Romania Class 2 (B2B) Gambling License: Complete Guide 2026

How to obtain the ONJN Class 2 license — Romanian entity and EU company routes, fees, documentation, and compliance obligations.

DEFINITION

1. What is the Romania Class 2 (B2B) Gambling License?

The Class 2 license is issued by category of B2B activity rather than per product. This means a single license covers the holder’s defined operational scope — not individual game titles or platform versions — for a validity period of up to 10 years.

The legal basis for the Class 2 license is:

• Government Emergency Ordinance No. 77/2009 on gambling activities (primary legislation)
• GEO 82/2023 (major 2023 amendment, reforming the enforcement framework)
• ONJN Presidential Orders Nos. 47/2016, 48/2016, 93/2016, and 89/2018 (technical and procedural rules)

ONJN (Oficiul Național pentru Jocuri de Noroc — the National Gambling Office of Romania) is the sole competent authority. It operates under the Ministry of Finance and is responsible for issuing, suspending, and revoking licenses, maintaining the blacklist of unlicensed operators (currently exceeding 1,600 domains), and enforcing supply-chain compliance.

SCOPE

2. Who Needs a Class 2 License?

Any company supplying the following products or services to a Romanian Class 1 (B2C) licensed operator must hold a Class 2 license. This is a hard legal requirement — not optional compliance. Romanian Class 1 operators are legally obligated to source services exclusively from Class 2-licensed B2B partners.

B2B Activity Category	Examples
Software development & platform provision	Casino platforms, sportsbook engines, PAM systems
Platform management & hosting	Managed platform services, cloud hosting for gambling data
Game manufacturing & distribution	Slot studios, RNG game suppliers, aggregators
Live casino streaming	Live dealer studios supplying Romanian operators
Payment processing	PSPs, e-wallets, payment gateways facilitating gambling transactions
Certification & testing	Technical laboratories, conformity assessment bodies
Affiliate & marketing services	Affiliates earning revenue through referrals to Romanian Class 1 operators

ELIGIBILITY

3. Who Can Apply for the Romania Class 2 License?

ONJN accepts Class 2 applications from legal entities incorporated in:

• Romania
• Any EU member state
• Any EEA member state (Iceland, Liechtenstein, Norway)
• Switzerland

This is a broader eligibility window than the Class 1 license, which requires physical presence or a permanent establishment in Romania.

Fit-and-Proper Requirements

The following eligibility standards apply to all key persons — shareholders with material ownership, directors, and ultimate beneficial owners (UBOs):

Requirement	Detail
No criminal convictions	Must have no convictions for fraud, financial crime, money laundering, or gambling-related offences
No insolvency history	No history of personal or corporate insolvency within ONJN’s defined look-back period
Source of funds	Must demonstrate lawful source of funds and source of wealth to ONJN’s satisfaction
No unlicensed activity	No concurrent involvement in unlicensed gambling activities in any jurisdiction
Corporate transparency	Full disclosure of ownership chain to natural persons; nominee directors and bearer shares trigger additional scrutiny

Structure

4. The Two Routes: Romanian SRL vs EU/EEA Entity

The most consequential decision for any incoming B2B provider is the licensing structure. Both routes lead to an identical Class 2 license with identical legal rights and ONJN obligations. The differences are structural, fiscal, and administrative.

Criterion	Route A — Romanian SRL	Route B — EU Entity
Entity incorporation	New Romanian SRL/SA (7–15 days)	Existing EU/EEA entity — no new company
Local director	Company officers of the Romanian entity	None — authorised representative provided
Romanian corporate tax	16% on Romanian-source profits	Zero — if no permanent establishment created
VAT obligations	Full Romanian VAT registration and filing	Assessed per service — generally not triggered for remote B2B
ONJN application fee	€10,500 (one-time)	€10,500 (one-time)
Annual license fee	€20,000 / year	€20,000 / year
RG contribution	€15,000 / year	€15,000 / year
Time to submission	~3–4 weeks from instruction	~2–3 weeks from instruction
Tax efficiency	Standard Romanian CIT + VAT exposure	Full tax efficiency for remote supply

COSTS

5. Romania Class 2 License — Fees and Costs

The Romania Class 2 license has a flat fee structure regardless of revenue. This is a significant advantage for providers with large or variable revenue bases.

License issuance fee (one-time)	€10,500
Annual license fee	€20,000 / year
Annual responsible gambling contribution	€15,000 / year
Total annual recurring cost (from Year 1)	€35,000 / year

DOCUMENTATION

6. Required Documents for the Class 2 License Application

ONJN requires a comprehensive documentation package. Incomplete submissions are the primary cause of delays. ONJN does not process partial applications.

Documents Required for All Applicants

• Certificate of incorporation and current articles of association — apostilled and translated into Romanian
• Certificate of good standing — issued within the preceding 3 months
• Corporate ownership chart identifying all shareholders, directors, and UBOs down to natural persons
• Identification documents (passports or national IDs) for all key persons
• Criminal record certificates for all key persons — from relevant national authorities
• Source of funds and source of wealth declarations for all material UBOs
• Financial statements for the preceding 2–3 financial years (audited where available)
• Business plan describing services, intended counterparties, and technical infrastructure
• Technical description and architecture of the platform, software, or services
• Evidence of technical certification by an accredited laboratory (where applicable)
• AML/KYC policy documentation — compliant with Romanian Law No. 129/2019
• Responsible gambling policy and implementation framework
• Draft contractual framework for relationships with Romanian Class 1 operators
• Proof of payment of the €10,500 application and evaluation fee

Additional Documents for EU/EEA Entity Applicants (Route B)

• Appointment letter for the local authorised representative
• Proof of the representative’s ONJN registration
• CIF certificate issued by ANAF (Romanian tax authority)

Key Points on Fees

• All fees are denominated in euros and paid to Romanian state treasury accounts
• The annual fees are fixed — they do not scale with GGR or revenue
• Annual renewal is not automatic — compliance documentation must be resubmitted
• Failure to renew on time creates a gap in licensed status, affecting operator supply-chain relationships
• The license is valid for 10 years subject to annual fee payment and compliance verification

PROCESS

7. Application Process — Step by Step

Step	Action	Timeline
1. Corporate preparation	Incorporate Romanian SRL with gambling objects (Route A) or verify EU entity eligibility and appoint local representative (Route B)	Week 1–2
2. Documentation assembly	Compile, translate, apostille, and notarise all required documents. Obtain criminal record certificates. Commission technical description.	Week 2–3
3. Tax registration	Register with ANAF to obtain Romanian CIF. Open local bank account for euro regulatory payments.	Week 2–3
4. Application submission	Submit complete application package to ONJN with proof of €10,500 fee payment.	Week 3–4
5. ONJN review	ONJN conducts integrity review, UBO background checks, technical assessment, and compliance framework evaluation.	Week 4–8 (30–60 days)
6. License issuance	ONJN issues Class 2 license by formal decision. Annual fees remitted. License entered in ONJN public register.	Week 8–10
7. Ongoing compliance	Monthly and annual ONJN reports. Annual fee payments. Technical recertification on material updates. ONJN notification of corporate changes.	Continuous

OBLIGATIONS

8. Ongoing Compliance Obligations

Technical Certification

Gaming software, RNG systems, and platform components supplied to Romanian operators must be certified by an ONJN-accredited testing laboratory. Any material update to certified systems requires re-certification and ONJN notification prior to deployment.

Monthly Reporting

Class 2 license holders must submit monthly reports to ONJN — due by the 10th of the following month — documenting: the number of Romanian players blocked from accessing services through unlicensed operators, and details of any non-compliant domains or platforms identified.

AML and Player Protection

All Class 2 licensees must maintain an AML/KYC framework compliant with Romanian Law No. 129/2019 and applicable EU Anti-Money Laundering Directives. Payment processors and affiliate operators have additional obligations around responsible gambling tooling and player protection.

Self-Exclusion Registry (ONJN Order 79/2025)

From June 2025, a national centralised self-exclusion registry is in operation. Class 2 providers whose services interface with player accounts must integrate with and honour exclusions recorded in this registry.

Unlicensed Operator Prohibition

Class 2 holders are prohibited from providing services to any B2C operator that is not licensed by ONJN and is targeting Romanian players. Where Romanian-player access through an unlicensed operator is identified, the Class 2 holder must restrict access, notify the operator, and report to ONJN in the next monthly submission.

Market Context

9. The Romanian iGaming Market

Romania operates one of the most structured and enforced online gambling frameworks in the EU. The 2023 reforms (GEO 82/2023) significantly strengthened ONJN’s enforcement powers, including mandatory ISP blocking, payment processor obligations, and supply-chain audit rights. ONJN actively enforces Class 2 licensing requirements and has blacklisted over 1,600 unlicensed domains.

FAQ

10. Frequently Asked Questions