Curaçao Gaming Licence Requirements in 2026
Curaçao gaming licence requirements under the LOK: a local company and resident director, CGA checks on every UBO, a €47,450 annual fee, 3 to 6 months.
Contents
Under the LOK regime a Curaçao gaming licence requires a Curaçao-registered company with a local registered office and at least one Curaçao-resident managing director. For nearly three decades a Curaçao gaming licence meant one thing: a cheap sub-licence, almost no local footprint and a live product in weeks. That world is gone. Under the National Ordinance on Games of Chance (the LOK), the Curaçao Gaming Authority (CGA) now issues licences directly, and the requirements file looks nothing like the old one.
The checklist below is the one we use in-house. It covers exactly what the 2026 regime demands, from the local company and its substance through direct CGA due diligence to the document pack, and how each of those differs from the master-and-sub model that required almost none of it. If you priced Curaçao on the old rules, this is what actually changed.
- The old master/sub-licence system is closed — you now apply for a DIRECT licence from the CGA under the LOK, with far heavier requirements.
- Mandatory local substance: a Curaçao-registered company, local registered office, a Curaçao-resident managing director (or local corporate management), a local key person and a dedicated compliance/MLRO function.
- Direct CGA due diligence on every UBO, shareholder, director and key person — identity verification, apostilled criminal checks, and source-of-funds/source-of-wealth.
- Official fee is €47,450/year plus a one-off €4,592 application fee, and the requirements, rather than regulator speed, determine whether you clear in 3 months or 6.
What changed: from sub-licence to direct CGA licence
Curaçao has licensed online gaming since 1996, and for most of that time it ran on a master-and-sub-licence model. A handful of master licensees issued sub-licences to operators, who went live with minimal local substance, light vetting and little direct regulatory contact. It was fast and cheap precisely because it asked for so little.
That model is over. Under the LOK the CGA issues licences directly: a separate B2C licence for operators and a B2B licence for suppliers whose services materially affect game outcomes or compliance. There is no sub-licensor in the middle: you apply to, are vetted by, and are supervised by the regulator itself. The heavier substance, stricter due diligence and full document pack described below all follow from that single structural change. For the full picture of the reform, read our flagship Curaçao LOK / CGA gaming licence guide. If you still operate under a sub-licence, the sub-licence to direct licence transition guide covers the move.
| Requirement | Under the LOK (2026) | Old master/sub model |
|---|---|---|
| Licensing route | Direct licence from the CGA | Sub-licence via a master licensee |
| Local company | Required — Curaçao-registered entity | Not required |
| Resident management | Resident director or local corporate management | None |
| Compliance / MLRO | Dedicated function, mandatory | Effectively optional |
| Due diligence | CGA-run; apostilled checks, source-of-wealth | Light, sub-licensor-run |
| Official fee | €47,450/yr + €4,592 one-off application fee | ≈$17,500 sub-licence |
Costs sit outside scope here — for the full fee breakdown and year-one all-in, see the Curaçao gaming licence cost guide.
Local substance requirements
This is the requirement that catches operators pricing Curaçao on the old rules. The LOK regime demands genuine local substance, and there is no remote-only route around it. At application you must have in place:
- A Curaçao-registered company as the applicant. Not an offshore holding company somewhere else — the entity that holds the licence is incorporated in Curaçao.
- A local registered office in Curaçao at a real address; a mailbox service does not count.
- At least one Curaçao-resident managing director, or management by a locally-registered corporate entity. The people directing the business must have a real Curaçao nexus.
- At least one local full-time key person and a dedicated compliance / MLRO function — someone accountable for the AML programme and the regulator relationship.
Note the contrast with the light offshore regimes: this is exactly what Anjouan, Tobique and similar permits do not require, and it is why they stayed cheap and fast while Curaçao got heavier. If you want to see how the local entity, ownership and management fit together in practice, our Curaçao corporate structure breakdown maps it out.
The Curaçao-registered company, resident management and compliance function are what make year-one materially higher than the headline fee, and they are also what make the licence bankable. Our team stands up the full substance stack end to end — see the Curaçao gaming licence service for how we run it.
Due diligence: UBOs, criminal checks and source of wealth
Under the LOK the CGA runs due diligence itself, and it covers the named applicant and every ultimate beneficial owner, shareholder, director and key person behind it. Each individual behind the company has to clear the same bar, and the depth is a step-change from the sub-licence era.
Identity verification for all UBOs, shareholders, directors and key persons, using certified documents; self-declaration is not accepted.
Apostilled criminal-background checks. A clean record is not enough on its own; the CGA expects the police-clearance documentation to be apostilled, which means allowing lead time to obtain and legalise it in each person’s home jurisdiction. This is a frequent cause of slippage for operators who leave it to the last week.
Source-of-funds and source-of-wealth assessment. You must demonstrate not only where the operating funds come from but how the beneficial owners built their wealth in the first place — the same standard a serious bank applies. Vague or undocumented wealth is the single most common reason a file stalls.
Finally, no disqualifying convictions, sanctions or watch-list hits are permitted for anyone in the structure. One unresolved UBO file (a missing apostille, an unexplained source of wealth) will hold the whole application, so assemble these in parallel from day one rather than treating them as a closing step.
These are also the documents that sat in the CGA’s licensing portal while an account registered under a false identity had access, from December 2025 to September 2026 by the regulator’s own account. If you filed in that window, read what the Casino Secrets leak means for people named in a Curaçao file.
The document pack the CGA expects
Alongside people and substance, the CGA reviews a defined set of documents. Filing with any of these missing or written for a different product is what turns a three-month approval into a six-month one. The core pack is:
| Document | What it proves | Notes |
|---|---|---|
| Certificate of incorporation, memorandum & articles | A properly constituted local applicant | For the Curaçao-registered company |
| UBO declaration & ownership chart | Transparent beneficial ownership | Feeds the due-diligence review |
| Business plan with financial projections | A viable, understood operation | Multi-year projections expected |
| AML/KYC & responsible-gaming policies | A working compliance programme | Must be in CGA format |
| RNG certification & technical docs | Fair games, secure platform | Issued or in process at application |
| GDPR-aligned data-protection policy | Lawful handling of player data | Secure storage and processing |
Two documents deserve emphasis. The AML/KYC and responsible-gaming policies must be operable documents mapped to the FATF Recommendations and drafted to the CGA’s format rather than copied from a template, because the compliance function is expected to actually run them. Where crypto is in scope, they must extend to the FATF Travel Rule for virtual-asset transfers. Our primer on iGaming AML and KYC covers what an operable programme looks like. And the RNG certification must come from a recognised, approved testing lab; it can be in process at application, but game fairness has to be backed by the lab’s evidence.
Ongoing requirements after the licence issues
The requirements do not stop at issuance. Because Curaçao is now a direct-supervision regime, you carry live obligations the sub-licence model never enforced. You must keep the local substance in good standing, so the company, resident management and compliance function cannot lapse. You file annual compliance reporting to the CGA and notify it promptly of any material change, including change of control. You run mandatory transaction monitoring to flag suspicious activity, and you keep responsible-gaming controls (self-exclusion, deposit limits, cooling-off periods, reality checks) implemented and enforced as well as documented. Your published player terms are now a supervised document too: the CGA’s April 2026 policy guideline sets a hard 8 October 2026 deadline for conforming B2C terms and conditions, covering consent, KYC thresholds, crypto clauses and complaints handling.
On the payments side, the practical reason operators tolerate all of this is Curaçao’s banking depth: it has wider PSP and banking acceptance than most offshore licences. But the rails still have to be built correctly — an EMI or neobank account rather than a mainstream processor that prohibits gambling, and, where a payment agent is used, one incorporated in Cyprus. Our Curaçao payments guide covers how that stack fits around the licence, and if you are checking an existing operator’s status, the Curaçao gaming licence check guide walks through verification.
Assembling the Curaçao file in the right order
The order of work matters too. To avoid rework, incorporate the Curaçao company and stand up the registered office, local management and compliance function first. Assemble every UBO due-diligence file, including apostilled checks and source-of-wealth evidence, in parallel, because these take the longest. Draft the AML/KYC, responsible-gaming and data-protection policies against your actual operating model, then finalise the technical documentation and RNG certification before submission. Only then does the CGA application go in. For a step-by-step run to go-live, see the Curaçao launch checklist.
The LOK regime is far from the light-touch permit Curaçao used to be. It asks for a local company, resident management and a working compliance programme, and in exchange gives you a direct regulator relationship and wide PSP and banking acceptance. Get the file complete and internally consistent the first time and the 3–6 month window is achievable; file with gaps and it drifts.
Ready to assemble your requirements pack, or want a second opinion on a file you have already started? Our team handles the full Curaçao substance, due-diligence and document build end to end and will review any application against the CGA’s expectations before you submit. Book a free consultation and we will tell you exactly what is missing.
Frequently asked questions
Do I need a local company and director in Curaçao?
Yes. Under the LOK regime the applicant must be a Curaçao-registered company with a local registered office, at least one Curaçao-resident managing director (or management by a locally-registered corporate entity), a local full-time key person and a dedicated compliance / MLRO function. This local-substance requirement is the biggest change from the old master-and-sub-licence model, which required almost none of it.
What documents does the CGA require for a Curaçao licence?
The core pack is the certificate of incorporation, memorandum and articles; a UBO declaration and ownership chart; a business plan with multi-year financial projections; AML/KYC and responsible-gaming policies in CGA format; RNG certification (issued or in process) with technical documentation; and a GDPR-aligned data-protection policy. Each is reviewed directly by the Curaçao Gaming Authority, since sub-licensors no longer play any part.
Who has to pass due diligence in Curaçao?
Every ultimate beneficial owner, shareholder, director and key person. Each undergoes identity verification, apostilled criminal-background checks and a source-of-funds and source-of-wealth assessment. No disqualifying convictions, sanctions or watch-list hits are permitted. The CGA runs this due diligence itself under the LOK, which is far stricter than anything the sub-licence era imposed.
How is this different from the old Curaçao master/sub licence?
The historic master-and-sub model let operators go live on a sub-licence with minimal local substance, light vetting and little direct oversight. That system is closed. Under the LOK the Curaçao Gaming Authority issues licences directly — with a local company, resident management, a compliance officer, apostilled due diligence and a full document pack. It costs more and takes longer, but it gives you a genuine regulator relationship.
Is a compliance officer or MLRO mandatory?
Yes. The LOK regime requires a dedicated compliance / MLRO function as part of local substance — someone accountable for the AML programme, transaction monitoring and reporting to the CGA. Under the old sub-licence model this was effectively optional. Now it is a condition of the licence, and the AML/KYC policies you file must be operable documents that this function actually runs.
How long do the Curaçao requirements take to satisfy?
Plan for 3–6 months with a clean file: roughly 2–4 weeks to incorporate the company and stand up local substance, 2–3 weeks to build compliance documentation, then a CGA review of around 6–10 weeks. A complete, internally consistent application moves faster than a thin one — the requirements themselves, not regulator speed, set the timeline.
Sources
This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.
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