Anjouan IBC Formation: The Step That Comes Before the Licence Application

Most guides to the Anjouan gaming licence start at the licence application form. They skip over the fact that you cannot submit that application without a company that already exists. The Anjouan IBC must be incorporated first.

Anjouan IBC Formation: The Step That Comes Before the Licence Application
Anjouan IBC Formation: The Step That Comes Before the Licence Application
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Most guides to the Anjouan gaming licence start at the licence application form. They skip over the fact that you cannot submit that application without a company that already exists. The Anjouan IBC must be incorporated first. These are two separate processes, with two separate sets of documents, and treating them as one is how operators lose two to three weeks at the very start of the process.

This article covers the company formation stage specifically. If you are already incorporated and looking at the licence application itself, that is a separate guide.


What Is an Anjouan IBC?

An Anjouan IBC is an International Business Company registered under the Anjouan Offshore Finance Authority. It is the standard legal entity used by gaming operators who hold or are applying for an Anjouan gaming licence. For gaming purposes, there is no alternative entity type that ALSI accepts.

The company name must end in "Limited", "Ltd." or "Inc." No other suffixes are permitted. The standard share structure is 10,000 shares at USD 1 par value. This is a paper structure and there is no requirement for you to deposit $10,000 as a minimal capital requirement.

No physical office in Anjouan is required. No local directors are required. The company can be managed entirely from abroad.


The Two-Stage Process Most Guides Do Not Mention

Something rarely acknowledged in third-party write-ups is that the Anjouan gaming licence process is two distinct stages, not one.

Stage 1 is the Company Intake Form. This is submitted to ALSI to incorporate the IBC. Once ALSI processes it, you receive a registration number and an incorporation date. That is your company.

Stage 2 is the Internet Gaming Licence Application. This is a separate submission. You cannot complete it without the registration number and incorporation date from Stage 1, because those details appear in multiple places throughout the application.

Most operators and, frankly, most third-party agents present this as a single process. They are not the same thing and should not be managed as if they are. Starting licence application document preparation before the IBC is registered does not save time in practice.


What the Company Intake Form Actually Requires

The Company Intake Form collects three preferred company names in priority order, shareholder details, UBO (Ultimate Beneficial Owner) details, and director details. It accepts up to four individual shareholders, up to four corporate shareholders, up to four UBOs, and up to four directors. Each person's country of tax residency is also required.

For every UBO and director, you will need to provide:

  • A certified copy of their passport
  • Proof of address dated within the last 90 days
  • A police clearance certificate from their country of residence, also within 90 days
  • A CV
  • A banker's reference (covering at least a two-year relationship)
  • A professional reference from an accountant or solicitor (also two years)

These are the same categories of documents you will need again for the licence application, which is worth bearing in mind when you are collecting them. Getting originals certified once and organising them properly from the start avoids having to go back to people a second time.

There is also a separate ALSI form called the UBO Declaration. Each UBO must sign this individually. It is a declaration confirming tax compliance on foreign income and that the funds behind the business are not derived from illegal activity. ALSI accepts digital signatures only. Wet ink signatures are not accepted on any ALSI form, so do not waste time posting documents.


The Registered Agent Requirement

Every Anjouan IBC must have a registered address in Anjouan. You cannot self-provide this as a foreign applicant. Engaging a local registered agent is mandatory, and it is the one element of Anjouan IBC formation that genuinely requires an external party.

The registered agent provides the legal address and handles the filing with the Registrar of International Business Companies on your behalf. Beyond that, how much you need from an external party depends on your situation. ALSI can itself handle application submission, so operators do not necessarily need to engage a separate corporate services firm for document preparation and submission. The non-negotiable external element is specifically the registered address in Anjouan.

On cost: a minimal registered address service typically runs EUR 1,000 to 1,500 per year. Full corporate services packages that include document handling, compliance support, and ongoing secretarial services run EUR 3,000 and above annually. What you need depends on your internal capacity and how much you want managed externally.


Naming Rules and Why They Matter More Than People Think

You submit three preferred company names in priority order on the Company Intake Form. ALSI checks each name against the existing register of Anjouan IBCs. If all three are taken or too similar to existing registrations, the application stalls.

The name must end in "Limited", "Ltd." or "Inc." Beyond that, the practical rule is this: generic names are almost certainly taken. Names like Global Gaming Limited, First Casino Ltd, or anything that could plausibly have been registered by dozens of operators before you should not feature on your shortlist.

The gaming licence will reference the company name directly. If you later want to operate under a different brand name, that is done through a separate trading name or domain, but the licence itself is issued to the company. Give the name more thought than most operators do at this stage. Three genuinely distinct names that you would actually be comfortable with commercially is the right approach.


Timeline and Cost for IBC Formation

Once documents are complete and submitted, ALSI processes IBC formation in three to five business days. This assumes no back-and-forth over document quality or missing information. If documents are incomplete or certified incorrectly, that clock resets.

The government registration fee is approximately USD 200 to 300. The registered agent annual fee is EUR 1,000 to 1,500 for a minimal service, or included within a full corporate package. Beyond that, any compliance support or document preparation fees depend on whether you are handling that internally or through a third party.


What Comes After Incorporation

Once the IBC is registered, you have three things: a confirmed company name, a registration number, and an incorporation date. Those three pieces of information are what the licence application needs to proceed.

The licence application is a substantially larger document pack. It includes your AML policy, KYC procedures, responsible gaming policy, a business plan, technical documentation, game content provider details, proof of domain ownership, and the personal due diligence documents for all directors and UBOs. Some of those personal documents overlap with what you submitted for the IBC, which is one of the practical arguments for organising your document set carefully from the start rather than treating each stage as independent.

The overlap is not automatic. The IBC formation documents go to the Registrar. The licence application documents go to ALSI for the gaming licence. You will need to confirm with ALSI at the time of application whether documents submitted for the IBC stage satisfy the personal due diligence requirements for the licence stage, or whether fresh copies are needed. Policies on this can shift, so ask directly rather than assuming.


Getting This Right From the Start

Anjouan IBC formation is not overly complex. The registered agent is the one external dependency you cannot avoid. Document requirements for UBOs and directors are straightforward but time-consuming to gather, and gathering them once properly is considerably better than gathering them twice.

If you go into the process knowing it is two stages, that all ALSI forms require digital signatures, that you need three genuinely distinct name options prepared, and that personal due diligence documents need to be dated within 90 days, you will avoid the delays that catch most first-time applicants out.


ICOS manages the full formation-to-licence process for Anjouan operators. Fixed pricing, no surprises. If you want to know what it costs for your specific situation, the intake form takes three minutes.

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