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Cross BorderLicensing

Curaçao Gaming Authority (CGA)

Gambling licence in Curaçao: what operators need to know

Curaçao replaced its long-standing master licence system with the Landsverordening Openbare Kansspelen (LOK) on 24 December 2024, moving licensing authority to a single regulator and materially raising the documentation bar for new and existing operators alike.

More key facts

Indicative timeline
Several months from a complete file to decision, longer if documentation is incomplete
Local presence
A local presence requirement applies under the LOK; specifics depend on licence type

What a Curaçao licence costs

The cost of a Curaçao licence is the sum of four things. Which of them dominates depends on your licence type and how far your structure already is from what the CGA expects.

Cost elementWhat it depends onHow we scope it
Regulator feesLicence type (B2C or B2B), your operating model and expected revenue.We confirm the CGA's current fee schedule for your structure before you commit.
Entity and local presenceThe entity structure, premises, staff and decision-makers the LOK requires for your licence type.We size the minimum presence your licence type actually needs — no more.
Application preparationHow complete your UBO, source-of-funds and policy documentation already is.A fixed scope, agreed after the intake review.
Ongoing complianceReporting duties, audits and the number of products you run.On demand or on a retainer, as you prefer.

Figures for your structure are given in the scoping call, once we have read your file. Our own fees are on the Pricing page.

Recent regulatory context

The LOK reform replaced the master licence system

Until December 2024, most Curaçao-licensed operators held a sub-licence under one of four master licence holders, with the master licensee carrying primary regulatory responsibility. The LOK abolished that structure and brought all operators under the direct oversight of the newly empowered Curaçao Gaming Authority.

Existing sub-licensees were required to transition to a direct CGA licence within a defined transitional window. Operators still relying on a master-licence relationship that predates the LOK should treat that transition as unfinished business, not a closed chapter.

Documentation and scrutiny have increased materially

The CGA's application requirements go well beyond what the pre-2024 master licence process typically asked for: a fuller UBO and source-of-funds picture, more detailed AML/CFT policy documentation, and closer scrutiny of the operator's actual technical and organisational setup rather than a template description of one.

Rejection risk has risen accordingly. Files that would have passed under the previous regime are being queried or returned under the LOK, most often on UBO transparency, source-of-funds evidencing, and AML policy documents that don't match how the operator actually intends to run.

Local presence is now a live requirement, not a formality

The LOK introduces a local presence requirement that operators cannot satisfy with a registered-agent address alone. What counts as sufficient presence depends on licence type and is one of the areas where generic, bundle-style application services most often under-deliver — because it requires an operational decision, not a paperwork one.

Why operators choose Curaçao

Curaçao is the fastest and lightest of the three routes, and since the LOK it is a regulated one. Operators choose it because:

  • The application is more straightforward than Malta's or the UK's, and the cost of entry is lower.
  • It suits operators building a global product, including markets that European regulators do not license.
  • Both B2C operators and B2B suppliers are licensed directly by the regulator, under one framework.
  • The LOK gives the licence a defined standard, so banks and partners have something to assess instead of an unknown.

The change to know about is that the old master licence and sub-licence system is gone. Every operator now holds its own licence from the Curaçao Gaming Authority and answers for its own file.

What the LOK requires

  • A Curaçao-registered company holding the licence in its own name.
  • Integrity screening by the CGA of the ultimate beneficial owners, the holders of qualifying positions and the key persons, including their source of funds and source of wealth.
  • Real local presence under the LOK: premises, people and decision-making in Curaçao that fit the licence type. The detail and the timetable for the local requirements depend on the licence type, and we confirm both for you.
  • Appointed compliance and AML roles, with AML/CFT and responsible gambling policies that fit your product.
  • Technical standards for the platform and its game integrity, to the standard the CGA sets for the licence type.

If you hold a sub-licence today and are weighing a direct licence, our article on moving to the LOK sets out what changes.

Regulator fees

FeeB2C operatorB2B supplier
Application fee€4,592€4,592
Annual licence fee (to the National Treasury)€24,490Not payable
Annual supervisory fee (to the CGA)€22,960€24,490
Total in a full year€47,450€24,490

Indicative annual figures in EUR from the CGA fee schedule under the LOK. Extra charges apply for items such as additional domains and for changes to owners or holders of qualifying positions. We confirm the current schedule for your structure before you commit.

Documents you will need

  • Corporate documents for the Curaçao company and a chart of the group down to the ultimate beneficial owners.
  • Identification and integrity information for every owner, qualifying-position holder, director and key person.
  • Evidence of the source of funds and the source of wealth behind the business.
  • A business plan with financial projections, and a description of the games, markets and payment flows.
  • AML/CFT policies and a business risk assessment, plus responsible gambling and player protection policies.
  • A technical description of the platform, game integrity and the controls that protect player data.
  • Evidence of the local presence: premises, staff and the appointed compliance roles.

The ownership documents are where most files are tested. See UBO, source of funds and source of wealth for what the regulator looks for.

The application, step by step

  1. 1

    Choose the licence type

    Decide between a B2C operator licence and a B2B supplier licence. Groups that do both plan separate licensed entities before filing.

  2. 2

    Set up the Curaçao company and map ownership

    Incorporate the entity and map every shareholder to the ultimate beneficial owners, so the CGA can follow the chain from the licence to the people behind it.

  3. 3

    Assemble the file

    Collect the identification and source-of-funds evidence, and write policies for the business as it will really run, not from a template.

  4. 4

    Plan the local presence

    Decide the premises, people and decision-making you need in Curaçao for your licence type, and appoint the compliance roles.

  5. 5

    File and answer queries

    Pay the application fee, submit, and answer the CGA's questions fast and consistently. Every answer must match the file.

  6. 6

    Complete technical and compliance checks

    Finalise the platform documentation and testing the CGA requires for the licence type, and complete banking and payment onboarding in parallel.

  7. 7

    Go live and stay compliant

    Launch on the approved terms, then run the reporting and supervision the LOK requires.

Ongoing obligations

TopicWhat applies
Annual feesThe annual licence and supervisory fees fall due each year, as in the fee table above.
Supervision and reportingThe CGA supervises licensees directly and expects regular reporting and documentation that stays current.
AML/CFTCustomer due diligence, monitoring, record-keeping and reporting of suspicious activity, with a named responsible person.
ChangesChanges to owners, qualifying-position holders or key persons are notified to the CGA, and the new people are screened.
TaxTax treatment depends on the structure and on where the group is managed. We coordinate it with your tax adviser.

For orientation. The detail depends on your licence type and structure and is confirmed in the scoping call.

Banking and payments

Banks and payment providers decide for themselves what they accept, and they look hard at gambling businesses whatever the licence. A Curaçao licence issued under the LOK gives them a defined standard to assess, but the file you give them still has to be strong: clear ownership, evidenced funds, and a credible account of your markets and payment flows.

Begin the banking and payment conversations early and in parallel with the application. Operators that wait until the licence arrives are the ones that launch late.

How Cross Border Licensing helps

  • Assessing whether an existing sub-licence relationship needs to transition under the LOK, and by when
  • Structuring the UBO chain and source-of-funds file to the standard the CGA now expects
  • Drafting AML/CFT and responsible gambling policies that reflect the operator's actual model, not a template
  • Advising on what local presence realistically requires for the operator's specific licence type
  • Liaising with the CGA on queries raised during file review, where authorised to do so

Frequently asked questions

Costs vary by licence type (B2C or B2B), corporate structure, and the scope of advisory support required, so we don't publish a fixed figure. We give an indicative range during a scoping call once we understand the operator's specific structure and product.

Considering a licence in Curaçao?

A short call will tell you where your file actually stands.

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