Anjouan Gaming License: B2B and Compliance Requirements for 2026

A current review of Anjouan supplier approvals, product-specific testing, ownership disclosures, ADR and renewal-readiness checks, updated from our 2025 article.

Published Updated 5 min readOfficial sources reviewed

Short answer

  • Operators must check that platform and content suppliers hold a valid Anjouan B2B licence or recognition certificate; a foreign licence or a contract alone is not enough.
  • RNG certification is product-specific: match certificates to the games, systems and versions actually supplied.
  • The 2026 amendments on beneficial ownership, ADR and B2B disclosures apply now to new applicants and by the next renewal for existing licensees.
  • Official warning: the Central Bank of the Comoros' notice signed on 8 December 2025 states that online gambling is not authorised in the Comoros and that no licences for it have been issued. Read [what the warning means](/anjouan-gaming-licence-central-bank-warning/) before relying on or renewing an Anjouan licence.

For an Anjouan gaming license in 2026, operators should check supplier licensing or recognition, product-specific testing evidence, ownership disclosures, dispute resolution and the commercial basis of B2B arrangements. These checks must match the relevant business model and license conditions. A supplier contract, an overseas license or a single technical certificate does not answer every compliance question.

This article focuses on the obligations that operators and suppliers need to review. For application documents, official fees and planning a submission, see our Anjouan gaming license application guide.

Which requirements apply to B2C operators and B2B suppliers?

Anjouan distinguishes B2C businesses serving players from B2B businesses supplying critical platform, software or technical services to operators. The category and the conditions attached to a license determine its scope. A business performing several roles should identify the legal entity responsible for each role rather than assume that one approval covers the entire group. See the official license categories.

What should operators verify about their suppliers?

The October 2026 conditions linked from the official downloads page address the fitness and propriety of platform and content suppliers and require a valid Anjouan B2B license or recognition certificate. A commercial agreement is not a substitute for checking that approval.

For a supplier relying on recognition, check its legal name, recognition number, status, validity period and domain against the official recognition register. Do not assume that holding a license overseas automatically establishes recognition in Anjouan. If the register and the supplier’s documents do not match, obtain clarification before relying on them.

Using an aggregator can reduce integration work. It does not, by itself, demonstrate the regulatory status of every underlying supplier or the testing evidence for every game. A practical review should connect each supplied service to its contracting entity, approval evidence and relevant technical records.

Does every B2B applicant need the same RNG certificate?

The published rule is product-specific: random number generators used in gaming products must be certified by an approved independent testing facility. It should not be restated as an identical certificate requirement for every type of B2B service. The applicant’s role, product and actual testing evidence still need to be assessed. See the official technical standards.

For preparation, match certificates to the games, systems and versions actually supplied. Check that the evidence covers the intended use, and resolve gaps with the supplier or the appropriate regulatory contact. A contract or a generic statement that games are tested cannot replace that review.

What changed in the 2026 compliance requirements?

The Authority’s September 2026 regulatory notice identifies amendments concerning beneficial ownership, alternative dispute resolution and B2B disclosures. The main preparation points are below.

Beneficial ownership transparency

The current conditions require disclosure of nominee, trust, foundation and threshold-avoiding ownership arrangements. The Authority may seek source-of-wealth evidence for a beneficial owner regardless of the percentage held. Ownership records must remain current, not merely be assembled at application. See the published ownership conditions.

An approved ADR provider and a usable complaints process

The conditions require an approved alternative dispute resolution (ADR) provider to be identified, with contact details, in player-facing terms. The approved-provider guidance describes an internal complaints stage, a 30-day resolution timeframe and escalation to ADR where a complaint remains unresolved. ADR costs fall to the operator.

Check the provider’s current approval and appointment terms, then align the player terms and internal complaint-handling process. Simply displaying a provider’s name or logo does not establish that the necessary engagement is in place.

B2B commercial rationale and financial disclosures

B2B licensees must demonstrate the commercial and economic rationale for relevant software, marketing, consultancy and technology contracts. The conditions also address significant cross-border B2B flows unrelated to regulated gambling and virtual-asset settlements. Reconcile contract descriptions with the services and payments actually provided. See the B2B commercial-substance conditions.

When the amendments apply

The published conditions say these ownership, ADR and B2B requirements apply immediately to new applications and no later than the next renewal for existing licensees. Check any license-specific conditions or directions as well. This is not a basis for postponing obligations that already apply.

Which version of the conditions should you use?

On 22 October 2026, the official downloads page linked an October 2026 v5 conditions document referring to the final KYC and AML Code dated 13 October 2026. If your records contain v4 or another earlier pack, confirm the applicable version before signing or submitting documents.

Keep the version, source and date received together. A later public download does not, by itself, resolve the status of an earlier signed document. Review the issued license and any specific directions, and seek written clarification where the documents differ. Use the Authority’s current downloads rather than an undated copy from a third party.

Does an Anjouan license remove territorial restrictions?

No. Anjouan licensing does not override local laws in a destination market. Operators remain responsible for market-access controls and local compliance, as the Authority’s international legal-context guidance explains. Review the applicable territorial conditions as well as local law before offering or advertising services.

A practical compliance review checklist

The following is a preparation checklist, not a replacement for the applicable legal requirements:

  1. Map the supply chain. Identify the applicant, platform provider, content suppliers and contracting entities.
  2. Verify approval evidence. Record the supplier’s license or recognition details, relevant service and date checked.
  3. Reconcile technical records. Match testing evidence to the games and versions in use.
  4. Review ownership records. Check that the structure and supporting evidence reflect the present position.
  5. Test complaint handling. Confirm responsibility for internal decisions, escalation and maintaining the ADR appointment.
  6. Check contracts and payments. Document the commercial explanation for the relevant B2B arrangements.
  7. Resolve version gaps. Confirm which conditions, forms and directions apply before making a compliance declaration.

Frequently asked questions

Is a foreign supplier license enough?

Do not rely on it alone. Verify the supplier’s applicable Anjouan license or recognition status for the relevant legal entity and service.

Does using an aggregator make every game compliant?

No automatic conclusion follows from the integration model. Review the underlying supplier approvals and the evidence for the products actually supplied.

Is the September 2025 date in the old article a current deadline?

No. It is a historical reference, not a new deadline. Use current published requirements and any directions applicable to the particular license.

What should be checked before renewal?

Start with the current document versions, ownership records, supplier evidence and complaint-handling arrangements. Identify unresolved questions early rather than signing a declaration based on an old checklist.

Official sources

  1. Anjouan Gaming — Official license categoriesanjouangaming.com
  2. Anjouan Gaming — Official downloads pageanjouangaming.com
  3. Anjouan Gaming — Official recognition registeranjouangaming.com
  4. Anjouan Gaming — Official technical standardsanjouangaming.com
  5. Anjouan Gaming — September 2026 regulatory noticeanjouangaming.com
  6. Anjouan Gaming — Published ownership conditionsanjouangaming.com
  7. Anjouan Gaming — Approved-provider guidanceanjouangaming.com
  8. Anjouan Gaming — International legal-context guidanceanjouangaming.com
  9. Central Bank of the Comoros — Notice signed 8 December 2025 (PDF)banque-comores.km

Checked on 22 Oct 2026. Rules, fees and forms change; confirm the current position before acting.