MGA Concludes Recognition Notice Consultation and Refines Foreign Licence Proposals

The Malta Gaming Authority (MGA) said on 29 October 2026 that it has concluded its targeted consultation on proposed updates to the Recognition Notice framework, refining its proposals after reviewing industry feedback.

The regulator said the feedback led to "a number of refinements" so that its approach remains proportionate, risk-based and practical. A Feedback Statement setting out the feedback received, the MGA's position and the way forward has been sent to Recognition Notice (RN) holders and their representatives. The MGA added that it will share more on the practical application of specific requirements "in due course".

What the MGA announced

The consultation closed out six months after it began. The MGA issued the targeted consultation on 29 April 2026, saying the proposals followed an internal review. It described them as aligned with Malta's latest National Risk Assessment (NRA) and the National Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Strategy 2024–2026.

The stated aim was to strengthen assessment at the authorisation stage and to introduce a "more structured and proportionate approach to ongoing monitoring" of RN holders.

How a Recognition Notice works today

An RN is a certificate recognising an authorisation issued by another EU or European Economic Area (EEA) state, or by a state deemed to offer largely equivalent safeguards. It has the same effect as an MGA authorisation for providing a gaming service or supply in or from Malta. The route matters to operators and suppliers that already hold a licence elsewhere and want a Maltese presence without a full local licence.

The MGA's licensee hub sets out the current mechanics:

The conclusion of the consultation does not change these published mechanics on its own. Any adjustments will depend on the Feedback Statement and the follow-up guidance the MGA has promised.

What the refinements mean: Szilaghi Consulting's view

The Feedback Statement went to RN holders and their representatives, not to the public. Its main points were first reported by NEXT.io: ownership disclosure cut back to ultimate beneficial owner (UBO) information, many obligations lifted for business-to-business (B2B) suppliers, no standardized legal opinion template, a focus on material fitness and licensing matters instead of a five-year regulatory history, deposits reported in predefined bands, and data collection for the 2025 reporting period limited to business-to-consumer (B2C) operators.

Szilaghi Consulting, which handles MGA licensing and Recognition Notice work, reads those changes this way:

Szilaghi Consulting also points to the open question on the MGA's statutory powers. According to the same reporting, some stakeholders questioned whether the MGA can request certain information under the current rules, and the regulator acknowledged some requirements may need changes to the framework. If that happens, parts of the regime will depend on new legislation, so timing is uncertain.

The MGA itself has said only that it refined the proposals and will publish more on practical application. Until it does, the reported changes describe the direction of travel, not final rules.

Context for operators and suppliers

The RN review sits within a year of active supervision in Malta. Earlier this year the regulator moved against a licensee, as covered in the MGA's cancellation of the Winzon licence. Cross-border questions have been a recurring theme for the authority, which previously repealed its UK-EU exit guidance note after Brexit, and for lawmakers, as in earlier proposed legislation on foreign accountability.

Cost is also on operators' minds. Malta's budget discussions included an indirect gaming tax proposal for 2026, which adds to the picture for groups weighing where to hold licences and how to structure them.

Szilaghi Consulting's practical advice for current RN holders and applicants:

• Read the Feedback Statement addressed to RN holders and their representatives.
• Map the ownership, payment and reporting data the MGA may request against existing internal records.
• Watch for the MGA's follow-up on how specific requirements will apply, including timing for any reporting.
• Check that the certified legal opinion and the issuing regulator's good-standing letter will be ready for the next annual review.

For groups deciding between a full MGA licence and a Recognition Notice, Szilaghi Consulting's guides cover the Malta licence and which jurisdictions recognise foreign gambling licences.

Status reviewed on 31 October 2026. The consultation dates, purpose and RN mechanics come from MGA publications; the specific refinements were first reported by NEXT.io, and the analysis is Szilaghi Consulting's. More regulation news and EMEA coverage.