Romania - ONJN: license classes
License Card: Class I/Class II/Class III
Class I - operators (B2C).
License for companies directly working with players (online and offline). For online activities, Class I is supplemented by product/platform authorizations and domain binding, and the operator is required to use only suppliers that have Class II. The official Class I issued lists are published by ONJN.
What covers: online casino/slots, poker, betting, etc. (within the list allowed by ONJN and specific authorization).
Class II - Providers (B2B).
License for all who serve Class I: platform/hosting, developers and software suppliers (including RNG/games), payment processors, certification laboratories, auditors, as well as affiliates/marketing partners working with Romanian traffic. ONJN maintains a separate Class II registry.
What covers: any "key service" for online - from hosting and certification to advertising traffic (affiliate model).
Class III is a state monopoly.
Reserved for National Lottery (online lotteries and related products). Commercial operators do not fall into this class.
Technical circuit: mirror & safe server
For remote operators, there is a requirement for a central IT system with a mirror and safe server available to ONJN for supervision and inspections. The system must write transactions to mirror in real time and generate regulated uploads to backup/safe. Accommodation - in a location/data center approved by the regulator.
Fees and duties: relevant for 2025
Annual Class I (remote) license fee: €500,000 (after increase in 2023).
Annual Class II licence fee: around €15,000-20,000 (depending on subcategory; for most B2B and affiliates - €15,000).
Class III (state monopoly lotteries): about €100,000 annually.
Additionally, authorization fees and recurring reporting payments apply. Clarifications - in ONJN orders/norms to GEO 77/2009.
What ONJN checks for each class
Class I (operator): beneficiaries/key persons, financial stability, IT landscape security, connection to mirror/safe, contracts only with Class II providers, domain correctness, rules and RTP games, KYC/AML procedures.
Class II (B2B/affiliates): competencies and quality control of services, information security procedures, impeccable reputation, audit/certification; for laboratories - accreditation; for affiliates - traffic transparency and compliance with advertising rules.
Class III: requirements for a lottery operator in a public law monopoly mode.
Practical checklist (online)
Legal & Structure
1. Define the role: operator (Class I) or provider/affiliate (Class II); for lotteries - Class III mode is not applicable to private companies.
2. Prepare dossiers on beneficiaries and key persons; enter into contracts only with counterparties that already have Class II.
Technology and data
3) Design a central IT system with a mirror/safe server, real-time transaction logging and routine uploads; coordinate placement.
4) Ensure Class II games/software certification before going to market; any new games - through separate ONJN approval.
Finance and fees
5) Put in P&L €500k/year for Class I (remote) + authorization payments; for Class II - €15-20k/year (by subcategory).
Marketing/Affiliates
6) If you are an affiliate or manage traffic to Romania - arrange Class II; the operator is jointly and severally liable for the partners' compliance.
Operations and compliance
7) Implement KYC/AML (including SoF/SoW on triggers), anti-fraud, data protection and incident reporting processes; prepare for ad-hoc ONJN checks.
Frequent errors of applicants
An attempt to start with providers without Class II or conduct affiliate activities without registering with Class II.
Ignoring requirements for a mirror/safe server (location, inspection access, completeness of real-time logs).
Bringing new games without prior Class II certification and ONJN approval.
Miscalculation of annual fees after 2023 + reform (underreporting of Class I).
Conclusion
Romanian model - clear and "technical": Class I for B2C operators, Class II for any key services and traffic, Class III for state lottery; at the same time, remote operators are required to support a mirror/safe circuit with real-time logs for ONJN. Those who build a partner network from Class II providers in advance plus at launch: it is easier to pass approvals for games, reporting and hosting, scale domains faster and withstand inspections.