ONJN Class 2 Licence Explained: Romania's Affiliate Regime

Romania is the one market in Europe where “do gambling affiliates need a licence?” has a flat, unambiguous yes. If you earn revenue-share or hybrid commissions from a Romania-licensed operator, you need an ONJN Class 2 licence — and in 2026 that means roughly €35,000 per year all-in, a 10-year term paid annually, a document file defined down to the annex, and obligations that keep biting long after approval. It is the most complete formal affiliate-licensing regime on the continent, and since March 2026 it also comes with proof that the licence itself won’t save you if your traffic goes to the wrong places.

Who needs the Class 2 licence

The trigger sits in the definition. Under HG 111/2016, art. 2 b), an affiliate is any natural or legal person earning revenue under a contract with a remote gambling organiser “as a result of the participation in gambling of players directed by it”. Read that carefully: the test isn’t what you call yourself, it’s whether your income moves with players’ gambling activity. If you just need the licence obtained, the Romania affiliate licence service covers scope, fees and process — this guide explains the regime itself.

• Revenue-share deals — squarely in. Your commission is literally a function of players’ participation.
• Hybrid deals (CPA plus a rev-share component) — in, for the same reason.
• Pure flat-fee media buying — the debated edge case. If a fixed banner fee never varies with player activity, practitioners argue it falls outside the definition; ONJN has not blessed that reading, so most compliance-minded networks license anyway or restructure.

The framework comes from OUG 77/2009, Romania’s umbrella gambling ordinance, which places affiliates on the Class 2 (B2B) side of the licensing system; HG 111/2016 supplies the operating norms, and the regime was successively tightened by GEO 82/2023, Law 107/2024 and Law 141/2025. If you’re still working out whether your model needs a licence anywhere at all, start with our country-by-country map of affiliate licensing requirements — Romania is the strictest entry on it.

What it costs in 2026

Romania’s affiliate licence used to be an afterthought line-item. It is now a real budget decision, because the fee has more than tripled in under two years of legislative activity:

The same 2023 reform also took the annual responsible-gambling contribution from €1,000 to €15,000 — payable by Class 2 licence holders alongside the fee. So the realistic running cost is:

• €20,000/yr — Class 2 licence fee (current per ICLG’s December 2025 Romania chapter)
• €15,000/yr — responsible-gambling fund contribution
• ≈ €35,000/yr all-in, every year of the 10-year term
• €10,500 one-off — licence issuance fee
• plus an administrative file-analysis fee charged when the application is examined

Two things the cost side does not include: there is no minimum share-capital requirement we could find for Class 2 affiliates, and there is no mandatory Romanian entity (more on that below). For context, this is the most expensive formal affiliate licence in Europe by a wide margin — Greece’s equivalent runs on a €1,000 registration deposit. We keep the current figures for both, alongside every other jurisdiction, in our affiliate licensing index and the wider licence fee index.

Ten years of validity — and the void-by-law trap

The Class 2 licence is issued for 10 years, which sounds generous until you read the payment mechanics. The fees are annual, and the calendar is strict:

• Year 1: payable by the 25th of the month following approval.
• Years 2–10: payable at least 10 days before the end of each licence year.

Here is the trap: if the first annual payment is missed, the approval is void by operation of law. Not suspended, not fined — void. You would be back to a fresh application, a fresh issuance fee and a fresh committee queue. Treat the year-1 payment date as part of the licensing project itself, not as a post-completion formality, and diarise the renewal payments for the remaining nine years.

The Annex 6b file: what ONJN wants to see

The application file is defined in HG 111/2016, Annex 6b. The core list:

• Application form in Romanian — the file is examined in Romanian, so translations are part of the project plan, not an afterthought;
• Corporate documents — trade-register certificate, the Romanian certificat constatator or, for foreign applicants, the equivalent certificates from your home registry, plus the articles of association;
• Description of the activity and the list of internet domains you will operate — the licence attaches to declared domains, so the list needs to be complete and kept current;
• Criminal-record certificates for every representative, shareholder and administrator — the standard is no convictions for intentional offences carrying prison terms of two years or more, and foreign equivalents are accepted;
• The affiliation contract with the Romania-licensed operator you’ll be working with.

That last item matters commercially: you need at least one signed operator deal before you file, so the licensing and business-development tracks have to run in parallel.

Timeline: 45–60 days, driven by the committee calendar

Class 2 applications are decided by ONJN’s Supervisory Committee, which meets roughly twice a month. Your complete file must be lodged at least 9 business days before the session that will hear it, and an approved licence takes effect on the 1st of the following month. Stack those mechanics together and you get the number practitioners consistently quote: 45–60 days end-to-end, assuming the file is right the first time. An incomplete criminal-record set or a missing domain declaration doesn’t add days — it adds a committee cycle.

Life after licensing: the obligations that actually bite

Getting the licence is the easy half. The compliance calendar afterwards is where Romanian regulation earns its reputation:

• File every affiliation contract with ONJN within 15 days of signing. The fine for missing this is RON 25,000–50,000 (HG 111/2016, arts. 150 and 151) — per contract, and it’s one of the most mechanically enforceable breaches on the books.
• Notify changes fast: 48 hours for online-relevant data, 5 business days for the rest.
• Law 141/2025 (in force 1 August 2025) hardened the B2B perimeter: Class 2 affiliates may serve Romania-licensed operators only, and must submit monthly blocking reports by the 10th confirming they are not exposing Romanian users to unlicensed product. Sanctions scale up to revocation.

Advertising rules affiliates must build around

• Bonuses may only be promoted on the operator’s own venues and websites, on licensed affiliates’ own sites, or via opt-in email (HG 111/2016, art. 6(3)). Your licence is literally what makes your bonus pages legal.
• Unlicensed brands may be mentioned only in same-size plain text, with no redirect to them (art. 6(4)).
• A 5% promotion tax applies to gambling advertising contracts — and under OG 15/2022 it is owed by the advertising provider when the provider isn’t the operator itself. If that’s you, it’s your tax bill.
• TV advertising is confined to 23:00–06:00, with a carve-out for live-sport betting promos (CNA rules, mid-2025).
• Celebrities and influencers are banned from gambling advertising outright since 6 October 2025 (CNA Decision 573/2025) — a hard stop for ambassador-led affiliate models.

Enforcement: the licence is not a shield

ONJN enforces at industrial scale. Its blacklist runs to over 1,500 domains — affiliate sites included — and ISPs that fail to block face fines of RON 50,000–100,000. In 2024 alone the regulator logged 14,100 inspections, 477 sanctions worth roughly RON 8.77 million, and 59 licence revocations; between April and September 2025 it added 5,130 controls, RON 3.78 million in fines and 93 newly blacklisted sites.

Then came the case that should reframe how every affiliate thinks about this market.

The lesson is blunt: the Class 2 licence authorises a compliant affiliate business; it does not launder a traffic-funnelling one. If your monetisation depends on routing Romanian users to unlicensed brands, the licence isn’t a workaround — it’s the paper trail the prosecutors will use.

Foreign companies can apply — no Romanian entity needed

A point consultancy marketing routinely gets wrong: Class 2 does not require a Romanian company. Annex 6b expressly accepts foreign equivalents of the corporate and criminal-record documents, and the local-presence requirement introduced by GEO 82/2023 binds B2C organisers, not Class 2 holders. Claims that a mandatory local representative is required don’t hold up against the primary texts we’ve reviewed. And for those tracking institutional risk: the 2025 rumours of ONJN being folded into the tax agency did not materialise — it remains a standalone authority under the Ministry of Finance, with its powers extended rather than trimmed.

Vantegris files ONJN Class 2 applications end-to-end: entity and document strategy, the Romanian-language file, criminal-record logistics across every shareholder and administrator, committee scheduling, and the post-licensing compliance calendar (contract filings, monthly blocking reports, renewal payments). See the affiliate licensing service for scope and fees, or talk to us about whether your commercial model even triggers the requirement — sometimes the right answer is restructuring the deal, not buying the licence.

Bottom line

Romania made the affiliate licence real: a defined trigger (revenue tied to players’ participation), a real price (≈ €35,000 a year plus €10,500 to enter), a real process (Annex 6b, the Supervisory Committee, 45–60 days) and real ongoing duties (15-day contract filings, monthly blocking reports, bonus-advertising limits). It is entirely obtainable — including for foreign companies — and entirely unforgiving of shortcuts, as the March 2026 criminal referral of a licensed affiliate proved. Go in with the compliance calendar budgeted, not just the fee. If you’re weighing Romania against other markets where your traffic earns, our licence finder is the fastest way to see the options side by side.

This article is general information, not legal advice. Romanian gambling regulation has changed almost annually since 2022 — we confirm the current fees and obligations for your specific model at scoping.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.