Curaçao Gaming Industry Enters a New Era with Full Implementation of the LOK Licensing Framework
Curaçao, 2025 – A Comprehensive Guide to the New Regulatory Landscape
The gaming industry in Curaçao has undergone a landmark transformation with the full implementation of the Landsverordening op de Kansspelen (LOK), the country’s long-anticipated gaming law. As of 2025, all gaming operators and suppliers must comply with the new framework, replacing the previous master and sub-license system with a centralised, government-issued licensing model.
This new regulatory structure strengthens Curaçao’s international reputation as a trusted iGaming hub while enforcing stricter compliance, financial oversight, and responsible gaming measures. The Curaçao Gaming Control Board (CGB), the newly established regulatory body, has now fully assumed responsibility for issuing licenses, ensuring adherence to anti-money laundering (AML) policies, and enforcing consumer protection standards.
With competitive fees, streamlined processes, and clear guidelines for both operators (B2C) and suppliers (B2B), Curaçao remains a top jurisdiction for iGaming businesses worldwide. This article provides a comprehensive breakdown of the new licensing requirements, application processes, fees, compliance obligations, and operational expectations under the LOK framework.
A New Era: The End of the Master and Sub-License System
For decades, Curaçao’s gaming license operated under a master and sub-license model, where only four master license holders had the power to grant sub-licenses to operators. Under the LOK, this system has been entirely eliminated, and now every operator must apply directly to the CGB for their own license.
This change provides greater transparency, regulatory oversight, and accountability, ensuring that all gaming businesses operate in compliance with international standards.
With the removal of sub-licenses, existing gaming operators must transition to a direct CGB-issued license to continue operations. The transition period allows time for compliance, but non-compliant operators risk losing their ability to conduct business in Curaçao.
Types of Licenses Under LOK
The LOK framework introduces two primary categories of licenses to cover the entire iGaming ecosystem:
1. B2C License (Gaming Operator License)
A B2C license is required for any company that operates an online gaming platform. This includes casinos, sports betting sites, poker rooms, and any other real-money gaming operation.
2. B2B License (Gaming Supplier License)
A B2B license is mandatory for companies that provide gaming-related goods or services to B2C operators. This includes game developers, platform providers, payment processors, software vendors, and technical service providers.
Holders of a B2B license are officially recognized by the CGA as approved suppliers and will be listed in a public register of licensed suppliers.
General Requirements for a Curaçao Gaming License
The LOK framework imposes stricter eligibility criteria for gaming licenses, ensuring that only financially stable, reputable, and compliant operators are approved. Below are the key requirements:
Legal & Corporate Requirements
- Applicants must establish a Curaçao-incorporated company, either as a naamloze vennootschap (N.V.) or a besloten vennootschap (B.V.), and register with the Curaçao Chamber of Commerce.
- Companies must have a physical office or designated business space in Curaçao.
- At least one Curaçao-resident Key Person must be appointed for the first four years of operation. This increases to three Key Persons from the fifth year onwards.
Technical & Compliance Requirements
- Operators must provide a detailed operational manual, covering:
- Game descriptions, payout structures, and betting limits.
- Player identity verification and AML policies.
- Data storage policies and cybersecurity measures.
- Responsible gaming initiatives, including self-exclusion options.
- All gaming software must be tested and certified by accredited, independent testing laboratories.
- Operators must maintain a Tier-IV certified server in Curaçao to ensure regulatory compliance.
Financial & AML Compliance
- Annual financial statements must be submitted to the CGB by June 30 each year.
- Operators must implement strict AML policies, requiring identity verification for players conducting transactions exceeding ANG 4,000.00.
- Player funds must be kept separate from operational funds to prevent misuse.
Player Protection & Market Restrictions
- Operators must implement self-exclusion programs and restrict access to vulnerable persons.
- The following individuals are prohibited from registering on Curaçao-licensed platforms:
- Persons under 18 years of age.
- Residents of Curaçao unless specifically permitted.
- US residents and individuals in restricted jurisdictions.
- Any individual designated as a Key Person in the company.
Application Process & Timelines
The licensing process under LOK is divided into two phases to ensure thorough vetting:
Step 1: Company Formation (2-3 Weeks)
- Applicants must register their Curaçao entity, appoint local directors, and secure a physical business presence.
Step 2: License Application (8-16 Weeks)
- The CGA reviews the application within 8 weeks. If additional verification is required, an extension of 8 weeks may be granted.
- The license approval process follows a two-phase approach:
- Initial Review – Background checks on company owners, Key Persons, and financial integrity.
- Full Compliance Review – Examination of technical, operational, and security measures.
- Provisional licenses may be issued for up to 6 months, allowing operators to commence operations while awaiting final approval.
License Duration & Renewal
Unlike the previous system, which required reapplying for a license every three years, LOK gaming licenses are issued for an indefinite period. However, licenses are subject to:
- Ongoing compliance checks, audits, and periodic reviews.
- Mandatory reporting of any changes in ownership, financial stability, or operational scope.
- License suspension or revocation in case of regulatory violations.
New Curaçao Gaming License Fees
The LOK introduces a transparent and structured fee system for both B2C and B2B license holders.
B2C (Gaming Operator) Fees
- Application Fee: €4,592 (one-time, non-refundable)
- Annual Fees:
- License Fee (National Treasury): €24,490
- Supervisory Fee (CGA): €22,960
- Total Annual Cost: €47,450
B2B (Gaming Supplier) Fees
- Application Fee: €4,592 (one-time, non-refundable)
- Annual Supervisory Fee (CGA): €24,490
Other Administrative Fees
- Additional Domains: €250 per domain (one-time)
- Change of UBOs or Qualified Interest Holders: €128 per person
Final Thoughts: The Future of Curaçao’s Gaming Industry
The implementation of LOK marks a new era of legitimacy and oversight for the Curaçao iGaming sector. With stronger compliance measures, competitive fees, and a well-structured licensing process, Curaçao solidifies its position as a leading international gaming jurisdiction.
For gaming operators, now is the time to ensure full compliance and transition to the new direct licensing model. The CGB is committed to maintaining regulatory integrity while ensuring a stable and innovative business environment for all licensed entities.
As Curaçao moves forward with this groundbreaking regulatory shift, the future of online gaming in the jurisdiction looks more secure, transparent, and sustainable than ever before.
How Chambers & Co Can Help You Navigate the New Curaçao Gaming Licensing Regime
With the LOK now fully implemented, obtaining and maintaining a Curaçao gaming license requires expert legal guidance, strategic structuring, and strict regulatory compliance. Our law firm specializes in gaming law, corporate structuring, and regulatory compliance, providing end-to-end legal support for both B2C gaming operators and B2B suppliers looking to establish or transition their business under the new framework.
Whether you are an existing operator seeking to transition from a sub-license or a new entrant looking to enter the market, our team of lawyers, compliance specialists, and corporate advisors is ready to assist you at every stage.
Our Comprehensive Legal Services
1. Company Formation & Corporate Structuring
- Assistance with registering a Curaçao-incorporated company (N.V. or B.V.) in full compliance with CGB requirements.
- Corporate structuring to meet tax efficiency, shareholder protection, and operational needs.
- Drafting of key governance documents, including Memorandums of Association, shareholder agreements, and corporate bylaws.
- Appointment of local Key Persons, ensuring compliance with residency and operational requirements.
2. Gaming License Application & Compliance Support
- Preparation and submission of license applications for both B2C and B2B businesses.
- Guidance on meeting AML, responsible gaming, and financial reporting requirements under the LOK.
- Liaison with the Curaçao Gaming Authority (CGB) throughout the licensing process.
- Assistance with gaming software certification and regulatory approvals.
3. Legal & Regulatory Compliance
- Ongoing compliance monitoring to ensure full adherence to CGB regulations and avoid penalties.
- Development of AML, KYC, and responsible gaming policies in line with LOK mandates.
- Legal representation in regulatory matters, including audits and dispute resolution.
- Updating license holders on legislative changes and assisting with necessary business adjustments.
4. Tax & Financial Advisory
- Advising on Curaçao’s tax framework for gaming businesses, including VAT, corporate income tax, and profit distributions.
- Ensuring proper financial reporting to meet CGB and Curaçao tax authority requirements.
- Structuring of banking relationships and financial compliance for operators and suppliers.
5. Transitioning from a Sub-License to a Direct License
- Legal review of existing agreements with former master license holders.
- Assistance with restructuring and obtaining a direct gaming license under the CGA.
- Compliance gap analysis and risk assessment for transitioning operators.
Why Choose Our Law Firm?
With extensive experience in Curaçao gaming law and international regulatory compliance, our team provides tailored legal solutions designed to help your gaming business thrive under the new LOK framework. We offer:
✔ Expertise in Curaçao’s gaming laws with a proven track record of successful license applications.
✔ Direct communication with CGA and government authorities to streamline regulatory approvals.
✔ Comprehensive legal, corporate, and tax services for B2C and B2B gaming entities.
✔ Ongoing compliance support to safeguard your license and ensure smooth operations.
Get Started with Your Curaçao Gaming License Today
Navigating the new Curaçao licensing regime requires expert legal support and strategic planning. Whether you need assistance with company formation, licensing, compliance, or regulatory transitions, our law firm is here to guide you every step of the way.
Contact us today to schedule a consultation and take the first step toward establishing your gaming business in Curaçao under the LOK framework.
