For nearly three decades, a Curaçao licence was something you bought from a middleman.
Four private master licence holders sold sub-licences, oversight was thin, and an operator could be live within weeks. That market no longer exists.
The National Ordinance on Games of Chance, known industry-wide as the LOK, came into force on December 24, 2024. Every operator now deals with one regulator directly.
Here is what a Curaçao gaming licence under the CGA actually involves today, what it costs, and how to get one without stalling in review.
What Actually Changed Under the LOK
The master and sub-licence model is gone
Antillephone, Curaçao eGaming, Gaming Curaçao, and CIL are no longer in the licensing chain. All legacy sub-licences expired in January 2025.
There is no grandfather clause. The orange sub-licence seals stopped being valid on October 15, 2025.
If a site is still running on old paperwork, it is running unlicensed.
One regulator, two licence categories
The body formerly known as the Curaçao Gaming Control Board now operates as the Curaçao Gaming Authority. It is the sole licensing body and the AML/CFT supervisor for the sector.
The LOK creates two main categories. The B2C licence covers casinos, sportsbooks, poker, bingo, and lottery under a single authorization. The B2B supplier licence covers game studios, platform providers, and other critical service suppliers.
You cannot run both under one licence without specific written CGA approval.
A public register replaced private paperwork
Every active licence sits in a public register linked to a dynamic seal on the operator’s site. The seal ties back to a certificate URL and the operator’s approved domains.
That matters more than it sounds. Acquirers, banks, and game suppliers now verify status in seconds.
Real substance requirements
Only a legal entity established under Curaçao law, with its statutory seat in Curaçao, can apply. The company needs at least one managing director resident in Curaçao.
Physical presence requirements took effect from January 1, 2026, with local staffing obligations phasing in after that. Nominee arrangements that look resident on paper do not survive review.
What a Curaçao Gaming Licence Under the CGA Costs
The fee schedule is published, fixed, and non-negotiable.
According to Asia Gaming Brief’s report on the CGA fee policy, the application fee is EUR 4,592 for both B2C and B2B applicants. B2C operators then pay EUR 47,450 annually, split into a EUR 24,490 licence fee to the National Treasury and a EUR 22,960 supervisory fee to the CGA. B2B suppliers pay a single annual supervisory fee of EUR 24,490.
Smaller charges apply for adding a main domain, requesting certificates, and updating UBO records.
Annual invoices are payable in full by January 15. Initial invoices fall due within 14 days of the grant notification.
There is no gross gaming revenue tax, so the cost stays flat as you scale. Once you add incorporation, a resident director, audits, and policy work, a realistic first-year budget runs well past the government fees alone.
Compare that to the old sub-licence, which many operators ran for a fraction of the price. The cheap entry point is what disappeared.
How to Get a Curaçao Gaming Licence Under the CGA
Step 1: Incorporate locally and secure a resident director
Set up the Curaçao entity first, with its statutory seat on the island. Appoint a managing director who genuinely lives there.
This is the step operators most often try to shortcut. It is also the one the CGA checks hardest.
Step 2: Register with goAML before you apply
Registration in the goAML reporting system is mandatory under national decree. Missing it is a listed ground for refusal, not a fixable detail during review.
Build your AML and CFT framework around it, including transaction monitoring, sanctions screening, and suspicious activity reporting.
Step 3: Document ownership and source of funds
The CGA verifies every ultimate beneficial owner and every person who determines company policy.
A conviction in the past eight years for fraud, theft, extortion, money laundering, or terrorist financing among key persons triggers refusal. So does capital the regulator cannot trace.
Prepare bank records, corporate history, and audited financials that show where the money came from.
Step 4: Build the player protection stack
Before filing, you need a responsible gambling policy, an approved alternative dispute resolution mechanism, and proof of liquidity to pay expected winnings.
These are not appendices. They are refusal grounds in their own right.
Step 5: File through the CGA portal only
Applications submitted outside the online gaming portal are not processed. Full stop.
You will complete the online gaming application form, the business and corporate information form, and a personal history disclosure form for each qualifying person. A business plan is submitted alongside them, following the CGA’s published guidelines.
Step 6: Clear the two-phase review
Phase one assesses integrity and financial stability. Phase two covers the wider regulatory requirements under the LOK.
The CGA aims to process each phase within eight weeks once documents are complete, with a possible four-week extension per phase. Budget for three to five months in practice.
If most conditions are met but a few remain open, the regulator can issue a provisional licence valid for up to six months, extendable once.
Step 7: Pay, display the correct seal, and manage domains
A licence is formally granted only after the initial invoice is paid. You then implement the CGA seal, preferably via the iframe version, linked to your certificate.
Domains are added and managed through the portal or its API. Running traffic on an unapproved domain is a compliance defect.
A definitive Curaçao gaming licence under the CGA has no expiry date. It stays valid while you pay and comply.
The 2026 Deadlines You Cannot Miss
October 8, 2026: terms and conditions. Every B2C licensee must upload T&Cs that comply with the CGA’s April 2026 policy guideline. It covers acceptance mechanics, dormant accounts, payouts, refunds, crypto remittances, and AML wording. This is a policy rewrite, not a footer edit.
December 24, 2026: supplier transition ends. Suppliers established in Curaçao must hold a supplier licence. Foreign suppliers of critical services must be registered. The CGA urged local suppliers to file by September 1, 2026, with registration expected to open in October.
That second deadline lands on operators too. A licensee may not source critical services from an unregistered supplier, so an unlicensed vendor in your stack becomes your compliance problem.
January 15, annually: fees. Late payment escalates quickly toward suspension and removal from the register.
Holding a Curaçao gaming merchant account and licence under the CGA is now an ongoing reporting relationship. Incident reports, player complaint reports, and change notifications all run through the portal.
What This Means for Your Payments Setup
A Curaçao gaming licence under the CGA solves regulatory status. It does not solve acceptance.
Acquirers underwriting gaming merchants now check the CGA register directly, and a provisional entry reads differently from a definitive one. Expect questions about which entity holds the licence, which domains it covers, and who the UBOs are.
Your merchant application should mirror your licence file exactly. Mismatched entity names, unlisted domains, or a different UBO structure will slow underwriting or kill it.
The same criteria for selecting a gambling merchant account apply here, with the added expectation that your processor understands LOK obligations.
The AML file you built for the CGA does double duty. Acquirers ask for the same verification records, which is why KYC compliance for gambling merchant accounts should be designed once and used for both audiences.
One practical point on descriptors. Your Curaçao entity name rarely matches your brand. Set the billing descriptor to the name players recognize, or you will pay for it in disputes.
Is Curaçao Still the Right Choice?
For many operators, yes. A single licence covers every vertical, there is no GGR tax, and the review runs months rather than the year Malta can take.
The tradeoffs are real. Fees jumped, substance is enforced, and the regulator has had a turbulent period, including the resignation of its supervisory board in September 2025 and slow movement from provisional to definitive status for some applicants.
Cheaper jurisdictions like Anjouan and Tobique exist, but they carry less weight with banks and tier-one suppliers.
That gap is exactly why the difference between domestic and offshore gaming merchant accounts is worth thinking through before you pick a licensing home.
If your growth plan depends on mainstream payment acceptance, a Curaçao gaming licence under the CGA still carries more credibility than the lighter alternatives.
Mistakes That Stall Applications
- Applying with an incomplete UBO file. Source of funds gaps are the single most common cause of delay.
- Treating the resident director as a formality. The CGA verifies actual residence.
- Leaving policies until phase two. Responsible gambling and ADR requirements are checked, not assumed.
- Ignoring supplier status. Your vendors’ registration is now part of your compliance profile.
- Starting the payments conversation too late. Most compliance requirements for gambling merchant accounts overlap with the LOK file, so prepare both together.
Final Word
The reform did what it was designed to do. It removed the intermediaries, raised the cost, and turned Curaçao into a jurisdiction with a regulator that can suspend and revoke.
Operators who treat the process as a form-filling exercise get stuck in provisional status. Operators who build the entity, the AML file, and the player protection stack properly get through.
If you are applying for a Curaçao gaming licence under the CGA and want your payment infrastructure ready before approval lands, speak with the team of EMS Global, who works with gaming merchants every day.
FAQs
Are old Curaçao sub-licences still valid?
No. All sub-licences expired in January 2025 and the orange seals became invalid on October 15, 2025. Every operator needs a direct licence from the CGA.
How long does approval take?
The CGA targets eight weeks per phase across two phases, with a possible four-week extension each. Most complete applications take three to five months end to end.
Do I need a company in Curaçao?
Yes. Only entities established under Curaçao law with a statutory seat on the island can apply, and at least one managing director must be resident there.
Can one licence cover both B2C and B2B activity?
Not by default. The categories are separate under the LOK, and combining them requires specific written authorization from the regulator.
Does a Curaçao gaming licence under the CGA guarantee a merchant account?
No. It improves your position considerably, but acquirers run their own underwriting on ownership, business model, chargeback history, and compliance controls.
