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Curaçao has adopted important legislative changes that will significantly affect the regulation of gambling on the island. On 24 December 2024, the LOK (Landsverordening op de Kansspelen) law came into force on the island, which introduces dramatic changes to the approach to the licensing and control of online casinos. The main aim of this reform is to ensure a higher level of transparency and increase the accountability of operators operating in the market. LOK sets out stricter rules to protect players, combat money laundering and improve security standards.

So what should we expect from these changes and what should operators prepare for? How will the new law affect the online gambling market? We’ll tell you more in this article.

The main points of the law

The central innovation is the creation of a new regulatory body, the Curaçao Gaming Authority (CGA), which replaces the former Gaming Control Board (GCB). This body is given the power to issue licences directly to operators, carry out inspections, monitor licensees and ensure compliance with international standards. Licences are only issued to companies registered in Curaçao with a transparent ownership structure. The CGA can refuse a licence if the applicant fails to provide full information about their financial resources or ultimate owners, or if they are found to be involved in criminal schemes.

Special attention is paid to player protection and responsible gaming. The law introduces clear mechanisms to identify vulnerable persons such as minors, people with gambling addictions or financially unstable individuals. Operators are required to provide players with the ability to set personal spending limits or opt out of games altogether. All players must also be given access to information on the risks of gaming addiction.

Requirements for UBOs (ultimate beneficial owners) and key participants

In order to obtain a Curaçao licence, the ultimate beneficial owners (UBOs) and key participants of a company must meet several mandatory requirements. Firstly, they must not have a criminal record within the last ten years, which confirms their legal integrity. Secondly, they must provide evidence of the legal and verified origin of their funds and assets, which ensures financial transparency and legitimacy of their activities.

In addition, all licence fees must be paid on time, and tax and other official obligations must be met in a timely manner, without delay. It is also important that the company has no unresolved issues related to gaming operations. The UBO and the company must also demonstrate the financial ability to pay winnings to players in a timely manner.

Company Requirements

First and foremost, the company must implement responsible gaming procedures that promote the safe and responsible use of gambling. An alternative dispute resolution mechanism must be established to resolve potential conflicts with players. Companies are also required to register with the goAML system and organise processes to report suspicious financial transactions, which is in line with international anti-money laundering standards.

Operators must set up a guarantee fund to ensure that winnings can be paid to players at any time. An important requirement is the storage of player data in a certified data centre of the fourth level of reliability, located in Curacao, which ensures a high level of information security. In addition, each casino must have a physical presence on the island – a registered office with open utility bills, which emphasises its real attachment to the jurisdiction of Curaçao.

User service policies and procedures

Firstly, a clear description of the games should be provided, as well as deposit and withdrawal procedures and payment methods. Software testing is also important, including a detailed description of testing and quality control processes.

With regard to the processing of player data, strict procedures should be in place to protect and process players’ personal data.

Procedures should also be put in place to protect vulnerable individuals, including minors, to prevent their access to gambling. In the event of system failures, provision should be made for the restoration of the operator’s organisational structure, including a schematic description and procedures for prompt recovery.

In addition, as previously stated, it is important to develop and support the implementation of responsible gambling principles, ensuring adequate support for players in this context. It is also necessary to provide up-to-date Terms and Conditions for players, as well as to establish procedures for handling complaints and resolving conflicts to ensure effective and fair dispute resolution.

Employment Requirements

In the first 4 years, the company is required to have a minimum of one full-time local employee (FTE), excluding the Managing Director. From the fifth year onwards, the requirements increase and the company must have a minimum of three full-time local employees.

Exemptions from labour requirements

If the Gross Game Result (GGR) is less than €11 million per year for the first 4 years, the company is exempt from the requirement to employ one full-time employee. This exemption is only valid for the first 4 years. Startups that have been operating for less than one year are also exempt from the requirement to employ one full-time employee, provided that the key persons or ultimate beneficial owners (UBOs) have not been involved in the organisation of online games in the last 2 years.

Reporting requirements

The company is required to file quarterly GGR reports with the CGA (Curaçao Gaming Commission). It is also required to submit semi-annual reports including information on incidents, changes and player transactions. In case of significant incidents such as data breaches, software impact, fraud or other major incidents, a report must be filed within 48 hours.

Fees

For B2C

Fee type Fee amount

Registration fee €4,592

Fee per Ultimate Beneficial Owner (UBO) €150 per UBO

Annual licence fee €22,960

Domain fee €250 per year per domain

Annual government fee €24,960

For B2B

Type of fee Amount of fee

Registration fee €4,592

Fee for each ultimate beneficial owner (UBO) €150 per UBO

Annual certificate fee €24,490

If you want to organise gambling activities in Curaçao, be prepared for start-up costs of €52,912 for B2C operators or €29,232 for B2B companies.

Conclusion

The new gambling regulation in Curaçao introduced by the LOK law has replaced the relatively new regulator Gaming Control Board (GCB) with the new regulator Curaçao Gaming Authority (CGA), which directly oversees operators.

Key changes:

1. Tighter licensing requirements.

Licences will only be issued to companies with a transparent ownership structure registered in Curaçao. Enhanced checks on criminal records and the origin of funds of ultimate beneficiaries.

2. Strengthened player protection.

Strict measures have been introduced to protect vulnerable individuals, including minors and players with addictions, as well as an obligation for operators to provide tools to control costs.

3. Transparency and financial sustainability.

Operators are required to establish guarantee funds, register with the anti-money laundering system (goAML) and ensure that winnings can be paid out at any time.

4. Local presence.

Companies are required to have an office in Curaçao, store player data in certified data centres and increase the number of local employees over time.

5. New reporting requirements.

Mandatory quarterly and half-yearly reports on operators’ activities have been introduced, as well as the obligation to report serious incidents to the regulator within 48 hours.

6. Changes to the fee structure.

Fixed annual fees and taxes are set, but there is no gaming tax.

Compared to the old legislation, the focus has shifted from a simpler licensing process to strict controls, financial transparency and player protection, reflecting the trend towards a more regulated industry on the island.

We strongly encourage clients to review their operations to ensure compliance with the applicable legislation, and should the new requirements be too costly for business, we are prepared to offer a switch to a less demanding licence such as Anjouan.