B2B Supplier Licensing Matrix: Notification, Registration, and Full Licence Requirements Across Eight Key Markets

Every game studio, platform provider, RNG supplier, and aggregator serving regulated iGaming markets operates within a licensing matrix that varies considerably by jurisdiction. The central question is deceptively simple: does your business need its own authorisation, or does supplying into a licensed operator’s stack satisfy the regulator? The answer differs not only by jurisdiction but by the type of supply involved. This article maps four practical tiers across eight markets: full licence, registration, ancillary approval, and notification-only. Misreading the tier means either a market access gap or unnecessary spend, and, increasingly, direct enforcement exposure.

The Four-Tier Framework: How Regulators Structure B2B Obligations

Before mapping individual markets, it is worth defining the four tiers, because regulatory terminology varies even where the underlying obligation is equivalent.

A full licence requires the B2B supplier to apply to the regulator directly, pass a fit-and-proper assessment, maintain ongoing compliance obligations, and hold the licence independently of any operator relationship. The MGA B2B licence and the UKGC gambling software licence are the clearest examples. A registration is structurally similar but typically carries a lighter compliance tail: the supplier is vetted, added to a register, and must meet standards, but the application process is less involved than a full operating-style licence. Ontario’s gaming-related supplier registration under the Gaming Control Act 1992 falls here. An ancillary approval covers situations where the supplier’s product must be technically approved or certified, such as game certification under SIFS 2022:3, without necessarily requiring a corporate entity-level licence. A notification regime requires the operator to inform the regulator that a specific supplier has been engaged, without the supplier itself holding any direct authorisation.

Most Tier 1 markets combine two or more of these tiers: an entity-level licence or registration, plus a product-level certification, plus ongoing notification obligations when material changes occur.

Does a Game Studio Need Its Own Licence in Every Market?

Yes, in every market covered by this article except Spain. The UKGC, MGA, AGCO, and all three US states covered here require the B2B supplier itself to hold an authorisation before its products or services can be used by a licensed operator. Spain operates a product-certification model where the operator holds the approval on the supplier’s behalf. In no jurisdiction does an operator’s own licence automatically extend to cover the critical gaming systems its suppliers provide.

United Kingdom: Gambling Software Licence Under the Gambling Act 2005

The UK Gambling Commission issues a gambling software licence under Part 8 of the Gambling Act 2005 to any business that manufactures, supplies, installs, adapts, or maintains gambling software where the use of that software would otherwise require an operating licence. This is a full entity-level licence, not a registration. A game studio whose titles are consumed by British-facing remote operators must hold this licence in its own name.

Under LCCP condition 2.3.1 (effective 6 April 2026), all licensees holding gambling software licences must comply with the Commission’s technical standards and with requirements set by the Commission relating to the timing and procedures for testing. The ancillary structure matters here: there are also remote gambling software licences and gaming machine technical licences, each covering different supply categories. A supplier providing both RNG-backed casino content and gaming machine software for premises-based use must assess whether it requires one licence or two.

LCCP condition 2.3.1 states that licensees must comply with the Commission’s technical standards and with requirements set by the Commission relating to the timing and procedures for testing. This obligation applies to all gambling software licence holders, including remote gambling software licences.

There is no passporting of the gambling software licence into the UK from another jurisdiction. An MGA B2B licence does not substitute for a UKGC gambling software licence when a supplier’s clients include UKGC-licensed operators serving British customers. The supply chain obligation sits with the supplier itself, not with the downstream operator’s licence coverage.

For suppliers serving British-facing operators and looking at the broader regulatory picture, our UKGC compliance guide sets out the full operating licence framework within which gambling software licensees must position their product obligations.

Malta MGA: Critical Gaming Supply vs. Material Supply

The MGA’s framework under the Gaming Act (Chapter 583 of the Laws of Malta) and Directive 3 of 2018 (V2, October 2021) creates a two-tier distinction that every B2B supplier must understand before engaging MGA-licensed operators.

A critical gaming supply, defined under clause 3 of the First Schedule to the Gaming Authorisations Regulations, includes platform software, random number generators, and core game content. Any entity providing a critical gaming supply to an MGA B2C licensee must hold an MGA B2B licence or an MGA recognition notice. Directive 3 of 2018, Article 27(1) is unambiguous: licensees obtaining a critical gaming supply from an outsourcing service provider must ensure that such provider is duly in possession of a B2B licence or a recognition notice. The recognition notice pathway is available to suppliers licensed in certain other qualified jurisdictions and reduces the friction of entering the Maltese market without a full application, but it remains a mandatory authorisation, not an exemption.

A material gaming supply, defined under the Third Schedule of the Gaming Authorisations Regulations, covers lower-criticality inputs. Under Directive 3 of 2018, Article 25(2), B2B licensees wishing to include material supplies within their B2B licence scope may do so voluntarily, and material supplies provided outside that scope are assessed on a case-by-case basis. The MGA Compliance Audit Manual (version 1, MGA/G/001) confirms that auditors check whether material gaming suppliers hold either a material supply certificate or a case-by-case approval. Suppliers providing material gaming inputs without either are non-compliant and expose the B2C operator to audit findings.

For a full treatment of MGA B2B licence obligations, disclosure requirements, and enforcement patterns, see our dedicated article on the MGA licensing framework.

Ontario AGCO: Gaming-Related Supplier Registration

Ontario’s internet gaming market, regulated by the Alcohol and Gaming Commission of Ontario under the Gaming Control Act 1992, requires B2B suppliers to obtain a gaming-related supplier registration before providing goods or services that would otherwise require registration under the Act. The AGCO Registrar’s Standards for Internet Gaming (last updated 29 May 2025) establish the framework.

Standard 1.22 of the Registrar’s Standards is the operative provision: operators and gaming-related suppliers must not provide an internet gaming operator or gaming-related supplier with any goods or services if, to provide those goods and services in iGaming Ontario’s regulated online lottery scheme, it would require registration under the Gaming Control Act 1992. The consequence is direct: an operator whose platform provider, game studio, or aggregator does not hold a gaming-related supplier registration is itself in breach of Standard 1.22.

Standard 1.19 further establishes that operators are responsible for the actions of third parties with whom they contract for the provision of any aspect of the operator’s business related to gaming in Ontario, and must require those third parties to conduct themselves as if they were bound by the same laws, regulations, and standards. The AGCO registration is therefore a condition of the commercial relationship, not merely a desirable accreditation.

Standard 1.20 adds an ongoing supply chain transparency obligation: operators and gaming-related suppliers must maintain a list of all suppliers providing goods or services in relation to lottery schemes and make it available to the Registrar upon request.

For operators navigating the Ontario market more broadly, our detailed Ontario iGaming compliance guide covers the full Registrar’s Standards framework, including responsible gambling and technical certification obligations that feed directly into supplier due diligence requirements.

Sweden: Gambling Software Permit and System Certification

Sweden’s Gambling Act (SFS 2018:1138) introduced a gambling software permit as a specific authorisation category for B2B suppliers. As documented in Spelinspektionen’s published licensing fee schedule, the application fee for a gambling software permit is SEK 120,000, with an annual supervisory fee of SEK 16,500. This is a modest fee relative to the operator licence cost (SEK 264,000 annual supervisory fee), but the permit is a full regulatory authorisation, not a simple registration.

The permit operates alongside, not instead of, a product-level certification obligation. Under SIFS 2022:3 (the Swedish Gambling Authority’s regulations on technical requirements and accreditation), operator licence applicants must ensure their gambling system is certified by an independent accredited testing house. Suppliers’ technical equipment and games form part of the operator’s gambling system, so supplier content must also be part of that certification. Spelinspektionen’s guidance published May 2025 confirms this explicitly: this fundamental principle remains even after the introduction of the gambling software permit.

The SIFS 2022:3 guidelines (May 2025) categorise sub-suppliers into three groups relevant to the regulations: suppliers of goods such as commodity software or hardware, suppliers of services such as operation, maintenance, or updates of part of a gaming service, and suppliers of customer-facing services. If a sub-supplier provides the same service to multiple licensees, Spelinspektionen notes that this may entail an enormous administrative burden, and such suppliers may be inspected, tested, or certified directly under Chapter 2 of the relevant regulations. For high-volume B2B suppliers, the entity-level permit and product-level certification obligations therefore converge.

Pennsylvania PGCB: Board-Licensed Vendors Under 58 Pa. Code

Pennsylvania regulates B2B suppliers under Chapter 809a and the interactive gaming provisions of Title 58 of the Pennsylvania Code. The Pennsylvania Gaming Control Board issues gaming supplier licences and manufacturer licences for entities providing interactive gaming systems, games, and ancillary services to certificate holders and interactive gaming operators.

Under 58 Pa. Code section 812a.2(e), interactive gaming certificate holders and interactive gaming operators may utilise third-party vendors to verify player information and provide ancillary services, so long as those vendors are licensed by the Board when required and the relevant agreements are submitted to the Board. The phrase “when required” creates a threshold question: not every vendor requires a Board licence, but those providing gaming-critical functions, including platforms, game content, RNG infrastructure, and payment processing, do. The determination of whether a specific supplier requires Board licensing is an assessment of the function performed, not the vendor’s self-classification.

Pennsylvania does not publish a single exhaustive list of which categories always require licensing, the analysis is function-based. Suppliers should seek specific guidance from the PGCB’s Bureau of Gaming Operations before deploying into a Pennsylvania operator’s stack. Engaging an unlicensed vendor for a function that requires licensing can render the certificate holder’s internal controls non-compliant, potentially triggering enforcement under the PGCB’s standards.

Michigan MGCB: Internet Gaming Supplier Approval

The Michigan Gaming Control Board regulates the internet gaming market under the Lawful Internet Gaming Act and its implementing regulations. B2B suppliers providing internet gaming-critical services to Michigan-licensed internet gaming operators must obtain a supplier licence from the MGCB. The MGCB serves as the designated licensing authority and has authorised Gaming Laboratories International as a designated test laboratory for Michigan, creating a layered certification requirement: entity-level supplier licence from the MGCB, plus game content certification by an MGCB-approved test laboratory.

The MGCB supplier approval process assesses principals, key employees, and associated entities of the applying supplier, covering background checks, financial integrity, and suitability. Michigan’s model is closest in structure to the UKGC gambling software licence: it is a full entity-level authorisation, not a registration or notification, and the supplier cannot provide services to an internet gaming operator until the licence is issued.

Suppliers already licensed in New Jersey are eligible to apply for expedited consideration in Michigan under the MGCB’s multi-state licensing recognition provisions. This does not constitute automatic approval, it reduces the evidential burden rather than eliminating the licensing requirement.

New Jersey DGE: Transactional Waiver and Vendor Registration

New Jersey’s Division of Gaming Enforcement regulates B2B suppliers under the Casino Control Act and the implementing internet gaming regulations. The DGE distinguishes between casino service industry enterprise (CSIE) licences for higher-risk or higher-value supplier functions, and a transactional waiver or vendor registration for lower-risk, non-gaming-critical supply relationships.

For B2B iGaming suppliers providing platform software, game content, and core gaming systems to New Jersey-licensed internet gaming operators, a CSIE licence is required. This is a multi-year approval process involving background investigations of key principals and beneficial owners with ten percent or more ownership interest. Suppliers providing ancillary services with limited impact on gaming outcomes or player funds may qualify for a transactional waiver, which allows services to commence while a full licence application is processed. New Jersey’s DGE system is one of the most established B2B supplier licensing regimes in the United States and remains the reference point for multi-state market entry sequencing in the Atlantic market.

New Jersey’s CSIE licensing framework, Pennsylvania’s Board-licensed vendor model, and Michigan’s MGCB supplier approval each require entity-level authorisation for gaming-critical supply chains, meaning the operator’s internet gaming licence does not extend to cover its platform or game providers.

Spain DGOJ: Operator-Centric Model with Technical Approval Requirements

Spain’s Directorate General for the Regulation of Gambling (DGOJ) under the Gambling Law 13/2011 does not require B2B game suppliers to hold a standalone entity licence in the way that the MGA or UKGC do. Spain operates an operator-centric model: the licensed operator holds the B2C operating licence and is responsible for the suitability and technical compliance of its game content and platform suppliers.

Technical approval is required at the product level. Software, games, and gambling systems deployed by DGOJ-licensed operators must receive technical certification from an approved testing laboratory authorised by the DGOJ. This approval is product-specific: each game title or platform component must be individually certified for use in the Spanish market. The operator holds the certified product approval, but the supplier must put its software through the certification process to enable the operator to deploy it lawfully.

Spain therefore sits in the ancillary approval tier rather than the full-licence tier for B2B suppliers: no entity-level licence or registration is required for the supplier itself, but no product may be deployed without a certified technical approval attached to an operator’s licence. The DGOJ has demonstrated willingness to enforce against those who facilitate non-compliant content distribution. According to iGaming Business (May 2026), the DGOJ fined production company Make Money Now SA for promoting an unlicensed operator on social media, with the fine reduced to €6,000, signalling that the regulator scrutinises the full supply and promotion chain even under an operator-centric model.

What Happens When a Supplier Skips Registration?

The enforcement risk falls on both parties. Under the MGA framework, an operator that deploys a critical gaming supply from an unlicensed provider is in direct breach of Directive 3 of 2018, Article 27(1), exposing itself to regulatory action regardless of whether the supplier was unaware of the requirement. Under the AGCO framework, Standard 1.22 places the prohibition on the operator, making the operator’s registration status contingent on the compliance status of its supply chain. In the US states, an operator’s interactive gaming certificate can be found non-compliant if its internal controls rely on an unlicensed vendor performing a function that requires Board licensing.

Cross-Market Implications for Compliance Teams

The matrix above reveals a clear pattern: markets with a strong player protection track record, including the UK, Malta, and Ontario, have moved firmly into the full-licence or mandatory-registration tier for critical gaming supply. Sweden has created a bespoke permit category with a light supervision fee structure. The US states (New Jersey, Pennsylvania, Michigan) each operate full entity-level licensing for critical B2B supply, with no passporting between states. Spain remains in the product-approval tier without a standalone B2B entity licence.

For a game studio or platform provider building a market entry sequence, the practical order of operations is as follows. First, assess whether your supply function constitutes a critical gaming supply, gaming-critical vendor function, or supplier-of-record role in each target market, as the classification determines the tier. Second, identify whether any existing licence or registration in one market reduces the evidential burden in another: the MGCB recognises New Jersey approvals as a basis for expedited review, and the MGA recognition notice is available to suppliers from qualified jurisdictions. Third, account for the product-level certification requirement that exists in parallel with the entity-level authorisation in every market covered here. Holding an MGA B2B licence does not substitute for SIFS 2022:3 certification of game content for Swedish operators, nor does a UKGC gambling software licence satisfy a PGCB product approval requirement.

Key Resources

UKGC Licence Conditions and Codes of Practice (effective 6 April 2026), including LCCP condition 2.3.1 on technical standards for gambling software licensees: gamblingcommission.gov.uk/licensees-and-businesses/lccp

MGA Gaming Authorisations and Compliance Directive (Directive 3 of 2018, V2 October 2021), Articles 25, 27 on critical gaming supply and B2B licensing obligations: mga.org.mt

AGCO Registrar’s Standards for Internet Gaming (last updated 29 May 2025), Standards 1.18, 1.22 on gaming-related supplier registration and operator responsibility: agco.ca/en/lottery-and-gaming/registrars-standards-internet-gaming

Spelinspektionen Gambling Laws and Regulations Report 2026, gambling software permit fee schedule and SIFS 2022:3 guidelines (May 2025): spelinspektionen.se

58 Pa. Code Chapter 812a, Interactive Gaming, section 812a.2(e) on Board-licensed vendor requirements: pacodeandbulletin.gov