Curaçao 2025 Gaming Regulations (LOK) – Comprehensive Analysis

The Curaçao National Ordinance on Games of Chance (LOK) 2024 brings major regulatory changes for gambling operators. It introduces stricter compliance requirements, a new licensing system, financial transparency, responsible gaming measures, and enhanced oversight.

We have carefully reviewed the 47-page regulatory document (download) to highlight the most important points for operators, suppliers, and investors.

Major Changes Under LOK 2025

Centralized Licensing and Compliance

For years, Curaçao’s licensing system relied on a master license and sub-license model. Previously,  companies could operate under a master license holder, which simplified the licensing process but lacked direct oversight from a central authority. 

Under the LOK:

• All operators must apply directly to the Curaçao Gaming Authority (CGA) for a license.
• The CGA becomes the sole regulatory body responsible for issuing licenses, conducting audits, and enforcing compliance.
• The previous master license holders no longer have the authority to grant sub-licenses.
• This shift aligns Curaçao more closely with Malta’s gaming framework, which has set international regulatory oversight and compliance standards.

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LOK introduces four main license categories:

• Gaming License – Required for online casinos, sportsbooks, and betting platforms.
• Supplier License – For game developers, payment processors, and cybersecurity providers.
• Nonprofit Game License – Reserved for charitable gaming activities.
• Certificate for Service Providers – For businesses supporting gaming operations (e.g., affiliate marketing, hosting, compliance software).

Each license category comes with its application process, compliance obligations, and annual renewal requirements.

Under the new regulation framework, all licenses will be issued directly by the Curaçao Gaming Authority (CGA)—the island’s newly empowered regulatory body. The CGA now has complete control over licensing, compliance, and enforcement, eliminating the fragmented system of the past.

Existing sub-license holders have a 12-month transition period to migrate to direct licensing. Failure to comply will result in license revocation.

The Higher Costs & Financial Commitments for Operators

The new regulatory framework significantly increases the cost of doing business in Curaçao. Key financial obligations include:

• Gaming License Fees: €47,450 annually (split between the CGA and National Treasury).
• Supplier License Fees: €24,490 per year.
• One-time Application Fee: €4,592.
• Additional Fees:
• €150 per Ultimate Beneficial Owner (UBO) background check.
• €2,551 per listed UBO registration.
• €250 per registered domain.
• €13 per new game added to a platform (subject to the CGA clarification).

Operators generating over €50 million in annual revenue will face additional obligations, including:

• Higher licensing fees.
• More frequent financial audits (up to twice per year).
• Stricter reporting requirements on Gross Gaming Revenue (GGR), deposits, and transactions.
• Additional security measures, such as increased financial reserves and robust AML controls.

These cost increases make Curaçao less accessible for startups and small operators, who may now seek alternative jurisdictions such as Anjouan or Malta.

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Impact of The LOK on Gambling Operators

Higher costs for operators than ever before: The updated framework introduces higher costs for operators: application fee, annual and monthly fees, as well as domain fees per each domain, and due diligence fee for all individuals associated with the business. 

Potential delays: The GCB will go through challenging times of increased workload. It’s impossible to issue licenses to all applicants at the same time, some will meet a delay. For example, the regulatory body has processed 200 applications from 741 transitioning from Masters since April and 300 more new ones. With a promise to process 600 total by January, but it sounds surreal given the current pace. 

It means to be delayed with every old and new applications..

Unpredictable compliance with the law: No one can say how the GCB intends to manage the licensing process and ensure compliance with the stricter requirements. 

It means more surprises are coming..  

Enhanced reputation and trust from players and financial institutions: With help of the LOK legislation, Curacao enhanced its reputation, taking the first place in the iGaming industry together with Anjouan license, leaving other licenses in second place. That is why the jurisdiction is attracted to some providers like Evolution Gaming, EGT, and Play'n GO. 

Potential impact on other jurisdictions: Curacao is going to replace Malta adopting its due diligence process but complete the full process faster. Other licenses, such as Anjouan, can become more attractive to operators, due to it taking the placeLocal Presence & Operational Requirements

The LOK law introduces a mandatory physical presence requirement for operators. To obtain a Curaçao gaming license, businesses must:

• Incorporate as a Curaçao-based legal entity.
• Employ at least one local key person for the first four years, increasing to three key persons in the fifth year.
• Lease or own an office in Curaçao with sufficient facilities to support gaming operations.
• Submit to periodic third-party audits conducted by CGA-approved firms.

Stronger Compliance & Regulatory Oversight

To align Curaçao’s iGaming industry with global best practices, LOK 2024 introduces strict Anti-Money Laundering (AML), Know-Your-Customer (KYC), and due diligence requirements.

The main areas of focus include:

AML  &  KYC Compliance

• Operators must register on goAML, a system that reports suspicious financial activities.
• KYC procedures are mandatory to verify player identities and prevent fraud.
• Operators must monitor transactions and report any unusual activity to the CGA.
• Compliance with Financial Action Task Force (FATF) and Caribbean FATF (CFATF) standards is mandatory.

Due Diligence and Background Checks

• Ultimate Beneficial Owners (UBOs) must be fully disclosed and undergo background screening.
• Operators must submit audited financial reports to prove financial stability.

Due diligence fees range from €140-€270 per individual.

Responsible Gaming Measures

To promote responsible gambling and protect players, Curaçao mandates:

• Deposit limits and self-exclusion programs.
• Prohibition of offering credit to players.
• Stricter advertising regulations, banning promotions targeting minors, or misleading claims.
• Regular audits on responsible gaming policies.

Exemptions & Alternative Compliance Options

Startups & Small Operators Exemption

Startups and small operators can qualify for exemptions from the local presence requirement under specific conditions:

• Businesses incorporated within one year of applying for a license ​​can receive an exemption to support early-stage growth.
• If Ultimate Beneficial Owners (UBOs) have not been linked to another gaming provider in the past two years, they may qualify.

Revenue-Based Exemption:

• Companies with annual Gross Gaming Revenue (GGR) below ANG 20 million (€10 million) for the first three years can delay full compliance.
• Starting from the fourth year, these businesses must fully comply with all local presence requirements.
• Operators must submit semi-annual financial reports to confirm eligibility.

Ministerial Exemption

If an operator cannot hire local key personnel or secure an office in Curaçao, they may qualify for a temporary two-year exemption granted by the Minister of Finance.

Operators who receive this exemption must still comply with Curaçao’s regulations through alternative measures:

• They must prove they can still be effectively monitored and regulated without a full physical presence.
• More frequent audits must be conducted to ensure they follow Curaçao’s gaming laws.

Alternative Compliance Measures

If an operator cannot afford or maintain a dedicated office in Curaçao, they have an alternative option—they can share office space with other licensed gaming companies. The CGA must review and approve such shared spaces to ensure they meet necessary operational, security, and accessibility standards.

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