Market entry in practice: How hard is entry, really?

Time-to-launch is typically 9 months or more, depending on the complexity and readiness of the application and technical setup. In order for a person to be eligible to hold an MGA licence, such person has to be established in the EEA. There is no specific requirement for a licensee to be an incorporated entity in Malta. However, the licensee must satisfy the applicable requirements concerning its operations . Furthermore, persons who perform key functions for the business do not necessarily have to be present in Malta. They must however be available upon MGA’s request The Key Function Roles have to be appointed at different stages of the application. At the application stage, notification to the MGA must be made regarding those who will hold the roles of Chief Executive Officer, Compliance Officer, and if applicable, the MLRO. Later, within six months of the issuing of the licence, the MGA must be notified as to who has been appointed to exercise the remaining Key Function Roles. Licensees are obliged to maintain a live or real-time mirror server for essential regulatory data being at all times accessible to the MGA. Minimum share capital is €100,000 (Type 1/2) or €40,000 (Type 3/4), with higher cumulative requirements applying where multiple game types are offered. Bottlenecks centre on fit-and-proper vetting, system review and the AML/CFT framework build. The adviser stack (including law firms, CSPs, auditors) is mature.