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The CGA is rejecting 4 in 10 applications.

Most rejection feedback in 2026 tracks back to three things: a paper-only Curaçao office that fails the new substance test, an AML programme that does not survive CGA scrutiny, or technical certificates that do not match the games actually integrated. None of these are hard problems to solve. They are unforgiving of shortcuts.

This is the planning document I use with operators launching new products under LOK. It walks you through the six phases of a clean B2C filing — corporate, local presence, documentation, AML/CFT, GLI certification, and post-grant obligations — with watch-outs on each phase mapped to the failure modes the CGA is actually rejecting on.

Use it before you talk to corporate-services agents, before you sign with a platform provider, and definitely before you wire the €4,592 application fee.

What is inside the PDF
  • The current LOK fee schedule — application, annual, domain, UBO, certificate-request fees, all in one table
  • Six-phase application checklist with 30+ checkable items, from pre-application strategy to post-grant obligations
  • The three rejection patterns the CGA is bouncing applications on in 2026, with a watch-out call-out for each phase
  • Realistic year-one budget figure with the assumptions behind it

Eight pages. Straight to your inbox.

No drip campaign, no newsletter you did not ask for. One email with the PDF, one follow-up if you indicated you are mid-application. That is it.

Your details land in my inbox. I do not share your address with vendors or partners. Unsubscribe in one click if the follow-up is not useful.

Founders launching a real B2C product.

The checklist is built for operators who plan to actually run from Curaçao under the new LOK regime — not for buyers of shelf companies hoping to short-circuit the substance requirements. The CGA is closing those doors and this document will not help you find new ones.

It is most useful if you are between deciding "Curaçao is the jurisdiction" and "we are wiring the application fee". That is where the most expensive mistakes get made.

Operator-side. Independent.

I work directly with operators on licensing strategy, multi-market entry, and CRM execution. The checklist captures what I would walk a new founder through in a half-day pre-filing workshop — distilled, with the order of operations that actually matters.

Compiled May 2026 from public CGA guidance and live LOK implementing decrees. Informational, not legal advice — always confirm with Curaçao counsel before you file.

Questions before you download.

Is the old Curaçao master license still valid in 2026?

No. The NOOGH master/sub-license framework was fully replaced when the LOK (Landsverordening op de Kansspelen) came into force on 20 December 2024. Existing sub-licensees had to transition through the CGA grandfathering window. New applicants now apply directly to the CGA for either a B2C operator licence or a B2B supplier licence.

How much should a 2026 Curaçao application realistically cost in year one?

Official CGA fees come to €4,592 application + €47,450 annual B2C licence fee. Realistic year-one budget is around €55,000 once you add Curaçao counsel, incorporation, GLI-aligned technical certification, and the local office. Capital reserves equal to six months of operations are required on top.

How long does CGA review take, and what is the rejection rate?

Eight to sixteen weeks for a clean application, with most clean files clearing in eight to twelve. Around 38% of 2025 applications were rejected — almost always on three failure modes: thin AML documentation, a paper-only Curaçao office that fails the substance test, and technical certificates that do not map to the games actually integrated.

Does a Curaçao licence cover the EU and other regulated markets?

No. Curaçao alone does not cover the Netherlands, France, Spain, Germany, the UK, Italy, or other markets with their own licensing regimes. Curaçao remains useful for parts of LATAM, EU markets that accept third-country licences, and as a stepping-stone jurisdiction. Map every target market to acceptance status before you build to it.

What is in the PDF?

Eight pages. The current LOK fee schedule. A six-phase application checklist covering pre-application strategy, corporate structure and local substance, the documentation pack, AML/CFT and responsible-gambling infrastructure, technical and game certification, and submission/post-grant obligations. Plus three "watch-out" callouts mapped to the most common rejection causes.

Want a second set of eyes
on your actual application?

The checklist is the planning document. If you would like a 30-minute review of where you are in it — what is solid, what is thin, what is going to bounce — message me and tell me operator type, current stage, and timeline. Same-day reply.

iGB London · July
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