MGA trims Recognition Notice framework requirements and drops legal opinion template

The Malta Gaming Authority (MGA) has revised its proposal on the Recognition Notice (RN) framework, reducing the precision of several requirements, removing the standardised legal opinion template and replacing exact figures with bands and percentages. The regulator published its final position in a public note dated 29 October 2026 and plans the first annual exercise to affect B2C holders in 2026, covering the 2025 calendar year. The MGA statement is available via its [regulatory releases](/regulation).

Key changes in the revised proposal

The MGA confirmed it is abandoning the standardised legal opinion template it proposed in April 2026 and replacing it with a list of required confirmations. The regulator cited concerns about rigidity, cost and the prospect of requiring lawyers to opine on operational matters.

The original requirement for a corporate structure diagram is replaced by the collection of ultimate beneficial owner (UBO) data, which will be gathered from existing holders on a phased basis. The requested regulatory history has been narrowed: it will be limited to fitness and propriety background, ownership and control, licensing status and material regulatory matters; the phrase "where known" is removed from the scope of what is required.

Obligations remain for identification of Money Laundering Reporting Officer (MLRO) contacts for B2C applicants and for declarations on sanctioned jurisdictions, FATF high-risk jurisdictions and land-based activity.

Annual reports: bands, scope and initial roll-out

The MGA confirms that the annual reporting exercise will use bands and percentages rather than exact figures. For B2C holders the first round, starting in 2026, will cover the period from 1 January to 31 December 2025. The first cycle will include only B2C operators; B2B holders will be incorporated in the subsequent cycle and further detail appears relevant for [B2B holders](/b2b).

The data fields that B2C holders will be required to provide include:

• active player accounts and their distribution by predefined bands of deposit value;

• percentage of deposits broken down by payment method category, without transaction-level tiers or exact figures;

• employees limited to full-time equivalent (FTE) staff based in Malta;

• revenues reported in band form.

The MGA has deferred the requirement to count the number of B2B customers for the first round. The feedback statement emphasises that bands are intended to show each holder’s scale, footprint in Malta and exposure to payment methods, without demanding detailed transactional data.

What the authority kept and what it removed

Among the elements dropped is the mandatory legal opinion template; the MGA withdrew it following objections about cost and applicability. The public communication dated October 2026 also states the authority heard concerns on proportionality, practicality and duplication with requirements from other licensing authorities.

Retained are MLRO identification, declarations relating to sanctioned and FATF jurisdictions, and the obligation on land-based activity. The indiscriminate collection of routine regulatory correspondence has been removed. The authority has not published the number of Recognition Notice holders, the number of respondents to the consultation, nor a concrete timetable for the legal amendments it says are necessary to implement some measures.

Regulatory context and international links

The MGA links the proposals to the 2023 National Risk Assessment and the National AML/CFT Strategy 2024–2026. The regulator defines that a Recognition Notice gives an authorisation issued by another EU or EEA Member State, or by a State the MGA considers to have safeguards largely equivalent to Maltese law, the same effect as a Maltese authorisation to provide a gaming service or supply gaming in or from Malta.

On judicial matters, the European file has been relevant to the authority: Advocate General Nicholas Emiliou on 23 April 2026 described the Austrian appeal in case C-683/24 as inadmissible and considered that, if answered, the provision would be "manifestly incompatible with the Brussels I bis Regulation". This line appears in the public communication and forms part of the context in which Malta defends its point-of-supply model.

Pending timings and next steps

The MGA’s note indicates guidance, templates and a risk-rating methodology still need to be published; those documents were not available at the time of the statement. With fewer than two months of 2026 remaining from the date of the communication, the authority acknowledges that definitions and the concrete bands for the first B2C declaration are yet to be published.

The announcement is the latest in a series of autumn changes in Malta: the new gaming tax entered into force on 1 October 2026 and the MGA also signed a player-protection agreement with the consumer entity MCCAA, according to the public note and referenced documents.

"manifestly incompatible with the Brussels I bis Regulation", quoted statement by Advocate General Nicholas Emiliou in relation to case C-683/24, 23 April 2026.

The MGA distributed the feedback statement to RN holders and their representatives after a targeted consultation held between 29 April and 27 May 2026. The regulator considers that most respondents supported the general direction of the reforms but insisted on proportionality, practicality and avoiding duplication with foreign authorities.