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Under the proposal, online gambling licensees must keep dedicated office premises in Curacao equipped for day-to-day operations, ending the long-criticised “postbox” setup.

From the go-live of the rules, licensees will also need at least one locally based Key Person (in addition to the local managing director). That individual must work full-time and be registered in Curacao’s population registry. Roles that can qualify as “key” are defined broadly (those exercising significant influence over governance, operations, risk or compliance), which in practice can include functions such as IT/engineering, marketing, product development, data analytics and compliance.

Year-five tightening and limited carve-outs

The CGA’s phased model lifts the staffing bar to three locally based Key Persons from the fifth year of a licence. The aim is to anchor real operational substance on the island as the regime under the National Ordinance on Games of Chance (LOK) fully beds in.

Exemptions are envisaged but narrow. According to local reporting on the consultation, relief may be available for smaller or newly established operators that meet strict conditions — among them gross gaming revenue below ~ANG 20 million (≈ €10 million) and no Ultimate Beneficial Owner with recent involvement in another gambling firm. Claims for exemption would be subject to enhanced reporting (e.g., periodic audited statements).

Timelines, how to respond, and what operators should do now

A grace period runs through 31 December 2025; full compliance is expected from 1 January 2026. The CGA is collecting written submissions at onlinegaming@cga.cw until 24 September 2025.

For operators, near-term priorities include scoping a Curacao office footprint, workforce planning for eligible Key Persons, and updating governance and conflict-of-interest controls to reflect the “significant influence” definition. The consultation also signals the regulator’s broader drive to end “paper-only” presences and ensure licensees contribute to the local economy under the LOK.

Source: https://www.linkedin.com/posts/curacao-gaming-authority_local-substance-consultation-document-activity-7371596292063404033-f9uL