How to get a sublicense from a platform provider

1) What is a "sublicense" and who needs it

Sublicense is the right to operate in iGaming under the regulatory umbrella of a licensed platform provider. The provider holds the basic license and infrastructure (platform, hosting, KYC/AML tools, access to game providers, payments), and you launch the brand as a partner operator on its stack.

Who is suitable:

startups with a limited budget and a goal to quickly enter the market;
studios/affiliates transitioning to B2C;
hypothesis test before obtaining your own license.

2) Work models: white-label vs. turn-key under umbrella

White-label (WL): the provider provides a platform, hosting, payments, compliance, access to content, sometimes support. You focus on brand, marketing and CRM. The launch is the fastest, but there is less freedom in customization and providers.

Turn-key under umbrella: more control (choice of games/PSP, own CRM/BI), but responsibility for processes is higher; Share compliance with the provider under the contract.

Hybrid: WL at the start → gradual customization of modules and migration to an independent license.

3) Applicant requirements (usual)

1. Legal entity and beneficiaries: statutory documents, ownership structure, KYC for UBO/directors, certificates of non-conviction/sanctions.

2. "Fit & Proper" of key persons: relevant experience (operations, compliance, risk, marketing).

3. Financial viability: confirmation of the source of funds (SoW) and the operating budget for 6-12 months.

4. Marketing plan and geo-strategy: target countries, channels, responsible advertising policy.

5. Politicians: KYC/AML/sanctions, Responsible Gaming, complaints/ADR, privacy/GDPR, information security.

4) Sublicense Process: Steps

Step 1. Pre-screening providers

Check: jurisdiction of the base license, reputation, list of connected studios/aggregators, available PSP/crypto processing, SLA compliance, geo requirements.

Step 2. NDA и data-room

The provider opens the conditions: contract template, pricing, onboarding checklist, due diligence questionnaires.

Step 3. Due diligence on you

KYC/" fit & proper" package, financial plan, marketing declaration, RG/AML policy, domains/trademarks.

Step 4. Contract and Responsibilities

controller/data processor boundaries;

who runs KYC/AML (built-in provider vs. your stack);
RG tools (limits/self-exclusion/reality check) and reporting;
marketing and affiliates (pre-approval of creatives, stop lists, prohibition of "risk-free");
geoblock and list of prohibited countries;
Ombudsman/ADR and Complaint Handling;
payments and segregation of player funds;

SLAs/fines, audits, termination, migration.

Step 5. Technical preparation and certification

Branding, domains, integration of game/payment providers, setting up CUS/sank screening, logging (WORM), RG/AML reporting, pentest/security.

Step 6. Marketing validation

Social media/platform policies (Google/Meta/YT/TikTok/X), 18 +/responsible play, bonus disclosure, ban on cloaking/mirrors.

Step 7. Soft-launch → go-live

Test deposits/conclusions, check SLA support, monitor anti-fraud and on-chain risks (if crypto), launch with limited traffic, then scale.

5) Timing and budget (benchmarks)

Timeline: 4-12 weeks from signing to soft-launch with ready-made content and creativity.

One-time: setup-fee platforms, integrations, brand package, legalization of documents (if necessary).

Operating: monthly platform fee,% GGR/turnover, KYC/AML checks, payment commissions, content royalties, as well as marketing and support costs.

💡 Important: different providers may have different models (flat fee + rev-share/rev-share only/minimals +%).

6) Pros and cons of sublicense

Pluses

Fast time-to-market and low receipt.

Ready-made integrations: top studios, PSP, anti-fraud/KYC/AML, reporting.

Consulting and operational support from an experienced team.

The ability to simultaneously prepare your own license.

Minuses

Less control over the stack and providers.

Geo/marketing restrictions (follow the politics and risk appetite of the platform).

Dependence on SLA/provider solutions, risk of pricing changes.

The reputation "under the umbrella" is sometimes weaker than its own license for some PSP/partners.

7) Compliance: that "must-have" even under an umbrella

KYC: ID + liveness, PoA, sanctions/PEP/address media; ownership of the payment method.

AML/CTF: risk score by country/channel, transaction monitoring, EDD/SoF at thresholds, onchain screening, and Travel Rule (if crypto).

Responsible Gaming: deposit/loss/time limits, timeouts and self-exclusion, behavioral alerts, VIP procedures, zero self-exclusion marketing.

Marketing rules: 18 +/21 +, prohibition of "risk-free/easy money," disclosure of bonuses (deposit, vager, deadline, max-win), control of affiliates.

Data and security: GDPR/ePrivacy, RoPA/DPIA, encryption, RBAC/MFA, WORM logs, incident plan (72 hours), DPA with sub-processors.

8) Checklist before signing the contract

Platform reputation and references; list of connected studios/PSPs.
Umbrella jurisdiction, compatibility with your geo and ads.
Monetization model (fees + rev-share), minimals, transparency of calculations.
SLA: uptime, LC/payouts, compliance and support response times.
Boundaries of responsibility for AML/RG, veto over creatives/affiliates.
Geo-block conditions, blacklists, VPN/ASN policy.
DPA/GDPR: supervisor/processor roles, list of sub-processors.
ADR/complaint procedures, logging and export of data "for inspection."
Termination and migration procedures (data, domains, wallets, players).

9) Typical mistakes and how to avoid them

The race for the minimum price → hidden restrictions on content/geo/payments. Take TCO, not just rev-share.

No marketing compliance → bans in Google/Meta/publishers, traffic stop. Prepare bonus disclosure templates and "responsible play."

Weak geoblocking → traffic from prohibited countries = risk of outages and fines.

KYC/AML "on paper" → without real logs/cases, the provider will limit the limits or suspend the brand.

Lack of a migration plan → a stop factor in growth. Agree on the transfer to your own license in advance.

10) 60/120 Day Roadmap

0-30 days: provider selection, NDA, pre-screening; KYC/" fit & proper" collection, geo/marketing coordination; draft contract.

30-60 days: branding, domains, content/PSP integrations, KYC/AML/RG setup, test payments; internal audit and pentest.

60-90 days: pre-approval of creatives/affiliates, soft-launch with limited traffic, calibration of anti-fraud and RG signals.

90-120 days: scaling, reporting, preparation for a possible migration to your own license.

11) Mini-FAQ

Sublicense replaces own license permanently?

No, it isn't. It's a fast start. As they grow, many migrate to their own license, keeping the platform or changing the stack.

Is it possible to connect "your" game/payment providers?

Depends on the model. In WL - less often; in turn-key under an umbrella - more often, but with approvals and technical requirements.

Who is responsible for AML/RG violations?

Both: you are for marketing, onboarding, operations; provider - for the "umbrella" and system contours. This should be clearly stated in the contract.

How long does a player's KYC take at kickoff?

With correct documents - minutes. UX prompts, good photos, lack of VPN and compliance of the payment method with the account owner are important.

Is it possible to work with crypto?

If the "umbrella" and the provider allow it, yes, but with online screening, Travel Rule (if necessary) and a policy of segregation of funds.

Sublicense from a platform provider is a pragmatic route to a quick launch: off-the-shelf infrastructure, content, payments and compliance reduce the entry threshold and the risk of errors. Success depends on three things:

1. correct choice of provider and transparent contract (roles, geo, SLA, migration), 2. real, not "paper" KYC/AML/RG outline and responsible marketing, 3. plan to scale and move to your own license.

With such a frame, you start faster without sacrificing the stability and trust of players and partners.