Back to previous page

Curaçao gambling license in 2026: costs, timeline and the new LOK rules

Article_image
light

A  Curaçao gambling license in 2026 is a direct license issued by the Curaçao Gaming Authority (CGA) under the National Ordinance on Games of Chance (LOK). This law replaced the old master-license system on 24 December 2024 (per the CGA licensing portal). The application fee is EUR 4,592, the annual cost of a B2C license is EUR 47,450, and the CGA aims to process each of the two review phases within eight weeks, extendable by up to four weeks per phase (License Fees under the LOK v2.0, CGA; CGA portal, Online Gaming Info). Sublicenses from master license holders no longer exist. If a provider offers you one, walk away.

This guide covers the new regime step by step: what the LOK changed, which license types exist, what the CGA checks, what everything costs, and how Curaçao now compares with Anjouan and Malta.

What changed: the LOK and the new Curaçao Gaming Authority

On 24 December 2024 the Landsverordening op de kansspelen (LOK), P.B. 2024 no. 157, came into force. The CGA states it plainly on its portal: “As of December 24, 2024, the new National Ordinance on Games of Chance (LOK) has officially come into effect” (CGA portal). The LOK replaced the National Ordinance on Offshore Games of Hazard (NOOGH), the 1993-era law behind the famous master-license model (archived CGA page on online gaming).

Three structural changes matter most for operators:

  1. A new regulator. The Gaming Control Board (GCB) became the Curaçao Gaming Authority (CGA) when the LOK took effect. The CGA has also been moved from the Ministry of Finance to the Ministry of Justice (CGA transition announcement, PDF), signaling that gambling supervision in Curaçao is now treated as an enforcement matter rather than just a fiscal one.
  2. Direct licensing only. Every operator applies to the CGA itself, through its online portal. The CGA’s FAQ confirms that all applications “must be submitted via this Portal” (CGA portal FAQ).
  3. The end of sublicenses. Former sublicensees underwent a transition process in 2025, and the last remnant of the old system, the “Orange Seal” certificate of operation, expired on 15 October 2025. The CGA warned that from that date “any operator displaying an orange seal on its domains will be in breach of Curaçao law” (CGA announcement, 25 September 2025, PDF).

A practical note on sources: the CGA’s main website was returning errors at the time of writing, so the live official reference point is the licensing portal at portal.gamingcontrolcuracao.org. The full English translation of the LOK is also published there (LOK, official English translation, PDF).

Which license types exist under the LOK?

The LOK fee schedule defines two direct licenses (License Fees under the LOK v2.0, CGA):

  • Online gaming license (B2C). The operating license for anyone offering games of chance to players. This is the license casinos, sportsbooks, and other operators need.
  • Supplier license (B2B). A platform and software license for suppliers. Important nuance: the B2B licensing requirement does not apply immediately. The CGA states that “this requirement will not take effect immediately but will come into force two years after the LOK takes effect”, so it applies from 24 December 2026 and applies to suppliers established in Curaçao (CGA portal, Online Gaming Info).

Both licenses come in two stages. If an applicant meets the integrity and financial tests but has not yet satisfied every operational requirement, the CGA can grant a provisional license for up to six months, extendable once by another six months. Once all conditions are met, the operator receives a definitive license, which is “issued for an indefinite duration”: no renewals. However, the CGA can suspend or revoke it (CGA portal, Online Gaming Info).

What are the requirements, step by step?

Step 1. Incorporate in Curaçao

Only “legal entities established under Curaçao law, with their statutory seat in Curaçao” can hold a license. The company needs at least one managing director who is a Curaçao resident, or a Curaçao corporate director that itself has a resident director (CGA portal, Online Gaming Info).

Step 2. Plan for local substance (deferred to 2027)

Article 5.12 of the LOK adds a real substance requirement: for the first four years, at least one full-time Key Person recruited from the Curaçao Population Register (in addition to the local director), rising to at least three Key Persons from year five, plus the operator’s own office premises on the island. The Minister of Justice has granted a general deferral: “Operators will not be required to meet this obligation under Article 5.12 before April 1, 2027” (CGA announcement, 23 January 2026, PDF). Budget for it now anyway. The obligation is in the law, not in a policy that can quietly disappear.

Step 3. Prepare the application file

Applications go exclusively through the CGA portal, using its official forms: the Online Gaming Application Form or Supplier License Application Form, the Business and Corporate Information Form, and a Personal History Disclosure Form for key individuals (CGA portal). The CGA also publishes an official AML policy template for applicants and license holders in its Guidelines section (CGA portal, publications).

The CGA must refuse an application on several mandatory grounds, including: UBOs, qualified interest holders or policy-makers that cannot be verified; convictions of key persons within the last eight years for fraud, money laundering or terrorist financing; an untraceable source of funds; outstanding tax or social insurance debts; insufficient liquidity to pay out player winnings; no responsible gaming policy; no ADR mechanism for player disputes; and no goAML registration (CGA portal, Online Gaming Info). Fix these before filing, not after a rejection.

Step 4. Pass the two-phase review

The CGA reviews applications in two phases: Phase 1 covers integrity and financial stability, Phase 2 covers the regulatory requirements of the LOK. For each phase, “the CGA aims to process the application within eight weeks. If more time is required, the process may be extended by up to four weeks in each phase” (CGA portal, Online Gaming Info). Realistic planning horizon: roughly four to six months from a complete file to a license, longer if the CGA asks follow-up questions.

Step 5. Operate under the license conditions

The conditions attached to a definitive license include: critical data hosted on a server in a Tier-IV data center in Curaçao, prior CGA permission for any change of key persons, incident reports within 24 hours, AML/CFT compliance under the NORUT and NOIS ordinances, and offering games only on CGA-approved domains (CGA license conditions, indefinite term). Provisional license holders have additional player-protection duties, including keeping winnings available to players for at least 30 months, account history for at least 90 days, and segregation of player funds (CGA provisional license conditions).

How much does a  Curaçao gambling license cost in 2026?

All figures below come from the CGA’s official fee document, License Fees under the LOK, Version 2.0, dated 15 October 2025, which mirrors Articles 5.18 and 5.19 of the LOK (PDF). The same fee table is published in the official gazette, Landscourant van Curaçao no. 46 of 14 November 2025 (gobiernu.cw).

FeeB2C (online gaming)B2B (supplier)
Application fee (one-time, non-refundable)EUR 4,592EUR 4,592
Per UBO screeningEUR 150 eachEUR 150 each
Per Qualified Interest Holder (≥10%)EUR 150 eachEUR 150 each
Per listed UBOEUR 2,551 eachEUR 2,551 each
Annual License Fee (National Treasury)EUR 24,490EUR 0 (not applicable)
Annual Supervisory Fee (CGA)EUR 22,960EUR 24,490
Total annual feesEUR 47,450EUR 24,490
Adding a main domain (one-time)EUR 250EUR 250
Certificate application (test labs, etc.)EUR 383EUR 383
Change or addition of a UBOEUR 128 per personEUR 128 per person
Change of a Qualified Interest HolderEUR 128 per personEUR 128 per person
Extending or replacing gamesEUR 13 per gameEUR 13 per game

Two payment rules deserve attention. First, the annual fees are due in full by 15 January each year. Second, the CGA enforces non-payment on a fixed day-count escalation: reminders on days 15 and 29, a Notice of Intended Suspension on day 43, suspension on day 57, and revocation on day 71, with the operator entered into the public Enforcement Register (License Fees under the LOK v2.0, CGA). Under the old regime, fee discipline was a private matter between the sublicensee and master license holder. Now it is public and automatic.

How does Curaçao compare with Anjouan and Malta in 2026?

The three jurisdictions now sit at clearly different price and obligation points.

Annual cost. Anjouan is the cheapest: EUR 17,828 for license issuance plus EUR 17,828 for annual renewal, with EUR 500 per additional B2C domain; all fees are payable in euros and non-refundable (Anjouan Offshore Financial Authority, fees). Curaçao sits in the middle: EUR 24,490 per year for B2B, EUR 47,450 for B2C. Malta is the most expensive once you look past the headline: EUR 5,000 application fee and a fixed annual license fee of EUR 25,000 for B2C (EUR 25,000 to 35,000 for B2B depending on revenue), plus a monthly compliance contribution that for a Type 1 B2C licensee runs from a minimum of EUR 15,000 to a maximum of EUR 375,000 per license period, plus a 5% gaming tax on gaming revenue from Malta-based players (MGA Guidance Note, Licence Fees and Taxation, PDF).

Tax model. Malta is the only one of the three that ties an ongoing levy to revenue (the 5% gaming tax plus the sliding compliance contribution). Curaçao and Anjouan charge fixed fees regardless of turnover, which makes budgeting simpler for early-stage operators.

Substance. Curaçao is the only one of the three with a staffing and office requirement written into the licensing law itself (LOK Article 5.12, deferred until 1 April 2027, as above). That raises the operating cost, but it is also exactly the kind of obligation that banks and payment providers read as a sign of a real, supervised business.

The honest summary: Malta remains the premium EU option; Curaçao has repositioned itself as a mid-tier supervised jurisdiction with real substance expectations; and Anjouan has taken over the niche Curaçao used to occupy: the fast and affordable entry license. Manimama’s iGaming team works with all three routes; see our dedicated Anjouan gaming license service page and the full iGaming legal support hub for scope and process. If your model depends on which license payment providers and B2B partners will accept, that comparison, not the fee table, should drive the decision, and it is worth a structured legal review before you commit an application fee anywhere. A Curaçao gambling license makes sense when you want fixed costs plus a supervision story you can show to banks; Anjouan wins on pure speed and price; Malta wins on EU market access.

FAQ

Is the Curaçao master license still available in 2026?

No. The master-license and sublicense system ended with the LOK, which took effect on 24 December 2024. Former sublicensees underwent a transition in 2025, and the final element, the Orange Seal, expired on 15 October 2025, per the CGA’s official announcement. Any offer of a Curaçao “sublicense” today has no legal basis. Only direct CGA licenses exist.

How long does it take to get a Curaçao license?

The CGA reviews applications in two phases: integrity and financials first, then regulatory compliance. It aims to complete each phase within eight weeks and may extend each by up to four weeks, per its official guidance. Plan for roughly 4 to 6 months, with a complete file. A provisional license (up to six months, extendable once) can bridge remaining operational gaps.

How much does a Curaçao gaming license cost per year?

A B2C operator pays EUR 47,450 per year: EUR 24,490 to the National Treasury and EUR 22,960 to the CGA as a supervisory fee, due in full by 15 January. A B2B supplier pays only the EUR 24,490 supervisory fee. The one-time application fee is EUR 4,592 for either license, per the CGA fee schedule of 15 October 2025.

Do I need a real office and staff in Curaçao?

Eventually, yes. Article 5.12 of the LOK requires operators to employ at least one full-time Key Person from the Curaçao Population Register in the first four years, three from year five, and to maintain their own office on the island. The CGA announced in January 2026 that this obligation will not be enforced before 1 April 2027.

Is a Curaçao license valid forever?

The definitive license is issued for an indefinite duration, so there is no renewal cycle. It remains valid as long as the operator pays the annual fees and complies with the license conditions, including Tier-IV local data hosting, 24-hour incident reporting, and AML/CFT duties. Unpaid fees trigger a fixed escalation ending in revocation on day 71 and a public Enforcement Register entry.

Our Contacts

If you would like to become our client or partner, please do not hesitate to contact us at support@manimama.eu.

Alternatively, you can use our Telegram @ManimamaBot, and we will respond to your inquiry.

We also invite you to visit our website.

Join our Telegram to receive news in a convenient way: Manimama Legal Channel.


The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation.


Ganna Voievodina

Written by:

Ganna Voievodina

CEO & Co-founder

Yuliia Kravchenko

Reviewed by:

Yuliia Kravchenko

Senior Lawyer, Head of Licensing and Advisory Team

Published:

Last updated:

Tags

Your global legal partner
for crypto & fintech success
Chat
Ready to move forward? Let's get started today

Tell us what you want to create. We will prepare a legal structure that ensures its implementation

Tokenization

Tokenization

Licensing

Incorporation

Other

Talk to our experts

By clicking the "Contact us" button, I confirm that I have read the Privacy Policy and agree to the collection and processing of my personal data in accordance with the General Data Protection Regulation (GDPR).