What’s Changing: Structure, Oversight and Compliance
End of the Old Licence Model
With LOK in effect since December 24, 2024, the legacy master- and sub‑licence regime has been formally phased out. All prior licences under the old system have been converted into provisional licences — subject to new, more stringent criteria.
Starting 2025, operators must now be fully compliant with Curaçao’s new regulatory requirements, including legal entity presence on the island, local resident directors (or legally compliant local management), transparent corporate structure, and full adherence to compliance obligations (AML, responsible gambling, dispute‑resolution mechanisms, etc.).
Stricter Regulatory Oversight
The shift to centralized oversight means greater accountability: the CGA (formerly under a license‑issuing network) now directly supervises all gaming operators. Entities using foreign licences or operating without a valid CGA‑issued licence are considered non‑compliant and face legal consequences. Non‑compliant operators risk license revocation, removal from the public register, or even formal enforcement actions.
Fees & Billing Under LOK — What’s New for 2025
In addition to structural changes, the CGA has rolled out a new fee policy (version 2.0) under LOK, effective October 15, 2025.
- The licence application fee remains unchanged.
- Annual oversight fees for B2C operators remain at the established level, but first‑year billing is now split into two six‑month invoices (rather than one upfront payment), to ease the transition for new licence holders.
- B2B suppliers continue under a defined fee schedule.
- New invoicing and collection procedures are now formalized: invoices must be paid within defined deadlines, and failure to do so may result in license suspension or revocation.
This updated fee and billing structure underscores the CGA’s push for transparency and financial discipline under the new regime.
What It Means for Operators & the Global iGaming Market
- Operators must reassess their compliance, corporate structure and financial planning — especially those who previously relied on sublicense models or foreign licences.
- Those aiming at European markets should be especially attentive: stricter AML and consumer‑protection requirements now bring Curaçao closer to international regulatory standards.
- For startups and new entrants — the new billing structure and updated requirements may increase upfront burden, but the reforms also offer a clear legal foundation and potential for long‑term stability under a recognized regulatory regime.
- Non‑compliant or slow‑to‑adapt operators risk losing access to European payment processors, reputation damage, or removal from the official license registry.
Final Thought
2025 marks a turning point for Curaçao’s online gambling industry. With LOK fully implemented, the era of easy offshore sublicences is ending. The shift to centralized oversight, combined with updated fee and compliance structures, sets a new standard — one that balances regulatory robustness, operator accountability, and market legitimacy. Operators willing to adapt can continue serving a global audience under a recognized and modernized Curaçao Gaming License regime. Those who do not — risk losing access to key markets and regulatory standing.
