Planning to launch an iGaming business? Here is what you need to consider first

The online gambling market continues to attract new operators, from established gaming groups expanding into new verticals to startups entering the industry for the first time. However, launching an iGaming business involves much more than incorporating a company and obtaining a licence.

An iGaming licence is not simply a formality. The licensing jurisdiction can affect ownership structure, target markets, operational setup, banking and payment arrangements, and the company’s long-term compliance obligations. It also does not automatically authorise an operator to accept players in every country.

Before choosing a jurisdiction or submitting an application, founders should understand the iGaming licensing requirements that apply to their business, how licensing regimes work in practice and which factors may affect the actual launch of the business.

Can I keep the UBOs and directors confidential?

In most licensed jurisdictions, no. Regulators require full disclosure of ultimate beneficial owners (“UBOs”), directors and, in many cases, key persons holding significant influence over the company, regardless of the size of their shareholding.

This information is submitted to the regulator as part of the licensing file. Regulators use it for fit-and-proper checks, covering criminal record, financial standing, source of funds, and prior involvement in gambling or financial services. Some registers are not publicly searchable, but “confidential from the regulator” is not an option. Structuring ownership through layered corporate vehicles does not remove the disclosure requirement, since regulators typically look through to the natural persons behind the structure.

Does one online Gambling licence allow us to accept players worldwide?

No. A licence issued in one jurisdiction does not automatically authorise an operator to target or accept players in every country.

Gambling regulation is generally territorial. The country where a player is located may require a local licence, restrict advertising by foreign operators, or prohibit online gambling services altogether. Operators therefore need to identify their target markets and maintain a restricted-jurisdictions framework before launch.

In practice, this may require geolocation controls, residency checks, payment restrictions and limits on marketing activities.

Get Legal Clarity for Your Business

Practical legal guidance for your next step.

Do I need to own the iGaming platform and games?

No. Most operators do not build their own gaming platform or develop games in-house. Operators commonly use a third-party platform and source games from external providers under commercial agreements, provided the relevant technology, games, and suppliers meet the requirements of the chosen licensing regime.

Regulators expect clarity: the operator must show which entity is responsible for player funds, game fairness, Random Number Generator (“RNG”) certification, and technical compliance, even when a partner supplies the underlying technology. This is usually addressed through platform and game-supply agreements, together with evidence that the suppliers themselves hold the relevant certifications or licences.

Owning the technology stack may make sense at a later stage of growth, but it is rarely a precondition for obtaining a licence.

What do responsible gambling requirements mean in practice?

Responsible gambling is not a single feature but a set of obligations that run through the entire operation. In practice, it typically includes deposit, loss, and time limits available to players; self-exclusion tools linked to national or regional registers where they exist; age and identity verification before real-money play; and staff training to recognise signs of problem gambling.

Operators are also generally expected to monitor player behaviour for markers of harm and to intervene, rather than simply making tools available and leaving players to use them unprompted. Marketing and bonus practices are usually subject to separate restrictions aimed at preventing aggressive promotion to vulnerable players.

Regulators increasingly treat responsible gambling as an ongoing supervisory matter rather than a box to tick at the licensing stage, so the systems put in place need to function in practice, not only on paper.

What should I prepare for an iGaming licence application?

An iGaming licence application is only as strong as its supporting documentation. Depending on the jurisdiction, applicants typically need to prepare corporate documents and ownership structure charts, source-of-funds and source-of-wealth evidence for UBOs, business and financial plans, AML and KYC policies, technical documentation for the platform and games, a responsible gambling policy, and data protection and information security documentation.

Applicants should also be prepared for a review of key personnel, not only founders and directors but often compliance officers and other individuals in controlled functions. Properly gathering and preparing this documentation before submission is usually the biggest factor in how quickly and smoothly a licensing process moves forward.

At Manimama Law Firm

At Manimama Law Firm, we help businesses navigate this regulatory environment. We prepare documentation, manage application processes, and develop long-term compliance strategies.