Curacao Gaming License 2026: LOK Rules, CGA Fees and Deadlines

Since 24 December 2024, every online gambling licence in Curacao has been issued directly by the Curacao Gaming Authority (CGA) under the National Ordinance on Games of Chance, known locally as the LOK. That date ended the master-licence model that had run since the 1990s, where four private master-licence holders sold sublicences to hundreds of operators with almost no individual oversight. The CGA had started the phased reform in November 2023, so most active operators were already in the new portal when the ordinance took effect. What 2026 adds is the second half of the job: the B2B supplier regime becomes enforceable on 24 December 2026, the local substance rule has been pushed to 1 April 2027, and the CGA has published its first enforcement policy.

The cheap sublicence of 2019 is gone. What replaced it is a real licence with a real regulator, and this guide covers what it costs, how long it takes, and which deadlines matter over the next twelve months.

Key facts

1. 24 December 2024: the LOK (PB 2024, no. 157) entered into force and the CGA became the sole licensing authority; sublicensing under the old LBH ordinance ended for new applicants.
2. Two phases of up to 8 weeks each: the CGA's target for processing an application once the file is complete, extendable by up to 4 weeks per phase; a provisional licence runs up to 6 months, extendable once by 6 months.
3. About EUR 47,000 a year: the combined annual B2C licence and supervisory fee reported by licensing firms since the CGA's fee update, on top of an application fee of ANG 9,000 (about EUR 4,600).
4. 1 April 2027: the new deadline for the local substance requirement in Article 5.12 (at least one full-time local key person plus office premises), announced by the CGA on 23 January 2026.
5. 24 December 2026: the end of the two-year transition for suppliers; from that day a CGA licensee may not buy critical services from a supplier missing from the CGA register (Article 5.16(4)).

Two licence types under the LOK

The LOK splits the market into operators and suppliers, and both need a relationship with the CGA.

B2C online gaming licence. Held by the company that contracts with players. It covers casino, live casino, sportsbook, poker, lottery-style products and crypto-funded play under one licence; there's no separate product permit and no separate crypto authorisation, though the CGA published a crypto policy guideline in the second quarter of 2026 that licensees are expected to follow. The licence is issued for an indefinite period once the second assessment phase is cleared, subject to suspension or revocation.

B2B supplier licence and supplier registration. A company established in Curacao that supplies critical services or goods, from RNG games and live studios to sportsbook engines, bet settlement, odds feeds and aggregation, needs a supplier licence. A foreign supplier doesn't need the licence, but it must be registered in the CGA's public register before a Curacao licensee can legally use it. The mechanics, the illustrative list of critical services and the 1 September 2026 filing date for local suppliers are covered in the Curacao supplier licensing explainer; the term itself is defined in the glossary under supplier licence.

The point of the split is enforcement reach. The CGA can't regulate a studio in Malta, but it can forbid its own licensees from buying from an unregistered one, and that's exactly what Article 5.16(4) does.

Application requirements and timeline

Only a legal entity incorporated under Curacao law with its statutory seat on the island can apply, and it has to be managed by at least one natural person resident in Curacao (or by a Curacao corporate director that itself has a resident director). Everything goes through the CGA online gaming portal, in two phases.

Phase one is the integrity and financial assessment: corporate documents, ownership down to every beneficial owner above 25%, source of funds and source of wealth, criminal record checks for owners and policy-makers, and proof the company can pay out winnings. Convictions for theft, fraud, money laundering or terrorism financing within the last eight years disqualify. Phase two is regulatory compliance: AML/CFT programme and appointed compliance officer, responsible gaming policy, a CGA-approved dispute resolution mechanism, technical set-up, game certification from a recognised lab (see game certification), and the list of domains you'll operate.

The CGA aims to decide each phase within eight weeks of receiving a complete file and can extend by up to four weeks. Add the weeks spent assembling the file and the near-certain round of follow-up questions, and three to five months from decision to definitive licence remains the realistic figure. Files put together without a licensing lawyer or corporate service provider still take six to nine months when documents get bounced. A provisional licence, valid for up to six months and extendable once, lets an operator trade while phase two is assessed.

Fees, tax and the numbers that matter

The CGA doesn't publish a public fee table on its site; it charges fees through the portal and has revised them more than once since 2024. The figures below are the ones consistently reported by licensing firms in 2026 and the same ones used across iGamingHub's licensing coverage. Treat them as approximate and confirm the current schedule with the CGA before you budget.

Regulator fees are only the visible part. A realistic first-year budget still lands at EUR 65,000 to 115,000 once you add the local managing director and corporate service provider (EUR 12,000 to 24,000 a year), incorporation, an iGaming-friendly bank account, game and RNG certification, legal work on the application and AML tooling. The "EUR 25,000 Curacao licence" headline has stopped appearing even in agents' adverts.

Acquirers still price Curacao licensees as high-risk, which means rolling reserve holds of 5-10% for the first months. The high-risk acquiring guide explains how to negotiate them down; a CGA licence with a clean reporting history helps more than the old sublicence ever did.

Ongoing obligations once licensed

The CGA supervises actively now. Its second stakeholder bulletin (May to July 2026) notes reminder letters to operators that missed the June 2026 deadline for their 2025 figures, meetings with the trust offices that service licensees, and work on tools to act against foreign entities holding player funds for operators. The standing obligations are:

• AML/CFT: a documented programme with customer due diligence, enhanced due diligence for PEPs and high-value players, transaction monitoring, suspicious transaction reporting, five-year record keeping and a named compliance officer. In August 2026 the CGA also published provisions for identification and verification without physical contact, which set how remote KYC has to work.
• Responsible gaming: self-exclusion, deposit and session limits, reality checks, and an approved player dispute mechanism.
• Reporting: annual financial figures to the CGA, ad hoc information requests, and incident notification. Operators below NAf 20 million in GGR can defer the substance rule but still report.
• Domains and geoblocking: every URL registered with the CGA, and access blocked from the Netherlands and its Caribbean territories, the United States, the United Kingdom and any market where local law requires a domestic licence. The rest is grey-market territory, and the CGA's 2026 seminar flagged "effectively managing access from restricted jurisdictions" as a priority.
• Suppliers: from 24 December 2026, only registered suppliers in your stack.

The compliance and enforcement policy for online gaming, published on 17 July 2026, sets out an escalation ladder for missed obligations: a conversation or warning first, then a formal instruction, then an order under administrative coercion or subject to a penalty, then an administrative fine, then suspension, amendment or revocation of the licence, and criminal referral for offences. The ladder only climbs when the violation continues.

What happened to the legacy sublicences

Under Article 15.1 of the LOK, a company that held its own licence under the old Offshore Games of Hazard ordinance (LBH) on 24 December 2024 and ran its own operation received a provisional LOK licence by operation of law for up to six months, extendable by six, with a six-month decision window for phase two. Applications still pending on that date were finished under LBH rules and converted the same way. Sublicensees, who never held a licence of their own, had to apply directly through the portal, which had been accepting them since November 2023; that's why the switch caused less disruption than expected.

The practical consequence in 2026: any company still advertising a "Curacao sublicence" or "master licence" is describing a structure the LOK no longer recognises. Check the licence number against the CGA's public register before signing a white-label or turnkey contract, and check that the vendor is either CGA-licensed (if it's in Curacao) or registered (if it isn't). The step-by-step guide to opening an online casino shows where the licence sits in the launch sequence.

Which platforms support a Curacao licence

Most turnkey and white-label vendors built their business on Curacao-licensed brands. iGamingHub tracks 20 platforms with a Curacao licence in its catalog. Four worth shortlisting:

• Softswiss: turnkey on a hybrid revenue model, lists MGA, Curacao, ONJN, Kahnawake and Brazil, and quotes 4 to 12 weeks to launch with crypto support built in.
• NuxGame: turnkey and white-label, revenue share, Curacao and Anjouan among a long licence list, 3 to 8 weeks to launch, with LATAM, Asia and Africa as its core markets.
• SoftGamings: white-label on a fixed fee, MGA, Curacao, Anjouan and others, the shortest quoted launch window in this group at 1 to 8 weeks.
• Hub88: white-label and aggregation on revenue share, MGA, Curacao and Anjouan, 4 to 10 weeks to launch.

Each of these is a foreign supplier from the CGA's point of view, so by December each needs to appear in the supplier register for its Curacao clients to stay compliant. Ask for the registration plan in writing before you sign.

How Curacao compares with Anjouan and Malta

Curacao now sits in the middle of the offshore range rather than at the bottom. Anjouan charges EUR 17,828 a year at the regulator's window and can be on a footer within a month, but payment acceptance is thinner and there's almost no supervisory track record. Malta costs EUR 5,000 to apply, EUR 25,000 a year plus a compliance contribution of 0.40% to 1.25% of GGR and 5% gaming tax on Malta players, takes four to six months and opens tier-one acquirers. Curacao costs roughly two and a half times Anjouan, lands three to five months in, and carries 0% gaming tax with improving payment access. The six-jurisdiction table, including Nevis, Kahnawake and the Isle of Man, is in the offshore licensing comparison.

The short version: pick Anjouan to validate a concept cheaply, Curacao to run a real business in LATAM, Asia or Africa on a licence processors recognise, and Malta when European markets or an exit are on the table.

Milestones ahead

• 1 September 2026: the date the CGA asked Curacao-established suppliers to file supplier licence applications by.
• October 2026: supplier registration scheduled to open for domestic and foreign suppliers on the portal.
• 24 December 2026: end of the two-year supplier transition; Article 5.16(4) becomes enforceable against operators and the register must be operational.
• 1 April 2027: local substance requirement in Article 5.12 becomes mandatory unless the ministerial decree extends it again (the LOK allows an exemption of at most two years).
• 24 December 2028: year five of the LOK, when the minimum local headcount for licensees above the GGR threshold rises from one key person to three.
• Rolling: annual figures due mid-year, the crypto policy guideline phased in over 12 months, and the CGA's public warning list of sites falsely claiming Curacao authorisation.

Primary sources

• Curacao Gaming Authority, online gaming regulation page: the LOK's entry into force on 24 December 2024 and the transition from the LBH.
• National Ordinance on Games of Chance (Landsverordening op de kansspelen), PB 2024 no. 157: the ordinance text (Dutch), including Articles 5.12, 5.16, 13.37 and 15.1.
• CGA online gaming portal, licensing information: eligibility, two-phase assessment, eight-week targets and provisional licence terms.
• CGA notice of 23 January 2026 on the postponement of the local substance requirement.
• CGA compliance and enforcement policy for online gaming, 17 July 2026.
• CGA stakeholder bulletin Q2 2026: supplier register deadline, crypto guideline and supervision activity.

Fee amounts aren't published on the CGA site; the ranges above are what licensing firms and operators reported in 2026, which is why they're marked approximate. Platform licence support is self-reported by each vendor in the iGamingHub catalog.