The Curacao Gaming Authority is seeking to ensure licensees have a local footprint through the publishing of new ‘local substance requirements’.
As a result of the new rules, B2C and B2B licence holders will be required to have at least one employee, other than the local Managing Director based in the area. The change in regulation will be implemented in a phased process.
For the first four years, licensees must have at least one employee located in the island country. After the five year mark, the minimum requirement elevates to three people.
Compliance with the guideline is compulsory from 1 January 2026, unless qualifying for an exemption. This clause in the LOK is largely catered to smaller operators, underpinning the potential struggles when it comes to scaling.
While there is a relatively broad definition of a key person in the LOK guidance, stating that it is anyone who “directly or indirectly exercises control or significant influence over the governance, finances, policies, operations, risk or compliance of the Curaçao-licensed entity.”
Furthermore, strengthening the local market presence, B2C and B2B firms must also have a local market footprint in the form of dedicated office premises in Curaçao.
It states: “The licensed entity shall maintain dedicated office premises in Curaçao equipped with standard business facilities to enable the licensed activities.
The office premises shall be clearly delineated or partitioned, ensuring that the licensed entity’s operations are operationally independent from other business activities.”
The importance of the office premise is somewhat crucial to the overall motive of the framework, which looks to end what has been called the ‘postbox’ model.
This refers to a practice in which operators are active internationally under a Curaçao licence while registering their businesses in different markets via a local postbox, without necessarily being fully licensed in said market.
Earlier in the year, Curacao governance took the decision to extend several license provisions.
That move applied to both Green Seal B2C entities and also to B2B license holders, with relevant parties now being ordered to ensure they are compliant with LOK requirements on 24 December 2025, under the same conditions as previously put forward.
The new (LOK) law is seeking to modernise the Curaçao gaming framework and licensing procedure.
Nonetheless, the Curaçao Gaming Authority did lay out that not all operators will be granted the full six-month extension period, underpinning the importance of them showing progress when it comes to LOK standards.
There are a number of requirements that need to be implemented as a result of the policy, specifically around player verification and social responsibility.
These checks include age verification, player self-assessments, deposit limits and additional training for marketing partners and affiliates.
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