A number of important changes to the Maltese legislative framework regulating the gaming industry were recently implemented.

The following is an overview of three key takeaways of the amendments made to the Gaming Authorisations and Compliance Directive (“the Directive”) and the MGA’s policy on the eligibility and ongoing competency criteria for key persons.

  1. Streamlining of key function roles

The list of the persons who are responsible to carry out the designated key functions, more commonly referred to as key functionaries or key persons, has been streamlined by the Malta Gaming Authority (“MGA”).

Prior to the implementation of these changes, B2C operators (remote gaming service licensees) were required to fill 15 key function roles, whereas the number of key function roles for B2B operators (critical gaming supply licensees) stood at 9.

The new list of key functionaries for both B2B and B2C operators is as follows:

Key function role B2C Operator B2B Operator
Chief Executive Officer
Gaming Operations / Chief Operations Officer
Chief Legal Officer / Legal Affairs
Data Protection / DPO
Compliance Officer
Chief Technology Officer
Internal Audit



An important amendment to the Directive provides that when no person is approved by the MGA to hold a key function role, the responsibility for such key function will automatically vest in the director of the particular B2B or B2C operator.

  1. Emphasis on competence & continuous professional development

In addition to being subjected to a fit and proper test (which must be satisfied on an ongoing basis), applicants for a key functionary role must prove that they possess an appropriate level of knowledge, professional expertise, and experience.

The competence assessment is two-pronged and involves a review of the (i) practical and professional experience gained through previous occupations and (ii) academic qualifications.  As part of the MGA’s assessment, the applicant may also be required to attend an interview with the MGA.

The importance of continuous professional development cannot be underestimated, particularly in an industry where changes are regular and constant.  Cognizant of this reality, the new framework also introduces the requirement of ongoing training (in the form of CPD hours), so as to ensure that key persons remain proficient and keep abreast of the developments in their respective fields.

  1. Sports integrity

Sports integrity is high on the agenda of the MGA.  As of 20 October 2021, the duty to notify the MGA in the case of bets being voided owing to the suspicion of manipulation of a sporting event has been extended also to B2B Operators.

This article is not intended to constitute legal advice and neither does it exhaust all relevant aspects of the topic


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