White-Label Gambling Solutions and Licensing in the EU: Turnkey Operator Models, Sub-Licensing Regulations, and Compliance Responsibilities

What Is White-Label Gambling?

White-label gambling represents one of the most common business models for entering European gambling markets without obtaining independent regulatory authorization. In a white-label arrangement, an entity with a gambling license (the "master licensee" or "platform provider") allows another business (the "white-label partner" or "skin operator") to operate a gambling website under the partner's own brand while leveraging the master licensee's licensing, technology infrastructure, and compliance framework.

The terminology can be confusing because "white-label" is used loosely in the industry. In the strictest sense, a white-label partner operates entirely under the master licensee's gambling license with no independent regulatory standing. This distinguishes white-label from B2B licensing arrangements where the technology provider holds a supplier license but the operator still needs their own B2C license.

How White-Label Arrangements Work

A typical white-label gambling arrangement involves the following structure:

• Master Licensee: Holds the gambling license from a regulatory authority (e.g., Malta Gaming Authority). Provides the gambling platform, payment processing integration, game content aggregation, and compliance infrastructure. Bears ultimate regulatory responsibility for all operations conducted under their license.
• White-Label Partner: Operates a branded gambling website without their own license. Handles marketing, customer acquisition, and brand development. May manage certain customer service functions. Pays the master licensee revenue share, setup fees, and ongoing platform fees.
• Players: Access the white-label partner's branded website but are technically customers of the master licensee for regulatory purposes. May not always be aware that the brand they're using operates under another company's license.

The commercial appeal is clear: white-label partners can enter gambling markets with significantly lower capital requirements (no license fees, reduced technical investment) and faster time-to-market. For master licensees, white-label partnerships generate revenue from platform fees and revenue share while leveraging existing infrastructure.

Distinction from Other Business Models

Understanding how white-label differs from related models is essential for regulatory clarity:

The key distinction is that white-label partners do not hold gambling licenses themselves - they operate entirely under the master licensee's regulatory authorization. This creates both opportunities and risks that regulators increasingly seek to address.

Regulatory Framework for White-Label Gambling in the EU

As explained in our guide to how EU gambling laws work, there is no unified European gambling regulation. Each EU member state determines its own licensing requirements, including whether and how white-label arrangements are permitted. The European Commission's gambling policy framework leaves licensing decisions to national authorities, resulting in a patchwork of approaches to white-label regulation.

Malta: The EU's White-Label Hub

Malta is the primary EU jurisdiction for white-label gambling operations. The Malta Gaming Authority (MGA) permits approved white-label partnerships under its B2C licensing framework, making the island the natural base for companies seeking to offer white-label services to the European market.

Key features of Malta's white-label framework include:

• Formal approval requirement: White-label arrangements must be disclosed to and approved by the MGA. The master licensee is responsible for conducting due diligence on potential white-label partners.
• Master licensee accountability: The B2C license holder bears full regulatory responsibility for all white-label operations. Any compliance failures by partners can result in enforcement action against the master license.
• Key function requirements: Certain "key functions" must be performed by the master licensee or approved parties, including AML compliance, responsible gambling, and player funds protection.
• Disclosure obligations: Players must be able to identify the licensed operator (master licensee) responsible for the gambling service, typically through terms and conditions and footer disclosures.

Malta's approach balances market access (allowing white-label entry) with regulatory accountability (holding master licensees responsible). However, the model has faced criticism regarding whether consumer protections are adequately communicated when players may not realize the brand they're using is operated under another company's license.

Germany: No Traditional White-Labels

Germany's gambling regulatory reform under the Interstate Treaty on Gambling (GlüStV 2021) effectively prohibits traditional white-label arrangements. The Gemeinsame Glücksspielbehörde der Länder (GGL) requires each gambling brand to hold its own license. This "one license per brand" approach was designed to ensure clear accountability and prevent diffusion of regulatory responsibility.

For the German market, companies that would otherwise pursue white-label arrangements must instead:

• Obtain their own German gambling license (currently issued for sports betting; virtual slot licenses available separately)
• Meet all licensing requirements including deposit limits (€1,000 per month), OASIS self-exclusion integration, and strict advertising rules
• Accept direct regulatory accountability to the GGL

This approach has significantly increased barriers to entry for smaller operators but arguably provides clearer consumer protection and regulatory oversight compared to white-label models.

Spain: Individual Licensing Required

Spain's gambling regulator, the Dirección General de Ordenación del Juego (DGOJ), requires each gambling brand to hold its own license. Similar to Germany, traditional white-label arrangements where a partner operates under another company's license are not permitted.

Spanish licensing requirements include substantial financial guarantees, technical certification, and ongoing compliance obligations that each operator must fulfill independently. This makes Spain a market where white-label entry is not viable - companies must commit to full licensing.

Italy: White-Labels Prohibited

Italy's gambling regulator, the Agenzia delle Dogane e dei Monopoli (ADM), does not permit white-label gambling arrangements. Each gambling operator must hold their own ADM concession, and the license cannot be extended to cover partner brands operating independently.

The Italian approach reflects a strict interpretation of licensing requirements where the license holder must be the entity directly operating the gambling service. With Italian license costs reaching €7 million for new concessions in 2026, the market has significant barriers to entry that cannot be bypassed through white-label arrangements.

Netherlands: Individual Licensing Model

The Netherlands' gambling market, regulated by the Kansspelautoriteit (KSA) since the Remote Gambling Act took effect in 2021, follows an individual licensing model. Each gambling brand must obtain its own Dutch license, and white-label arrangements where one license covers multiple independent brands are not permitted.

Dutch licensing requirements include integration with the CRUKS self-exclusion register, strict advertising restrictions, and substantial compliance obligations that each operator must fulfill directly.

Other EU Jurisdictions

The regulatory approach to white-label gambling varies across other EU member states:

Compliance Responsibilities in White-Label Arrangements

One of the most critical aspects of white-label gambling is understanding how compliance responsibilities are allocated between master licensees and white-label partners. Regardless of commercial agreements, regulators typically hold the license holder ultimately responsible for all operations conducted under their authorization.

Master Licensee Obligations

The master licensee bears primary regulatory responsibility including:

• Licensing compliance: Maintaining the gambling license in good standing and ensuring all operations (including white-label brands) comply with license conditions
• AML compliance: Implementing anti-money laundering controls across all brands as required by the EU Anti-Money Laundering Directives and national legislation. See our AML compliance guide for detailed requirements
• Responsible gambling: Ensuring responsible gambling measures are implemented across all brands, including deposit limits, self-exclusion, and player protection tools
• Player funds protection: Safeguarding player funds and ensuring they are segregated and protected in case of insolvency
• Technical standards: Maintaining platform security, RNG certification, and game fairness across all operations
• Reporting: Submitting regulatory reports covering all operations, including white-label brand activity

White-Label Partner Responsibilities

While the master licensee bears ultimate regulatory responsibility, white-label partners typically have contractual obligations including:

• Marketing compliance: Ensuring advertising and promotional materials comply with applicable regulations (though the master licensee remains responsible to the regulator)
• Customer service: Handling customer inquiries while escalating regulatory matters to the master licensee
• Brand management: Operating the brand in accordance with agreed standards and not engaging in activities that could jeopardize the master license
• Data provision: Supplying customer and transaction data needed for the master licensee's compliance reporting
• Cooperation: Cooperating with regulatory inquiries and audits as required

The Accountability Gap

A fundamental tension in white-label gambling is the "accountability gap" - the master licensee is legally responsible for compliance, but may have limited practical control over the white-label partner's day-to-day operations. This creates risks for both parties:

For master licensees: White-label partners' marketing misconduct, inadequate customer service, or compliance failures can result in regulatory action against the master license. Even if the master licensee wasn't directly at fault, they may face fines, license conditions, or revocation.

For white-label partners: If the master licensee's license is suspended or revoked (whether due to the partner's actions or unrelated issues), the white-label partner loses their ability to operate entirely. They have no independent standing with the regulator and may face significant business disruption.

Regulators are increasingly alert to these risks. The trend toward requiring individual licensing per brand (as in Germany, Spain, Italy) reflects a regulatory preference for clear, direct accountability rather than the layered responsibility of white-label models.

Due Diligence for White-Label Arrangements

For businesses considering white-label gambling partnerships, thorough due diligence is essential. Both master licensees evaluating potential partners and white-label partners evaluating potential licensees should conduct comprehensive assessments.

Due Diligence on Master Licensees

White-label partners should evaluate potential master licensees on:

• License standing: Verify the license is current and in good standing with no pending enforcement actions or conditions
• Regulatory history: Review any past enforcement actions, fines, or warnings against the licensee
• Jurisdiction coverage: Confirm which markets the license actually permits access to (a Malta license doesn't authorize operation in Germany, for example)
• Financial stability: Assess the licensee's financial position and ability to maintain operations and player fund protection
• Technical capability: Evaluate platform reliability, security, and game content quality
• Compliance infrastructure: Review AML, responsible gambling, and player protection systems
• Other white-label partners: Understand the licensee's existing partner portfolio and any reputation risks
• Contractual terms: Review exit provisions, liability allocation, and dispute resolution mechanisms

Due Diligence on White-Label Partners

Master licensees should evaluate potential white-label partners on:

• Beneficial ownership: Identify ultimate beneficial owners and assess any regulatory or reputational risks
• Marketing history: Review past marketing practices for compliance with advertising standards
• Business model: Understand target markets, acquisition strategies, and customer demographics
• Financial capacity: Assess ability to fund operations, marketing, and any required deposits
• Management experience: Evaluate management team's gambling industry experience and compliance awareness
• Geographic focus: Confirm target markets align with license permissions and don't create regulatory exposure

Commercial Considerations

White-label gambling arrangements involve significant commercial negotiation. Understanding typical terms helps both parties structure fair agreements.

Typical Fee Structures

Revenue share models vary significantly based on scale, exclusivity, and the services included. Some arrangements offer lower revenue share but higher fixed fees, while others prioritize revenue share with minimal fixed costs.

Key Contract Terms

Important contractual provisions in white-label agreements include:

• Territory restrictions: Which geographic markets the white-label partner may target
• Exclusivity: Whether the partner may operate other gambling brands or use competing platforms
• Marketing approval: What marketing materials require master licensee approval
• Compliance cooperation: How compliance responsibilities are allocated and enforced
• Player data: Who owns player data and what happens to it on termination
• Exit provisions: Notice periods, player transition, and brand rights on termination
• Liability caps: Limits on liability for regulatory fines or player claims
• Indemnification: Cross-indemnities for losses caused by the other party's breach

Regulatory Trends and Future Outlook

The regulatory environment for white-label gambling is evolving. Several trends suggest tighter oversight ahead.

Increasing Scrutiny of Accountability

Regulators are increasingly focused on ensuring clear accountability for gambling operations. The German and Spanish approach requiring individual licensing per brand reflects a preference for direct regulatory relationships over the layered accountability of white-label models. Other jurisdictions may follow this trend.

Consumer Protection Concerns

Consumer advocacy groups have raised concerns about player awareness in white-label arrangements. When players sign up with a branded casino site, they may not realize that another company holds the license and is ultimately responsible for their funds and complaints. Regulators may require more prominent disclosure of master licensee identity.

AML and Source of Funds

Anti-money laundering requirements are becoming more stringent under the EU's evolving FATF-aligned framework. White-label arrangements can create complexity in AML compliance, as customer due diligence and suspicious activity reporting involve both the white-label partner (who may have customer contact) and the master licensee (who bears regulatory responsibility). Regulators may require clearer AML role allocation in white-label agreements.

Cross-Border Enforcement

As EU member states strengthen enforcement against unlicensed gambling, the question of whether white-label operations are properly licensed for specific markets becomes more acute. A Malta-licensed white-label targeting German players operates in a gray zone - technically the brand has no German license. German regulators have pursued payment blocking and other measures against unlicensed operators, potentially affecting white-label arrangements targeting German players.

Alternatives to White-Label

For businesses seeking to enter EU gambling markets without full independent licensing, alternatives to traditional white-label include:

B2B Platform Licensing

Rather than operating under another company's B2C license, some businesses obtain their own B2C license and use B2B platform providers for technology. This requires greater regulatory engagement but provides direct accountability and more control. Our B2B licensing guide covers platform provider regulations.

Affiliate Marketing

Affiliate marketing allows businesses to earn revenue from gambling without operating gambling services themselves. Affiliates refer players to licensed operators and earn commission on player activity. While affiliate marketing faces its own regulations, it involves lower regulatory risk than white-label operation.

Acquisition of Licensed Operators

Acquiring an existing licensed operator provides immediate market access with established regulatory standing. While capital-intensive, this approach avoids the dependency risks of white-label arrangements.

Direct Licensing

For businesses committed to EU gambling markets, obtaining direct licenses - even if multiple licenses are needed for different countries - provides the clearest regulatory standing. Our license cost estimator helps assess the financial requirements.

Conclusion

White-label gambling solutions offer a pathway to European gambling markets without independent licensing, but they come with significant regulatory complexity and risk. The arrangement works well in jurisdictions like Malta that formally accommodate white-label models with clear accountability frameworks. However, the trend toward requiring individual licensing per brand (Germany, Spain, Italy) suggests that traditional white-label arrangements may face increasing restrictions.

For businesses considering white-label gambling, thorough due diligence on the master licensee, clear contractual allocation of responsibilities, and understanding of the regulatory limitations in target markets are essential. As EU gambling regulation continues to evolve toward greater consumer protection and clearer accountability, the viability of white-label models in specific markets may change.

Related Resources

• B2B Gambling Licensing in the EU - Software supplier and platform provider regulations
• EU Gambling License Cost Estimator - Compare licensing costs across jurisdictions
• Affiliate Marketing Rules for Gambling in the EU - An alternative market entry model
• AML Compliance Requirements in EU Gambling - Anti-money laundering obligations for operators
• EU Gambling Compliance Risk Assessor - Assess regulatory risk across EU markets
• License Revocation and Enforcement Actions - Understanding regulatory enforcement risks

Last Updated: January 2026