Curacao Gaming Reform: Key Takeaways

Curaçao, long known as a hub for online gaming operators due to its easy licensing and favorable tax regime, is undergoing an overarching reform of its gaming licenses. In 2024, the island nation shifted from its Master License/Sublicense system to a new regulatory model featuring Business-to-Consumer (B2C) and Business-to-Business (B2B) licenses. The reform establishes a centralized Curaçao Gaming Authority (CGA) and enacts a rigorous compliance framework aligned with international standards. 

In this article, we analyze Curaçao’s regulatory background, detail the key features of the 2024 legislative changes, explore the motivations driving the change, and discuss the impact on the global gaming industry and its stakeholders. We also break down the new licensing process, compliance requirements, fees, and enforcement mechanisms under the LOK.

The Old Days: Master Licenses and Sublicenses

For decades, Curaçao operated a highly permissive online gambling licensing system based on Master Licenses and Sublicenses. After legalizing online gaming in 1993 with one of the world’s first e-gaming laws, Curaçao issued just a handful of Master Licenses – only four entities held them, each authorized to grant an unlimited number of sublicenses to online casino and betting operators. This structure meant that hundreds of operators around the globe could essentially piggyback under a Master License, allowing multiple companies to operate under a single license. The appeal was obvious: minimal bureaucracy and low fees made Curaçao an attractive entry point for start-ups and entrepreneurs in iGaming.

Why Now? A Push for a Change

Several factors drove Curaçao to reform its gambling laws in 2024. International pressure and reputational concerns were, of course, the defining factors. Curaçao faced scrutiny from Dutch authorities and global financial watchdogs regarding the risks posed by its lax gaming regime. This came amidst an ongoing licensing scandal on the island, involving allegations of corruption and licenses issued without proper legal basis, underscoring the need for a more robust and transparent system.

The New Legislation: LOK and the Curaçao Gaming Authority (CGA)

Curaçao’s gambling sector has undergone a significant transformation with the introduction of the National Ordinance on Games of Chance (LOK), a landmark law passed by Parliament in December 2024. Approved with a 13–6 vote, the act replaces the island’s outdated Master License system with a modern regulatory framework designed to align with international standards. At the heart of this reform is the creation of the Curaçao Gaming Authority (CGA), an independent body tasked with overseeing all gambling activities on the island. It succeeds the former Gaming Control Board and operates free from direct governmental oversight to ensure impartiality and efficiency in its regulatory duties.

The CGA holds extensive responsibilities, including issuing licenses, monitoring compliance, and enforcing gambling regulations for both B2C (Business-to-Consumer) and B2B (Business-to-Business) operators. Unlike the previous system, which permitted sublicensing with minimal supervision, the LOK explicitly prohibits unlicensed gambling activities. Any entity offering games of chance from Curaçao must now secure a direct, non-transferable license from the CGA.

B2C and B2B Licensing: A Dual-License System

One of the major changes introduced by the LOK is the adoption of a dual-license system, comprising B2C and B2B licenses. It replaces the previous uniform sublicense model with a more structured and precise approach:

• B2C License (Operator License). This license applies to businesses that offer gambling services directly to players, such as online casinos, sports betting platforms, poker rooms, and lottery operators. B2C licensees manage the full spectrum of player interactions, including registration, Know Your Customer (KYC) processes, fund handling, and adherence to consumer protection laws like responsible gambling policies and anti-money laundering (AML) measures.
• B2B License (Supplier License). This category targets companies that provide essential services or infrastructure to the gaming industry without engaging players directly. This includes game software developers, platform providers, payment processors, and affiliate management firms. B2B licensees support B2C operators but cannot offer games to the public unless they also hold a B2C license. 

Key Compliance Requirements and New Oversight Measures

The LOK establishes a stringent compliance framework that significantly elevates the standards for license holders, aiming to boost integrity, and protect players. Key requirements include:

• Local Incorporation and Presence. Applicants must establish a legal entity in Curaçao, complete with a statutory seat and at least one resident director. Within 4 years, licensees must maintain a physical office and 1 key staff member on the island, increasing to 3 staff members within 5 years. 
• Integrity and Fit-and-Proper Checks.The CGA conducts background checks on applicants, UBOs, and key personnel. Individuals with financial crime convictions within the past 8 years are barred from holding significant roles. Applicants must demonstrate integrity, competence, and financial stability.
• Financial Stability and Player Fund Protection. Licensees must prove sufficient liquidity to sustain operations and guarantee payouts. Player funds — deposits and winnings — must be held in segregated accounts, separate from operational finances, to safeguard them in case of insolvency.
• AML/CFT and KYC Obligations. Enhanced AML/CFT rules require licensees to appoint a compliance officer, implement KYC and customer due diligence (CDD) protocols, and report suspicious activities to the Financial Intelligence Unit. These measures align with global FATF standards, preventing illicit financial activities and money laundering operations.
• Technical and Operational Standards. Gaming software must be certified by approved testing labs for fairness and integrity. Critical data, including player records and transactions, must be stored on Curaçao-based servers, ensuring the CGA’s access for audits or investigations. This strengthens operational oversight and security.
• Responsible Gambling Measures. Operators must enforce deposit and betting limits, offer mandatory breaks, provide self-exclusion options, and supply resources for problem gambling. These mandates protect vulnerable players and reflect international best practices in consumer welfare.
• Regular Audits and Reporting. Licensees must undergo biannual audits for the first 2 years, followed by annual audits thereafter. They are also required to submit financial and operational reports via an online portal.

These requirements mark a dramatic improvement over the previous system, enhancing the legitimacy and reliability of Curaçao’s gambling industry.

License Application Process and Fee Structure under LOK

The process of obtaining a gaming license under the LOK is now more thorough and formalized. Prospective operators must follow these steps:

1. Establish a Curaçao-registered entity with a resident director.
2. Submit documents, including passports, CVs, financial statements, business plans, AML/KYC policies, and technical certifications. 
3. Pay a non-refundable fee of €4,592 for either a B2C or B2B license application, covering administrative costs.
4. Upon approval, B2C licensees pay an annual fee of approximately €47,500 (comprising a government fee of €24,500 and a CGA supervisory fee of €23,000 ), while B2B licensees pay €24,500 annually.

Though more expensive than the old system, these costs remain competitive globally, especially given Curaçao’s favorable tax environment — 0% gaming tax and a 2% corporate tax for e-zone companies. 

Enforcement and Transition Measures

The CGA wields significant enforcement powers, including the ability to investigate, impose fines, suspend operations, or revoke licenses for non-compliance. This firm approach aims to eliminate the laxity of the past and uphold the new standards. Operating without a valid license or under an expired sublicense is now illegal, subjecting offenders to penalties.

To ease the shift, the CGA has extended provisional licenses, allowing existing operators until December 24, 2025, to achieve full compliance. During this period, operators must demonstrate progress on meeting the new requirements. However, challenges such as application delays and operator confusion have slowed the transition, though the CGA remains committed to enforcing the new regime by the deadline.

Impacts and Implications for the Global Gaming Industry

Curaçao’s reform carries broad implications:

• Existing operators face increased costs and compliance demands, potentially driving smaller players out of the market. Master License holders lose their sublicense-issuing privileges but gain transition time to adapt. Those who comply will benefit from enhanced credibility.
• For new entrants, the stricter entry requirements and higher costs may deter some, but the improved license reputation could ease banking and payment challenges. Curaçao remains appealing due to its all-encompassing license, moderate fees, and tax benefits, potentially attracting more reputable operators.