The Curacao Gaming Authority (CGA) has confirmed that operators licensed under the revised Landsverordening op de Kansspelen (LOK) will be granted additional time to comply with the law’s local substance requirements, pushing the effective deadline back by more than a year.
In a notice dated January 23rd, 2026, the regulator said the Minister of Justice has exercised the discretion provided under Article 5.12, paragraph 6 of the LOK to grant a general extension for all affected operators. As a result, licensees will not be required to meet the local substance obligation set out in Article 5.12 before April 1st, 2027.
The local substance requirement is one of the most significant structural reforms introduced under the new LOK framework, which came into force as part of Curacao’s broader effort to overhaul its online gambling regime. Article 5.12 requires licensed operators to establish a meaningful economic presence in Curacao, including local staffing, decision-making functions, and operational substance, rather than operating purely as offshore or “letterbox” entities.
The measure was designed to address longstanding international criticism of Curacao’s historic master license system, which was often viewed as permissive and lacking effective oversight. By mandating local substance, the government aims to align the jurisdiction more closely with global regulatory expectations, particularly those related to tax transparency, anti-money laundering supervision, and regulatory accountability.
However, since the introduction of the requirement, industry stakeholders have raised concerns about the practical challenges of implementation within the original timelines. These concerns have included the limited availability of suitably qualified local staff, immigration and work permit constraints for foreign professionals, and the capacity of local infrastructure to absorb a sudden influx of regulated gaming operations.
According to the CGA, the decision to postpone enforcement reflects feedback received from across the industry and is consistent with the regulator’s stated focus on the long-term sustainability and integrity of the Curacao gaming jurisdiction. The authority emphasized that while compliance is deferred, the underlying policy objective remains unchanged.
Operators are not prohibited from establishing local substance earlier than required, and the CGA noted that licensees who wish to begin building a presence in Curacao ahead of the revised deadline are free to do so. Several larger operators have already taken steps in this direction, including setting up compliance teams, payment oversight functions, and customer support operations on the island.
The extension comes at a time when Curaçao continues to emphasize improvements in other core regulatory areas under the LOK framework. The CGA reiterated its commitment, alongside industry participants, to strengthening Anti-Money Laundering (AML) controls, Know Your Customer (KYC) procedures, responsible gambling standards, and player protection mechanisms. These elements form the backbone of the new regulatory model and are viewed by the authority as essential to restoring international confidence in the license.
In preparation for the revised April 2027 deadline, the Ministry of Justice said it will work closely with the CGA and relevant stakeholders to create 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 that has been repeatedly highlighted by operators as a bottleneck. Allowing qualified foreign professionals to relocate to Curacao more efficiently is seen as critical to ensuring that operators can meet substance requirements without compromising operational quality or compliance standards.
The postponement may also provide regulators with additional time to clarify expectations around what constitutes sufficient “local substance” in practice, an issue that has generated uncertainty since the LOK reforms were introduced. 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. Until then, 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 a relaxation of standards.
