CGA Extends Provisional Licenses Under LOK Law

The Curaçao Gaming Authority (CGA) has issued a formal notice regarding the expiration and extension of provisional gaming licenses initially granted under the newly implemented National Ordinance for Games of Chance (LOK). According to the announcement, provisional licenses granted by operation of law to operators already holding valid licenses as of the LOK’s commencement date—December 24, 2024—will officially expire on June 24, 2025. However, operators who have not been explicitly contacted regarding the expiration of their licenses may assume their provisional status has been extended for another six months, now valid until December 24, 2025.

Background on LOK implementation

The National Ordinance for Games of Chance (LOK) represents a sweeping regulatory reform in Curaçao's online gambling sector. Enacted on December 24, 2024, the LOK aims to modernize and tighten oversight over both B2C (business-to-consumer) and B2B (business-to-business) licensees operating within or from Curaçao. The LOK was introduced in response to increasing international scrutiny and the need for alignment with global regulatory standards.

Prior to the LOK, Curaçao’s licensing regime was widely perceived as overly permissive, with limited supervision and inadequate safeguards for responsible gaming, anti-money laundering (AML), and player protection. The reform intends to rectify these concerns through stricter compliance obligations, enhanced due diligence protocols, and active monitoring by a centralized regulatory authority—the CGA.

Extension granted for compliant operators

In its June 2025 announcement, the CGA clarified that all license holders who have not received specific notification of non-renewal are presumed to be in compliance at a level that justifies the extension of their provisional licenses. These licenses will remain valid until December 24, 2025, and formal documentation confirming the extension will be provided to each qualifying operator no later than Friday, June 27, 2025.

This extension applies uniformly to both Green Seal B2C entities and B2B license holders under the CGA's regulatory scope. The Green Seal designation refers to operators that have met a preliminary threshold of compliance and transparency, making them eligible for temporary licensure under the new framework.

Compliance expectations during the extension period

The CGA emphasized that the second six-month extension is conditional upon strict adherence to the requirements outlined in the LOK. Operators must demonstrate measurable progress in addressing items detailed in the CGA Portal checklists, which include various licensing, corporate governance, risk management, and AML/CTF (anti-money laundering and counter-terrorism financing) obligations.

Failure to make significant compliance improvements or failure to fully cooperate with the CGA may result in non-renewal of the license after December 2025 or denial of a full license. Operators must also be mindful of new policies introduced by the CGA during this transitional period, which are designed to support LOK’s regulatory objectives.

Treatment of operators licensed after December 24, 2024

Operators who were licensed by the CGA after the LOK’s enactment date are subject to slightly different transitional arrangements. These operators must either fully comply with all checklist items or demonstrate significant progress within the first six-month period following the issuance of their provisional license. Depending on the degree of compliance achieved, these licensees may be granted either an extension (up to a further six months) or a full license at the CGA’s discretion.

This approach aligns with the CGA’s broader goal of ensuring that only well-governed, responsible, and law-abiding entities are permitted to operate under Curaçao’s jurisdiction in the long term.

Significance of the phased licensing process

The CGA’s decision to implement a phased approach to licensing reflects a commitment to both regulatory integrity and business continuity. Rather than immediately revoking or denying licenses to operators struggling to adapt to the new rules, the authority has opted for a measured strategy that prioritizes education, collaboration, and accountability.

This approach mitigates the risk of regulatory disruption in the gaming sector while ensuring that all market participants are given a fair opportunity to meet the new standards. It also serves to safeguard the interests of players, service providers, and other stakeholders who rely on the stability of Curaçao’s gaming ecosystem.

Legal and reputational considerations for licensees

From a legal standpoint, the CGA’s licensing extensions are not automatic guarantees of long-term approval. Operators are reminded that provisional status does not confer permanent operating rights. Each license holder must continue to operate with diligence, transparency, and full respect for the terms set out by the LOK.

Furthermore, failure to comply with LOK requirements could result in public censure, license suspension, or termination. Such consequences would not only impair business continuity but could also lead to reputational damage in regulated markets abroad—especially in jurisdictions where Curaçao licensees are actively targeting players.

International pressure and compliance obligations

The regulatory overhaul under LOK was largely driven by international concerns about Curaçao’s previous licensing model. In recent years, global organizations including the Financial Action Task Force (FATF), European Union bodies, and other international regulators have raised red flags regarding Curaçao’s lax oversight, especially in relation to financial crime, KYC (know-your-customer) procedures, and the facilitation of grey-market operations.

By instituting a more robust and transparent framework through the LOK, the Curaçao government seeks to bolster the island’s credibility as a serious licensing jurisdiction. Compliance with the LOK is not merely a local regulatory obligation—it is an essential component of Curaçao’s strategy to remain competitive and reputable on the international stage.

Timeline and operator responsibilities

The CGA’s June 2025 announcement provides a clear roadmap for operators over the next six months. In summary:

• Operators with existing provisional licenses as of December 24, 2024, are extended until December 24, 2025, unless otherwise notified.
• Operators licensed after that date are subject to a maximum six-month extension, contingent on demonstrable progress.
• Full licenses will be considered based on completion of CGA Portal checklists and adherence to new LOK policies.
• All operators are expected to be fully compliant by the end of their respective provisional periods to qualify for permanent licensing.

To meet these expectations, operators should maintain close communication with the CGA, prioritize compliance audits, and retain qualified legal and regulatory advisors.

Conclusion

The extension of provisional gaming licenses by the Curaçao Gaming Authority marks a pivotal moment in the country’s transition to a modern, accountable gaming regulatory system under the LOK. While the CGA has provided a grace period to support operational continuity, the message is clear: full compliance is non-negotiable.

As the December 2025 deadline approaches, licensees must demonstrate not only procedural adherence but a genuine commitment to transparency, player protection, and financial integrity. Those who fail to meet the standards set forth by the LOK may find themselves excluded from Curaçao’s newly regulated gaming landscape.

FAQs

What is the LOK in Curaçao’s gambling framework?
The LOK, or National Ordinance for Games of Chance, is a new law enacted in Curaçao to regulate online gambling activities more stringently and align the jurisdiction with international standards.

When was the LOK implemented?
The LOK officially came into effect on December 24, 2024.

What happens to my provisional license under the new rules?
If you held a valid license before LOK came into force and have not been contacted by the CGA about non-renewal, your provisional license is extended until December 24, 2025.

Does the extension apply to all types of operators?
Yes, the extension covers both B2C Green Seal entities and B2B license holders, provided they meet the CGA’s compliance expectations.

What is the purpose of the CGA Portal checklist?
The checklist outlines compliance items that must be completed before an operator can receive a full license under the LOK framework.

What if I received my license after December 24, 2024?
Operators licensed after this date must show significant compliance progress within six months to be eligible for an extension or a full license.

When will license extension documents be issued?
The CGA will issue official extension documentation by no later than Friday, June 27, 2025.

Can a provisional license be revoked before December 2025?
Yes, failure to meet ongoing compliance requirements could result in revocation or non-renewal of a provisional license.

Why was the LOK introduced?
The LOK was introduced to reform Curaçao’s gambling oversight and address concerns about inadequate regulation, especially in relation to AML and player protection.

What are the risks of non-compliance with the LOK?
Non-compliance could lead to license loss, reputational harm, and reduced market access in regulated jurisdictions abroad.