Comparing the UAE gaming framework with other jurisdictions

The licence fee is only part of a gaming operator’s budget. Spending on personnel, local presence, customer checks and reporting can significantly influence the choice of jurisdiction. Equally important is which services the company may offer and which players it may serve. Comparing the UAE, Malta, Nevis and Gibraltar requires separate assessments of licensing eligibility and restrictions on subsequent operations. In this article, we examine each framework, operators’ key obligations and the criteria for choosing a jurisdiction.

UAE: the GCGRA framework and market entry

Commercial gaming in the UAE is regulated by the General Commercial Gaming Regulatory Authority (GCGRA). Its remit covers lotteries, online gaming, sports wagering and land-based gaming facilities. Activities requiring GCGRA authorisation cannot be conducted under a foreign gaming licence.

A key feature is preliminary eligibility screening. Under the GCGRA procedure, applicants first submit an Intake Form describing the project and requested licence. Following an initial assessment, the regulator decides whether to grant portal access for a full application. The existence of a relevant licence category does not itself guarantee a project’s eligibility.

The licensing framework covers several groups:

• Operators of gaming platforms, betting services, lotteries and land-based facilities;
• Suppliers of gaming equipment and related services;
• Entities performing key functions within the ownership or management structure;
• Individuals classified as key personnel;
• Employees whose duties fall within licensing requirements.

Project preparation therefore extends beyond the operator’s licence. Applicants must identify which group companies, suppliers and employees also require authorisation.

When reviewing an application, the GCGRA assesses the applicant’s integrity, operational capabilities, business plan and compliance framework. Approval is followed by periodic reporting and ongoing supervision, including financial crime prevention and player protection.

Entry costs should be calculated after confirming the licence category and identifying all applicants. The budget must cover applicable fees, infrastructure, personnel and technical compliance. Corporate taxes require a separate assessment. The practical first step is to confirm the proposed model’s eligibility through the GCGRA process before making substantial investment commitments.

Malta: B2C licensing and regulatory requirements

Malta’s gaming sector is regulated by the Malta Gaming Authority (MGA) under the Gaming Act and subsidiary legislation. A B2C Gaming Service Licence authorises operators to serve players directly. Applicants may be companies incorporated in Malta or another EU/EEA country.

Licensing involves assessing owners and key persons, financial stability, the business plan and technical system. Operators must assign mandatory management and control functions, implement AML/KYC measures, safeguard player funds and establish responsible gaming procedures.

Under the MGA fee schedule, the main payments include:

• €5,000 – a non-refundable application fee;
• €25,000 – a fixed annual licence fee;
• €10,000 instead of €25,000 – for operators offering exclusively Type 4 services, namely controlled skill games;
• Compliance Contribution – an additional payment based on game type and gaming revenue.

Taxation is assessed separately. The standard corporate tax rate is 35%. Subject to applicable conditions, shareholders may receive a refund of part or all of the tax after dividends are distributed. Presenting Malta as a jurisdiction with an unconditional 5% corporate tax rate is therefore incorrect.

Until 30 September 2026, gaming tax on qualifying revenue from Malta-based players is 5%. Changes to gaming taxation and VAT take effect on 1 October 2026, so launch budgets must account for the new rules.

A Maltese licence provides a basis for operating a regulated gaming business but does not grant EU-wide authorisation. The legality of serving players in each country must be assessed separately.

Nevis: licensing structure and operator obligations

The Nevis framework is based on the Nevis Online Gaming Ordinance, 2025, with oversight by the Nevis Online Gaming Authority (NOGA). Serving players requires a B2C licence, while relevant supplier activities require a separate B2B licence. Applicants must incorporate a company in Nevis and disclose the ownership structure through to the ultimate beneficial owners.

The initial B2C licence fee is €28,000, with annual renewal costing a further €28,000. Each additional URL costs €750 per licensing cycle. These amounts exclude corporate services, mandatory personnel and technical preparation.

The main requirements for a B2C operator include:

• An independent Compliance Officer and a local Reporting Officer;
• Evidence of the owners’ source of funds and source of wealth;
• AML/KYC procedures, age verification and responsible gaming measures;
• Rights to domains and gaming content, and applicable technical certificates;
• Geoblocking of prohibited territories.

Unlike the UAE framework, a Nevis licence is not intended to serve the domestic market: St. Kitts and Nevis are listed as prohibited territories. Access from several major markets, including the US and the UK, is also restricted. Sublicensing is prohibited, so operators cannot authorise other companies to operate under their licence.

Tax benefits require a separate justification. Tax authority guidance distinguishes between residents and non-residents by reference to the location of management and the source of income. A non-resident company’s foreign profits may fall outside local corporate taxation, but there is no universal guarantee of “0% tax for every licensee”.

When comparing jurisdictions, the benefit of fixed licensing payments must be weighed against target-market restrictions and ongoing compliance costs.

Gibraltar: licensing, substance and supervision

Gibraltar updated its framework under the Gambling Act 2025, whose main provisions took effect on 1 April 2026. The Licensing Authority makes licensing decisions, while the Gambling Commissioner provides ongoing supervision. The framework distinguishes between B2C operators, B2B suppliers and gambling support services.

A key licensing condition is substantive business presence in Gibraltar. Management, personnel, premises and other indicators of economic activity are assessed. Incorporation alone is insufficient: the structure must reflect the operator’s actual functions. Owners, financial resources and the ability to meet regulatory requirements are also reviewed.

Under the Gambling (Duties and Licence Fees) Regulations 2026, B2C gaming and betting fees are:

• £30,000 for a new application of the relevant type;
• £50,000 annually where annual gross yield is below £20 million;
• £100,000 annually where gross yield is between £20 million and £300 million;
• £200,000 annually where gross yield exceeds £300 million.

Where an operator holds both gaming and betting licences, annual fees are cumulative. Gaming or betting duty of 0.15% also applies to the statutory tax base, with the first £100,000 exempt. The standard corporate tax rate is 15% and is calculated separately.

After licensing, operators must maintain AML controls, player protection and compliance with reporting and change-of-control requirements. Compared with Nevis, the budget depends more heavily on operational scale and local presence. A Gibraltar licence does not authorise access to the British market: serving players in Great Britain requires separate authorisation from the Gambling Commission.

Cross-border operations: what a licence does not cover

Choosing Malta, Nevis or Gibraltar as a base does not resolve access to players in the UAE. Activities subject to local regulation require GCGRA authorisation. Neither a foreign licence nor an agreement with a licensed platform provider replaces it.

Before entering each market, the operator must check:

• Whether the selected games or betting activities require a local licence;
• Whether advertising, affiliate marketing and bonus offers are permitted;
• Whether local taxes apply to gaming revenue;
• Which restrictions apply to payments, data processing and player identification.

The findings must be reflected in platform settings and business processes. Where access from a country is prohibited, a clause in the user agreement is insufficient. Geoblocking, customer registration, payment acceptance and advertising partners’ activities must be aligned.

The location of business management is a separate issue. A company may hold a licence in one jurisdiction while making strategic decisions and performing core functions in another. Depending on local law, this may create tax residence or permanent establishment risks. Owners may also need an assessment of controlled foreign company rules.

For example, relocating management to the UAE does not automatically transfer a foreign licence or end existing tax obligations. The current licence conditions, GCGRA requirements and tax implications of the new structure must be reviewed.

The comparison must therefore cover the entire operating model: the licensed company, team location, player geography and fund flows. A low fee in one country does not compensate for missing authorisation in another.

UAE, Malta, Nevis and Gibraltar: comparison at a glance

The table compares the main requirements for B2C operators. Licensing payments are presented separately from taxes and the costs of personnel, infrastructure and corporate services.

Malta’s budget calculations must account for gaming tax and VAT changes taking effect on 1 October 2026. In Gibraltar, combining gaming and betting increases the annual fee: the charges for these activities are cumulative.

If the project targets the UAE market, the first consideration is eligibility for the relevant GCGRA authorisation. For international operations, choosing a base requires comparing accessible markets, total costs and the ability to maintain the required presence.

How Key2Law supports gaming operators

Key2Law team helps operators choose a jurisdiction based on their gaming products, target markets, ownership structure and budget. We assess licensing and tax requirements together to ensure that company incorporation arrangements align with the actual business model.

The Key2Law team provides comprehensive support, including:

• Comparing UAE, Malta, Nevis and Gibraltar requirements for a specific project;
• Identifying the licences required for the operator and related companies;
• Reviewing restrictions on serving players and promoting services;
• Designing a corporate structure that addresses management and local presence;
• Assessing tax risks and mandatory costs;
• Preparing ownership and funding-source documentation;
• Developing AML/KYC policies and player protection procedures;
• Reviewing agreements with platform, gaming and payment providers;
• Supporting licensing and ongoing compliance within the permitted procedures for regulatory interaction.

If you plan to enter the UAE market or choose a base for an international gaming business, contact the Key2Law team. We will help identify the appropriate licensing route and prepare a launch plan detailing requirements, costs and preparation stages.

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This article is provided for general informational purposes and does not constitute legal, tax or financial advice. Applicable requirements depend on the jurisdiction and specific circumstances; professional advice should be obtained before making legal or business decisions.