For two years, game studios, platform providers and aggregators serving Curaçao-licensed casinos could keep working while the new rules bedded in. That transition ends on 24 December 2026. From that date, the Curaçao Gaming Authority (CGA) expects every “critical” supplier to be licensed or registered under the National Ordinance on Games of Chance (LOK), and licensed operators may not take critical services from a supplier that is not. This guide explains who is caught, the difference between a B2B license and registration, what it costs and what to do before the deadline.
Why 24 December 2026 Matters
The LOK entered into force on 24 December 2024 and gave the market a two-year transitional period for suppliers. In a formal announcement on 24 June 2026, the CGA set out the end-game:
- Locally established suppliers without a license were urged to apply through the CGA Online Gaming Portal by 1 September 2026.
- Registration for local and foreign suppliers was expected to open in October 2026 ‹verify that the registration module is live›.
- Full enforcement starts on 24 December 2026.
The pressure falls on both sides. Under the LOK, a licensee may not obtain critical services or goods from a supplier that is not registered with the CGA. Operators will start asking for proof well before Christmas, and suppliers without it risk losing Curaçao clients.
Who Counts as a “Critical Supplier”?
The CGA’s list is illustrative and may be extended, but it currently covers businesses that provide:
- random number generators and casino games, including game studios;
- live dealer studios;
- poker and other peer-to-peer software;
- lottery systems;
- sportsbook platforms, bet capture and settlement;
- odds and line services;
- game aggregation.
Generic services such as hosting, marketing or accounting are not on the list. If your product sits close to the line, for example a player-account management system or a payment gateway with wallet functions, get a written view before assuming you are out of scope.
B2B License vs Registration: Local and Foreign Suppliers
This is the point most often misunderstood. The LOK distinguishes between where a supplier is established and what it supplies:
- Suppliers established in Curaçao that provide critical goods or services need a CGA supplier (B2B) license and must be registered.
- Foreign suppliers serving CGA licensees need to register with the CGA; they do not need a local license.
In other words, a Malta- or UK-based studio does not have to set up a local company. It does need to appear on the CGA register before 24 December 2026 if it wants to keep supplying these operators. Our team handles both routes through the Curaçao B2B license service.
B2B License versus B2C License
| B2B supplier license | B2C operator license | |
|---|---|---|
| Who needs it | Curaçao-established critical suppliers | Operators offering games of chance to players |
| Application fee | €4,592 | €4,592 |
| Annual fees | €24,490 supervisory fee | €47,450 (€24,490 license fee + €22,960 supervisory fee) |
| Player-facing duties | None directly; technical and integrity standards | Player protection, responsible gambling, complaints handling, AML on players |
| Main evidence | Ownership and key persons, product certification, AML controls | All the left, plus business plan, player-funds and RG framework |
Fees are as published in the CGA’s fee guidance (reported October–November 2025). Some secondary sources quote US dollar equivalents, so always check the current CGA invoice currency ‹verify›. Annual fees are invoiced in advance and fall due by 15 January each year.
For operators, the full B2C route is covered on our Curaçao gambling license page.
What to Prepare Before Applying
- Scope check: map each product to the CGA’s critical-supplier categories and decide whether you need a license (local entity) or registration only (foreign entity).
- Ownership file: UBO and key-person KYC, structure chart, source of funds. The CGA charges extra per additional UBO and per qualifying position holder.
- Product evidence: RNG and game certificates from an accredited testing lab. Our overview of game provider certifications explains what labs test.
- Compliance documents: AML/CFT policy, information security, change management and incident procedures.
- Client list: the CGA licensees you supply, so they can evidence that their critical suppliers are registered.
Curaçao vs Anjouan for B2B Suppliers
Anjouan introduced a similar requirement earlier: since July 2025, B2B providers working with Anjouan-licensed operators must hold a local B2B license or a B2B Recognition Certificate. Many studios serve both markets, so it is efficient to prepare one compliance file and adapt it to each regulator. See our guide to the Anjouan B2B license certificate for that side.
Frequently Asked Questions
Does a foreign game studio need a Curaçao license?
No. Foreign critical suppliers must register with the CGA; only locally established suppliers need a B2B license.
What happens after 24 December 2026 if a supplier is not registered?
CGA licensees may not obtain critical services or goods from unregistered suppliers, so operators will have to stop using them or risk enforcement action against their own license.
How much does the Curaçao B2B license cost?
A one-off €4,592 application fee and an annual supervisory fee of €24,490, plus additional charges per extra UBO or qualifying position holder.
Is a payment provider a critical supplier?
Payment services are not on the CGA’s current illustrative list, but the list can be extended. Providers with gaming-specific functions should seek a case-by-case assessment.
When are annual CGA fees due?
By 15 January each year, after the initial pro-rated invoices in the first license year.
Sources: CGA formal announcement on B2B supplier compliance, 24 June 2026 (reported by AGBrief); CGA fee guidance under the LOK (October–November 2025); National Ordinance on Games of Chance (LOK). Last updated: October 2026.
Disclaimer: This article is general information as of October 2026 and is not legal advice. CGA requirements, lists and fees can change; confirm your position with the CGA and a qualified adviser before relying on it.