The global gambling industry has undergone a fundamental structural transformation over the past decade, with white label and business-to-business (B2B) platform models emerging as dominant market entry strategies. Industry analysis from Statista indicates that approximately 40% of online gambling operators now rely on white label or turnkey solutions rather than proprietary technology, creating complex regulatory challenges around accountability, licensing, and consumer protection.
This proliferation of B2B gambling relationships has prompted gambling regulators to develop increasingly sophisticated frameworks governing platform providers, software suppliers, and the operators who utilize their services. Understanding these regulatory requirements has become essential for platform providers, operators considering white label market entry, compliance professionals, and investors evaluating gambling sector opportunities.
This analysis examines the regulatory landscape governing white label and B2B gambling operations across major jurisdictions, the licensing requirements imposed on platform providers, the accountability frameworks that determine responsibility for compliance failures, and the evolving trends shaping this critical segment of gambling regulation.
Understanding White Label and B2B Gambling Models
Before examining regulatory frameworks, it is essential to understand the various B2B relationships that characterize the modern gambling industry. These models exist on a spectrum from simple software licensing to comprehensive turnkey solutions.
Software and Game Licensing
At the most basic level, B2B relationships involve licensed gambling operators contracting with independent software vendors (ISVs) to provide specific games or components. Game developers such as NetEnt, Pragmatic Play, and Evolution Gaming supply content to licensed operators while maintaining their own B2B licenses. These arrangements require the game provider to hold appropriate certifications but place primary regulatory responsibility with the licensed operator integrating the content.
Platform-as-a-Service (PaaS)
Platform providers offer comprehensive gambling technology infrastructure including player account management, payment processing integration, game aggregation, and compliance tools. Operators using platform services maintain their own gambling licenses but rely on the platform for core operational technology. Major platform providers including Kambi, SBTech, and Gaming Innovation Group serve dozens of licensed operators across multiple jurisdictions.
White Label Solutions
White label arrangements represent a more comprehensive relationship where the platform provider supplies the entire operational infrastructure while the white label partner handles marketing, customer acquisition, and often customer service. The platform provider's license typically covers the gambling activity, with the white label partner operating under that license umbrella. This model creates complex accountability questions that regulators have addressed with varying approaches.
Turnkey Operations
Turnkey solutions represent the most comprehensive B2B offering, where the platform provider handles virtually all operational aspects including licensing, payment processing, customer support, and compliance. The turnkey client provides primarily marketing and brand identity. These arrangements create the most significant regulatory challenges regarding accountability and oversight.
UK Gambling Commission B2B Framework
The UK Gambling Commission (UKGC) has developed one of the most comprehensive frameworks for regulating B2B gambling relationships, establishing distinct license categories and clear accountability principles that have influenced approaches globally.
B2B License Categories
The UKGC issues specific license categories for B2B gambling services. Gambling software licenses authorize providers to manufacture, supply, install, or adapt gambling software for use in connection with gambling activities. These licenses carry substantial compliance obligations and annual fees scaled to business volume. The Commission has emphasized that software providers bear direct regulatory responsibility for the products they supply.
Hosting and technical services licenses authorize providers to offer platform services including transaction processing, information storage, and player management systems. License holders must demonstrate robust due diligence procedures, comprehensive auditing capabilities, and clear contractual terms governing their relationships with B2C operators.
Primary Activity Provider Accountability
The UKGC's framework establishes that operators holding B2C licenses bear primary responsibility for all customer-facing gambling activity, regardless of B2B relationships. However, the Commission has increasingly held B2B providers accountable for systemic failures. Our 2026 enforcement review documents several cases where platform providers faced sanctions for deficiencies that manifested across multiple client operators.
The Commission requires B2B providers to maintain registers of all B2C operators using their services and to report material events affecting those operators. Platform providers must also demonstrate adequate due diligence on new clients, including verification of appropriate licensing and regulatory standing.
White Label Operator Restrictions
The UKGC has progressively tightened requirements around white label arrangements. While historically white label partners could operate under the platform provider's license, the Commission now generally requires all entities actively involved in offering gambling to hold appropriate licenses. This includes white label partners who maintain customer relationships, even if they do not directly process gambling transactions.
The Commission's approach reflects concerns about regulatory visibility and accountability dilution. As explored in our analysis of licensing due diligence, the UKGC expects full transparency regarding ownership and control structures, including through B2B arrangements.
Malta Gaming Authority B2B Regulation
The Malta Gaming Authority (MGA) has established a comprehensive B2B licensing framework that accommodates the diverse range of gambling technology services provided from Malta, one of the world's largest gambling licensing jurisdictions.
Critical Gaming Supply License
The MGA's Critical Gaming Supply license covers providers of core gambling technology including random number generators, game logic, odds calculation engines, and player account management systems. License holders must demonstrate technical compliance through independent testing laboratory certification and maintain ongoing compliance with the MGA's technical standards.
Critical suppliers face substantial due diligence requirements regarding their B2C operator clients. The MGA expects suppliers to verify that operators hold appropriate licenses and to implement contractual provisions requiring compliance with applicable regulatory requirements.
Ancillary Gaming Services
For providers of non-critical services including payment processing, customer verification, and marketing platforms, the MGA has established recognition frameworks that impose lighter regulatory burdens while maintaining oversight. Recognized providers must notify the MGA of their services and clients but do not require full licensing.
White Label Host Provisions
Malta permits white label arrangements under specific conditions. The hosting operator (platform provider) must hold an appropriate B2C license and bears primary regulatory responsibility for activities conducted under that license. White label partners must satisfy the MGA's fit and proper requirements and are subject to ongoing due diligence by the hosting operator.
The MGA has issued guidance clarifying that hosting operators cannot simply "lend" their licenses to partners who would not independently qualify for licensing. The Authority expects hosting operators to maintain genuine operational control and oversight of white label activities, with the hosting license reflecting the reality of regulatory responsibility rather than a convenient commercial arrangement.
European Regulatory Approaches
European gambling markets have developed varying approaches to B2B regulation, creating a complex compliance landscape for platform providers and technology companies serving multiple jurisdictions.
Swedish Spelinspektionen Framework
Sweden's gambling regulator Spelinspektionen requires B2B providers serving Swedish-licensed operators to obtain specific authorization. Platform providers must demonstrate compliance with Swedish technical standards, including integration with the Spelpaus national self-exclusion system and adherence to Swedish responsible gambling requirements.
The Swedish approach places substantial responsibility on B2C operators for their B2B relationships, requiring operators to ensure that platform providers meet regulatory standards. This approach has prompted several international platform providers to establish Swedish-compliant infrastructure specifically for operators serving the Swedish market.
German GlüStV 2021 Requirements
Germany's Interstate Treaty on Gambling 2021 (GlüStV 2021) established significant requirements for B2B providers serving the German market. The German gambling authority (GGL) requires platform providers to obtain specific authorization and comply with Germany's unique technical requirements including deposit limits, loss limits, and reality check mechanisms.
The German framework's stringent requirements have prompted some platform providers to develop Germany-specific configurations, while others have exited the market entirely. As discussed in our market exit analysis, several operators withdrew from Germany citing the complexity of adapting their B2B services to German requirements.
Netherlands Kansspelautoriteit Approach
The Netherlands gambling regulator Kansspelautoriteit (KSA) has developed robust B2B oversight mechanisms as part of the country's online gambling liberalization. Platform providers must obtain recognition from the KSA and demonstrate compliance with Dutch technical and responsible gambling standards, including integration with the CRUKS national self-exclusion system.
North American B2B Regulation
The state-based nature of US gambling regulation creates particular complexity for B2B providers, who may need to obtain authorization in multiple states to serve their operator clients.
US State Gaming Commission Requirements
US state gaming commissions generally require platform providers serving licensed operators to obtain vendor or supplier licenses. These licenses involve substantial background investigations covering company principals, key employees, and often significant shareholders. The investigation process, conducted by state gaming enforcement divisions, can extend to 12-18 months and involve considerable expense.
As examined in our US sports betting market overview, the fragmented state-by-state approach has favored established platform providers who have already navigated licensing in multiple states, creating significant barriers for new market entrants.
Multi-State Licensing Coordination
The American Gaming Association has advocated for improved multi-state licensing coordination to reduce duplicative investigations for B2B providers. Some states have developed reciprocity arrangements recognizing licenses issued by other states, though comprehensive harmonization remains elusive.
The Multi-State Internet Gaming Agreement (MSIGA) facilitates coordination for poker liquidity sharing but does not extend to B2B licensing harmonization. Platform providers continue to navigate individual state requirements, with successful multi-state operations requiring substantial regulatory affairs infrastructure.
Ontario iGaming B2B Framework
Ontario's regulated iGaming market, launched in 2022, established specific requirements for B2B providers. The Alcohol and Gaming Commission of Ontario (AGCO) and iGaming Ontario require platform providers to register and demonstrate compliance with Ontario's technical and responsible gambling standards. The framework distinguishes between gaming-related suppliers subject to full registration and non-gaming suppliers subject to lighter requirements.
Accountability Distribution in B2B Relationships
One of the most complex aspects of B2B gambling regulation involves determining how regulatory responsibility distributes between platform providers and operators when compliance failures occur.
Primary vs. Shared Accountability Models
Regulatory approaches to accountability distribution generally fall into two categories. Primary accountability models place regulatory responsibility squarely with the B2C license holder, treating B2B providers as commercial contractors whose compliance obligations flow through contractual relationships rather than direct regulatory supervision. Shared accountability models impose direct regulatory obligations on both B2B and B2C parties, with each bearing responsibility for aspects within their control.
The trend across major jurisdictions has been toward shared accountability, with regulators recognizing that platform providers' technological decisions can systemically affect compliance across multiple operators. This evolution has significant implications for platform providers, who increasingly face direct enforcement exposure for failures that might previously have been attributed solely to their operator clients.
Compliance Responsibility Allocation
Well-structured B2B agreements clearly allocate compliance responsibilities between parties. Platform providers typically bear responsibility for game fairness, random number generation integrity, technical platform security, and data protection for systems they control. Operators typically bear responsibility for customer due diligence, responsible gambling interventions, marketing compliance, and customer fund protection.
Gray areas exist regarding integrated functions such as automated responsible gambling controls, AML transaction monitoring, and customer communication. The Financial Action Task Force (FATF) guidance emphasizes that AML obligations cannot be fully delegated, requiring operators to maintain meaningful oversight of AML activities even when platform providers handle transaction monitoring. Our AML compliance analysis examines these obligations in detail.
Enforcement Case Studies
Recent enforcement actions illuminate how regulators approach B2B accountability in practice. In several UK cases, the Gambling Commission has sanctioned both platform providers and operators for related failures, with platform providers facing penalties for systemic deficiencies affecting multiple clients while individual operators faced penalties for their specific customer-facing failures.
The MGA has similarly pursued enforcement against B2B providers, including cases where platform technology enabled operators to circumvent responsible gambling requirements. These actions signal that B2B providers cannot assume their regulatory exposure is limited to their direct license conditions but extends to the downstream use of their services.
Technical Compliance for B2B Providers
B2B gambling providers face extensive technical compliance requirements that vary by jurisdiction and service type but share common elements focused on game integrity, security, and regulatory reporting.
Game and RNG Certification
Game developers and platform providers must obtain certification from accredited testing laboratories confirming that games operate fairly and as represented. Testing covers random number generator quality, theoretical return-to-player calculations, game rules implementation, and display accuracy. Major testing laboratories including eCOGRA, BMM Testlabs, and GLI provide certification services recognized across multiple jurisdictions.
Our RTP Compliance Calculator provides interactive reference for RTP requirements across jurisdictions, illustrating the technical compliance landscape B2B providers must navigate.
Platform Security Requirements
Platform providers must demonstrate robust cybersecurity measures including penetration testing, vulnerability management, and incident response capabilities. Regulatory frameworks increasingly reference international standards such as ISO 27001 as compliance benchmarks. Our cybersecurity requirements analysis examines these standards in detail.
Platform providers handling payment data must also comply with Payment Card Industry Data Security Standard (PCI DSS) requirements, with certification levels determined by transaction volume. Many jurisdictions now explicitly reference PCI DSS in gambling technology requirements.
Data Protection and Processing
B2B providers processing player data face substantial data protection obligations under GDPR and equivalent frameworks. The determination of data controller versus processor status in B2B relationships has significant implications for data protection responsibility allocation. Platform providers typically act as data processors on behalf of operator data controllers, but arrangements must be clearly documented through appropriate data processing agreements.
Cross-border data transfers present particular complexity for B2B providers serving operators in multiple jurisdictions. As examined in our data protection analysis, platform providers must implement appropriate transfer mechanisms when player data moves between jurisdictions.
Due Diligence Requirements for B2B Relationships
Both platform providers and operators face substantial due diligence obligations when entering B2B gambling relationships.
Platform Provider Client Due Diligence
Platform providers must implement robust due diligence procedures for prospective operator clients. Requirements typically include verification of gambling license status and regulatory standing, assessment of beneficial ownership and control structures, review of AML and responsible gambling policies, and ongoing monitoring of client regulatory status.
Regulators expect platform providers to decline relationships with operators who present elevated risk, including operators with poor regulatory track records, operators targeting jurisdictions where they lack appropriate licensing, or operators whose beneficial ownership cannot be verified.
Operator Vendor Due Diligence
Operators must similarly conduct due diligence on B2B providers before engaging their services. This includes verification of appropriate B2B licensing, review of testing laboratory certifications, assessment of information security and data protection practices, and evaluation of financial stability and business continuity arrangements.
Operators cannot rely solely on the fact that a B2B provider holds regulatory authorization. The obligation to ensure B2B providers meet applicable standards remains with the operator, and regulatory failures attributable to B2B provider deficiencies will generally result in operator enforcement rather than excuse non-compliance.
Commercial and Regulatory Considerations for White Label Entry
Entities considering white label market entry must carefully evaluate both commercial and regulatory factors that will determine the viability and risk profile of the arrangement.
License Dependency Risks
White label operators typically depend entirely on the platform provider's license for their regulatory status. This creates significant business continuity risk if the platform provider faces regulatory action, financial difficulty, or decides to exit the market. Our market exit analysis examines how these dependencies can leave white label operators vulnerable during platform provider transitions.
Sophisticated white label agreements include provisions addressing these risks, including termination rights upon material regulatory events, transition assistance obligations, and escrow arrangements for critical technology and data.
Regulatory Evolution and Independence
White label operators should consider whether their long-term strategy requires eventual independence from platform provider licensing. Many jurisdictions are moving toward requiring all gambling-involved entities to hold appropriate licenses, which may eventually render white label models based on license-sharing unviable.
Operators using white label arrangements as market entry strategies should plan for eventual licensing independence, building the compliance infrastructure and regulatory relationships that will support future license applications.
Accountability Exposure Assessment
Despite operating under platform provider licenses, white label operators may still face regulatory exposure for activities within their control, particularly marketing and customer relationships. Entities entering white label arrangements should conduct comprehensive assessment of potential regulatory exposure and ensure appropriate compliance resources for areas within their responsibility.
Emerging Trends in B2B Gambling Regulation
Several trends are shaping the evolution of B2B gambling regulation with significant implications for platform providers and their operator clients.
Increased Direct Regulation of B2B Providers
Regulators are increasingly imposing direct obligations on B2B providers rather than relying solely on operators to manage their supply chains. This trend reflects recognition that B2B providers can address compliance requirements more efficiently at the platform level than individual operators implementing independent solutions.
As explored in our RegTech market analysis, this evolution is driving investment in compliance technology that can be deployed across multiple operators from a platform level, creating economies of scale in regulatory compliance.
Regulatory Technology Integration Requirements
Jurisdictions are increasingly mandating specific technology integrations for B2B platforms, including connections to national self-exclusion systems, real-time regulatory reporting feeds, and standardized responsible gambling interventions. These requirements are particularly prominent in European markets that have implemented comprehensive player protection frameworks.
Cross-Border Regulatory Coordination
As B2B providers increasingly serve operators across multiple jurisdictions, regulators are developing enhanced coordination mechanisms for oversight. The International Association of Gaming Regulators (IAGR) has facilitated information sharing regarding B2B provider regulatory status, enabling more efficient multi-jurisdictional oversight.
Our cross-border cooperation analysis examines these coordination frameworks and their implications for B2B providers operating internationally.
Conclusion
The regulation of white label and B2B gambling relationships represents one of the most complex and rapidly evolving areas of gambling oversight. As the industry continues to operate through increasingly sophisticated technology supply chains, regulators have developed comprehensive frameworks that impose direct obligations on platform providers while maintaining operator accountability for customer-facing activities.
For platform providers, this regulatory evolution requires substantial investment in compliance infrastructure, robust client due diligence programs, and careful attention to the specific requirements of each jurisdiction served. For operators considering white label or B2B market entry strategies, understanding the accountability implications of these arrangements is essential for managing regulatory risk.
The trend toward more direct B2B regulation is likely to continue as regulators recognize the efficiency gains from addressing compliance at the platform level. Market participants who develop sophisticated compliance capabilities for B2B relationships will be well-positioned as regulatory frameworks continue to mature and expectations for B2B governance continue to rise.