Offshore gambling licences in 2026: 15 active jurisdictions compared, the gray zones, and whether a Curaçao licence is legal in the Philippines

Many offshore casino sites show a licence seal in the footer. That seal answers one narrow question: which authority, if any, supervises the company in the place where it is set up. AskSpinner's earlier explainer on how offshore casinos are licensed and how countries push back covered the basic model. This piece goes further: a jurisdiction-by-jurisdiction comparison of every hub still issuing licences to operators that serve foreign players, built from the regulators' own registers, laws and fee schedules.

The full dataset is available to download as a CSV: AskSpinner offshore gambling licences dataset (v2026-11-11). All register counts were taken on November 11, 2026 (Beijing time) unless a different date is shown.

Which offshore licensing jurisdictions are still active?

"Not compiled" means the regulator may publish fees, but they were not verified for this comparison. Figures are not estimates.

The Caribbean and Comoros hubs

Curaçao. The LOK replaced Curaçao's old master-licence and sub-licence system, under which a handful of master licensees issued sub-licences to operators. The CGA now licenses each company directly. Its registry, last updated November 5, 2026, lists 667 licences: 203 with an indefinite term, 294 marked "Assessment in progress", 51 still inside their first six-month provisional term, 53 expired, 62 revoked at the operator's own request and 4 under re-evaluation. Every one of the 294 "Assessment in progress" entries shows a printed expiry date that has already passed. The oldest of these expired on November 23, 2025. The CGA's register page itself says the overviews "do not guarantee the current validity of the licenses."

The CGA's fee document sets a €4,592 application fee plus €150 for each beneficial owner. B2C holders pay €47,450 a year, split into a €24,490 licence fee to the National Treasury and a €22,960 supervisory fee to the CGA. B2B suppliers pay €24,490. Players must first complain to the operator, and licensees must offer free alternative dispute resolution (ADR) under the CGA's Player Complaints Policy. The enforcement register, dated September 14, 2026, lists 31 revocations and one licence the CGA declined to extend.

2026 also exposed operational weaknesses. On September 17 the CGA said it had found unauthorised access to its online gaming portal. It later said a researcher had entered the portal in December 2025 and published licence holders' data. On October 7 it announced that the portal would not return to service and that the digital seal used to link a domain to a licence would be affected. AskSpinner has previously reported an allegation that a forged document was used in a Curaçao licence application.

Anjouan. Anjouan is one of the three islands of the Union of the Comoros. It licenses under the Computer Gaming Licensing Act of 2005, and a private company, Anjouan Licensing Services Inc., administers the licences as "sole authorised administrator." Its register lists 1,287 entries: 1,064 B2C, 173 B2B and 50 combined. Every entry is marked "valid." Ninety-six of them carry a printed expiry date before November 11, 2026: 68 expired in October and 28 between November 1 and 10. The register's published revoked and suspended lists showed no entries. One licence costs €17,828 to issue and the same again each year. The authority says it "does not handle, mediate, or adjudicate player complaints." Players must go to the operator and then to an approved ADR provider. AskSpinner reported one such case this week in its story on Lucky.fun's Anjouan licence.

Mohéli (Mwali). The Mwali International Services Authority lists 14 gambling companies, all marked "Active." The Banque Centrale des Comores has issued public warnings that banking and financial licences issued through MISA are not recognised in the Comoros. Those warnings concern banking. No equivalent statement on gambling licences was found. No separate gambling regulator was found for Grande Comore (Ngazidja).

Nevis. The Nevis Online Gaming Authority is a newer entrant. It publishes the Nevis Online Gaming Ordinance, 2025, and its register lists 17 licences. Its website says it is run by Apex Capital Partners, "acting as the management company" of the authority. The authority publishes a list of restricted countries that licensees must geo-block: Australia, Austria, St Kitts & Nevis, France, Germany, the Netherlands, Spain, the UK and the US, plus FATF-blacklisted and sanctioned countries. It also offers a separate prediction-market licence.

Antigua & Barbuda lists four active licensees, along with a list of companies that falsely claim to hold an Antiguan licence. Vanuatu's licences are sold through VGA Limited, which calls itself the "sole exclusive agent" working with the customs department as regulator. VGA publishes fees of €5,000 to apply and €10,000 a year, but no public register: its licence search is marked "soon."

First Nations regulators in Canada

Kahnawà:ke. The Kahnawà:ke Gaming Commission has issued its single hosting licence to Mohawk Internet Technologies since 1999. Operators receive a Client Provider Authorization and must be hosted there. The permit-holder page lists 53 CPA holders and two casino software providers, with about 220 URLs. The page still carries the line "Updated September 28, 2023."

Tobique. Tobique First Nation (Neqotkuk) in New Brunswick enacted the Tobique Gaming Act on October 13, 2023. Its commission lists 213 remote gambling licences: 189 B2C and 24 B2B. Section 4 of the Act says it is "paramount over any other legislative act or regulation" on gaming, "including any act or regulation of the Parliament of Canada" and of the provinces. That is the Nation's own position. The commission also publishes a list of sites that falsely claim a Tobique licence.

European and Crown Dependency regulators

These regulators also license companies that serve players abroad. Their registers are smaller, but their supervisory activity is better documented.

• Malta. At the end of 2025 the MGA had 302 licensed companies holding 311 licences. Its online base was 131 B2C and 171 B2B licences. In 2025 it imposed 30 administrative penalties, suspended one licence, cancelled two and issued 35 cease-and-desist letters, according to its 2025 Annual Report. Article 56A of the Gaming Act, which tells Maltese courts to refuse to enforce some foreign judgments against MGA licensees, is the subject of European Commission infringement proceedings (INFR(2025)2100).
• Isle of Man. The Gambling Supervision Commission's register, updated October 29, 2026, lists 49 licences under the Online Gambling Regulation Act 2001.
• Gibraltar. The Gambling Act 2025 came into force on April 1, 2026, apart from sections 55 to 77. The register lists 29 B2C remote operators and 33 B2B remote entries.
• Alderney. The AGCC lists 20 eGambling licensees. Alderney is also where remote gambling in the wider Bailiwick of Guernsey is licensed, so Guernsey and Sark were not counted separately.

Smaller and domestic-facing regimes

Seychelles granted its only current interactive gambling operator licence, to Amazon Betting (Proprietary) Limited, with effect from June 16, 2026 (S.I. 55 of 2026). Panama's JCJ authorises internet gaming, but its 2026 Law 527 (Gaceta Oficial No. 30534-B, May 28, 2026) points the regime at unlicensed operators serving Panama, and no full public list of online licensees was found. Costa Rica has no online gambling licence. Under Law 9050 of 2012, companies that "receive and process data generating electronic bets" pay an annual tax of 57, 85 or 113 base salaries depending on how many staff they have (Article 4), and municipalities keep the power to issue their business permits (Article 6). A Costa Rican "permit" is therefore a tax and business registration, not a gaming licence.

Jurisdictions dropped from the comparison

• Belize: In a June 9, 2025 notice, the government said a moratorium on online gaming licences means "no online gaming companies are currently licensed to operate from Belize."
• Philippines (PAGCOR offshore licences): PAGCOR cancelled all Internet Gaming Licensees and Authorized Providers effective December 15, 2024, after Executive Order No. 74.
• Philippines (CEZA/First Cagayan and APECO/Aurora): Section 5 of the Anti-POGO Act of 2025 permanently revoked offshore gaming licences issued by "special economic zone authorities ... freeport authorities, and other government agencies."
• Labuan: No gambling licence regime was found under the Labuan Financial Services Authority.
• Cyprus: Betting licences cover only betting offered in Cyprus.
• Guernsey and Sark: No remote regime separate from Alderney's.
• Grande Comore and Trinidad & Tobago: No active regulator issuing licences for offshore online gambling was found.

The gray zones, in the regulators' own words

1. A home licence, not a passport. Curaçao's licence conditions for indefinite-term licences (Article 3) require holders to ensure that "the applicable laws and regulations of the jurisdictions in which they offer remote games of chance, are strictly adhered to." Anjouan's standard conditions require licensees to "comply with all applicable laws." In other words, the issuing regulators themselves do not claim to authorise operators in markets that require a local licence. Many of those markets set their own rules, as AskSpinner's guide to gambling licence requirements by country shows.

2. The master-licence legacy. Before the LOK, a few Curaçao master licensees issued sub-licences. The CGA's register now lists only licences it granted itself after November 15, 2023. Older sub-licence numbers in site footers do not appear on it.

3. Registers that do not age entries out. Curaçao has 294 "Assessment in progress" entries and Anjouan has 96 "valid" entries, all with passed printed expiry dates. In both cases a register entry alone does not show whether a licence was actually renewed or extended. Only Curaçao's register warns readers of this directly.

4. Seals and copycats. Curaçao's digital seal was affected when its portal was retired. Tobique, Antigua and Malta all publish lists of websites that falsely claim their licences. In 2025 the MGA found fraudulent references to the Authority or its licensees on 42 of the 109 URLs it reviewed.

5. Payments and blocking in player markets. Target markets act on what they can reach at home. In the Philippines, the central bank's Memorandum M-2025-029 ordered all BSP-supervised institutions to remove in-app links to gambling sites from mobile payment apps within 48 hours. PAGCOR says it is working with the Department of Information and Communications Technology (DICT), the National Telecommunications Commission (NTC) and the Cybercrime Investigation and Coordination Center (CICC) against illegal online gambling operators, and it plans a licence-check app for December 2026. Panama's Law 527 gives its regulator the power to order blocking of unlicensed sites.

Case study: Is a Curaçao-licensed casino legal in the Philippines?

Who may license gambling. Section 10 of PAGCOR's charter (Presidential Decree No. 1869, as amended by Republic Act No. 9487) grants PAGCOR "the rights, privileges and authority to operate and license gambling casinos, gaming clubs and other similar recreation or amusement places, gaming pools ... whether on land or sea, within the territorial jurisdiction of the Republic of the Philippines." The exceptions are franchises and special laws, such as the old economic-zone regimes, and games licensed by local governments, such as cockfighting. PAGCOR licenses domestic online play only as an extension of a licensed gaming venue, as set out in AskSpinner's Philippines licence guide. A licence from the Curaçao Gaming Authority is not among the authorities the charter recognises.

Offshore licences are gone. Executive Order No. 74 (November 5, 2024) barred new applications and renewals for POGO and internet gaming licences (Section 2). It classed offshore operators without a licence as "illegal gambling entities." The Anti-POGO Act of 2025 (Republic Act No. 12312, approved October 23, 2025) bans offshore gaming. Section 4 prohibits "acceptance of any form of betting for offshore gaming operations" and related support services. Section 13 sets prison terms of six to twelve years and fines from PHP 15 million up to PHP 50 million. The Act's definition of offshore gaming covers operations run from the Philippines for players abroad. It does not cover foreign-licensed sites taking Philippine players. Those fall under the general illegal-gambling law.

Penalties for unauthorised gambling, including for players. Section 1(a)(1) of Presidential Decree No. 1602 penalises "any person" who "shall directly or indirectly take part in any illegal or unauthorized activities or games." Its list runs from card games, roulette and slot machines to sports contests, and ends with "any other game scheme, whether upon chance or skill, wherein wagers ... are at stake." The penalty is prisión correccional in its medium period or a fine of PHP 1,000 to PHP 6,000. Maintainers and conductors face heavier penalties under Section 1(b). Section 6 of the Cybercrime Prevention Act (RA 10175) applies to crimes under special laws "committed by, through and with the use of information and communications technologies" and sets the penalty "one (1) degree higher." Republic Act No. 9287 sets separate penalties, including 30 to 90 days in prison for a bettor, but it covers only illegal numbers games such as jueteng.

Bills in Congress. Bills proposing to ban online gambling, such as Senate Bill No. 30 (the proposed Ban on Online Gambling Act), were filed in the 20th Congress. As of November 11, 2026, none had become law.

What the law says. A Curaçao licence is not a PAGCOR licence and does not make offering games to people in the Philippines lawful. Under PD 1602, taking part in unauthorised gambling is an offence for "any person," and Philippine law does not exempt players. The Curaçao licence's own conditions also require compliance with the laws of each market served. No published prosecution data for individual online players was found.

This article is for information only and is not legal advice. Laws and registers change; check the regulator's current documents.

Information as of November 11, 2026. Register counts are AskSpinner's tallies of each regulator's published list on that date.