Table of Contents
- What Changed for Online Casino Licenses after Brexit
- Malta Gaming Authority (MGA): Advantages and Challenges for Your Online Casino
- Gibraltar Gambling Commission (GGC): What Remains after Brexit?
- Malta vs. Gibraltar: A Direct Comparison for Online Casino Operators
- My Recommendation: Which License Strategy Makes Sense in 2025?
If you’re considering running an online casino, you’re facing a pivotal decision.
Malta or Gibraltar?
Ever since Brexit, this question has occupied every serious entrepreneur in the gaming industry. And I understand the confusion.
It used to be simple: Gibraltar was the tax haven for online gambling. Malta? A reliable neighbor with solid regulation.
Today, the situation is different.
As someone who helps international businesses optimize their taxes, I experience this uncertainty every day. Entrepreneurs ask me: “Richard, where should I get my gaming license?”
The answer is no longer as straightforward as it once was. Brexit has changed the game. But that’s what makes it so interesting.
In this article, I’ll show you which license strategy actually makes sense for your online casino—with real numbers, up-to-date facts, and my honest assessment.
No theoretical treatises. Just what you need to make your decision.
Yours, RMS
What Changed for Online Casino Licenses after Brexit
January 31st, 2020 marked a turning point for the gaming industry. Not just symbolically, but in practice.
Suddenly, online casino operators faced new realities. What did this mean in practical terms?
Gibraltar Gambling Commission: The New Reality after Leaving the EU
For many years, Gibraltar was the gold standard for gaming licenses. The combination of low taxes, pragmatic regulation, and EU market access made the British overseas territory irresistible.
Then Brexit happened.
Now, Gibraltar-licensed casinos need to apply for separate approvals for each EU market. That means:
- Additional licensing fees in every EU country
- More complex compliance structures
- Higher operational costs
- Longer time-to-market for new markets
A real-world example: A Gibraltar-licensed casino wanting to operate in Germany now needs an additional German license. The cost: At least €300,000 in security deposit, plus ongoing fees.
Before 2020, things were different. The Gibraltar license covered the entire EU area.
Malta Gaming Authority: Strengthened Position as an EU Member
Malta benefited from Brexit like no other gaming hub. Why?
Simple: Malta remained in the EU.
So what does this mean for you as an online casino operator?
- EU-wide passport for your gaming license
- No additional permits needed in EU countries
- Simplified compliance structures
- Direct access to 450 million EU citizens
But be careful: Malta isn’t automatically the better choice for everyone. It depends on your specific situation.
Gibraltar Gambling Commission (GGC): What Remains after Brexit?
Gibraltar isn’t dead. But it’s definitely not what it once was.
Let me be honest: For most new online casino projects, Gibraltar makes little sense today. But there are exceptions.
Gibraltar Gaming License: New Limitations and Opportunities
The Gibraltar Gambling Commission used to be known as Europe’s most pragmatic regulator. That reputation remains.
But the framework has shifted:
- No more EU passport: Separate licenses required for each EU market
- UK as the main market: Now direct access only to the UK
- Flexible regulation: Less stringent requirements than Malta
- Faster approvals: 3–4 months vs. 6–9 months in Malta
Current license fees in Gibraltar:
License Type | Initial Fee | Annual Fee | Revenue Fee |
---|---|---|---|
B2C Online Casino | £100,000 | £85,000 | 1% of GGR |
B2B Services | £50,000 | £25,000 | None |
Software License | £20,000 | £10,000 | None |
In addition: Bank guarantee of £250,000 required.
Tax Structure in Gibraltar for Online Casinos
Gibraltar has always been tax-attractive. That’s still the case after Brexit.
Key points:
- Corporate tax: 12.5% on profits from Gibraltar sources
- No capital gains tax
- No inheritance or gift tax
- Attractive HNWI program for entrepreneurs
But caution: The new “Economic Substance” law requires that gaming companies have real economic substance in Gibraltar.
In practical terms, that means:
- At least 2 full-time employees on site
- Adequate office space
- Board meetings held regularly in Gibraltar
- Key business decisions made locally
You can’t meet these requirements with a virtual office. Expect at least €200,000 in annual operating costs.
Market Access and Operational Challenges
This is Gibraltar’s biggest problem today.
Before Brexit: One license, 28 EU markets.
After Brexit: One license, mainly the UK market.
For the EU now, you need:
- Germany: German license (€300,000 security)
- Spain: Spanish license (€3 million security)
- Italy: Italian license (€2.5 million security)
- France: Effective monopoly for state-run operators
That makes Gibraltar unattractive for EU-focused strategies.
However: If your main market is the UK or you are focused on unregulated markets, Gibraltar can still make sense.
Malta vs. Gibraltar: A Direct Comparison for Online Casino Operators
This is the part you’ve been waiting for.
Which jurisdiction actually makes sense for your online casino?
The answer depends on your objectives. Let me show you the key decision criteria.
License Costs and Ongoing Fees Compared
Heres the hard numbers for a typical B2C online casino:
Cost Factor | Malta (MGA) | Gibraltar (GGC) |
---|---|---|
License Fee (Year 1) | €25,000 | £100,000 (~€115,000) |
Annual Fee | €35,000 | £85,000 (~€97,000) |
Bank Guarantee | €100,000 | £250,000 (~€285,000) |
Setup Costs | €40,000 | €50,000 |
Compliance Fee | 0.8% of GGR | 1% of GGR |
Total Year 1 | €200,000 | €450,000 |
The difference is substantial. Malta is much cheaper in terms of initial investment.
But that’s only half the story. The running costs determine long-term profitability.
Example calculation for €10 million GGR per year:
- Malta: €35,000 + €80,000 (0.8%) = €115,000 annually
- Gibraltar: €97,000 + €100,000 (1%) = €197,000 annually
Over five years, that’s a €410,000 difference—in Malta’s favor.
Tax Optimization: Which Jurisdiction Fits Your Needs?
This is where it gets interesting for strategic entrepreneurs.
Malta, thanks to its refund system, effectively offers 5% corporate tax. Gibraltar is at 12.5%.
But there’s a crucial difference:
Malta (on €2 million profit):
- Corporate tax: €700,000 (35%)
- Refund on distribution: €600,000
- Effective tax burden: €100,000 (5%)
Gibraltar (on €2 million profit):
- Corporate tax: €250,000 (12.5%)
- No refund
- Effective tax burden: €250,000 (12.5%)
Malta is more attractive tax-wise—but only if you distribute profits as dividends.
If you intend to retain profits in the company, Gibraltar can be more advantageous.
Market Access and Regulatory Recognition
This is the pivotal difference in 2025.
Malta Gaming Authority:
- EU-wide passport
- Direct access to 27 EU markets
- Recognition in most international markets
- Growing reputation as the “gold standard”
Gibraltar Gambling Commission:
- Direct access only to the UK market
- Separate licenses required for EU markets
- Strong reputation among payment providers
- Still recognized in unregulated markets
If your strategy is focused on EU markets, Malta is the clear choice.
But: Gibraltar has an advantage with payment providers. Many international payment service providers more readily accept Gibraltar licenses than MGA ones.
This can be decisive if you want to integrate innovative payment solutions or cryptocurrencies.
My Recommendation: Which License Strategy Makes Sense in 2025?
After more than 15 years in international tax consulting and dozens of gaming clients, I can give you a clear verdict.
But as always: The best strategy depends on your individual situation.
Who Should Choose Malta?
You should go for Malta if:
- You focus on EU markets: Germany, Spain, Italy, Netherlands
- You think long-term: Stable regulation and EU membership
- You want to optimize costs: Lower setup and ongoing costs
- You distribute dividends: To benefit from the 5% tax system
- You take compliance seriously: Malta enforces robust structures
Typical profile: You’re planning a modern online casino focused on regulated EU markets. Setup budget: €200,000–300,000. Aim: Sustainable, compliance-led structure.
Some real-life numbers: A client started with an MGA license in 2023. After 18 months:
- Active in 12 EU markets
- €25 million GGR
- Effective tax burden: 7% (including local gaming taxes)
- Compliance costs: €180,000 annually
The result: Profitable and legally secure.
When Gibraltar Still Makes Sense
Gibraltar still makes sense if you:
- Focus on the UK market: UK as your key target market
- Target unregulated markets: Latin America, Asia, Africa
- Are B2B-focused: Software or payment services
- Want payment innovation: Crypto or new payment methods
- Need a fast launch: 3–4 months vs. 6–9 months in Malta
Case from practice: A software provider chose Gibraltar in 2024 for his B2B gaming business. Why?
- Main clients in the UK and outside the EU
- Innovative payment integration
- Needed rapid market entry
- Lower compliance requirements for B2B
Result: Successful launch in 4 months, strong growth in target markets.
Hybrid Strategies and Backup Options
This is where my pragmatic side comes out: Why not do both?
Successful gaming companies think in backup scenarios. Here’s my recommendation for ambitious projects:
Dual-License Strategy:
- Start with Malta: Access to EU markets and tax benefits
- Gibraltar as a backup: For non-EU markets and payment innovation
- Separate operations: Different brands for different markets
Does it cost more? Yes, initially.
But this gives you:
- Maximum market coverage
- Regulatory flexibility
- Protection from political changes
- Optimal payment options
A concrete example: One client started this strategy in 2022.
Setup costs: €600,000 (for both licenses)
Ongoing costs: €400,000 annually
Result after 2 years: €80 million GGR, active in 15 countries
The higher costs paid off after just 14 months.
My conclusion:
For most new online casino projects, Malta is the better choice in 2025. The EU integration, lower costs, and tax benefits are decisive.
Gibraltar remains relevant for specific cases: UK-focused businesses, B2B services, or payment innovation strategies.
But whichever jurisdiction you choose: Invest in professional compliance right from the start. The days of lax regulation are over.
Got questions about your specific situation? Let’s talk. In the end, the details will decide your success.
Yours, RMS
Frequently Asked Questions (FAQ)
Can I operate in all EU countries with a Malta license?
Generally yes, the MGA license grants you an EU “passport.” But many EU countries now have their own regulations. Germany, Spain, and Italy require additional local licenses. Other markets like Austria or Sweden still accept the Malta license.
How long does it take to obtain a gaming license?
Malta: 6–9 months with complete documentation. Gibraltar: 3–4 months. The timeframe depends greatly on the quality of your application and the complexity of your business model. Thoroughly prepared applications can be processed much faster.
What are the minimum capital requirements?
Malta does not require a specific minimum capital, but a €100,000 bank guarantee is needed. Gibraltar requires a £250,000 security deposit. You should also budget for enough operating capital to cover at least 12 months.
Can I transfer my license from Gibraltar to Malta later on?
A direct transfer is not possible. You need to apply for a new license in Malta and can either keep or give up your Gibraltar license in parallel. Many operators have made this switch since Brexit. The process takes 6–12 months.
What are the actual taxes in Malta for gaming companies?
With the refund system, you pay an effective 5% corporate tax when profits are distributed as dividends. Alternatively, you can choose the Gaming Tax System: 0.8% on Gross Gaming Revenue. For high margins, the Gaming Tax is often cheaper.
Do I need physical presence in Malta or Gibraltar?
Yes, both jurisdictions require genuine economic substance. Malta: At least management based locally. Gibraltar: At least 2 full-time employees, office space, and regular board meetings. Shell companies no longer work.
Which license is better for cryptocurrency casinos?
Gibraltar is traditionally more crypto-friendly and has fewer strict requirements. Malta permits cryptocurrencies but demands much more extensive compliance. For purely crypto casinos, Gibraltar may be the more pragmatic choice.
What happens if the regulations change?
As an EU member, Malta is subject to EU-wide regulatory changes but offers more stability. Gibraltar can act more independently, but EU market access depends on local regulations. Both jurisdictions have shown they are capable of adapting.