Jurisdictions › Guernsey — Alderney
GG-ALD

Guernsey — Alderney

GG-ALD
Tier 1 Offshore HubData collected 2026-10-04Data published 2026-10-04
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Board Briefing

Alderney remains an operational offshore eGambling hub via AGCC's Category 1/2 licence and Associate Certificate model.
What has changed ›
2024-2025 AML/proliferation-financing amendments layered onto the 2009 framework; AGCC leadership transition announced.
What to do now ›
Confirm current consolidated legislative text via the AGCC legislation index before relying on 2009 originals; verify AML/PF obligations against the 2024 Regulations.
What to watch ›
AGCC Commissioner bench composition; any published enforcement-action log; a dedicated GGR/tax-rate instrument not yet located in this pass.

Standing brief, pending expert review.

Alderney operates as an established offshore eGambling hub, regulated by the Alderney Gambling Control Commission under the Gambling (Alderney) Law 1999, the Alderney eGambling Ordinance 2009 and the Alderney eGambling Regulations 2009. The architecture rests on a two-part licence split: a Category 1 licence for the organisation and preparation of gambling operations, covering player registration, the contractual relationship with the player and management of player funds, and a Category 2 licence for effecting the gambling transaction itself, including operational management of a gambling platform within an approved hosting centre. Named licensees operating under this structure include Bayroc, Greentube, Kambi Sports Solutions, Marathon, Playtech Software and Stanleybet Compliance Services, each established as an Alderney entity. The compliance stack has recently been extended by a dedicated proliferation-financing instrument, layered onto the 2009 framework without altering the underlying licensing architecture itself.

Summary

Amber

Market Opportunity

Green

Licensing & Regulation

Alderney's licensing framework offers four routes: the Category 1 licence and Category 2 licence under the Ordinance 2009 and Regulations 2009, a Temporary eGambling Licence capped at twenty-nine continuous days or fifty-nine aggregate days within a six-month period before a full application is required within forty-two days, and a Category 1/2 Associate Certificate for a foreign entity already associated with an existing licensee, which an Alderney company cannot itself hold unless it also holds a Category 1 or 2 licence. The Alderney Gambling Control Commission administers all four routes, though the Commission's own guidance states that the Greffier of the States of Alderney, not AGCC, is the official legislative source, with AGCC-hosted texts standing as convenience copies. Guernsey's financial-crime lead has joined AGCC as a new Commissioner, a change the Commission itself frames as a governance transition rather than a shift in licensing policy.

Licensing required
yes
B2B licensing
required
Casino
Open
Poker
Open
Betting
Open
Skill Games
Not yet assessed
We have not made a determination for this product in this market yet. This is a statement about our coverage, not about the law.
Lottery
Open
Software B2B
Open
Bingo
Open
Fantasy Sports
Not yet assessed
We have not made a determination for this product in this market yet. This is a statement about our coverage, not about the law.
Esports Betting
Not yet assessed
We have not made a determination for this product in this market yet. This is a statement about our coverage, not about the law.
Sweepstakes
Not yet assessed
We have not made a determination for this product in this market yet. This is a statement about our coverage, not about the law.
Crypto Gambling
Not yet assessed
We have not made a determination for this product in this market yet. This is a statement about our coverage, not about the law.
Affiliate Marketing
Not yet assessed
We have not made a determination for this product in this market yet. This is a statement about our coverage, not about the law.
Payments For Gambling
Not yet assessed
We have not made a determination for this product in this market yet. This is a statement about our coverage, not about the law.
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Regulated Activity Classes

All 20 canonical activity classes are shown for every jurisdiction so the grid is directly comparable. 13 carry an assessed status here. Where a class has no statutory activity-class assessment of its own, the status shown is the product-coverage position for that jurisdiction and is marked via product coverage — it describes whether the product can lawfully be offered, not that the regulator operates a separate licence class for it. Not yet assessed describes the state of our coverage and is not a statement that the activity is unregulated.

Player products

Casino
Open
Alderney eGambling Ordinance, 2009; Regulations, 2009
Poker
Open
Subsumed under Category 1/2 eGambling licence (no standalone poker statute identified) — Rule 18 default applied
Bingo
Open
Covered under Category 1 eGambling licence; evidenced by current licensee operations
Lottery
Open
Alderney eGambling Regulations, 2009 (definition of gambling transaction includes lottery participation)
Sports betting
Open
Alderney eGambling Regulations, 2009 (definition of gambling transaction includes betting)
Other event betting
Not yet assessed
Horse racing betting
Not yet assessed
Esports betting
Not yet assessed
via product coverage
Exchange betting
Not yet assessed
Pool betting
Not yet assessed
Virtual event betting
Not yet assessed
Fantasy sports
Not yet assessed
via product coverage
Skill games
Not yet assessed
No explicit statutory treatment located in this research pass
Prediction markets
Not yet assessed
Sweepstakes
Not yet assessed
via product coverage
Free play
Not yet assessed

Supply roles

Software / B2B
Open
Category 2 eGambling licence / Associate Certificate route
Affiliate marketing
Not yet assessed
via product coverage
Payments for gambling
Not yet assessed
via product coverage

Settlement rails

Crypto gambling
Not yet assessed
No AGCC-specific crypto-gambling instrument located

Standing brief, pending expert review.

Casino holds confirmed open status under Alderney's Category 1/2 eGambling licence architecture. Poker has no standalone statute of its own and is treated, by default convention, as subsumed under the same licence structure in the absence of contrary evidence, a position worth flagging for a product-specific legal opinion. Crypto gambling remains unresolved: no AGCC-specific instrument addressing crypto gambling has been identified, leaving that activity class without a settled statutory basis pending a dedicated test. The regulator's own activity-class reading places betting, lottery, bingo and software B2B activity within the same open Category 1/2 architecture as casino, meaning the entry mechanics applicable to casino extend across those verticals as well.

Green

Entry Pathways

Market entry proceeds via a Category 1 licence, a Category 2 licence, a Temporary eGambling Licence, or a Category 1/2 Associate Certificate for a foreign entity already associated with an existing licensee. Entry under the substantive licences is gated by the Regulation 243 capital-adequacy test: cash held must exceed player balances, current assets must exceed current liabilities, and total assets must exceed total liabilities by at least twenty-five per cent.

· ~1 min read

Applicants pay an initial investigation deposit of ten thousand pounds, a supplementary deposit of ten thousand pounds, and a modification fee of one hundred pounds where an application is varied. The Temporary eGambling Licence route is capped at twenty-nine continuous days or fifty-nine aggregate days within a six-month period, after which a full licence application is required within forty-two days, giving an operator a fast provisional route to market ahead of full licensing.

Category 1 eGambling Licence
Operational · Alderney Gambling Control Commission (AGCC) · Alderney eGambling Ordinance, 2009; Alderney eGambling Regulations, 2009, Regs 21-22
Category 2 eGambling Licence
Operational · Alderney Gambling Control Commission (AGCC) · Alderney eGambling Ordinance, 2009; Alderney eGambling Regulations, 2009, Regs 21-22
Temporary eGambling Licence
Operational · Alderney Gambling Control Commission (AGCC) · Alderney eGambling Regulations, 2009, Part I Chapter 4
Category 1/2 Associate Certificate
Operational · Alderney Gambling Control Commission (AGCC) · Alderney eGambling Regulations, 2009, Part II, Regs 66-67, 74
B2B licensing
2 services
Key conditions
6 conditions
Amber

Player Protection

Confidence
Uncertain
Green

Consumer Protection

Alderney does not run a separate general-consumer ADR scheme for gambling complaints; instead, AGCC itself functions as the escalation body. A player must raise a complaint with the licensee first, and if the complaint is unresolved may lodge a formal complaint with the AGCC Commission under Regulation 238.

· ~1 min read

This places the regulator, rather than an independent ombudsman, at the centre of the consumer-protection pathway for an Alderney-licensed product, a different design choice from jurisdictions that route unresolved complaints to a separate ADR body, worth noting for an operator building its own complaints-handling process around the expectation of eventual regulator involvement.

Consumer Law Framework
Not independently identified this pass (general Bailiwick consumer law, outside AGCC remit)
Mandatory Adr
False
Complaint Escalation Path
Player raises complaint with licensee first; if unresolved, lodges a formal complaint with the AGCC Commission under Regulation 238
Confidence
Probable
Amber

Distribution & Platform Rules

Geo Gating Requirements
ip_based
Confidence
Uncertain
Amber

Enforcement

AGCC holds a financial-penalty power, set out in the Regulations' fee and penalty table, capped at two hundred and fifty thousand pounds or ten per cent of turnover, whichever is greater. No publicly searchable enforcement-action register sits alongside that power, and no named fine, suspension or revocation against an Alderney licensee has been identified, leaving the statutory ceiling clear while the pattern of its actual use is not independently visible from a public record.

· ~1 min read

Several features function as practical revocation-risk drivers: a failure to maintain the Regulation 243 capital-adequacy position is a direct breach of a core licence condition; non-compliance with the 2024 Proliferation Financing Regulations and the designated-reporting-entity obligations they carry is a further driver, given the instrument's recent addition to the compliance stack; and AGCC's requirement that all eGambling equipment receive pre-launch approval, with internal control systems reviewed before go-live, makes launching unapproved equipment or systems its own exposure.

Enforcement Style
risk_based
Enforcement Targeting
licensed
Enforcement Summary Last 12M
low
Enforcement Powers
Basis: Instrument cited
Enforcement Style
risk_based
Enforcement Targeting
licensed
Enforcement Summary Last 12M
low
Enforcement Powers
Basis: Instrument cited
Green

Extraterritorial Reach

No correspondent-banking disruption, payment-processor deplatforming pattern, FATF typology citation, or adverse advisory has been identified against Alderney. That absence of an adverse signal sits alongside the Council of Europe's MONEYVAL evaluation of Guernsey's AML/CFT framework, which returned a positive assessment that AGCC itself welcomed.

· ~1 min read

Taken together, these two points support a reading of Alderney as a jurisdiction without an active extraterritorial-enforcement exposure pattern directed at it. An operator assessing cross-border payment-rail risk for an Alderney-licensed product should weigh this absence of adverse signal as a point in the jurisdiction's favour, while recognising that an absence of adverse signal is not itself a guarantee against future action.

Confidence
Probable
Amber

AML / CFT

Alderney's AML/CFT stack sits beneath the Bailiwick-level framework and was recently extended by the Alderney eGambling (Proliferation Financing etc.) Regulations 2024, together with accompanying 2024 and 2025 Amendment Ordinances, which add information-gathering and information-sharing powers and proliferation-financing obligations onto the 2009 licensing framework.

· ~1 min read

Gambling operators in Alderney carry designated-reporting-entity status under that regime. This tightening sits against a positive backdrop: the Council of Europe's MONEYVAL evaluation of Guernsey's AML/CFT framework returned a positive assessment, which AGCC itself welcomed, indicating the new proliferation-financing obligations are layered onto a framework already regarded favourably by an external evaluator. For an operator, the practical consequence is an incremental compliance lift concentrated in information-gathering and reporting duties, rather than a change to the underlying licence categories or entry routes themselves.

Designated Reporting Entity
True
Aml Cft Obligations Band
high
Confidence
Probable
Covered elsewhere

Data Protection

Data protection obligations are not covered in this report. They are not specific to gambling licensing: the controller and processor duties that apply to a licensee are the same ones that apply to any business handling personal data in this jurisdiction, so this report links to the specialist source rather than restating it. Gambling-specific privacy duties -- player data retention, age and identity verification, marketing consent -- are covered in the player protection and operational obligations sections above.

Data protection obligations for this jurisdiction →

Green

Technical Compliance

AGCC requires all eGambling equipment to receive pre-launch approval under the Regulations, and reviews a licensee's internal control systems before go-live. This places a technical-certification gate ahead of commercial launch: a Category 1 or Category 2 licensee must clear its platform, equipment and internal control systems with the Commission before taking the product live, rather than certifying on a post-launch or self-certification basis.

· ~1 min read

For an operator building a launch timeline, this pre-launch review is a structural dependency sitting alongside, rather than instead of, the Regulation 243 capital-adequacy test that gates the licence itself.

Rng Certification Required
True
Game Approval Process
pre_launch_approval
Geolocation Required
not_yet_assessed
Data Localisation
none
Hosting Requirements
approved_locations
Technical Standards Body
AGCC
Confidence
Probable
Amber

Operational Obligations

Alderney licensees carry ongoing technical and operational obligations tied to the Category 1/2 structure. AGCC requires all eGambling equipment to receive pre-launch approval under the Regulations, and reviews internal control systems before go-live, so a licensee must have its platform and systems cleared by the Commission ahead of launch rather than on a post-launch basis.

· ~1 min read

The organisation-and-preparation function held under a Category 1 licence, covering player registration and verification, the contractual relationship with the player and management of player funds, sits alongside the effecting-of-transaction function held under a Category 2 licence, covering operational management of a gambling platform within an approved hosting centre, giving the two-category split a direct operational as well as licensing dimension.

Confidence
Probable
Amber

Cost to Operate

Alderney's licence-fee table bands cost to net gaming yield. A first-year Category 1 licence costs seventeen thousand five hundred pounds for a genuinely new entrant, rising to thirty-five thousand pounds for an application that does not meet that criterion. Renewal fees run from thirty-five thousand pounds for operators below five hundred thousand pounds of net gaming yield up to four hundred thousand pounds for operators at or above thirty million pounds of net gaming yield.

· ~1 min read

Applicants separately pay an initial investigation deposit of ten thousand pounds, a supplementary deposit of ten thousand pounds, and a modification fee of one hundred pounds where an application is varied, each payable in addition to the licence-fee table itself.

Tax Basis
GGR
Confidence
Probable
Amber

Payments & Money Flow

Confidence
Uncertain
Amber

Competitive Landscape

AGCC's own homepage cites an undated figure of more than ten hosting facilities and more than seventy licences and certificates in issue, a figure the source itself frames as approximate rather than a dated register extract. Named licensees operating under the framework include Bayroc (Alderney) Limited, Greentube Alderney Limited, Kambi Sports Solutions (Alderney) Limited, Marathon Alderney Limited, Playtech Software (Alderney) Ltd and Stanleybet Compliance Services Limited.

· ~1 min read

No Temporary eGambling Licensees are currently on issue, indicating the licensee base presently operating in Alderney relies on the substantive Category 1 and Category 2 routes rather than the time-limited temporary route.

Market Concentration
fragmented
Amber

Reform Horizon

A consultation addressing information-gathering and information-sharing powers and proliferation financing has concluded into the Alderney eGambling (Proliferation Financing etc.) Regulations 2024, together with accompanying 2024 and 2025 Amendment Ordinances. That transition from consultation to enacted instrument represents the completed reform item on Alderney's near-term horizon, layering additional information-gathering and reporting obligations onto the 2009 licensing framework without altering the underlying licence categories themselves.

· ~1 min read

AGCC's own guidance notes that the Greffier of the States of Alderney, not AGCC, is the official legislative source for the resulting instruments, so an operator tracking the detail of these obligations should look to the Greffier's published text rather than treat AGCC's own hosted copy as definitive.

Reform Stage
enacted_in_force
Regulatory Direction
tightening
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Trust & verification

1 contributor named on this record.

Expert review
Pending expert review
Content Source
AI-assembled from cited sources
Content Source
AI-assembled from cited sources
Advennt Baseline Research PipelineAsym Intel

Architecture patterns

7 patterns
Category 1 / Category 2 split-licence model
B2C/B2B Functional Separation Within One Regulator
player funds managementplatform operation
Associate Certificate pass-through for foreign entities
Supplier/Affiliate Certification Route
supplier due diligence
Approved hosting centre requirement for Category 2
Infrastructure Localisation Control
technical compliance
Temporary licence short-duration testing window
Time-Boxed Market-Entry Route
licensing compliance
AeGL/AGCC advisory-regulator separation
Developmental Advisory Body Distinct From The Regulator
conflict of interest mitigation
Net-gaming-yield banded renewal fee structure
Scaled Regulatory Fee Model
cost to operate
Multi-brand/domain operation under a single Category 1 licence
Brand-Sprawl Under Consolidated Licensing
marketing oversighttechnical compliance

Red Flags

4 flags
New Proliferation Financing Regulations 2024 and Amendment Ordinances 2024/2025 layered onto 2009 originals
Compliance teams relying on the 2009 originals without checking the AGCC consolidated/amendment stack risk non-compliance.
mediumaml cft
No public enforcement-action register/log located distinct from the licensee and fee pages
Limits counterparty due-diligence visibility into AGCC's actual enforcement record.
mediumenforcement transparency
AGCC leadership transition announced on the homepage
Supervisory posture/enforcement priorities may shift with new Commissioner composition.
lowgovernance
AGCC states the Greffier of the States of Alderney, not AGCC itself, is the only official legislative source
AGCC-hosted consolidated PDFs are convenience copies; legal reliance should verify against the Greffier's register.
lowlegislative sourcing
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What changed this cycle

Standing brief, pending expert review.

Alderney operates as an established offshore eGambling hub, regulated by the Alderney Gambling Control Commission under the Gambling (Alderney) Law 1999, the Alderney eGambling Ordinance 2009 and the Alderney eGambling Regulations 2009. The architecture rests on a two-part licence split: a Category 1 licence for the organisation and preparation of gambling operations, covering player registration, the contractual relationship with the player and management of player funds, and a Category 2 licence for effecting the gambling transaction itself, including operational management of a gambling platform within an approved hosting centre. Named licensees operating under this structure include Bayroc, Greentube, Kambi Sports Solutions, Marathon, Playtech Software and Stanleybet Compliance Services, each established as an Alderney entity. The compliance stack has recently been extended by a dedicated proliferation-financing instrument, layered onto the 2009 framework without altering the underlying licensing architecture itself.