A gaming licence is the foundation of an iGaming business: banks, payment providers and game studios work with licensed operators. The licensing map has changed: Curaçao replaced master licences with direct licences from its Gaming Authority in December 2024, while international projects often also consider Anjouan (Comoros), whose status is now disputed. We go through how to choose a jurisdiction by target markets, budget and partners, what the new Curaçao requirements change and what an operator with an Anjouan licence risks.
Checked on 25 October 2026. Rules and sources are current as of this date.
What has changed since 2024
Curaçao’s National Ordinance on Games of Chance (Landsverordening op de kansspelen, LOK) has applied since 24 December 2024. Only the Curaçao Gaming Authority (CGA) now issues licences, and the system of master licences and sub-licences is gone. Existing operators received a provisional licence by law for up to six months, extendable by another six (Article 15.1 LOK). A regular LOK licence is issued for an indefinite period (Article 2.1).
Anjouan (Comoros) offers online casino and betting licences citing a 2005 law on computer gaming licensing (the Computer Gaming Licensing Act). In October 2026, according to media reports, the Comoros government publicly disputed the legitimacy of the Anjouan licensing bodies, including the Anjouan Offshore Finance Authority. The Central Bank of the Comoros, in its communiqué on offshore activity, calls fictitious the structures that issue banking and financial licences in the name of Anjouan and Mohéli. The communiqué concerns banking, not gambling directly. We found no formal decision declaring gambling licences invalid, but the risk to an operator is real, because banks and payment providers may not accept such a licence.
In September 2026 the CGA reported unauthorised access to its licensing portal and publication of licensees’ data. On 7 October 2026 it announced that the portal will not return to service and that it is moving to a new platform. According to the CGA, this does not affect the validity of existing licences or operators’ obligations, and portal submission deadlines have been postponed.
LOK requirements for a Curaçao operator
Only an NV (public limited company) or BV (private limited company) company incorporated under Curaçao law with its registered seat there can obtain a licence. It must be managed by at least one director resident in Curaçao, or by a local company with such a director (Article 2.1).
An application is reviewed in two phases (Article 5.1). In the first, the CGA assesses the integrity of beneficial owners, qualifying holders and management, and the applicant’s financial position and viability. It decides within eight weeks of receiving all documents, extendable by at most four weeks. Once the application moves to the second phase, documents are due within four weeks, and the CGA again decides within eight weeks with a possible four-week extension. During the second phase the CGA may grant a provisional licence for up to six months, extendable by at most six.
A licence must be refused in particular if not all beneficial owners are established, if a beneficial owner or holder of more than 25% or a manager was convicted in the eight years before the application of an offence for gain, money laundering or terrorist financing, if the source of funds and wealth is not established, if the applicant lacks sufficient liquid funds to pay expected winnings immediately, if it has no responsible gaming policy or is not registered in goAML (Article 2.2).
Once licensed, presence requirements apply (Article 5.12). For the first four years after the LOK took effect the operator must give permanent full-time work to at least one key person registered in Curaçao who is not its director, and to at least three from the fifth year. It also needs its own office in Curaçao with the usual facilities, used only for business under the licence. There is an exemption for small new companies if, among other things, the company was set up no earlier than one year before applying, its beneficial owners are not involved in other gaming operators and gross gaming revenue stays below NAf 20 million a year (Article 5.12(4)).
Under the CGA fee document of 15 October 2025, a B2C (business to consumer) or B2B (business to business) application costs EUR 4,592 one-off. A B2C operator pays EUR 47,450 a year, of which EUR 24,490 is the licence fee to the Treasury and EUR 22,960 the CGA supervisory fee. A B2B operator pays EUR 24,490 a year.
Why you need a licence
Legality
Operating without a licence is illegal in most countries and can lead to criminal liability and blocking of your domains.
Player trust
Users trust licensed platforms with their money. A licence from a reputable regulator signals fairness.
Partners
Banks, payment systems and leading game providers work with licensed operators only. Without a licence you cannot open a corporate account or connect these partners.
Scaling
A licence opens access to international markets and lets you attract traffic legally.
Expect blocked domains and payment accounts, refusals from game providers and, in many countries, criminal liability for the owners.
We will review your situation and propose a solution for your project.
iGaming licence: jurisdictions compared
The Isle of Man and Kahnawake are also used, usually by established operators. Each has its own fees, conditions and market access, so compare them against your plan.
Licensing steps
Prepare
Collect data on beneficiaries and directors, and write the business plan.
Start hereRegister the company
Incorporate the legal entity in the chosen jurisdiction.
Submit the documents
AML/KYC and responsible gaming policies, a software description and the business model.
ImportantPass due diligence
The regulator checks the founders and key persons, including source of wealth.
Certify the platform
Technical audit and RNG (random number generator) certification against the regulator’s standards.
Receive the licence
After all checks, the licence is issued.
Frequently asked questions
Can I rely on an Anjouan (Comoros) licence?
It carries risk. The Comoros government disputes the legitimacy of the Anjouan licensing bodies, and the Central Bank of the Comoros calls fictitious the structures that issue offshore banking licences in the name of Anjouan. We found no formal decision declaring gambling licences invalid, but banks and payment providers may refuse an operator with such a licence.
Do I need an office and local staff in Curaçao?
Yes. Article 5.12 LOK requires your own office in Curaçao and at least one local key person who is not a director for the first four years, and at least three from the fifth year. Small new companies can be exempt.
How long does a Curaçao licence take now?
Under the LOK the process has two phases of about eight weeks each, with a possible four-week extension per phase. The “one to two months” that was quoted under the old system no longer applies.
Is Curaçao still the cheapest option?
Fees are moderate, but requirements are stricter than under the old sub-licence model: an office, liquidity for player claims and key persons in Curaçao. Compare the full cost, not just the fee.
Can I operate before I have a licence?
No. Accepting players without a licence is illegal in most countries and cuts you off from banks, payment providers and game suppliers.
Which licence should I pick?
It depends on your target markets, budget and partners. Start from where your players are and which payment methods and game providers you need, then compare regimes.
See also: How to choose a jurisdiction for your company registration?; Loot Boxes and Secondary Markets: When a Game Mechanic Becomes Gambling Under EU and US Law; Online casino licence: Curaçao, Malta, Estonia, Anjouan or Tobique; EMI and Payment Institution Licence in the EU, UK and Canada; Responsible gambling and AML for operators. Services: legal services for iGaming.
- CGA: Landsverordening op de kansspelen (LOK), P.B. 2024 no. 157
- CGA: License Fees under the LOK, v2.0, 15.10.2025
- CGA: Transition to a New Regulatory Platform, 07.10.2026
- Malta Gaming Authority: Licence Fees and Taxation
- Central Bank of the Comoros: communiqué on illegal offshore banking activity
- Casino.org: report on the Comoros government position (19 October 2026). A media report, as we could not find the primary government statement
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