Malta Scales Back Foreign Licence Recognition Reforms After Industry Pushback
The Malta Gaming Authority has scaled back its planned overhaul of the Recognition Notice regime, the framework that lets Malta-based gambling businesses operate under foreign licences, after pushback from the industry.
The regulator set out the softened package in a feedback statement dated October 26, 2026, and said that some of the new requirements may require changes to the existing legal framework.
The retreat follows a consultation the MGA opened in April as part of Malta's National AML/CFT Strategy for 2024 to 2026.
It also sits alongside other recent moves by the island's government and regulator, including the narrowing of the gambling VAT exemption covered in our Malta VAT report.
How The Recognition Notice Regime Works
A Recognition Notice allows a gambling business based in Malta to operate without a separate MGA licence when it already holds a licence from a regulator in another EU or EEA country, or from one of several other jurisdictions judged to have broadly equivalent anti-money-laundering rules.
The arrangement covers both business-to-consumer and business-to-business companies. In practice, many of the businesses using the route hold Swedish or British licences.
Malta's 2023 money-laundering National Risk Assessment rated the regime's residual risk as medium-high, above the figure for online and land-based gaming as a whole.
It noted that the system relies heavily on firms telling the MGA that they are operating under a foreign licence, and that some may be subject to a weaker anti-money-laundering framework abroad.
The same assessment recorded that 111 Malta-incorporated gaming companies were operating under Recognition Notices by 2021, including 46 business-to-consumer operators, according to SectorWire.
Malta was added to the Financial Action Task Force grey list in 2021 and removed a year later, which explains why the island is sensitive about its AML record.
What The MGA Has Dropped Or Softened
The regulator described consultation responses as constructive and said stakeholders broadly backed the direction of travel.
They did, however, stress proportionality, operational practicality and the need to avoid duplicating what foreign licensing authorities already require.
Most of the original proposals were relaxed, and one was removed outright. The MGA had asked for a full corporate structure chart, but after objections regarding duplication, it will now request only ultimate beneficial owner information.
A standardised legal opinion template has been dropped altogether because stakeholders argued that different countries' legal systems cannot be squeezed into a single format.
A floated requirement for five years of regulatory history, including correspondence, has also gone. Licensees will instead be asked for material fitness and licensing matters.
On annual deposit value and volume, which operators called commercially sensitive, the MGA appears to have settled for predefined bands rather than exact figures, and payment methods will be reported in aggregated categories.
B2B suppliers were exempted from many of the obligations after firms argued that checks designed for consumer-facing operators should not extend to them.
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Legal Limits And What Happens Next
Some stakeholders questioned whether the MGA has the statutory authority to request certain information.
The regulator acknowledged that some of the new Recognition Notice requirements may require amendments to the existing framework, which would be a matter for the Maltese government rather than the authority itself.
The MGA will still begin collecting information from foreign licence holders under the new regime this year. That first round covers the 2025 reporting period and is limited to business-to-consumer operators.
The change matters for operators that base staff in Malta but hold licences elsewhere, and for the wider debate over how much oversight the island applies to them.
Malta's regulator has shown it is willing to move on technology and policy topics, as with its AI gaming charter, but this episode shows the limits of what it can impose without legislative backing.
Further stakeholder consultation is expected, and any move to amend the legislation behind the Recognition Notice system would be the next signal to watch.
