Curaçao T&C Compliance 2026: Six Months to Get It Right
May 18, 2026
Every B2C license holder operating under Curaçao’s Landsverordening op de Kansspelen (LOK) has until October 8, 2026 to bring their terms and conditions (T&Cs) into full compliance with the Curaçao Gaming Authority’s (CGA) new policy.
The CGA’s Policy Guideline: Terms and Conditions (Version 1.0, April 2026) sets out a comprehensive framework covering how players accept your T&Cs, how you handle dormant accounts, crypto remittances, and anti-money laundering (AML) obligations. Curaçao T&C compliance 2026 affects the structure, content, and legal standing of every player agreement you have in place. For context on the regulatory journey that brought us here, see our guide on the Curaçao gaming license and the LOK reforms.
Six months is enough time to get this right — and we are here to assist you with this.
What the New CGA Policy Actually Requires
Your most current version of T&Cs must be available to players at all times across your website, mobile platform, and any other delivery channel, and accessible within one click from your homepage, registration page, and player account area.
Beyond that, the policy requires your T&Cs to prominently disclose your legal name, registered address, Chamber of Commerce number, and CGA license details. If you operate multiple brands, each must clearly identify which products fall under CGA regulation and flag any redirection to a non-CGA entity. Furthermore, it must state that the laws of Curacao govern the relationship with the player and that disputes must be submitted to the courts of Curacao. Eligible jurisdictions, minimum age, third-party registration prohibitions, and rules on duplicate and dormant accounts must all be covered.
Explicit Consent — Passive Acceptance Is Gone
Passive acceptance — phrases like “by using this site you accept our terms” — is no longer sufficient. Players must actively acknowledge the T&Cs at registration, for example by ticking a checkbox. Material changes require active re-acceptance, supported by notification that references the specific clauses changed, the effective date, and a direct link to the updated document. Retrospective amendments are largely prohibited, except where a change does not disadvantage the player or corrects a clear error.
Operators must also maintain a full archive of T&C versions from December 24, 2024 onwards — the date the LOK came into force — and make these available to the CGA on request.
Financial Disclosures, KYC, and the AML Threshold
Operators must provide a complete overview of all deposit and withdrawal methods, including expected processing times for each. Withdrawal conditions — including any restrictions on withdrawing unwagered funds — must also be stated, along with identity verification requirements that apply particularly where cumulative deposits and withdrawals exceed XCG 4,000 (approximately EUR 2,000).
KYC: What Your T&Cs Must Cover
Your T&Cs must make clear that KYC will be required of players, provide an overview of what this entails and when it comes into effect, including the documentation that may be required and what will happen if a player does not provide it or cannot be sufficiently verified. Where KYC detail is held in a standalone policy rather than within the T&Cs themselves, a direct reference or link to that policy must be included.
The policy further requires your T&Cs to explain that all transactions are monitored for AML and counter-terrorism financing (CTF) compliance, that unusual or suspicious activity will be reported to relevant authorities under Curaçao law, and that player data is screened against sanctions and politically exposed persons (PEPs) lists. The XCG 4,000 threshold is not a standalone rule — it sits within this broader AML/CTF framework, and your T&Cs must reflect it accordingly.
Operators whose AML health checks are not current should treat this deadline as a prompt to review both documents together.
Crypto-Specific Obligations
For operators accepting cryptocurrency, the obligations go further. Your T&Cs must address scenarios that standard payment terms do not cover: lost or unavailable wallets, deactivated or non-compliant wallets, sanctioned addresses, delisted tokens, and chain forks. Your T&Cs must also explicitly confirm that you are not a financial institution and that no interest is owed or paid on deposited player funds.
Bonus Terms, Dormant Accounts, and Additional Requirements
Bonus terms must be clearly disclosed — either in the main T&Cs or a linked bonus document — and players must explicitly accept them before participation. Wagering requirements, expiry periods, forfeiture conditions, withdrawal restrictions, and cashability of bonus funds must all be spelled out.
Dormant account rules must define inactivity criteria, the consequences of dormancy, and your notification obligations. Any associated fees must be fair, proportionate, and disclosed in advance. Our Policies and Procedures team can help you structure these sections correctly.
Several further requirements are easy to overlook but equally enforceable:
- Wager cancellation: T&Cs must address what happens when events, bets, or wagers are cancelled, including for odds errors, software bugs, and live dealer mistakes, with refund procedures defined.
- Fairness and game rules: T&Cs must confirm all games use certified random number generators (RNGs) and explain how results are determined for fixed odds and live dealer products.
- Player complaint policy: the T&C must detail or provide a link to the complaints policy including complaint handling and escalation procedures such as the ADR company. Final provisions: A severability clause, entire agreement clause, player support contact details, and a statement confirming periodic T&C review must all be included.
The Enforcement Stakes
Non-compliance constitutes a formal breach of Article 11 of your License Conditions. Consequences range from directives to amend T&Cs within a set timeframe and administrative fines to license suspension or revocation.
The English-language current version of your T&Cs must be uploaded to the CGA portal at all times. Multi-brand operators must upload all versions. The CGA may request historical versions at its discretion. Furthermore in order to strengthen its enforceabitily in Curacao, it is advisable to submit the latest copy of your T&C to the court of Curacao for registration. For a full view of your obligations under the LOK, our legal compliance team is ready to assist.
Frequently Asked Questions
What is the deadline for Curaçao T&C compliance in 2026?
The CGA policy (Version 1.0) was released in April 2026 and enters into force six months from that date. All B2C license holders must have fully compliant T&Cs uploaded to the CGA portal by October 8th, 2026.
What happens if my T&Cs are not compliant by the October 2026 deadline?
Non-compliance is a formal breach of your License Conditions. The CGA may issue a directive to correct your T&Cs within a set timeframe, impose administrative fines, or — in serious cases — suspend or revoke your license.
What does the XCG 4,000 threshold mean for my T&Cs?
Your T&Cs must explicitly state that enhanced identity verification applies once cumulative deposits and withdrawals exceed XCG 4,000 (approximately EUR 2,000). They must describe what that verification entails, when it is triggered, and what documentation may be required — in line with your AML/CTF policy.
Getting Your T&Cs Right Is an Opportunity
Compliance deadlines feel like pressure. In practice, this one is an opportunity to build a cleaner, more transparent player relationship — one that stands up to regulatory scrutiny and reduces the risk of disputes down the line.
We have been in Curaçao since 2005 and have supported operators through every significant regulatory shift in the market. If you need support reviewing, restructuring, or rewriting your T&Cs ahead of October 8, 2026, reach out to our Curaçao compliance services team today.
Written by Arran McCarthy
