REGULATORY REFORM
In the long term, the impact of supplier regulation may prove every bit as significant as the direct licensing of operators. If implemented effectively, it has the potential to improve transparency, strengthen market integrity, raise industry standards and contribute to the overall perception of Curaçao as a regulated gaming jurisdiction. B2B providers outside Curaçao An often-overlooked aspect of the new framework is that the LOK does not focus exclusively on suppliers established in Curaçao. While Curaçao-based suppliers will ultimately be required to obtain a supplier license under the LOK, foreign suppliers offering such services to Curaçao-based B2C license holders (Operators) are not entirely outside the regulatory perimeter. Under the new regime, foreign B2B providers that offer critical gaming-related goods or services to Curaçao-licensed operators will be required to register online with the Curaçao Gaming Authority. This reflects the reality that many essential functions within the modern gaming industry are performed by businesses located outside the jurisdiction. Game studios, platform providers, sportsbook suppliers, KYC providers, payment technology companies and other specialized service providers frequently operate on a cross-border basis while supporting Curaçao-licensed operators. The registration requirement serves several regulatory objectives. It provides the CGA with greater visibility over the wider ecosystem supporting licensed operators, enables the regulator to identify who is performing critical outsourced functions and reduces the risk that key operational components remain entirely outside the regulator's field of view. For foreign suppliers, registration is considerably less burdensome than full licensing. Nevertheless, it signals a clear shift in Curaçao's regulatory philosophy. Rather than limiting oversight to entities physically established within the jurisdiction, the CGA is seeking greater transparency across the entire supply chain. What will players notice? Ultimately, the success of any gaming reform should not be measured solely by licensing procedures, compliance
frameworks or regulatory architecture. It should also be measured by whether consumers experience a safer and more reliable gaming environment. The LOK places far greater emphasis on player protection than Curaçao's previous framework 7 . Consumer protection, responsible gambling and the prevention of gambling-related harm are now embedded within the regulatory framework, while the Curaçao Gaming Authority has also been granted enhanced supervisory and enforcement powers. Operators are expected to implement measures aimed at preventing underage gambling, identifying vulnerable players and promoting responsible gaming. Whether players will immediately notice a difference, however, remains uncertain. Historically, criticism of Curaçao was often less about the absence of rules and more about concerns regarding enforcement and direct supervision. Complaints relating to delayed withdrawals, disputed account closures and difficulties obtaining meaningful regulatory intervention regularly raised questions about the effectiveness of the existing framework. The transition to a direct licensing regime seeks to address these concerns. By establishing a direct relationship between the regulator and individual operators, the CGA is in a stronger position to supervise licensees, investigate complaints and take enforcement action where needed. Yet consumers are unlikely to judge the success of the LOK on legislative provisions. They will judge it on practical outcomes: are complaints handled efficiently and transparently, are operators sanctioned when misconduct occurs, and does a Curaçao license provide greater confidence that an operator is subject to genuine oversight? The answers will emerge only over time. Regulatory confidence is built through consistent supervision and enforcement rather than legislation alone. If the CGA demonstrates a willingness to intervene where operators fail to meet their obligations, the reforms may gradually strengthen both consumer confidence and Curaçao's broader reputation as a regulated gaming jurisdiction. For that reason, responsible gaming and player protection may ultimately prove the most important measures of whether the LOK has achieved its objectives.
Malta: the regulatory benchmark Any discussion of where Curaçao is heading benefits from
7 Action CGA regarding unlicensed parties: https://portal.cga.cw/uploads/publications/1IbMHtQhvVOo7GkCFYx9jq6tS1wxMZlWckDMNG6T.pdf
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IMGL MAGAZINE | SEPTEMBER 2026
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