By Antonina Tupikova · Founder, iGaming Times
Curaçao's sweeping legislative overhaul of its online gaming sector came into force on 24 December 2024, replacing decades-old offshore hazard rules with the new Landsverordening op de Kansspelen and elevating the Curaçao Gaming Authority to a more independent regulatory footing. For the thousands of operators licensed through the jurisdiction, the transition marks the start of a stricter compliance era.
The Curaçao Gaming Authority has confirmed that the Landsverordening op de Kansspelen, known by its Dutch acronym LOK and translated as the National Ordinance on Games of Chance, entered into force on 24 December 2024. The ordinance replaces the Landsverordening buitengaatse hazardspelen (LBH), the National Ordinance on Offshore Games of Hazard, which had served as the legal foundation for Curaçao's online gaming licences since the jurisdiction first established itself as a major offshore licensing hub.
According to the CGA, the new legislation is designed to address longstanding issues within the industry and to deliver a safer, more transparent, and better-regulated environment for all stakeholders. The authority describes the LOK as a key component of a broader reform commitment, while acknowledging that not all industry challenges can be resolved in a single legislative step.
The groundwork for the LOK was laid in November 2023, when the CGA, acting on behalf of the Minister of Finance, began implementing phased reforms to prepare the jurisdiction for the transition. The Minister of Finance had assumed responsibility for licensing and supervision under the previous LBH framework in 2019, with the CGA carrying out those functions in practice from March 2020 onwards. The December 2024 activation therefore represents the culmination of a reform process spanning more than a year of preparatory work.
One significant institutional consequence of the LOK is a formal name change and a shift in the authority's standing. The body previously referred to in some contexts as the Gaming Control Board (GCB) is now designated the Curaçao Gaming Authority, a change the CGA says solidifies its role as a more independent organisation in relation to online gaming. That independence from direct ministerial control is a central theme of the reform, positioning the CGA closer to the model adopted by regulators in other established jurisdictions.
The previous regime has not been fully retired. The CGA confirms that the LBH remains relevant under transitional provisions set out in Article 15.1 of the LOK, meaning that certain legacy licensing arrangements continue to operate under the older ordinance. Operators holding authorisations granted before the LOK's commencement will need to assess carefully which regulatory framework currently governs their activities and when migration to the new regime is required.
On the complaints and enforcement side, the CGA has clarified that it does not mediate individual player disputes or act as a civil court. Instead, it is developing a standardised web-based complaints form that will feed reported concerns into a central database, informing the authority's risk-based supervisory approach. The CGA has indicated that patterns of complaints may prompt regulatory action against operators, even where individual grievances cannot be adjudicated directly.
The LOK's Independence Provision Is the Reform's Most Consequential Structural Change
The elevation of the CGA to a more independent footing, away from direct operational dependence on the Minister of Finance, is the single most structurally significant element of the LOK. Curaçao's reputation as a licensing jurisdiction has long been complicated by perceptions that its governance arrangements lacked the arm's-length separation expected of a credible regulator. By formalising the CGA's independence in statute, the LOK addresses one of the most persistent criticisms levelled by international counterparts, player-protection advocates, and correspondent banks wary of exposure to Curaçao-licensed operators. The practical weight of that independence will depend on how the CGA exercises its new powers: a formally independent authority that continues to operate permissively will satisfy no one, while one that uses its mandate to raise compliance standards substantively could meaningfully shift how the jurisdiction is perceived in markets that scrutinise the licensing provenance of operators seeking access.
Transitional Provisions Create a Dual-Regime Period That Operators Must Navigate Carefully
The survival of the LBH under Article 15.1 transitional provisions introduces a period of regulatory complexity that operators and their compliance teams cannot afford to treat lightly. Two licensing frameworks are simultaneously active, and the boundary between them, which authorisations fall under which ordinance and for how long, has not been spelled out in detail in the CGA's public communications to date. Jurisdictions that have managed similar transitions, such as the Netherlands when it moved from a de facto toleration policy to the full Koa framework, found that ambiguity in transitional arrangements generated significant compliance uncertainty and, in some cases, enforcement disputes. The CGA's risk-based supervisory approach, informed partly by the incoming complaints database, may mean that operators relying on legacy LBH authorisations without a clear migration path become early candidates for scrutiny.
The Risk-Based Complaints Database Signals a More Proactive Supervisory Posture
The CGA's decision to build a structured, database-driven complaints system, rather than simply directing players elsewhere, reflects a material shift in how the authority intends to use regulatory intelligence. A risk-based supervisory model that aggregates complaint patterns across operators can surface systemic problems that individual case-handling would miss, and it brings the CGA's methodology closer to the approach adopted by regulators such as the Dutch KSA and the Malta Gaming Authority. The caveat is implementation: the form has not yet launched, and the CGA has confirmed it will not disclose the status of investigations or actions taken. Transparency about outcomes, even in aggregate and anonymised form, will ultimately determine whether the system builds confidence among players and partner jurisdictions or operates as a black box. The framework is architecturally sound. Whether it delivers on its stated purpose depends on the rigour with which the CGA applies it once the data starts flowing.
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