Curacao - a new model of eGaming licenses

1) Quick reference: what has changed

Since the end of 2024, Curacao has switched from a "master + sub-license" model to a centralized licensing system for LOK (National Ordinance on Games of Chance): now there are B2C licenses for operators and B2B licenses for critical service/software providers; supervision is carried out by the Curaçao Gaming Authority (CGA) (formerly GCB). The goal is to strengthen the compliance and international reputation of the regime.

2) Types of licenses and perimeter

B2C (Operator License): online casino/betting and other verticals for working with players (account/wallet/content/payment in the perimeter).
B2B (Supplier License): delivery of "critical" services and goods for gambling (gaming software, sports book modules, RGS, etc.).

3) Migration from "clogs" and timeline

The historic master/sub-license scheme is discontinued; the transition to LOK was confirmed by parliament (December 2024).
The regulator gradually transferred holders of sub-licenses in 2024-2025; registration and renewal "windows" were in effect, Digital Seal (digital seal of conformity) was introduced.
The rollback/suspension of new applications was periodically announced (closing the portal for the launch of LOK and the subsequent re-open waves for B2C/B2B in 2025). Check the current status of the window during planning.

4) Duties and Benchmarks by Value (LOK, 2025)

• Starting feed (application) for B2C: about €4,592 + €150 for each UBO.
• Annual fees: about €22,960 for all licensees; for B2C, an additional €24,490 to the treasury (national levy/supervision). The result depends on the profile and the basket of services.

5) Requirements for presence and equipment (substance/infra)

Actual legal presence in Curaçao (local company/office, management functions).
Enhanced fit-and-proper (UBO/management), AML/KYC/SoF/SoW contours, RG policy, journaling, incident management.
Infrastructure: CGA policy assumes a local tech circuit; for a number of applicants - placing part of the production infrastructure on the island (server/cluster) and compliance with hosting/monitoring requirements. Parts are locked into license terms.

6) Technical and user standards

RNG/game certification at recognized test houses; Version/release management audit log.
Security: access control, log storage, timeouts/retrays, DR/BCP plans.
In the user part: transparent T&C, correct RTP/probability representations, Digital Seal branding in accordance with CGA policy.

7) Submission: Workflow (B2C/B2B)

Step 1. Account on portal. gamingcontrolcuracao. org → type selection (B2C/B2B).
Step 2. Document package: corporate structure/UBO, financial plan, AML/RG/KYC policies, architecture (PAM/RGS/RNG/payments), contracts with providers, market map.
Step 3. Payment application-fee; appointment of contact persons, approval of substance/infra.
Step 4. Interaction with CGA (RFI/clarifications), if necessary - preliminary hosting/security checks.
Step 5. Solution, release of license terms, publication of Digital Seal and go-live.

8) Reporting and Supervision

Digital Seal: use according to CGA manual (display/validation requirements).
Regular reporting on activities/finance, incident notifications and material changes (UBO/management/infrastructure).
Inspection plans/desk-review, thematic AML/RG inspections are possible as part of the enhanced LOK supervision.

9) Operator Check List (B2C)

Law and governance

• Local company and substance plan (office, management, on-island function bench).
• RG/AML/KYC/SoF/SoW policies, complaint procedure/ADR, marketing standards.

Machinery and product

• Architecture: PAM, RGS/RNG, payment gateways, anti-fraud, rate/speed limits.
• Game certification, p95-latency monitoring, SLA/SLO, glitch/anomaly alerts.

Finance & Reporting

• Calculation of LOK charges, preparation of Regulatory Returns/operative notifications.
• Setting up Digital Seal, storing confirmation logs.

10) Vendor Check List (B2B)

• List of "critical services/goods" (games, engines, sports book software, hosting, risk management).
• Contractual model with B2C, responsibility sharing, export of logs/reports for customers and CGA.
• Compliance with portal requirements (onboarding, reporting, card version updates).

11) Frequent Questions (FAQs)

Q: Can I continue to work on a "sub-license"?
A: No - the master/sub system is de facto collapsed; Requires migration to LOK (B2C/B2B) within CGA migration windows.

Q: What are the basic payments at the start now?
A: Plan application ≈ €4,592 + €150/UBO, then annual fees (≈ €22,960 all + ≈ €24,490 for B2C). Check current CGA tables.

Q: Do I need local servers?
A: CGA promotes real tech substance; for a number of applicants - the requirement to keep part of the production circuit/server in Curacao is fixed in conditions. Check your license and portal.

Q: Who is the regulator now - GCB or CGA?
A: After joining LOK, GCB acts as the Curaçao Gaming Authority (CGA) and maintains a portal/oversight under that name.

12) Short total

The Curaçao reform secured a two-circuit system: B2C (operators) and B2B (critical suppliers) under a single CGA. Submission - through the portal; substance, AML/RG, technical and reporting requirements have been strengthened, Digital Seal has been introduced. For migration from "clogs" and new applications, take into account the windows and current LOK fees; Prepare the policy package, architecture, contracts, and local presence plan before you start. This raises the entry threshold, but gives predictability and a "white" reputation in 2025-2026.