The Gaming Licence Compliance Calendar: MGA, Nevis, Curaçao, and Anjouan

When you receive your gaming licence, nobody hands you a calendar. There is no single document from any regulator that says here is what you owe, file, submit, and renew, and when. You are expected to know theThis is the calendar I wish someone had given me.

The Gaming Licence Compliance Calendar: MGA, Curaçao, and Anjouan
The Gaming Licence Compliance Calendar: MGA, Curaçao, and Anjouan
Table of Content

When you receive your gaming licence, nobody hands you a calendar. There is no single document from any regulator that says here is what you owe, file, submit, and renew, and when. You are expected to know.

This is the calendar I wish someone had given me the first time I worked through a licensing cycle. It covers MGA, Curaçao, Anjouan, and Nevis, structured by obligation type, with the exact deadlines that matter. Bookmark it. Come back to it every quarter.


MGA Compliance Calendar

The MGA is the most demanding of the four jurisdictions covered here. The reporting cycle is continuous, the deadlines are hard, and missed submissions are published in enforcement notices.

Monthly Obligations (Due by the 20th of the Following Month)

Every MGA licensee submits a Tax Report each month. B2C licensees also submit a Player Funds Report and an ADR Report by the same date. All three reports share the same deadline, the 20th of the month following the reporting period.

The Player Funds Report must include supporting bank statement evidence. The ADR Report requires dispute details and rulings. These are not administrative boxes to tick. The MGA reviews them and will act on anomalies.

One operational note: if your finance team treats these three reports as separate workflows with separate owners, they will eventually miss one. All three are due on the same date, every month. They should be managed as a single monthly deliverable.

Compliance contribution is also payable monthly, calculated on GGR, due by the 20th of the following month.

Annual Fee

The annual licence fee is due by 15 January. This applies to all MGA licensees. Set a December calendar reminder to confirm the invoice has been received and payment is queued.

Industry Performance Returns (IPR)

The IPR is submitted twice a year and covers different data windows:

  • H1 data: due by 7 September
  • H2 data: due by 28 February

These are aggregate performance reports. They are separate from the monthly Tax Report and operate on their own schedule.

Financial Reporting (2025 Framework)

The MGA updated its financial reporting requirements in 2025. The current structure is:

  • Interim Financial Report: due within 2 months of mid-year end
  • Annual Financial Report: due within 2 months of year end (this replaces the former Interim Financial Statements requirement)
  • Audited Financial Statements: due within 6 months of year end (prepared under IFRS and audited to ISA; player funds must be shown separately)
  • Auditor Player Funds and Gaming Revenue Declaration plus Auditor's Management Letter: due within 9 months of year end

If your year end is 31 December, the practical schedule looks like this: Interim Financial Report by end of February, Annual Financial Report by end of February, Audited Financials by 30 June, Auditor declarations by 30 September.

Year 1 Compliance Audit

The MGA typically issues notice for a Compliance Audit after your first year of operation. Once notice is issued, you have 90 days to complete it. The audit is conducted by an MGA-approved Authorised Service Provider against your live operational environment.

This is not a desk review. The auditor will assess whether your live operation matches your declared System Documentation. If there is drift between your policies and your actual processes, this is where it surfaces.

MGA Penalties

The MGA publishes enforcement actions. Missed reports are visible and penalised. Fines run from EUR 10,000 to EUR 500,000 depending on the nature and frequency of the breach.


Curaçao Compliance Calendar

The Curaçao framework is lighter than MGA in terms of monthly reporting, but it has one absolute deadline that suspends licences without warning.

Annual Fee (Absolute Deadline)

The annual fee of EUR 47,450 is split across two invoices, both due by 15 January:

  • EUR 24,490 to the National Treasury
  • EUR 22,960 to the CGA

Non-payment of either invoice triggers a suspension process. There is no grace period. Set a reminder in November to confirm both invoices have arrived and are scheduled for payment before the deadline.

Quarterly Obligations

Operational reports are submitted to the CGA portal each quarter. These cover your business activity, player data, and any material changes to operations during the period.

Every Six Months

Your Operations Manual must be reviewed and updated bi-annually, or immediately on any material change. The CGA can request the current version with 5 working days' notice. If your manual still reflects the business you described at application rather than the business you actually run, that is a compliance gap.

Ongoing Obligations (No Fixed Deadline, Always Active)

  • AML transaction monitoring must be active at all times, from the first player transaction
  • Suspicious Transaction Reports (STRs) are filed via goAML without delay on confirmed suspicion
  • Complaints inbox must be actively monitored and responded to
  • Self-exclusion requests must be processed immediately on receipt

On Change (Act Before or Immediately After)

  • AML policy updates must be uploaded to the CGA portal when the policy changes
  • UBO and key person changes must be notified to the CGA
  • New domains must be registered on the CGA portal before going live

Annual Financial Statements

Audited financial statements are due by 30 June each year, prepared by a Curaçao-registered accountant. Operators claiming the GGR under ANG 20 million substance exemption must also submit semi-annual financial reports.


Anjouan Compliance Calendar

Anjouan has the lightest formal reporting burden of the four jurisdictions. There is no confirmed mandatory monthly or quarterly report cycle. What Anjouan does have is a hard annual renewal that, if missed, causes the licence to lapse immediately.

The Annual Renewal (Most Important Date in Your Calendar)

The Anjouan licence runs for one year. Start the renewal process 3 to 4 weeks before your expiry date. The process takes 5 to 10 business days when the document pack is complete.

Do not rely on the 3-week window. Set a calendar reminder 6 weeks before expiry, not 4. If any document needs chasing, a 4-week runway is not enough. A 6-week runway gives you time to absorb delays.

At renewal, you will need:

  • Updated KYC documents for all directors and UBOs, dated within 90 days of submission
  • Updated policies if anything has changed since the previous renewal
  • Current RNG certificates
  • Disclosure of any changes to corporate structure, directors, shareholders, domains, or game providers
  • Renewal fee: EUR 13,300 to EUR 17,000 depending on your structure

The 90-day KYC requirement is the one that catches operators out. You cannot prepare the renewal pack 6 months in advance and leave it on a shelf. Police clearance certificates and banker's references must be ordered close to the renewal date, not well in advance of it.

Ongoing Obligations (Always Active)

  • AML and KYC monitoring active at all times
  • Self-exclusion requests reported to Anjouan Gaming within 1 working day of receipt
  • Complaints handled internally within 30 days before escalation to ADR. ADR participation is mandatory.
  • Complaints and self-exclusion inbox must be actively monitored

Annual (No Fixed Calendar Date)

  • AML and KYC programme review completed each year
  • Staff AML training completed and recorded annually

Nevis (NOGA) Compliance Calendar

The Nevis Online Gaming Ordinance was passed in April 2025 and NOGA is still developing its regulatory framework. That means the current reporting burden is light, but operators should expect it to become more prescriptive over time. What NOGA does have, right now, is a set of clear licence conditions with specific notification windows that are already enforceable.

Annual Licence Renewal

The NOGA licence runs for one year. The renewal fee is EUR 28,000, the same rate as the initial licence. NOGA has not published a specific renewal timeline or lead time in its current documentation, but I would apply the same practical advice as Anjouan: start the process 6 weeks before expiry, not 4. If NOGA requests updated documentation or the payment transfer takes longer than expected, the extra time gives you room.

Unlike Anjouan, NOGA does not currently specify a 90-day freshness window for KYC documents at renewal. That said, submitting stale documents to any regulator is a bad habit. Keep them current.

Periodic Reporting to NOGA (Licence Condition 7)

Here is where Nevis differs from the other three. NOGA Licence Condition 7 requires licensees to submit reports at intervals and in a format determined by NOGA, but those intervals and formats have not yet been published. There is no confirmed monthly report, no confirmed quarterly submission, and no confirmed annual financial return specified in the current primary documents.

This will change. NOGA has the authority to define reporting requirements and will likely do so as the regulator matures. Operators should build internal reporting infrastructure that can accommodate a defined schedule when it arrives, rather than treating the current gap as permanent.

Financial Ratio Compliance (Licence Condition 8)

Operators must at all times satisfy the financial ratio requirements notified by NOGA. This is an ongoing obligation, not a periodic filing. You should maintain financial records sufficient to demonstrate compliance on request.

Notification Obligations (Fixed Windows)

NOGA's licence conditions include several event-driven notification obligations with specific deadlines. These are not periodic but they are binding:

  • Ownership change (5% or more): notify NOGA within 10 business days (Condition 14)
  • Serious incident: notify NOGA within 3 working days (Condition 16)
  • Licence suspended or terminated elsewhere: notify NOGA as soon as practicable (Condition 15)
  • Material change to application information: notify NOGA as soon as reasonably practicable (Condition 17)
  • ADR provider change: notify NOGA (Condition 13)

NOGA Meetings (Licence Condition 18)

NOGA can request a meeting with 5 business days' notice. You must have a representative available who can attend and respond to their questions. This is worth knowing about in advance so you are not caught off guard.

Ongoing Obligations (Always Active)

  • AML monitoring and reporting active at all times, with suspicious transaction reports filed via the Local Reporting Officer to the FSRC (Condition 9)
  • ADR provider contract maintained throughout the licence term at operator's cost (Condition 13)
  • NOGA site seal visible in the website footer at all times, unmodified (Condition 12)
  • Compliance Officer reporting to NOGA regularly on gaming compliance matters (Condition 10)
  • Local Reporting Officer registered with the FSRC and maintaining AML/CFT reporting to FSRC (Condition 11)
  • Complaints inbox actively monitored
  • Self-exclusion requests processed on receipt

Nevis Penalties

Fines can reach USD 50,000 for individuals and USD 150,000 for companies for breaches of licence conditions. These figures come from secondary sources however. We'll get confirmation of the scope of penalties from the Regulator in due course.


The Deadlines That Catch Operators Out

After working through multiple licensing cycles, these are the five points where operators most consistently run into difficulty.

MGA January fee: The annual fee is due by 15 January every year without exception. Operators who are in the middle of year-end reporting, holiday periods, and budget planning regularly let this slip. Put the reminder in November and mark it as non-negotiable.

MGA monthly 20th: Three separate reports share one deadline. Tax Report, Player Funds Report, ADR Report. All due on the 20th. If these are owned by different people with different internal processes, the risk of a misfire is high. Treat them as one coordinated monthly close.

Curaçao Operations Manual: The bi-annual review trips up operators who drafted the manual for their application and never returned to it. The manual should reflect how you actually operate. The CGA can ask for the current version with 5 working days' notice. That is not a lot of time to locate, update, and submit a document you have not looked at in a year.

Anjouan KYC at renewal: You cannot stockpile these documents. Fresh police clearance certificates and banker's references need to be ordered close to the renewal window. Start the process 6 weeks out, not 4.

Nevis notification windows: Because NOGA's periodic reporting is still undefined, operators can fall into the habit of treating Nevis as hands-off. It is not. The event-driven notification obligations are already live: 10 business days for ownership changes, 3 working days for serious incidents. If you do not have a process to capture these events internally and route them to someone who can notify NOGA within the window, the deadline will pass before you realise it applies.


Why Calendar Management Gets Outsourced

Writing the policies to secure the licence is a project. It has a start date, a submission date, and an end point. Staying compliant with the calendar is a different type of work entirely. It has no end date. It runs for as long as you hold the licence.

Most operators who start managing compliance in-house eventually move the calendar management to a specialist service. Not because the individual tasks are technically complex, but because the cumulative weight of tracking, preparing, filing, and verifying across multiple deadlines, multiple report types, and changing regulatory requirements requires sustained attention. Early-stage operators rarely have that capacity available in-house.

The operators who handle it well tend to have one of two things: a dedicated compliance resource whose primary role is calendar management, or an external arrangement that takes ownership of the calendar.

With four jurisdictions now on the table, that weight increases. MGA alone generates a dozen or more discrete filing obligations per year. Adding Curaçao quarterly reports, Anjouan renewal preparation, and Nevis's evolving notification regime means the calendar gets complex faster than most small teams expect.


What ICOS's Maintenance Arrangement Covers

After licence issuance, ICOS offers a fixed-price monthly arrangement that covers the ongoing calendar. This includes regulatory update monitoring, monthly and quarterly report filing for MGA and Curaçao, policy updates when frameworks change, annual renewal management for Anjouan and Nevis, and responding to regulator information requests as they arise.

For Nevis specifically, the maintenance arrangement includes monitoring NOGA for new reporting requirements as the framework matures, managing the annual renewal, and tracking the notification obligations so you do not miss a window.

If you want to see what the maintenance arrangement costs for your jurisdiction, the intake form takes three minutes. You will have a number within 24 hours.

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