Curaçao Postpones Local Substance Requirement Under LOK Until April 2027

The Curaçao Gaming Authority has postponed the Local Substance Requirement under LOK Article 5.12 until April 1, 2027. Learn what this means for gaming operators and compliance planning.

Curaçao Gaming Authority Extends Local Substance Deadline Under LOK

The Curaçao Gaming Authority (CGA) has announced a postponement of the Local Substance Requirement under Article 5.12 of the National Ordinance for Games of Chance (LOK). Under the extension granted by the Minister of Justice, licensed gaming operators will not be required to comply with local substance obligations until April 1, 2027.

This regulatory update forms part of Curaçao’s broader modernization of its online gaming regulatory framework, following feedback from industry stakeholders regarding the operational implementation of local substance requirements.

What Is the Local Substance Requirement Under LOK Article 5.12?

The Local Substance Requirement is intended to ensure that licensed gaming operators maintain a meaningful operational and economic presence in Curaçao, beyond purely offshore or administrative structures.

Key objectives of Article 5.12 include:

• Increasing local workforce participation

• Strengthening governance and decision-making presence in Curaçao

• Ensuring operational accountability and regulatory oversight

• Enhancing Curaçao’s international credibility as a regulated iGaming jurisdiction

The requirement represents a strategic pillar in Curaçao’s effort to strengthen regulatory integrity, transparency, and long-term sustainability in the iGaming sector.

What the Postponement Means for Gaming Operators

Under the revised timeline:

• Operators are not required to meet local substance obligations before April 1, 2027

• Licensees may voluntarily begin implementing local substance earlier

• Authorities will use the extension period to create enabling legal, workforce, and administrative conditions

During this transition, the Ministry of Justice, in coordination with the CGA and industry stakeholders, will focus on:

• Expanding and strengthening the local talent pool

• Improving immigration and work permit processes for qualified professionals

• Building the structural foundation for effective enforcement of Article 5.12

This approach aims to ensure that implementation of local substance requirements is practical, enforceable, and aligned with long-term regulatory goals.

Regulatory Oversight Remains Strong in AML, KYC, and Responsible Gaming

While the Local Substance Requirement has been postponed, Curaçao continues to reinforce regulatory expectations in critical compliance areas, including:

• Anti-Money Laundering (AML)

• Know Your Customer (KYC)

• Responsible gaming

• Player protection and dispute resolution

These areas remain core components of Curaçao’s evolving regulatory framework, supporting the jurisdiction’s reputation as a credible and internationally recognized gaming hub.

Institutional Context Behind the Policy Update

The postponement follows a period of institutional restructuring within Curaçao’s gaming regulatory environment. Oversight of the sector has recently shifted from the Ministry of

Finance to the Ministry of Justice, a move designed to strengthen legal enforcement capabilities and address illegal gaming activity more effectively.

Despite recent governance challenges, Curaçao’s regulators have reaffirmed their commitment to regulatory modernization, stability, and market confidence.

Strategic Implications for iGaming Operators in Curaçao

The extended timeline offers gaming operators a strategic window to plan and structure sustainable local presence models, rather than delaying preparation.

Operators may use this period to:

• Design long-term local substance strategies

• Align corporate governance and accountability frameworks

• Strengthen internal compliance and reporting structures

• Prepare for future supervisory and licensing expectations

Early planning may support smoother regulatory engagement, stronger market credibility, and improved long-term licensing resilience.