Armenia’s online gambling market is in the middle of its most significant legal overhaul in two decades, and a single misstep in licensing, advertising, or domain strategy can trigger fines of up to 10 million AMD, mandatory equipment confiscation, and potential criminal exposure for unauthorized entrepreneurial activity. Whether you are a B2C operator preparing to enter the market or a B2B software provider structuring an Armenian back-office, the regulatory complexity demands precise, jurisdiction-specific legal counsel.
Our gaming and gambling law practice provides comprehensive iGaming legal services Armenia, delivering end-to-end legal, corporate, and regulatory solutions for iGaming and land-based gambling businesses operating in or through Armenia. Below, we explain how the current framework works, where the critical compliance triggers sit, and which services your business will likely need.
The Armenian Legal Framework at a Glance
Armenia is currently operating under what practitioners refer to as a “legislative bridge.” Two regimes are technically relevant, and understanding which one applies to your operation is the first step addressed through professional iGaming legal services in Armenia and compliant market-entry strategy.
The Law “On Games of Chance, Internet Games of Chance and Casinos” (2003) and the Law “On Lotteries” (2003) remain the active governing statutes today. They continue to operate because the new Gaming Activity Regulation Operator has not yet been appointed by the government.
The newer Law on Regulation of Gambling Activity (2024) is technically in force but with deferred implementation. Under Article 58, Clause 4, its core operational provisions activate only on the day following the end of the sixth month after the Gaming Activity Regulation Operator is defined. In substance, however, the 2003 and 2024 laws treat the classification of support services very similarly. The most consequential change is jurisdictional: the 2003 law applied a cumulative test (local servers + Armenian IP + .AM domain), while the 2024 law (Article 8, Clause 9) treats the .AM domain as the decisive marker for whether gaming activity is “organized in Armenia” or “organized abroad.”
Need experienced legal guidance before launching or scaling your iGaming business in Armenia? Contact our team to secure a compliant market-entry strategy and avoid costly regulatory risks from day one.
Who Regulates What
Three authorities matter for any gaming-related operation:
- Authorized Body (Ministry of Economy): Issues licenses and develops gambling policy.
- Supervisory Body (State Revenue Committee): Monitors tax compliance, financial flows, and enforces penalties for unlicensed activity.
- Central Bank of Armenia (CBA): Regulates the financial and AML dimensions of the sector.
Once appointed, the Gaming Activity Regulation Operator will manage the Electronic Control System and the Monitoring Centre, issue Certificates of Conformity for game products, and certify individuals working in gambling operations.
B2C Gambling Operations: Licensing & Compliance
For operators dealing directly with players – online casinos, sports betting platforms, and lotteries – the path to a compliant Armenian gambling licence involves three license categories and a substantial financial commitment.
Gaming License Types in Armenia
| License Category | Annual State Duty | Notes |
| Internet Winning Games | 600,000,000 AMD | Online slots, table games, casino-style products |
| Lottery Organization | 600,000,000 AMD | Draw-based, non-draw, and combined lotteries |
| Casinos – Tsaghkadzor | 180,000,000 AMD | Land-based; location-specific |
| Casinos – Sevan | 150,000,000 AMD | Land-based; location-specific |
| Casinos – Jermuk | 100,000,000 AMD | Land-based; location-specific |
| Casinos – Meghri | 35,000,000 AMD | Land-based; location-specific |
| Casinos – Other Locations | 5,500,000,000 AMD | Default location duty |
Each type of gambling activity requires a separate license, and only commercial organizations registered in Armenia are eligible to apply. This is one of the first questions we work through when we help foreign founders register an Armenian company for a gambling project.
The “Right to Accept Bets” Duty
Online operators must also pay a separate state duty for the legal right to accept wagers, calculated on bet volume and a progressive annual coefficient:
- Internet Winning Games: For every 100 billion AMD in accepted bets, the duty is 175,000 × base unit (1,000 AMD) × annual coefficient
- Totalisators / Online Bookmaking: For every 50 billion AMD in accepted bets, the duty is 50,000 × base unit × annual coefficient
The annual coefficient escalates over time: 2.0 in 2025 (from 1 April), 3.0 in 2026, 4.0 in 2027, and 5.0 in 2028. Duties paid for the right to accept bets are non-refundable, even when the operator does not use the full purchased threshold.
Mandatory Bank Deposit & Financial Security
Holders of Internet Winning Games, bookmaking, and lottery licenses must maintain a bank deposit in an Armenian bank equal to double the annual state duty – approximately 1.2 billion AMD for an online gaming licence. This deposit must remain in place throughout the licence period. Land-based winning games are exempt from this specific deposit requirement. Because Armenian banks apply Enhanced Due Diligence to any gambling-adjacent entity, we typically pair licensing with a structured bank account opening process in Armenia to avoid timing risk.
- Technical Compliance: Certificate of Conformity preparation for game software, including the mandatory 90% minimum RTP for automated games and ISO/IEC 27000 information-security standards.
- Monitoring Centre Integration: Ensuring your platform connects to the state Monitoring Centre once the Sectoral Operator is appointed.
Contact our team to launch your iGaming business in Armenia with confidence and full regulatory compliance.
B2B iGaming Services: Software, Aggregators & Affiliates
Here is where Armenia diverges from offshore jurisdictions like Malta or the Isle of Man: Armenia does not currently issue a standalone B2B gambling license. Instead, the regulatory perimeter is defined by Article 5, Clause 10 of the 2024 Law, which acts as a “transfer of functions” trigger within the broader framework of iGaming services Armenia.
The B2B Supply Permit Trigger Explained
If an organiser transfers any of its functions – payment processing, customer verification, platform management, financial flow handling, or game outcome determination – to a third party through agency, commission, or outsourcing contracts, the activities of that third party become subject to mandatory licensing as a gambling organiser. This means a B2B provider performing core “organiser functions” must hold the same Internet Winning Games license as its B2C client.
In practice, this creates two viable structures for B2B providers:
- Operate inside the perimeter with a full Armenian licence – appropriate when the B2B provider supplies regulated functions to the local market.
- Operate outside the perimeter – viable when the provider serves only offshore operators that (a) use a non-.AM domain and (b) implement robust geoblocking of Armenian IP addresses.
Under Article 8, Clause 9, gaming activity on an interactive platform is officially considered organised in a foreign state if the organiser’s information resources are not located within the .AM domain area. Combined with geoblocking, this places the operation outside the jurisdictional reach of Armenian gambling law – which is the foundation for the BPO and back-office model that many Armenian-incorporated technology and IT companies now use. For borderline cases, we typically deliver a written regulatory legal opinion confirming non-licensed status before the client commits to a structure.
Our Comprehensive iGaming Legal Solutions
Beyond licensing, an Armenian gaming operation touches a wide horizontal legal framework. As part of iGaming legal services Armenia practice, we offer a full suite of services for both established operators and market entrants:
Corporate Structuring
We establish local legal entities, most commonly a Limited Liability Company (LLC) offering limited liability and simplified governance through a General Director and Meeting of Participants. For larger or investment-ready structures, we form Joint Stock Companies with full board governance via our M&A and corporate team. LLC registration is typically completed within one working day and is free of charge with the State Register. Foreign founders must provide apostilled corporate documents and director identification. Branches of foreign companies cannot hold a gambling licence but may operate representative branch in Armenia for non-gambling activities such as marketing or technical support.
Banking & Financial Onboarding
Armenian banks apply Enhanced Due Diligence (EDD) to any entity with gambling proximity, even pure BPO providers. Not every commercial bank will open accounts for gaming-adjacent businesses. Within our iGaming legal services Armenia,we coordinate preliminary inquiries with multiple banks, prepare comprehensive onboarding packs with full source-of-funds justification, and manage UBO documentation for shareholders with 20%+ control – drawing on our experience across the Armenian banking and finance sector.
Tax Advisory
As part of our iGaming legal services Armenia,we advise on Armenia’s gambling-specific tax regulations and framework, including VAT exemptions for licensed organisers, the progressive coefficients on betting rights duties, transfer pricing for intercompany service fees (Arm’s Length Principle), and the mandatory IFRS-compliant annual audit performed by a top-tier international firm. When the State Revenue Committee challenges a return or reassesses turnover, our tax disputes and litigation team represents the operator from audit through to court.
AML & KYC Policy Drafting
Licensed gambling organisers are statutory “obliged entities” under Armenian AML/CFT law. Within our iGaming legal services Armenia, we draft AML/CFT policies that satisfy the State Revenue Committee, including the mandatory reporting of transactions reaching or exceeding 1 million AMD, suspicious activity reporting to the Central Bank of Armenia, and the real-time (sub-3-second latency) transaction-monitoring infrastructure expected of online operators. If a regulator or law-enforcement body opens a money-laundering investigation, our defence team takes the file from the first interview.
Labour Law & Employment
For operators relocating international staff, we structure employment contracts under Armenian labour law compliant with Article 84 of the RA Labour Code and prepare for the mandatory digital labour contract system effective 1 July 2027. We also track the anticipated amendments to the Law on Aliens entering into force on 1 November 2026, which will materially affect residence and work authorisation for foreign nationals. Where disputes with employees do arise – termination, bonus claims, non-competes – they are handled by our employment disputes practice.
Dispute Resolution
Our casino lawyers represent clients in administrative matters and regulatory audits, commercial litigation, and proceedings before the Supervisory Body.
B2B vs B2C iGaming: Key Differences
A frequent question from new entrants is how the two models actually differ in practice. Both serve the same end industry, but the legal, financial, and operational profiles diverge sharply.
Quick Comparison: B2B vs B2C iGaming Software
| Feature | B2B iGaming software | B2C iGaming platform |
| Target audience | Operators, casinos, sportsbooks | End-users (players aged 21+) |
| Revenue model | Licensing fees, revenue share (typically 10–25%) | Player wagers, deposits, GGR |
| Time to market | 2–4 weeks (typical integration) | 6–12 months (licensing + build) |
| Cost | Lower upfront, recurring fees | High capital outlay (1.2B+ AMD deposit alone) |
| Control | Limited; provider sets the technical roadmap | Full operational control |
| Scalability | High; multi-tenant architecture | Constrained by licence and jurisdiction |
| Technical complexity | Provider-managed | Operator must manage the full technical stack |
| Armenian licence required? | Only if “organiser functions” are transferred locally | Yes; per gambling type |
The single most important takeaway: in Armenia, the distinction between B2B and B2C is functional, not formal. What you do – not how you label yourself – determines whether you need a licence.
FAQs
What is the difference between B2B and B2C in iGaming?
B2C companies run consumer-facing platforms (casinos, sportsbooks, lotteries) and hold the licence. B2B companies supply technology and services to those operators. In Armenia, the distinction is functional: a B2B provider that takes on “organiser functions” is treated as a B2C operator by law.
Does Armenia issue a separate B2B gambling license?
No. Article 5, Clause 10 of the 2024 Law applies a “transfer of functions” test – third parties performing core organiser functions must hold the same licence as the operator. A dedicated B2B category is under discussion but not yet enacted.
How long does it take to obtain a gambling license in Armenia?
LLC incorporation takes one working day. The full licensing process (suitability checks, source-of-funds verification, technical certification, and the bank deposit) typically takes several months.
What are the gambling tax and duty rates in Armenia?
The annual state duty for an Internet Winning Games licence is 600 million AMD, plus a separate duty for the “right to accept bets” based on wager volume and an annual coefficient (2.0 in 2025, rising to 5.0 by 2028). A bank deposit of roughly 1.2 billion AMD is also mandatory.
Can foreign companies operate online casinos in Armenia?
Not directly. Only commercial organisations registered in Armenia can hold a gambling licence. Foreign investors typically incorporate a local LLC. Branches of foreign entities are not eligible.
Do B2B iGaming software providers need to be certified in Armenia?
Only if the software gives Armenian-accessible players the opportunity to bet. In that case, it requires a Certificate of Conformity (90% minimum RTP, ISO/IEC 27000 standards) and connection to the state Monitoring Centre. Providers serving only offshore operators on non-.AM domains with geoblocking in place can typically avoid these requirements.
Ready to Enter the Armenian iGaming Market?
The window for entering Armenia’s regulated gambling sector with first-mover positioning is narrowing as the 2024 Law’s implementation timeline progresses. Whether you need a full B2C licence, a regulatory opinion confirming non-licensed B2B status, or a phased market-entry strategy that begins with a BPO footprint, our gaming lawyers can scope the engagement in a single consultation.
Book a confidential consultation with our iGaming legal team to map your licensing pathway, model your fees and deposit requirements, and structure your corporate and technical architecture before you commit capital – request a quote or contact MB Legal directly.
