Online Gaming Licence (B2C operating licence) under the LOK (Curaçao)
The Online Gaming Licence (B2C operating licence) under the LOK is issued by Curaçao Gaming Authority (CGA) under National Ordinance on Games of Chance (Landsverordening op de kansspelen), P.B. 2024 no. 157. The official register lists 571 entries tagged 'B2C' in the CGA Online Gaming License Registry (of 665 total register entries; includes historic expired/revoked ones) current holders. Ownership changes need the regulator's approval before completion.
At a glance
| Official name | Online Gaming Licence (B2C operating licence) under the LOK1 |
|---|---|
| Also known as | Curaçao B2C gaming licence · Curaçao online gaming licence · Curaçao iGaming licence · LOK B2C licence · Curacao online casino licence |
| Market names to check | Curacao Green Seal licence: Sales brand, not a statutory name; the licence is the B2C operating licence issued under the LOK |
| Issued by | Curaçao Gaming Authority |
| Jurisdiction | Curaçao |
| Licence family | Gaming and betting |
| Legal basis | National Ordinance on Games of Chance (Landsverordening op de kansspelen), P.B. 2024 no. 1572 |
| Passporting | Domestic only |
| Application fee | EUR 4,592 one-time (plus EUR 150 per UBO/qualified interest holder, EUR 2,551 per listed UBO)1 |
| Annual fee | EUR 128 administrative fee per changed or added UBO or qualified interest holder1 |
| Statutory decision time | Two-phase review (integrity/financial stability, then LOK regulatory requirements); each phase decided within 8 weeks, extendable by up to 4 weeks per phase: up to about 24 weeks in total3 |
| Public register | official register4 |
| Current holders | 571 entries tagged 'B2C' in the CGA Online Gaming License Registry (of 665 total register entries; includes historic expired/revoked ones)4 |
What it lets you do, and where
What does a Curaçao B2C gaming licence let you do, and where can you serve clients?
A Curaçao licence may be granted for organising remote games of chance, with a two-phase review. Licence conditions explicitly prohibit offering games to residents of Curaçao. National gambling regulators elsewhere enforce their own domestic licensing and issue site-blocking orders against unlicensed cross-border operators, so serving those markets requires their local licences.2812
Activities it covers
| Online gaming and betting for players (B2C) | Offering casino games, sports betting, poker or lotteries directly to players over the internet. |
|---|
Where it is valid
Do you need it, and is Curaçao the right choice?
What is a Curaçao B2C online gaming licence and do you actually need one?
A Curaçao B2C online gaming licence is an official authorisation issued by the Curaçao Gaming Authority (CGA) under the National Ordinance on Games of Chance (LOK, P.B. 2024 no. 157). You need one if your company directly offers remote casino games, sports betting, or poker to players for real money. A white-label brand operating under an existing licensee's framework does not hold its own licence.213
Is a Curaçao B2C licence right for your model, and when is Curaçao the wrong choice?
Curaçao is the wrong choice if your primary target is regulated European or North American retail markets, or if you cannot meet the local substance requirements postponed to 1 April 2027. High-tier operators have migrated to European domestic licensing (Yolo Group rebranded to Estonia). Operators also weigh Curaçao B2C licensing against Anjouan and tier-1 regimes on market positioning and operational feasibility.116
B2C licence, B2B supplier licence, or white label, which gaming model fits your business?
The LOK provides a supplier licence (leveranciersvergunning) under Article 5.13, distinct from the B2C operating licence. The LOK sets separate annual fees: EUR 22,960 and EUR 24,490 for one licence type, and EUR 24,490 per year for the Article 5.13 licence.213
Which markets can you legally serve under a Curaçao B2C licence, and which must you geoblock?
CGA licence conditions mandate strict geoblocking of Curaçao domestic residents and adherence to international restrictions. Dutch KSA enforcement decisions imposed a €3.08m fine on Chestoption and €24m on Novatech for targeting Dutch players. The ANJ publishes a non-exhaustive blacklist of illegal sites subject to administrative blocking.81412
The CGA tests liquidity at application and can revoke a licence where the holder cannot pay expected prizes immediately. LOK Article 5.8(g) (Chapter 5) provides for rules on segregation and reservation of player funds, and Article 1.4(c) prohibits licensees from extending any form of credit to players. Acquirers typically hold 5% to 10% rolling reserves for 30 to 180 days on high-risk (including gambling) merchants.6215
Major payment aggregators (Stripe, Square, PayPal and Shopify Payments) explicitly prohibit gambling in their acceptable use policies, so operators need specialised high-risk merchant accounts.16
What it really takes
How much capital do you really need for a Curaçao B2C licence?
There is no fixed statutory share capital minimum. Under LOK Art 5.2(2)(e), the CGA may request information on the applicant's liquidity and solvency. CGA rules require player funds to be held in segregated accounts and prohibit wagering credit. Payment processors withhold a rolling reserve of 5% to 10%, held for 30 to 180 days, on high-risk gaming merchants.2615
Who do you have to hire for a Curaçao B2C licence, and where must they be based?
Local substance rules under LOK Article 5.12 (a dedicated local office and a resident key person, scaling from one to three employees) are postponed until 1 April 2027. Local managing director services cost €6,000 to €12,000 annually, with registered office fees between €2,000 and €4,000.1727
LOK Chapter 5 and Article 5.2 define mandatory information and evidentiary documentation for licence applications. A detailed compliance checklist covers governance, AML manuals, IT security, and RNG audits for Curaçao B2C applicants. CGA Licensing Management Portal guidelines outline Phase 1 and Phase 2 document submission requirements.2
The legal framework
| Level | Document | What it does here |
|---|---|---|
| Act | National Ordinance of 20 December 2024 laying down rules on games of chance (National Ordinance on Games of Chance) | Foundational national gambling act establishing the CGA as independent administrative authority, the direct B2C online gaming licensing regime, two-phase assessment procedure, integrity criteria, player protection rules, and statutory fee schedule (Chapters 1, 2, 5, 6, 12, 13, 15) |
| Act | Landsverordening buitengaatse hazardspelen (LBH), P.B. 1993 no. 63 (repealed; transitional provisions in LOK Chapter 15) transitional only | Predecessor offshore hazard games ordinance repealed on 24 December 2024; transitional provisions under LOK Chapter 15 grandfathered legacy master/sub-licence operations pending direct LOK licensing |
| Secondary legislation | Landsbesluit goAML meldportaal, P.B. 2020 no. 157 | Mandates electronic registration of obliged gaming operators on the goAML reporting portal for reporting to FIU Curaçao; failure to register constitutes a mandatory licence refusal ground under LOK Art. 2.2(2)(k) |
| Secondary legislation | CGA announcement: postponement of the local substance requirement under LOK Article 5.12 (23 January 2026) | Postpones the enforcement of mandatory local physical office and full-time resident key person substance requirements under LOK Art. 5.12 until 1 April 2027 pursuant to ministerial exemption powers under Art. 5.12(6) |
| Regulator rules | CGA License Conditions for an Indefinite-Term Online Gaming License | Binding standard licence conditions issued by the CGA setting operational obligations, player fund segregation, key person rules, reporting, and prior 'Critical Change Consent' approval for corporate changes (Art. 4) |
| Regulator rules | Provisions for Identification and Verification without Physical Contact (CBCS, FIU and CGA, July 2026) | Binding regulatory technical provisions issued by CGA establishing digital KYC, biometric facial verification, electronic identity verification, and fraud prevention standards under LID and LOK |
| Procedure law | Landsverordening administratieve rechtspraak (LAR), P.B. 2001 no. 79 (as amended / GT P.B. 2007 no. 31) | General administrative procedure ordinance governing administrative objections (bezwaarschrift) to the CGA within 6 weeks, judicial review appeals (beroepschrift) before the Court of First Instance of Curaçao within 6 weeks, and fictitious refusal remedies upon regulatory silence |
| Procedure law | Landsverordening officiële talen, P.B. 2007 no. 16 | Designates Dutch, English, and Papiamentu as co-official languages of Curaçao, establishing legal statutory validity for regulatory applications and corporate filings submitted in English |
| Fee schedule | License Fees under the National Ordinance on Games of Chance ('LOK'), CGA Publication Version 2.0 (15 October 2025) | Official schedule setting application charges, annual supervisory and treasury fees, administrative amendment charges, and domain fees for B2C operating licences under LOK Arts. 5.18 and 5.19 |
| Forms | CGA Online Gaming Application Forms and Electronic Modules (Portal) | Prescribes the mandatory standard electronic application forms and declaration templates (Online Gaming Application Form, Business Information Form, Personal History Disclosure Form) under LOK Arts. 2.1(2), 5.1(3), 5.2(3) |
6 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | CGA Compliance and Enforcement Policy for Online Gaming (17 July 2026) | Sets out supervisory methodology, inspection frameworks, risk ratings, administrative enforcement measures, penalty calculation principles, and remedial directions under LOK Chapter 13 |
| Related regime | Landsverordening identificatie bij dienstverlening (LID), P.B. 2017 no. 92 | Mandates customer identification, verification (CDD/KYC), source-of-funds checks, and beneficial ownership transparency for remote gaming operators as designated obliged service providers under Article 15.4 LOK |
| Related regime | Landsverordening melding ongebruikelijke transacties (LMOT), P.B. 2017 no. 99 | Obligates online gaming licensees to report unusual transactions to FIU Curaçao, appoint a compliance officer, and maintain internal AML/CFT controls under Article 15.5 LOK |
| Related regime | Sanctielandsverordening 2014 (P.B. 2014 no. 55, GT) and Rijkssanctiewet (P.B. 2016 no. 54) | Imposes international sanctions, asset-freezing, and counter-terrorist financing obligations; non-compliance triggers mandatory licence refusal or revocation under LOK Arts. 2.2(2)(b), 2.4(1)(i), 2.4(2)(k) |
| Related regime | Burgerlijk Wetboek van Curaçao, Boek 2 (Rechtspersonen), P.B. 2009 no. 51 (as amended) | Governs the incorporation, statutory seat in Curaçao, governance, local resident managing director, and articles of association of the mandatory NV or BV corporate vehicle under LOK Art. 2.1(1) and 2.1(4) |
| Related regime | Algemene landsverordening Landsbelastingen (ALL), P.B. 2001 no. 89 (consolidated P.B. 2013 no. 53, GT) | General national tax ordinance; proof of tax compliance and absence of tax debts to the Tax Collector (Ontvanger) is a mandatory condition and refusal ground under LOK Arts. 2.2(2)(e) and 2.4(2)(j) |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | One secondary source states that a gaming licence application is accepted only through the CGA online gaming portal, and that files submitted outside it are not considered.367 | Landsverordening op de kansspelen (P.B. 2024 no. 157), Artikel 2.1(1)-(3), (6), Artikel 5.1(1)-(3), Artikel 5.2(3)-(4) |
| Language | Only one language rule is stated: certifications must be in English; if they are not, they must be translated to English and certified as a true copy. Professional reference letters must show the lawyer's or accountant's name in English.8 | |
| What the application contains | Applications are accepted only through the CGA online gaming portal and run in two phases under the LOK. Phase one: the corporate and business information form, a personal history disclosure per qualifying person, and evidence of source of funds and source of wealth. Phase two: the business plan, operations manual, AML/CFT, responsible gaming and information security policies, plus a Curaçao hosting node, an approved test laboratory and a certified ADR provider.9367 | Landsverordening op de kansspelen (P.B. 2024 no. 157), Artikel 2.1, 2.2, 5.1(2)-(3), 5.2(1)-(2), 5.8, 5.9, 5.11, 5.12; CGA License Management Portal instructions |
| Decision clock | The CGA reviews in two phases, each taking about eight weeks and extendable by four weeks. The statutory clock only runs once submissions are complete, not on receipt. On silence they give no rule (no deemed approval or refusal is stated). The only remedy described is objection or appeal against an enforcement decision.6710 | |
| Fees set by law | The one-off application fee is €4,592, plus €150 per UBO or qualified interest holder and €2,551 per listed UBO. Annual fees total €47,450: €24,490 to the National Treasury and €22,960 to the CGA, both due by 15 January. Adding a domain costs €250, extending the game portfolio €13 per title, and a UBO or qualified interest change €128 per person. Fees follow the CGA LOK fee schedule v2.0 (15 October 2025).176 | Landsverordening op de kansspelen (P.B. 2024 no. 157), Artikel 5.18 en 5.19; CGA Publication 'License Fees under the National Ordinance on Games of Chance (LOK)', Version 2.0 |
| Grounds for refusal | They only note that involvement in a gaming operation under licence suspension or revocation is a bar to licensing, and that unverifiable ownership chains, thin source-of-funds evidence and missing key-person disclosures stall the application. The LOK (P.B. 2024 no. 157) is named as the primary law behind every grant.6 | |
| Appeal | Under the National Ordinance on Administrative Jurisdiction, a party disagreeing with an enforcement decision may either lodge an objection with the CGA or appeal directly to the Court of First Instance of Curaçao; the choice is optional. If an objection is filed, an appeal can only be lodged after the CGA has decided it. The decision itself lists the available remedies. For a direction under Art. 13.43 LOK, an objection does not suspend the decision. No deadline is stated.102 | Landsverordening administratieve rechtspraak (LAR), P.B. 2001 no. 79 (as amended / GT P.B. 2007 no. 31), Artikelen 3, 9, 14, 16, 56; Landsverordening op de kansspelen (P.B. 2024 no. 157), Artikelen 2.5, 5.17(6), 13.43(2) en Voetnoot 20. An interested party (belanghebbende) may lodge a notice of objection (bezwaarschrift) with the CGA within 6 weeks (42 calendar days) from the notification of the decision or from expiry of the statutory decision clock (fictieve weigering). Against the CGA's decision on objection, an appeal (beroepschrift) may be filed within 6 weeks (42 calendar days) before the Gerecht in eerste aanleg van Curaçao. A further appeal (hoger beroep) on points of law and fact may be lodged within 6 weeks (42 calendar days) before the Joint Court of Justice. Under LOK Art. 2.5(6), lodging an objection or appeal does not have suspensive effect (geen schorsende werking). |
| Validity | The definitive B2C licence is granted for an indefinite period, with no expiry date and no renewal application. It stays in force through payment of annual fees, which are due in full by 15 January each year, and remains subject to suspension or revocation. A provisional licence, by contrast, runs up to six months and can be extended once by a further six months.67 | |
| Change of control | They only confirm that a UBO or qualified interest change costs EUR 128 per person and is described as regulator approval of a change in ownership or control, and that a licence cannot be transferred, assigned or sub-licensed.6 | |
| Reapplying after a refusal | None of the governing texts held for this licence (National Ordinance of 20 December 2024 laying down rules on games of chance (National Ordinance on Games of Chance); National Ordinance of 20 December 2024 laying down rules on games of chance (National Ordinance on Games of Chance)) contains a provision on a waiting period before a new application after refusal or withdrawal. | |
| Serving other countries | A Curaçao B2C licence authorises remote gaming from Curaçao to international markets but is not a passport into regulated territories. Markets with their own licensing regime require a local licence, and the operator stays responsible for the law of every market it accepts players from, so geo-blocking is a licence condition in practice. One source adds that the licence does not authorise serving EU-resident players, and that Curaçao residents, minors, and players in the USA, France, Australia and the Netherlands cannot be accepted.6118 |
How long it takes
How long does getting a Curaçao B2C licence really take?
Under the LOK framework the CGA runs a two-phase application review, each phase taking roughly eight weeks and extendable by four weeks. A realistic end-to-end licensing turnaround is 3 to 5 months for a clean file.76
The CGA runs a two-phase review of roughly eight weeks per phase (each extendable by four weeks) under the LOK framework. LOK Article 5.1 runs each 8-week decision period only from receipt of all required information; incomplete files not completed within 4 weeks after reminder are not processed further.7
Statutory: Two-phase review (integrity/financial stability, then LOK regulatory requirements); each phase decided within 8 weeks, extendable by up to 4 weeks per phase: up to about 24 weeks in total3. Observed: not published. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.
What it costs
What does a Curaçao B2C gaming licence cost in total, first year and ongoing?
Year-one launch spending ranges from €70,000 to €110,000 all-in, settling to roughly €55,000 to €85,000 annually thereafter. LOK Art. 5.18 sets a €4,592 application fee (plus per-UBO/holder surcharges) and Art. 5.19 sets annual fees of €22,960 (CGA supervision) plus €24,490 (licence right), €47,450 in total, for an Art. 5.1 licence.72
Approval odds and who can own it
What are the real approval odds for a Curaçao B2C licence, and why do applications fail?
Close to 38 percent of direct applications were rejected or shelved. The CGA published a public fraud alert against unlicensed GEM55 gambling sites displaying counterfeit digital seals. The CGA Online Gaming License Registry (21 Sep 2026) lists 664 entries, 571 of them B2C; registry-wide 207 are Indefinite and 279 'Assessment in progress'.18194
Who can own and run a Curaçao licensed B2C gaming company?
Curaçao licensing requires fit-and-proper checks, certificates of no criminal record, and financial reputation or source-of-wealth documents for owners, directors, and key employees. Unverifiable ownership chains, thin source-of-funds evidence, and missing key-person disclosures stall phase one of the review.6
After you get the licence
What else will you need alongside a Curaçao B2C online gaming licence?
Alongside the licence, LOK Article 5.16 requires registration of suppliers of critical services or goods, while Article 5.17 certification is discretionary on application. The licence may be revoked for breaching the Landsverordening melding ongebruikelijke transacties. Destination regulators impose multi-million euro penalties on offshore operators targeting local players without national licences, so local licences are needed for those markets.214
Will you get a bank account and payment processing with a Curaçao B2C licence?
Major payment aggregators including Stripe, Square, PayPal, and Shopify Payments explicitly prohibit online gambling in their acceptable use policies. Curaçao is widely recognised by acquirers and PSPs and sits in an upper tier compared with budget routes such as Anjouan and Tobique.167
What does it take to keep a Curaçao B2C licence, and what upcoming changes apply?
LOK Article 5.19 mandates annual licence fees totalling €47,450 (€24,490 Treasury plus €22,960 CGA supervisory fee). A ministerial circular postpones Article 5.12 local substance mandates to 1 April 2027. Critical Change Consent is mandatory before transferring ownership; the licence itself cannot be transferred or assigned.217
The CGA registry lists new-policy licences with specific expiry dates (about six months after issue). LOK statutory provisions prohibit transfer or assignment of gambling authorisations. Licence conditions govern indefinite-term online gaming licences and triggers requiring prior CGA consent.42
What changed under Curaçao's LOK after 31 January 2025, and which compliance deadlines remain?
All four private master licence holders and sub-licences were abolished under the LOK, transitioning to direct CGA licensing. A ministerial circular postpones Article 5.12 local substance mandates to 1 April 2027. The Curaçao critical supplier licence takes effect two years after LOK entry into force (24 December 2026).11176
Buying a company that already holds it
Prior approval required. Prior written CGA permission ('Critical Change Consent', licence condition art. 4) is required before a licensee changes or adds a UBO, a qualifying-interest holder (≥10% of capital or voting rights), a director or other key person, a domain, or amends its articles of association. The administrative fee is EUR 128 per changed/added UBO or qualifying-interest holder; no assignment/transfer of the licence itself is possible: only a change of the licensed company's own ownership.5
Ready-made companies holding this licence: see verified positions.
Gaming in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Curaçao | Supplier LicenceSupplier Licence (B2B platform/software licence) under the LOK | CGA | n/a | EUR 4,592 | ~1.8 mo |
| Curaçao | Online Gaming Licence (B2C operating licence)Online Gaming Licence (B2C operating licence) under the LOK | CGA | n/a | EUR 4,592 | ~8.3 mo |
| Malta | Critical Gaming Supply LicenceCritical Gaming Supply Licence (B2B Game Providers and Back Office) | MGA | n/a | EUR 5,000 | n/a |
| Malta | Gaming Service Licence | MGA | n/a | EUR 5,000 | n/a |
| Malta | Recognition Notice Certificate | MGA | n/a | EUR 5,000 | n/a |
Values come from each licence's page, where every figure has its source.
Laws behind it
Frequently asked questions
What is a Curaçao B2C online gaming licence and do you actually need one?
A Curaçao B2C online gaming licence is an official authorisation issued by the Curaçao Gaming Authority (CGA) under the National Ordinance on Games of Chance (LOK, P.B. 2024 no. 157).
How much capital do you really need for a Curaçao B2C licence?
There is no fixed statutory share capital minimum. Under LOK Art 5.2(2)(e), the CGA may request information on the applicant's liquidity and solvency. CGA rules require player funds to be held in segregated accounts and prohibit wagering credit. Payment processors withhold a rolling reserve of 5% to 10%, held for 30 to 180 days, on high-risk gaming merchants.
How long does getting a Curaçao B2C licence really take?
Under the LOK framework the CGA runs a two-phase application review, each phase taking roughly eight weeks and extendable by four weeks.
What does a Curaçao B2C gaming licence cost in total, first year and ongoing?
Year-one launch spending ranges from €70,000 to €110,000 all-in, settling to roughly €55,000 to €85,000 annually thereafter.
What are the real approval odds for a Curaçao B2C licence, and why do applications fail?
Close to 38 percent of direct applications were rejected or shelved.
What does a Curaçao B2C gaming licence let you do, and where can you serve clients?
A Curaçao licence may be granted for organising remote games of chance, with a two-phase review.
Will you get a bank account and payment processing with a Curaçao B2C licence?
Major payment aggregators including Stripe, Square, PayPal, and Shopify Payments explicitly prohibit online gambling in their acceptable use policies.
Who do you have to hire for a Curaçao B2C licence, and where must they be based?
Local substance rules under LOK Article 5.12 (a dedicated local office and a resident key person, scaling from one to three employees) are postponed until 1 April 2027.
Is a Curaçao B2C licence right for your model, and when is Curaçao the wrong choice?
Curaçao is the wrong choice if your primary target is regulated European or North American retail markets, or if you cannot meet the local substance requirements postponed to 1 April 2027.
What does it take to keep a Curaçao B2C licence, and what upcoming changes apply?
LOK Article 5.19 mandates annual licence fees totalling €47,450 (€24,490 Treasury plus €22,960 CGA supervisory fee).
Sources
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- National Ordinance of 20 December 2024 laying down rules on games of chance (National Ordinance on Games of Chance) · retrieved 2026-09-24
- portal.cga.cw · retrieved 2026-09-24
- gamingcontrol.spin-cdn.com: 20260921 20260921 ogl license registry (PDF) · retrieved 2026-09-24
- portal.cga.cw: license conditions indefinite term online gaming license · retrieved 2026-09-24
- nuxgame.com: curacao gaming license complete review · retrieved 2026-10-01
- thepointlegal.com: curacao gaming licence · retrieved 2026-10-01
- gbo-intl.com: curacao gaming license · retrieved 2026-10-01
- gamingcontrol.spin-cdn.com: 20241230 landsverordening op de kansspelen.pdf and (PDF) · retrieved 2026-10-01
- gamingcontrol.spin-cdn.com: 20260717 cga compliance and enforcement policy online gaming (PDF) · retrieved 2026-10-01
- zitadelleag.com: offshore igaming curacao license guide · retrieved 2026-10-01
- anj.fr: liste noire des sites de jeux dargent et de hasard interdits · retrieved 2026-06-18
- costiganking.com: white labels and gambling licences responsibility · secondary · retrieved 2025-10-06
- bitcointalk.org: index · secondary · retrieved 2026-06-18
- corefy.com: rolling reserve an extensive guide for high risk merchants · secondary · retrieved 2025
- unisonpayment.com: online gambling merchant account · secondary · retrieved 2025
- gamingcontrol.spin-cdn.com: 20260123 postponement of local substance requirement 1769167 (PDF) · retrieved 2026-01-23
- brightsideofnews.com: curacao gaming license reform 2026 · secondary · retrieved 2026-04
- curacaochronicle.com: curacao gaming authority warns public about unlicensed gem55 · secondary · retrieved 2026-02-03
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