MGA Softens Recognition Notice Rules After Industry Pushback
The Malta Gaming Authority has backed off its planned tightening of the Recognition Notice framework. That's the regime letting companies operate out of Malta on foreign licences without an MGA permit. The climbdown is set out in a Feedback Statement dated 26 October. Industry pushback drove it. And the framework it touches? Malta's own 2023 National Risk Assessment rated it medium-high for money-laundering risk.
Gone is the standard template for legal opinions. The MGA will instead spell out which confirmations those opinions have to contain. Holders will hand over ultimate beneficial owner details, not a full corporate structure chart. B2B suppliers are exempt from many of the new obligations. Respondents had argued the proposals duplicated what foreign regulators already impose, and they resisted disclosing commercially sensitive information.
All of which sits awkwardly with the risk assessment published in January 2024. The 2023 exercise was the first to give the framework a rating. The 2018 assessment had left it unrated. Same exercise, another result: remote gaming's residual risk fell from high to medium. Subject persons were told to reflect the identified risks in their own assessments. On 21 April 2026 the MGA opened its targeted consultation, pitching the proposals as aligned with that assessment and with the National AML/CFT Strategy 2024–2026. Tighter checks at authorisation. More structured ongoing monitoring.
The commercial stakes are high. Malta is Europe's main hub for B2C operators and B2B suppliers, and plenty of them work there through Recognition Notices. Romanian licences are common among Malta-based gambling businesses. Some observers treat the regime as a loophole, particularly for B2B firms. A certificate runs for one year, with annual maintenance. The application fee is €5,000, plus another €5,000 due each year in advance. Applicants need a letter of good standing from their licensing authority and a certified legal opinion from a warranted professional. B2C applicants must list the URLs where they offer games. Notice holders don't escape Malta's tax net either: under Legal Notice 84 of 2026, in force from 1 October 2026, they remain within the restructured gaming tax.
Detail from the regulator has been thin. Its short public notice on 28 October called the changes adjustments prompted by consultation responses, aimed at rules holders can work with in practice and that scale with risk. The Feedback Statement itself wasn't published. It went only to notice holders and their representatives.
Some new requirements may need changes to the existing legal framework, the MGA has conceded. Gaming legislation introduced the week before may be connected, given the timing. More information on how specific requirements will work in practice is promised later.