Denmark: game-supplier market-entry brief

Decision addressed: What should a game studio or B2B game supplier establish before planning distribution to Danish-licensed betting or online-casino operators?

Executive finding

Denmark has a dedicated game-supplier licensing route. Spillemyndigheden, the Danish Gambling Authority, states that supplying games to betting and online-casino licence holders requires a supplier licence. This covers casino games and services that operate and settle bets. The licence permits supply to operators licensed in Denmark; it is issued for up to five years. [S1]

Research implication: Before estimating an entry date, map the proposed product, supplying legal entity, operator relationships and certification responsibilities. Treat licensing and technical readiness as separate workstreams. This is a planning interpretation, rather than a finding that any specific applicant qualifies.

1. Separate the supplier and operator roles

The Authority describes online-casino gambling in terms of a paid stake, an opportunity to win a prize and an element of chance. Its operator page says online-casino games may only be offered with the relevant Danish licence. [S2]

Open question: A platform, aggregator or mixed business model needs its actual functions mapped against the applicable guidance. This sample does not classify an unidentified product or establish an exemption.

2. Application materials and entity checks

The supplier application page identifies application form 2-06, personal declaration Annex A / 2-02, and Annex B-2 / 2-08. It states that the application fee is due when the application is submitted. It also identifies executive and board members, relevant beneficial owners and an appointed Danish representative among persons addressed by the declaration requirements. [S3]

Practical output for a commissioned study: An entity-and-persons checklist, a document-gap register, links to current forms, and unanswered questions for the applicant’s advisers. Fees, representation requirements, supporting evidence and processing assumptions would be checked against the specific applicant and current materials. No application-cost or approval-time estimate is made here.

3. Technical certification is an ongoing dependency

The supplier certification page says operators and game suppliers must remain certified for the parts of the programme applicable to their products. Its responsibility table allocates base-platform certification to operators, while suppliers and operators with their own games are responsible for random-number-generator and game requirements. Information-security management, penetration testing, vulnerability scanning and change management are listed for both operators and game suppliers. [S4]

The table lists twelve-month frequencies for security management, penetration testing and change management, and a three-month frequency for vulnerability scanning. It also specifies reporting through the Games Register and relevant submission deadlines. These are programme-level entries: the applicable documents, boundaries and report requirements still need product-specific review. [S4]

Research implication: A supplier should build a responsibility matrix covering its product, platform interfaces, operator integration and test evidence. Existing certification in another jurisdiction is not evaluated in this sample.

4. Counterparty and advertising checks

The Authority publishes separate official lists of licensed game suppliers and gambling operators. Use them to check the relevant legal entity and record the date of the check; this sample does not endorse or certify a counterparty. [S5-S6]

The Authority’s illegal-advertising guidance prohibits advertising and sponsorship for unlicensed gambling or gambling operators. It also explains factors it uses when assessing whether an unlicensed gambling offer targets Denmark. [S7]

Scope boundary: That guidance should not be treated as a complete classification of supplier-to-business marketing. A specific launch would require review of the proposed audience, claims, channels and any player-facing promotion.

5. Questions for the next decision

• Which legal entity will supply each game or betting service?
• Will distribution be direct, through an aggregator, or through a mixed arrangement?
• Which counterparties hold the relevant Danish authorisation?
• Who owns each certification and integration task, and what evidence is missing?
• What fee, testing and operational costs belong in the entry budget?
• Which planned marketing activities require separate review?

Scope and evidence

This illustrative brief uses public regulator guidance only. It demonstrates a research format; it is not a comprehensive legal review, an application assessment or a guarantee of licensing or compliance. Tax, AML, detailed game standards, contractual allocation, enforcement history and commercial market sizing are outside this sample. A commissioned engagement would define these boundaries and an evidence cut-off in writing.