How to get a gambling licence in the Comoros: fees and steps

Anjouan Gaming describes two licence categories, each issued to a company. One B2C licence covers a range of verticals, set in the conditions attached to each licence; there is no product-by-product licence and no cap on the number of licences.

• Each additional domain on a B2C licence costs EUR 500 per licensing cycle; only approved domains may operate, and a revoked licence's domains are permanently blocked from any other licence.
• The register printed 1,087 B2C and 223 B2B licences on 6 November 2026 (23 of them both); Anjouan Gaming's own count is close to 1,500 active licences (14 July 2026).
• A B2C licence does not authorise supplying platforms or content to other operators, and suppliers need an Anjouan B2B licence or recognition certificate (condition 14).
• Lottery, esports, virtual betting, live casino and slots are not named separately in the documents; ask Anjouan Gaming what a given licence authorises.

Laws that apply

• Computer Gaming Licensing Act 007 of 2005 (the Act the licence conditions require compliance with; not published by the regulator and not covered in this edition)
• Offshore Finance Authority Act 003 of 2005 and International Business Companies Act 004 of 2005 (the AOFA's powers and the company vehicle)
• Money Laundering (Prevention) Act 008 of 2005 (applies to "financial institutions"; gaming is not listed)
• Anjouan Gaming Licence Conditions v5 (October 2026) and the KYC and AML Code of Conduct (final edition, 13 October 2026)
• Union of the Comoros: Penal Code, Loi 20-038/AU of 29 December 2020 (arts. 201-204, 476-477), which applies to the Comoros itself

The applicant is a legal entity in Anjouan or in another jurisdiction Anjouan Gaming accepts; a foreign entity's eligibility is confirmed under programme policy and incorporation elsewhere does not guarantee acceptance. No nationality bar is printed.

• An Anjouan company is an International Business Company with a registered office and a licensed registered agent in Anjouan; no operating office or staff on the island is required, and the licence itself needs no local bank account or local director.
• Directors, beneficial owners and key persons give government ID, proof of address, police clearance and a CV, and are screened against sanctions, politically exposed person and adverse-media lists; the licence is not issued where screening leaves unresolved concerns.
• The application shows the full ownership chain to the ultimate beneficial owners, any nominee, trust or foundation, holdings kept below the 10% notification threshold, source of wealth and source of funds; citizenship-by-investment status does not replace due diligence.
• No minimum share capital is stated; the applicant must show adequate financial resources, and audited statements or bank references may be asked for. No bank guarantee, bond or deposit is required.
• A former holder whose licence was revoked will not be considered again.

• Excluded territories (licence conditions s. 2): Australia, Austria, the Comoros, France, Germany, the Netherlands, Spain, the United Kingdom and the United States, a non-exhaustive list that also covers sanctioned and FATF call-for-action jurisdictions. Licensees must not knowingly target their residents and should implement effective GEO-IP blocking.
• Games and random number generators are tested by an independent laboratory approved by Anjouan Gaming; GLI-19 and GLI-33 are named where the product needs them. No laboratory list is published and no local server is required.
• Identity is verified at the earliest of EUR 3,000 of lifetime deposits (or any other qualifying transaction of EUR 3,000, single or linked), the first withdrawal request or suspicion, and before any payout.
• Suspicious activity reports go to the AOFA-designated channel promptly and no later than 24 hours after suspicion arises; currency transaction reports are weekly for movements of USD 10,000 or more once the KYC and AML Code takes effect; records are kept for at least five years.
• An MLRO and deputy, a Key Person and a Compliance Officer are appointed; the AML programme is audited independently every year.
• Ownership changes of 10% or more are notified within 10 business days; domain changes need approval; the interactive licence seal is shown in the site footer.
• The operator joins an approved ADR provider at its own cost, and players complain to the operator first; Anjouan Gaming does not decide player disputes.

The regulator's schedule lists fixed euro fees, payable in euros and subject to periodic review. No gambling tax appears in Anjouan Gaming's published documents; the Union's tax code was not covered.

• The schedule does not say whether the first year also carries the renewal fee; if it did, the first year would be EUR 35,656.
• Not priced by the regulator: incorporation and registered-agent charges, independent testing, ADR participation and administrative-service charges for domain changes, amendments and replacement certificates.
• The IBC Act 004 of 2005 exempts a compliant international business company from corporate, income, withholding and capital gains tax on income from outside the State (s. 99); the Union's position on that exemption is not stated. VAT and winnings tax are not covered in this edition.

• No channel ban or pre-approval applies to licensees' advertising; it must not target under-age persons or knowingly target residents of the excluded territories, and it must carry responsible gaming messaging and prominent bonus terms.
• The minimum age is 18, or the higher minimum in the player's jurisdiction. There is no national self-exclusion register: self-exclusion works operator by operator.
• Operators must offer deposit, loss and time limits and reality checks, and keep players' funds segregated from operational funds.
• In the Comoros itself, the Penal Code punishes players of games not authorised by law (art. 203: six months to two years and KMF 50,000 to 200,000), bans payments for illicit gambling and obliges banks to notify violations (art. 477).

The route for a new applicant as Anjouan Gaming describes it, as of 10 November 2026. Timing is an estimate, not a service guarantee.

1. 01

   Set up the entity

   Anjouan or an accepted jurisdiction

   Establish a legal entity; an Anjouan company needs a registered office and a licensed registered agent in Anjouan. Where incorporation services are requested, the corporate KYC and payment come first.

2. 02

   Prepare the file

   Documents and forms

   Gather certified corporate documents, the ownership chart, ID, police clearance and CVs for key persons, a business plan with three-year projections, platform and testing evidence, and the AML and responsible gaming policies; complete the application form, personal information form and UBO declaration.

3. 03

   Submit and pay

   Digital signature only

   Send the file through the authorised channel; wet-ink signatures are not valid. Pay the non-refundable application fee and the licensing fees as the fee schedule directs.

4. 04

   Due diligence

   About six weeks

   Allow about six weeks on average for due diligence, background investigation and assessment once a complete application and payment are received; complex structures or missing documents extend it. No fast track is implied.

5. 05

   Licence, seal and domains

   EUR 17,828

   On approval the licence is issued for the approved brands and domains; show the interactive seal in the footer and operate only on approved domains. Platform migrations, new products and new domains need approval first.

6. 06

   Renew every year

   EUR 17,828

   Submit the annual renewal application, updated documents and fees before expiry; renewal is not automatic, and beneficial ownership disclosure under condition 15 applies at renewal.

Tier-ordered: official government first, then practitioner, then trade media. Every primary figure was read from the in-force text on 10 Nov 2026.