Curacao Gaming Authority Grants Extension on Local Substance Compliance Under Revised LOK

The Curacao Gaming Authority (CGA) has confirmed that operators licensed under the updated Landsverordening op de Kansspelen (LOK) will receive additional time to meet the law’s local substance requirements, extending the effective deadline by more than a year. In a notice dated January 23, 2026, the regulator stated that the Minister of Justice had exercised the discretion provided under Article 5.12, paragraph 6 of the LOK to grant a general extension for all affected operators. Consequently, licensees will not be required to fulfill the local substance obligation outlined in Article 5.12 before April 1, 2027.

The local substance requirement represents one of the most significant structural reforms introduced under the new LOK framework, part of Curacao’s broader initiative to overhaul its online gambling regime. Article 5.12 obliges licensed operators to establish a meaningful economic presence in Curacao, encompassing local staffing, decision-making functions, and operational substance, rather than functioning solely as offshore or “letterbox” entities.

This reform was designed to address longstanding international criticism of Curacao’s historic master license system, which was frequently regarded as permissive and lacking effective oversight. By mandating local substance, the government seeks to bring the jurisdiction in line with global regulatory expectations, particularly regarding tax transparency, anti-money laundering supervision, and regulatory accountability.

Since the introduction of the requirement, industry stakeholders have raised concerns about the practical challenges of implementation within the original timelines. Issues cited include the limited availability of suitably qualified local staff, immigration and work permit constraints for foreign professionals, and the capacity of local infrastructure to accommodate a sudden influx of regulated gaming operations.

According to the CGA, the decision to postpone enforcement reflects feedback received from across the industry and aligns with the regulator’s stated emphasis on the long-term sustainability and integrity of the Curacao gaming sector. The authority emphasized that while compliance is deferred, the underlying policy objective remains unchanged.

Operators are not prohibited from establishing local substance ahead of the revised deadline, and the CGA noted that licensees who wish to build a presence in Curacao earlier are free to do so. Several larger operators have already taken steps in this direction, including establishing compliance teams, payment oversight functions, and customer support operations on the island.

The extension coincides with Curacao’s continued focus on strengthening other core regulatory areas under the LOK framework. The CGA reiterated its commitment, alongside industry participants, to enhancing Anti-Money Laundering (AML) controls, Know Your Customer (KYC) procedures, responsible gambling standards, and player protection mechanisms. These elements are considered fundamental to the new regulatory model and are viewed as essential for restoring international confidence in the jurisdiction’s licensing system.

In preparation for the revised April 2027 deadline, the Ministry of Justice indicated it will collaborate closely with the CGA and relevant stakeholders to establish the necessary conditions for effective implementation of Article 5.12. This includes initiatives aimed at developing the local workforce, expanding training opportunities, and improving the regulatory and administrative environment for gaming-related employment. Particular attention is expected to be given to immigration and work permit flexibility, an area repeatedly highlighted by operators as a bottleneck. Facilitating the relocation of qualified foreign professionals to Curacao is seen as critical to enabling operators to meet substance requirements without compromising operational quality or compliance standards.

The postponement may also give regulators additional time to clarify expectations around what constitutes sufficient “local substance” in practice, an issue that has caused uncertainty since the introduction of the LOK reforms. While the law sets out high-level requirements, operators have sought more detailed guidance on acceptable staffing models, outsourcing arrangements, and the minimum scale of on-island operations.

A Ministerial Decree formally enshrining the extension is expected to be issued shortly by the Ministry of Justice. In the meantime, the CGA has advised operators to continue engaging proactively with the regulator and to treat the additional time as an opportunity to prepare for compliance rather than as a relaxation of standards.

By fLEXI tEAM