One Product — Many Markets: Framing the Problem
A modern gambling product — a game, an RNG module, a platform — rarely serves a single jurisdiction. A supplier simultaneously serving Georgian operators and international markets must pass the same product through compliance checks several times: in Georgia, within the framework of the authorisation certificate connected to the electronic control system; abroad, through reports of testing institutes recognised by regulators. This page does not describe any single jurisdiction's procedure — our certification series does that; here we discuss how to design a unified certification strategy so that multiple certificates form a coordinated portfolio rather than a mutually cancelling chaos.
The strategic point is simple: certification is not a one-off formality but a process accompanying the product's life cycle. Every change to a game, its mathematics or the platform simultaneously undermines the freshness of certificates on several markets. Portfolio planning is therefore change-management planning.
The Georgian Axis: the Authorisation Certificate and the Selected Person
In Georgia the legal axis of technical compliance is Article 36-1 of the Law on Organising Lotteries, Gambling and Profitable Games. Where a permit seeker or holder uses a system built with its own resources for its activity, the selected person must examine that system and issue an authorisation certificate in accordance with the standards and requirements established by a legal act of the Minister of Finance; the rules and conditions of issuance are likewise set by a legal act of the Minister of Finance. The certificate confirms the conformity of the game and of the essential products and services with those standards.
The institutional frame matters too: the electronic control system is deployed and operated by the selected person under a contract with the Revenue Service — for a term of no more than 15 years — and that person's server must be located in Georgia. The permit seeker or holder must pay fees for the first-time examination of the online gaming system and for the issuance of the corresponding authorisation certificate, for equipment and monitoring, for installation, for the operation of the control system (an operating fee) and for the supply of POS terminals. The types, amounts, periodicity and procedure of those fees are determined by a legal act of the Government of Georgia — the concrete figures are confirmed with the regulator. Moreover, the Government may impose additional requirements on organisers and suppliers in connection with the system, and non-fulfilment is treated as a violation of permit conditions.
The International Laboratory Layer
On foreign markets the testing standard is shaped by international testing laboratories — the GLI/BMM-type institutes known on the market, which run RNG verification, game-mathematics reports and platform integration testing. The Georgian law names no laboratories by name — it regulates the role (the selected person, the authorisation certificate) — so the value of an international laboratory report within the Georgian process is a practical question to be clarified with the regulator and the selected person.
The regulators' own frameworks provide orientation: Gibraltar's Gambling Division publishes a list of Approved Testing Facilities; the Kahnawake commission issues Casino Software Provider Authorizations — an application fee of $35,000 and $5,000 per key person, an annual fee of $20,000 and $3,000 per third-party operator on the list — with the authorisation appended to the single IGL; in Malta a B2B critical gaming supply licence is issued through two routes — Game Providers and Back Office, or Back Office only — and one licence covers games from Type 1 to Type 4, while a group licence is available where the parent holds more than 90 percent of the group's entities; on the Isle of Man the Software Supplier and Token/Blockchain-Based Software Supplier licences exist separately — with annual fees of £36,750 and £52,500 respectively, and an application fee of £5,250 for every type.
Planning the Certification Portfolio
The first principle of a unified strategy is isolating the core: the RNG's behaviour, the game rules and mathematics, volatility limits and reporting logic form the layer nearly every regulator requires in almost the same form; describing that layer once, strictly documented, allows the same technical file to serve several markets. The second principle is ordering markets by priority: certification begins where the real revenue is, not where an agent offers it cheapest. The third is change management: every product release should be recorded in a change log with a classification that determines in advance which certificate on which market constrains the novelty.
The strategic questions a portfolio owner must keep asking: how compatible are different markets' technical requirements within one architecture; where do contradictory requirements hide (for instance, different data-localisation demands); and which certificate serves as the starting platform for the others. In practice it is common that a technical file built to one premium market's requirements passes the remaining markets with reduced additional work — an argument for planning certification at the strategy level rather than the deal level.
Costs and Risks
The cost picture splits into two layers: on the Georgian side, the fee types payable to the selected person (first-time examination, authorisation certificate, equipment/monitoring, operating fee, POS terminals), whose amounts are set by a government act; and on the international side, the direct prices of laboratory testing and licences quoted above from official sources. In the risk layer, three dominate: version divergence — when builds for different markets grow apart and silently drift out of the certified state; certificate expiry — when the renewal process is not strategically planned; and the consequences of non-fulfilment — on the Georgian side, non-fulfilment of the system's requirements is treated as a violation of permit conditions, which is grounds for sanctions.
A properly built portfolio discounts these risks: a change log plus a unified technical file plus a renewal calendar is the minimal administrative frame that makes multiple certificates manageable. And the practical conclusion: a certification strategy is part of the supplier's business model — it should be recalculated as value on every new market entry, not after the first fine or the first suspended release appears.
Frequently Asked Questions
Who issues the authorisation certificate in Georgia?
The selected person — in accordance with the standards and requirements established by a legal act of the Minister of Finance, after examining the online system; the issuance rules and conditions are set by the Minister's act.
Does the Georgian side recognise a foreign laboratory's report?
The law names no laboratories — it regulates the role. The value of an international report within the Georgian process is a practical question clarified with the regulator and the selected person.
How expensive is an international supplier authorisation?
Kahnawake's Casino Software Provider Authorization application is $35,000 ($5,000 per key person), the annual fee $20,000 and $3,000 per third-party operator; the Isle of Man Software Supplier annual fee is £36,750, the Token-Based one £52,500.
Can one licence serve several markets?
Not directly — every regulator requires its own confirmation. But one licence can have a broad internal scope: the MGA's B2B licence covers games from Type 1 to Type 4, and a group licence consolidates groups with more than 90 percent ownership.
What happens when a certified system is changed?
The change undermines the certificate's freshness: on the Georgian side, non-fulfilment of the system's requirements is treated as a violation of permit conditions — every release must be managed through a change log and a renewal calendar.
How We Help on Legal.ge
We build the certification portfolio as a unified strategy: we isolate the core technical file, order the markets by priority, write down the change-management rules and assist with the sequential execution of the Georgian authorisation process — from dealing with the selected person to planning the fee types. Contact us on Legal.ge and receive the certification map for your product.