Kahnawake — a Mohawk territory in Canada — hosts one of the oldest interactive-gaming regulators in the business: the Kahnawake Gaming Commission has been issuing interactive-gaming regulations since 1999, and its current consolidated regulations are dated 25 March 2026. For a Georgian client, the most persistently misrepresented part of this regime is structural. "Getting a Kahnawake licence" sounds like an idiom for market entry, but under the regulations the real route in is a Client Provider Authorization (CPA), appended to the single existing Interactive Gaming Licence (IGL). This page describes the regime from the regulations' own text — the five permit types, the complete fee schedule in US dollars, the increase taking effect on 1 January 2027 — and closes with the Georgian cross-border layer.
The standard warning also applies: a Kahnawake permit creates no access to the Georgian market and does not remove the Georgian permit-tax-reporting layer, which the final section deals with.
The legal basis and the five permit types
Interactive gaming is regulated under the Kahnawake Gaming Law and the regulations concerning interactive gaming issued under section 35 of that law — first enacted on 8 July 1999. Land-based gambling (poker rooms, raffles, gaming devices) is regulated separately. Regulation 10 distinguishes five types: the Interactive Gaming Licence (IGL); Client Provider Authorizations (CPA); Casino Software Provider Authorizations; Live Dealer Studio Authorizations; and Key Person Permits.
Here is the structural fact you need and will not get from agent marketing. The IGL holder operates the co-location facility — the internet-services infrastructure located in Kahnawà:ke — and the regulations say it plainly: only one Interactive Gaming Licence will ever be issued by the Commission at any given time. The operator's real route is the CPA: its holder is entitled to conduct interactive gaming from the co-location facility owned and operated by a valid IGL holder. A CPA and a Casino Software Provider Authorization must be appended to a valid IGL and last only while the IGL remains in good standing; and under regulation 13, the IGL holder is jointly responsible for the breaches of its Authorized Client Providers. Two practical conclusions follow. First, choosing infrastructure in Kahnawake is simultaneously a compliance choice, because your host's failures reflect onto your own position. Second, the contract with the IGL holder is the central document of the structure. The Live Dealer Studio Authorization concerns a physical studio in the territory — a direction of direct interest to Georgian live-studio exporters.
The complete fee schedule — from the text of the regulations
Unlike many jurisdictions, Kahnawake's fees are written into the regulations themselves, and they read exactly as follows. Application fees: IGL — $30,000 (including a non-refundable due-diligence component; the first annual fee is refundable if refused); CPA — $35,000 (same structure; excluding the costs of the Control System assessment); Casino Software Provider — $35,000 plus $5,000 per key person; Live Dealer Studio — $25,000 (including premises inspection) plus $5,000 per key person; Key Person Permit — $5,000 each.
Annual fees: IGL — $15,000; CPA — $20,000; Casino Software Provider — $20,000 plus $3,000 per third-party operator on the operator list; Live Dealer Studio — $10,000; Key Person Permit — $1,000. Annual fees are payable on each anniversary; a Key Person Permit lapses after six months without a key relationship. And the final accent: the Commission has published a fee-increase notice taking effect on 1 January 2027 — the CPA application fee rises from $35,000 to $40,000 (the annual fee is unchanged; the five-year renewal rises from $5,000 to $40,000 including the annual fee), and the Key Person Permit application fee from $5,000 to $6,000. The old rates are locked in for applications submitted before 1 January 2027 — which creates a natural planning horizon.
Process, vetting and player protection
The process is form-based: application and data forms (annexes B, C, D, E and others of the regulations) are submitted to the Commission electronically, and the Commission's Approved Agents may assist applicants. The objects of vetting are the applicant, every director and every shareholder above 10% — through personal and financial information; key persons require Key Person Permits; each undergoes suitability testing; and the operational system must be presented with a Control System Submission. Structural changes require a Material Change Report; renewals run through a separate form. On the player-protection side the Commission operates a comprehensive self-exclusion system and a complaints channel — relevant also to Georgian clients handling player-side disputes. The Commission does not publish official processing timelines — the schedule must be confirmed with it.
The Georgian cross-border layer
The Kahnawake permit stays within the same boundary: it gives nothing on the Georgian market. Article 5, part 1 of the Georgian law on gambling ties organising and supplying into Georgia to a Georgian permit, and article 11, part 2 grants that permit only to an entrepreneur registered in Georgia. Kahnawake adds one further detail: the CPA structure means the operator stands in a continuous contractual relationship with the IGL-holding host, and that documentary chain must also be examined from the standpoint of Georgian contract practice.
The articles of the Georgian layer: article 80, part 7 of the Tax Code — margin taxation of an individual organiser; article 81 — the rates, including the 5% line; article 8 — player winnings and loss offsetting; article 171(b) — VAT exemption of gambling services. 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 reporting to the Financial Monitoring Service; article 36-1 — the selected-person regime for system-electronic supply. Articles 951 and 952 of the Civil Code: a claim arises only from a permitted game.
Frequently asked questions
Four questions repeat themselves in connection with Kahnawake.
Can a new IGL be obtained?
No — under the regulations the Commission issues only one Interactive Gaming Licence at any given time, and it belongs to the operator of the co-location facility. The operator's route in is the Client Provider Authorization: a permit appended to the IGL, working from the IGL holder's infrastructure.
What does a CPA cost?
By the text of the regulations: an application fee of $35,000 (excluding Control System assessment costs) and an annual fee of $20,000. From 1 January 2027 the application fee rises to $40,000; applications submitted before that date are locked in at the old rate.
What does the IGL holder's joint responsibility mean?
Under regulation 13, the IGL holder is jointly responsible for the breaches of its Authorized Client Providers, and a CPA lasts only while the IGL remains in good standing. For an operator this means: choosing the host is a compliance decision, and the contract with the host is the structure's central document.
Does a Kahnawake permit replace a Georgian permit?
No. Articles 5 and 11 of the Georgian gambling law tie organising and supplying into Georgia to a Georgian permit, issued only to an entrepreneur registered in Georgia.
How We Help on Legal.ge
Legal.ge starts the Kahnawake direction from the correct structure: we determine which permit your model needs — a CPA as an operator, a Casino Software Provider or a Live Dealer Studio authorization as a supplier; we prepare the negotiation and contract framework with the IGL-holding host, accounting for the joint-responsibility risk; we build the complete fee and timing budget on the regulations' own figures, with the 2027 increase on the horizon; we assemble the application and vetting forms for your directors and holders of more than 10%; and in parallel we construct the Georgian layer — the tax and reporting plan of the person behind the structure. Kahnawake is a regime with three decades of history in which everything is written in the text of the regulations — and that is exactly the text we work from. Contact us to build your project in conformity with it.
