Romania

Romanian ONJN Class II License: Conditions, Documents and the Procedure Step by Step

Who can hold a Class II license, the conditions ONJN checks, every document in the file and the seven steps from instruction to license, with timings for the EU-company and Romanian-SRL routes.

By the iGaming Express teamOctober 25, 20269 min read
Short answer

To get a Romanian ONJN Class II license, the applicant must be a Romanian company or a company from the EU, EEA or Switzerland with an authorized representative in Romania; its owners, directors and beneficial owners must pass fit-and-proper checks; and it must document its corporate structure, finances, technical systems, software ownership and AML policies. The file, in Romanian, goes to ONJN with proof of the €10,500 one-off fee. ONJN reviews a complete file in about 30–60 days, so the whole process typically takes 8–12 weeks from instruction to license.

Key takeaways
  • Who can apply: a Romanian SRL/SA, or an EU, EEA or Swiss company directly, with an authorized representative in Romania.
  • Conditions: transparent ownership to natural persons, clean records, lawful source of funds, technical capability, software rights and an AML framework.
  • Documents: apostilled and translated corporate papers, UBO chart, criminal records, financial statements, business plan, technical description, certification, AML and RG policies, fee proof.
  • Procedure: structure, documents, ANAF registration, submission, ONJN review (30–60 days), grant, then ongoing compliance.
  • Timeline: about 8–10 weeks on the EU-company route and 10–12 weeks with a new Romanian SRL.

The Romanian Class II license is granted on paper, not in an interview: ONJN decides on the file you submit. A complete, consistent and well-translated file moves through review in weeks; a file with gaps can stall for months. This guide sets out who can apply, the conditions ONJN checks, every document in the file and the procedure from instruction to license. The legal basis is Government Emergency Ordinance (GEO) 77/2009 and its implementing rules in Government Decision (GD) 111/2016.

Who can apply

  • A Romanian company (SRL or SA) with the Class II activity in its objects; or
  • A company incorporated in the EU, EEA or Switzerland, applying directly, with an authorized representative in Romania and an address for service.

Companies from outside those areas, including Gibraltar and Curaçao, cannot apply directly; they use a Romanian company or a qualifying EU/EEA entity in their group. Unlike Class I operators, a Class II supplier does not need a Romanian permanent establishment. If you are not sure whether your business needs Class II at all, start with what the Class II license covers.

The conditions ONJN checks

ConditionWhat ONJN looks for
Transparent ownershipThe full chain from the applicant to the natural persons who own or control it; nominee arrangements and bearer shares draw extra scrutiny
Good reputeNo convictions of shareholders, directors or beneficial owners for fraud, financial crime, money laundering or gambling offences
Financial standingFinancial statements, lawful source of funds and wealth, and no insolvency
No unlicensed activityNo involvement in gambling that targets Romania without a license
Technical capabilityA clear description of the systems, how they connect to operators and how data flows, plus laboratory certification where the activity requires it
Software rightsProof that you own the software or have the right to distribute it
Compliance frameworkAML/CFT policy under Law 129/2019, responsible gambling policy and GDPR-compliant data handling

The document checklist

ONJN does not process partial files, so the package should be complete at submission. Foreign public documents are apostilled and filed with certified Romanian translations; certificates should be recent, typically issued within three months.

Corporate

  • Certificate of incorporation and current articles of association
  • Certificate of good standing
  • Ownership chart down to the ultimate beneficial owners
  • Board and management structure

Key persons (shareholders, directors, beneficial owners)

  • Passports or national ID cards
  • Criminal record certificates
  • Source of funds and source of wealth declarations

Financial and business

  • Financial statements for the last two to three years, audited where available
  • Business plan: services, intended operator clients and infrastructure
  • Draft contracts with Romanian Class I operators

Technical

  • Technical description and architecture of the platform, games or service
  • Certificates from an accredited testing laboratory, where the activity requires them
  • Proof of software ownership or distribution rights (for example ORDA registration or license agreements)

Compliance

  • AML/KYC policy under Law 129/2019
  • Responsible gambling policy
  • Data protection documentation

Route-specific and fees

  • EU/EEA/Swiss applicants: appointment of the authorized representative and the Romanian tax identification number (CIF) from ANAF
  • Proof of payment of the €10,500 one-off fee; the license fee and social contribution follow on grant (see all Class II fees)

The procedure step by step

StepWhat happensTiming
1. StructureChoose the route, define the Class II activities, appoint the Romanian representative or incorporate the SRLWeeks 1–2
2. DocumentsCollect, apostille, translate and notarize; prepare the technical description and policiesWeeks 2–3
3. Tax registrationObtain the Romanian CIF from ANAF and set up payment of state feesWeeks 2–3
4. SubmissionFile the complete package with ONJN with proof of the €10,500 feeWeeks 3–4
5. ONJN reviewIntegrity and beneficial-owner checks, technical and compliance assessment; ONJN may ask questions30–60 days
6. GrantONJN issues the license, the annual fees are paid and the license enters the public registerWeeks 8–12
7. Ongoing complianceMonthly reports, annual fees, change notices and recertificationFor the license term

Class II needs no operating authorization after the grant: the license itself allows the listed activities. What it does need is a steady compliance routine, set out in our Class II obligations guide.

EU company or Romanian SRL

EU/EEA or Swiss companyRomanian SRL
New companyNoYes, about 7–15 days to incorporate
Local presenceAuthorized representative and address for serviceRegistered office and officers in Romania
Romanian corporate taxNone if no permanent establishment arisesOn Romanian-source profits
Typical timeline8–10 weeks10–12 weeks
Government feesIdentical: €10,500 one-off, €20,000 license fee, €15,000 social contribution

Choosing the Romanian route? Our company formation service sets up the SRL with the right objects.

How to avoid delays

  • Trace every owner. The ownership chart must end with natural persons, matching the corporate documents.
  • Prove the software. Missing proof of ownership or distribution rights is one of the most common gaps.
  • Explain the system plainly. The technical description should show what you supply, how it connects to operators and where data is held.
  • Keep documents fresh and consistent. Expired certificates or names spelled differently across documents trigger questions.
  • Answer ONJN fast. Questions during review pause the clock until they are answered.

For how Class II compares with the operator license, see Class I vs Class II license in Romania, and for everything in one place, the Romania Class II complete guide.

Frequently asked questions

Who can apply for a Class II license in Romania?

A company incorporated in Romania, or a company from an EU or EEA member state or Switzerland applying directly through an authorized representative in Romania. Companies from Gibraltar, Curaçao or other non-EU jurisdictions apply through a Romanian or EU/EEA entity.

What documents does ONJN require for a Class II application?

Corporate documents and a good standing certificate (apostilled and translated), an ownership chart to the beneficial owners, IDs and criminal records of key persons, source-of-funds declarations, financial statements, a business plan, a technical description of the platform or services, laboratory certification where applicable, proof of software rights, AML and responsible gambling policies, draft operator contracts and proof of the €10,500 fee.

Do documents have to be in Romanian?

Yes. Foreign documents are submitted with certified Romanian translations, and public documents usually need an apostille. Certificates such as good standing and criminal records should be recent, typically issued within the last three months.

How long does the ONJN Class II procedure take?

ONJN reviews a complete file in about 30–60 days. With preparation and translations, plan for 8–10 weeks on the EU-company route and 10–12 weeks if a new Romanian SRL is incorporated first.

What are the most common reasons for delays?

Incomplete files, ownership that cannot be traced to natural persons, missing proof of software ownership, technical descriptions that do not explain how the system connects to operators, and documents that are too old or not properly translated.

Can one application cover several Class II activities?

The license lists the Class II activities you are authorized for, such as producer, distributor, payment processing, testing or affiliate. Define all the activities you need before filing, so the file and the technical documentation cover each one.

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Sources

  1. ONJN, National Gambling Office of Romania (opens in a new tab)