Nevis Gaming Licence 2026: What the Ordinance, the Gazetted Fees and the Register Show

What the Nevis licence is

St Kitts and Nevis is a two-island federation, and Nevis has its own Island Assembly and Administration. The online gaming regime is a Nevis law, not a federal one. The Nevis Island Assembly passed the Nevis Online Gaming Ordinance, No. 2 of 2025 on 29 April 2025. The Regulations that make it workable, S.R.O. No. 5 of 2025, were published in Official Gazette No. 34 on 26 June 2025 and came into effect on 1 July 2025, the day NOGA began taking applications. Section 1(2) leaves the Ordinance’s commencement to a ministerial order in the Gazette. We did not find that order; press reports give 1 May 2025.

The Ordinance creates two classes of licence (s. 8). A B2C licence lets an operator offer online gaming directly to players. A B2B licence lets a supplier provide “critical supply of services, gaming systems and software” to B2C operators. One licence may cover several forms of gaming (s. 8(2)), and “online gaming” is defined widely: casino games, sports betting, poker, lotteries and “any other game of chance conducted over the internet” (s. 2). NOGA’s licensing requirements add that a white-label operation needs both a B2C and a B2B licence plus separate authorisation.

Who licenses, and who runs the Authority

Most vendor pages describe NOGA as “the regulator”. The Ordinance spreads the job across three parties, and the money goes to a fourth.

Role	Who	Section
Receives and reviews applications, recommends grant, refusal, suspension or revocation	Nevis Online Gaming Authority	s. 4(1)(a)-(b)
Issues, refuses, amends, suspends and revokes licences	Minister responsible for Finance in the Nevis Island Administration	ss. 14(3), 15(2), 16, 21, 22
Supervises and examines licensees, may inspect without notice	The Regulator, an individual appointed by the Minister	ss. 35-37
Runs the Authority day to day, hires its staff, collects fees	The management company	ss. 3(1)-(2), 5, 13(2)

Section 3(1) says the Authority “shall be managed by the management company”. The management company recruits and pays the staff (s. 3(2), (5)), must be a local company (s. 5(2)), reports to a “Board” defined as the board of directors of the management company (s. 2), and may not hold a licence or have a financial interest in a licensee (s. 5(7)). Section 13(2) is blunt: “Fees paid under this Ordinance shall be payable to the management company which manages the Authority.” The Ordinance does not say what share of that money, if any, reaches the Administration.

NOGA’s own website fills in the names. Its footer says the site “is owned and operated by Apex Capital Partners, incorporated in Nevis, acting as the management company of the Nevis Online Gaming Authority”, and that “NGA Management Limited, incorporated in Gibraltar, acts as the payment processor for all fees”. Its team page lists a CEO, COO and CCO, the kind of staff s. 3(2) has the management company appoint, next to the government Regulator.

On the regulator side, the Nevis Island Administration announced on 2 October 2026 that Phil Jones would be Regulator, Online Gaming, at the Nevis Branch of the Financial Services Regulatory Commission. He handed his international banking responsibilities to Marie-Grace Michel on 1 October 2026. Until then one person held both portfolios.

None of this makes the licence unlawful. The structure is written into a statute passed by an elected assembly. It does change what a bank or payment provider is looking at. The decision on a file is a ministerial one, made on the recommendation of a body that the fee recipient manages, under supervision by one designated FSRC officer. Tobique’s Gaming Act also gives a management company a role in licensing; our Tobique register analysis covers it.

The fees, as gazetted

Schedule 1 to the Regulations is the legal fee schedule. Regulation 3 makes every fee in it non-refundable.

Fee	Schedule 1 description	EUR	Frequency (Schedule 1)
Licence fee (B2C)	Annual fee for operating online gaming services	28,000	Annual
Licence fee (B2B)	Annual fee for providers supplying to licensees	28,000	Annual
Licence renewal fee	For renewal of licence	28,000	Annual
Additional URLs	For adding additional URLs	750	Per licensing cycle
Sub-domains, up to 49	Each sub-domain	35	Per licensing cycle
Sub-domains, 50 or more	Each, submitted together	15	Per licensing cycle
Change request	Due diligence on a new director, shareholder or UBO	1,000	Per request
Change request	Material change in ownership	5,000	Per request

NOGA’s fees page prints the same amounts with one difference. It describes the B2C and B2B licence fee as a “Setup fee”, payable “One time”, and keeps the renewal fee as annual. The gazette describes that same fee as annual. Section 22(1)(g) speaks of a licensee that “fails to pay its annual fee to renew its licence”, which fits a single EUR 28,000 a year: the licence fee in year one, the renewal fee after that. That is how NOGA charges, and it is the reading we use below. It is worth having in writing.

Section 10(2)(b) requires the applicant to tender “a non-refundable fee as prescribed” together with “the applicable annual license fee”. Schedule 1 prescribes no separate application fee, so in practice the EUR 28,000 is paid when the application goes in (s. 13(1)) and is not returned if the application is refused. The same fees page also says “volume discounts available”, which a gazetted schedule does not provide for.

Other sums in the Ordinance are in US dollars, since ”$” means US dollars unless stated otherwise (s. 2): USD 10,000 to appeal a refusal or revocation, refunded if the appeal succeeds (s. 40(5)); USD 2,500 plus USD 1,000 a day for not displaying the licence on the website (s. 26(2)); USD 15,000 plus USD 1,000 a day for not keeping financial records at the Nevis registered office (s. 29(3)); USD 500 a day for late audited accounts (s. 30(4)); USD 8,000 for letting a self-excluded player keep playing (s. 32(9)).

Three years of regulator fees, compared

The table counts only fees set by each regulator’s own published schedule, for one B2C licence held for three years. Company formation, the local reporting officer, legal work and banking are excluded everywhere.

Licence	Year 1	Years 2 and 3	Three-year total	Source
Nevis	EUR 28,000	EUR 28,000 each	EUR 84,000	S.R.O. 5/2025, Sch. 1
Anjouan	EUR 17,828	EUR 17,828 each	EUR 53,484	Anjouan fee schedule
Curaçao	EUR 4,592 + 47,450	EUR 47,450 each	EUR 146,942	LOK arts 5.18-5.19, Curaçao cost guide

Nevis costs EUR 30,516 more than Anjouan over three years, about 57% more each year. It costs about 57% of Curaçao’s B2C fees, and the substance gap is wider than the fee gap: Curaçao requires a resident manager and a Key Person on the local population register, while Nevis asks for a local reporting officer registered with the FSRC. A group that needs both a B2C and a B2B licence in Nevis pays EUR 56,000 a year. Two extra URLs add EUR 1,500 a year. We could not confirm from the gazette how many URLs the base fee includes.

What the register shows

NOGA’s License Register lists the holder, status, licence number, expiry date, type and authorised URLs. We read it on 12 October 2026 and counted the rows with a script.

Measure	12 October 2026
Licences listed	11
B2C	9
B2B	2
Status other than Active	0
Authorised URLs	13 (one licensee holds three)
Earliest issue date	24 December 2025
Latest issue date	20 September 2026

Section 19 makes a licence expire on the anniversary of its issue, so each issue date is the listed expiry minus one year. The licence numbers carry the same year and month (LIC-B2C202512… for the licence expiring 24 December 2026). By that count the first licence came 176 days after applications opened, and ten more followed between February and September 2026, a little over one a month.

One date does not reconcile. On 7 May 2026 NOGA announced the issue of its “eighth online gaming licence”. The register as we read it shows seven licences issued before that date. Either a licence issued before May has left the register, or the announcement counted something else. The register has no expired, suspended or revoked rows that would say which. Section 18 requires those statuses to be published, together with each licensee’s registered address and contact information. The register shows neither.

At EUR 28,000 each, the 11 listed licences represent at least EUR 308,000 in licence fees, all payable to the management company under s. 13(2).

What a licensee has to do

Company. Sections 7 and 9 allow a Nevis company or corporation, and s. 7(1)(b) also allows a foreign company registered in Nevis. NOGA’s application page says “Only companies incorporated in Nevis are eligible to apply”, so plan for a Nevis entity. The licence is not transferable (s. 14(5)), and at least one director must be an individual (s. 16(2)(d)).

People. A Compliance Officer and a Reporting Officer appointed under the FSRC (Minimum Guidelines for Compliance and Reporting Officers) Regulations, No. 11 of 2018 (s. 17). The licence conditions add a Key Person, a money laundering reporting officer, and a local reporting officer in Nevis registered with the FSRC (conditions 9-11). Directors, beneficial owners and senior managers must pass fit-and-proper tests and keep passing them (s. 9(3)).

Records. Financial records kept at the Nevis registered office (s. 29(2)) for five years after the business relationship ends (s. 29(4)). Financial statements are due within three months of each year end (s. 30(2)), and an annual report covers revenue, player data and compliance measures (s. 29(6)).

Players. Registration with identity, date of birth and residence before play (s. 31(2)), a minimum age of 18 (s. 32(3)), self-exclusion for at least three months (s. 33(2)), and an addiction warning on the entry screen (s. 32(2)). Licence conditions 4 and 5 require photo ID and a utility bill before any payout, and once aggregate deposits reach USD 2,000. Unresolved disputes go to an ADR provider approved by NOGA, at the licensee’s cost (condition 13).

Markets. The Regulations require geo-IP blocking of Australia, Austria, France, Germany, the Netherlands, Spain, St Kitts and Nevis, the UK, the USA and FATF-blacklisted countries (Sch. 3 para. 6(d)). NOGA’s restricted-countries list and condition 2 add “all sanctioned countries”. The licence cannot be used to serve players in the federation that issues it.

What we could not verify

• The ministerial commencement order under s. 1(2). Press reports give 1 May 2025; the copy of the Ordinance we read carries the date 1 May 2025 under the Governor-General’s line.
• Any agreement between the Nevis Island Administration and Apex Capital Partners, or how the fees collected are shared.
• Regulations under s. 18 prescribing where and when the list of licensees must be published.
• Corporate and other tax treatment of a Nevis licensee. The Ordinance contains no gaming tax. We have not checked the Nevis corporate statutes for this page.

Small inconsistencies remain in NOGA’s own documents. The definition section of the Ordinance calls the body the “Nevis Gaming Authority” and s. 3 calls it the “Nevis Online Gaming Authority”. The licence conditions require compliance with an “Online Gaming Act, 2025”, a name no Nevis statute carries. None of these changes what a licensee pays or must do. They are worth knowing when a bank’s compliance team reads the same documents.