The Anjouan gaming license: published cost, statutory basis and the Comoros legitimacy dispute What the regulator’s own fee page says, and what the Comorian state says about the regulator

The search term is “anjouan gaming license cost” and the expectation behind it is a cheap license. The published number is EUR 17,828 to issue and EUR 17,828 to renew each year, read off the fee page maintained by Anjouan Gaming and verified 21 September 2026. Those figures are the most reliable data point here, because they come from the issuer rather than a reseller, and they are higher than most numbers quoted in the market.

The second point is harder to put cleanly, so we put it plainly and attribute it. The Union of the Comoros, through its central bank, has stated more than once that the bodies issuing these licenses have no legal existence. That is reported by ABC News on 31 December 2025 and the Irish Examiner in March 2026. The bodies concerned reject it. This page sets out both positions, dates them and names who said what.

For a counterparty reviewer the consequence is that Anjouan does not sit in the same risk category as Curacao or Costa Rica, though the three are habitually grouped. Curacao has a statutory regulator under an ordinance in force since 24 December 2024; Costa Rica has no gambling law and no regulator at all. Anjouan is a third thing: it presents a regulator, a register and a fee schedule, and the government of the state named on the license says publicly that the issuer is not what it presents itself to be.

The regulator’s own site previously served the Act as a PDF. Verified by direct request on 21 September 2026, that URL returns an HTTP 301 redirect to the site root and the document is no longer served; no archived copy was retrievable. We could not verify the Act’s text, its section numbering, or whether it contains a fee schedule. Put plainly: the primary law on which more than 1,650 claimed licenses rest cannot be read by the people buying them.

One citation should be retired. Several guides attribute the regime to a “Decree 003 of 2005”. We found no support for it in any source, official or commercial, and do not publish it.

The history is contested in its dates. The Irish Examiner, March 2026, reports that Anjouan declared independence in 1997, that the Anjouan Offshore Finance Authority dates from that separatist period, that the island rejoined the Comoros in 2002, and that later banking laws stripped the authority of regulatory status. ABC News, 31 December 2025, dates that removal to banking legislation of 2013 and 2015. The two reconcile if reunification is the 2001 to 2002 event and the operative legislation is 2013 and 2015; that reconciliation is ours and is unconfirmed.

Anjouan Gaming, operating in association with the Anjouan Offshore Finance Authority, states that it administers a regime established under the Computer Gaming Licensing Act 007 of 2005 of the Autonomous Island of Anjouan, Union of the Comoros. Its news page, checked 21 September 2026, states that more than 1,650 licenses have been issued and approximately 1,500 are active as of 14 July 2026. Administration passed to Anjouan Licensing Services Inc. in May 2023 according to secondary guides.

On 10 June 2026 it issued a public statement rejecting international criticism, reported by Focus Gaming News, citing due diligence, AML and KYC checks, fit-and-proper assessment of owners, directors and beneficial owners, sanctions and politically exposed person screening, and technical and responsible-gambling standards. Two lines define the ground it chose: that an Anjouan license is not a universal authorisation to operate in every country, and that no licensing authority can exempt an operator from local law. Both are correct and undisputed. It is worth observing, without drawing a conclusion, that the statement answered the claim that the license works as global authorisation rather than the claim that the issuer lacks legal existence.

The following are statements by Comorian officials and institutions, as reported. They are reported statements, not findings of this publication. Note also that several lookalike domains present themselves as the authority; a claimed license should be checked only at anjouangaming.com.

In 2020 an official of the Central Bank of the Comoros said the entities behind Anjouan licenses operate online via websites to scam people, as reported by ABC News on 31 December 2025. In 2022 the Central Bank declared the Anjouan Offshore Finance Authority a fictitious structure that, in the bank’s words, issues licenses and provides banking and financial services illegally, as reported by the Irish Examiner in March 2026. In 2023 the Central Bank stated that the Anjouan regulators and the firms selling their licenses are fictitious structures with, again in the bank’s words, in reality no physical or legal existence, as reported by ABC News. A former Comoros Attorney-General is quoted by ABC News describing Anjouan Licensing Services as an illegal entity. In early January 2026 Comoros officials warned the iGaming industry that entities selling Anjouan licenses have no legal authority to do so, reported by Focus Gaming News and iGaming Today.

The commercial effect was large. On reported volume figures: 19 licensees on a Gaming Control Anjouan site in April 2024, per an unverified secondary report; 825 active licenses claimed as of 20 May 2025 in a trade-press column discussed in section 06; approximately 1,300 claimed as of 31 December 2025 by ABC News; and more than 1,650 issued as of 14 July 2026 on the issuer’s own page.

Roughly eightyfold growth in about 27 months is not in itself a compliance problem. It becomes one against section 07, where the published suspension and revocation registers are both empty: a body that grew its book that fast while naming no suspended and no revoked licensee is describing either an extraordinarily well-behaved population or a supervisory function that produces no public outcomes.

That last point is routinely misattributed. The master and sub-license pattern that drew a decade of criticism belongs to Curacao, where it ran from 1993 until abolished in December 2024. It is not an Anjouan feature. The structural risk here is different: high volume, fast approval and no published enforcement outcomes.

Corporate and technical requirements are a weaker evidence area. The following come from broker and adviser sources only and are unverified against any primary instrument as of 21 September 2026: a registered legal address in Anjouan, with no resident director and no local shareholder; an Anjouan international business company, or with approval a foreign company with a local agent; one shareholder and one director, who may be the same person. On server location the sources contradict each other, one requiring servers in Anjouan and others accepting a real-time mirrored environment. No minimum capital requirement was found on any source.

Approval speed is the one point on which friendly and hostile sources agree: two to four weeks in adviser guides, a few days in one advertorial column, all unverified. Critics read that speed as thin due diligence rather than efficiency, and the empty registers in section 07 make that reading hard to dismiss.

Two features matter beyond the headline. The renewal fee equals the issuance fee, so a five-year view is roughly EUR 89,000 in license fees alone, and application fees are non-refundable regardless of outcome. The figures below are the ones an applicant is more likely to meet first, because they sit on the pages of firms that sell the license.

Zero percent gross gaming revenue tax, VAT and corporate income tax is claimed universally, by the regime’s promoters and every adviser we reviewed. We did not find it stated in any primary Anjouan or Comorian tax instrument. Treat it as widely asserted but not primary-sourced as of 21 September 2026: it depends on a legal framework whose existence the national government disputes.

A large share of apparently editorial Anjouan coverage in the trade press is authored by firms that sell offshore licensing services. We verified one instance directly. A widely cited “milestone” article published by Yogonet International on 21 May 2025, reporting 825 active licenses and 2,017 live sites, is a column written by the founder of Fast Offshore, a firm that sells offshore licensing services, and it promotes that firm throughout. The same founder and firm are named in the ABC News investigation of 31 December 2025 as promoters of Anjouan licenses.

We are not suggesting those figures are wrong. We are saying a column by a vendor is not independent reporting of the vendor’s own product, and a due-diligence file should record it as a vendor claim rather than press corroboration. The same caution applies to guides and jurisdiction reviews published by licensing agents and offshore advisers, which are the dominant source of Anjouan content online. On Anjouan, read the byline before you read the article.

Each register carries a table with columns for company, date, license number, type, domains and reason. On 21 September 2026 the Currently Suspended Licenses table held zero entries and the Currently Revoked Licenses table held zero entries. Set that against the issuer’s own claim of more than 1,650 licenses issued and approximately 1,500 active as of 14 July 2026: on the published record there is no named suspension and no named revocation across the history of the regime. The regulator published an enforcement update dated 1 April 2026, but no operator has been named in either register.

Two readings are available. The generous one is that the registers show only currently active measures, so a lifted suspension would not appear. The unfavourable one is that a supervisory function producing no named public outcome across roughly 1,650 licenses is not observably functioning. The registers cannot distinguish between them, because they are empty. What is certain is that anyone running a counterparty check finds no public enforcement history, the opposite of Malta, Great Britain or Ontario.

The complaint side is thinner but consistent. Casino Guru recorded a 90 percent increase in unresolved complaints involving Anjouan-licensed operators during 2024, to 148 cases; we obtained that through search indexing rather than direct retrieval, so we grade it medium confidence. Forum threads at Casino Guru and AskGamblers describe the authority as unresponsive.

As of the most recent FATF plenary cycle reviewed for this page, the Union of the Comoros is not on the grey list of jurisdictions under increased monitoring and not on the call-for-action blacklist, which remains Iran, the Democratic People’s Republic of Korea and Myanmar. A claim circulating in search summaries that the Comoros became subject to a call for action on 13 February 2026 is wrong. Automated verification against fatf-gafi.org was blocked, so confirm any live status line manually.

The Comoros underwent a mutual evaluation dated May 2024, conducted under GIABA. Against the 40 FATF Recommendations, which assess technical compliance, it was rated Compliant on 11 and Largely Compliant on 12. Against the 11 Immediate Outcomes, which assess whether the system works, it was rated Highly Effective on zero and Substantially Effective on zero.

That zero is the meaningful figure: law on paper, no demonstrated effectiveness in applying it. Place it next to section 03, in which the national authorities say the licensing bodies are not lawfully constituted at all, and the conclusion follows: there is no plausible national anti-money-laundering supervision of Anjouan-licensed operators.

The regime’s own stated requirements, from the issuer’s statement of 10 June 2026 and its licensing pages checked 21 September 2026, are due diligence and corporate reviews, AML and KYC checks, fit-and-proper assessment of key persons including ultimate beneficial owners, sanctions and PEP screening, technical and responsible-gambling standards, an RNG test certificate from 2025 and B2B supplier recognition from July 2025, the last two per secondary sources. We have no independent means of testing how they are applied.

The issuer makes the first half of the point itself: its statement of 10 June 2026 says the license is not a universal authorisation and that no licensing authority can exempt an operator from local law. An operator holding only this license must geoblock the United States, the United Kingdom, France, Germany, Spain, the Netherlands, Austria, Australia and the other nationally licensed markets.

Two national positions are on the record. The Gambling Regulatory Authority of Ireland confirmed to the Irish Examiner in March 2026 that offering betting without an Irish license is, in its words, a serious offence, carrying up to eight years’ imprisonment on conviction. ABC News documented on 31 December 2025 that Anjouan-licensed sites were offering products banned under Australian law, including online slots and in-play betting, to Australian customers using local payment methods.

The market repeats claims in both directions and neither is supported. We found no credible evidence that any major game supplier has publicly refused to supply Anjouan-licensed operators, and none that any endorses the license. Claims that named content providers support it appear only on broker and lead-generation sites; no supplier press release, filing or statement confirming supply was located, and no report of a withdrawal either.

The framing this publication uses is therefore: supplier acceptance of Anjouan is asserted by license intermediaries and is not confirmed by any supplier on the record. Operators should obtain written confirmation from each supplier’s compliance team rather than relying on jurisdiction lists published by licensing agents. The one documented flow of control runs the opposite way: from July 2025, per secondary sources, Anjouan requires its licensees to use only B2B suppliers holding an Anjouan B2B license or recognised certificate, with non-compliance after 30 September 2025 stated as grounds for suspension.

Every source on this topic is commercial, and the figures should be read accordingly. Anjouan-licensed entities are classed high risk and the acquirer pool is thin. Rolling reserves of 20 to 35 percent are reported for Anjouan and comparable newer offshore licenses; those figures are commercially sourced and unverified as of 21 September 2026, and should not carry a cash-flow model without a written quote from a named acquirer.

The directional points are firmer than the numbers. Crypto-focused payment providers are materially more accepting than fiat acquirers, and fiat acquiring frequently requires Malta-level or Curacao-level licensing, which is why Anjouan clusters with crypto-first operators. A common workaround is a payment-agent entity in an EU jurisdiction, Cyprus most often, holding the acquirer contracts; treat that as a flag rather than a mitigant.

On first-year license fees Anjouan is roughly one third the cost of post-LOK Curacao and about half the cost of Malta, and several times faster to obtain. Costa Rica is cheaper still, and has the distinction of not claiming to be a regulator at all.

What the saving buys is documentation rather than regulation. Curacao’s higher cost buys a statutory regulator under an ordinance that can be read; Malta’s buys an EU-supervised authority with a published enforcement record and fiat banking on ordinary terms. Anjouan’s EUR 17,828 buys a certificate from a body whose legal existence the Comorian state disputes in public, under an Act whose text is not publicly obtainable, with no named suspension or revocation on its own registers. That is a different product, and the price difference is the size of the legitimacy gap. See the comparison tool and the Curacao and Malta profiles.