"data processing" model instead of license: how online operators work in Costa Rica

Costa Rica has a special place on the iGaming map: there is no separate law and no single regulator for online gambling, and there is no classic "online casino license." Instead, companies are formed as data processing businesses and conduct activities focused on foreign players. The key principle is not to target Costa Rican residents. This design is often used to quickly enter the market at moderate costs, understanding its limitations.

What "no separate law/license" means

There is no profile online act and regulator. There is no special legal regime in the country that issues a "gambling license" for the Internet. The industry information materials explicitly state: Costa Rica does not provide formal online licenses, and operators register as data processing businesses.

Extraterritorial logic. It is allowed to serve only foreign customers; at the same time, the norms of those jurisdictions where services are actually offered should be observed. A ban on serving Costa Rican residents is a standard condition.

How the data processing model works

1. Incorporation (S.A./S. R.L.) and registration. Further, the company receives a municipal/commercial permission for data processing activities (business/data processing license).

2. Actual activities - hosting, support, risk analytics, processing of transaction/game data - are conducted in Costa Rica, and the product is focused on foreign markets.

3. Access rules for players. The sites establish geo-restrictions and disclaimers about the lack of an offer for residents of the country.

Advantages of the model

Fast and inexpensive launch. There is no long-term licensing: corporate registration and permission for data processing are enough. This lowers the entry threshold for startups and MVPs.

Low regulatory load. There are no annual "gaming" audits from the profile regulator; general requirements relate mainly to corporate and AML/KYC circuits.

Cons and vulnerabilities

Payment infrastructure. Without a formal online "license," banks and acquiring providers often refuse or require an increased volume of documents; card schemes and popular PSPs are available to a limited extent.

Reputation and partnerships. The absence of a "stamp" of the licensing jurisdiction reduces the confidence of some affiliates and B2B partners; it is often recommended to buy a second, "classic" license later.

Tight geo-control. Violation of the ban on serving local players can entail risks and claims; geo-blocks and verification - must-have.

Taxes and operating expenses (brief)

Taxation regime - general corporate, without special rates "for online"; often the revenues generated outside the country are structured so as not to be taxed in Costa Rica. Actual amounts depend on the group's corporate scheme and municipal fees.

Practical start-up checklist

1. Establish S.A./S. R.L. and issue a municipal/business license for data processing. 2) Register the extraterritorial model in the statutory documents and contracts. 3) Enable geo-blocking CR and clear disclaimers on the site. 4) Configure AML/KYC and Responsible Gambling policy. 5) Test several payment circuits (aggregators, alternative methods, crypto-on/off-ramp) and, if necessary, transfer acquiring to other jurisdictions.

Who it suits

Startups and small operators who care about speed and economy.

B2B players (outsource/platforms) placing part of the team and processes in Latin America.

Brands with a "two-step" strategy: a quick start in Costa Rica and the subsequent receipt of a classic license (Curacao, Malta, Maine, etc.) to improve payments/reputation.

Important caveats

Information on municipal permitting practices, bank requirements, and interpretation of regulations may change. Before launching, it is recommended to obtain a local legal opinion and update the payment plan with specific PSPs. Recent industry surveys in Costa Rica confirm that the base model remains "data processing without a separate online license," while the growth of requirements from payment partners continues.

Inference. In Costa Rica, instead of the classic online license, the corporate model of "data processing" is used: it allows you to quickly launch and serve foreign markets, but requires strict geo-compliance and a well-thought-out payment architecture. For scaling, it is almost always useful to plan a "second" - licensing - jurisdiction.