Curaçao’s Regulator Rolls Out Fresh Fee Guidance — Regulation Moves Forward Despite Turbulence
What’s new with the fees?
Released on 15th October 2025, the updated guidance provides fresh structure on how annual fees will be treated during the transition period under LOK. Key points:
- Applicants approved in the 12 months following LOK’s enactment (24 December 2024) will receive invoices split into two six-month cycles, rather than a full-year bill upfront.
- B2C operators: Annual fee €47,450 (≈ US$55,000) — split between €24,490 (fee to National Treasury) + €22,960 (supervisory fee to CGA).
- B2B suppliers: Annual supervisory fee €24,490 (≈ US$28,400).
- Important: an invoice alone does not confirm licence continuation or extension — CGA must issue explicit written confirmation. If a licence is revoked mid-period, full fee remains payable.
Why this matters
Despite earlier turbulence — board resignations, regulator realignment, calls for reform — the CGA is pushing ahead with LOK’s implementation and fee regime. This is a signal to the industry: Curaçao is serious about the new regulatory era.
For years, the island had a reputation for being “easy-in / easy-out”. With LOK and updated guidelines, the bar is being raised.
What affiliates should note
If you’re working with operators licensed in or through Curaçao (or considering doing so), here are key takeaways:
- Licence-fee increases mean higher operator costs — operators may adjust terms, commissions or funnel quality-checks accordingly.
- Clarified rules = less “grey” area — affiliates can now ask more pointed questions of their operator-partners: “Are you compliant under LOK? Did you get written continuation confirmation?”
- Timing matters — the two-invoice scheme means some licences span calendar years before normal annual billing kicks in. Keep an eye on your partner operator’s billing cycle and compliance timeline.
- Risk awareness remains critical — the fact that invoice payment alone does not guarantee licence continuation is a warning sign. Affiliates should verify operator status and monitor for revocations or changes.
- Messaging for traffic & content — As the jurisdiction upgrades its regulatory posture, affiliates can emphasise that the brands they promote are part of a “modernised” regime, not the old “wild-west” environment. Trust matters.
Final thought
The CGA’s updated fee guidance shows that while Curaçao’s regulatory system may be in flux, progress continues. For affiliates, this means the jurisdiction may still offer value, but only if you’re working with operators who are fully up to speed with the new rules and fee structures.
Staying ahead means asking the right questions, aligning with compliant partners, and treating Curaçao not as a “cheap licence” route, but as a jurisdiction in transition — one where being early, transparent and diligent can pay off.
