For a Georgian operator looking beyond the borders, Europe's regulated markets are a difficult target for two reasons: everything there is regulated — and there is no single licence. By the European Commission's own position there is no sector-specific EU legislation in gambling services, and the member states run their own regimes; by Estonia's official formulation, one member state's licence means nothing in the next. Entering Europe is therefore not "getting a licence" — it is a sequence of decisions: which markets, which regime, with your own licence or through a partnership, and what remains in the Georgian contour. This page arranges that sequence with official numbers.
The first decision: own licence or partnership
There are two real routes in. The first — your own licence: the Georgian group incorporates a subsidiary in a member state, licensed under the local regime; this route demands full control and full responsibility. The second — partnership: entering a market through a local licensee or a licensed platform, by a supply agreement, a white-label model or the B2B direction. This route is fast, but its value depends on the partner's quality and is measured by contract design. The choice depends on market size, time and resources — and it is often hybrid: your own licence in one market, a partnership in another. In serious regimes the B2B direction is itself a separate object of licensing — in Malta, for example, critical gaming supply has its own B2B application routes — which means that "entering by supply" too must be part of a fully considered structure.
Licensing minimums: two official bookends
For planning the own-licence route there are two fully countable examples — both from official sources. Malta: application fee €5,000; annual fee €25,000 for B2C (€10,000 for Type 4 only), €25,000–35,000 for B2B; a monthly compliance contribution by game type; gaming tax of 5% of revenue; minimum capital from €40,000 to €240,000; a licence for 10 years; and the decisive condition — the applicant must be incorporated in the EU/EEA. Estonia: an activity licence for an indefinite term, with state fees of €47,940 for games of chance, €31,960 for toto and €3,200 for games of skill; €3,200 per operating permit; capital minima of €1,000,000, €130,000 and €25,000; decision deadlines of four and two months; and a statutory rule — gambling must be the company's only activity. Between these two bookends every other member state's regime interpolates — and exact numbers must always be taken from the regulator's official pages.
Partnership practice: what must be verified
Entering by partnership means that the legal foundation of your European presence is someone else's licence — and that foundation is solid only if verified. In practice there are three checks. First — the licence's reality: serious regulators keep public licensee registers, and the partner's status must be found in the register. Second — change-of-control risk: in regulated markets an ownership change requires the regulator's consent — the Maltese regime, for example, treats an equity or control change above 75% as a completely fresh application, and Gibraltar's new regime sets a separate fee for it; in other words, a sale of your partner touches your contract too. Third — contract design: supply terms, exit, data and liability caps — the blocks analysed in detail on our white-label and aggregators pages. The general principle: a partnership is not a licence rental — it is a contract that writes the rules of working under someone else's licence.
The Georgian dual contour
The Georgian layer of European expansion is dual. Toward Europe: the licence works only in the state that issues it and gives nothing on the Georgian market — article 5, part 1 of the gambling law ties organising and supplying into Georgia to a Georgian permit, and article 11, part 2 grants it only to an entrepreneur registered in Georgia. Toward Georgia: the position of the person behind the structure remains governed by its own articles — 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; article 8 concerns player winnings; article 171(b) exempts gambling services from VAT. Reporting: 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; article 36-1 — the selected-person regime. Articles 951 and 952 of the Civil Code work separately for each market: a claim from a game arises only on a permitted game.
Frequently asked questions
Four questions repeat themselves on European expansion.
Which is the cheapest European entry?
On the official numbers the lowest fixed annual cost is Malta's Type 4 direction — a €10,000 annual fee — but it covers only skill games. For the full casino direction Malta's B2C annual fee is €25,000 with capital from €100,000; in Estonia the capital for games of chance is €1,000,000. "Cheap" and "suitable" are different things — the choice starts with the game type.
Is it possible to enter Europe on a partner's licence?
Yes — by a supply agreement, a white-label model or the B2B direction; in serious regimes the B2B direction is itself separately licensed. The condition: the licence is verified in the regulator's public register, and the contract is written with exit, data and liability clauses.
How long does a licence take?
Estonia publishes deadlines officially: four months for the activity licence and two months for the operating permit. Malta publishes the process stages and individual windows but no overall guarantee — leave reserve time in the plan.
What remains in Georgia during this expansion?
The Georgian contour: a Georgian permit for organising and supplying into Georgia is issued separately under articles 5 and 11, and the tax and reporting duties of the person behind the structure remain under Georgian articles — both wings of the dual structure are built separately.
How We Help on Legal.ge
Legal.ge runs European expansion from the strategy level: we identify the target markets and their regimes; we weigh the two routes — own licence or partnership — against official numbers and your resources; on the own-licence route we build the member-state subsidiary and the application; on the partnership route — the verification and the contract; and in both cases we construct the Georgian dual contour in parallel — the permit, tax and reporting plan. Europe does not give one licence — but it gives a clear choice in official numbers. Contact us, and we will build that choice together.