🇨🇼 October 2025 Curaçao Gaming Authority Updates LOK Fees

This version refines the structure of application and annual fees, clarifies invoicing and payment timelines, and removes transitional provisions related to the old NOOGH regime - marking another major step toward a fully operational LOK system.

⚙️ Key Changes at a Glance

💰 Application Fees (Non-Refundable):

• B2C / B2B Licence Application: EUR 4,592

• UBO / Qualified Interest Holder Fee: EUR 150 per person

• Listed UBO Fee: EUR 2,551 per entity

🏦 Annual Fees:

• B2C Operators: EUR 47,450 total

• EUR 24,490 (License Fee to National Treasury)

• EUR 22,960 (Supervisory Fee to CGA)

• B2B Suppliers: EUR 24,490 Supervisory Fee

• Due date: 15 January each year

📆 First-Year Transitional Treatment:

For the first 12 months following LOK enactment (24 Dec 2024 → 24 Dec 2025), licences are issued only once the first invoice is paid.

The initial invoice covers six months; a second invoice may be issued if the licence extends within the first year.

After the first year, annual billing will apply.

📨 Invoicing & Collection Policy:

Invoices are sent via email to the local director and uploaded to the CGA portal.

Clear escalation process for unpaid invoices:

Reminder → Notice → Suspension → Revocation at Day 71 post-invoice if unpaid.

🧾 Administrative Fees:

• Add a domain: EUR 250

• Certificate application: EUR 383

• UBO/QIH change: EUR 128 per person

🧩 Removed / Updated Sections:

• Removal of NOOGH transitional provisions

• Additions on invoicing, collection policy, and first-year duration treatment

🔍 Why This Matters

These updates reshape how both operators and suppliers manage their compliance and cashflow obligations under the LOK framework.

For Operators (B2C):

Budgeting for nearly EUR 50,000 annually (plus admin costs) is now a core compliance requirement. The new “invoice-first” rule means you’ll need funds in place before licence activation.

For Suppliers (B2B):

Even without the National Treasury fee, the Supervisory Fee and new admin costs represent a material operational expense — make sure these are forecasted.

For All Licence Holders:

The new collection policy introduces strict payment enforcement. Missing an invoice could trigger suspension and, ultimately, revocation — so internal tracking and compliance calendars are essential.

🛠 NUR Legal’s Recommendations

✅ Review your cashflow forecasts to ensure timely payment of the first and subsequent invoices.

✅ Verify that the local director’s contact details are current and that invoices are being received.

✅ Budget for UBO/QIH updates and domain additions under the new fee schedule.

✅ Establish a compliance calendar to monitor the CGA’s Day 1 → Day 71 collection cycle.

📣 Our View

The CGA’s latest update shows a steady move toward transparent, structured governance under the LOK framework.

While the fee increase is notable, the clarified invoicing and enforcement process adds predictability — a welcome development for serious market participants.

💼 Need Guidance?

At NUR Legal, we support operators, suppliers, and service providers navigating Curaçao’s LOK transition.

We can assist with:

• Licence and invoice reviews

• UBO/QIH compliance

• Communication with the CGA

• Cashflow and compliance planning

📩 Contact us to discuss how these changes impact your business.

Disclaimer: This post is for informational purposes only and does not constitute legal advice. In case of discrepancies, the official Curaçao Gaming Authority documentation prevails.

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