• The Curacao Gaming Authority has introduced new “local substance requirements” as part of its major regulatory overhaul, the National Ordinance on Games of Chance (LOK).
• The new rules are designed to end the jurisdiction’s reputation as a “postbox” hub by requiring licensees to have a genuine physical presence on the island.
• All licensees will now be required to have at least one local employee (in addition to a director), a number that rises to three after five years of licensure.
• Companies must also maintain “dedicated” and “operationally independent” physical office premises in Curacao.
• The requirements will become compulsory from 1 January 2026, marking a major step in the professionalisation of one of the world’s largest offshore licensing jurisdictions.

The gambling regulator in Curacao has published new guidelines that will require all its licensed operators to establish and maintain a genuine physical presence on the island, a landmark move designed to end the jurisdiction’s long-standing “postbox company” model.

The new “local substance requirements” are a central component of the country’s sweeping new regulatory framework, the National Ordinance on Games of Chance (LOK). They represent the most significant and concrete step yet in Curacao’s ongoing effort to modernise its framework and align with international standards.

Ending the ‘Postbox’ Model

For years, Curacao has been criticised for its “postbox” model, a practice where international operators hold a Curacao licence but have no substantive physical presence-such as staff or offices-on the island. This model has drawn fire from other regulators and industry bodies for its perceived lack of meaningful oversight.

The new requirements directly attack this practice by mandating a tangible, local footprint for all B2C and B2B licence holders.

The Specific Requirements

Under the new rules, which become compulsory from 1 January 2026, all licensees must satisfy two key conditions:

1. Local Employees: Companies must have at least one key person employed and physically located in Curacao (this is in addition to the required local Managing Director). After the five-year mark of holding a licence, this minimum requirement will increase to three local employees.
2. Physical Office: Licensees must “maintain dedicated office premises in Curacao.” The guidance specifies that these offices must be operationally independent and clearly partitioned from other business activities.

While there are some provisions for exemptions, these are expected to apply mainly to smaller, start-up operators.

A Market in Transition

These new substance requirements are part of the much broader LOK reform process, which is also introducing stricter standards for player protection, KYC, responsible gambling, and marketing. The regulator has been clear that it is moving away from its previous, more hands-off approach.

This is a clear and determined effort by Curacao to shed its reputation as a light-touch, low-cost jurisdiction and to enhance its credibility on the global stage. For operators, it means the cost and complexity of holding a Curacao licence are set to increase significantly. For the jurisdiction itself, it’s a calculated move designed to secure its long-term future as a more respected and sustainable licensing hub.