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Topic · cross-market

Key persons & fit-and-proper

Who passes the suitability test before the operator launches

Every indexed market screens "key persons", directors, officers, key employees, qualifying owners, before licensing and on ongoing change events. The terminology varies (qualifier in most US states, "key function holder" in Malta, "personal management licence" in the UK under LCCP Part II) but the underlying test is the same: criminal record, financial integrity, industry experience, and ongoing suitability monitoring.

  • 13frameworks indexed
  • 8with matched standard
  • 62%topic coverage

Side by side

Best-match standard per framework. Scored against titles, requirements and editorial tags, click through for the full text.

Market Standard Excerpt Source
AGCO No standard directly indexed Open ↗
AGLC AGLC 2.4.4 An applicant's key employees include individuals that exercise influence or control over day-to-day operations… An applicant's key employees include individuals that exercise influence or control over day-to-day operations or decision-making and individuals who have the authority to hire or terminate the employment of employees, a… Open ↗
DGA EO 43/2025 § 5 Insider-betting prohibition: owners, directors, oddsmakers and relations (EO 43/2025 § 5 & § 6) The licensee must ensure that beneficial owners, board members, executives, persons involved in setting odds, and their close relations do not place bets with the licensee. Where odds-setting is outsourced, the licensee… Open ↗
DGOJ L 13/2011 art. 13 Fit-and-proper and honorabilidad of directors and major shareholders Directors, de facto managers and shareholders holding a significant stake must demonstrate honorabilidad comercial y profesional — no relevant criminal convictions, no insolvency proceedings, no prior gambling-licence… Open ↗
GGL No standard directly indexed Open ↗
MGA GACD 6(1) Eight key functions for remote B2C licensees Remote B2C licensees must appoint key persons responsible for: (a) chief executive role; (b) day-to-day gaming operations, including finance, payments and anti-fraud; (c) compliance with all MGA obligations, including re… Open ↗
MGCB No standard directly indexed Open ↗
NJ DGE § 69D-1.6 Monthly iGaming gross revenue reports Casino licensees must file monthly, quarterly, and annual financial and statistical reports with the Division electronically. Monthly gross revenue reports and Internet gaming gross revenue tax returns are due by 9:00 A.… Open ↗
OCCC OAC 1.2 Key Employee, Gaming Employee, and Supplier Licensing Each individual who performs a gaming-related duty for a sports gaming proprietor, management services provider, mobile management services provider, or supplier must hold a current gaming employee or key employee licenc… Open ↗
PA PGCB 58 Pa. Code § 802.3 Interactive gaming operator license Third-party platform operators that provide the technology, brand, or marketing on behalf of a certificate holder must themselves hold a PGCB-issued operator license, with key-employee licensing and disclosure of benefic… Open ↗
SGA Ch4 §4 Fit-and-proper assessment A licence may only be granted to an applicant whom the authority finds suitable as regards financial conditions, knowledge and experience, and general conduct. The assessment extends to owners with qualifying holdings an… Open ↗
UKGC LCCP No standard directly indexed Open ↗
UKGC RTS No standard directly indexed Open ↗

The policy trend line

1

Ongoing suitability is the operational reality

One-time pre-licence review is now augmented by change-notification rules. Every indexed regulator requires notification of material changes to key persons within a statutory window, typically 14 days. The UK and Malta require re-examination on specified trigger events; the US states require re-examination on change-of-control.

2

Ohio: Type A/B/C proprietor and individual gaming-employee licences

Ohio prohibits any person from offering sports gaming to patrons in Ohio without a current Type A (online/mobile), Type B (brick-and-mortar), or Type C (host) proprietor licence under ORC Chapter 3775, and every key employee or gaming employee must hold an individual licence before performing a gaming-related duty. Fingerprinting, background check and suitability disclosures are required, and the Commission must be notified within ten days of any material change in employment or disqualifying conduct.

Frequently asked

Who counts as a "key person"?

Directors, officers, the MLRO / compliance officer, and qualifying owners (typically defined as holding a threshold share, 5% or 10% depending on the market). Malta adds "key function holders" for specified operational roles. The UK requires personal management licences for named individuals under LCCP Part II.

Primary sources

Every claim above traces to one of these citations. Matched standards link straight into the framework explorer; overlay facts link to the RG Observatory card with its audit note.

Indexed standards

Built 2026-05-11 from the same datasets that power the framework explorers. Not legal advice; verify against the issuing regulator.