Malta regulator scales back Recognition Notice reforms after industry pushback

Malta's Gaming Authority altered its planned changes to the Recognition Notice framework following industry feedback, the regulator said in a statement dated 26 October 2026. The revisions reduce or remove several proposed obligations for foreign licence holders and delay full data collection while emphasising a risk-based, differentiated approach for B2C and B2B holders.

What the MGA changed

The proposals were introduced under Malta's National AML/CFT Strategy 2024–2026 after concerns that the existing system could let companies operate under foreign licences with insufficient anti-money laundering oversight. The MGA opened a targeted consultation in April 2026 on strengthening assessment and monitoring of Recognition Notices. NEXT.io reported on the subsequent policy shift.

The MGA listed a series of scaled-back measures it will now apply:

• Requests for full corporate structure charts have been narrowed to information on ultimate beneficial owners (UBOs).

• Many of the requirements originally proposed for consumer-facing operators will not apply to B2B suppliers; B2B suppliers will be exempt from several obligations.

• A proposed standardised legal-opinion template has been dropped; the regulator will instead set out the key points legal opinions must address.

• Operators will no longer be required to provide five years of regulatory correspondence; disclosure is limited to material licensing and fitness matters.

• Exact annual deposit figures will be replaced by predefined ranges.

• Payment-method reporting will use broader categories rather than detailed payment data.

The MGA said the revised framework introduces “a more differentiated approach between B2B and B2C RN holders” and places greater emphasis on risk-based supervision.

Reporting timetable and legal questions

The regulator intends to begin gathering information from foreign licence holders for the reporting period 2025, with initial collection applying only to B2C holders. Several stakeholders queried whether the MGA has the legal authority to demand all the information it initially proposed; the MGA acknowledged those concerns and said it has modified proposals to avoid issues related to commercial confidentiality, administrative burden and duplication of foreign regulatory checks.

The authority said the consultation responses were constructive and that stakeholders underlined the need for a “proportionate approach, operational convenience, and the absence of unnecessary duplications in requirements applied by licensing authorities from other jurisdictions.” The MGA also said its amended approach would allow for proper oversight while remaining "dedicated, risk-sensitive, and responsive to the nature of the areas it operates". The statement of comments has been shared with holders of Recognition Notices and their representatives.

For background on how Recognition Notices fit into Malta’s framework, see the regulator's section on recognition mechanisms.