Curaçao Supplier Licensing Requirements: What the CGA’s December Deadline Means for Your Business
26 June, 2026
Before we get to deadlines, let us take a quick — and well-deserved — victory lap, Curaçao style. 🌍⚽
- The smallest nation at the World Cup? ✅
- Our very first goal on football's grandest stage? ✅
- Our first hard-earned point in the group stages? ✅
For a country of +150,000 people, this is not just participation — it is history in the making.
We are proud to celebrate this incredible achievement together with you.
Now, for the next milestone: your Curacao-focused B2B activities.
Read on to see what is next and what is required.
If your business supplies critical services or goods to Curaçao gaming license holders, you have until 24 December 2026 to comply with the Curaçao Gaming Authority’s (CGA) supplier licensing and registration requirements under the National Ordinance on Games of Chance (LOK). That deadline is now less than six months away — and based on the CGA’s formal announcement issued on 24 June 2026, the authority’s message is unambiguous: act now, not in December.
Here is what the new framework requires, who it applies to, and what you need to do next.
What Does the LOK Require from Suppliers?
The LOK establishes two distinct obligations for suppliers of critical services or goods to Curaçao gaming operators. Our full guide to LOK compliance requirements covers the broader framework, but the supplier-specific rules break down as follows.
Under Article 1.5(1), it is prohibited to provide critical services or goods in or from Curaçao without a valid supplier license issued by the CGA. Under Article 5.16(4), holders of a CGA gaming license may only work with suppliers that are registered with the CGA. Together, those two provisions create a closed ecosystem: operators must use registered suppliers, and locally established suppliers must be licensed.
The CGA has provided a two-year transitional period since the LOK entered into force. That window closes on 24 December 2026, after which both requirements become fully mandatory and enforceable.
Are You a Local Supplier or a Foreign Supplier? The Rules Differ.
This is one of the most practically important clarifications in the CGA’s announcement, and one that has caused confusion across the industry.
Suppliers established in Curaçao
Suppliers established in Curaçao must hold a valid CGA supplier license and be duly registered with the CGA. Both requirements apply. Article 1.5(1) LOK makes this a hard legal prohibition: providing critical services without a license is not permitted.
Suppliers established outside Curaçao
Suppliers established outside Curaçao are not required to obtain a Curaçao supplier license. However, if they provide critical services or goods to CGA gaming license holders, they must register with the CGA by 24 December 2026. Registration is mandatory; licensing is not.
The practical implication is that a software provider based in Malta, the Netherlands, or elsewhere in Europe does not need a Curaçao supplier license — but it does need to complete CGA registration before the end of the transitional period.
What Counts as a Critical Service or Good?
The CGA’s current policy framework, as set out in the 24 June 2026 announcement, identifies the following as critical services or goods: 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.
These categories are illustrative and may be expanded by the CGA over time. If your product or service falls into any of these categories — or into a category that could reasonably be considered critical to the operation of a remote gaming license — we recommend treating registration as a requirement and preparing accordingly.
What Is the Application and Registration Timeline?
Local suppliers: apply by 1 September 2026
For suppliers established in Curaçao applying for a license, application forms and procedures are available through the CGA Online Gaming Portal. The CGA is explicitly encouraging suppliers to submit applications no later than 1 September 2026 — three months ahead of the December deadline — to allow sufficient processing time before enforcement begins.
Foreign suppliers: registration expected to open October 2026
For foreign suppliers, the CGA has confirmed that the supplier registration process is expected to open in October 2026. That leaves approximately two months between the process opening and the enforcement deadline. That is workable, but not generous. Suppliers in this category should begin their internal preparations — entity documentation, ultimate beneficial owners (UBOs), compliance records — now, so they are ready to submit the moment registration opens.
What Do B2C License Holders Need to Know?
The CGA’s announcement also places obligations on operators, not just suppliers. Under Article 5.16(4) of the LOK, holders of a CGA gaming license may not obtain critical services or goods from suppliers that are not registered with the CGA.
That means operators have a compliance obligation that runs in parallel with their suppliers’ own obligations. From 24 December 2026, using an unregistered supplier is a license compliance issue. Operators should begin auditing their supply chain now and confirm that each critical services provider is either already registered or on track to complete registration before the deadline.
This sits alongside other active CGA compliance deadlines this year. If you are a B2C license holder, it is worth reviewing our guide to other CGA compliance deadlines in 2026, including the T&C compliance deadline of 8 October 2026.
EM Group has been supporting operators and corporate services clients across Curaçao since 2005 and has guided clients through every major regulatory transition the jurisdiction has undergone, including the LOK reform. Our team in Curaçao can help operators map their supply chain, identify gaps, and prepare for the December deadline. Review our compliance obligations under the LOK or learn more about the full Curaçao iGaming license application process.
FAQ: Curaçao Supplier Licensing Under the LOK
No. Suppliers established outside Curaçao are not required to obtain a CGA supplier license. They are, however, required to register with the CGA if they supply critical services or goods to CGA gaming license holders. The registration deadline is 24 December 2026.
The CGA has indicated that the supplier registration process is expected to open in October 2026, giving suppliers until 24 December 2026 to complete registration.
The CGA strongly recommends that locally established suppliers submit their license applications by 1 September 2026 — three months before the 24 December 2026 enforcement date — to allow sufficient processing time.
No. Article 5.16(4) of the LOK prohibits CGA gaming license holders from obtaining critical services or goods from suppliers not registered with the CGA. Using an unregistered supplier after the transitional period constitutes a compliance breach.
The CGA’s current framework includes RNG game manufacturers, live dealer studio providers, peer-to-peer software suppliers, lottery providers, sportsbook software suppliers, bet capture and settlement providers, odds providers, and game aggregators. The list may be expanded.
EM Group supports iGaming operators and their corporate structures across Curaçao, Malta, Cyprus and the Netherlands, with licensing support across the UK, the Isle of Man and other key iGaming jurisdictions. Our Curaçao team can help operators and suppliers prepare for the December deadline. Contact us to discuss your situation.
The Bottom Line
The CGA has been clear, consistent, and reasonable in how it has rolled out the LOK supplier framework. The transitional period was two years. The deadline is 24 December 2026. The guidance published on 24 June 2026 leaves no ambiguity about what is required or when.
Whether you are a Curaçao-based supplier preparing a license application, a foreign software provider mapping your registration obligations, or an operator auditing your supply chain, the right time to act is now — not October, and certainly not December.
We recommend contacting the Curaçao Gaming Authority directly for official guidance, or reaching out to our Curaçao team to clarify your specific obligations and plan your path to compliance.
