A licence issued by the Curaçao Gaming Authority in 2026 is a different instrument from the one operators obtained through master licence holders three years ago. The National Ordinance on Games of Chance replaced a private intermediary market with direct licensing, statutory enforcement powers and a published register. That reform is real. It is also unfinished, and the gap between the two is what GICNT-LS assessments have to price in.
What the LOK Changed in Curacao Licensing
The Landsverordening op de kansspelen (National Ordinance on Games of Chance, known across the industry as the LOK) entered into force on 24 December 2024, published as P.B. 2024 no. 157. It ended the arrangement under which four private master licence holders sold sub-licences to operators the government had never assessed. The master licence model was abolished in Curaçao outright rather than wound down, and nothing in the ordinance preserves a private right to issue authorisations.
The predecessor statute has not disappeared from the picture. The Landsverordening buitengaatse hazardspelen (National Ordinance on Offshore Games of Hazard, or LBH) remains relevant under transitional provisions based on Article 15.1 of the LOK. Applications filed before the commencement date continue to be processed under the older policy, and legacy authorisations were converted into provisional licences rather than reissued from scratch.
Institutionally the change is larger than the rebranding from Gaming Control Board to Curaçao Gaming Authority suggests. Article 12.1 of the LOK designates the CGA as an independent administrative body within the meaning of Article 111, paragraph 1 of the Constitution of Curaçao. Its mandate reaches beyond the gambling ordinance to the identification and unusual transaction reporting ordinances, the anti-money laundering ordinance of 2024 and the Sanction Decree published as P.B. 2025 no. 52. Anyone placing the island among recognised licensing jurisdictions should read the reform at that level rather than at the level of marketing claims about a new licence.
Licence Categories and Validity Periods Under the CGA
B2C and B2B licence types in Curaçao follow different assessment tracks, and the distinction matters for counterparty risk: a supplier authorisation says nothing about how the operator deploying that software treats players.
| Element | Position under the LOK |
|---|---|
| B2C licence | Covers the offering of games of chance to players, issued directly by the CGA |
| B2B supplier licence | Covers critical services and goods, including game and sportsbook software |
| Provisional licence | Valid for up to six months, extendable by up to a further six months |
| Definitive licence | Issued for an indefinite period, subject to amendment, suspension or revocation |
| Objection or appeal | Six weeks from the decision, to the CGA or to the Court of First Instance of Curaçao |
| Supplier registration | Registration of suppliers of critical services and goods required to be operational no later than 24 December 2026 |
A definitive licence carries no expiry date, which is why the register records those entries as indefinite. That is not the same as permanent. The enforcement measures available to the authority run from an instruction, through orders subject to a penalty, orders under administrative coercion and administrative fines, up to suspension or revocation of the licence and referral to the Public Prosecution Office. Set against the conditions attached to MGA licence types, the statutory powers look broadly familiar and the published track record is very much shorter.
How to Verify a Curacao Licence Before Onboarding a Partner
The authority publishes its register on cga.cw as a set of periodically updated PDF documents rather than a queryable database. A CGA licence register check therefore always has a date attached to it. The online gaming registry current at the time of writing is dated 14 August 2026 and runs to 26 pages and 661 numbered entries. The file states in terms that it does not guarantee the current validity of the licences listed and that no rights can be derived from it.
- Locate the entry by licence number rather than by brand name. Numbers issued during the transitional period carry the OGL prefix; those issued from 2025 onward carry CGA.
- Read the status column instead of treating presence in the register as approval. Entries appear as indefinite, assessment in progress, expired or revoked.
- Compare the expiry date against the date of the register file itself. An entry can show an expiry date months in the past alongside a status of assessment in progress.
- Cross-check the separate enforcement register. The version dated 10 July 2026 contains 31 entries and states that it covers only actions affecting licence status, not the full set of measures the authority has taken.
- Verify the digital authorisation seal on the operator’s domain against the register, never the reverse. On 12 February 2026 the CGA published a warning that the site TRUMPBET.CC was neither authorised nor licensed and was using the authority’s logo and seal to mislead the public.
Any internal reference on gambling regulators by country should record the register file date next to the result, because a screenshot taken in March proves nothing in September.
Where the Transition Remains Unfinished
The design of the reform is sound. Implementation is running behind the design, and three areas account for most of the residual risk.
Provisional Licences That Outlast Their Expiry Dates
An applicant that does not yet meet every requirement may receive a provisional licence valid for up to six months, extendable once by up to six months, after which the authority is expected to grant a definitive licence or refuse the application. The register shows that this timetable has not held. Entries whose provisional licence status in Curaçao expired between late 2025 and the middle of 2026 are still listed as assessment in progress in the 14 August 2026 file, some of them more than nine months past the stated expiry date. For a counterparty that means the register cannot answer the only question worth asking, which is whether the operator has cleared substantive review or is still queued behind it.
Governance Turbulence at the Authority
Political responsibility for the regulator moved from the Ministry of Finance to the Ministry of Justice on 19 August 2025. The three supervisory commissioners resigned in mid-September 2025, and on 14 October 2025 the CGA confirmed the resignations, stated that the appointment of replacements had begun and said that supervisory duties and LOK implementation would continue uninterrupted. Licensing work did continue. The episode still belongs in a file note, because an authority less than two years old that loses its entire supervisory layer has a shorter demonstrated record of independence than its statutory design implies.
Supply Chain Oversight and Player Funds
Two gaps are acknowledged by the authority itself. Registration of suppliers of critical services and goods is not yet live, and the CGA reported in August 2026 that the functionality must be operational no later than 24 December 2026. Separately, it has said it is assessing options for taking action against foreign entities that manage player funds on behalf of licensed operators, which is a direct acknowledgement that money held for players can sit outside the perimeter the licence covers. Operators weighing the island against emerging offshore licences should note that the second point is a question every offshore regime has to answer, not a local peculiarity.
Certified Test Houses and Dispute Resolution Providers Under Article 5.17
Article 5.17 of the LOK underpins a certification regime for gaming test laboratories and alternative dispute resolution providers, and the authority publishes the list of certificate holders. As at 1 July 2026 that list contains five certified test laboratories and six certified ADR providers, each certificate running three years from its effective date.
| Category | Certificate holders listed at 1 July 2026 |
|---|---|
| Gaming test laboratories | Gaming Laboratories International, eCOGRA, Quinel, BMM Spain Testlabs, Gaming Associates Europe |
| Alternative dispute resolution | Resolvo Curaçao, ADR Curaçao, Cadre, EGIS-FZCO, ABC-ADR, iGamingADR |
The testing side is served by houses that regulated European markets already accept, so an operator’s RNG certification obligations can be evidenced with reports that travel across jurisdictions rather than reports produced solely for local consumption.
The dispute resolution requirement carries more weight than its placement suggests, because the CGA does not resolve individual player disputes. The authority states plainly that it is not a civil court, that it cannot order operators to compensate players and that mediation and arbitration fall outside its mandate. Complaints sent to it function as supervisory intelligence. Player redress runs instead through the certified provider the operator has appointed, which makes the identity of that provider, and its visibility to players, a verifiable point in any assessment.
Why GICNT-LS Applies Enhanced Scrutiny Rather Than Exclusion
GICNT-LS covers licensing and legal status and sits on an Annual Review cycle. It maintains no list of banned jurisdictions, and an authorisation from the island is not treated as disqualifying. It is treated as a licence whose supporting evidence has to be assembled rather than assumed, which is what enhanced due diligence for Curaçao operators means in practice.
- Verification against the register file current on the assessment date, with that file date recorded, rather than a seal image or a screenshot supplied by the operator.
- The status field, expiry date and licence number reproduced in the assessment record, with provisional and definitive authorisations distinguished from one another.
- A check of the enforcement register against the licensee entity and against related entities sharing a company registration number.
- Confirmation of which certified ADR provider handles player complaints, together with evidence that the route is disclosed to players before they deposit.
- The local substance position documented, including any reliance on the deferral of the additional key person requirements to 1 April 2027.
- Evidence of geo-blocking for markets that license locally, since the licence confers no right to serve players in the Netherlands, Germany, France or comparable regulated jurisdictions.
None of this turns a certification mark into a substitute for the licence. The distinction between certification versus licensing is load-bearing here: GICNT assesses whether an operator meets a published standard, while the CGA decides whether that operator may lawfully offer games of chance from Curaçao. An operator can hold one without the other, and the two answer different questions.
Frequently Asked Questions About Curacao Licensing
Are sub-licences issued by master licence holders still valid?
No. The master and sub-licence model ended with the LOK, and legacy authorisations were converted into provisional licences under the new framework rather than continuing in their previous form. An operator presenting a sub-licence document as current evidence of authorisation is presenting an instrument that no longer exists.
What does an assessment in progress status mean on the CGA register?
It indicates that the authority has not yet reached a final decision on whether to grant a definitive licence, and it can appear against entries whose stated expiry date has already passed. It is not equivalent to a definitive licence and should not be recorded in a due diligence file as one.
Does a Curacao licence allow an operator to serve players in the European Union?
No. Jurisdictions that license locally, including the Netherlands, Germany, France and Sweden, require their own authorisation. The licence covers the offering of games from Curaçao and does not displace national licensing obligations elsewhere, which is why geo-blocking configuration belongs in any competent review.
Who handles a player complaint against a Curacao-licensed operator?
A certified alternative dispute resolution provider appointed by the operator. The CGA has stated that it does not handle individual complaints, that it is not a civil court and that it cannot order compensation, although complaints reaching it may inform its supervisory work.
Does GICNT certification replace a Curacao licence?
No. GICNT is a standards and certification body rather than a licensing authority, and its mark carries no legal permission to operate. Certification assesses conformity with the GICNT framework, while the licence remains the operator’s legal basis for offering games of chance.