Gambling License Duration and Renewal Requirements in the EU

Why License Duration and Renewal Matters

Gambling licenses are not permanent authorizations. Every EU jurisdiction issues licenses for fixed validity periods, after which operators must successfully renew or lose their right to offer gambling services. Understanding license lifecycles is critical for business continuity planning, regulatory compliance, and avoiding the operational disaster of an expired license.

For operators holding multiple EU licenses, managing different renewal timelines across jurisdictions becomes a significant compliance challenge. Missing a renewal deadline doesn't just mean paperwork delays—it can force immediate market exit, strand player funds, trigger regulatory enforcement, and permanently damage operator reputation.

According to the European Gaming and Betting Association (EGBA), the European online gambling market includes over 800 licensed operators across various jurisdictions, each managing their own license renewal calendars. The complexity of multi-jurisdictional compliance makes systematic license management essential.

License Validity Periods Across the EU

License duration varies significantly between EU member states, reflecting different regulatory philosophies about how frequently operators should demonstrate ongoing compliance. Some jurisdictions favor longer validity periods to reduce administrative burden, while others prefer shorter terms that enable more frequent regulatory review.

Long-Term Licenses (7-10+ Years)

Several established gambling jurisdictions issue licenses with extended validity periods:

• Malta (MGA): 10-year validity for both B2C and B2B licenses, making it one of the longest standard license terms in Europe. The Malta Gaming Authority compensates for long validity periods through rigorous ongoing compliance monitoring, annual reporting requirements, and the power to suspend or revoke licenses at any time for cause.
• Gibraltar: Licenses typically issued for 5-10 year periods, though the jurisdiction is outside the EU post-Brexit and operates under its own framework.
• Isle of Man: Similar to Malta with extended validity periods, though also outside EU regulatory frameworks.

Medium-Term Licenses (5-7 Years)

The most common validity period across EU member states falls in the 5-7 year range:

• Spain: The Dirección General de Ordenación del Juego (DGOJ) issues online gambling licenses for 10-year periods, with general licenses covering the full term. Singular licenses for specific game types may have 5-year validity.
• Italy: The Agenzia delle Dogane e dei Monopoli (ADM) issues online gambling concessions typically for 9-year periods, though specific product licenses may vary.
• Denmark: Online gambling licenses from the Danish Gambling Authority (Spillemyndigheden) are valid for 5 years with the possibility of renewal.
• Portugal: The SRIJ (Serviço de Regulação e Inspeção de Jogos) issues online gambling licenses for 3-year initial periods, renewable for additional 3-year terms.

Short-Term Licenses (1-5 Years)

Some jurisdictions prefer shorter license terms that require more frequent renewal:

• Germany: Under the Interstate Treaty on Gambling (GlüStV 2021), the GGL (Gemeinsame Glücksspielbehörde der Länder) issues online gambling licenses for fixed terms, typically 5-7 years. The relatively new regulatory framework means renewal procedures are still being established as the first cohort of licenses approaches expiration.
• Netherlands: The Kansspelautoriteit (KSA) issues online gambling licenses for 5-year periods under the Remote Gambling Act (KOA). With the market opening in October 2021, first renewals will occur from 2026.
• Belgium: The Belgian Gaming Commission issues online gambling licenses for renewable periods, with F1+ licenses (online casino) typically valid for 5 years.
• Sweden: Spelinspektionen issues online gambling licenses for 5-year periods, with renewal applications required well in advance of expiration.

Comparative License Duration Table

The License Renewal Process

While specific procedures vary by jurisdiction, most EU gambling license renewals follow a similar framework with common documentation requirements and evaluation criteria.

Step 1: Pre-Renewal Compliance Audit

Before initiating formal renewal, operators should conduct internal compliance audits to identify and remediate any issues that could jeopardize renewal approval. Key areas include:

• Regulatory Compliance History: Review of any violations, warnings, or sanctions received during the license period
• AML/KYC Performance: Assessment of anti-money laundering compliance and customer due diligence procedures
• Responsible Gambling Implementation: Verification that all responsible gambling requirements are properly implemented
• Technical Standards: Confirmation that software testing and certification remains current
• Financial Stability: Review of financial health and player fund protection arrangements

Step 2: Documentation Preparation

Renewal applications typically require comprehensive documentation demonstrating ongoing fitness to hold a license:

• Corporate Documents: Updated certificates of incorporation, shareholder registers, beneficial ownership declarations
• Financial Statements: Audited accounts for the license period, evidence of financial stability, player fund segregation proof
• Key Personnel: Updated declarations for key persons and management, any changes since initial licensing
• Compliance Reports: Summary of compliance audit results, remediation actions taken, ongoing monitoring systems
• Technical Documentation: Current game certifications, RNG test reports, security audit results
• Business Plan: Updated operational plans, market projections, and strategic direction

Step 3: Renewal Application Submission

Submit the formal renewal application well in advance of license expiration. Most jurisdictions require 3-12 months lead time:

• Malta (MGA): Renewal applications should be submitted 6-12 months before expiration to ensure processing time
• Germany (GGL): Minimum 6 months advance notice required
• Netherlands (KSA): Applications recommended 6 months before expiration
• Portugal (SRIJ): 3 months minimum, though earlier submission recommended

Step 4: Regulatory Review and Due Diligence

Regulators conduct renewed due diligence during the application review period, which may include:

• Background checks on any new beneficial owners or key personnel
• Review of compliance history and any regulatory actions taken during the license period
• Assessment of financial stability and player protection measures
• Evaluation of responsible gambling program effectiveness
• Technical review of gaming systems and security measures

Step 5: Conditional Approval and Fee Payment

Upon satisfactory review, regulators typically issue conditional approval subject to payment of renewal fees. Fee structures vary:

• Flat Renewal Fee: Fixed amount regardless of operator size (common in smaller jurisdictions)
• Tiered Fees: Amount based on operator category, revenue, or license type
• Annual License Fees: Some jurisdictions charge annual fees throughout the license period rather than separate renewal fees

Malta Gaming Authority: Renewal Deep Dive

As one of Europe's most significant gambling jurisdictions, MGA renewal procedures merit detailed examination. The Malta Gaming Authority's approach balances long license terms with rigorous ongoing compliance requirements.

MGA License Duration

MGA licenses are valid for 10 years from issue date. This extended validity reflects Malta's philosophy of establishing long-term regulatory relationships with operators while maintaining continuous oversight through:

• Mandatory annual compliance submissions
• Regular compliance audits (scheduled and unannounced)
• Continuous monitoring of player complaints and operator conduct
• Power to suspend or revoke at any time for cause

MGA Renewal Requirements

According to MGA guidance, license renewal requires:

• Submission of renewal application at least 6 months before expiration (12 months recommended)
• Updated fit and proper documentation for all beneficial owners and key persons
• Current financial statements demonstrating continued solvency
• Evidence of player fund protection through segregated accounts or equivalent guarantees
• Updated responsible gambling policies and implementation evidence
• Payment of applicable renewal fees (approximately EUR 25,000 for B2C licenses)

MGA Renewal Considerations

The MGA considers several factors when evaluating renewal applications:

• Compliance history during the license period—operators with clean records face smoother renewals
• Resolution of any outstanding compliance matters, player complaints, or enforcement actions
• Changes in beneficial ownership requiring new fit and proper assessments
• Financial stability and ability to meet ongoing regulatory obligations
• Technical compliance with current gaming standards and responsible gambling requirements

Germany: GGL License Renewal Framework

Germany's regulated online gambling market under the GlüStV 2021 is relatively new, with the GGL (Gemeinsame Glücksspielbehörde der Länder) issuing the first federal licenses from late 2021. As the market matures, renewal procedures are being established.

German License Validity

GGL licenses for online sports betting and virtual slot machines are issued for fixed terms, typically 5-7 years depending on license type and conditions. The first major renewal cycle will occur from approximately 2026-2028.

Anticipated German Renewal Requirements

Based on the regulatory framework and GGL guidance, German license renewals will likely require:

• Demonstrated compliance with GlüStV requirements throughout the license period
• Integration with OASIS (national self-exclusion system) and LUGAS (deposit limit system)
• Compliance with strict advertising restrictions and responsible gambling measures
• Technical compliance including €1 stake limits, 5-second spin times for slots, and autoplay bans
• Clean regulatory record with no significant enforcement actions

German Enforcement Context

The GGL has demonstrated willingness to take enforcement actions against non-compliant operators. Operators seeking renewal should ensure full compliance well before their renewal window opens, as ongoing violations could jeopardize renewal approval. See our coverage of gambling operator fines and sanctions for context on German enforcement trends.

Spain: DGOJ Renewal Procedures

Spain's online gambling market, regulated by the DGOJ, features one of the longer license validity periods in Europe at 10 years for general licenses.

Spanish License Structure

The Spanish system includes:

• General License: 10-year validity, covers the operator's overall authorization to provide gambling services
• Singular Licenses: Required for specific game types, may have shorter validity periods

DGOJ Renewal Requirements

Spanish license renewal requires demonstrating continued compliance with Royal Decree 1614/2011 and subsequent regulatory amendments:

• Updated corporate and beneficial ownership documentation
• Evidence of compliance with advertising restrictions (among the strictest in Europe)
• Responsible gambling program documentation including RGIAJ self-exclusion system integration
• Technical compliance certification for gaming systems
• Financial statements demonstrating operational viability

Renewal Challenges and Common Issues

License renewal is not guaranteed, and operators face several common challenges that can complicate or derail the renewal process.

Compliance History Problems

Operators with enforcement actions, sanctions, or unresolved compliance issues face increased scrutiny during renewal. Regulators may:

• Require remediation of all outstanding issues before processing renewal
• Impose additional conditions on renewed licenses
• Reduce license scope or add restrictions
• In severe cases, refuse renewal entirely

Ownership Changes

Changes in beneficial ownership during the license period can complicate renewal. New owners must pass fit and proper assessments, and any unapproved ownership changes could result in license issues. See our guide to gambling license transfer and acquisition for managing ownership changes properly.

Financial Difficulties

Regulators closely examine financial stability during renewal. Operators showing signs of distress, inadequate player fund protection, or inability to meet ongoing obligations may face enhanced scrutiny or renewal denial. The player fund protection framework is particularly critical.

Regulatory Changes

Gambling regulations evolve during license periods. Renewal may require compliance with new requirements that didn't exist at initial licensing, such as:

• New responsible gambling tools and player protection measures
• Enhanced AML/KYC requirements under updated EU directives
• Technical standards changes (e.g., new pace of play requirements)
• Additional advertising restrictions or direct marketing consent requirements

Multi-Jurisdictional License Management

Operators holding licenses across multiple EU jurisdictions face particular challenges managing different renewal timelines, requirements, and fee schedules.

Centralized License Calendar

Best practice involves maintaining a centralized calendar tracking:

• License expiration dates for all jurisdictions
• Renewal application deadlines (accounting for required lead times)
• Annual reporting deadlines
• Fee payment schedules
• Compliance audit schedules

Resource Planning

License renewals require significant resources. Operators should plan for:

• Internal compliance team time for documentation preparation
• External legal counsel for complex jurisdictions
• Auditor fees for financial statement preparation
• Technical compliance testing and certification costs
• Renewal fees themselves, which can be substantial

Use the License Cost Estimator

Our EU Gambling License Cost Estimator tool can help operators project both initial and ongoing licensing costs across multiple EU jurisdictions, including renewal fees where data is available.

What Happens If Renewal Fails?

If a license expires without successful renewal, the consequences are severe:

• Immediate Cessation: Operators must stop all gambling activities in that jurisdiction immediately upon expiration
• Player Protection: Remaining player balances must be returned promptly according to regulatory requirements
• Potential Penalties: Operating after expiration constitutes unlicensed gambling, subject to significant fines and potentially criminal sanctions
• Reputation Damage: Market exit damages operator reputation and may affect licensing in other jurisdictions
• Re-Application: Operators may need to apply as new licensees, facing full application fees and extended processing times

Grace Periods and Provisional Continuation

Some jurisdictions allow provisional continuation of operations while renewal applications are pending, provided:

• The renewal application was submitted on time (before the deadline)
• The operator remains in good standing with no outstanding compliance issues
• All required fees are current

However, this varies by jurisdiction and is not guaranteed. Operators should never rely on grace periods as a fallback—timely renewal remains essential.

Best Practices for License Renewal

Start Early

Begin renewal preparation 12-18 months before expiration, even if formal applications aren't due until later. Early preparation allows time to:

• Identify and resolve compliance issues
• Gather required documentation
• Address any changes in beneficial ownership or key personnel
• Budget for renewal fees and associated costs

Maintain Continuous Compliance

The best renewal preparation is continuous compliance throughout the license period. Operators should:

• Keep documentation current at all times, not just for renewal
• Address compliance issues immediately when identified
• Stay current with regulatory changes and implement new requirements promptly
• Maintain open communication with regulators

Engage Specialists

Consider engaging specialized legal counsel and compliance consultants for complex jurisdictions or where compliance history presents challenges. Expert guidance can help navigate tricky situations and maximize renewal success likelihood.

Document Everything

Maintain comprehensive records of all compliance activities, training, audits, and regulatory interactions throughout the license period. This documentation becomes valuable evidence supporting renewal applications.