iGaming Licensing Landscape Shifts as Operators Turn to Grey Jurisdictions

The once well-understood hierarchy of iGaming licensing jurisdictions is undergoing a rapid transformation, as recent expos in Europe and beyond have revealed. Not long ago, a license from a so-called “white” jurisdiction such as Malta or the Isle of Man was seen as the industry’s gold standard. It was more than a regulatory approval—it was a symbol of credibility, signaling robust oversight, trustworthiness, and a pathway to key markets, reliable banking relationships, and partnerships with major software providers. The industry assumption was clear: a top-tier license was always the preferred route.

But that certainty is now giving way to a more complicated reality. A quiet but steady migration toward “grey” jurisdictions—places like Anjouan, Nevis, Tobique, and Curacao—is reshaping the licensing map. Companies are increasingly weighing the crushing costs and complex obligations of white jurisdictions against the more straightforward, cost-effective frameworks offered elsewhere.

The pressure fueling this shift is rooted in compliance burdens. Securing a license in a leading jurisdiction now goes far beyond the initial application fee. Operators face ongoing audits, mandatory local directorships, strict anti-money laundering (AML) measures, and exhaustive reporting requirements. For smaller operators and new entrants in particular, these expenses are becoming unsustainable.

The impact is not limited to operators. Corporate service providers (CSPs)—the intermediaries that guide companies through licensing—are also rethinking their business models. At a recent conference, one CSP noted they had stopped offering licenses across a broad range of jurisdictions and were instead focusing exclusively on Anjouan, Nevis, and Curacao. This narrowing of scope allows CSPs to streamline compliance, reduce costs, and increase profitability. For many, the days of offering a “menu” of global options are giving way to specialization in a few manageable jurisdictions.

This consolidation has created a wider ripple effect. Some CSPs are even relocating their own businesses to these more accommodating jurisdictions, making it easier to manage compliance while strengthening their foothold in the grey licensing ecosystem.

Anjouan, part of the Comoros, exemplifies this growing appeal. It offers a straightforward process in which a single license covers all iGaming verticals, with costs significantly lower than in top-tier jurisdictions. The added tax benefits only enhance its attraction. Nevis, long known for its financial services sector, is another rising player, promoting a tax-neutral and cost-effective environment for market entry. The Tobique First Nation in Canada presents yet another alternative with its unique licensing framework, drawing interest from a particular niche of operators.

Curacao, perhaps the most recognized of the grey jurisdictions, is also in the midst of change. Historically seen as offering a “one size fits all” license with minimal oversight, it is now overhauling its framework to include stricter AML measures and responsible gambling requirements. The move is designed to improve its international reputation, but even under the reformed system, costs remain far lower than those in Malta or the Isle of Man, preserving Curacao’s attractiveness.

For operators, the immediate advantages of these jurisdictions are obvious: reduced costs, quicker time to market, and greater operational flexibility. Freed from heavy compliance expenditures, companies can channel more resources into marketing, product development, and expansion into emerging markets, where a white license may not be necessary for entry.

Still, the trade-offs are real. A grey license can limit access to mainstream banks and payment processors, many of which hesitate to work with entities tied to jurisdictions lacking strong compliance reputations. It can also make it harder to attract players in tightly regulated markets, where consumers are increasingly aware of licensing standards and may be wary of operators with lesser-known approvals.

The paradox was on display at recent industry gatherings. While regulators, banks, and governments call for stricter oversight, CSPs openly promote low-compliance options, often alongside operators with questionable regulatory histories. In some cases, turnkey providers even pitched unlicensed solutions, with one implying that “obtaining or holding any kind of B2C license was not a requirement to work with them.”

This divergence underscores the difficult choices now confronting iGaming companies. On one path lies the pursuit of greater compliance and alignment with mainstream financial and regulatory systems. On the other lies the temptation to operate in the grey zones—or even in the shadows—where oversight is light and costs are lower, but the risks are higher. For an industry caught between ever-tighter regulations and the lure of quick, affordable access, the future looks increasingly like a forked road.

By fLEXI tEAM