LOK (National Ordinance on Games of Chance) has been in force since 24 December 2024 and introduced a new regulatory framework for online gambling under the supervision of the Curaçao Gaming Authority (CGA).
A key LOK requirement is local substance under Article 5.12.
However, in January 2026, the CGA postponed its application: operators are not required to comply with Article 5.12 until 1 April 2027.
It is important to remember: the substance requirement has not been abolished, but only postponed.
After 1 April 2027, local presence is expected to include, in particular:
- at least one Key Person who resides in Curaçao during the first four years from the date LOK enters into force;
- three Key Persons from the fifth year,
- requirements regarding a local office.
It is important to remember that the postponement of the substance requirement does not extend to other LOK requirements: all other compliance requirements (including AML/KYC, responsible gambling and other rules) remain in force.
Therefore, although by 1 April 2027 a business may not need to rush to ensure full local substance, this does not mean that it can be forgotten. Doing business in Curaçao requires careful preparation and proper structuring, so it is worth considering the future structure and ensuring its compliance with the requirements already now. Lextensio will help with your questions regarding starting a business.
Author:
Maryna Davydenko,
Junio Business Development Manager at Lextensio
