Curaçao's LOK reform explained: the end of the master-licence era

For two decades Curaçao was the pragmatic default for online gambling operators who wanted a cheap, fast licence and did not need EU market access. That model — a handful of master licences sub-licensing thousands of operators — has now been dismantled. The LOK (Landsverordening op de kansspelen), in force since 24 December 2024, replaces the 1993 offshore regime and rebuilds Curaçao’s licensing from the ground up.

What actually changed

Under the old NOOGH regime, four master-licence holders issued sub-licences to operators with little direct oversight from the government. The LOK abolishes that structure entirely. Licences are now issued directly by the Curaçao Gaming Authority (CGA) — the former Gaming Control Board, reconstituted under the new law — and recorded in a public register. Two licence categories replace the old chain: a B2C licence covering online casino and sports betting across all verticals, and a B2B licence or registration for suppliers and platforms.

The shift from a private sub-licensing chain to direct, publicly registered licensing is the whole point of the reform. It moves accountability from master-licence intermediaries to the regulator, makes the identity of every licensee a matter of public record, and gives the CGA a direct supervisory relationship with each operator rather than a supervisory relationship with four gatekeepers.

The fee structure

The LOK also puts published numbers on what a Curaçao licence costs, replacing the opaque commercial arrangements of the master-licence era. Verified fees include an application fee of roughly €4,592, a B2C annual cost of around €47,450 — comprising a €24,490 licence fee plus a €22,960 CGA supervisory fee — and a B2B annual supervisory fee of about €24,490. Curaçao continues to levy no GGR or turnover tax on internationally oriented online gaming; operators are taxed on net profits under general corporate tax, with consultancy sources citing a low effective rate that the CGA has not itself published.

Phasing out the old regime

The transition has been deliberate. In November 2025 the CGA updated its fee policy under the LOK — introducing pro-rata six-month billing for the first LOK year, 14-day invoice terms with revocation after 71 days of non-payment, and, critically, removing the NOOGH transitional section altogether. That last step signalled that the old offshore regime is fully phased out rather than running in parallel. Leadership and board changes at the CGA followed in October 2025.

Compliance obligations then tightened. From January 2026, following updated LOK requirements published on 20 January 2026, licensees must file mandatory reporting on player complaints, alternative dispute resolution and financial data. For operators used to the light-touch NOOGH world, ongoing reporting to a regulator is a genuine change in operating posture.

Why it matters

Curaçao’s importance is one of scale: a very large number of online operators worldwide have historically run on a Curaçao licence, so a structural reform of the jurisdiction touches a broad slice of the global market. The LOK does not turn Curaçao into an EU-grade regulator, and it retains the tax advantages that made the island attractive. What it changes is accountability — direct licensing, a public register, prudential and reporting obligations — which raises the compliance floor for a base that previously had almost none.

For operators, the practical questions are migration and standing: moving from a sub-licence to a direct CGA licence, meeting the new reporting duties, and judging whether a reformed Curaçao licence carries enough credibility for their banking and payment partners. For suppliers, the B2B registration brings the platform layer into the regulated perimeter for the first time. Teams weighing Curaçao against other bases can track the reform’s rollout in the iGaming regulatory tracker.

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