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Jurisdictions › Comoros

Comoros Online Gambling Regulation, Licensing & Tax Regime

Federal layer
13 closed · 7 not yet assessed → 20 classes
Regulator: None — Gambling Prohibited (Banque Centrale des Comores / BCC offsho… · Collected 25 Oct 2026 · Published 25 Oct 2026 · Changed 25 Oct 2026 PDF Sign in for PDF Compare
Regulatory DimensionComoros Standing Position
JurisdictionComoros (KM)
Primary Gambling RegulatorNone — Gambling Prohibited (Banque Centrale des Comores / BCC offshore warning)
Product Access Summary13 closed · 7 not yet assessed
Permitted (Open) VerticalsNone recorded as open
Prohibited (Closed) VerticalsCasino, Poker, Bingo, Lottery, Sports betting, Esports betting, Fantasy sports, Skill games, Sweepstakes, Software / B2B, Affiliate marketing, Payments for gambling, Crypto gambling
Primary Instruments ReferencedBCC-COMMUNIQUE-2025-12-08-PAGE; BCC-COMMUNIQUE-2025-12-08-PDF; GIABA-FATF-MER-COMOROS-2024-05
Verification & CurrencyAI research, not expert reviewed · Published 25 Oct 2026 (collected 25 Oct 2026)

Can we offer our product?

Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product.

Player products

  • CasinoProhibited
    Closed
  • PokerProhibited
    Closed
  • BingoProhibited
    Closed
  • LotteryProhibited
    Closed
  • Sports bettingProhibited
    Closed
  • Other event betting
    Not yet assessed
  • Horse and greyhound racing betting
    Not yet assessed
  • Esports bettingProhibited
    Closed
  • Exchange betting
    Not yet assessed
  • Pool betting
    Not yet assessed
  • Virtual event betting
    Not yet assessed
  • Fantasy sportsProhibited
    Closed
  • Skill gamesProhibited
    Closed
  • Prediction markets
    Not yet assessed
  • SweepstakesProhibited
    Closed
  • Free play
    Not yet assessed

Supply roles

  • Software / B2BProhibited
    Closed
  • Affiliate marketingProhibited
    Closed
  • Payments for gamblingProhibited
    Closed

Settlement rail

  • Crypto gamblingProhibited
    Closed

No class-level certainty grade is recorded for this jurisdiction yet; confidence is carried per section below.

Board briefing

Comoros remains a hard-closed, criminally-enforced gambling prohibition with no licensing pathway of any kind; a December 2025 Central Bank communique newly and explicitly disclaims the Anjouan, Mwali/Moheli and Grande Comore island-level bodies as sources of any recognised licence.

What has changed

  • The Central Bank of the Comoros issued a communique on 8 December 2025 stating that entities claim, without authorisation, to be organisations or financial institutions linked to the Union of Comoros, and that no national online betting/gaming licence has been or can be issued by the disclaimed island-level claimant bodies.

What to do now

  • Treat any Anjouan, Mwali/Moheli, or Grande Comore gaming licence as having zero legal standing under Union of Comoros law; do not rely on such licences for compliance purposes; flag any counterparty presenting one as a critical red flag.

What to watch

  • Watch for (a) any future BCC communique naming additional claimant bodies, (b) resolution of the unexplained historical FATF/APG data point showing operating casinos in Comoros despite the statutory prohibition, and (c) any primary Penal Code text becoming independently accessible to firm up the art. 201 citation.

11 answers, each dated and graded

The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain.

Unfavourable

No licence types, issuing authority, or application pathway exist for gambling in Comoros. The licensing-pathway-exists field for the jurisdiction resolves to false, reflecting the absence of any statutory mechanism by which an operator could apply for, hold, or renew a gambling licence. The control…

Full analysis · 149 words

No licence types, issuing authority, or application pathway exist for gambling in Comoros. The licensing-pathway-exists field for the jurisdiction resolves to false, reflecting the absence of any statutory mechanism by which an operator could apply for, hold, or renew a gambling licence. The controlling instrument is the Penal Code itself (Law No. 20-038/AU of 29 December 2020, article 201 et seq.), which prohibits casinos and gambling establishments outright and separately prohibits lotteries and all games of chance. No agrement — the licence instrument used for financial activity in Comoros — has ever been issued for the offshore exercise of banking, finance-company or financial-establishment activity tied to any Comorian island, a disclaimer that reaches beyond banking into the claimant gaming-licensing space addressed by the Central Bank's December 2025 communique. There is accordingly no B2B or B2C licensing requirement, renewal process, or suspension or revocation mechanism distinct from general criminal enforcement.

Confirmed · AI-generated · Read full analysis & tables →
08 · What must the platform meet?

Comoros Gambling — Technical compliance

Unfavourable

No RNG certification regime, approved testing laboratories, game-approval process, or technical-standards body exists for gambling in Comoros; the technical-standards-body-exists field resolves to false. The prohibition is enforced through general criminal law under the Penal Code, Law No. 20-038/AU…

Full analysis · 107 words

No RNG certification regime, approved testing laboratories, game-approval process, or technical-standards body exists for gambling in Comoros; the technical-standards-body-exists field resolves to false. The prohibition is enforced through general criminal law under the Penal Code, Law No. 20-038/AU article 201 et seq., rather than through a technical-compliance apparatus of the kind found in regulated markets, meaning there is no server-location rule, no GLI- or ISO-equivalent conformance standard, and no certification cost or lift for an operator to budget for. This is a direct consequence of the absence of any licence against which a technical standard could be imposed, rather than a gap within an otherwise-operating technical-compliance regime.

Confirmed · AI-generated · Read full analysis & tables →
09 · Can we ship through apps and platforms?

Comoros Gambling — Distribution and platforms

Unfavourable

No platform-specific regulatory instrument — no app-store ruling, no ISP-blocking order, no search-engine de-listing requirement, and no affiliate-marketing-platform restriction — specific to Comoros was identified. Restrictions in this area are inferred from the blanket statutory prohibition of cas…

Full analysis · 107 words

No platform-specific regulatory instrument — no app-store ruling, no ISP-blocking order, no search-engine de-listing requirement, and no affiliate-marketing-platform restriction — specific to Comoros was identified. Restrictions in this area are inferred from the blanket statutory prohibition of casinos, gambling establishments, lotteries and games of chance under the Penal Code rather than directly evidenced by a dedicated distribution-platform instrument. Affiliate marketing of gambling is treated as falling under the same general prohibition, absent any statutory carve-out for promotional activity, which is the closest the record comes to a platform- or marketing-adjacent rule; no payment-provider platform restriction specific to gambling distribution was separately identified beyond the general payments posture.

Uncertain · AI-generated · Read full analysis & tables →
10 · How hard does the regulator enforce?

Comoros Gambling — Enforcement

Mixed

The Comoros Union government has requested United Kingdom law-enforcement and financial-intelligence cooperation and stated that it is preparing domestic legal action over the Anjouan-branded licensing network, which markets gambling, forex and CFD, and crypto-business authorisations with no recogni…

Full analysis · 147 words

The Comoros Union government has requested United Kingdom law-enforcement and financial-intelligence cooperation and stated that it is preparing domestic legal action over the Anjouan-branded licensing network, which markets gambling, forex and CFD, and crypto-business authorisations with no recognised legal basis under Union law. This marks a material shift from prior unilateral government disclaimers to active cross-border cooperation, following reporting that named United Kingdom-registered entities, ACS Global Custodian and Sherm Group, both linked to London's Sorsky family, as administering the disputed licensing ecosystem. No primary Comoros government document confirming the cooperation request or the stated legal action has been located this period; the record rests on secondary trade-press reporting of an underlying investigation. Whether a Comoros court or administrative body has separately ruled on the validity of the Anjouan-claimant Computer Gaming Licensing Act of 2005 remains unestablished beyond a single report that the instrument is unsigned and unstamped.

Uncertain · AI-generated · 1 enforcement event · Read full analysis & tables →
Evidential record & source register 0 enforcement · 3 red flags · 8 sources · Expand full record

What gets operators fined

3 red flags (1 high, 1 medium) and 0 controls that address them.

  • high
    Documented misuse of the KM IBAN by offshore companies.
    Indicates an active typology of using Comorian banking identifiers to lend false legitimacy to offshore financial flows, which is directly relevant to any gambling-adjacent payment rail touching Comoros.
    Sources
  • medium
    Historical FATF/APG data showing operating casinos in Comoros despite a documented statutory prohibition.
    Suggests either stale data, a tolerated informal sector, or an unresolved legal gap — all of which raise due-diligence uncertainty for any counterparty claiming a lawful physical gambling presence.
    Sources
  • critical
    Any counterparty presenting an Anjouan, Mwali/Moheli, or 'Grande Comore' gaming licence as a national Comorian authorisation.
    The BCC has publicly and specifically disclaimed these bodies as unrecognised; reliance exposes the operator to zero national legal protection and potential criminal liability.
    Sources

What we looked for and could not find

Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall.

Market opportunity. no GGR estimate, market-size figure, or growth data exists for a jurisdiction with a blanket statutory prohibition and no tolerated grey market identified.
  • searched: Comoros gambling market size estimate
  • searched: Comoros GGR gambling
  • searched: Comoros online betting market revenue
  • checked: banque-comores.km
Cost to operate. no fee schedule or tax basis exists — there is no licence to tax.
  • searched: Comoros gambling tax rate
  • searched: Comoros gambling licence fee
  • searched: Comoros gaming duty
  • checked: banque-comores.km
Payments and money flow. no gambling-specific payment rules or capital-control instrument located beyond the BCC's general offshore-finance disclaimers.
  • searched: Comoros capital controls gambling payments
  • searched: Comoros BCC foreign exchange gambling
  • searched: Comoros payment processor gambling restriction
  • checked: banque-comores.km
Technical compliance. no technical standards body, RNG certification regime, or hosting requirement exists for gambling because no licensing framework exists.
  • searched: Comoros gambling technical standards
  • searched: Comoros RNG certification
  • searched: Comoros gaming equipment testing
  • checked: banque-comores.km
Distribution platform rules. no named regulator or platform-specific ruling located; statuses inferred rather than directly sourced.
  • searched: Comoros app store gambling restriction
  • searched: Comoros Google Play betting app ban
  • searched: Comoros advertising gambling law
  • checked: banque-comores.km
Data protection. no primary data-protection statute or supervisory authority for the Comoros was identified this run, gambling-specific or otherwise.
  • searched: Comoros data protection law
  • searched: Comoros data protection authority
  • searched: Comoros loi protection des données personnelles
  • checked: banque-comores.km
Consumer protection. no general consumer-law framework or ADR body for the Comoros was identified this run.
  • searched: Comoros consumer protection law
  • searched: Comoros ADR consumer disputes
  • searched: Comoros loi protection consommateur
  • checked: banque-comores.km
Licensing and regulation / regulated activity classes. primary Penal Code text (Law No. 20-038/AU, art. 201 et seq.) was not independently fetched — all statutory claims rest on the GIABA MER's characterisation of it, not the primary instrument.
  • searched: Comoros Penal Code loi 20-038/AU texte intégral
  • searched: Comoros Journal Officiel loi gambling 2020
  • searched: Comoros Code Pénal article 201
  • checked: banque-comores.km

Source register

Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites.