Introduction
For most of the past three decades, the Curaçao gambling license was synonymous with accessibility. Four private master license holders — Cyberluck, Antillephone, Gaming Curaçao, and Curaçao Interactive Licensing — issued sublicenses to anyone who could pay the fee. At its peak, roughly 1,200 operators held some form of Curaçao authorization. Compliance was largely self-reported. Oversight was minimal. The jurisdiction was, as industry insiders often noted, the "easy entry" point into regulated online gambling.
That model is now gone. Between September 2023 and October 2025, Curaçao completed the most significant overhaul of its gambling regulation in thirty years. This article documents the reform timeline, the new licensing framework, the political turbulence that accompanied it, and what the changes mean for operators and players in 2026.
Background: The Old System and Its Limits
The pre-reform framework was established under the 1993 Offshore Games Ordinance (NOOGH). It authorized four private entities to act as master license holders, each empowered to issue sublicenses to third-party operators. The system was fast and inexpensive — a sublicense could be obtained in weeks for a few thousand euros — but it lacked centralized oversight, mandatory AML controls, and any meaningful player protection framework.
International regulators and financial institutions increasingly viewed Curaçao-licensed operators with suspicion. Payment processors were reluctant to work with sublicensed operators. European market access was limited. The reputational ceiling of the jurisdiction was, by the early 2020s, clearly visible.
The Reform Process: September 2023 to December 2024
September 2023: The Licensing Window Opens
In September 2023, the Curaçao Gaming Authority (CGA) — at that point still operating as the Gaming Control Board — opened a new licensing window under a transitional framework. Operators were invited to begin applying for direct licenses ahead of the new legislation. The process was designed to allow the regulator to build capacity and assess applicants before the formal legal transition.
The response was larger than anticipated. An influx of applications in the summer of 2024, many of which lacked complete documentation, created processing backlogs that would persist throughout the transition period.
December 2024: The LOK Enters into Force
The Landsverordening op de Kansspelen (LOK — National Ordinance on Games of Chance) was enacted on 17 December 2024 and entered into force on 24 December 2024. It replaced the 1993 NOOGH in its entirety and established the CGA as the sole licensing and supervisory authority for all online gambling operations in or from Curaçao.
The four master license holders ceased to have legal authority to issue new sublicenses. All existing sublicenses were given a transition deadline of 31 January 2025, after which they would no longer be valid. Cyberluck, one of the four master holders, had already been declared bankrupt in October 2024.
Key Changes Under the LOK Framework
The LOK introduced structural changes across every dimension of the licensing regime:
| Dimension | Before LOK | After LOK |
|---|---|---|
| Licensing authority | Four private master holders | CGA (state regulator) |
| License type | Master + sublicense | Direct B2C and B2B licenses |
| Public register | No | Yes — all licenses publicly listed |
| AML requirements | Minimal, self-reported | Mandatory, CGA-supervised |
| UBO disclosure | Not required | Mandatory for all key persons |
| Substance requirements | None | Local office, local staff required |
| Responsible gaming | Optional | Mandatory framework + ADR provider |
| Application process | Fast, minimal due diligence | Two-phase, 8 weeks per phase |
| Annual cost (B2C) | ~EUR 5,000–15,000 (sublicense) | EUR 47,450 (government + supervisory fees) |
| Application fee | Minimal | EUR 4,592 + per-UBO fees |
B2C and B2B License Categories
Under the LOK, Curaçao issues two license types. The B2C license (Gaming Operator License) authorizes direct-to-player operations including online casinos, sports betting, live dealer products, poker, and crypto gambling. The B2B license (Supplier License) covers software developers, platform providers, payment infrastructure, and other critical gaming service suppliers. A single entity cannot hold both license types unless separately authorized by the CGA.
Two-Phase Application Process
Applications are submitted through the CGA's online portal and assessed in two formal phases. Phase one focuses on corporate integrity, UBO background checks, and financial viability — typically four to eight weeks. Phase two assesses technical compliance, responsible gaming systems, AML frameworks, and operational readiness — another four to eight weeks. Operators who pass phase one may receive a provisional six-month license while phase two is completed.
Substance and Governance Requirements
Unlike the sublicense model, the LOK requires operators to maintain a genuine physical presence in Curaçao: a registered office address, at least one locally resident managing director or a Curaçao-registered management entity, and local employees. The local staffing enforcement deadline was subsequently pushed to 1 April 2027, providing operators additional runway to comply.
The Transition Period: January–October 2025
Provisional Licenses and Extensions
Operators who received provisional licenses under the LOK on 24 December 2024 were initially given six months — until 24 June 2025 — to achieve full compliance. On 24 June 2025, the CGA announced a six-month extension for select Green Seal B2C and B2B operators, moving the deadline to 24 December 2025. The extension was conditional on demonstrated progress against compliance checklists.
On 23 December 2025, one day before the second deadline, the CGA confirmed it had not reached final decisions for a group of operators, citing the volume of information under review. Those operators were told they could continue operating while reviews were completed, with no timeline provided.
The Orange Seal System Ends
Operators who had been operating under the transitional "Orange Seal" framework — a certificate of operation issued during the pre-LOK window — were given until 15 October 2025 to obtain direct CGA licenses. The CGA announced in September 2025 that Orange Seal digital seals would no longer be valid after mid-October. This marked the formal end of the sublicensing era.
Political Turbulence
The reform did not proceed without controversy. In November 2024, forensic investigator Luigi Faneyte filed a criminal complaint accusing Finance Minister Javier Silvania of fraud and money laundering related to the issuance of provisional licenses during the LOK transition. In September 2025, leaked audio recordings surfaced of exchanges between Silvania and the head of the Tax Receiver's Office. Silvania resigned on 15 October 2025, and the CGA was transferred from the Ministry of Finance to the Ministry of Justice.
In March 2025, the CGA's entire supervisory board — Shelwyn Salesia, Robert Reijnaert, and Ildefons Simon — resigned. The CGA described the departure as a routine reshuffle following a government transition. In early 2026, the Finance Minister clarified that no formal investigation was underway, and the departing board members retracted their integrity allegations, acknowledging they had relied on unverified information.
The Outcome: From 1,200 Operators to Roughly 300
The scale of the market contraction is significant. Before the LOK, approximately 1,200 operators held some form of Curaçao authorization. As of early 2026, roughly 300 operators hold valid CGA licenses. The reduction reflects several factors: the higher cost of the new license, the substance requirements, the two-phase compliance process, and the uncertainty created by the political turbulence.
Some operators — including BC.Game, which voluntarily withdrew its Curaçao license in December 2024 — migrated to alternative jurisdictions such as Anjouan or Nevis. Others closed operations entirely. The operators who remained are, in the CGA's framing, the foundation of a more credible and internationally recognized licensing regime.
What the Reform Means in Practice
For Operators
The new framework imposes materially higher compliance costs and operational requirements. The annual cost of a B2C license is approximately EUR 47,450–52,000 when supervisory and treasury fees are combined. Physical substance in Curaçao is mandatory. AML, KYC, and responsible gaming frameworks must be formally documented and maintained. Changes in ownership or control require prior CGA approval.
For operators who can meet these requirements, the CGA license is gaining recognition from payment processors, banking partners, and software providers who previously avoided the jurisdiction. The public license register provides a verifiable record of licensed operators, which supports commercial relationships that were difficult to establish under the sublicense model.
For Players
The reform improves player protection in several measurable ways. Licensed operators are required to appoint a CGA-certified Alternative Dispute Resolution provider, maintain a formal complaints process, and comply with responsible gaming obligations including self-exclusion mechanisms. The public license register allows players to verify operator status directly against the official CGA database.
For the Jurisdiction
The reform was intended to replace private sublicensing with direct public supervision. Whether the transition achieved its stated objectives cannot be inferred from this historical article alone; that assessment requires current primary-source evidence about the register, supervision and enforcement.
Historical Status Snapshot (May 2026)
The CGA continues to process license applications under the LOK framework. New supervisory board members are being appointed following the September 2025 resignations. The local staffing enforcement deadline has been extended to 1 April 2027. The CGA has reiterated its commitment to implementing the LOK alongside the Ministry of Justice.
The article's May 2026 snapshot contained 654 records attributed to the CGA source used at that time. That historical count has not completed the current claim-level review and must not be presented as today's register total or current transition status.
Sources
This article draws on the following publicly available sources:
- Curaçao Gaming Authority official website: cga.cw
- LOK (Landsverordening op de Kansspelen), enacted 17 December 2024, in force 24 December 2024
- iGaming Business: "Curaçao confirms six-month extension for provisional licences" (24 June 2025)
- Fast Offshore: "Curacao's Regulatory Crisis: What It Means for Your License" (9 March 2026)
- Gambling911: "One Year After Curacao's New Gaming Law: Has the Reform Really Worked?" (13 November 2025)
- GFLO Consultancy: "Curacao Gambling License: Requirements, Costs & New Rules (2026 Guide)" (9 January 2026)
- Advennt: Curaçao jurisdiction overview (accessed May 2026)
Data on operator counts is sourced from the CGA public register and industry reporting. All figures are subject to change as the licensing transition continues.