Most online casino license delays are not caused by the regulator—they are caused by incomplete evidence packs. The “application” is only the tip of the iceberg. The real work is producing consistent documents that prove who you are, how you operate, and how you control risk.
This casino license application checklist is designed as a practical inventory. Use it to build your internal “application room” so you can respond quickly to regulator queries and avoid rework.
Corporate and ownership documents
- Certificate of incorporation / registration extract
- Articles/bylaws and constitutional documents
- Register of directors and shareholders
- Cap table / share certificates / shareholder agreements
- Group structure chart (holdco, opco, IP, marketing entities)
- UBO disclosures and any nominee arrangements explained
Funding and financial evidence
- Business plan and financial projections
- Bank letters/statements or proof of capitalization
- Source-of-funds/source-of-wealth evidence for UBOs (as required)
- Audited accounts (if available) or management accounts
Key persons and suitability pack
- Passports/IDs and proof of address
- CVs and employment history
- Declarations and fit-and-proper forms
- Police clearances/background checks (where required)
- Role descriptions (CEO, compliance, MLRO, payments, tech)
Compliance policies (must match your platform reality)
- AML risk assessment
- AML policy and procedures
- KYC/CDD/EDD program and verification gates
- Sanctions/PEP screening procedure
- Transaction monitoring approach and escalation
- Suspicious activity reporting workflow
- Responsible gambling policy (limits, self-exclusion, intervention)
- Complaints and dispute resolution policy
- Privacy/data protection and retention policy
Technical and operational evidence
- Platform architecture overview
- Access control model and audit logs
- Change management and release process
- Security controls and incident response plan
- RNG/game fairness certificates (or studio certification packs)
- Geo-blocking strategy and prohibited market controls
- Reporting samples (player history, financial reports, RG reports)
Vendor contracts and oversight
- Game supplier contracts
- PSP/acquirer contracts and settlement flows
- KYC/screening vendor contracts
- Hosting and security vendors
- Affiliate tracking and marketing vendors
- Vendor due diligence and SLAs
Common pitfalls
- Inconsistent ownership story: different versions across documents.
- Policies that don’t match the platform: e.g., policy says “no withdrawals before KYC,” but platform allows it.
- Missing evidence: certifications referenced but not provided, or scope unclear.
- Weak affiliate governance: marketing risk is a top enforcement area.
Bottom line: A complete, consistent evidence pack is the fastest path to licensing. Build the application room early, keep a document register, and ensure product, operations, and policy tell the same story.
