The Curacao Gaming Authority has officially announced a significant postponement in the enforcement of local substance requirements for operators licensed under the updated Landsverordening op de Kansspelen (LOK). The revised timeline grants license holders more than an additional year to achieve compliance with the new rules.
In a regulatory notice issued on January 23, 2026, the authority confirmed that the Minister of Justice has exercised discretionary powers under Article 5.12(6) of the LOK to approve a blanket extension applicable to all affected operators. As a result, the obligation to comply with local substance requirements under Article 5.12 will not take effect until April 1, 2027.
Local substance as a core pillar of LOK reforms
Local substance remains one of the most significant reforms introduced under the LOK framework as part of Curaçao’s broader effort to modernize its online gambling regime. Article 5.12 requires licensed operators to establish a genuine economic presence on the island, including local staff, operational decision-making, and substantive business functions.
The measure was introduced in response to international criticism of Curaçao’s former master license system and is intended to align the jurisdiction with global standards on regulatory oversight, tax transparency, and anti-money laundering supervision.
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Industry challenges and regulatory response
Since the introduction of the local substance requirement, industry stakeholders have raised concerns regarding practical implementation. Key challenges include limited availability of qualified local personnel, immigration and work permit constraints for foreign specialists, and the readiness of local infrastructure to support a growing regulated gaming sector.
According to the CGA, the postponement reflects industry feedback and supports the regulator’s focus on long-term sustainability and regulatory integrity. While enforcement is deferred, the authority emphasized that the underlying policy objective remains unchanged.
Next steps toward the 2027 deadline
Operators are not restricted from establishing local substance ahead of the revised deadline, and several larger licensees have already begun building on-island compliance, payment, and support functions.
In the lead-up to April 2027, the Ministry of Justice of Curaçao and the CGA are expected to work with industry participants to improve workforce development, immigration flexibility, and regulatory clarity. A Ministerial Decree formally confirming the extension is expected to be issued shortly, with operators encouraged to use the additional time to prepare for full compliance rather than view it as a relaxation of standards.
