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Fees, documents and conditions checked against published sources on 15 October 2026. Produced in partnership with MGL Solutions, a licensing adviser.
An Anjouan gaming licence is an internet gaming licence with two categories: B2C for operators and B2B for suppliers. Its issuer, Anjouan Gaming, says it grants these licences under the laws of the Autonomous Island of Anjouan. The Central Bank of the Comoros rejects that authority, so read who issues the licence before you pay. The licence fits a project only when four conditions hold. Your role matches the category. Your target markets let you serve players on this licence. Your payment providers and game suppliers accept it. And the full first-year budget works, beyond the issuer’s fee.
Licensing and launch are separate projects. Licensing ends when the licence is issued. Launch depends on others: payment partners, platform and content suppliers, approved domains and controls that work on the live site.
The licence lets one named company offer internet gaming in one category, B2C or B2B, on domains approved for it. Activity on unapproved domains is prohibited under the published licence conditions.
The International Cooperation page names the Anjouan Offshore Financial Authority (AOFA) as the competent authority. It names Anjouan Licensing Services Inc. (ALSI) as licence administrator, and register numbers carry the ALSI prefix. The current conditions, forms and invoices come from ANJ Management Ltd. The site does not explain how ALSI and ANJ Management relate, so check who signs your licence and your invoice.
That authority is disputed. The issuer relies on the 2001 Constitution of the Comoros, Anjouan acts from 2005 and a legal opinion from a law firm it does not name. In a communiqué of 8 December 2025 the Central Bank of the Comoros says AOFA is not recognised in the Union. It adds that no online gaming licence has been issued and that any claim to operate under a Comorian approval it did not grant is fraudulent. No court has ruled yet.
Keep five items apart:
Pass three filters before you pay any fee. First, the law of each target market lets you serve its players on this licence. Second, your main payment service providers (PSPs) and suppliers confirm in writing that they accept an Anjouan licensee in your model. Third, owners and directors can pass due diligence on ownership and source of funds. If one filter fails, fix it before anything else.
| Scenario | What to verify | Reason to reconsider | Next step |
| New B2C operator | No local licence needed in player countries; main PSP accepts Anjouan | Core market is excluded or requires its own licence | Get a market legal check and a written PSP pre-assessment |
| Existing operator migrating | Player countries, supplier status, domain transfer approval | Many players in excluded or locally licensed markets | Map traffic by country and suppliers by status |
| Game or platform supplier | Whether clients need you to hold an Anjouan B2B licence or recognition | Clients mostly sit in markets that license suppliers locally | Ask target clients which status they require |
| White-label model | Which company contracts with players and holds the domain approval | The plan relies on trading under the provider’s licence | Decide whether the brand owner will hold its own B2C licence |
| Operator needing a specific regulated market | Whether that market accepts offshore-licensed operators | The market requires its own licence | Apply for the local licence; Anjouan does not replace it |
Each benefit below holds only under a condition you need to check first.
| Potential benefit | When it matters | What to verify |
| Several verticals under one B2C licence (the form lists casino, sportsbook, poker, bingo, horse racing) | Multi-vertical operators | Each product is declared and approved |
| A published fee schedule | Limited budgets | The full first-year cost |
| A published due diligence estimate | Fixed launch plans | Your file is complete; the figure is an estimate only |
| Remote processing | Founders abroad | Whether your company’s jurisdiction is accepted |
Anjouan Gaming publishes two licence categories. B2C covers operators that offer gaming directly to consumers. B2B covers critical service suppliers of platform, software or technical services. The application guidance is explicit: a B2C licence does not automatically authorise supplying platforms or content to unrelated operators.
| Business role | Activity | Licence route to verify | Evidence needed |
| Operator | Takes deposits and bets on its own domains | B2C | Approved domains, player terms naming the licensee, alternative dispute resolution (ADR) provider |
| Platform or game supplier | Supplies Anjouan licensees | B2B licence, or recognition if licensed elsewhere | Existing licences, testing where required, contracts |
| Company doing both | Runs own brands and supplies others | Confirm whether both categories are needed | Each activity described separately in the application |
| Affiliate or PSP | Marketing or payments | Not addressed by these categories; confirm case by case | The licensee’s due diligence on the provider |
The licence conditions require an operator’s platform and content suppliers to hold an Anjouan B2B licence or a recognition certificate. Recognition holders sit on a separate Recognition Letter Register. The criteria for recognition are not published. Get the issuer’s written confirmation of what a letter covers before you treat it as a B2B licence.
For white-label set-ups, settle three questions before you file: which company takes player funds, which signs the player terms and which answers for compliance. The Anjouan Code of Conduct prohibits sublicensing. In July 2026 a B2C licence was revoked with the published reason “Illegal sublicensing”.
An Anjouan licence opens no country by itself. Run three checks: the Anjouan licence conditions, the law of each player’s country, and the rules of each payment provider, bank and content supplier. A country missing from the Anjouan exclusion list is not proof that you may operate there.
The October 2026 licence conditions (version 5) exclude, on a non-exhaustive basis, Australia, Austria, the Comoros, France, Germany, the Netherlands, Spain, the United Kingdom and the United States, plus sanctioned jurisdictions, countries under a Financial Action Task Force (FATF) call for action and any jurisdiction AOFA designates. The same document says absence from the list does not make gaming there lawful. It also says effective GEO-IP blocking (blocking by IP location) should be implemented. The International Cooperation page still says Anjouan licences “do not contain territorial restrictions under Anjouan law”. The conditions you sign are what bind you. Check them again at each renewal.
Great Britain shows why the local check comes first. The Gambling Commission says a business needs its licence to provide remote gambling to consumers in Great Britain, even when the business is based abroad.
A working sequence:
1. List target countries and products.
2. Check each country’s local licensing rules with qualified local counsel. The licence conditions expect legal opinions where necessary.
3. Compare the list against the current Anjouan excluded territories and any AOFA designations.
4. Check PSP, bank and supplier contracts for their own country restrictions.
5. Configure GEO-IP blocking and registration country checks, then record test results and monitor traffic.
The issuer’s fee is €17,828 for issuance and €17,828 for each annual renewal, for both B2C and B2B. That is the Anjouan Gaming fee schedule as checked on 15 October 2026. Each extra domain under a B2C licence costs €500 per licensing cycle. These are issuer fees only.
The page says application fees are non-refundable and must accompany the submission, but gives no separate application fee. It does not say how many domains the base fee includes either. Ask both questions before you pay.
Every project pays the issuance fee and funds one company, a compliance function and an ADR provider. Extra domains, technical testing and crypto controls depend on the model. Incorporation, corporate maintenance and policy preparation may sit inside an adviser package, so check the breakdown.
| Cost item | Initial or recurring | Amount or quote basis | Included scope | Source and date |
| Licence issuance | Initial | €17,828 | One B2C or B2B licence; domain allowance not stated | Fee schedule, 15 Oct 2026 |
| Annual renewal | Recurring, from the next licence period | €17,828 | Renewal of the same category | Fee schedule, 15 Oct 2026 |
| Additional domain (B2C) | Per licensing cycle | €500 each | One extra domain | Fee schedule, 15 Oct 2026 |
| Administrative changes | When requested | Quoted on request | Domain changes, amendments, replacement certificates | Fee schedule, 15 Oct 2026 |
| Company incorporation | Initial | Formation agent quote | One entity, in Anjouan or another accepted jurisdiction | Application guidance, Oct 2026 |
| Corporate maintenance | Annual | Provider quote | Registered office, agent, government fees | Provider quote |
| Advisory and application preparation | Initial | Adviser quote | Scope agreed in writing | Adviser proposal |
| Compliance function | Initial and recurring | Quote or internal cost | Compliance Officer, money laundering reporting officer (MLRO), policies | Licence conditions v5, Oct 2026 |
| ADR provider | Recurring | Provider quote | ADR participation at the licensee’s cost | Licence conditions v5, Oct 2026 |
| Technical testing | Where required | Test lab quote | GLI-19 or GLI-33 where the product requires it | Application guidance, Oct 2026 |
| Operational launch | Initial | Own budget | Platform, identity verification (KYC) tools, market legal opinions | Operator estimate |
For year one, add the issuance fee, any extra fees, one company and its upkeep, preparation and checks, and the services you choose. Renewal belongs to the next licence period, so list it separately. Ask any package provider for an itemised breakdown that shows whether the issuer fee, extra domains and due diligence or key person checks are included. Without it, an all-in figure is a guess.
An Anjouan application needs corporate records, personal records for directors, owners and key persons, financial evidence, operational policies and technical evidence. The Required Documents page lists the first three groups; the October 2026 application guidance on the Forms & Downloads page adds the rest.
| Document or requirement | Who supplies it | Purpose and basis | What to check before submission |
| Certificate of incorporation, articles, shareholder and director registers | Formation agent | Applicant identity and control (required) | Certified copies, current at submission |
| Ownership chart to the ultimate beneficial owners (UBOs) | Founders, lawyer | Beneficial ownership review (required) | Every layer to individuals; nominees, trusts and foundations disclosed |
| ID, recent address evidence, police clearance, CV | Each director, UBO and key person | Personal suitability (ID and address required; police clearance and CV per guidance) | Certification and translation where requested |
| Personal Information Form and UBO Declaration | Each relevant individual | Politically exposed person (PEP), sanctions and source of wealth declarations (required) | Current form versions |
| Source of funds, bank references, financial statements | Owners, finance lead | Financial standing (required; documents per guidance) | Documents trace the actual funds |
| Business plan with three-year projections | Management | Viability and target markets (guidance) | Markets fit licence restrictions |
| Anti-money laundering (AML/CFT) policies, risk assessment, sanctions and PEP procedures | Compliance Officer or MLRO | AML readiness (guidance) | Match the current KYC and AML Code |
| Terms, responsible gaming, complaints and ADR arrangements | Compliance, legal | Player protection (guidance) | ADR provider named in player terms |
| Platform architecture, hosting, game list, testing, supplier contracts | CTO, suppliers | Technical assessment (guidance) | Suppliers hold a B2B licence or recognition |
Required means the Required Documents page lists the group as required. Guidance means the October 2026 application guidance asks for the item “as required by the current checklist”. GLI-19 or GLI-33 testing applies only where the product requires it. The issuer may ask for more during review.
The pages reviewed set no validity period for address evidence, no minimum share capital and no local company requirement. Ownership changes carry two deadlines. AOFA must hear of a change of 10% or more within 10 business days. The UBO Declaration also commits the signatory to tell ANJ Management Ltd. of any ownership or control change within 14 days. AOFA may ask any beneficial owner for source of wealth evidence, whatever the stake. Check certification, apostille, translation and hosting rules against the current forms.
The Application Process page sets out four formal stages: submission, review for completeness, regulatory due diligence and licence issuance. The October 2026 application guidance estimates about six weeks on average for due diligence and assessment, from receipt of a complete application and payment until the assessment ends. It gives no time for the decision that follows. The guidance calls the six weeks an estimate, not a guarantee. Preparation before submission and launch checks after issuance come on top.
| Stage | Applicant input | Adviser or issuer action | Completion evidence | Possible delay |
| 1. Fit assessment (planning step) | Model, markets, PSP list | Adviser reviews fit | Written notes on open issues | Unconfirmed market or PSP |
| 2. Structure confirmation | Ownership chart, entity choice | Formation agent incorporates | Certificate of incorporation | Unclear ownership |
| 3. Document collection | Corporate, personal, financial, technical files | Adviser checks consistency | Complete indexed file | Missing certifications |
| 4. Submission and payment | Forms and fees | Issuer screens for completeness | Proof of payment, acknowledgement | Incomplete files are not processed |
| 5. Review and due diligence | Answers to queries | Issuer reviews structure, people, funds, sanctions, technology | Queries closed | Adverse findings |
| 6. Decision and issuance | Signed licence conditions | Issuer decides | Licence and register entry | Conditions to meet |
| 7. Launch readiness (planning step) | Live controls | Operator tests | Approved domains, validator, test records | Supplier or PSP not ready |
Stages 4 to 6 are the issuer’s process; the rest is project work. Complex structures, missing documents or adverse findings can extend the estimate. Three example dependencies (illustrations, with no claim about frequency):
A licence on paper is not a working business. Issuance does not make payment providers, the platform or suppliers ready.
Obligations start on the day of issuance. The licence conditions require approved domains only and the unmodified interactive seal in every site footer. They also require a Key Person, a Compliance Officer, AML controls, an approved ADR provider named in the player terms and notice of ownership changes. Renewal is not automatic, the guidance adds.
Published deadlines:
The licence conditions call the KYC and AML Code of 13 October 2026 in effect, but the Code and the guidance say it applies from a date set by AOFA notice. Confirm in writing which edition governs your launch.
The matrix below is a working tool; the binding rules sit in the licence conditions and the Code.
| Area | Practical check | Evidence of readiness | Owner |
| Player onboarding | Run registration and identity verification end to end | Test results, recorded decision | Product, compliance |
| Markets | Test access blocking for excluded and restricted countries | Market matrix and test results | Compliance, engineering |
| Payments | Run the agreed deposit and withdrawal flow | Partner acceptance, tests, error handling | Payments, operations |
| Games | Match products and suppliers to approvals and certificates | List of approved content and documents | Platform, compliance |
| Player protection | Test limits and self-exclusion in practice | Proof that controls work | Product, compliance |
| Records and changes | Extract required data and run the change process | Sample export, log, obligations calendar | Operations, compliance |
For crypto, check custody, blockchain tracing, sanctions screening and high-risk transaction handling.
Before go-live, confirm three things separately: the domains are approved, the validator shows the correct status and no dependency is still open.
Verify in the issuer’s public register, not by the seal image. The Verify a Licence page accepts a licence number, company name or operational domain and returns the registered name, licence number, licence type and current status.
1. Open the register directly on the issuer’s site, anjouangaming.com.
2. Search by licence number, legal name or domain.
3. Match the registered name, number, category and status to the company you contract with.
4. Confirm the domain you are checking is linked to that record and the site seal is the interactive validator for it. If the register shows no licence period, ask the operator for the certificate.
5. Check the published suspended and revoked licence lists.
6. If anything differs, ask the operator and the issuer in writing.
The issuer says verification confirms whether an entity holds a licence and its current status, is not an endorsement and uses periodically updated data. The register is the issuer’s own record. A valid entry does not show that the operator may serve a given market, that a PSP accepts it, or that its service is sound.
Consider another route when a core requirement of your project cannot be met under Anjouan, whatever the fee.
| Criterion | Consider another route when |
| Target market | Most revenue would come from an excluded market or one requiring its own licence |
| Partner acceptance | A PSP, bank or game supplier you depend on declines Anjouan licensees for your model |
| Structure and presence | Investors or partners require a gambling licence from a regulator with local supervision or substance rules |
| Total cost | Multi-year cost, renewals included, compares poorly with a route that opens your markets |
| Operational duties | Your team cannot run the required AML reporting and controls |
Compare like with like: the same B2C or B2B scope, the same period and the same included services. A full fee and timeline comparison across jurisdictions is outside this guide, so check each alternative against its own dated primary sources.
Once your model and target markets are settled, the remaining work is the corporate structure, the documents and the submission. MGL Solutions is a licensing adviser that offers Anjouan support for these tasks. It advises and does not issue licences. Depending on the package, its published scope includes:
Operators who want help with company formation, application documents and licensing coordination can review Anjouan licensing support from MGL Solutions. Before engaging any adviser, ask for a proposal listing the application package, the policies to be prepared, the support stages and an itemised cost breakdown.
Before requesting support, prepare a one-page brief covering:
Then ask for a project assessment and an itemised quote. It should show what is included, what is excluded and which dependencies stay with you or with third parties, such as banks, payment providers and game suppliers.
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