Curaçao Gaming Authority gives operators six months to rewrite T&Cs
Table of contents
- The Curaçao Gaming Authority has issued new policy requiring licensed operators to extensively revise their terms and conditions by October 8, 2026.
- Requirements cover account management, financial transparency, cryptocurrency handling, and bonus disclosure, with non-compliance treated as a licence breach.
- The update forms part of the CGA’s broader LOK reform push, which has been shadowed by governance upheaval and integrity concerns since mid-2025.
The Curaçao Gaming Authority (CGA) has introduced sweeping new requirements for the terms and conditions of licensed online gambling operators, setting a six-month deadline for compliance and signalling a more assertive enforcement posture.
The policy, announced on April 8, 2026, significantly expands what operators must disclose to players and how they must structure their contractual obligations. Operators have until October 8, 2026 to comply.
The rules apply to all B2C licence holders under the Landsverordening op de Kansspelen (LOK), Curaçao’s National Ordinance on Games of Chance, which came into force in December 2024.
Transparency demands
The regulator’s headline stipulations centre on the visibility of T&Cs to players. Per policy guidance, the current version must be available at all times in a clear and readable form across all websites, mobile platforms and other delivery channels.
The CGA has tightened disclosure requirements, mandating that T&Cs prominently display core licensee information, including legal identity, registration details and licence credentials. Operators must clearly distinguish which products fall under CGA regulation and flag any redirection to non-CGA entities, addressing concerns around multi-brand structures.
The regulator eliminates passive acceptance and insists on explicit, recorded consent and re-acceptance for material changes, creating an auditable trail. Retrospective changes to T&Cs are largely prohibited unless they do not disadvantage players or correct clear errors.
Responsible gaming and dispute resolution frameworks must be embedded or clearly linked within T&Cs, while fairness provisions must explain how game outcomes are determined, including the use of certified RNGs.
Financial and crypto rules
Financial transparency is a key pillar of the new framework. Operators must provide a full overview of deposit and withdrawal methods, including expected processing times. Withdrawal rules must also specify identity verification requirements, particularly for larger transactions.
Enhanced verification triggers apply at XCG 4,000 (approximately $2,200), aligning operational practices with AML expectations. Operators must also detail how they handle crypto-specific scenarios, including lost wallets, chain forks and sanctioned addresses.
In a notable clarification, operators are required to state explicitly that they are not financial institutions and do not pay interest on player balances, reinforcing the legal distinction between gaming accounts and banking services.
Bonus and account rules
Bonus terms, long a source of player complaints, must be clearly disclosed, explicitly accepted and structured in a way that does not prevent players from reviewing full conditions. Operators must also specify the circumstances under which winnings may be withheld or payouts denied.
Account lifecycle obligations are equally detailed. Operators must define inactivity criteria and potential consequences for dormant accounts, notify players before taking action, and ensure any associated fees are transparent and proportionate.
From an enforcement standpoint, the CGA has adopted a harder line. Non-compliance with the policy constitutes a breach of licence conditions and may result in corrective directives, administrative fines or licence suspension or revocation.
Operators will also be required to upload current and historical versions of their T&Cs to the CGA portal, ensuring ongoing regulatory visibility.
Reform under pressure
The new T&C policy arrives against a turbulent backdrop for the CGA. The regulator’s entire supervisory board resigned abruptly in mid-September 2025, leaving the newly established authority without governance barely three months after launch.
Prime Minister Gilmar Pisas stepped in to assume direct oversight, with formal correspondence handled through the Prime Minister’s Office rather than the Finance Ministry.
That political crisis deepened when Finance Minister Javier Silvania — who had championed the LOK modernisation programme — submitted his resignation on October 15, 2025, amid an escalating conflict within the Tax Office and mounting political pressure.
The transition also bears directly on legacy operators: under the LOK, all pre-existing sub-licences expired by January 2026, requiring operators to migrate fully to direct B2C or B2B licences issued by the CGA.
Governance questions persisted into late 2025. The Financial Supervision Board for Curaçao and Sint Maarten flagged integrity concerns around the CGA in its reaction to Curaçao’s third 2025 budget implementation report, noting it had received signals that integrity was a matter of discussion at the authority. The CGA and the Curaçao government disputed those claims.
For what has historically been viewed as a loosely regulated regime, the new T&C framework represents a move to bring Curaçao’s licensing procedures into closer alignment with other regulated markets.
The authority’s institutional stability ahead of the October deadline remains the question operators and payment providers will be watching most closely.
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