Nevis is the newest jurisdiction in the offshore gaming licence market. The Nevis Online Gaming Ordinance was passed by the Nevis Island Assembly on 29 April 2025, and the Nevis Online Gaming Authority (NOGA) began accepting licence applications shortly after.

I added Nevis to the ICOS portfolio in early 2026 after reviewing the primary regulatory documents. The short version: it fills a genuine gap in the market between Anjouan and Curaçao, specifically for operators who need better banking and payment processor access than Anjouan provides but cannot justify the substance requirements and cost of a Curaçao LOK licence.

This article covers the full picture: what the licence costs, what the application process looks like, what you need to prepare, who it is right for, and where the limitations are.

Why Nevis Matters (The FATF Whitelist Argument)

Before getting into the mechanics, it is worth understanding the one fact that makes Nevis different from Anjouan in a way that actually affects your business.

The Federation of St Kitts and Nevis is a FATF whitelist member through its membership in CFATF (Caribbean Financial Action Task Force). Anjouan is not. Under the FATF 2024 Mutual Evaluation Report, gambling in the Comoros (which includes Anjouan) is prohibited under national law. That creates real friction with payment processors and banking relationships.

For Nevis, FATF compliance is inherited from the sovereign state. GBO Licensing rates Nevis-licensed operators at the same "High" PSP and banking access tier as Curaçao. That is the single most important commercial difference between the two jurisdictions at this price point.

If your business model depends on reliable fiat card processing and you are working within the EUR 30,000 to EUR 50,000 budget range, this is why Nevis exists as an option.

What the Licence Covers

NOGA issues two licence categories: B2C for operators and B2B for suppliers. Both are separate applications with separate fees.

The B2C licence covers all gaming verticals under a single instrument: online casino, poker, sports betting (fixed odds, in-play, virtual, eSports), lottery, and any other form of online gaming NOGA approves. This is the same single-licence model as Anjouan and Curaçao. MGA, by contrast, requires different approval types for different game verticals.

The licence covers up to two operational domains by default. Additional domains cost EUR 750 each per licensing cycle. Sub-domains are EUR 35 each, dropping to EUR 15 when you submit 50 or more.

White-label operations require both a B2C and B2B licence plus separate NOGA approval. That is a more prescriptive approach than Anjouan, which does not require separate white-label approval.

The licence term is one year, renewable annually. Same as Anjouan. Contrast with Curaçao (indefinite) and MGA (10 years).

Sublicensing is strictly prohibited. Licences are non-transferable.

What It Costs: The Full Breakdown

NOGA Fees

There is no GGR tax, no corporate income tax on offshore income, no capital gains tax, and no dividends tax. The EUR 28,000 annual fee is the regulatory cost, regardless of revenue.

Corporate Setup Costs

Year 1 Total

That excludes key employee registrations, optional application support, domain fees, and any legal or advisory costs.

Year 2 and Beyond

For comparison: Anjouan sits at approximately EUR 22,000 in Year 1 (standard structure). Curaçao is EUR 52,000 and above. MGA is EUR 80,000 and above.

Nevis lands in the middle ground between Anjouan and Curaçao, which is exactly where it is positioned commercially.

The Application Process: Step by Step

Before You Apply

You need a Nevis-registered company before you can submit a licence application. NOGA accepts two entity types: an IBC (International Business Company) or an LLC (Limited Liability Company). Both require a licensed local registered agent in Nevis. Foreign-incorporated entities are not accepted.

Company formation takes 1 to 2 weeks including apostille of documents. The government registration fee is approximately USD 450. The registered agent annual fee runs USD 500 to USD 1,200. There is no minimum share capital.

IBC names must end in "Inc.", "Corp.", "Ltd." or similar. LLC names must end in "LLC" or "Limited Liability Company". Pick three distinct options because the register is checked for duplicates and restricted words.

The Application Sequence

Step 1: Email NOGA at info@nevisgaming.com with the subject "License Application Request" and attach your Certificate of Incorporation. NOGA verifies it and sends payment instructions.

Step 2: Pay the EUR 28,000 application fee. This also serves as the first-year licence fee. It is non-refundable.

Step 3: NOGA grants portal access. You compile and submit your full documentation package through the online portal.

Step 4: NOGA reviews the application.

Step 5: Licence issued.

NOGA quotes 4 to 6 weeks from a complete submission. In practice, the end-to-end timeline from company formation through to licence issuance runs 8 to 12 weeks. The difference reflects the time spent on company registration, document collection, and portal submission before NOGA's internal review period begins.

What You Need to Submit

The document pack is substantial. Here is what NOGA requires.

Corporate Documents (notarised or apostilled)

• Certificate of Incorporation
• Articles of Incorporation
• Certificate of Incumbency (within last 3 months)
• Certificate of Good Standing (if company is over 1 year old)
• By-Laws
• Signed and dated organisational chart showing Directors, Shareholders, and UBOs
• For any parent companies or corporate directors: extracts, incumbency certificates, good standing certificates, and memorandum and articles of association

Personal Due Diligence (per Director and per Shareholder/UBO holding 10%+)

• Completed NOGA personal form
• Certified passport copy (within last 90 days; certifier must confirm photo is a true likeness)
• Proof of address (within 90 days; utility bill, government letter, or bank statement; mobile phone bills are not accepted)
• Bank reference letter (within 90 days; must confirm 2+ year relationship; on bank letterhead with signature and contact details; address must match proof of address). Alternative: an Account Confirmation Letter or 6 months of bank statements.
• Professional reference letter (within 90 days; from a licensed lawyer or accountant; 2+ year relationship; must be typed, not handwritten)
• Curriculum Vitae (in English; must include full name, email, phone, and address matching proof of address)

Business Plan

NOGA requires a "brief document, signed by the director" but the content requirements are not brief at all:

• Executive summary
• Marketing plan (target jurisdictions, customer segments, acquisition and retention strategy)
• Unique selling proposition
• Working history of Directors, Shareholders, and UBOs
• Financial projections: 3 years minimum with revenue forecasts, clearly stated assumptions, cost breakdowns, P&L and cash flow statements, and all sources of funding. NOGA's own requirements document states that "high-level summaries without supporting figures and underlying assumptions will not be considered sufficient."
• Key suppliers and platform providers
• Internal policy framework (data protection, financial controls, HR, customer success)
• Compliance framework (AML/CTF, responsible gambling, KYC, fraud prevention, internal monitoring)
• Legal entity details and corporate structure

That financial projections requirement is worth flagging. Three years of detailed P&L and cash flow with stated assumptions is more rigorous than most operators expect from a Tier 2 offshore jurisdiction. Take it seriously.

Compliance Policies (dated PDF format)

• KYC Policy
• Responsible Gaming Policy
• Underage Gaming Policy
• AML Policy

B2C Supporting Documents

• Financial statements (for existing companies)
• Completed Source of Funds / Source of Wealth form (NOGA standard form)
• Supporting SOF/SOW documentation
• Proof of domain ownership
• Geo-IP blocking for NOGA restricted jurisdictions
• Compliant Terms and Conditions (dated PDF)
• Independent RNG testing certificates (if software developed in-house)
• Copies of game/content provider agreements

The Key People You Need to Appoint

Compliance Officer

The Compliance Officer must be completely independent of the company structure. They cannot be a Director, Shareholder, or UBO. Their CV must show at least 1 to 2 years of relevant industry experience or an appropriate degree. Outsourcing is permitted, but the third-party provider must designate a specific named individual who meets the same independence and documentation requirements.

This independence rule is stricter than Anjouan. On Anjouan, the Compliance Officer role does not carry this formal prohibition on being a Director or UBO. On Nevis, it does.

Local Reporting Officer

A Local Reporting Officer must reside in Nevis and be registered with the Nevis Financial Services Regulatory Commission (FSRC). This person handles AML/CFT reporting obligations to the FSRC and is the bridge between your operation and local financial services compliance.

This is typically arranged through a registered agent in Nevis for approximately EUR 4,200 per year. It is not a full employee and not an office. It is a registered compliance contact.

Substance Requirements (or Lack of Them)

This is where Nevis sits closer to Anjouan than to Curaçao on the spectrum.

• No physical office in Nevis required
• No local directors required
• No local employees required
• Remote management from any jurisdiction is fully permitted
• No minimum share capital

The only local presence requirement is the Reporting Officer. For a solo founder or a small team, the operational overhead is a single service contract at EUR 4,200 per year. The jump from Anjouan (zero substance) to Nevis is that one line item. The jump from Nevis to Curaçao, by contrast, is a physical office, a resident managing director, and escalating key person obligations through to 2029.

How Nevis Handles Player Protection and KYC

NOGA's framework is principled rather than prescriptive at this stage. That means the obligations exist but the specifics are still developing.

KYC before any payout: NOGA Licence Condition 4 requires identity verification (government-issued photo ID and utility bill) before any withdrawal of any amount via any method. This is a first-payout trigger rather than a threshold-based trigger. When aggregate deposits reach USD 10,000, full enhanced KYC is required (Condition 5).

Responsible gaming: Operators must establish procedures to identify at-risk players and provide access to counselling and support organisations. No specific self-exclusion durations, markers of harm, or reality check pop-up requirements are mandated yet. Expect this to become more prescriptive as NOGA matures.

ADR: Mandatory. The operator bears the cost. The ADR provider must be NOGA-approved, and the contract must be maintained throughout the licence term.

Geo-blocking: Restricted countries list is set by NOGA. You must technically prevent residents of restricted countries from accessing the platform. This is both a compliance and a technical obligation.

What the Ongoing Compliance Calendar Looks Like

I covered this in detail in Article 10 (The Gaming Licence Compliance Calendar), but the summary for Nevis is:

Annual renewal: EUR 28,000. The licence runs for one year. Start the process 6 weeks before expiry.

Periodic reporting: NOGA Licence Condition 7 gives NOGA the authority to set reporting intervals and formats, but these have not yet been published. There is no confirmed monthly or quarterly report requirement at this stage. Build internal reporting infrastructure that can accommodate a schedule when it arrives.

Event-driven notifications: These are live now and enforceable. Ownership changes (5%+) within 10 business days. Serious incidents within 3 working days. Material changes to application information as soon as reasonably practicable. Licence actions in other jurisdictions as soon as practicable.

Always active: AML monitoring and STR filing via the Reporting Officer, ADR provider contract, site seal, Compliance Officer reports to NOGA, complaints and self-exclusion processing.

Who Nevis Is Right For

Good fit:

• Operators who need better payment processor and banking access than Anjouan provides but whose budget sits below the EUR 50,000 threshold where Curaçao becomes viable
• Operators who want FATF whitelist status for their licensing jurisdiction without taking on the cost and substance of Curaçao or MGA
• Crypto-friendly operators (Nevis explicitly supports crypto payment methods) who also need a fiat processing fallback
• Operators treating Nevis as a deliberate step on the upgrade path from Anjouan, before eventually moving to Curaçao or MGA
• Solo founders or small teams who cannot justify a physical office and resident staff in another country

Not a good fit:

• Operators who need to be live within 30 days. Even at the faster end, Nevis takes 8 weeks end-to-end. Anjouan is the only sub-60-day option.
• Operators targeting EU players. MGA is the only jurisdiction among these four that provides EU regulatory recognition.
• Operators whose Year 1 budget sits below EUR 30,000. At EUR 34,400 base cost, Nevis does not work at that level. Anjouan is the right answer.
• Operators who already have strong banking relationships under an Anjouan licence and face no PSP friction. If Anjouan's banking limitations are not affecting you, the additional EUR 12,000 per year for Nevis may not generate a return.

The Honest Assessment

Nevis is a framework that is less than two years old. The ordinance passed in April 2025. NOGA is still developing its operational maturity. Periodic reporting formats do not exist yet. The penalty framework draws from secondary sources. The responsible gaming requirements are principled, not prescriptive.

None of that makes it illegitimate. It means operators should go in with realistic expectations. The regulatory framework will evolve. Requirements will become more demanding over time. The operators who build their compliance infrastructure to a higher standard than the current minimum will have an easier time when NOGA tightens the rules. Those who build to the bare minimum will be retrofitting.

What Nevis does offer right now is a genuine commercial proposition for a specific type of operator: someone who has outgrown Anjouan's banking limitations or wants to start above them, but who is not ready for Curaçao's operational commitments. At EUR 34,400 in Year 1 with no physical presence required beyond a Reporting Officer, the maths work for early-stage operators in a way that Curaçao's EUR 52,000+ with a physical office simply does not.

Ready to Apply?

ICOS handles Nevis NOGA applications at fixed pricing. The intake form takes three minutes and you will have a confirmed number within 24 hours, covering both NOGA fees and the ICOS service fee as separate line items. No discovery call, no two-week wait for a proposal.