Unlike the official The King of Fighters Game Boy games, the character roster is actually split up into teams instead of having random characters from every team. The only ones not set to teams are Iori and Shingo, who did not have teams in The King of Fighters '97. The roster are as follows:

Additionally, Rugal serves as the final boss, despite not appearing in the official The King of Fighters '97. The game's intro is based on King of Fighters '98 with alterations to exclude characters not present in King of Fighters '97.

While many of the characters are taken from the previous official King of Fighters ports done by Takara, several of them have new sprites that were designed specifically for this game and do not appear in any official GB ports.