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Understanding MGA Key Functions and Their Regulatory Role
The Malta Gaming Authority requires all licensed gaming operators to appoint specific individuals to carry out Key Functions. A Key Function refers to an important role or task carried out by a person in connection with a gaming service or a gaming supply, as defined in the Gaming Authorisations and Compliance Directive known as Directive 3 of 2018.
Only natural persons can act as Key Function holders. Each individual must hold a Certificate of Approval issued by the Authority. This certificate confirms that the person is fit and proper, has the necessary knowledge and experience, and is actively involved in the licensee’s operations. Appointments must be notified to the Authority using the appropriate portal.
A2CO helps B2C and B2B gaming businesses in Malta appoint and manage approved Key Persons with confidence and full compliance.
Key Function Roles for MGA Licensees
Key Function roles vary depending on the type of licence the business holds.
B2C Licence Holders (Remote Gaming and Controlled Premises)
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Chief Executive Officer or equivalent
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Management of day-to-day operations including payments, risk management, and fraud prevention
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Compliance including responsible gambling, player protection, and marketing standards
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Legal Affairs
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Data Protection and Privacy
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Anti-Money Laundering and Countering the Financing of Terrorism
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Technology and network security including back-end control systems
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Internal Audit
Operators of controlled premises must also appoint individuals responsible for:
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Surveillance systems
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Supervision of the gaming area
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Pit management
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Operation of urns or manual game result devices
B2B Licence Holders
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Chief Executive Officer or equivalent
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Operational management including tax and finance
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Compliance and sports integrity obligations
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Legal Affairs
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Data Protection if applicable
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Technology and information security
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Internal Audit
National Lottery Licence Holders
Includes all roles listed under B2C plus:
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Authorised persons who sell national lottery products
Each Key Function must be carried out by someone with the appropriate qualifications, experience, and understanding of the licensee’s operations.
B2C Licence Holders (Remote Gaming and Controlled Premises)
-
Chief Executive Officer or equivalent
-
Management of day-to-day operations including payments, risk management, and fraud prevention
-
Compliance including responsible gambling, player protection, and marketing standards
-
Legal Affairs
-
Data Protection and Privacy
-
Anti-Money Laundering and Countering the Financing of Terrorism
-
Technology and network security including back-end control systems
-
Internal Audit
Operators of controlled premises must also appoint individuals responsible for:
-
Surveillance systems
-
Supervision of the gaming area
-
Pit management
-
Operation of urns or manual game result devices
B2B Licence Holders
-
Chief Executive Officer or equivalent
-
Operational management including tax and finance
-
Compliance and sports integrity obligations
-
Legal Affairs
-
Data Protection if applicable
-
Technology and information security
-
Internal Audit
National Lottery Licence Holders
Includes all roles listed under B2C plus:
-
Authorised persons who sell national lottery products
Each Key Function must be carried out by someone with the appropriate qualifications, experience, and understanding of the licensee’s operations.
MGA Key Function Roles: Eligibility Criteria, CPD Requirements, and Conflict of Interest Rule
Suitability and Eligibility Criteria for Key Function Holders
To become a Key Function holder, a person must pass the Malta Gaming Authority’s fitness and propriety assessment. This includes checks on:
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Professional reputation
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Relevant qualifications and experience
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Availability to the Authority for information or reporting
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Competence and capability for the assigned function
Approved individuals are issued a Certificate of Approval which confirms their authorisation. The Authority also monitors all Key Persons during their appointment to ensure they continue to meet the expected standards.
A2CO supports you through the application process and helps ensure all eligibility criteria are met.
Continuous Professional Development for Key Persons
All Key Function holders are required to complete Continuous Professional Development to retain their approval. These obligations were introduced through amendments to the Gaming Authorisations and Compliance Directive that took effect in October 2021.
Key Persons must:
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Complete a minimum number of CPD hours each year
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Stay informed about regulatory changes and technical developments
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Maintain competence in their specific role or task
We help you track CPD progress and stay compliant with the Authority’s expectations.
Compatibility of Roles and Conflict of Interest
Certain roles are considered incompatible by nature. The Malta Gaming Authority prohibits any Key Person from holding functions that create a conflict of interest.
For example:
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A person responsible for Internal Audit cannot be involved in operations, compliance, or risk
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A single person may not carry out both executive and regulatory roles unless explicitly permitted
We help you design a governance structure that respects the Authority’s compatibility of roles requirements while remaining efficient and practical.
Suitability and Eligibility Criteria for Key Function Holders
To become a Key Function holder, a person must pass the Malta Gaming Authority’s fitness and propriety assessment. This includes checks on:
-
Professional reputation
-
Relevant qualifications and experience
-
Availability to the Authority for information or reporting
-
Competence and capability for the assigned function
Approved individuals are issued a Certificate of Approval which confirms their authorisation. The Authority also monitors all Key Persons during their appointment to ensure they continue to meet the expected standards.
A2CO supports you through the application process and helps ensure all eligibility criteria are met.
Continuous Professional Development for Key Persons
All Key Function holders are required to complete Continuous Professional Development to retain their approval. These obligations were introduced through amendments to the Gaming Authorisations and Compliance Directive that took effect in October 2021.
Key Persons must:
-
Complete a minimum number of CPD hours each year
-
Stay informed about regulatory changes and technical developments
-
Maintain competence in their specific role or task
We help you track CPD progress and stay compliant with the Authority’s expectations.
Compatibility of Roles and Conflict of Interest
Certain roles are considered incompatible by nature. The Malta Gaming Authority prohibits any Key Person from holding functions that create a conflict of interest.
For example:
-
A person responsible for Internal Audit cannot be involved in operations, compliance, or risk
-
A single person may not carry out both executive and regulatory roles unless explicitly permitted
We help you design a governance structure that respects the Authority’s compatibility of roles requirements while remaining efficient and practical.
Key Function Services Offered by A2CO
A2CO provides a full range of Key Function services for iGaming operators in Malta. Whether you are applying for a new licence, replacing a current Key Person, or seeking ongoing advisory, we can assist. All Key Persons we appoint are experienced, vetted, and approved in line with the MGA’s regulatory framework.
Our support includes:
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Outsourced Key Function holders across multiple roles
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Full preparation and submission of applications to the Authority
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Temporary cover for Key Functions
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CPD monitoring and advisory
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Strategic planning to meet role compatibility requirements
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Compliance Officer
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Money Laundering Reporting Officer
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Legal Officer
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Internal Auditor
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Data Protection Officer
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Technology and Security Oversight
Why Choose A2CO
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Full understanding of MGA Key Function regulations and policies
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Support tailored for B2C, B2B, and National Lottery operations
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Access to qualified and pre-approved Key Function holders
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Step-by-step guidance from application to long-term compliance
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Trusted by regulated operators across multiple jurisdictions
Frequently Asked Questions
They are defined roles required under Directive 3 of 2018 which must be assigned to approved individuals who are actively involved in the operation of a licensed gaming business.
You must notify the MGA within 3 working days and nominate a new key person with 15 working days.
Yes. Key Functions may be outsourced if the person is approved by the Authority and their role is formally registered with the MGA.
Yes, but only if the roles are compatible and do not create a conflict of interest. The Authority must approve any such arrangement.
The applicant must meet all eligibility criteria including competence, honesty, availability, and commitment to continuous professional development.
