Curaçao

Curaçao historically issued huge numbers of online gambling permits through four private 'master' licence holders that sold sub-licences, a model widely criticised for weak oversight. Under the LOK (Landsverordening op de kansspelen / National Ordinance for Games of Chance), passed by parliament on 17 December 2024 and in force from 24 December 2024, the new Curaçao Gaming Authority (CGA) now licenses operators directly, maintains a public register, runs its own UBO due diligence, and enforces AML/CFT and player-protection rules. Master/sub-licences were phased out with old sub-licences expiring in 2025 as holders migrate to direct CGA licences. The CGA is still publishing the detailed secondary requirements as the direct-licensing regime beds in.

The old master-licence layer

For decades Curaçao licensing ran through four private master licence holders, each able to issue sub-licences to operators with limited state involvement. Much day-to-day supervision effectively sat with those private intermediaries rather than a public regulator, and only the four masters answered directly to government. Critics linked this structure to thin due diligence, weak player protection and limited transparency over who ultimately owned licensed operators. The arrangement traced back to the 1996 offshore regime and drew sustained scrutiny from international observers and payment providers wary of the oversight gap.

What the LOK changed

The LOK dismantles that intermediary layer. The Curaçao Gaming Authority now licenses operators directly and publishes a public register, so the identity of authorised operators is meant to be verifiable rather than obscured behind a master holder. The CGA runs its own ultimate beneficial owner checks and enforces anti-money-laundering and counter-terrorist-financing obligations, with enforcement powers that include suspension and revocation. In principle this shifts supervision from private hands to a public authority, bringing the framework closer to how licensing operates in more established jurisdictions, though the arrangement is recent.

Transition in practice

The change is recent and not fully settled. Legacy sub-licences were set to lapse through 2025 as holders migrated to direct CGA authorisations, and the Authority is still issuing detailed secondary requirements as the regime beds in. Provisional or transitional permits can run shorter than the standard term while applications are assessed. For a diligence reader this means the paper framework exists but its track record is thin: how consistently the CGA exercises its powers, and how completely operators have migrated, remains to be demonstrated over time rather than assumed.

The low-cost economics

The cost base is unusually low, and by design. Curaçao levies no dedicated gaming tax on gross gaming revenue and no VAT on international wagers; operators instead pay corporate income tax at an effective rate of around 2% under the territorial e-zone model. The main qualifier is the OECD Pillar Two global minimum tax, a 15% top-up that applies only to groups with consolidated revenue of at least EUR 750 million. Smaller operators fall outside that threshold, so for most licensees the low effective rate is what applies.

The credibility question

Reputation and legal status are separate from the reform's ambitions. A Curaçao licence is not recognised across the European Union, and several markets, including the United Kingdom and much of Europe, require their own domestic authorisation; serving players there on a Curaçao licence alone is generally treated as grey-market activity. Payment providers and banks have historically viewed the jurisdiction cautiously. The LOK is aimed at the oversight failings that drove that caution, but whether external perception shifts depends on enforcement in practice, which cannot yet be evidenced.

Tax

Key facts

Compare Curaçao head-to-head

Open forecasts

Licence types

Fees

Change-watch

Sources (4)