The Curaçao Gaming Authority plans to require licensees to have a real presence on the island by introducing new “local substance requirements.”
Under the updated rules, both B2C and B2B license holders must employ at least one staff member in addition to the local Managing Director. The new conditions will be implemented gradually.
For the first four years, licensees must employ at least one staff member based in Curaçao. From the fifth year onwards, the minimum requirement will increase to three people.
Compliance with these requirements will become mandatory from January 1, 2026, unless a company qualifies for an exemption. This provision of the Gambling Ordinance (LOK) is primarily aimed at smaller operators, who may face challenges when scaling their business.
The LOK also provides a broad definition of a “key person” — anyone who “directly or indirectly exercises influence or control over the governance, finances, policies, operations, risk management, or compliance of a Curaçao-licensed company.”
In addition, as part of the strengthened local presence requirements, B2C and B2B companies will also be required to maintain a dedicated office in Curaçao.
The document specifies: “The licensed entity shall maintain dedicated office premises in Curaçao equipped with standard business resources necessary to carry out licensed activities. The office must be clearly delineated or partitioned to ensure the licensed entity’s operations are operationally independent from other business activities.”
Establishing an office presence is considered a key step in the new regulatory framework, designed to eliminate the so-called “postbox model.”
This refers to the practice where operators work internationally under a Curaçao licence but formally register their business in other countries through a local mailbox, without obtaining a full licence in those jurisdictions.
Earlier this year, the Curaçao government decided to extend several licensing provisions.
The changes apply to both Green Seal B2C companies and B2B license holders. All operators must bring their operations into full compliance with LOK requirements by December 24, 2025, under the previously established conditions.
The LOK law is aimed at modernising Curaçao’s gaming regulation and licensing framework.
However, the Curaçao Gaming Authority clarified that not all operators will be granted the full six-month extension period — demonstrating real progress toward LOK standards will be a mandatory condition.
According to the new rules, operators must also implement additional measures related to player verification and social responsibility.
These include age verification, player self-assessments, deposit limits, and additional training for marketing partners and affiliates.
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