Service · Malta

High-risk merchant account for skill gaming and esports platforms with a Maltese company

Yes, a Maltese company can obtain a high-risk merchant account for a skill gaming or esports platform. Success depends on a clear legal distinction from gambling, robust age verification, and a strong corporate and processing history. We arrange these accounts by building a comprehensive underwriting file that evidences your business model's legitimacy and presenting it to specialist acquirers licensed to handle skill gaming merchants in Malta.

Profile at a glance
Service
High-risk merchant account
Industry
Skill gaming and esports
Typical MCC
7994 or 5816 depending on model
Entity
Private limited liability company
Authorities
Malta Business Registry; MFSA; Malta Gaming Authority
Currencies
EUR
Prerequisite
Legal opinion distinguishing skill from chance per market
Reserves
Often required at onboarding; indicative
Timeline
Typically 2 to 6 weeks from complete file to live processing

How we arrange merchant accounts for Maltese skill gaming platforms

We arrange stable, long-term merchant accounts for Maltese skill gaming and esports businesses by preparing a file that meets the specific requirements of our network of specialist acquirers. Our process begins with a detailed review of your business model, including the legal opinion that distinguishes your game from chance-based gambling. We analyse your processing history, focusing on chargeback and refund ratios to demonstrate a healthy payment flow.

Next, we build a full underwriting submission. This includes your corporate documents from the Malta Business Registry, director and UBO identification, and a thorough review of your website to ensure it complies with card scheme rules. We pay close attention to your terms of service, prize payout rules, and age verification process. The file is then matched with EEA-licensed acquirers or payment institutions that have a proven appetite for MCC 7994 or 5816 and understand the nuances of the skill gaming industry. We manage the application and underwriting queries, ensuring a smooth dialogue with the provider's risk team. Post-approval, we help establish appropriate settlement terms and rolling reserve levels.

What underwriters check for a Malta-based skill gaming merchant

Underwriters for skill gaming merchant accounts focus on legal compliance, operational transparency, and financial stability. For a Maltese entity, they will first scrutinise the legal opinion that classifies your product as a game of skill, not chance, in your key markets. This is the single most important document, as it directly addresses the primary risk of being miscategorised as gambling.

Compliance teams will then conduct a full review of your website and payment flow. They check for clear terms and conditions, prize payout policies, robust age gating mechanisms, and transparent company details. They will request a complete set of Know Your Business (KYB) documents for the Maltese company and KYC for all ultimate beneficial owners and directors. Financially, they will analyse at least six months of recent payment processing statements to verify your turnover, transaction patterns, and, most importantly, your chargeback and refund rates. Consistent, low chargeback ratios are critical to demonstrating that your business is well-managed and poses a predictable risk.

How we run it

  1. 1.Profile review of MCC, processing history, chargeback ratios and ownership
  2. 2.Underwriting file built: website compliance, refund policy, descriptor, KYB pack
  3. 3.Matched to acquirer types licensed for the MCC and the entity's jurisdiction
  4. 4.Warm introduction and underwriting Q&A handled with the acquirer
  5. 5.Post-approval: reserve, rolling limits and chargeback monitoring set up

Documents to prepare

  • Certificate of registration
  • Memorandum and articles
  • Beneficial ownership extract
  • Skill-game legal opinion
  • Age verification flow
  • Prize terms
  • Passport and proof of address for each UBO and director

How a Maltese entity affects your skill gaming payment processing

Using a Maltese company for your skill gaming or esports platform provides a credible European base, but it comes with specific expectations. While Malta is known for its iGaming framework under the MGA, a skill gaming operation often falls outside this scope and is governed by general commercial law. Acquirers will expect your Maltese entity to be in good standing with the Malta Business Registry, with all beneficial ownership information correctly filed and accessible.

Although local retail banks in Malta can be conservative with gaming-related businesses, the jurisdiction is well-served by international banks and EEA-licensed electronic money institutions that specialise in this sector. Your corporate structure must demonstrate substance; simply having a registered office is rarely sufficient. Acquirers prefer to see evidence of local operations or management, which aligns with Malta's own expectations for substantive economic activity. All processing will be in EUR unless you arrange for multi-currency acquiring, and your reporting obligations include filing audited annual accounts, which provides further assurance to your payment partners.

Why skill gaming merchant accounts are declined or terminated

Skill gaming merchant accounts are frequently declined or shut down due to their perceived proximity to gambling. The most common reason for rejection is the absence of a clear and convincing legal opinion that differentiates the game mechanic from one of chance. If an underwriter suspects the game could be considered gambling in the user's jurisdiction, they will decline the application to avoid regulatory and card scheme compliance risks.

Accounts can also be terminated for high chargeback ratios. Friendly fraud is common in this sector, where users may claim a deposit was unauthorised after losing a match. We help prevent this by preparing a file that demonstrates robust anti-fraud measures and a clear refund policy. Other triggers for termination include inadequate age verification controls, which expose the acquirer to risks associated with underage participation, and misleading marketing language that implies guaranteed winnings. Our file preparation process addresses these points directly, ensuring your website and terms are compliant with acquirer standards from the outset, preventing post-approval termination.

Timeline for approval and maintaining your merchant account

For a well-prepared Maltese skill gaming company, the typical timeline to secure a live merchant account is between two and six weeks from the moment we have a complete underwriting file. The initial stage involves our own review and file compilation, which can take a few days, depending on how quickly you can provide documents like processing history and the skill-game legal opinion. Once submitted to the chosen acquirer, their underwriting and compliance review is the longest phase, usually lasting one to four weeks.

After approval, integration can be completed within days. To stay live, the key is maintaining a low chargeback ratio. We assist in setting up chargeback alerts and monitoring to keep your ratios well below the card scheme thresholds. You must notify your acquirer of any significant changes to your business model, prize structure, or game mechanics. Proactive communication and consistent compliance with your terms of service are fundamental to building a long-term, stable relationship with your payment provider and avoiding any interruption to your service.

Malta compared for skill gaming and esports platforms

JurisdictionEntityCurrenciesBanking reality
MaltaPrivate limited liability companyEURLocal banks are conservative; licensed gaming and fintech operators often bank with EU EMIs and specialists
EstoniaPrivate limited company (OÜ), often via e-ResidencyEUREstonian banks are cautious with non-residents; EU EMIs are the usual first account
CyprusPrivate limited companyEUR, USDLocal banks are thorough on UBO and substance; EU EMIs and regional banks complement them
MauritiusGlobal Business Company (GBC) or Authorised CompanyUSD, EUR, MURLocal banks onboard GBCs through the management company; well suited to Africa and India facing flows

General information, not legal or tax advice. Requirements change; confirm with your counsel.

What we will not do

  • Place chance-based products described as skill games
  • Open accounts for unlicensed activity where a licence is required
  • Help conceal beneficial ownership or source of funds
  • Work with sanctioned persons, countries or goods
  • Promise approval: every institution makes its own decision

Xavion Capital is not a bank, acquirer or payment institution. We prepare files and introduce lawful, properly licensed businesses to regulated institutions.

Frequently asked
Do I need a Malta Gaming Authority (MGA) licence for a skill gaming merchant account?
Not necessarily. If your product is a genuine game of skill, it typically falls outside the scope of Malta's gambling legislation and does not require an MGA licence. However, you must provide your acquirer with a robust legal opinion from qualified counsel confirming this classification. This opinion is critical as it provides the legal basis for your acquirer to onboard you as a skill gaming merchant (e.g. MCC 7994) rather than a licensed gambling operator. Without this distinction, you will be unable to get a merchant account.
What is a rolling reserve for a skill gaming merchant account?
A rolling reserve is a risk management measure used by acquirers for high-risk industries like skill gaming. It involves holding back a percentage of your daily or weekly processing volume for a set period, typically 90-180 days. For example, an acquirer might hold 10% of your funds for 180 days on a rolling basis. This creates a security fund to cover potential future chargebacks. The reserve is released back to you after the holding period expires. The size and term of the reserve depend on your processing history, chargeback ratio, and business model.
Can I accept player deposits from the USA with a Maltese company?
Accepting payments from US customers depends entirely on the policies of the specific acquirer and the legal status of skill gaming in the relevant states. Many EEA-licensed acquirers are hesitant to process transactions from the US due to the complex legal landscape (e.g., UIGEA). To do so, you would need an acquirer with a specific appetite for US-facing skill gaming and a legal opinion that covers the specific states you wish to operate in. It adds significant complexity compared to processing for European or other international markets.
What payment descriptors are best for a skill gaming platform in Malta?
The best payment descriptor is one that is clear, accurate, and easily recognisable to the customer, as this helps prevent chargebacks. It should include your trading name or website URL. For a Maltese skill gaming platform, a good descriptor format would be 'XAVIONGAMES MALTA' or 'XAVION-GAMES.COM'. The goal is for the user to immediately recognise the charge on their bank statement. Vague or generic descriptors are a major cause of 'friendly fraud' chargebacks where the customer does not remember making the payment. Your acquirer must approve the descriptor during onboarding.
How does my chargeback ratio affect my skill gaming merchant account?
Your chargeback ratio is the most critical metric for maintaining your merchant account. Card schemes like Visa and Mastercard require merchants to stay below a 1% chargeback-to-transaction ratio, but most high-risk acquirers impose a much lower threshold, often around 0.5%. Exceeding this can lead to penalties, increased reserves, or account termination. For skill gaming, where 'friendly fraud' is a risk, proactively managing this ratio with clear descriptors, good customer service, and fraud prevention tools is essential for account stability. We help you establish this framework from day one.
Confidential assessment

Talk to us about high-risk merchant account for your skill gaming and esports business

Send your structure, industry and volumes. A partner replies within one business day.

Replies within 1 business day · Confidential