Curacao Corporate Structuring & E-Gaming Compliance Advisory

For businesses operating in the online e-gaming sector, navigating licensing and regulatory change can be complex. Our advisory team helps operators launching or relicensing under the current CGA framework structure their entity correctly from the outset.

The Curacao Gaming License, issued directly by the Curacao Gaming Authority (CGA) under the National Ordinance on Games of Chance (LOK), allows you to legally offer online casino games, sports betting, poker, bingo, and more under a single license.

Elite Incorporate does not operate, own, or provide online gambling services. We provide licensing and corporate structuring support for gaming operators, we are not affiliated with, endorsed by, or acting on behalf of any government authority, and we do not guarantee outcomes, approvals, or processing times, as these are subject to the relevant authorities.

Consulting on CGA Framework Compliance & Entity Setup

Fill out the form below with your details, and one of our team will get back to you to discuss the right structure for your business.

By submitting this form, you accept that your data will be securely stored and processed within our tools. Your data will be used with caution, aiming to give us a better understanding of your wants and needs as well as helping us to reach you with relevant information.

For businesses operating in the online e-gaming sector, navigating licensing and regulatory change can be complex. Our advisory team helps operators launching or relicensing under the current CGA framework structure their entity correctly from the outset.

The Curacao Gaming License, issued directly by the Curacao Gaming Authority (CGA) under the National Ordinance on Games of Chance (LOK), allows you to legally offer online casino games, sports betting, poker, bingo, and more under a single license.

Elite Incorporate does not operate, own, or provide online gambling services. We provide licensing and corporate structuring support for gaming operators, we are not affiliated with, endorsed by, or acting on behalf of any government authority, and we do not guarantee outcomes, approvals, or processing times, as these are subject to the relevant authorities.

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Curacao Corporate Structuring at a Glance

Advantages of a Curacao Corporate Structuring

Types of Products You Can Offer

What Changed Under the LOK Reform

If you’ve come across older information describing a ‘Master License’ and ‘sub-license’ structure, or an ‘e-Zone company’ as the licensing vehicle, that system no longer exists. The LOK abolished the entire master/sub-license model.

All legacy sub-licenses expired in January 2025. Every Curacao gaming operation now requires a direct license from the CGA, issued only to a Curacao-incorporated entity, no foreign companies are eligible.

Area Before LOK Current (CGA / LOK)
Licensing model Master license + sub-license (“IP”) Direct license from the CGA
Licensing vehicle e-Zone free-zone company Curacao-incorporated entity, statutory seat in Curacao
Local presence Not required Resident managing director + office required now; headcount scales to 3 by April 2027
Oversight Private master licensors Direct CGA supervision, public register, UBO investigations

Documentation & Checks

As this is a regulated business, the CGA reviews both the individuals and the company behind the application.

  • Certified copy of passport
  • Birth certificate
  • Original utility bill / proof of address (or certified copy)
  • Original bank reference letter (relationship longer than 2 years)
  • Original professional reference letter (from accountant or lawyer, relationship longer than 2 years)
  • CV
  • Certificate of Good Conduct (criminal record clearance) — the standard Curacao document, or equivalent police clearance for non-residents
  • For beneficial owners holding equity above the CGA’s reporting threshold: source of wealth documentation (bank statements, audited accounts, tax returns, or similar)
  • A business plan with financial projections
  • Evidence of sufficient financial liquidity to operate and cover player payouts
  • RNG certification for the gaming platform, from an approved testing lab (e.g. eCOGRA, BMM, GLI, or iTech Labs)
  • Details of gambling software and website ownership
  • Legal pages: responsible gaming policy, privacy policy, payment policy, and a plan to prevent underage gambling and money laundering
  • Appointment of a Money Laundering Reporting Officer (MLRO) and a documented AML/CFT programme
  • Appointment of a separate Compliance Officer, distinct from the MLRO, subject to CGA approval of their fit-and-proper status
  • Annual financial statements and reports once licensed

Why Choose Elite Incorporate

We’ve worked with the Curacao regulatory environment for years and know the process, the documentation standards, and what the CGA expects at each phase.

We assist with the full structure, company incorporation, license application, AML/CFT framework, and introductions to banking and payment-processing partners suited to gaming operators.

Requirements to Apply

Already required today: a Curacao-incorporated entity with its statutory seat in Curacao, a registered office (virtual offices don’t qualify), and at least one Curacao-resident managing director.

Deferred to 1 April 2027: only the additional local headcount — scaling from one full-time local key person to three by the fifth year of operation. The basic presence requirement above is already in force, not part of the 2027 deadline.

Licensing is a formal two-phase review. The CGA’s own review takes 8–16 weeks once your application is complete — but the realistic total time from starting the engagement to actually being live, including entity formation, RNG certification, and banking/payment integration, is typically 4–8 months.

  1. Phase 1 — Corporate integrity and financial stability: the CGA reviews corporate documentation, shareholder registers, UBO disclosures, police clearances, financial stability evidence, and your business plan. Typical CGA target: around 8 weeks, extendable by 4.
  2. Phase 2 — Regulatory compliance and technical review: AML/CFT policies, KYC systems, responsible gaming framework, and technical platform review against GLI standards, plus domain registration and verification through the CGA portal.
  3. Outcome: a fully compliant application results in a definitive license of indefinite duration, subject to ongoing compliance. An application that isn’t fully compliant may instead receive a provisional license, valid 6 months and extendable once.

Cryptocurrency deposits and withdrawals are permitted under the standard B2C license — no separate virtual-asset license is required, and Blockchain-based and Web3 gaming platforms use the same license as fiat operators. In June 2026, the CGA introduced a dedicated set of crypto rules that add real operational obligations:

• Crypto may be accepted for gambling purposes only — operators cannot act as an exchange, custodian, or VASP

• Mandatory blockchain analytics: wallet screening, risk-scoring, and transaction monitoring at both deposit and withdrawal

• Fiat-backed stablecoins are preferred; privacy coins, meme coins, and wrapped tokens of unclear origin require individual assessment or exclusion

• Player, operational, and treasury wallets must be kept separate; personal or UBO-linked wallets are banned

• Sanctioned wallets and mixers/tumblers are banned outright

Compliance follows a staged timeline: a compliant crypto policy filed with the CGA by September 2026, risk assessments and VASP due diligence completed by December 2026, and full technical compliance — wallet segregation, blockchain analytics, and audit-ready records — by June 2027.

Opening a bank account or securing an EMI (Electronic Money Institution) relationship is one of the most challenging steps for a newly licensed gaming operator.

Direct CGA oversight under the LOK framework has improved how banks and payment providers view Curacao-licensed operators compared to the old sub-license era, but institutions still run their own independent compliance review regardless of your CGA approval.

We assist clients with introductions to banking and EMI partners experienced with the gaming industry, and help prepare the compliance documentation these institutions typically require.

Frequently Asked Questions

Yes, completely. The LOK, effective 24 December 2024, abolished the entire master/sub-license system. All
legacy sub-licenses expired in January 2025. There is no grandfather provision — every operator needs a direct
CGA license.

B2C, for operators offering games directly to players, and B2B, for suppliers of software, platforms, or other services to licensed operators. B2B licensing formally comes into force in December 2026.

The CGA’s own review takes 8–16 weeks once your application is complete. The realistic total time from starting
the engagement to being live — including entity formation and banking setup — is typically 4–8 months.

Yes. Crypto deposits and withdrawals are explicitly permitted under the standard B2C license, with no separate
crypto authorization required, subject to the CGA’s 2026 crypto compliance rules covering wallet screening, asset
controls, and staged compliance deadlines through June 2027.

No — only entities incorporated under Curacao law, with their statutory seat in Curacao, are eligible. We assist with setting up this structure as part of the application.

No. Since 1 July 2025, the CGA has prohibited Curacao-registered companies from operating under a foreign
license as a workaround. This is treated as illegal, with enforcement action possible under Curacao&’s Penal Code.

The USA, the Netherlands, France, Germany, Australia, the UK, Curacao itself, and FATF high-risk jurisdictions are excluded. Geo-blocking these markets is a mandatory technical requirement.

Do you want to run an Online Gambling Website?

The Curacao Gaming License allows you to legally offer every eGame you can think of

As one of the first countries in the world Curacao offered gaming licenses to international entrepreneurs.
This license is tried and tested; and is relatively easy to get.


It allows you to offer on your website every type of online game you want. If you’re interested in running an online casino or any type of online gaming website, Curacao has a very attractive offer for you!

  • Offer every type of online gaming product with just one license;
-> online casinos, sports betting, lotto, poker, bingo, and more.
  • Profit from your gaming site with little taxes.
  • Save money. Curacao is the least expensive of the big 3 licensing options.
  • Save time. The license is easy to get. A fast and logical procedure.
  • Keep your site humming for years with low annual fees and little paperwork.
  • Benefit from innovative IT infrastructure—run your website without down-time.
  • Do business under modern, compliant, well written and fair regulations
(written by people from- or trained in the Netherlands).

Curaçao E-Gaming is one of the oldest and most reputable providers of regulated E-Gaming services. Since 1996, Curacao E-Gaming has proudly served some of the most highly regarded E-Gaming operators and providers of services.

The island has a unique status as part of the Kingdom of the Netherlands. It offers the regulatory benefits of the EU, without being a part of the EU. More importantly, without being subject to Europe’s high tax rates.

Unlike other countries, Curacao offers one E-Gaming license that covers everything. How it is organized, is that there are only four organizations holding a ‘Master-License’. They act as franchises, and are responsible for issuing and overseeing sublicenses.

No new Master Licenses are approved, and the only real, and widely used option is what the industry calls a ‘sub-license’. However, the correct term is ‘IP’ (Information Provider). Through our long involvement in the industry, we work directly with three of four Master Licensors.

The Curacao E-Gaming IP license covers all forms of electronic gaming including games and services of skill, chance, betting, lotteries and casinos.

Types of products you can offer under this license:

  • Online casino games (roulette, blackjack, slots – as examples)
  • Sports betting Peer to peer games (poker, backgammon, Mah-jong, etc.)
  • Mobile phone games, betting
  • Live dealing
  • Bingo
  • Fantasy football (or similar)
  • Various trading activity
  • Pari-mutual and pool betting
  • Network gaming
  • Lotteries
  • Trivia
  • Common platforms
  • Affiliate’s, Skins, Marketing services
  • And more…

We advise all our clients to start a company in one of the free zones on the island. This is the easiest and most tax efficient way to apply for the license.

If an “e-Zone company” holds the licence, this allows you to benefit from:

  • 0% tax on gross bets
  • Favourable income tax*
  • No VAT, Sales Tax or import duties
  • No restriction on dividend withdrawals

So besides having the ability to offer every game imaginable, you can also start enjoying your (passive) income with very little taxes.

*Tax rules

As of January 1 st , 2020, Curacao changed from a worldwide tax system with exemptions for foreign permanent establishments and sales to foreign buyers, to a stricter territorial system where only income from a domestic enterprise is included in the taxable basis.

To determine whether income is considered domestic or foreign, the profit before indirect cost is allocated based on direct foreign and direct domestic expenses. For this reason the income tax rate is variable and depending on the set-up. We can ensure that Curacao remains a favourable tax regime. Make sure to ask us for the details. 

Processing agent

Due to ongoing regulatory scrutiny, it is now next to impossible for offshore companies in jurisdictions such as Curacao to accept online payments, or open bank account to receive those online payments. Given the fact that you need to accept payments on your website before people can start playing, you need this crucial element: a payment processing agent, also known as a Payment Agent Company.

A processing agent is a company that is part of the structure which processes payments for your website. For this, it receives a small fee (to satisfy local tax rules). The best jurisdiction has a low tax rate, has experience with such arrangements, and offers access to a variety of credit-card payment providers. The best option for this is Cyprus.

Cyprus is a EU country and it has one of the lowest corporate tax rates of the developed world. It allows access to payment systems and its regulatory body accepts these set-ups. In order to start a business here you do need local substance, such as a director, a company secretary, and an accountant.

You might also consider using an experienced company to handle the day-to-day administration and management of the corporate structure; this way you can focus on the important matters promoting the platform and driving up revenues!

To summarize the structure

For this structure you need to set-up a company in Curacao, which acquires the license. This company then becomes the shareholder of a Cyprus company, which is set-up to process payments.

All the income in this structure passes through Cyprus, but flows directly to Curacao. Of the total income 3% is invoiced as management fee by the Cyprus company, which is then taxed at 12.5%. This is an effective tax rate on total income of 0.375%. The income of the Cyprus company is than distributed to the Curacao company. All profits in Curacao are taxed according to the arrangement mentioned above. From there, your profits can be freely distributed to you without withholding taxes on dividends.

As you can see, to offer gaming services requires some planning. But for the serious entrepreneur, this structure offers a solid low-tax legitimate way to offer gaming products that are massively in demand at the moment.

Step 1. Preliminary review of the activities

The first step is to complete a review of the activities done by us. This includes providing basic information about your activities, territories you will be targeting and domains/applications/software you are looking to license. This is a preliminary review and approval of your activities which is granted within 24 hours.

Step 2. Pre-Approval IP Application Form Submission

Upon confirmation that the activities are permitted a pre-application is submitted with the supporting documents to the Curacao E-Gaming authority together with a non-refundable fee. Depending on the Master Licensor the fee can range from 750 to 1,000 Euro..

Step 3. IP E-gaming License Approval

Once the approval is granted by the E-Gaming authority, applicants are required to settle all necessary one-off fees and deposits.

Step 4. Application Evaluation

At this stage we proceed to incorporate the e-Zone company through our authorised E-Gaming service provider.

While the e-Zone company is being incorporated, we work on gathering, preparing, reviewing and submitting all the required documents for the licence. At the same time, tech-teams proceed with the technical requirements.

Once the application is evaluated and all the requirements have been met, the license is approved and the authorities will issue the sub-licence certificate (game providers are required to have an RNG certification).

Step 5. Incorporation of Cyprus Payment Processing company

As a final step we set-up the Cyprus company, and proceed approaching Payment Processing Service providers depending on your target markets.

We are up to date with current trends and we also offer solutions for Crypto Payment processing. Once we are preliminary approved for the merchant accounts we proceed opening bank accounts for both Companies.


Congratulations. You are now in business!



If everything is done properly, we expect that the entire process can be done in 4 weeks.

As this is a regulated business, there are requirements for this kind of operation. Of every authorized person, director, shareholder or beneficial owner of the structure, the following is needed:

Of the people involved:

  • Certified Copy of Passport
  • Original utility bill (or certified copy)
  • Original bank reference letter (Relationship must be longer than 2 years)
  • Original professional Letter of Reference (from accountant or lawyer, relationship must be longer than 2 years)
  • CV
  • Proof of no criminal record

Of the business:

  • Details of gambling software and website ownership
  • Copies of legal pages including responsible gaming policy, privacy policy, payment policy, and a plan to prevent under-age gambling and money-laundering
  • Submit annual financial statements and reports

We’ve been working with the people in Curacao almost every day this past seven years and have come to know what they want and how they want it and pretty much the whole process by heart.

We can assist you with setting up just the right corporate structure to suit your needs.

We guarantee a hassle-free application.

We work fast and at reasonable costs.

We assist you with bank and merchant account opening through our extensive network of banks and payment processors

Are you interested in obtaining a license for your online gaming website and want an experienced agent to help you obtain it?

…Then contact us by filling in the form.

Are you interested in obtaining a license for your online gaming website and want an experienced agent to help you obtain it?


By submitting this form, you accept that your data will be securely stored and processed within our tools. Your data will be used with caution, aiming to give us a better understanding of your wants and needs as well as helping us to reach you with relevant information.