Elimination of the Sub-License System• Operators are no longer required to obtain licenses through master licensees.
• All operators must now obtain a personal license — either B2C (for operators) or B2B (for providers and platforms).
Stronger Compliance and Legal Requirements• Mandatory implementation of AML and KYC procedures.
• Appointment of a Compliance Officer and MLRO (Money Laundering Reporting Officer).
• Internal audits and continuous compliance monitoring.
Physical Presence in Curaçao- The new licensee must:
- Register a legal entity in Curaçao.
- Appoint at least one local director.
- Maintain an office and technical infrastructure (e.g., server or access point).
Financial Guarantees and Share Capital• Operators must prove financial solvency.
• Minimum share capital — ANG 500,000 (approx. €250,000).
• Proof of reserve funds to cover client balances.
• Financial statements and audits required.
Game Integrity and Technical Certification- RNG (Random Number Generator) testing and certification is mandatory.
- Verification of gaming algorithms and interfaces.
- Cybersecurity protocols against data breaches and hacking.
Geographic Restrictions- Curaçao licenses do not permit players from the following regions:
- USA, UK, Netherlands, France, Germany, Australia, Cyprus, Singapore, etc.
- FATF blacklist jurisdictions.
- Countries with legal bans on online gambling.
Responsible Gambling• Mandatory implementation of self-exclusion functions.
• Deposit and time limit mechanisms.
• Access to support and addiction information.
Consequences for Operators• The licensing process is now longer and more complex but ensures full international recognition and legal protection.
• New requirements increase the credibility of payment providers and gaming partners, opening access to top-tier B2B partnerships
• Direct communication with the national regulator — without intermediaries — allows for greater transparency.