Curaçao Gaming Licence under the LOK: Fees, Rules and Register Checks

A Curaçao gaming licence is now a direct licence from the Curaçao Gaming Authority (CGA), granted under the National Ordinance on Games of Chance (Landsverordening op de kansspelen, LOK), which came into force on 24 December 2024. The old model, where a handful of master licence holders issued sublicences, is finished: the CGA’s Orange Seal expired on 15 October 2025. As of October 2026 a B2C operator pays a EUR 4,592 application fee and EUR 47,450 a year, and must run a locally managed Curaçao company.

This page sets out how the LOK regime works for operators and suppliers: licence types, the fees the CGA publishes, the substance rules in the ordinance itself, how long a decision takes, what the register labels mean, where player disputes go, and what changed after the CGA’s licensing portal was breached in September 2026. For the wider picture of offshore and onshore options, see our overview of gambling licensing jurisdictions.

What is a Curaçao gaming licence under the LOK?

Under the LOK (P.B. 2024, no. 157), in force since 24 December 2024, the Curaçao Gaming Authority grants online gaming licences directly to a public or private limited company (N.V. or B.V.) incorporated in Curaçao with its statutory seat there. Article 2.1 also requires at least one managing director resident in Curaçao, and grants the licence for an indefinite period unless the ordinance says otherwise.

The CGA is the former Gaming Control Board, re-designated by the LOK as an independent administrative body (article 12.1). Some of its older guidance documents still carry the “GCB” name, which is worth knowing when a supplier sends a PDF that looks out of date. The authority supervises land-based casinos, lotteries and online gaming, and it acts as the anti-money-laundering supervisor for the sector under the National Ordinance on Identification in Services (NOIS) and the National Ordinance on the Reporting of Unusual Transactions (NORUT).

Two practical points flow from article 2.1. First, a foreign group cannot hold the licence through a Cyprus, Malta or UK company: the licensee itself must be Curaçaoan. Second, “indefinite” does not mean “unconditional”. The CGA can suspend a licence for up to three months, extendable by a further three (article 2.3), and revoke it on the grounds listed in article 2.4, which range from breach of conditions to unpaid fees.

How did the master licence system end?

Curaçao’s reform ran in three steps: on 15 November 2023 the regulator began accepting direct applications under transitional policy; on 24 December 2024 the LOK replaced the 1993 offshore games of hazard ordinance (NOOGH); and on 15 October 2025 the CGA let the Orange Seal (certificate of operations) expire, which its reclassification notice describes as bringing the former sublicence system to an end.

Under the NOOGH, a few private companies held master licences and resold sublicences to operators, who often had no direct relationship with the government regulator. Player complaints, due diligence and enforcement all ran through the master holder. That arrangement is why Curaçao acquired its reputation for light-touch oversight, and it is the main thing the LOK was written to remove.

Licence numbers on the current register reflect the transition. Entries beginning OGL/2023/ and OGL/2024/ were issued during the direct-application phase, while numbers beginning CGA/2025/ come from the LOK period. Some NOOGH-era licensees had been classified as B2C even though they only supplied software; the CGA’s reclassification policy of 15 October 2025 sets out how those firms move to a LOK B2B licence, and why a business that changes from B2C to B2B (or the reverse) must first have its old licence revoked.

Which licence types does the CGA issue?

The CGA issues two licence categories under the LOK: a B2C gaming licence for operators that hold player accounts and funds, and a B2B supplier licence for platform and game providers. Separately, article 5.17 lets it certify service firms such as test laboratories and dispute resolution bodies for up to three years. One company may hold several licences of one kind, but never a B2B and a B2C licence together.

For suppliers, the 24 December 2026 date matters. Until then a game studio or platform can serve Curaçao operators without its own B2B licence, although the CGA’s B2C operations manual guideline (September 2026) already requires each operator to keep a game supplier register and check content against the official CGA supplier list. Expect that check to tighten once the B2B obligation bites. Our B2B supply chain section covers how supplier licensing works across markets.

How much does a Curaçao gaming licence cost?

The CGA’s fee document “License Fees under the LOK”, version 2.0 of 15 October 2025, sets a one-time EUR 4,592 application fee for both B2C and B2B, plus EUR 150 for each ultimate beneficial owner (UBO) and each qualified interest holder. A B2C licence then costs EUR 47,450 a year and a B2B licence EUR 24,490, all non-refundable and payable in full by 15 January.

A worked example shows how the numbers stack up. Take a B2C applicant owned by two UBOs, with one further investor holding 15% (a qualified interest holder, defined by the CGA as 10% or more). The application invoice is EUR 4,592 + 2 x 150 + 150 = EUR 5,042. If the licence is granted on 1 July 2026, the first annual invoice is pro-rated for the rest of 2026, roughly half of EUR 47,450, or about EUR 23,725 (the CGA calculates the exact figure). A full EUR 47,450 is then due by 15 January 2027. Adding two extra brand domains costs EUR 500. Cash out to the regulator and Treasury in the first seven months: about EUR 76,700, before company formation, local directors, compliance staff, testing and legal costs.

Late payment is handled on a fixed ladder. For annual fees, reminders go out on days 15 and 29 after the invoice, a notice of intended suspension on day 43, a formal 21-day suspension on day 57, and a notice of revocation on day 71, after which the licence moves from the public licence register to the enforcement register. An applicant whose approval invoices stay unpaid loses the approval on day 57. The fee note also warns that an invoice alone does not confirm a licence continuation; only written confirmation from the CGA does.

What substance does the LOK require of a licensee?

Substance under the LOK starts with article 2.1: the licensee must be a Curaçao N.V. or B.V. with its statutory seat on the island and at least one resident natural-person managing director, or a Curaçao corporate director that is itself managed by a resident. The CGA adds a compliance officer requirement, effective 1 January 2025, with fixed experience thresholds.

Article 2.2 lists grounds on which the CGA must refuse a licence. They include an unclear identity of any UBO, qualified interest holder or policymaker; a conviction in the previous eight years for a crime committed for unlawful gain (fraud, theft, money laundering and the like) by anyone with more than 25% or by a policymaker; unverified source of funds or wealth; outstanding tax or social security debts; involvement in an operation whose licence was suspended or revoked; insufficient liquid funds to pay prizes that can reasonably be expected; and failure to register in the goAML reporting system.

The compliance officer rules come from the CGA’s requirements document under NOIS and NORUT:

• Qualifications: either two years of AML/CFT experience in a reporting role plus a bachelor’s degree or a recognised certificate such as CAMS, or four years’ experience alone. Two years as an MLRO elsewhere also qualifies.
• Independence: the role cannot be combined with UBO, CEO, CFO, COO or other operational functions, nor with internal audit.
• Outsourcing: permitted to a reputable third party, but one person may cover no more than ten operators, counting similar roles abroad.
• Training: at least ten hours of AML training a year.
• Scope: B2B licensees are exempt from this appointment.

For hosting, the operations manual guideline asks each B2C licensee to state its hosting arrangement (a Tier-IV facility and provider) and to keep an infrastructure diagram and disaster recovery plan ready for inspection. Article 5.9 of the LOK requires the operations manual itself to be produced within five working days of a first request. None of this amounts to the staff-and-office substance tests of Malta or the Isle of Man, which is one of the clearest dividing lines covered on our MGA vs Curaçao comparison.

How long does a Curaçao licence application take?

Article 5.1 of the LOK splits every online application into two phases with statutory clocks. The CGA decides on phase one (integrity of owners and policymakers, financial standing and viability) within eight weeks of a complete file, extendable by four weeks. The applicant then has four weeks to file phase two, which the CGA decides within a further eight weeks, again extendable by four.

1. Incorporate the Curaçao N.V. or B.V. and appoint the resident director.
2. File the online gaming licence application form, the business and corporate information form and personal history disclosures for UBOs and key persons; pay the application invoice, since processing does not start until it is paid.
3. Completeness check: the CGA says within two weeks whether a phase’s file is complete. An applicant who does not cure gaps within four weeks of a reminder is dropped (extendable by four weeks).
4. Phase one decision: proceed or refuse, within eight weeks plus up to four.
5. Phase two filing within four weeks: policies (AML/CFT, responsible gaming, complaints, terms and conditions), technical documentation, game and platform certification, domains and ADR agreement.
6. Phase two decision within eight weeks plus up to four. During this phase the CGA may grant a provisional licence for up to six months, extendable once by six months.
7. Pay the first annual invoice within 14 days of notice to the local director. The licence is formally granted, and the seal issued, only after payment.

On paper the statutory maximum from complete file to decision is therefore around 28 weeks, plus the applicant’s own filing windows. In practice the six-month provisional periods visible on the register show that many licensees are still moving through phase two. The portal shutdown of autumn 2026 has also pushed every documentary deadline back, as explained below.

What do the status labels on the CGA register mean?

The CGA publishes its online licence register as a PDF on cga.cw. The file dated 14 October 2026 lists about 615 licences with licence number, licensee, B2C or B2B type, Chamber of Commerce number, a six-month issue and expiry window, and a status column. The CGA states that no rights can be derived from the register, so it is a starting point for checks, not proof.

The enforcement register is a separate PDF. Its edition dated 14 September 2026 lists 30 entries: 29 revocations dated between June 2025 and July 2026, and one licence the CGA did not extend. The CGA notes that it covers only status-changing measures, not every enforcement step. Our enforcement tracker follows regulator actions across jurisdictions.

Does the Curaçao Gaming Authority resolve player complaints?

No. The CGA does not mediate individual disputes: a player must complain to the casino first, then go to one of the seven CGA-certified ADR bodies (list dated 31 August 2026). The CGA’s Player Complaints Policy (version 1.1, 18 June 2025) says it will not decide complaints about gambling transactions, though it uses complaint data for supervision and enforcement.

The seven certified ADR providers on the 31 August 2026 list are Resolvo Curaçao N.V., ADR Curaçao B.V., Cadre BV, EGIS-FZCO, ABC-ADR Limited, iGamingADR Limited (formerly Blue Sea Limited) and Independent Betting Adjudication Service Ltd (IBAS). The same list names five certified test laboratories: eCOGRA, Gaming Laboratories International, Gaming Associates Europe, BMM Spain Testlabs and Quinel. For how labs fit into licensing, see our testing labs guide.

Operators have hard obligations under article 5.3 of the LOK and the policy:

• Players may complain free of charge within six months of the bet settling or the incident.
• Receipt must be confirmed in writing within one week, and a reasoned final answer given within four weeks, extendable once by four weeks.
• Responsible gaming complaints (self-exclusion failures, targeting of vulnerable players) should be resolved within five business days.
• ADR must be offered at the operator’s cost, and an agreement with at least one certified ADR body uploaded to the CGA.
• Complaint reports are due to the CGA each 15 January and 15 June.

Article 5.5 adds that the player contract must be governed by Curaçao law, with disputes going to the Curaçao courts.

What happened to the CGA portal in September 2026?

The CGA confirmed unauthorised access to its online gaming portal on 17 and 22 September 2026; the portal was still offline on 2 October 2026, and the CGA says existing licences remain valid. On 7 October 2026 it went further and announced that the portal will not be returned to service, with an interim arrangement for licensing and a replacement mechanism for showing that a domain is licensed.

According to the 22 September statement, access came through the customer-facing side of the portal using an account registered in December 2025 under a false identity, and continued until it was found in September 2026. A German security researcher had claimed in the media to have extracted operator data and internal documents; the CGA said this was consistent with its own investigation and that the full extent of the material taken was not yet established.

The operational effects for licensees, as of mid-October 2026:

• Submissions meant for the portal cannot be sent by email instead; the CGA has postponed portal deadlines until a replacement exists.
• Licence validity, licensee obligations and the CGA’s supervisory powers are unaffected, per the 2 October and 7 October notices.
• The availability of the current digital seal is affected, so seal-based checks may fail for reasons that have nothing to do with a licence’s status.
• Operators were asked to apply security changes on their side after 17 September.

For compliance teams the lesson is that documents and personal data filed with any regulator’s portal sit outside the operator’s own security controls. Data minimisation in submissions, and a plan for notifying UBOs and key persons if a regulator reports a breach, belong in the same file as the licence itself.

How do you verify a Curaçao licence?

Verification works best when it uses three CGA sources together: the online licence register PDF on cga.cw, the separate enforcement register, and the operator’s seal, historically validated through cert.cga.cw. Since the 7 October 2026 announcement the seal is being replaced, so the register PDFs carry more weight than usual until the new mechanism is live.

1. Get the licence number, the legal entity name and the Curaçao Chamber of Commerce number from the operator’s terms and footer.
2. Find the entity in the current register PDF and check that the type (B2C or B2B) matches the activity.
3. Read the status column and the six-month window; anything other than a blank current entry needs a written explanation from the operator.
4. Search the enforcement register for the entity and licence number.
5. Confirm the domain is one the licence covers. Each additional domain is a separate CGA approval at EUR 250.
6. Use only cga.cw and cert.cga.cw. The old gamingcontrolcuracao.org domain no longer resolves, and lookalike sites exist.

Payment service providers, affiliates and B2B suppliers usually repeat this check at onboarding and at each renewal window. Affiliates have a separate exposure, since promoting an operator into a market where it holds no local licence can breach that market’s advertising rules regardless of Curaçao status; see our page on affiliate marketing compliance.

What responsible gaming, AML and crypto rules apply?

Licensees must run a responsible gaming policy under article 5.4 of the LOK, honour self-exclusion requests for at least twelve months, keep marketing and bonuses from targeting vulnerable people (article 5.6), and apply the CGA’s AML/CFT policy of January 2025. Crypto is permitted, but the CGA’s June 2026 crypto guideline treats it as high risk and bans operators from acting as exchanges.

Under article 5.4 a self-exclusion request is irrevocable for its term of at least twelve months. The CGA’s priorities, set out in its compliance and enforcement policy (version of 31 March 2026, published July 2026), put protection of minors and vulnerable persons first, then illegal gambling, then fraud, money laundering and terrorist or proliferation financing, then advertising and responsible gaming rules. Article 5.7 provides for a guarantee fund to secure player balances, with premiums to be set by ministerial regulation.

The June 2026 crypto policy guideline asks B2C licensees to:

• use blockchain analytics (the CGA names Chainalysis, Elliptic and TRM Labs as examples without mandating one) for deposit screening, ongoing monitoring, source-of-funds tracing and withdrawal screening;
• set specific rules for privacy coins such as Monero and Zcash, and for meme tokens;
• refuse wrapped or bridged tokens whose provenance cannot be established;
• avoid converting, swapping, custody or wallet services outside gambling transactions;
• prefer regulated fiat-backed stablecoins where possible.

Our pages on AML and KYC for gambling operators and gambling payments place these rules alongside EU and UK requirements.

Is there a gaming tax on Curaçao licensees?

The LOK itself does not levy a tax on gross gaming revenue. The Curaçao government’s share comes through the EUR 24,490 annual licence fee paid to the National Treasury by each B2C licensee, set in the CGA’s October 2025 fee note. Corporate profit tax is a separate question under Curaçao’s general tax legislation and depends on the group’s structure.

That makes Curaçao’s fixed-fee model very different from percentage-based regimes. Malta charges a compliance contribution on gaming revenue and a 5% gaming tax on revenue from players in Malta, while Gibraltar and the Isle of Man levy duty on gaming yield. A small operator pays proportionally far more of its revenue in fixed Curaçao fees than a large one does.

Who is a Curaçao licence right for?

A Curaçao licence suits operators targeting markets that have no local licensing regime, or that tolerate offshore supply, and suppliers serving that segment. It does not authorise anyone to serve players in markets with their own licensing, such as Great Britain, Sweden, Germany, the Netherlands or Italy, where the local regulator’s licence is required regardless of any Curaçao authorisation.

That limit is a legal one, not just commercial. In Germany, for example, the Gemeinsame Glücksspielbehörde der Länder (GGL) treats any offer not on its official whitelist as unlawful. Payment providers, app stores and many B2B suppliers apply their own market lists on top. Teams weighing Curaçao against an EU or offshore alternative can use our Anjouan vs Curaçao comparison and the European markets guide to map which countries remain open.

Frequently asked questions

Is a Curaçao licence still a sublicence in 2026?

No. Since the LOK took effect on 24 December 2024, licences are issued directly by the Curaçao Gaming Authority to a Curaçao company. The Orange Seal used under the old master licence model expired on 15 October 2025, which the CGA describes as ending the sublicence system.

Can a non-resident group own a Curaçao-licensed company?

Yes. Ownership can sit abroad, but the licensee must be a Curaçao N.V. or B.V. with its statutory seat in Curaçao and at least one resident managing director (LOK article 2.1). Every UBO and qualified interest holder is vetted and pays a EUR 150 fee with the application.

Does a game provider need a CGA B2B licence today?

Not yet. The CGA’s reclassification policy of 15 October 2025 says a B2B licence is not mandatory for suppliers serving Curaçao-licensed B2C operators until 24 December 2026. Operators must already record their game suppliers and check them against the CGA supplier list.

What does ‘Assessment in progress’ mean on the CGA register?

It appears where a six-month licence window has ended or is ending and the CGA has not yet recorded a decision on continuation. Treat it as unresolved and ask the operator for the CGA’s latest written confirmation, because the CGA states that an invoice alone does not confirm continuation.

Where should a player take an unresolved Curaçao casino dispute?

First to the operator’s complaints process, which must answer within four weeks (extendable once by four). If still unresolved, the player can use the operator’s CGA-certified ADR body free of charge. The CGA itself does not decide individual disputes.

Is the CGA seal still a reliable check after the portal breach?

Not on its own. On 7 October 2026 the CGA said the current digital seal’s availability is affected and that it will introduce an alternative way for operators to show a domain is licensed. Until then, check the register and enforcement register PDFs on cga.cw as well.