Detailed overview
Curaçao at a glance
Curaçao is an autonomous constituent country of the Kingdom of the Netherlands (population approximately 158,000) and one of the world's most important iGaming hubs by licence count. Until 2024, gambling regulation operated under the National Ordinance on Offshore Games of Hazard (NOOGH) of 1991 (with first licences issued in 1996 and the Gaming Control Board established in 1999). Under NOOGH, four "master license" holders — Antillephone (license 8048/JAZ), Curaçao Interactive Licensing (CIL, license 5536/JAZ), Cyberluck Curaçao / Curaçao-eGaming, and Gaming Curaçao (license 365/JAZ) — could issue sublicenses to hundreds of operators with minimal regulatory oversight.
The reform was driven by:
- Netherlands pressure: Curaçao agreed to gambling-sector reform as a condition of the Kingdom of the Netherlands' COVID-19 pandemic relief package.
- FATF risk: growing threat of placement on the FATF list of jurisdictions under increased monitoring.
- Budget deficit: most licensing fees flowed to the four master license holders rather than the state treasury.
- Reputational damage: international markets and payment providers increasingly rejected Curaçao sublicensees.
Reform timeline:
- 17 July 2023: Ministry of Finance formally announced new licensing regime.
- 15 November 2023: applications opened under direct GCB licensing (still under NOOGH).
- 30 April 2024: deadline for final sublicense applications.
- 17 December 2024: parliament passed the LOK (13–6 vote).
- 24 December 2024: LOK entered into force.
- June 2025: deadline for existing NOOGH operators to transition (with 6-month extension option).
- 15 October 2025: orange (transitional) seals permanently expired.
The CGA had granted over 220 direct licences by the end of 2024 and was processing approximately 600 more in Q1 2025. By early 2026, the LOK regime has 330+ active licences and operates a public verification register with colour-coded digital seals (green for B2C, blue for B2B, orange for transitional — now expired).
The reform brought Curaçao into closer cooperation with the Netherlands Gambling Authority. The CGA has separately introduced an updated anti-money laundering policy, revised MLRO (Money Laundering Reporting Officer) requirements, and is consulting on responsible-gambling policy. KYC (Know Your Customer), ADR (Alternative Dispute Resolution), Training and Qualification, Local Hardware, Records and Reporting, and Technical Standards rules are being progressively rolled out.
Curaçao implemented the 15% global minimum corporate tax (Pillar Two) from 1 January 2025 — applicable only to multinational groups with consolidated annual revenue of at least EUR 750 million. Smaller operators continue to pay the 2% E-Zone tax rate, preserving Curaçao's tax advantage for the global mid-market.
Last verified: May 2026. Reference rate: EUR 1 = USD 1.17. ANG (Antillean Guilder) is pegged to USD at 1.79.
The LOK reform fundamentally repositioned Curaçao from a self-regulated grey-market jurisdiction to a directly licensed regulator. Operators expecting the old light-touch framework should look elsewhere.
Is there a crypto licence in Curaçao?
No. Curaçao does not have a dedicated VASP or crypto-asset licensing framework. Crypto operators in Curaçao typically obtain a Curaçao corporate structure and operate under foreign or international standards rather than a domestic crypto licence.
There is no equivalent of MiCA, MiCAR or a Caribbean-region crypto framework in Curaçao. Crypto-related businesses that operate from Curaçao typically structure as Curaçao corporates (NV / BV) for tax purposes (Curaçao's 2% E-Zone rate continues to apply to qualifying mid-market operators), with the underlying activity unregulated at the local level. For crypto-payments and crypto-on-ramp functionality used by Curaçao gambling licensees, the CGA expects strict disclosures of virtual asset wallets and on-chain transaction monitoring as part of the LOK application — anonymous crypto platforms are rejected at Phase 1 of the application process.
For comprehensive crypto-asset regulation in the wider Dutch-Caribbean / Caribbean region, operators should look to other jurisdictions (e.g., the Cayman Islands' VASP Law, the British Virgin Islands' VASP Act, or Bermuda's Digital Asset Business Act).
Is there a gambling licence in Curaçao?
Yes — and it is the focus of the jurisdiction. The CGA (formerly GCB) issues direct B2C, B2B and Nonprofit licences under the LOK in force from 24 December 2024.
The legal framework:
- National Ordinance on Games of Chance (LOK): of 17 December 2024, in force from 24 December 2024. Published in PB 2024, no. 157.
- National Ordinance on Offshore Games of Hazard (NOOGH): of 1993 — repealed, but Article 15.1 of the LOK preserves NOOGH for transitional purposes for legacy licensees.
- Curaçao Gaming Authority (CGA): established by the LOK as the independent regulator (renaming the GCB and giving it statutory independence). The CGA acts as the sole licensing authority — no intermediaries, no sub-licensing.
Key LOK reform elements:
- Non-transferable licences: each licence is tied to the licensee; other parties cannot operate under the same licence.
- Stricter local presence: licensees must employ at least 1 key staff member in Curaçao within 4 years and 3 within 5 years (the local managing director is excluded from this count). CGA deferred enforcement of staffing rules to April 2027.
- Financial transparency: enhanced anti-money laundering and counter-terrorist financing requirements aligned with FATF standards.
- Phase-1 corporate integrity assessment: Ultimate Beneficial Owners, Qualified Interest holders, decision-makers must be fully verified.
- Phase-2 operational assessment: business plan, internal policies, technical infrastructure, complete documentation.
- Public register: 330+ active licences published with colour-coded seals (green B2C, blue B2B, orange transitional — orange permanently expired 15 October 2025).
- AML/KYC mandatory: all operators must implement FATF-aligned AML and KYC frameworks.
- ADR mandatory: Alternative Dispute Resolution mechanism for player complaints.
- Responsible gambling: enforced through CGA-issued policy, with stricter protocols for vulnerable players.
- Indefinite licence validity: subject to ongoing compliance; no fixed renewal date, but CGA retains revocation/suspension powers.
- Sanctioned-jurisdiction exclusion: individuals from sanctioned jurisdictions (Russia, Iran) cannot be ownership holders.
- At least one Curaçao-based managing director: required.
B2C Gaming Licence (CGA)
Best for online casino operators, sportsbooks, lottery, bingo and peer-to-peer poker platforms serving players directly.
What it is: Direct CGA licence under the LOK authorising B2C gaming operations.
Who it suits: Operators serving end-users directly with online casino, sports betting, lottery, bingo, or peer-to-peer poker. Includes platforms that control player funds or player data, or that meaningfully facilitate B2C operations.
Covers: Online casino games (slots, table games, RNG products); sports betting (online and event-based); lottery products; bingo; peer-to-peer poker. Emerging products such as prediction markets and event contracts operate under separate regulatory frameworks (not covered by the LOK B2C licence). Up to 40 domains under the previous NOOGH framework; under LOK, domain limits are subject to per-domain fees of EUR 250 per additional main domain.
Operational requirement: Company incorporated in Curaçao (NV or BV). At least one locally-based managing director. Registered office in Curaçao. Local key person requirements: 1 by year 4, 3 by year 5 (excluding the managing director); enforcement deferred to April 2027. Phase 1 corporate integrity assessment (UBOs, Qualified Interest holders, decision-makers verified). Phase 2 operational assessment with business plan, AML/KYC framework, ADR mechanism, responsible gambling policy, technical standards. Local data storage infrastructure. AML/CFT framework aligned with FATF Recommendations. MLRO appointment (updated CGA requirements). Sanctions screening; sanctioned-jurisdiction individuals excluded from ownership.
Headline figures
- Application fee: EUR 4,592 (about USD 5,373) — non-refundable
- Annual fee total: EUR 47,450 (about USD 55,517)
- National Treasury Licence Fee: EUR 24,490 (about USD 28,653)
- CGA Supervisory Fee: EUR 22,960 (about USD 26,863)
- Due diligence fee (per person): EUR 125–250 depending on role
- Additional main domain fee: EUR 250 (about USD 293) per annum per domain
- Certificate application fee: EUR 383 (about USD 448)
- UBO / qualified-interest-holder update fee: EUR 128 (about USD 150)
- Permission to add new games or B2B services: EUR 13 per item (about USD 15)
- All-in first-year budget (regulatory + corporate setup + compliance + advisory): EUR 70,000–110,000 (about USD 82,000–129,000)
- Year 2+ ongoing cost: EUR 55,000–85,000 (about USD 64,000–99,000)
- Tax (E-Zone, mid-market operators): 2%
- Tax (multinational groups >EUR 750M consolidated revenue): 15% (Pillar Two)
- Annual fee payment deadline: 15 January each year; initial payment within 14 days of CGA notice
- Pro-rata first-year billing: two installments (6 months + 6 months) for LOK enactment year
- Licence term: indefinite, subject to ongoing compliance
B2B Supplier Licence (CGA)
Best for software developers, platform providers, payment processors and other critical-service suppliers to B2C operators.
What it is: Direct CGA licence under the LOK for B2B service providers supplying critical services to B2C operators.
Who it suits: Game studios, RNG suppliers, platform-as-a-service providers, payment processors, technical-service vendors and other critical-service providers to licensed B2C operators.
Covers: Supply of gambling technology and services that materially affect the B2C operator's regulated activity.
Operational requirement: Same general framework as B2C — Curaçao incorporation, local managing director, Phase 1 and Phase 2 assessment, AML/KYC framework, fit-and-proper checks on UBOs and key persons. No domain requirements; no monthly fees.
Headline figures
- Application fee: EUR 4,592 (about USD 5,373)
- Annual Supervisory Fee: EUR 24,490 (about USD 28,653) — sole annual fee for B2B
- Due diligence fee (per person): EUR 125–250 depending on role
- No monthly fee, no domain fee
- Annual fee payment deadline: 15 January
B2B Certificate (CGA)
Best for service providers supplying non-critical goods or services to operators.
What it is: A separate CGA certificate (not a full licence) for non-critical service providers.
Who it suits: Vendors providing non-critical goods or services to operators (e.g., consulting, marketing services not directly affecting gameplay or player funds).
Covers: Supply of non-critical goods or services.
Headline figures
- Validity: 3 years
- Annual renewal: none
- Annual fee: none
Nonprofit Game Licence (CGA)
Best for charitable gaming initiatives.
What it is: CGA licence for nonprofit and charitable gaming activities under the LOK.
Who it suits: Charities, fundraising organisations and other nonprofit operators.
Covers: Charitable gaming activities under the LOK framework.
Provisional Licence and Digital Seal System
Transitional and ongoing licence verification framework.
Provisional Licence: During Phase 2 of the assessment, the CGA may grant a provisional licence valid for up to 6 months, extendable for another 6 months (except where prohibited by Article 2.2 of the LOK). Operators with provisional licences operate while final approval is pending.
Digital Seal System: Each active licensee receives a colour-coded seal that links to the CGA's public verification database:
- Green seal: Active B2C licence
- Blue seal: Active B2B licence
- Orange seal: Provisional / transitional licence — expired permanently on 15 October 2025. Platforms without a green or blue seal after this date lose operating rights.
Each seal is tied to approved domains and corresponds to the operator's Certificate of Operation.
What about NOOGH legacy licences?
NOOGH was repealed by the LOK. Transitional provisions in Article 15.1 of the LOK preserve narrow legacy effects.
The four master license holders (Antillephone, CIL, Cyberluck, Gaming Curaçao) had their licences expire during 2024:
- Cyberluck Curaçao (Curaçao-eGaming): expired 1 October 2024
- Gaming Curaçao: expired 18 August 2024
- Antillephone: effective until 28 November 2024
- Curaçao Interactive Licensing (CIL): effective until 31 January 2025
Sublicensees had until 30 April 2024 to apply for new direct GCB licences. NOOGH licences issued in 2024 were automatically converted into provisional LOK licences. Operators with provisional (orange-seal) status were required to complete LOK conversion by mid-2025. Operators that did not complete conversion lost their operating rights. The orange seal permanently expired on 15 October 2025.
Curaçao corporate, tax and substance framework
E-Zone tax rate: 2% on profits for qualifying export-oriented businesses. Continues to apply to mid-market gambling operators below the EUR 750M Pillar Two threshold.
Pillar Two (Global Minimum Tax): 15% from 1 January 2025 for multinational groups with consolidated annual revenue of at least EUR 750 million.
Substance requirements:
- Curaçao-incorporated entity (NV or BV)
- Registered office in Curaçao
- Locally-based managing director (real, not nominee)
- Local key person hires: 1 by year 4, 3 by year 5 (excluding managing director); enforcement deferred to April 2027
Compliance reports: Player Transaction Report (amounts credited/debited per account; payment instruments used); Complaints Report; AML reports (quarterly).
Costs and timelines at a glance
- LOK enactment: 24 December 2024
- CGA active licences (late 2024): 220+ direct GCB licences
- CGA active licences (early 2026): 330+
- B2C application fee: EUR 4,592 (about USD 5,373)
- B2C annual fee total: EUR 47,450 (about USD 55,517)
- B2C National Treasury Fee: EUR 24,490 (about USD 28,653)
- B2C CGA Supervisory Fee: EUR 22,960 (about USD 26,863)
- B2B application fee: EUR 4,592 (about USD 5,373)
- B2B annual fee: EUR 24,490 (about USD 28,653) — supervisory only
- First-year all-in B2C budget: EUR 70,000–110,000 (about USD 82,000–129,000)
- Year 2+ ongoing B2C cost: EUR 55,000–85,000 (about USD 64,000–99,000)
- Provisional licence: up to 6 months, extendable for another 6 months
- Phase assessment timeline: ~8 weeks per phase (Phase 1 + Phase 2)
- Licence term: indefinite, subject to compliance
- Tax rate (E-Zone, mid-market): 2%
- Tax rate (Pillar Two, ≥EUR 750M groups): 15%
- Orange (transitional) seal: permanently expired 15 October 2025
- Local managing director: mandatory
- Key person staffing: 1 by year 4, 3 by year 5; enforcement to April 2027
- Sanctioned-jurisdiction owners (Russia, Iran): excluded
- No crypto-licensing regime in Curaçao
Who Curaçao suits and who it does not
Suitable for
- Online casino operators ready to fund the EUR 4,592 application fee, EUR 47,450 annual fee, and EUR 70,000–110,000 first-year all-in budget under the new LOK framework
- Sports-betting operators with multi-vertical product offerings (casino + sportsbook + bingo + lottery) seeking a single comprehensive B2C licence
- B2B suppliers (game studios, platform providers, payment processors) wanting Curaçao authorisation for international supply
- Operators willing to maintain genuine Curaçao substance — local entity, managing director, office, and key staff hires by 2027
- Mid-market operators (below the EUR 750M Pillar Two threshold) benefiting from the 2% E-Zone tax rate
- Operators serving non-EU/non-UK / non-MGA markets where Curaçao credentials are accepted by payment providers
- Operators willing to operate to FATF-aligned AML/CFT, KYC, ADR, and responsible gambling standards
- Charitable gaming initiatives under the Nonprofit Game Licence
- Operators willing to provide on-chain transaction monitoring and disclose virtual asset wallets if accepting crypto payments
Not suitable for
- Operators looking for the old NOOGH master-license framework — fully repealed since 24 December 2024
- Sublicensees that did not transition to direct CGA licences by mid-2025 — orange (transitional) seals permanently expired 15 October 2025; operating without a green or blue seal is unlicensed gambling
- Crypto-asset service providers seeking a domestic VASP framework — none exists in Curaçao; alternative Caribbean jurisdictions (BVI, Cayman, Bermuda) offer dedicated regimes
- Anonymous crypto-payment-only platforms — CGA rejects these at Phase 1 application
- Operators from or beneficially owned by individuals in sanctioned jurisdictions (Russia, Iran, etc.)
- Operators unable to fund the EUR 70,000–110,000 first-year all-in budget
- Operators expecting indefinite light-touch regulation — LOK introduces real AML/KYC, real ADR, real responsible gambling and real local substance requirements
- Large multinational groups (≥EUR 750M consolidated revenue) seeking the 2% E-Zone tax rate — Pillar Two minimum tax applies at 15%
- Operators expecting to combine B2C and B2B activity under a single licence — the LOK B2C2B hybrid model has been abolished
- Operators planning offerings of prediction markets or event contracts — these fall outside the LOK B2C licence and require separate regulatory analysis
- Operators wanting to defer the local-staffing requirements — enforcement deferred to April 2027 but cannot be avoided indefinitely