU markets, Romania as a domestic-market add-on where the operator targets Romanian players specifically. Stacking jurisdictions in this way is more common than relying on a single licence.
Frequently asked questions
Which is cheapest end-to-end?
Anjouan, by a substantial margin — all-in first-year cost (formation, licence, banking setup, operational infrastructure) typically runs $25K–$60K versus €350K–€600K for Romania Class 1 or €250K–€450K for Malta B2C. The cost gap reflects regulatory rigour and banking access, not arbitrary pricing.
Which is fastest to authorise?
Curaçao under LOK at 2–8 weeks for clean files, followed by Anjouan at 6–10 weeks. Malta runs 4–6 months. Romania runs 6–12 months. The speed gap is structural: offshore licences process applications administratively; Malta and Romania run substantive fit-and-proper and technical reviews.
Which has the strongest brand for B2B partners?
Malta, by some distance, followed by Romania for partners with CEE presence. UK Gambling Commission licences carry similar prestige but are not commonly compared in this set because the UKGC application is structurally different and rarely available to non-UK operators. Anjouan and Curaçao carry meaningful brand friction with premium B2B partners.
Can I hold multiple licences simultaneously?
Yes, and many serious operators do. A common stack: MGA as primary EU regulated, Curaçao/Anjouan for non-EU markets, Romania as a per-country add-on. Each licence requires its own substance, capital, and ongoing fees, so multi-licensing only makes commercial sense above a meaningful revenue threshold — typically €5M+ GGR annually before adding a second jurisdiction.
Which is best for crypto-casino operations?
None of the four allow native crypto-deposit operations under their primary frameworks. Curaçao has historically been most accommodating but the LOK transition is tightening this. Anjouan operates under similarly evolving rules. Malta's VFA framework permits crypto-adjacent operations under separate licensing. Romania does not currently permit crypto deposits for Class 1 operators. Operators with crypto-deposit business models typically operate under offshore structures (Costa Rica, Curaçao pre-LOK) that are progressively narrowing.
Is Malta still worth the cost in 2026?
For operators with multi-EU-market ambitions and the budget to absorb higher upfront cost, yes — Malta's brand, banking ecosystem, and regulatory recognition remain genuinely best-in-class. For single-market operators or those constrained on capital, the cost-benefit case has weakened relative to Romania-for-Romania or Curaçao-LOK-for-non-EU. Malta is no longer the default answer; it is the best answer for a specific operator profile.
Talk to us
The licence-jurisdiction decision is rarely about the licence in isolation — it's about how the licence fits your market strategy, banking footprint, brand positioning, and operational capacity. We work this through with prospective operators on the discovery call and tell you straight which jurisdiction fits, even when that answer is "not Romania." Book a 30-minute call.
Related guides
- iGaming licensing under ONJN: the complete 2026 guide — the pillar — Romania-specific detail
- ONJN Class 1 (B2C) authorisation in detail — Romanian Class 1 mechanics
- ONJN Class 2 (B2B) supplier authorisation — Romanian Class 2 mechanics
- Romania's iGaming tax stack: the 27% revenue tax — Romanian tax detail referenced in the comparison
- Substance and inspection regime for ONJN licensees — Romanian operational burden