Malta Gaming Hub vs. Gibraltar Online Gaming: British vs. Maltese Licenses for German Online Casinos – Brexit Impacts and Opportunities

Malta Gaming Hub 2025: The Advantages of the Maltese Gaming License

Malta has established itself as Europe’s gaming hub. That’s not a coincidence.

The Malta Gaming Authority (MGA) was founded in 2001 and has since issued over 400 gaming licenses. That means Malta has over two decades of experience in gaming regulation.

What makes Malta a special gaming location?

First, the basics: Malta has been an EU member since 2004. As a German entrepreneur, this means full access to the EU Single Market—no customs barriers, no currency risks, no complex third-country rules.

The MGA differentiates between four license types:

• Class 1: Skill games and lotteries
• Class 2: Fixed odds betting/games of chance
• Class 3: Peer-to-peer games
• Class 4: Other gaming services

But thats just the starting point. The real benefits are practical:

Tax Structure in Malta for Gaming Companies

Malta applies a unique full-imputation system. Here’s how it works:

Your Maltese gaming company initially pays 35% corporate income tax. Sounds high, but it’s not—because when profits are distributed to you as a shareholder, you get back 6/7 of the tax paid.

The result: An effective rate of only 5%.

Malta also offers special gaming tax rules. Online gaming companies can choose between two models:

Regulatory Advantages of the Maltese Gaming License

Malta has introduced a single license system—meaning: one license entitles you to all types of gaming activity across the EU. No need for separate applications in every EU country.

Furthermore, Germany accepts Maltese licenses under certain conditions. Since the new German Interstate Gambling Act 2021, Maltese operators can apply for a German license.

Processing time for a Maltese gaming license is usually 6-9 months—a lot quicker than in many other EU countries.

Infrastructure and Talent Pool in Malta

Malta is making major investments in gaming infrastructure. Over 300 gaming companies are based on the island, creating a one-of-a-kind ecosystem:

• Law firms specializing in gaming law
• IT service providers focused on gaming
• Experienced compliance professionals
• International talent pipeline

The University of Malta even offers a Master’s program in Gaming and Gambling Studies. Clearly—Malta thinks long-term.

Gibraltar Online Gaming after Brexit: What German Entrepreneurs Need to Know

For years, Gibraltar was Europe’s insider tip for gaming. Brexit changed everything.

Let me be honest: Gibraltar faces serious challenges—but also unique opportunities.

Gibraltar Gaming Commission: Tradition Meets Innovation

The Gibraltar Gaming Commission has existed since 1998, making it one of the world’s most experienced gaming authorities. Over 60 companies currently hold a license.

Gibraltar prioritizes quality over quantity. The number of licenses is deliberately limited. For you, this means: Less competition, but stricter requirements.

Gibraltar’s license types are pragmatically structured:

• B2C license: Direct customer contact
• B2B license: Software and services
• Ancillary license: Supporting services

The Impact of Brexit on Gibraltar Gaming Licenses

This part gets tricky. Since January 1, 2021, Gibraltar is no longer part of the EU Single Market. This has far-reaching consequences:

First, the bad news: Automatic EU market access is gone. Gibraltar-licensed companies need separate approvals for EU markets.

But there’s good news, too. Gibraltar was quick to respond:

The New Gibraltar Strategy: Going Global, Not Just EU

Gibraltar is using Brexit as an opportunity to reposition itself globally. The strategy is a smart one:

First: Strengthened cooperation with non-EU countries. Gibraltar has already signed agreements with the Isle of Man and Jersey.

Second: Focus on innovative gaming technologies. Blockchain-based gaming solutions and cryptocurrencies are actively promoted.

Third: Maintaining high regulatory standards. Gibraltar aims to remain the “gold standard” in gaming regulation.

Germany and Gibraltar after Brexit

Here’s the sticking point for German entrepreneurs: Since Brexit, Germany treats Gibraltar as a third country—resulting in more complex application procedures.

Still, Gibraltar remains attractive for certain business models:

• B2B gaming software without German end-customer contact
• International gaming platforms
• Crypto-gaming applications
• Innovation labs for new gaming technologies

Processing times for Gibraltar licenses are still among the fastest at 3-6 months.

German Online Casinos: Direct Comparison of License Options

The German gambling law of 2021 changed the game completely—finally some clarity, but also new restrictions.

Let’s walk through the options systematically:

German License vs. EU License: Whats the Current Rule?

With the Interstate Gambling Treaty 2021, Germany introduced a paradigm shift. Online gambling is now legal—but strictly regulated.

The Joint Gambling Authority of the German States (GGL) issues three types of licenses:

1. Online Casino License: Virtual slots
2. Online Poker License: Poker tournaments & cash games
3. Sports Betting License: Online sports betting

But be careful: Regulations are strict. Monthly deposit limits of €1,000, spin limits of €1, minimum game duration of 5 seconds.

Malta vs. Gibraltar vs. Germany: The Full Comparison

Which License Fits Which Business Model?

The choice of location depends on your concrete business model. Here are my recommendations:

For the German market: A German license is mandatory if you want to serve German customers—no alternatives.

For EU-wide expansion: Malta remains the top choice. The EU passporting system still works.

For B2B gaming software: Gibraltar can be attractive despite Brexit, especially for innovative technologies.

For global markets: A combination of several licenses is often best—Malta for the EU, additional licenses for other markets.

Compliance Requirements in Comparison

Compliance is the key to any gaming operation. Requirements vary widely:

Malta: Comprehensive compliance framework, but there are established consulting resources.

Gibraltar: Pragmatic regulation focused on player protection and anti-money laundering.

Germany: Very strict regulations and high penalties for violations.

My advice: Invest in professional compliance consulting from the start. The cost is minimal compared to the risks.

Brexit’s Impact on the Gaming Industry: Opportunities and Risks

Brexit was an earthquake for the gaming sector. And the aftershocks are still being felt today.

Let me break down the effects for you:

Upheaval in the European Gaming Landscape

Before Brexit, it was simple: EU license = access to the whole EU. Gibraltar was especially popular for its efficient regulation.

Today, it’s much more complicated. Gibraltar-licensed firms face new challenges:

• Loss of EU passporting rights
• Requirement for separate EU licenses
• More complex compliance requirements
• Possible capital flight to Malta

But Brexit also created winners—Malta benefits hugely from uncertainty around Gibraltar.

New Market Dynamics since 2021

This has interesting consequences:

Strategic Realignment of Gaming Companies

Successful gaming companies reacted quickly to Brexit. The most common strategies:

Multi-jurisdictional approach: Licenses in multiple countries instead of relying on a single EU license.

Hub-and-spoke model: HQ in Malta for EU markets, separate licenses for third countries.

Technology-first: Focusing on innovative gaming technologies that transcend regulatory borders.

Brexit as a Catalyst for Innovation

Here’s the surprising element: Brexit has accelerated innovation.

Gibraltar is pushing blockchain gaming and cryptocurrencies, with more progressive regulation than the EU.

Malta is responding with its own innovation programs. The Malta Digital Innovation Authority (MDIA) framework for blockchain is among the world’s best.

Germany is taking pragmatic steps with virtual sports betting and e-sports.

Long-term Outlook after Brexit

My perspective after three years of Brexit:

Gibraltar will establish itself as a niche location, focusing on B2B software and innovative gaming tech.

Malta will cement its place as the EU’s gaming hub—its infrastructure and expertise are second to none.

Germany is becoming Europe’s largest regulated gaming market—the potential is huge.

For entrepreneurs like you, that means: the days of simple solutions are over—but the opportunities have never been better.

Tax Aspects: Malta vs. Gibraltar for Gaming Companies

Now it’s time to talk numbers—let’s discuss your money.

The tax differences between Malta and Gibraltar can make or break your gaming company’s success.

Malta: The Full-Imputation System Explained

Malta uses a unique tax system, organized across three accounts:

1. Final Tax Account (FTA): For profits from Maltese sources
2. Immaterial Property Income Account (IPI): For IP income
3. Foreign Income Account (FIA): For foreign income

The IPI account is especially attractive for gaming companies—gaming software and platforms qualify as intellectual property.

Example: Your Maltese gaming company earns €1 million in profit from IP licensing:

Gibraltar: Clear 10%—No Complexity

Gibraltar is more straightforward. Gaming companies pay a flat 10% corporate tax, period.

No complicated refund procedures, no multiple accounts, no distribution requirements.

The same example in Gibraltar:

• Company profit: €1,000,000
• Tax burden: €100,000 (10%)
• Available funds: €900,000

At first glance, Gibraltar seems cheaper. But beware: That’s not the whole story.

Hidden Costs and Compliance Workload

Malta requires higher administration:

• Annual compliance costs: €15,000–25,000
• Tax advice for full-imputation: €5,000–10,000
• MGA license fees: 0.5% of net revenues

Gibraltar is leaner:

• Annual compliance costs: €8,000–15,000
• Simple tax advisory: €2,000–5,000
• License fees: flat €85,000 annually

International Double Taxation Agreements

Here’s an important difference:

Malta has over 70 double taxation treaties, which is essential if you receive dividends as a German resident.

Gibraltar has far fewer treaties, which can result in a higher tax burden on dividends.

Example for German shareholders:

Gaming-Specific Tax Advantages

Both jurisdictions offer special gaming tax regimes:

Malta Gaming Tax: An alternative to corporate tax at 0.5% of net revenues—ideal for large businesses with high turnover.

Gibraltar Gaming Duty: Flat annual license fee instead of revenue-based taxation.

The best option depends on your business model. Malta’s gaming tax makes sense from around €20 million in net revenues.

My Tax Recommendation

For gaming startups: Gibraltar offers simplicity and predictability.

For established companies: Malta enables significantly lower tax rates through smart structuring.

For German founders: Malta provides greater flexibility thanks to EU membership and its treaty network.

But remember: The lowest tax doesn’t help if the structure doesn’t fit your lifestyle.

Legal Framework 2025: EU Regulation and National Laws

Gaming regulation isn’t getting simpler—it’s getting more complex. 2025 brings another wave of challenges.

Allow me to outline the most important developments:

EU Digital Services Act and the Gaming Sector

The Digital Services Act (DSA) has been fully in effect since February 2024. This affects gaming platforms with over 45 million EU users.

The new requirements include:

• Transparency reports on content moderation
• External algorithm audits
• Stricter reporting obligations for illegal content
• Risk assessments for social impact

This applies if your gaming platform enables user-generated content. Chat features, forums, or social gaming count here.

Understanding National Regulatory Differences

Despite EU harmonization, there are significant national differences:

Anti-Money Laundering Provisions for Gaming

The 6th EU Anti-Money Laundering Directive brought stricter gaming-specific rules:

Enhanced due diligence from €2,000 turnover per customer (previously €15,000).

Suspicious transaction reports must be submitted within 24 hours (previously 48).

Blockchain-based gaming tokens are fully covered by AML regulation.

What this means: Invest early in professional AML-compliance systems. Fines have increased sharply.

Data Protection and Gaming: GDPR 2.0

Gaming companies process particularly sensitive data. Supervisory authorities are tightening up:

Gaming behavior is now considered profiling—stricter consent rules apply.

Geolocation data for license compliance is permitted, but must be used only for that purpose.

Algorithmic decisions (bonus offers, game recommendations) require transparency.

Upcoming Regulatory Changes 2025–2026

The EU Commission is planning further regulations specific to gaming:

Digital Gambling Act: EU-wide harmonization of gambling law planned for 2026.

AI in Gaming Regulation: Specific rules for AI-driven gaming algorithms from 2025.

Cross-border enforcement: Stronger cooperation among national gambling authorities.

My advice: Start preparations now—don’t wait for the laws to be finalized.

Creating Legal Certainty: Best Practices

Successful gaming businesses invest proactively in compliance:

1. Legal monitoring: Continuous updates on regulatory changes
2. Multi-jurisdictional compliance: Uniform standards across markets
3. Technology compliance: Automated compliance via specialized software
4. Regular audits: Annual external compliance checks

Investment in compliance pays off. Regulatory penalties can be existentially threatening.

Location Selection for Gaming Companies: The Ultimate Decision Guide

Let’s get practical. How do you make the right choice for your gaming company?

I’ll guide you through a structured decision-making process I’ve developed with my clients.

Step 1: Business Model Analysis

First, you need to clearly define your business model:

B2C online casino: Direct customer service, high compliance demands, usually needs local licenses.

B2B gaming software: Lower regulatory hurdles, focus on IP protection and tax structuring.

Gaming platform as a service: Hybrid model, requires flexible licensing.

Blockchain gaming: New regulatory challenges, innovative locations preferred.

Step 2: Defining Your Target Market

Your target customers determine your location choice:

Step 3: Financial Assessment

Prepare a 5-year calculation of all costs:

Setup costs:

• License fees and consulting
• Company formation and compliance setup
• Initial capital requirements

Ongoing costs:

• Annual license fees
• Compliance and legal
• Tax advice and accounting

Tax burden:

• Effective corporate tax rate
• Personal dividend taxation
• Potential double taxation

Decision Matrix: Malta vs. Gibraltar vs. Germany

Rate each factor from 1–10 for your specific situation:

Risk Assessment and Contingency Planning

Each location carries specific risks:

Malta risks:

• Possible EU-wide harmonization of gaming law
• Rising compliance costs
• MGA overload with higher application volumes

Gibraltar risks:

• Post-Brexit uncertainty
• Possible loss of further EU market access
• Dependency on UK policy

Germany risks:

• Restrictive advertising regulation
• High compliance costs
• Potential for further tightening

My Recommendation for 2025

Based on current trends, I recommend the following priorities:

For gaming startups: Malta first, with Gibraltar as an option for later expansion.

For a German market focus: A German license is unavoidable; Malta as your EU hub.

For B2B software: Gibraltar or Malta, depending on your target customers.

For blockchain gaming: Gibraltar, thanks to progressive crypto regulations.

Always remember: The best decision is the one that fits your lifestyle and long-term goals.

Yours, RMS

Frequently Asked Questions about Malta and Gibraltar Gaming Licenses

Can I operate in Germany with a Maltese license?

Only with limitations. Since the 2021 Interstate Gambling Treaty, you need a German license to serve German customers. The Maltese license can serve as a basis for a German application but does not grant direct rights to operate in Germany.

How long does it take to get a gaming license in Malta vs. Gibraltar?

Malta: 6–9 months with all documents complete. Gibraltar: 3–6 months, but requirements have increased since Brexit. Allow extra time for possible queries.

What are the minimum capital requirements?

Malta requires a minimum €40,000 paid-in capital plus a €100,000 bank guarantee. Gibraltar requires £50,000 minimum capital. Germany varies by license type from €200,000 to €2 million.

Are gaming profits in Malta tax-free for German residents?

No, that’s a misconception. German tax residents must declare Maltese dividends in Germany. Malta charges no withholding tax on distributions, but Germany taxes worldwide income.

What happens to Gibraltar licenses after Brexit?

Existing licenses remain valid, but EU market access is lost. Gibraltar-licensed companies need separate EU licenses or must operate via Maltese subsidiaries.

Can I operate gaming businesses with a regular trading license?

Absolutely not. Gaming requires specific licenses in all jurisdictions. Operating without a gaming license is a criminal offense and can result in jail time. Don’t let dubious advisors tell you otherwise.

What compliance costs should I expect?

Malta: €15,000–25,000 annually for compliance, legal, and tax consulting. Gibraltar: €8,000–15,000 per year. Germany: €30,000–50,000 yearly due to stricter regulation. Add software costs for AML and player protection on top of that.

Is combining Malta and Gibraltar licenses sensible?

Combination can make sense for different business segments. Malta for EU B2C gaming, Gibraltar for B2B software or innovative gaming tech. But a more complex structure means higher compliance costs.

What are the personal requirements for license holders?

All jurisdictions perform comprehensive background checks. Prior convictions for fraud or money laundering disqualify applicants. Insolvency within the past five years can also be an issue.

Can I sell my gaming license later on?

Gaming licenses are generally transferrable but require regulatory approval. The buyer must also pass the same fit-and-proper tests. The process typically takes 3–6 months and costs €10,000–25,000.