Curaçao Supplier Licensing: CGA Urges Local B2B Suppliers to File Before 1 September 2026
The Curaçao Gaming Authority (CGA) is approaching a key stage in the implementation of Curaçao’s new B2B supplier regime. Suppliers established in Curaçao that provide critical gaming services or goods are strongly encouraged to submit their supplier licence applications no later than 1 September 2026.
That date is important, but it is not the statutory compliance deadline. The CGA recommends early filing to facilitate processing before 24 December 2026, when delayed supplier licensing and operator-side registration provisions under the National Ordinance on Games of Chance (LOK) become effective.
The rules also extend beyond Curaçao-based B2B companies. Foreign suppliers serving CGA-licensed operators will need to register with the authority, while B2C operators will have to ensure that critical suppliers in their supply chain are registered.
For suppliers, operators, game studios, sportsbook technology businesses and aggregators, this leaves limited time for regulatory classification, licensing preparation and supply-chain remediation. For readers’ convenience, we have placed the key official sources and regulatory materials at the end of this article.
Publish Date
28 Aug 2026
Reading Time
12 minutes
Category
Legal News
Jurisdiction
Curaçao
Curaçao’s supplier regime is approaching its enforcement stage
The LOK entered into force on 24 December 2024 and replaced Curaçao’s previous offshore gaming framework with a system of direct regulatory supervision by the Curaçao Gaming Authority. The legislation created separate rules for remote gaming operators and suppliers of critical gaming services and goods.
However, two important provisions were deliberately delayed.
Why 24 December 2026 matters
Article 15.10(3) of the LOK provides that Article 1.5 and Article 5.16(4) enter into force two years after the ordinance itself. Since the LOK took effect on 24 December 2024, those provisions become effective on 24 December 2026.
The distinction matters because these are the provisions that establish two central restrictions.
Under Article 1.5, providing critical services or goods in or from Curaçao without the required supplier licence is prohibited. Under Article 5.16(4), a gaming licensee may not purchase critical services or goods from an unregistered supplier.
The CGA consequently describes 24 December 2026 as the point from which supplier licensing and supplier registration requirements become fully mandatory and enforceable.
Why 1 September 2026 is different
The 1 September 2026 date comes from the CGA’s regulatory guidance rather than directly from the LOK.
The authority has strongly encouraged Curaçao-established suppliers already providing critical services or goods without a CGA supplier licence to apply by that date. Its stated purpose is to facilitate processing and improve the likelihood of licensing before 24 December.
This distinction should be understood correctly. Missing 1 September does not, by itself, mean that a statutory licensing deadline has been breached. It does, however, reduce the available processing window before the legal prohibition becomes effective.
That risk is significant because Article 5.14 gives the CGA eight weeks to decide a supplier licence application, with a possible extension of up to a further eight weeks.
Which suppliers need a Curaçao supplier licence?
The most important clarification from the CGA concerns the supplier’s place of establishment.
A business supplying a Curaçao operator does not automatically need a Curaçao B2B licence merely because its customer holds a CGA licence.
Suppliers established in Curaçao
Suppliers established in Curaçao that provide critical services or goods will need both:
- a valid supplier licence issued by the CGA; and
- registration with the CGA under the supplier registration framework.
Under Article 5.13, the supplier licence may be granted to a Curaçao corporation or closed corporation organised under Curaçao law and statutorily established there.
The CGA’s current portal already accepts supplier licence applications and states that all such applications must be submitted through its online system. Supplier application forms are publicly available.
The current CGA fee schedule lists a EUR 4,592 non-refundable B2B application fee. It also lists an annual EUR 24,490 CGA supervisory fee for a supplier licence, while no separate National Treasury licence fee is currently charged for B2B licences.
Suppliers established outside Curaçao
The position is different for foreign suppliers.
The CGA’s June 2026 announcement expressly confirms that suppliers established outside Curaçao do not need a Curaçao supplier licence solely because they provide critical services or goods to a Curaçao gaming licence holder.
They will, however, need to be registered with the CGA by 24 December 2026 where they provide critical services or goods to a CGA-licensed operator.
This distinction is particularly important for international game studios, sportsbook technology businesses and aggregators with no Curaçao establishment. Their immediate task is generally registration readiness rather than creating a Curaçao entity purely to obtain a supplier licence.
Existing B2B licence holders still need registration
Licensing and registration should not be treated as interchangeable.
The CGA states that locally established suppliers must be both licensed and registered. Its planned registration process is also intended for locally licensed suppliers as well as foreign suppliers.
An existing supplier licence therefore does not remove the separate registration requirement.
What counts as a critical service or good?
The LOK defines critical services and goods by reference to their importance to the gaming activity. The definition covers gaming-related services or goods that are indispensable in determining game outcomes, or whose failure could significantly affect a licensee’s ability to meet its regulatory obligations.
The CGA has supplemented that legal definition with an illustrative list.
Categories currently identified by the CGA
The authority currently identifies the following categories, among others:
- RNG game manufacturers;
- live dealer studio providers;
- poker and other peer-to-peer software suppliers;
- lottery providers;
- sportsbook software suppliers;
- bet capture and settlement providers;
- sports betting line and odds providers; and
- game aggregators.
The CGA expressly states that this list is illustrative and may be expanded or amended. It should therefore not be treated as an exhaustive statutory perimeter.
Suppliers outside the list may still require analysis
A company should not assume it falls outside the framework simply because its commercial description does not appear on the CGA’s list.
The decisive issue is the function performed and whether the service or product satisfies the legal concept of a critical service or good. That can require a review of the product architecture, contractual arrangements, integration with the operator and the role played in game operation or settlement.
Where the position is unclear, obtaining a regulatory perimeter assessment or seeking clarification from the CGA is preferable to treating an informal industry label as decisive.
Supplier registration is separate from licensing
Registration is particularly important because it creates a regulatory obligation for both suppliers and the B2C operators using them.
What Article 5.16 requires
Article 5.16 requires the CGA to maintain a public register of suppliers providing critical services or goods to remote gaming licence holders.
The register must make it possible to establish the activities performed by registered suppliers and the status of their registered office. The provision also requires the CGA to register suppliers that present themselves for registration.
The crucial operator-side rule appears in Article 5.16(4): a licensee may not buy critical services or goods from an unregistered supplier. That restriction becomes effective on 24 December 2026.
Registration is expected to open in October 2026
The CGA’s accessible 24 June 2026 announcement states that further information about supplier registration will be published separately.
It also says the authority expects registration for both locally licensed and foreign suppliers to open in October 2026.
“Expected” is important here. October is the regulator’s announced implementation timetable, rather than a date fixed in the LOK itself.
Businesses should therefore monitor CGA publications closely instead of assuming that the final forms, fees and procedural requirements are already settled.
What Curaçao-based suppliers should do now
For locally established businesses already providing critical services, the immediate issue is the approaching 1 September 2026 recommendation.
Submit a complete licence application as early as possible
Supplier licence applications must be made through the CGA online portal. The current application process requires official forms and supporting documentation, and the portal warns that incomplete submissions will not be processed until the required information has been supplied correctly.
Given the statutory decision period and potential extension, waiting until late in the year can create an obvious timing problem.
Prepare ownership, governance and financial information
Under Article 5.14, the CGA may assess matters including:
- the applicant’s registered office;
- group ownership and control;
- key persons;
- ultimate beneficial owners;
- liquidity and solvency;
- the purpose and viability of the business; and
- the reliability and suitability of the operations and systems used to supply services or goods.
Supplier licensing is therefore not a simple company-registration exercise. Corporate records, ownership data, governance arrangements and operational materials need to be internally consistent and capable of regulatory verification.
Filing does not guarantee approval before December
The CGA’s 1 September recommendation is designed to increase the likelihood of obtaining a supplier licence before 24 December. It is not an assurance that applications filed by that date will automatically be approved.
Businesses with incomplete corporate structures, outstanding due diligence or material regulatory gaps should therefore address those issues in parallel with the application process.
What foreign suppliers should prepare before registration opens
Foreign suppliers have more limited formal action available until the registration process itself opens. That does not mean they should wait until October to begin preparing.
Confirm whether the service is critical
The first task is regulatory classification.
A provider should identify exactly which services or goods it supplies to Curaçao-licensed operators and test those activities against the LOK definition and CGA categories.
Map Curaçao-facing contracts and group entities
International groups should establish which legal entity contracts with each CGA licensee.
This is particularly important where development, distribution, aggregation, licensing of intellectual property and customer contracting sit in different entities. Registration should reflect the actual supplier relationship rather than simply the group’s commercial brand
Prepare current corporate and service information
Article 5.16 requires the public register to identify supplier activities and the status of the supplier’s registered office.
Until the CGA publishes the final registration instructions, firms should avoid assuming that particular documents or disclosure thresholds will be required. They can, however, ensure that basic corporate, ownership, establishment and service information is current and readily available.
What B2C operators need to do before 24 December 2026
The supplier framework is not solely a B2B compliance exercise.
From 24 December 2026, using an unregistered provider of critical services or goods can create a compliance issue for the Curaçao-licensed operator itself.
Build a critical-supplier inventory
Operators should identify their full gaming technology chain rather than reviewing only direct game studios.
That exercise should establish the service performed, contractual supplier, jurisdiction of establishment, whether a Curaçao supplier licence is required, and whether the supplier is expected to complete CGA registration.
Game aggregators deserve particular attention because a single commercial relationship can sit between the operator and a much larger network of underlying game manufacturers.
Track supplier registration status
Once the new registration process becomes available, operators should implement a method for monitoring supplier status ahead of the December deadline.
This can form part of vendor onboarding, procurement controls and ongoing regulatory compliance rather than being treated as a one-off exercise.
Review supplier contracts
Operators should also consider whether existing agreements adequately address regulatory status.
Depending on the relationship, useful contractual protections may include requirements to maintain relevant licences and registrations, provide evidence of regulatory status, notify material changes and cooperate with a transition if continued use of the supplier becomes legally problematic.
These are commercial risk-management measures rather than specific clauses prescribed by the CGA, so the appropriate drafting will depend on the contract and operating model.
Curaçao supplier compliance timeline
| Date | Development | Practical significance |
|---|---|---|
| 24 December 2024 | LOK entered into force | Start of the two-year delayed commencement period for Articles 1.5 and 5.16(4) |
| 1 September 2026 | CGA-recommended application date for relevant Curaçao suppliers | Strong regulatory recommendation, but not the statutory deadline |
| October 2026 | Supplier registration expected to open | CGA timetable; further registration information remains to be published |
| 24 December 2026 | Articles 1.5 and 5.16(4) become effective | Supplier licensing and operator-side registration restrictions become enforceable |
What businesses should do before December
The remaining preparation depends on where the business sits in the Curaçao gaming supply chain.
Curaçao-established suppliers
Businesses supplying critical services or goods in or from Curaçao should prioritise the supplier licence application and prepare simultaneously for the separate registration process.
Where an application has not yet been filed, the CGA’s 1 September 2026 recommendation now makes timing particularly important.
Foreign suppliers
Foreign suppliers should determine whether their services fall within the critical-services perimeter and identify the legal entity that will need to register.
They should also monitor the CGA for the final registration procedure rather than relying on assumptions based on the licence application portal.
Curaçao B2C operators
Operators should map critical suppliers now and establish a clear internal owner for registration verification.
Waiting until December could leave insufficient time to replace or remediate a material supplier relationship where registration is delayed.
Legasset assists iGaming operators, B2B suppliers and investors with licensing strategy, regulatory structuring, market entry and compliance gap analysis. Our work may include supplier-perimeter assessments, Curaçao licensing preparation, supply-chain reviews and regulatory support for gaming businesses entering or restructuring their presence in the jurisdiction.
Curaçao Supplier Licensing FAQ
Is 1 September 2026 the legal deadline for a Curaçao supplier licence?
No. 1 September 2026 is a CGA-recommended filing date, intended to facilitate processing and increase the prospect of licensing before December.
The legally significant date is 24 December 2026, when Article 1.5 becomes effective.
When do Curaçao supplier licensing requirements become enforceable?
The delayed supplier licensing prohibition under Article 1.5 becomes effective on 24 December 2026.
The operator-side prohibition against buying critical services or goods from an unregistered supplier under Article 5.16(4)becomes effective on the same date.
Does a foreign game supplier need a Curaçao B2B licence?
Not merely because it supplies a CGA-licensed operator.
The CGA has expressly stated that the Curaçao supplier licence requirement applies to suppliers established in Curaçao. Foreign suppliers providing critical services or goods must instead comply with the CGA registration requirement.
Do existing Curaçao B2B licence holders also need to register?
Yes. The CGA treats licensing and supplier registration as separate requirements.
Its June announcement states that Curaçao-established suppliers must hold a valid licence and be registered, while the registration process is intended to cover locally licensed and foreign suppliers.
When will Curaçao supplier registration open?
The CGA’s accessible 24 June announcement says it expects the registration process to open in October 2026.
Further information about the registration process is still to be published through the regulator’s official channels.
Can a Curaçao operator use an unregistered critical supplier after 24 December 2026?
Article 5.16(4) states that a licensee may not buy critical services or goods from an unregistered supplier.
That provision becomes effective on 24 December 2026, making supplier registration relevant to the operator’s own compliance position.
Which suppliers does the CGA currently consider critical?
The CGA currently identifies RNG game manufacturers, live dealer studios, poker and other peer-to-peer software suppliers, lottery providers, sportsbook software providers, bet capture and settlement providers, sports betting line and odds providers, and game aggregators.
The list is illustrative and can be changed or expanded, so businesses outside these labels may still require a perimeter assessment.
Curaçao Supplier Licensing: Official CGA and LOK Materials
The CGA’s 24 June 2026 announcement explains the 1 September 2026 recommended filing date, the distinction between Curaçao-established and foreign suppliers, the expected October registration process and the 24 December 2026compliance date.
II. Curaçao Gaming Authority — National Ordinance on Games of Chance, Official English Translation
The official English translation of the National Ordinance on Games of Chance contains the supplier licensing provisions, the definition of critical services and goods, the supplier register rules and the delayed commencement provisions relevant to 24 December 2026.
III. Curaçao Gaming Authority — Online Gaming Portal
The official CGA portal provides access to supplier licence application information, regulatory forms, current guidance, announcements and other materials relevant to Curaçao gaming licence holders and suppliers.
IV. Curaçao Gaming Authority — Supplier Licence Application Forms
This section of the CGA portal contains the forms and application materials used by Curaçao-established suppliers preparing a supplier licence application under the new regulatory framework.
V. Curaçao Gaming Authority — LOK Fees Version 2.0
The current CGA fee schedule sets out the application and supervisory fees applicable under the LOK, including the fees relevant to B2B supplier licensing.
