Difference between B2C and B2B licenses in gambling

1) Basic definitions

B2C license - the right to accept players: keep the front (site/application), accept deposits/bets, accrue bonuses, store and pay funds, conduct marketing and support.

B2B license - the right to supply product/services to other licensed companies: platforms, games and RNG, content aggregators, payment gateways, anti-fraud/KUS services, hosting, affiliate networks, live casino studios, etc.

2) Who is responsible for what (responsibility architecture)

Zone	B2C	B2B
Relationship with player	Yes (offer agreement, payments, complaints, ADR)	No, only B2B contract
KYC/AML/Sanctions	Full responsibility	Only for their clients-companies (KYB)
Responsible Gambling (RG)	Mandatory (limits, self-exclusion, interventions)	Indirect (functions in product, SLA)
Payments and funds storage	Segregation of client funds, PSP, Travel Rule (if crypto)	None (except for B2B custodial models)
Advertising/Marketing	Full compliance (18 +, bonus disclosure)	Limited (B2B marketing, no "games" for the public)
Reporting to the regulator	GGR, payments, RG/AML KPI, complaints	Certifications, contracts, supplier audits
Technical certification	Platform, integrations, RNG/games (via B2B)	Platform/games/RNG itself, hosting, security

3) Requirements for the applicant: what is the difference

B2C (operator)

Fit & Proper beneficiaries and top management.

KYC/AML/CTF policies, sanction screening, transaction monitoring, EDD/SoF/SoW.

Responsible Gambling: deposit/loss/time limits, timeouts, self-exclusion, behavioral monitoring, VIP procedures.

Marketing: 18 +/21 +, prohibition of "risk-free/easy money," disclosure of bonuses, control of affiliates.

Payments: PSP/crypto-processing contracts, segregation of funds, chargeback/ADR procedures.

Data and security: GDPR/ePrivacy, DPIA, DPA with processors, WORM magazine, incident plan.

B2B (provider)

Fit & Proper safety executives and engineers.

Technical certification: RNG, games, platform, penetration/audit reports, DevSecOps processes.

KYB and sanctions on company customers; control of permissible jurisdictions.

SLA/policies: uptime, delays, incidents, export of logs "for inspection."

Licensed content framework: RTP/volatility, judicial settings, responsible-features in API/SDK.

4) Documents and checks (what is waiting on the filing)

General: statutory, ownership structure, register of beneficiaries, certificates of non-conviction, financial plan, business risk assessment (BWRA).

For B2C: KYC/AML/RG/marketing/complaints policies, PSP and ADR contracts, geoblock/banned country lists, user agreements, Privacy/Cookies.

For B2B: tech dossiers (architecture, hosting, access, encryption), laboratory reports on RNG/games, SDK/API documentation, versioning procedures, DPIA for telemetry.

5) Post-licensing responsibilities

B2C

Periodic reporting on GGR/taxes, RG/AML KPI, complaint log and ADR decisions.

"Signal" inspections (allocating limits, payment delays, marketing violations).

Updates of platform certifications and integrations, re-screening of sanctions/REP.

B2B

Maintaining RNG certificates/games and platform; monitoring judicial settings.

Client register and geo-perimeter; termination of services in case of violations.

Export logs/artifacts for customer and regulator checks; independent audits.

6) Taxes, fees and economics

B2C: pays license fees + taxes on GGR/profits, sometimes deductions to the responsible play fund; high operating expenses on KYC/AML/RG, support, marketing.

B2B: supplier license fees, income taxes/royalties; CAPEX/OPEX in certification, security, hosting, SLA penalties; revenue - subscription, royalties, rev-share.

7) Contracts and "boundaries" between B2C and B2B

DPA and Roles (GDPR): who is the controller/processor; List of sub-processors order of incidents (72 hours).

SLA: uptime, RTO/RPO, RNG delay/payout limits, log format, read-only access for audit.

Compliance clauses: prohibition of "gray" geo, mandatory RG features, prohibition of RTP manipulations, the right to suspend service in case of violations.

Marketing: using studio brands, limiting creatives, banning "risk-free."

8) When B2C is needed, when B2B is needed, and when both

B2C only: pure operator with purchased content/platform; the goal is to work with the player and marketing.

Only B2B: game studio, aggregator, platform, anti-fraud/KUS-service, live-provider.

Both: a holding with an operator wing (B2C) and a vendor wing (B2B): accelerates integration, but requires separation of roles, data and risk management (ring-fencing).

9) Typical errors

B2C thinks "B2B will close everything." No: RG/AML, marketing, payouts - B2C operator zone.

B2B forgets about judicial settings. Delivering content to banned geos is a risk for both.

No DPA/SLA. Without contractual roles and metrics, it is difficult to pass an audit and defend yourself in disputes.

"Risk-free" in B2C marketing. Even with a "white" license, creatives with promises are the way to fines and bans.

Data mixing. No segregation (prod/test, customers/players) = risk of incidents and sanctions.

10) Checklists

B2C - Before Supply

KYC/AML/RG policies and work tools (limits, self-exclusion, case manager).
PSP/ADR contracts, segregation of funds, geoblock/blacklists.
Marketing guide: 18 +/disclosure of bonuses/prohibition of "risk-free," control of affiliates.
Platform and integrations are certified; WORM, SOC/pentest logs.

B2B - before supply

RNG/Games/Platform Certification, Lab Reports.
DPIA/security: encryption, RBAC/MFA, admin log, DR/BCP.
SLA/DPA templates, incident processes (72 hours), sub-processor register.
Client admission policy (KYB, sanctions, geo), offboarding in case of violations.

11) Mini-FAQ

Is it possible to sell games without a B2B license if customers are offshore?

In most mature regimes, no. A vendor license and content certification will be required.

Can B2C work without its own platform?

Yes, on the licensed B2B platform, but responsibility for RG/AML/marketing remains with B2C.

Does the affiliate need a B2B license?

Not usually unless it delivers games/platform. But advertising rules and contracts with B2C apply.

If we are B2B, do we have RG responsibilities?

Indirect: obliged to provide RG functions in the product and not interfere with B2C to perform them.

Can I convert B2B to B2C?

These are different permissions. It is often more convenient to open a separate entity and obtain a second license.

The separation is simple: B2C is about the player and money, B2B is about technology and content. From here, different requirements grow: B2C lives KYC/AML/RG, payments and advertising; B2B - RNG/game certification, SLA and platform security. When choosing a path, proceed from a role in the value chain. If you build an ecosystem, separate licenses, processes and data: it's easier to go through audits, scale and maintain the trust of regulators, payment partners and studios.