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.
Each chip is one indexed rulebook. Green = we have a directly matched standard on this topic; dim = the topic may be covered under different wording, explore the framework to verify.
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 ↗ |
| Coljuegos Coljuegos — UBO and ownership transparency | Ultimate beneficial owner transparency | Operators must keep ultimate beneficial owner records up to date and disclose them to Coljuegos on request. Ownership changes that affect control or beneficial-ownership composition must be notified. | 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 ↗ |
| DIA OCGA 2026 §fit | [ACT - phased commencement] Fit-and-proper test for operators, key personnel, beneficial owners | Licence applicants must satisfy DIA's fit-and-proper test across the operator entity, parent group, beneficial owners with significant influence, and key personnel (directors, CEO, Compliance Officer, Money Laundering Re… | Open ↗ |
| GCB Full UBO disclosure | Disclosure of ultimate beneficial owners up the chain | Applicants must disclose every ultimate beneficial owner holding 10 percent or more of the applicant entity or exercising effective control, mapped through the full corporate chain. The CGA verifies UBO identity against… | 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 ↗ |
| MINCETUR Resolución SBS 03622-2025 — Oficial de Cumplimiento | Designation of the Oficial de Cumplimiento | Every operator must designate an Oficial de Cumplimiento responsible for supervising the SPLAFT and for being the direct point of contact with UIF-Perú and MINCETUR. The officer must demonstrate experience and suitabili… | 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 ↗ |
| PAGCOR PD 1869 sec. 4 | Board of Directors composition | Section 4 of PD 1869 constitutes PAGCOR's Board of Directors with a Chairman and four Members appointed by the President of the Philippines. The Chairman concurrently serves as Chief Executive Officer, fusing oversight a… | Open ↗ |
| SEGOB RLFJS art. 22 | Permit-holder eligibility and fit-and-proper | Article 22 sets the eligibility conditions for a permit holder: Mexican legal personality, corporate purpose covering the requested activity, evidence of technical and economic capacity, and absence of disqualifying crim… | 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 ↗ |
| SPA/MF Portaria SPA/MF 827/2024 art. 10 | Fit-and-proper test for directors and qualifying shareholders | Directors, de facto managers and qualifying shareholders must demonstrate honourability, technical competence and absence of disqualifying convictions. Administrators must show at least three years' professional experien… | Open ↗ |
| UKGC LCCP | No standard directly indexed | — | Open ↗ |
| UKGC RTS | No standard directly indexed | — | Open ↗ |
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.
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.
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.
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.
Built 2026-07-14 from the same datasets that power the framework explorers. Not legal advice; verify against the issuing regulator.