Legal basis
The Tobique First Nation (Neqotkuk) in New Brunswick enacted the Tobique Gaming Act 2023 under the inherent right to self-government recognised by section 35 of the Constitution Act, 1982. Version 2.0 of the Act, published April 2024, claims paramountcy over federal and provincial gaming law (section 4) and applies to interactive gaming with players inside and outside the territory (section 3). The same Canadian law firm that drafted Kahnawake's regulations assisted with Tobique's, and the two regimes share the constitutional theory. Neither has been tested in a Canadian court. The Commission's AML Code was enacted on 5 April 2024 and is now at version 3.0 (July 2026); a General Code of Practice v2.0 followed the same month.
Day-to-day licensing is delegated to a management company whose direct licensee, Differentia Licensing Advisory Group in Douglas, Isle of Man, runs the application portal. AML and KYC monitoring is outsourced to LI Compliance. The first licence went to a SOFTSWISS entity on 3 April 2024.
Fees, as quoted by the people who file them
The Commission publishes no fee schedule. The figures below come from licensing agents and were checked on 13 September 2026; they have changed once since 2024 and differ by agent, so treat them as a budget, not a price list.
| Item | Amount | Quoted by |
|---|---|---|
| Preliminary review | €2,500, non-refundable | Legal Bison, July 2026 |
| Licence fee, year one | €33,500 (total €36,000 with the review) | Legal Bison, July 2026; Rikk Law, February 2026 |
| Renewal | €19,875 (€18,000 + €650 admin + €1,225 social contribution) | Legal Bison |
| Mandatory compliance package | €7,000 a year, covers up to 5 domains | Legal Bison; Advennt; Rikk Law |
| Older quote (2024) | €18,000 application + €18,000 a year + €7,000 compliance | Advennt, June 2024 |
| All-in year one with company and services | €63,000 to €79,000 | Equilex, August 2026; Rikk Law |
| Gaming tax | 0% of GGR | all agents; not stated by the Commission |
Fees can be paid in bitcoin, ether or ERC-20 stablecoins. Ignore the CAD 5,000 / 15,000 figures that appear on one large agency's page; they contradict every other source and the portal's own FAQ on refunds.
What the licence requires of you
- No local entity, staff or servers. "Everything can be cloud based" is the portal's phrase. Most licensees hold the licence through a Costa Rica S.R.L.; the register is full of them.
- Full infrastructure disclosure: data-centre location, architecture, disaster-recovery plan, and a bi-weekly encrypted off-site backup of transaction data with a provider the Commission selects.
- A compliance officer and MLRO (an existing senior manager can hold the role), AML and CTF policies, segregated player funds, a contract with a Tobique-approved ADR provider, RNG certification, responsible-gambling tools, and a site footer with the TGC validation shield and ten policy links.
- Customer due diligence within 30 days of a first deposit or before a player wagers €2,000 of their own funds, whichever comes first, and always before a payout. Crypto deposits are treated as high risk and trigger enhanced due diligence.
- Reporting: player-account submissions every two weeks, monthly compliance change reports, terrorist-activity reports within 24 hours.
- Restricted territories: the United States, the United Kingdom, New Brunswick and FATF-sanctioned countries, per the portal. Agents list 22 in total including Ontario, Israel, Russia and China; the Commission's own Appendix A is published as an image and we could not verify the full list at source.
Timeline
Pre-approval first. After it, the portal quotes two to three weeks and a hard ceiling of eight. Agents say four to eight weeks in practice, and the difference is nearly always the UBO paperwork: every owner at 10% or more goes through full due diligence including source of wealth.
Where it sits against the alternatives
Tobique costs about twice Anjouan and a third of Curaçao, and buys a noticeably wider set of payment rails: Interac, several UK and EU electronic money institutions, Trustly, Skrill and Neteller are reported live with Tobique brands, which is not true of Anjouan. Tier-one game studios may still want a conversation before they connect. Point Legal's June 2026 comparison calls it "a pragmatic launch licence rather than a reputational anchor" with moderate-tier banking access; Advennt rates its framework above Anjouan, Curaçao and Kahnawake on transparency. Both are fair. The register grew from 103 entries in October 2025 to about 190 in September 2026, so the market has voted.
We use Tobique for card-and-bank-funded brands in LatAm, Canada outside Ontario and New Brunswick, and parts of Asia where a Curaçao budget is not justified. The platform side of the application is the infrastructure disclosure and the backup arrangement; we supply both as standard with our turnkey casino and sportsbook builds.
Questions operators ask
Can I take Canadian players?
Not from New Brunswick, and not from Ontario, which has its own iGaming regime. Other provinces are grey; the licence conditions do not forbid them but provincial lottery corporations dispute the First Nation's jurisdiction. Get local advice per province.
Do I need a Tobique company?
No. Any jurisdiction works; Costa Rica is the default because agents have the incorporation packaged, not because the Commission prefers it.
Is there a B2B licence?
Yes, case by case and voluntary, along Isle of Man lines. Suppliers do not need one to serve Tobique licensees, unlike Anjouan since July 2025.
Sources
- thetgc.ca: home, licence-holders register, regulatory documents; Tobique Gaming Act 2023 v2.0 (April 2024); AML Code of Practice v3.0 (revised 10 July 2026), accessed 13 September 2026
- dlagglobal.com Tobique licence FAQ (June 2026 pack)
- Advennt, 26 June 2024 and 31 October 2025; Yogonet, 3 April 2024 (first licence)
- Legal Bison, updated 26 July 2026; Rikk Law, 27 February 2026; Equilex, 7 August 2026; Point Legal, 22 June 2026