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Licensing · Gaming · Curaçao

Online gaming licensing in Curaçao under the new LOK

Curaçao has replaced its former master-licence and sublicence system with direct licensing by the Curaçao Gaming Authority under the National Ordinance on Games of Chance (LOK), in force since 24 December 2024. Operators now hold their own B2C or B2B licence, pay published fees and face stronger AML, player protection and local substance obligations.

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Key facts
Regulator
Curaçao Gaming Authority (CGA)
Legal basis
National Ordinance on Games of Chance (Landsverordening op de kansspelen, LOK), in force 24 December 2024
Licence types
B2C (operators) and B2B (suppliers)
Application fee
EUR 4,592 for B2C and B2B
Annual fees
B2C EUR 47,450 (EUR 24,490 licence fee plus EUR 22,960 supervisory fee); B2B EUR 24,490
Review timeline
Two phases of 8 weeks each, extendable by 4 weeks
Local substance
Article 5.12 economic presence; enforcement deferred until 1 April 2027
01

Overview

For decades, Curaçao online gaming operated under the National Ordinance on Offshore Games of Hazard, where a small number of master licence holders issued sublicences to operators. That model was widely criticised for weak oversight. Reform began in 2023 with direct applications to the Gaming Control Board, and the Curaçao Parliament approved the LOK on 17 December 2024. It entered into force on 24 December 2024, establishing the Curaçao Gaming Authority as an independent regulator. Licences under the old regime were given a transition period to June 2025, with a possible six-month extension, and the CGA now treats the old regime as fully phased out.

Under the LOK, each operator applies in its own name for a B2C licence, while suppliers of games, platforms and other services apply for a B2B licence. The application fee is EUR 4,592 for either type. The annual cost of a B2C licence is EUR 47,450, consisting of a EUR 24,490 licence fee paid to the National Treasury and a EUR 22,960 supervisory fee paid to the CGA; B2B licensees pay a single annual supervisory fee of EUR 24,490. Smaller administrative charges apply for adding domains, certificates and ownership updates. In the first year, fees are invoiced in two six-month instalments, with the first paid before the licence is granted.

Applications are reviewed in two phases of eight weeks each, with a possible four-week extension. The first phase focuses on ultimate beneficial owners and key persons, including verification of source of wealth and financial standing; the second covers the remaining operational and compliance requirements. Applicants must show sufficient, identifiable liquidity to cover potential player claims, and must implement updated AML/CFT, MLRO, responsible gambling and player protection frameworks.

The LOK also requires licensees to establish meaningful economic presence in Curaçao, including local staffing, decision-making and operational substance. In January 2026 the CGA announced a general extension, so that licensees need not meet this obligation before 1 April 2027. Operators should plan their office, key persons and local functions now, as further guidance on what constitutes sufficient substance is expected.

02

Key benefits

  • Direct licence held by the operator, rather than a sublicence dependent on a master holder
  • Published, predictable fee schedule in euros
  • Separate B2B licence for suppliers serving licensed operators
  • Defined two-phase review timeline
  • Stronger regulatory framework that supports payment processing and banking relationships
  • Time to build local substance before the April 2027 enforcement date
03

Requirements

  • A Curaçao legal entity applying in its own name for a B2C or B2B licence
  • Disclosure and verification of ultimate beneficial owners and qualified interest-holders, including source of wealth
  • Fit and proper key persons, with an approved MLRO
  • Sufficient, clearly identifiable liquid assets to cover potential player claims
  • AML/CFT policies, KYC procedures and transaction monitoring
  • Responsible gambling and player protection policies, including complaints handling
  • Technical documentation for platform, games and domains, with certified systems
  • Payment of the application fee and first-year fee instalment before grant
  • Office and meaningful economic presence in Curaçao, enforceable from 1 April 2027
04

Licence options & capital

B2C licence

EUR 4,592 application; EUR 47,450 per year

For operators offering games of chance to players, such as online casinos, sportsbooks and poker. Includes the National Treasury licence fee and CGA supervisory fee.

B2B licence

EUR 4,592 application; EUR 24,490 per year

For suppliers of games, platforms and related services to licensed operators. One annual supervisory fee applies.

05

Step-by-step process

  1. 1

    Structure and ownership review

    Map beneficial owners, qualified interest-holders and key persons, and gather source of wealth documentation.

  2. 2

    Entity and local presence

    Establish the Curaçao entity and plan office, staffing and decision-making functions.

  3. 3

    Policy framework

    Prepare AML/CFT, KYC, responsible gambling, complaints and technical documentation.

  4. 4

    Phase 1 review

    The CGA verifies UBOs and key persons over eight weeks, extendable by four weeks.

  5. 5

    Phase 2 review

    The CGA assesses the remaining operational and compliance requirements over a further eight weeks.

  6. 6

    Grant and ongoing supervision

    Pay the first-year instalment, receive the licence and maintain compliance, fee payments and substance plans.

06

Typical documents

  • Certificate of incorporation and constitutional documents of the Curaçao entity
  • Corporate structure chart showing UBOs and qualified interest-holders
  • Personal declarations, passports, proof of address and police certificates for key persons
  • Source of wealth and source of funds evidence for UBOs
  • Business plan and financial projections, with evidence of player-claim liquidity
  • AML/CFT manual, KYC procedures and MLRO appointment
  • Responsible gambling and complaints-handling policies
  • Technical description of platform, game providers and domains
07

How Legal Wealth helps

Legal Wealth helps gaming entrepreneurs move from legacy arrangements to a direct LOK licence with a structure that will stand up to scrutiny. We prepare ownership and source of wealth files with discretion, coordinate policy documentation and plan the local substance needed before April 2027. Where the operating company sits within a wider family or investment structure, we align the licence with banking, holding and succession arrangements. Contact info@legalwealthglobal.com.

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08

Frequently asked questions

Are Curaçao sublicences still valid?

No. Licences under the old offshore regime were given a transition period to June 2025, with a possible six-month extension, and the CGA now treats that regime as fully phased out. Operators need their own LOK licence.

What does a B2C licence cost each year?

EUR 47,450: a EUR 24,490 licence fee paid to the National Treasury and a EUR 22,960 supervisory fee paid to the CGA, in addition to the EUR 4,592 application fee.

How long does the application take?

The CGA reviews applications in two phases of eight weeks each, with possible four-week extensions, provided the file is complete.

Do I need staff in Curaçao?

The LOK requires meaningful economic presence, including local staffing and decision-making. Enforcement of this obligation has been deferred until 1 April 2027, but planning should start now.

What happens if fees are not paid?

Invoices are due within 14 days. Non-payment within 71 days leads to revocation and removal from the public register.

Contact

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