Curaçao B2C online gaming licence under the LOK

Under the National Ordinance on Games of Chance (LOK), the Curaçao Gaming Authority licenses online gaming operators directly. The old master licence and sub-licence model is gone, and every licence appears on a public register. Applicants must be a Curaçao company with at least one Curaçao-resident director, and the further local staff and office rules apply from 1 April 2027.

In transitionLOK in force since 24 Dec 2024; local substance under Art. 5.12 deferred to 1 April 2027

Facts under review · last checked 2026-10-08 · confirm figures with the regulator before relying on them

Regulator · Curaçao Gaming Authority (CGA) ↗

Key facts

Legal framework in force: Landsverordening op de kansspelen (LOK) in force since 24 December 2024LOK-Art-15.10as of 2026-10-08Source ↗
Who can hold the licence: A Curaçao NV or BV with its registered seat in Curaçao, managed by at least one director resident in CuraçaoLOK-Art-2.1as of 2026-10-08Source ↗
Application handling fee (statutory): EUR 4,592, plus EUR 150 per ultimate beneficial owner and EUR 150 per qualifying holderLOK-Art-5.18(1)as of 2026-10-08Source ↗
Local substance (Art. 5.12): At least one full-time Curaçao-registered key person besides the director (three from year five) and dedicated office premises in Curaçao; not required before 1 April 2027LOK-Art-5.12as of 2026-10-08Source ↗
Public register: The CGA keeps a free, public register of all gaming licences, supplier licences and certificatesLOK-Art-3.1as of 2026-10-08Source ↗

Realistic timeline

Who does what, and how long each phase usually takes once work starts. The regulator’s share is outside anyone’s control.

HartsizScoping, structure and ownership review2–4 weeks
YouCompany formation, local director, policies and application pack4–10 weeksHartsiz drafts the pack; the client supplies people, documents and decisions
RegulatorCGA two-phase review (integrity and finances, then other requirements)12–30 weeksOutside our control; depends on CGA workload and the quality of answers

Estimated end to end: 4–10 months. Not a guarantee.

What the regulator expects to see

Curaçao NV or BV with registered seat in Curaçao (LOK Art. 2.1(1))
At least one Curaçao-resident director (LOK Art. 2.1(4))
From 1 April 2027, at least one full-time key person registered in Curaçao who is not the director, and a dedicated local office (LOK Art. 5.12)
AML/CFT programme supervised by the CGA

Questions we get

Can we still operate under a master licence holder's sub-licence?

No. The LOK replaced the master and sub-licence model. Operators now need their own licence from the Curaçao Gaming Authority, and licences are shown on the CGA public register.

When do the local staff and office rules start to bite?

The CGA announced on 23 January 2026 that operators will not have to meet the Article 5.12 substance requirement before 1 April 2027. The resident-director rule in Article 2.1 is separate and is not covered by that deferral.

What are the annual licence fees?

The LOK sets annual levies in euro, but the CGA's later invoicing guidance has been reported in US dollars. We confirm the current figure with the CGA for each client rather than quote a number that may be out of date.

Changes affecting this route

2027-04-01Upcoming
Curaçao · iGaming · high impact
Curaçao local substance requirement takes effect
On 23 January 2026 the Curaçao Gaming Authority announced that the Minister of Justice had granted a general extension of the local substance requirement in Article 5.12 of the LOK, so operators do not need to meet it before 1 April 2027. Licensees should use the time to plan local management, staff and premises.
Source ↗