After the grant, a Romanian ONJN Class II licensee must file a monthly report with ONJN by the 10th of the following month, including the statement under article 1(5^8) of GEO 77/2009 on blocking access to operators that target Romania without a license; pay the €20,000 license fee and €15,000 social responsibility contribution every year; notify ONJN of online changes within 48 hours and offline changes within 5 days; recertify software before material updates; keep an AML/CFT program under Law 129/2019; and never supply operators that target Romanian players without a license. Foreign holders do most of this through their Romanian representative.
- Monthly: report to ONJN by the 10th of the following month, including the article 1(5^8) statement on blocked unlicensed operators, even in months with nothing to report.
- Annually: €20,000 license fee and €15,000 social responsibility contribution, plus updated compliance documentation.
- On change: online changes notified within 48 hours, offline changes within 5 days; recertify software before material updates.
- Always: AML/CFT program under Law 129/2019, and no supply to operators that target Romania without an ONJN license.
- 2026 is the first renewal cycle for licenses granted in 2016: ONJN reviews the full reporting and compliance history.
Getting a Romanian Class II license takes about two to three months. Keeping it takes discipline for ten years. ONJN treats a supplier's reporting and payment record as evidence of reliability, and that record is reviewed in full at renewal. This guide covers every recurring obligation of a Class II holder and when it falls due.
The compliance calendar
| Frequency | Obligation | Deadline |
|---|---|---|
| Monthly | Report to ONJN, including the article 1(5^8) statement on blocked unlicensed operators | By the 10th of the following month |
| Annually | License fee (€20,000) and social responsibility contribution (€15,000) | Each year the license is in force |
| Annually | Updated compliance documentation and Romanian tax filings for foreign holders | Each year |
| On change | Notification of changes affecting online systems | Within 48 hours |
| On change | Notification of other changes, such as ownership, directors or address | Within 5 days |
| Before release | Recertification of materially updated software | Before deployment to Romanian operators |
| Continuous | AML/CFT program, record-keeping and supply-chain controls | Always |
The monthly report
Every Class II holder files a monthly report with ONJN by the 10th of the following month. Its core is the statement required by article 1(5^8) of GEO 77/2009: the holder confirms the measures it took so that its games, platform or services do not reach Romanian players through operators that target Romania without an ONJN license, and reports any blocking events in the month.
- Nil months still count. A statement is due every month, even when no Romanian traffic was detected and nothing was blocked.
- Months with blocking events need the detail of what was detected, which operator or domain was involved and what was done; a cover letter explaining the events is good practice.
- Activity-specific content. Payment processors, platform providers and affiliates add data that fits their activity; testing laboratories report on their certification work.
Most foreign holders have their Romanian representative prepare and file the statement each month, with the original documents sent by courier where ONJN requires them.
Annual fees and documentation
The license fee of €20,000 and the social responsibility contribution of €15,000 are due every year the license is in force. They are fixed and do not depend on revenue; see how much the Class II license costs. Alongside the payments, ONJN expects compliance documentation to stay current: corporate documents, beneficial ownership, key persons and policies. Foreign holders also keep their Romanian tax registration alive with the annual filings and certificates ANAF requires.
Change notifications and recertification
ONJN must always know who owns and runs the licensee and what it supplies:
- Online changes, such as changes to systems, servers or the services connected to Romanian operators, are notified within 48 hours.
- Offline changes, such as a new shareholder, director, beneficial owner or address, are notified within 5 days.
- Software updates: games, RNGs and platform components supplied to Romanian operators are certified by an accredited laboratory, and a material update needs recertification and notification before it is deployed in Romania.
AML/CFT duties
Class II holders maintain an anti-money laundering and counter-terrorist financing framework under Law 129/2019 and the EU AML directives: a business risk assessment, due diligence on the operators they contract with, ongoing monitoring, record-keeping and reporting of suspicious transactions. Payment processors carry the heaviest load because they see the money; studios and platforms focus on knowing their operator clients. Where a supplier's services touch player accounts, it also respects the national self-exclusion registry run under ONJN Order 79/2025. Our compliance and AML service builds and runs this framework for Class II holders.
The supply-chain rule
Romania regulates the whole chain. A Class I operator may only use licensed Class II suppliers, and a Class II supplier may not serve operators that target Romanian players without an ONJN license. If Romanian players reach your content or service through such an operator, you restrict access, notify the operator and report it in your next monthly statement. ONJN maintains a blacklist of unlicensed domains, and suppliers are expected to check their client lists against it. This is the rule ONJN enforces most actively, and the one most likely to put a license at risk.
Renewal and the 2026 cycle
Class II licenses run for up to 10 years. Licenses granted in 2016, when the online regime started, reach the end of their term from 2026, and renewal comes with a review of the holder's full history: monthly statements, payments, notifications and any enforcement. Start preparing 6–12 months before expiry, and fix any gaps in your filing record first. The renewal file follows the same structure as a first application, described in our conditions, documents and procedure guide.
What happens when obligations are missed
ONJN can fine a licensee, suspend or revoke its license and blacklist it, and Class I operators that rely on a non-compliant supplier are exposed too. In practice, the most common problems are late or missing monthly statements, unpaid annual fees and unreported ownership changes, all of which are avoidable with a fixed calendar and a reliable representative. For how Class II fits with operator licensing, see Class I vs Class II license in Romania, and for the whole license in one place, our Romania Class II complete guide.
Frequently asked questions
What must a Class II licensee report to ONJN every month?
A monthly report due by the 10th of the following month. It includes the statement under article 1(5^8) of GEO 77/2009 on Romanian players' access to unlicensed operators and the blocking measures taken, plus the activity data that applies to your Class II activity. A nil statement is still required when nothing happened.
What is the article 1(5^8) statement?
A monthly statement in which a Class II holder confirms what it did to prevent its products or services from reaching Romanian players through operators that are not licensed by ONJN, and reports any blocking events. Months with blocking events need more detail than nil months.
How quickly must changes be notified to ONJN?
Changes affecting online systems must be notified within 48 hours and other changes, such as corporate or ownership changes, within 5 days. Material updates to certified software need recertification before they are deployed.
Does a Class II holder need an AML program?
Yes. Class II holders keep an AML/CFT framework under Law 129/2019, with risk assessment, customer due diligence on operator clients and suspicious-transaction reporting. Payment processors carry the heaviest duties.
Can a Class II supplier work with offshore operators?
Yes, but not in a way that reaches Romanian players. A Class II holder may not serve operators that target Romania without an ONJN license, and must restrict access and report it when Romanian players reach its products through such operators.
What happens if obligations are missed?
ONJN can issue fines, suspend or revoke the license and blacklist the supplier. Late reports and missed annual payments are also reviewed when the license comes up for renewal.
Who handles these obligations for a foreign Class II holder?
Usually the Romanian authorized representative, who files the monthly statements, receives ONJN correspondence and keeps the ANAF tax registration current.
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