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Industry structure

How the stack is built

Almost every dispute a player has starts with a misunderstanding about who they are dealing with. The name on the website, the company that runs it, the company that holds the licence and the company that holds the money are frequently four different legal persons in three countries. This page describes the layers — it names no company and makes no claim about any real party.

Layer methodologyNot live dataNo company namedPublished provider dossiers

01The layer model

From the player to the game

Read top to bottom: each layer buys from the one beneath it. Payment providers and affiliates sit alongside the stack rather than inside it, and the licence holder and its regulator sit over the middle of it.

The layer model of an online gambling operationA central column runs from player, to domain and brand, to operator, to platform or white-label provider, to aggregator, to game providers; each layer buys from the one beneath it. Affiliates sit to the left and send players in. Payment providers sit to the right, carrying deposits and withdrawals between the player and the payment rails and settling to the operator. A licence-holder perimeter encloses the operator and platform layers, and a regulator to the left supervises that perimeter rather than any single layer. The travelling highlights show the direction of each relationship and nothing else — no rate, volume or duration is depicted. The same structure is written out in full beneath the diagram.Player — The person depositing, playing and asking to be paid.PLAYERthe person placing the betDomain / brand — The hostname and brand a player arrives at. A brand is marketing, not a legal person — several brands can sit on one operation, and one brand can move between operations.DOMAIN / BRANDthe site and name the player seesOperator — Runs the consumer-facing operation and holds the account relationship. Whether it also holds the licence depends on how the operation is arranged.OPERATORruns the brand, holds the customer relationshipPlatform / white label — Supplies the system the operation runs on: account management, wallet, bonusing, game integration and reporting. Under a white-label arrangement the provider also holds the licence, and the partner running the brand is not the licensee.PLATFORM / WHITE LABELaccounts, wallet, game integration, reportingAggregator — Bundles many game studios behind a single integration, so hundreds of titles arrive through one contract rather than one contract per studio.AGGREGATORone integration, many game studiosGame providers — Develop the games themselves. A studio's titles can appear on operations it has no direct contract with, because the aggregator sits in between.GAME PROVIDERSbuild and supply the gamesVISITSOPERATED BYRUNS ONINTEGRATESBUNDLESLICENCE HOLDERWHERE A COMPLAINT ATTACHESAffiliates — Market operations to players for commission. They are not part of the operating stack, but they are frequently how a player arrived — and their incentives are not the player's.AFFILIATESmarketing partners, paid on commissionRegulator — The authority that issues the licence, sets its conditions and can suspend or revoke it. Its power reaches the licensee, which is why identifying the licensee matters.REGULATORlicenses and supervises the licenseePayment providers — Move money between the player and the operation — card acquiring, wallets, bank transfer and crypto rails. A payment can stop with an intermediary that the player has never heard of and did not choose.PAYMENT PROVIDERScard, wallet, bank and crypto railsSENDSDEPOSITS / WITHDRAWALSSETTLES TOSUPERVISESINDUSTRY LAYER METHODOLOGY · ROLES, NOT COMPANIESMOTION SHOWS DIRECTION, NOT SPEED

Industry layer methodology. This fixed diagram defines roles; it is not a live company or relationship map, and no arrangement shown here describes a particular organisation. The highlights travelling the spine and the side links show which way each relationship runs — they carry no rate, volume or duration, and every direction they trace is also drawn as an arrowhead.

The stack in words
  1. 01

    Player

    The person depositing, playing and asking to be paid.

  2. 02

    Domain / brand

    The hostname and brand a player arrives at. A brand is marketing, not a legal person — several brands can sit on one operation, and one brand can move between operations.

  3. 03

    Operator

    Runs the consumer-facing operation and holds the account relationship. Whether it also holds the licence depends on how the operation is arranged.

  4. 04

    Platform / white label

    Supplies the system the operation runs on: account management, wallet, bonusing, game integration and reporting. Under a white-label arrangement the provider also holds the licence, and the partner running the brand is not the licensee.

  5. 05

    Aggregator

    Bundles many game studios behind a single integration, so hundreds of titles arrive through one contract rather than one contract per studio.

  6. 06

    Game providers

    Develop the games themselves. A studio's titles can appear on operations it has no direct contract with, because the aggregator sits in between.

Alongside the stack

Payment providers
Move money between the player and the operation — card acquiring, wallets, bank transfer and crypto rails. A payment can stop with an intermediary that the player has never heard of and did not choose.
Affiliates
Market operations to players for commission. They are not part of the operating stack, but they are frequently how a player arrived — and their incentives are not the player's.

Over the stack

Licence holder
The legal person named on a regulator's register. This is the party a complaint and a regulator's enforcement power actually attach to — and it is often not the brand the player believes they were dealing with.
Regulator
The authority that issues the licence, sets its conditions and can suspend or revoke it. Its power reaches the licensee, which is why identifying the licensee matters.
Licence register

02Vocabulary

Every entity kind, defined

These are the categories the platform records against. They are definitions, not a catalogue: no company is named here, and none is implied.

No records published

No public entity dossier meets the publication requirements

A dossier becomes public only once the entity's role in the stack can be attributed to a document that is held on file and can be opened — a corporate filing, a licence register entry, a supplier list, a technical record or the company's own statement. None currently does, across any of the eleven kinds defined below. The definitions are GambleLABS' own explanatory material and apply whether or not a dossier exists.

Corporate filingLicence register entryCompany statementTechnical record
How a dossier reaches publication
Operator
Runs the consumer-facing gambling brand, holds the customer relationship and, where required, the licence.
Company
A corporate body in the ownership chain that does not itself operate a gambling brand.
Platform
Supplies the core gaming system — account management, wallet, game integration and reporting — that an operator runs on.
White-label provider
Holds the licence and technical stack, then lets a partner run a branded site on top of it. The partner is often not the licensee.
Game provider
Develops and supplies the games themselves.
Aggregator
Bundles many game providers behind one integration, so an operator can add hundreds of titles through a single contract.
Payment provider
Moves player funds — card acquiring, wallets, bank transfer or crypto rails — between the player and the operator.
Affiliate
Markets operators to players for commission. Not part of the operating stack, but part of how players arrive.
Hosting provider
Supplies the servers, CDN or DNS the service runs on.
Licence holder
The legal person named on a regulator's register. Frequently not the brand a player believes they are dealing with.
Other
A participant that does not fit the categories above.

03Reading

Structure explainers

All research

GambleLABS' own explanatory writing on how an operation is assembled and how to tell the layers apart from the outside.

Why the layer matters to a player

A complaint has to be addressed to the party that can answer it. A regulator can act against its licensee, not against a brand name; a payment dispute may have to be raised with the intermediary that holds the funds rather than the site that took the deposit.

The licence conditions that protect you are attached to the licensee and to the jurisdiction that issued them. Two sites that look identical can sit under different licensees, in different countries, with different protections and different complaint routes.

Knowing the layer also tells you what a claim can mean. “Fully licensed” on a homepage is a statement about some company somewhere; the register tells you which company, for which activity, in which country, and whether the licence is still in force.

Player rights by country Search the licence registerProvider dossiers