Online Gaming Licensing in Curaçao
Practical legal advice on Curaçao gaming applications, company structures and ongoing compliance.
ZL Attorneys assists gaming businesses with the Curaçao legal aspects of company formation, licence applications, commercial agreements and ongoing compliance. Start by establishing what your business will do, who controls it and which markets it intends to serve. A Curaçao licence is not a promise of unrestricted access to other countries.
Which licence does your business need?
The Curaçao Gaming Authority (CGA) regulates online gaming under the Landsverordening op de kansspelen (LOK). The law distinguishes operating games from supplying critical gaming services or goods. In industry terminology these are commonly called B2C and B2B licences. The actual activities determine the assessment, rather than the label used in a white-label or software contract. See LOK articles 1.1, 1.2, 1.5 and 5.13.
The LOK took effect on 24 December 2024. Earlier LBH arrangements may remain relevant through transitional provisions; an existing operation needs its own transition assessment. See the CGA legislative overview.
Who can apply?
For a gaming licence, article 2.1 requires an NV or BV incorporated under Curaçao law with its statutory seat in Curaçao. The management requirement is at least one Curaçao-resident natural-person director, or a Curaçao-incorporated corporate director with its statutory seat there that is itself managed by at least one resident natural person. Supplier eligibility is addressed separately in article 5.13.
Incorporating a company does not establish eligibility by itself. The authority assesses ownership, control, integrity and funding. Article 2.2 sets out refusal grounds, while article 5.2 covers information required for online gaming applications. Prepare an ownership chart, director details, a funding explanation and an operational plan that agree with one another. Read the LOK, articles 2.1–2.2, 5.2 and 5.13.
Application stages and timing
For an online gaming operator, article 5.1 describes two assessment phases:
- Integrity and financial assessment: people involved in the operation, beneficial owners, qualifying interest holders, decision-makers, financial position and viability.
- The other licensing requirements: the remaining legal and operational conditions applicable to the application.
The law provides an eight-week decision period in each phase once the required complete information has been received, with a possible extension of up to four weeks in each phase. After a decision to proceed, the phase-two material must be submitted within four weeks. Completeness checks and requests for missing documents have their own rules. These are statutory stages, not a guaranteed launch timetable. Provisional licensing is discretionary and conditional. LOK article 5.1.
Check the current submission channel first. On 7 October 2026, the CGA announced that its old portal would not return to service and that regulatory processing would continue through alternative arrangements. Existing licences and operator obligations were not suspended by that announcement. Follow the CGA platform-transition notice and subsequent official instructions; do not upload sensitive application material through an old or unverified portal link.
What should you budget for?
The CGA's published fee schedule, version 2.0 dated 15 October 2025, lists the following base amounts:
| Category | Application | Annual licence and supervision total |
|---|---|---|
| B2C operator | EUR 4,592 | EUR 47,450 |
| B2B supplier | EUR 4,592 | EUR 24,490 |
Additional charges and initial-period invoicing rules apply. These figures exclude legal, incorporation and operational costs. Confirm the applicable current amounts and invoice before budgeting or paying. CGA fee schedule.
Local presence is more than a registered address
Article 5.12 provides for dedicated business premises in Curaçao and permanent full-time work for locally registered key persons other than the director: at least one during the first four years after the law takes effect, and at least three from the fifth year. The reference point is the law's commencement, not each company's incorporation date.
The article also contains a conditional exception for qualifying startups and a possible temporary ministerial exemption for special circumstances. These require an individual assessment; do not assume that a small business, shared address or nominee director automatically satisfies them. Supplier licences cross-reference specified local-presence provisions in article 5.13. LOK articles 5.12–5.13.
Duties continue after approval
Operators need working procedures for responsible gaming, player complaints, record keeping and reporting. For example:
- Article 5.10 requires several reporting categories, including changes, incidents, player transactions and complaints.
- Under article 5.10(5)–(6), reportable incidents include specified security breaches, system failures, gaming-related fraud and other serious events. The incident report must reach the CGA within 24 hours after the incident. This is not a general deadline for responding to every client question or player complaint.
- Article 5.11 addresses administration and annual accounts; article 5.3 sets a separate player-complaints framework.
Build an escalation procedure, assign responsibilities and confirm the current reporting channel before an incident occurs. LOK articles 5.3 and 5.10–5.11.
How ZL Attorneys can help
Our work includes company formation, governance and management arrangements, licensing preparation, and the negotiation or review of software licences, shareholder agreements, purchase contracts and terms and conditions. We also provide ongoing corporate and contract advice. The authority decides licence applications; banks make their own account-opening decisions.
For an initial discussion, prepare a short description of your activities, ownership and funding, intended markets, existing licences, supplier arrangements and planned Curaçao operations. Our application-readiness checklist helps organize that discussion. Send only a brief outline through the public contact form; arrange a suitable channel for sensitive records.
Common questions
Does a licence let us accept players everywhere?
No. Assess the licence conditions and the laws of each target market separately. A Curaçao licence does not replace authorization that another country requires.
Can we start operating after incorporating or paying an application fee?
Neither incorporation nor an application payment is a licence. Confirm the written authorization and its conditions before commencing the regulated activity.
Is the 24-hour rule a player-complaints deadline?
No. It concerns incident reporting under article 5.10. Player complaints have a separate framework under article 5.3, and not every complaint is a reportable incident. Establish a process that identifies when both obligations may be relevant.
Can you guarantee approval or a particular completion date?
No. We can help prepare and assess the legal file, but approval and requests for further information remain with the CGA. Contact ZL Attorneys to discuss the circumstances of your business.
This page is general information. Application instructions, policy documents and fees may change. Check the linked primary sources and obtain advice for the specific operation before relying on a requirement or deadline.
Our application readiness checklist explains how to organize the ownership, operating and supplier-contract evidence before a review.
