Malta backs down on Recognition Notice rules

The Malta Gaming Authority (MGA) has softened its plan to tighten rules for companies operating from Malta under foreign licences, following pushback from the industry. In a feedback notice dated 26 October, many proposals were changed. The standard template for legal opinions will be removed, and the MGA will set out which confirmations these opinions must contain. License holders will provide ultimate beneficial owner information instead of a full corporate structure chart. B2B suppliers have also been exempted from many of the new obligations.

The industry argued that the proposals repeated conditions that foreign regulators had already imposed. It also opposed sharing commercially sensitive information.

However, this retreat is not consistent with Malta's own risk assessment. The 2023 assessment rated this framework for the first time, while the 2018 assessment had not given a rating. In the same study, the residual risk of remote gaming dropped from high to medium. The assessment was published in January 2024, and obliged persons were asked to reflect these risks in their own risk assessments.

The MGA launched a targeted consultation on 21 April 2026. The proposals were stated to aim at tightening controls at the licensing stage and making ongoing monitoring more structured, and to be consistent with the 2024 to 2026 National AML/CFT Strategy. Malta is the main hub in Europe for B2C operators and B2B suppliers. Many companies work in this area under a Recognition Notice. Many Malta-based gaming companies, for example, operate under Romanian licences. Some sources see the regime as a gap, particularly for B2B companies.

Under current rules, the certificate is valid for one year and must pass maintenance each year. The application fee is 5,000 euros, and the annual upfront payment is also 5,000 euros. Notification holders will fall under the restructured gaming tax from 1 October 2026 under Legal Notice 84 of 2026. The MGA accepted that some new requirements may require changes to the existing legal framework. It is said that gaming legislation introduced a week ago may be linked to this process.