Curaçao

Curaçao is moving from its old offshore licensing framework to a regime in which the regulator licenses operators directly. The Landsverordening op de kansspelen (LOK), the National Ordinance on Games of Chance, came into effect on 24 December 2024. On that date the former Gaming Control Board was designated the Curaçao Gaming Authority (CGA). The CGA now regulates the island's online gaming industry along with land-based casinos and lotteries, and supervises the sector for AML/CFT compliance.

We classify the market as being in licensing transition rather than fully settled. The CGA itself says the old Landsverordening buitengaatse hazardspelen (LBH), the National Ordinance on Offshore Games of Hazard, "remains relevant" through the transitional provisions in Article 15.1 of the LOK. Several core LOK obligations are also still being phased in. Political responsibility for the CGA moved from the Minister of Finance to the Minister of Justice from 19 August 2025.

Regulator and licensing

Under the LOK, the CGA issues gaming licences (kansspelvergunningen) directly. Unless the ordinance says otherwise, a gaming licence is granted for an indefinite period. The applicant entity must be managed by at least one Curaçao resident, or by a Curaçao-incorporated entity that is itself managed by one.

Transitional provisions: Article 15.1 of the LOK covers holders of LBH licences who operate their own licensed activities. They received a provisional licence by operation of law for up to six months, extendable once by up to six months. Pending LBH-era applications are handled under the old rules, and applicants may keep operating until a decision is made. The CGA's Q2 2026 stakeholder bulletin says its supervision department is still collecting 2025 figures and outstanding documents. It needs them to complete its assessment of licences issued for an indefinite period.

B2B layer: The LOK splits suppliers into three groups:

• Critical suppliers: Firms that supply "critical services and goods", meaning those indispensable to determining a game's outcome or whose failure would significantly affect a licensee's compliance, need a supplier licence (leveranciersvergunning). Only a Curaçao-incorporated NV or BV can hold one.
• Supplier register: The CGA keeps a public register of suppliers of critical services and goods. Licensees may not buy those services or goods from unregistered suppliers. According to the Q2 bulletin, the registration function must be operational by 24 December 2026.
• Other gaming-related providers: Providers outside the critical category, excluding professionals such as lawyers, can apply for a CGA certificate valid for up to three years.

The LOK does not use the word "affiliate". How marketing affiliates fit into these categories therefore depends on the CGA's application of the ordinance.

Key rules for affiliates

Article 5.6 of the LOK makes the licensee responsible for its marketing and advertising, including bonus offers. That marketing must not encourage excessive participation, must not be misleading and must not target vulnerable persons. The LOK defines vulnerable persons to include minors and people who are excluded from gambling. More detailed rules on content, target groups, volume, timing and placement can be set by national decree.

The CGA's Compliance and Enforcement Policy for online gaming lists four highest priorities: protecting minors and vulnerable persons; combating illegal gambling; preventing fraud, money laundering and terrorist and proliferation financing; and compliance with advertising and responsible gaming rules. The policy sets out an escalation ladder that runs from a conversation or warning up to revocation of the licence. The CGA also publishes public warnings about unlicensed operators, most recently two notices on 17 July 2026.

Curaçao licences do not grant access to other jurisdictions. At the CGA's May 2026 seminar, participants discussed the growing international trend towards national licensing regimes, as summarised in the Q2 bulletin. They also discussed the need to manage access from restricted jurisdictions effectively.

Recent changes

• 24 December 2024: The LOK entered into force and the GCB became the CGA.
• 19 August 2025: Political responsibility for the CGA moved to the Minister of Justice. The government announced the move on 13 October 2025. The CGA's supervisory board resigned in mid-September 2025.
• 23 January 2026: The CGA announced that the Minister of Justice had granted a general extension of the local substance requirement in Article 5.12. Operators do not need to comply before 1 April 2027.
• 28 May 2026: The CGA held its seminar "Stronger Together: The Future of Gaming in Curaçao".
• Q2 2026 (May to July): The CGA released three documents: wind-down instructions, its compliance and enforcement policy, and a crypto policy guideline for licensees.
• 17 September 2026: The CGA disclosed unauthorised access to its online gaming licensing portal.
  • A follow-up dated 22 September 2026 said a German security researcher had gained access through an account registered in December 2025 under a false identity. Access ran until September 2026.
• October 2026: In a subsequent announcement, the CGA said the portal is offline.
  • The outage does not affect the validity of existing licences or operators' ongoing obligations.
  • Deadlines for documents due through the portal are postponed until it is available again.