Curaçao licence reform explained: the LOK, the Curaçao Gaming Authority and the end of sublicences

Why Curaçao matters to Australian players

Curaçao has long been one of the most common licensing jurisdictions for online casinos that accept players from countries where they are not locally licensed, including Australia. Under the Interactive Gambling Act 2001 it is prohibited to offer online casino services to customers in Australia, and the ACMA describes subsection 15(2A) as a civil penalty provision; a customer link exists if any customers are physically present in Australia. A Curaçao licence does not change that position. The Act targets providers, not individual players, but a player at an offshore site has no Australian regulator to turn to. The Australian gambling law overview explains the domestic side.

What a Curaçao licence does determine is which foreign regulator, if any, supervises the operator and which complaint route exists. That is why the 2024 reform matters.

The old system: master licences and sublicences

Before the reform, online gaming in Curaçao ran under the National Ordinance on Offshore Games of Hazard. A small number of master licence holders were authorised by the government, and they in turn issued sublicences to individual operators. Each sublicensed site displayed a seal, known as the Orange Seal or Certificate of Operations.

The weakness was distance. The regulator supervised the master licence holders, while the day-to-day oversight of hundreds of operators sat with those private licence holders. The CGA's own online gaming page acknowledges "longstanding issues and challenges within the industry" as the reason for reform.

The reform timeline

What the LOK changed

The main structural change is that licences are now issued directly by the regulator to the operator, rather than through a private master licence holder. Licence numbers in the current register appear in formats such as OGL/2024/ or CGA/2025/ followed by a serial number.

The transition had several parts:

• Provisional licences. Article 15(1) of the LOK gives holders of a licence under the old offshore ordinance who themselves operate games a provisional licence by operation of law for a maximum of six months, which can be extended by six months.
• Reclassification. The CGA's License Reclassification notice dated 15 October 2025 says licences issued under the old ordinance were converted, and that the expiry of the Orange Seal on that date effectively brought the former sublicence system to an end.
• A named regulator. Article 15(2) designates the existing Gaming Control Board foundation as the Curaçao Gaming Authority.
• Player complaints in law. Article 5(3) gives players a free right to complain to the licensee within six months of an incident, with an acknowledgement within one week and a reasoned decision within four weeks, extendable once by four weeks. Licensees must also make alternative dispute resolution available, at their own cost. The offshore casino complaints article covers how that works in practice.

The rulebook that now sits around a licence

Alongside the ordinance itself, the CGA's online gaming page lists the policies and procedures licensees must follow. They include an ADR policy, an anti-money laundering and counter-terrorist financing policy, a change of control procedure, a crypto policy guideline, a policy on licence fees under the LOK, the license reclassification notice, operations manual guidelines for B2C licence holders, the player complaints policy, a policy guideline on terms and conditions, requirements for compliance officers, a responsible gaming policy, a testing labs policy, and instructions for winding down operations and taking down online interfaces.

For a player, three of those matter most. The terms and conditions guideline sets expectations for how a licensee writes its rules. The responsible gaming policy sets the obligations behind deposit limits and self-exclusion tools on the site. And the wind-down instructions cover what a licensee must do when it stops operating, which is the situation in which player balances are most at risk. A casino that cannot point to these obligations in its own terms is worth treating with caution.

The CGA has also shown it will act publicly. Its public warnings page lists notices about named sites, including GEM55 (30 January 2026), TRUMPBET.CC (12 February 2026), KEANUBET (20 February 2026), and Famagousta and BlackSands (both 17 July 2026). Its news page also records a postponement of local substance requirements in January 2026, a reminder that parts of the new framework are still being phased in.

The 2026 portal breach and the digital seal

In 2026 the reform hit an operational problem. On 17 September 2026 the CGA said it was investigating unauthorised access to its online gaming portal. A follow-up on 22 September said a German security researcher had used an account registered in December 2025 under a false identity, and that access ran from December 2025 to September 2026.

On 2 October 2026 the CGA said the portal was offline, that the validity of licences was not affected, and that deadlines were postponed. On 7 October 2026 it went further: the portal will not return, the CGA is moving to a new platform, and the availability of the digital seal is affected. The CGA said it would introduce an alternative way to show that a domain is licensed, with interim arrangements targeted for no later than 9 October 2026.

For players, the practical consequence is that a seal on a casino's footer is, for now, a weaker signal than usual. The register is the better check.

How to check a Curaçao licence

1. Find the licence details on the casino site. Look for the legal entity name, the licence number and the issuing body in the footer or terms. A reference to a master licence holder or an Orange Seal is out of date since 15 October 2025.
2. Search the CGA licence register. The CGA publishes an online gaming licence registry as a PDF on its licence register page. The version seen for this guide was last updated on 14 October 2026 and runs to 19 pages. Check that the entity name and licence number match, and read the status column: entries can show revocation, including revocations at the operator's request.
3. Check the enforcement register. The CGA also publishes an enforcement register. The version updated on 14 September 2026 lists revocations from June 2025 to July 2026.
4. Check public warnings. The CGA's public warnings page lists named sites it has warned about.
5. Read the disclaimer. The CGA states that its overviews do not guarantee current validity and that no rights can be derived from them. Treat the register as a strong check, not a guarantee.

The safe casinos guide lists other checks that apply whatever the licence.

What the reform does not do for Australians

A valid Curaçao licence means an operator is supervised by the CGA under Curaçao law. It does not make the operator lawful in Australia, and it does not stop ACMA blocking. The ACMA reports that it has blocked 1,708 illegal gambling and affiliate websites since its first blocking request in November 2019, and it warns that Australians using illegal services are not protected by Australian laws if a provider withholds winnings.

The CGA's own complaints policy also says it does not resolve individual disputes. It uses complaint information for supervision, and the player's route to a binding outcome is the operator's ADR provider. That is better than the old model, where there was often no clear route at all, but it is still a foreign process, in English, with no Australian body involved.

If gambling is causing problems, Gambling Help Online offers free and confidential support on 1800 858 858, and BetStop is the national self-exclusion register for licensed Australian wagering providers.

Questions readers ask

Sources

Every figure and date in this article comes from the documents below; we re-check them when a source changes.

1. Curaçao Gaming Authority: Online gaming
2. CGA press release, 14 October 2025
3. CGA: License Reclassification, 15 October 2025
4. Landsverordening op de kansspelen (LOK)
5. CGA: License register
6. CGA: Online gaming licence registry (updated 14 October 2026)
7. CGA: Enforcement register (updated 14 September 2026)
8. CGA: Public warnings
9. CGA: Postponement of local substance requirements (January 2026)
10. CGA press release: unauthorised access to the online gaming portal, 17 September 2026
11. CGA: Follow-up on unauthorised access to the online gaming portal
12. CGA: Announcement regarding the online gaming portal, 2 October 2026
13. CGA: Transition to a new platform, 7 October 2026
14. CGA: Player Complaints Policy v1.1, June 2025
15. ACMA: Formal warning under subsection 15(2A) of the Interactive Gambling Act (2 September 2026)
16. ACMA: Latest illegal online gambling websites blocked

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