The Curaçao Gaming Authority (CGA) has published draft economic substance requirements for all licensees for public consultation. From January 1, 2026, operators must employ at least one full-time key employee (at least 30 hours per week) registered in the island’s civil registry and rent a dedicated office.
The government of Curaçao, via the CGA, is moving to tighten regulatory oversight of its gambling sector by compelling licensed online gambling companies to establish a tangible presence on the island. Under proposed reforms, operators would be required to maintain local offices and to employ key managerial staff who are residents, strengthening the so-called “economic substance” requirements. This will be in action as of January 1, 2026. The transition period for compliance will last until the end of 2025.
According to the proposal, once operators have been licensed for five years, they’ll need to fill three “key person” positions locally, i.e., starting from December 2028. The requirement isn’t limited to remote or virtual leadership; the individuals must be physically based in Curaçao. Additionally, the companies will be obligated to hold property on the island—further cementing their operational presence. Exceptions are provided for under four conditions, including turnover of less than €10 million per year and the owners having no stake in other gambling companies for two years prior to filing an application. Key employees include IT specialists, marketers, developers, analysts, and compliance managers.
These measures emerge in the broader context of the National Ordinance on Games of Chance (LOK), the legal framework that has already redefined Curaçao’s gambling licensing regime. The LOK has introduced stricter controls over licensing, higher standards for anti-money laundering (AML) and player protection, and restrictions on sublicensing structures.
Officials say these reforms are designed to align Curaçao’s iGaming regulatory regime with international norms. Critics have long argued that Curaçao’s previous system allowed operators to exploit “offshore” or loosely regulated status—sometimes undermining transparency, accountability, or effective oversight. The government’s goal now is to enhance credibility, ensure better supervision, and reduce risks such as money laundering or insufficient consumer protection.
By making local operation, property holding, and resident key staff mandatory, Curaçao aims to shift the sector away from being purely virtual. Stakeholders say that this can not only help with regulatory enforcement but also with practical aspects like tax, auditing, cooperation with law enforcement, and maintaining the integrity of services for players.
For established operators that have long functioned with minimal physical presence on the island, the proposed requirements could mean significant restructuring. They may have to recruit qualified local personnel, secure or lease property, and demonstrate operational activity beyond remote management. These changes could increase operational costs, raise barriers to entry, or prompt some operators to reconsider their licensing jurisdiction.
On the other hand, proponents contend that the long-term benefits—stronger regulatory compliance, enhanced reputation, risk mitigation—will outweigh the costs. Investors and operators that adhere to rigorous standards may find it easier to access global banking systems, payment providers, or partnerships that demand proof of substance.
The reform proposals are under consideration, with no final implementation date yet confirmed. Once adopted, there may be transitional grace periods to allow companies to adapt to the new requirements. Regulatory bodies such as the Curaçao Gaming Authority and Gaming Control Board are expected to provide guidance and oversight during the shift.
As Curaçao positions itself to offer more robust and transparent licensing, the global gambling industry will be watching closely. The outcome may serve as a model for other jurisdictions, balancing the appeal of attracting online gambling operators with the demands of good governance and international regulatory expectations.
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