In the gambling business the aggregator is the gateway through which hundreds of games from dozens of studios enter an operator's site at once — and that is exactly why it is one of the hardest objects of contract design: one chain simultaneously contains the game's creator, the aggregator, the operator and the regulator, each with its own interest. This page is written through the prism of contract practice: what the B2B licensing reality looks like from verified sources, which clauses decide the allocation of risk in an aggregation agreement, and how the Georgian legal layer works over this chain. We do not quote particular aggregators' terms or tariffs here — those are a matter for negotiation.
The B2B licensing reality: who answers for what
The first thing to see: in serious jurisdictions the supply of games is a separate object of licensing, and this reads from the official taxonomies. In Malta the B2B direction — the critical gaming supply — has its own application routes: Game Providers and Back Office, or Back Office only, which covers the systems generating and processing regulatory records. The Kahnawake regulations distinguish a Casino Software Provider Authorization, appended to the single IGL and valid only while it remains in good standing. Gibraltar's new regime defines B2B as supplies made in or from Gibraltar or to a Gibraltar entity, and separately establishes content-provider approval for supply through the Gibraltar-licensed aggregator platform. These taxonomies matter to a Georgian client for one reason: they show that every ring of the supply chain is recognisable in the regulator's eyes — and the contracts must follow that recognisability.
Through the Georgian prism this chain has its own clear rule: article 5, part 1 of the gambling law ties both the organising and the supplying of gambling into Georgia to a permit, and article 11, part 2 issues that permit only to an entrepreneur registered in Georgia. Entering the Georgian contour of an aggregation chain therefore means that a Georgian permit-holding entrepreneur must appear in the chain — and contract design builds the bridge between these two worlds.
Contract design: where the risk is allocated
In practice an aggregation agreement splits into blocks, and each block loads the risk onto the supplier, the operator or the aggregator. The first block — game quality and certification: warranties about the RNG and game logic, the existence and renewal of certificates, the involvement of certified laboratories when changes are made. In the Georgian contour a local component is added: integration with the gambling electronic control system and the authorization-certificate question — this process is governed by the selected-person regime of article 36-1 of the gambling law, and the contract must state who answers for the integration and how the supplier ensures compliance. The second block — commercial terms: revenue-share models, minimum guaranteed payments, currency and payment conditions. The third — intellectual property and branding: whose logo, whose titles, what happens with exclusivity arrangements. The fourth — exit and continuity: what happens when a game is withdrawn at a regulator's demand, who compensates players for running bonuses and jackpots, what happens to the data.
The Civil Code's freedom of contract offers wide possibilities here, but in an international chain two further questions arise: the governing law and the dispute-resolution forum — these clauses become decisive in a crisis, and writing them in advance is cheap. Both the aggregator's side and the operator's side have their standard forms — and since the Entrepreneurs law gives the Georgian contour a defined form, those forms need fitting to the Georgian structure.
The advertising layer: game promotion in the Georgian frame
Game promotion — from aggregators' marketing materials to banners placed on the operator's site — falls within the frame of article 8-3 of the law on advertising: gambling advertising is prohibited in any form except four exceptions — placement on the website where system-electronic gambling is permitted; at a sports event venue as consideration for sponsorship, visually and on the inner perimeter; on the object where gambling is permitted, with one sign up to ten square metres; and at an international airport or border crossing point. This means that marketing agreements concluded with aggregators and suppliers, insofar as they target Georgia, must be planned within these four formats — and the contract itself should say so, otherwise a party assumes the risk of a legal violation.
The Georgian cross-border layer
When a Georgian entity sits in the B2B chain — whether operator, supplier or both — the common layer switches on. The tax side: article 80, part 7 of the Tax Code taxes an individual organiser's income on the margin; article 81 sets the rates, including the 5% line on supply-permit excess income; article 171(b) exempts gambling services from VAT — while the concrete tax picture for platform and software fees depends on the transaction's structure and must be assessed separately in each case. The reporting side: articles 3, 11 and 12 of the AML law where a Georgian entity is in the chain; article 29(b) of the gambling law — winnings registration with the Financial Monitoring Service; and article 36-1 — the selected-person regime for system-electronic supply. On the civil side: articles 951 and 952 — a claim from a game arises only on a permitted game.
Frequently asked questions
Four questions repeat themselves on aggregation and B2B contracts.
Does an aggregator need a licence?
It depends on the jurisdiction and the role. Verified examples: in Malta a critical gaming supply requires a B2B licence; in Kahnawake there is the Casino Software Provider Authorization; Gibraltar's new regime brings B2B supply within its scope. Through the Georgian prism the decisive formulations are those of articles 5 and 11: organising and supplying into Georgia requires a Georgian permit.
Which clause carries the most weight in an aggregation agreement?
The allocation of risk on regulatory events: if a regulator withdraws a game or a certificate is revoked, who answers for the operator's loss, the players' bonuses and jackpots. In standard forms this clause is often incomplete — and it is exactly what must be written in negotiation.
How does certification enter the contract?
Certificates become objects of the contract: warranties on the RNG and game logic, the involvement of certified laboratories, re-testing upon changes. In the Georgian contour the integration of article 36-1 and the authorization certificate are added — and the contract must state who bears that duty.
How are payments modelled?
In practice revenue-share models and fixed fees are used — the concrete terms are a matter of negotiation. In the tax prism the transaction's structure is decisive: gambling services are VAT-exempt, while the taxation of platform fees requires separate assessment.
How We Help on Legal.ge
Legal.ge builds aggregation and B2B contracts from the design level: we draw the map of the chain — who is the supplier, the aggregator, the operator, and where the Georgian contour sits; we write the risk-allocation blocks — certification, regulatory events, exit, data; we take the Georgian layer into account — the permit under articles 5 and 11, integration under article 36-1, the four advertising exceptions, VAT and AML rules; and we run the negotiation in the operator's interest. The beauty of a B2B chain is that it works for everyone — but only when the risks are written down. Contact us before the contract form is chosen.