Comoros gambling laws for operators: illegal to offer
The Union of the Comoros punishes games of chance not authorised by law (Penal Code arts. 203, 476-477) and no Union gambling licence appears in the report's sources. Anjouan Gaming issues offshore Internet Gaming Licences under the island's 2005 Acts for players outside the Comoros; the Central Bank of the Comoros stated on 8 December 2025 that the AOFA is not recognised in the Union.
Product by product
Every applicant is a legal entity that gives the full ownership chain and meets Anjouan Gaming's due diligence, and no licensee may knowingly target residents of the excluded territories, which include the Comoros.| Product | Status | Licensed by | Tax | Key restriction | Advertising |
|---|---|---|---|---|---|
| Sports betting | Offshore only | Anjouan Gaming, B2C Operator Licence | No gambling tax published; fixed licence fees | Listed activity; the Comoros is an excluded territory. Union: the Central Bank stated that online sports betting licences are not authorised nationally; no block order or blocked-site list is published, and the operator does the geo-blocking. | No channel ban; responsible gaming messaging; no targeting of under-age people or excluded territories |
| Online casino | Offshore only | Anjouan Gaming, B2C Operator Licence | As for Sports betting | Listed activity; live casino and slots are not named separately. Union: games of chance not authorised by law are prohibited (art. 203). Anjouan states operators remain solely responsible for geo-blocking; no Union block order is published. | No channel ban; bonus terms shown prominently |
| Poker and bingo | Offshore only | Anjouan Gaming, B2C Operator Licence | No gambling tax found | Listed activities, with the same excluded-territory condition as online casino. | No channel ban |
| Lottery | Not licensed | Not listed by Anjouan Gaming; no Union licence | Not covered | Anjouan Gaming does not list lottery. Union: lotteries and games of chance that hold out a large gain for a small stake are prohibited (art. 201) and organising illicit online lottery is punished (art. 476). | Prohibited lottery advertising punished under art. 476 |
| Crypto and prediction markets | Offshore only | Anjouan Gaming, B2C Operator Licence | No gambling tax found | Cryptocurrency-enabled gaming, blockchain-based platforms and prediction markets are listed; virtual-asset use is described in the application and monitored. Union: the Central Bank stated that virtual assets and their providers are not authorised nationally. | As other B2C products |
What did the Central Bank of the Comoros state about the Anjouan authorities?
On 8 December 2025 the Central Bank of the Comoros stated that the AOFA and Anjouan Corporate Services are not recognised in the Union of the Comoros. It also said that online gambling and sports betting licences are not authorised on the national territory and that none has been issued. Anjouan Gaming says it issues its licences under the laws of the Autonomous Island of Anjouan. The sources do not reconcile the two statements.
Central Bank of the Comoros, communiqué of 8 December 2025 ↗Anjouan Gaming licence conditions v5 ↗
Regulator and player protection in Comoros
Which casinos & betting sites are licensed in Comoros?
See the full official list of licensed operators and their authorised domains.
Heads-up for operators
3 items · last change 10 Nov 2026
No bill, decree or court filing on the Anjouan licences appears in the official sources the report cites, as of 10 November 2026. On the Anjouan side, the KYC and AML Code's weekly reporting cycle starts on a date to be set in an AOFA adoption notice that does not appear on Anjouan Gaming's Regulatory Notices page, and Anjouan Gaming's first Annual Regulatory Report is in preparation. In the Union, a further AML/CFT bill was before the Assembly's constitutional-law commission on 23 June 2025, and the ministerial order fixing the casino threshold under Loi 21-004/AU art. 83 does not appear in the report's sources
KYC and AML Code, final edition
The licence conditions call the Code in effect, while the Code and the application overview say it applies from a date set in an AOFA adoption notice, which does not appear on Anjouan Gaming's Regulatory Notices page. The weekly currency transaction reporting cycle starts as that notice specifies.
Source: 1
First Annual Regulatory Report
Anjouan Gaming states its first Annual Regulatory Report is in preparation.
Source: 2
Not yet in force: drafts, laws adopted without a start date, and sections of the law still to be commenced. An item moves to the timeline below on the day it takes effect.
Getting licensed: apply to Anjouan Gaming
Gambling tax and fees in the Comoros
No gambling tax rate is stated in Anjouan Gaming's published documents, and none mentions a tax on gross gaming revenue, either to impose or to exempt it (5.01, 5.02).
- What the documents print
- the International Business Companies Act 004 of 2005 exempts an international business company that complies with the Act from corporate, income, withholding, capital gains and other like taxes on assets or income originating outside the State or in connection with company administration in the State, for 25 years from incorporation, but not a Resident (s. 99);
- VAT is not covered; the Union's tax code is not covered in this edition, and the Union's position on this exemption is not stated.
- Licence fees are fixed euro amounts, not taxes: EUR 17,828 on issuance, EUR 17,828 each year on renewal (B2C and B2B), EUR 500 for each additional B2C domain.
Which foreign licences the Comoros accepts
The Comoros recognises none of these 8 foreign licences.
BannedMalta (MGA) · United Kingdom (UKGC) · Gibraltar (GRA) · Isle of Man (GSC) · Curaçao (CGB) · Kahnawake (KGC) · Alderney (AGCC)
Not authorised by law in the Union: the Penal Code (art. 203) punishes games of chance not authorised by law on the territory of the Comoros, and no Union rule recognising this licence appears in the report's sources.
Anjouan (AGB)
The Anjouan licence is for players outside the Comoros: the Comoros is on the licence conditions' excluded-territory list (s. 2). The Central Bank of the Comoros stated on 8 December 2025 that the AOFA and Anjouan Corporate Services are not recognised in the Union.
Bonus rules in the Comoros
Anjouan Gaming's documents do not ban bonuses or promotions: they require terms to be transparent and complete, with wagering requirements, restrictions and expiry dates disclosed prominently, and they bar promotions to self-excluded players. Those are Anjouan's standards for its licensees. The Union authorises no online gambling (Central Bank of the Comoros, 8 December 2025), and no Union rule on bonuses appears in the report's sources.
No bonus type is banned or named in Anjouan Gaming's documents, and no wagering cap is set. No bonus may be sent to a self-excluded player, and self-exclusion or protective tools may not be made conditional on bonus requirements.
- Messages ads may not give
- Guaranteed winnings
- A claim that gambling solves financial problems
- Advertising that targets minors or vulnerable people
- Mandatory disclaimer
Responsible gaming messaging in advertising; no prescribed wording
- Penalties
Anjouan Gaming's enforcement policy lists compliance notices, administrative penalties, suspension and revocation; no fine amount is published. In the Union, art. 476 of the Penal Code punishes prohibited lottery advertising by whoever organises unauthorised online gambling: one to five years and a fine of KMF 500,000 to 10,000,000.
Licensees must not knowingly target residents of the excluded territories, which include the Comoros (licence conditions s. 2).
How the Comoros enforces against unlicensed operators
Anjouan Gaming's enforcement tools are compliance notices, administrative penalties, licence suspension and revocation, all against licence holders; it publishes no fine schedule. In the Union, no blocking order, blocked-site list or prosecution for online gambling appears in the sources the report cites, as of 10 November 2026, although the Penal Code provides prison and fines for players (art. 203) and organisers (art. 476).
- 1 April 2026: Anjouan Gaming reported 12 supervisory assessments and 3 formal compliance notices for January to March 2026, and no fine.
- 8 December 2025: the Central Bank of the Comoros stated that the AOFA and Anjouan Corporate Services are not recognised in the Union, that online gambling and sports betting licences are not authorised on the national territory and that none has been issued; it said it would pursue the entities concerned through the courts.
- 10 November 2026: the Anjouan register's Suspended and Revoked Licences pages and a public notice of termination of licence for two companies are published; no Union blocking order is.
Licensed operators: 1140
The regulator's register lists 1,140 Anjouan licence holders (checked 2026-11-11, no change since 2026-11-06).
Traps operators hit in the Comoros
Specific operational risks that have caught new entrants in this market. Each item is country-specific. Generic gambling-ops issues (KYC, RG tools) are not included unless they have a local twist.
The Union does not recognise the issuing authorities
The Central Bank of the Comoros stated on 8 December 2025 that the AOFA and Anjouan Corporate Services are not recognised in the Union and that online gambling licences are not authorised on the national territory. The Penal Code (arts. 476-477) punishes organising unauthorised online gambling with one to five years in prison and a fine of KMF 500,000 to 10,000,000, bans payments for it and makes banks notify violations; directors and agents can be prosecuted (art. 202 for gaming houses; legal persons, art. 27-bis).
The Comoros is an excluded territory
Licence conditions s. 2 bar licensees from knowingly targeting residents of the excluded territories (Australia, Austria, the Comoros, France, Germany, the Netherlands, Spain, the United Kingdom and the United States, a non-exhaustive list) and say effective GEO-IP blocking should be implemented. Anjouan Gaming states that operators remain solely responsible for geo-blocking and local compliance, and that the licence does not replace any local licence.
The Act that creates the licence is not published
The Computer Gaming Licensing Act 007 of 2005 is not on Anjouan Gaming's site or the AOFA's Acts and Documents page, and is cited under three different titles in the regulator's own documents. Every statement about the licence rests on what the regulator says the Act provides.
The first-year cost is only partly priced
The fee schedule lists EUR 17,828 on issuance, EUR 17,828 on annual renewal and EUR 500 for each additional B2C domain. It does not say whether the first year also carries the renewal fee (which would make it EUR 35,656), and it leaves testing, ADR participation, incorporation and administrative-service charges unpriced.
Suppliers need an Anjouan licence or recognition
A B2C licensee must satisfy the AOFA that its platform and content suppliers hold a valid Anjouan B2B licence or recognition certificate (licence condition 14). The conditions for a recognition letter are not published.
Beneficial ownership is disclosed in full
Changes of 10% or more in beneficial ownership are notified within 10 business days; nominee, trust or foundation structures and holdings kept below the 10% threshold must be disclosed, and the AOFA may ask for source of wealth for any owner, including holders through citizenship-by-investment programmes (conditions ss. 11 and 15).
Markets abroad treat Anjouan-licensed sites as unlicensed
Each market's own authority, in its own document: Sweden's Spelinspektionen counts sites claiming an Anjouan licence among unlicensed gambling (situation report of 20 March 2025); a Bratislava court ordered an Anjouan-licensed site blocked in Slovakia (order 2Ntn/23/2025 of 28 October 2025); Latvia's State Revenue Service lists an Anjouan company as unlicensed (decision of 28 October 2024); the Massachusetts Attorney General (3 October 2024) and the Tennessee Sports Wagering Council (9 September 2026) ordered Anjouan-based operators to stop serving their residents. No market accepting the licence appears in the report's sources, and Anjouan Gaming says its licences do not override local prohibitions.
Timeline: rules in force
- September 2026
Licence conditions amended
Anjouan Gaming's notice 'License Conditions Amended: Beneficial Ownership, ADR and B2B Disclosure Requirements' (only its title is on the notices page); Licence Conditions v5 of October 2026 apply section 15 at once to new applications and on renewal to existing licensees.
Source: 15
- 8 Dec 2025
Central Bank of the Comoros communiqué
States that the AOFA and Anjouan Corporate Services are not recognised in the Union and that online gambling and sports betting licences are not authorised on the national territory, none having been issued. Posted on the Bank's site on 24 February 2026.
Source: 5
- May 2024
GIABA evaluation of the Union
The evaluation report records that gambling is prohibited in the Union (criterion 28.1) and treats casinos as not applicable for AML purposes.
Source: 16
- 29 Dec 2020
Union Penal Code, Loi 20-038/AU
Chapter V on games of chance (arts. 201-204) and arts. 476-477 on unauthorised online gambling and payments for it; promulgated in February 2021.
Source: 4
- 2005
The Anjouan 2005 Acts
Anjouan Gaming and the AOFA state four 2005 Acts as the basis of their regime: the Computer Gaming Licensing Act 007, the Offshore Finance Authority Act 003, the International Business Companies Act 004 and the Money Laundering (Prevention) Act 008. The gaming Act itself is not published and is not covered in this edition.
Source: 7
Operator myths vs reality in the Comoros
Common assumptions about gambling licensing that turn out to be wrong in practice.
- MythAn Anjouan licence is accepted in the Union of the Comoros.Reality
The Central Bank of the Comoros stated on 8 December 2025 that the AOFA and Anjouan Corporate Services are not recognised in the Union and that no online gambling or sports betting licence has been issued nationally. The Comoros is itself an excluded territory in the licence conditions (s. 2).
- MythThe licence conditions are law, so the licence is fully documented.Reality
The Computer Gaming Licensing Act 007 of 2005 is not published on Anjouan Gaming's site or the AOFA's Acts page, and the regulator cites it under three titles. The conditions, codes and guides are the regulator's own instruments; the Code of Conduct binds only to the extent adopted by the AOFA and the Website Compliance guide does not itself amend a licence condition.
- MythThe licence comes with a 0% tax rate.
Markets that work like Comoros
Compared on what our records hold for each country: whether online casino, betting, poker and lottery are licensed, state-run or banned, the licensing model, what the operator tax is levied on and its band, how most advertising channels are treated, and how foreign licences are treated. A point we hold for only one of the two countries counts for nothing.
Methodology & sources
Our Deep AI Scan took Comoros through all 201 questions of our regulatory checklist, from 54 official documents, read on 10 Nov 2026. Our research team then traced every figure on this page to the document and sentence that states it. The full research report is due to go to our compliance team. Where a fact rests on a press report or a law-firm summary rather than an official document, the page says so.
Documents cited on this page
- 1Anjouan Gaming (ANJ Management Ltd.): regulatory-guidance.zip (October 2026): KYC and AML Code, Code of Conduct, Responsible Gaming Guidelines, Website Compliance, Application Process
- 2Anjouan Gaming: Enforcement Policy
- 3Anjouan Gaming (ANJ Management Ltd.): 2026 Licence Conditions v5 (October 2026)
- 4Loi n°20-038/AU of 29 December 2020 (Code pénal), promulgated by Décret n°21-018/PR
- 5Banque Centrale des Comores: communiqué of 8 December 2025
- 6Anjouan Gaming: Enforcement Update, Quarterly Compliance Review Summary, 1 April 2026
- 7Anjouan Gaming: About the Authority, Overview
- 8Anjouan Gaming: Fees
- 9Anjouan Gaming: Licence Types
- 10Spelinspektionen (Sweden), Lägesbild: onlinespel utanför den licensierade marknaden, 20 March 2025 (Dnr 24Si2002)
- 11Krajský súd v Bratislave, príkaz 2Ntn/23/2025 of 28 Oct 2025 (on the application of the URHH)
- 12Valsts ieņēmumu dienests (Latvia), list of blocked (unlicensed) interactive gambling companies
- 13Massachusetts Attorney General, cease-and-desist letter to Harp Media B.V. and Hove Media d/b/a Bovada, 3 Oct 2024
- 14Tennessee Sports Wagering Council, news of 9 Sep 2026: cease-and-desist shuts down another illegal sportsbook
- 15Anjouan Gaming: Regulatory Notices & Updates
- 16GIABA: Mutual Evaluation Report of the Union of the Comoros (May 2024)
- 17Anjouan International Business Companies Act 004 of 2005
The 10 documents this page relies on most
- Anjouan Gaming: regulatory-guidance.zip (October 2026), file 'Anjouan-Application-Process-October-2026.pdf' (ANJ Management Ltd., revised 13 October 2026)Regulator
- Anjouan Gaming: 2026 Licence Conditions v5 Final (ANJ Management Ltd., October 2026), PDFRegulator
- Anjouan Gaming: Licensing > Fees (page, read 10 November 2026)Regulator
- Banque Centrale des Comores, communiqué of 8 December 2025 (PDF, OCR; page 'Communiqué du 8 décembre 2025', posted 24 February 2026)Regulator
- Anjouan Gaming, Regulatory StandardsRegulator
- Anjouan Gaming: Licence Types (page, read 10 November 2026)Regulator
- International Business Companies Act 004 of 2005 (AOFA site, 2.pdf)Law
- Anjouan Gaming: forms-10-26.zip, '2026 Interactive License Application v5' (September 2026), with the Personal Information Form v32 and UBO Declaration v2.0Regulator
- Loi n°20-038/AU du 29 décembre 2020 portant Code pénal, promulgated by Décret n°21-018/PR (Ministère de la Justice des Comores, 133-page scan, read by OCR)Law
- AOFA: 'Online Gaming' (page, read 10 November 2026)Regulator
Also cited on this page
- Anjouan Gaming: Public Register, License Register
- Anjouan Gaming: Player Complaint Process (Third-Party Complaint Policy)
- Anjouan Gaming: Authorized ADR Providers
54 documents in all. Request the full research report for every source, answer by answer.