REGULATORY REFORM
ability to supervise its activities or hold key individuals accountable when problems arise. The LOK represents a deliberate move away from that model. License holders are intended to be established under Curaçao law, maintain their statutory seat in Curaçao and demonstrate genuine local management arrangements and operational presence rather than merely a corporate registration. The rationale is straightforward: effective supervision becomes considerably more difficult when key decision-makers, operational functions and corporate records are scattered across multiple jurisdictions, and substance requirements seek to bridge that gap by bringing operators closer to the regulator. Nevertheless, establishing and maintaining a meaningful presence in Curaçao requires investment. Local directors, office facilities, personnel and support functions all increase operational expenditure. Businesses that historically relied on highly decentralized corporate structures may need to reconsider aspects of their governance arrangements to meet evolving expectations. There is also another side to the equation. While substance requirements involve investments, they also enhance the value of the license itself. A regulatory framework built upon genuine local presence and accountability is likely to inspire greater confidence among banks, payment service providers, software suppliers, investors and foreign regulators. In practice, the introduction of substance requirements reflects a broader strategic decision by Curaçao to compete on more than speed, accessibility and cost. Economic substance has become an increasingly important feature of gaming regulation worldwide and is already embedded within many mature licensing jurisdictions. The ultimate question is whether the market will appreciate the additional investments as a burden or as an added value to participate in a more credible and sustainable regulatory environment. The expanding role of suppliers Historically, gaming regulation has focused primarily on B2C operators, because they interact directly with players and ultimately bear responsibility for compliance with licensing conditions. Increasingly, however, regulators have recognized that many of the most important risks within the gaming
ecosystem originate much earlier in the chain. Software suppliers determine how games function, platform providers influence operational integrity, payment providers facilitate financial transactions, and technology vendors often control critical aspects of customer interactions, data management and compliance infrastructure. The LOK reflects this evolving regulatory philosophy by introducing a licensing framework for suppliers of critical gaming-related goods and services established in Curaçao. Importantly, this obligation does not take effect immediately. The legislation provides a delay of entry for two years, meaning supplier licensing requirements are becoming effective at the end of 2026. This transitional period has given both the regulator and the industry time to prepare for an expansion of Curaçao's regulatory framework, acknowledging that supplier supervision presents different challenges from operator supervision and will require careful preparation on both sides 6 . From a regulatory perspective, the introduction of supplier licensing addresses a longstanding gap in the oversight framework. Modern gaming businesses often rely on a complex network of third-party providers. Critical functions such as game development, platform management, sports betting infrastructure, payment processing, customer verification and data security are frequently outsourced. If those service providers remain entirely outside the regulatory perimeter, significant risks may arise that are difficult for regulators to monitor or control. The practical implications for B2B suppliers could therefore be considerable. Companies that previously operated with little direct regulatory engagement may find themselves subject to reporting obligations and compliance expectations, somewhat similar to those imposed on operators. In particular, issues relating to ownership transparency, governance, AML controls and operational integrity are likely to receive increased scrutiny. At the same time, supplier licensing may create important commercial advantages. A licensing framework may provide operators with greater confidence when selecting technology partners and thus will encourage more robust due diligence throughout the supply chain.
6 Publication on the B2B license and supplier requirements: https://www.linkedin.com/posts/curacao-gaming-authority_supplier-license-activity- 7475522184057364480-5YTs?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAEDdjIB9DJYVkkcI1OqA5IJKV8VmfeCY-w
IMGL MAGAZINE | SEPTEMBER 2026
PAGE 39
Made with FlippingBook flipbook maker