Curaçao's new licensing system — what it really gives a player

If you look at the licence text in a crypto casino's footer, you will probably see one of two things. An older
site says something like "licensed under master licence 1668/JAZ". A newer one says "OGL/2024/1451/0918,
Curaçao Gaming Authority".

Those two sentences mean entirely different things and the difference is concrete for a player: in the first case you have
practically nowhere to complain, in the second you do.

In 2023–2024 Curaçao replaced its whole gambling regulation. This article explains what
really changed, what the new licence gives a player and what it does not — and how to check any casino's
licence yourself in three minutes.

The old system: four masters and hundreds of sub-tenants

For decades Curaçao worked on a master licence model. The government had issued four
master licences — known by the numbers 1668/JAZ, 8048/JAZ, 5536/JAZ and 365/JAZ — and their holders
could sell sub-licences on to anyone.

In practice that meant the following. A casino never dealt with the regulator. It bought a sub-licence
from a private company, paid a fee and got the right to say it was "Curaçao licensed". Supervision was carried out —
theoretically — by the master licence holder, who was at the same time the seller of the service. The supervisor and the customer
were two ends of the same business relationship.

For a player the consequences were as follows:

• There was practically no complaints procedure. If a casino refused to pay out, you could write

to the master licence holder, who took a cut of their customer's revenue. The results were accordingly.

• A licence could not be checked. There was no public register. A number in the footer proved

nothing and forging it was trivial.

• Sanctions were essentially not applied. Losing a licence was a rare event.

It is precisely that reputation — "a Curaçao licence means nothing" — that many players still remember and it
was a fair assessment of the old system.

What changed: the LOK and the Curaçao Gaming Authority

At the end of 2023 a new gambling act, Landsverordening op de Kansspelen (LOK), came into force and a
real regulator was created — the Curaçao Gaming Authority (CGA). The transition took place during 2024 and the old
master licences are being phased out.

Four important changes.

A direct licence. A casino applies for a licence directly from the CGA. There is no intermediary and the supervisor is
no longer your service provider. That is the core of the whole reform.

A public register. Every licence has a number in the form OGL/2024/xxxx/xxxx and it can be checked
on the regulator's public page. From that arises, for the first time,
the possibility of proving that a casino's claimed licence is real.

A substantive background check. An applicant's owners, funding and business plan are reviewed. In the old system
that was a formality.

A complaints procedure. Under the new order an operator must have a complaints handling procedure and a player can
take an unresolved dispute to the regulator. That is for the first time a real route, not a polite reply.

In addition came requirements for anti-money-laundering (AML) procedures,
responsible gambling tools and the clarity of terms.

What it really gives a player

Let us be precise, because exaggeration here helps nobody.

What it gives:

• The ability to check whether a licence is real — before you put money in.
• A place to complain to when a withdrawal gets stuck, which is not a beneficiary of the casino's own revenue.
• A requirement that terms be accessible and clear. That is why we penalise in the score

operators who do not publish their terms before registration — like BC.Game.

• Mandatory responsible gambling tools on the account.

What it does not give:

• Your money back if the casino goes bankrupt. There is no deposit protection or guarantee fund.
• Supervision at Malta's or the United Kingdom's level. The CGA is a new authority, its resources are limited and

the practice is only forming.

• Estonian consumer protection. A Curaçao licence is not an Estonian licence and

HAMPI self-exclusion does not reach there.

• A fast resolution. The complaints procedure exists, but it takes time and the outcome is not guaranteed.

An honest summary: the new Curaçao is clearly better than the old Curaçao and clearly weaker than Malta. It is
a sensible middle, not a cure-all.

Anjouan: where some of the operators moved

Here comes a part that concerns a player directly. When Curaçao's requirements tightened, not all
operators came along. Some moved to Anjouan — a licence of an autonomous island of the Comoros, whose
numbers look like ALSI-202410011-FI1.

Anjouan is to today's Curaçao what the old Curaçao was to Malta: cheaper, faster, with weaker
supervision. The complaints procedure is weak, the register is less transparent and the practice is short.

In our ranking there are four houses with an Anjouan licence — Thunderpick,
MetaWin, Rainbet and BC.Game — and it lowers each one's trust score.
That does not mean they do not pay out; in our tests all of them have paid. It means that
when a dispute arises, you have less support.

BC.Game's case is especially telling: the house gave up its Curaçao licence in 2024 and
moved to Anjouan. The operator's own explanation referred to disagreements that had arisen with the regulator. However
that is interpreted, for a player the direction is one: towards weaker supervision.

How to check a licence yourself

Three minutes, three steps.

Step 1 — find the number. Scroll to the end of the casino's page. The licence information is in the footer, often in small print
or hidden behind a logo. Look for the pattern OGL/2024/xxxx/xxxx (Curaçao) or ALSI-xxxxxxxxx-FIx (Anjouan).
If there is no number at all, that is an answer in itself.

Step 2 — check the register. Curaçao licences can be checked
on the regulator's page. Search by the operator's legal name, which is
also in the footer — for example Medium Rare N.V. (Stake), Natural Nine B.V.
(Shuffle), Raw Entertainment B.V. (Roobet).

Step 3 — see whether the name matches. This is the step most people skip. A licence may be
real but belong to a different legal entity from the one you are contracting with. If
the operator's name in the footer and the licence holder in the register do not coincide, there is reason to ask.

In our ranking every house's licence, number and operator are listed separately — precisely so
that you do not have to do it yourself every time.

What happens when a casino does not pay out

First an honest warning: in most cases when a withdrawal does not succeed, the reason is in the terms, not in
malice. Exceeding the max bet,
not meeting the wagering, passing the bonus's deadline or unfinished
KYC — those four cover the overwhelming majority of cases.

Once you have ruled those out, the procedure is as follows.

Step 1 — a written demand to the casino. Ask for a specific justification with a reference to a clause of the terms.
Save the whole conversation. Talk in a chat window cannot be proved with anything afterwards — insist on an email.

Step 2 — an official complaint to the operator. Under the new LOK an operator must have a complaints handling
procedure and a deadline. Find it in the terms and use exactly that channel.

Step 3 — the regulator. With a Curaçao CGA licence you can take an unresolved dispute to the regulator.
You need: the licence number, the operator's name, the account details, the transaction history and all the correspondence.

Step 4 — publicity. Dispute databases and forums are not law enforcement, but with large operators
they work as reputational pressure often faster than an official procedure.

With Anjouan and Tobique licences this chain ends in practice at step 2. That is worth knowing
before, not after.

Why we weigh the licence separately in the score

Our casino score consists of six categories and one of them is trust and licence. That is not
a cosmetic point.

A licence's value shows only when something goes wrong. When everything goes smoothly — and mostly it does —
you do not notice the difference between Curaçao and Anjouan at all. The difference shows on exactly the day when you have a big
win and someone on the other side of the screen decides whether to pay it out.

That is why our scale is:

500 Casino is an example of the old Curaçao eGaming regime, Winna of Tobique.
Both are functioning casinos; both have a correspondingly lower trust score.

Houses with an Estonian Tax Board licence are covered by our sister projects
freespin.ee, pangakasiinod.ee and
kiiredvaljamaksed.ee. Valid Estonian licences can be checked in the
Tax Board's register.

The licensing landscape: who really requires what

So that Curaçao's position is clear, it is worth seeing the whole scale. The following is a practical comparison from a player's
point of view, not an operator's.

The United Kingdom (UKGC)

The strictest of the large regimes. A mandatory self-exclusion register (GAMSTOP), a ban on credit card payments,
mandatory loss limits, strict advertising control and a requirement to segregate deposits. Crypto payments
are in practice not allowed. Player protection is at a maximum, freedom of choice at a minimum.

Malta (MGA)

Europe's mature standard. A strong complaints procedure, a requirement to segregate deposits, regular audits. Malta has
for years been the place large operators go when they want credibility. Malta has opened up to crypto slowly
and conditionally.

Estonia (the Tax Board)

A local licence that brings with it Estonian consumer protection, an obligation to provide support in Estonian and a connection to the
HAMPI self-exclusion register. For an Estonian player it is
the strongest protection there is at all — because it is the only one whose enforcement happens within Estonian law.
Those houses are covered by freespin.ee,
pangakasiinod.ee and
kiiredvaljamaksed.ee.

Curaçao (CGA, new)

A direct licence, a public register, a complaints procedure, AML and RG requirements. There is no deposit protection. The practice
is only forming. Open to crypto — that is exactly why crypto casinos are here.

Anjouan

Cheap, fast, with weak supervision. A register exists, but transparency and enforcement are limited.
The complaints procedure ends in practice with the operator itself.

Tobique

The regulator of a Canadian First Nation community, new and little known. The same profile as Anjouan: it works, but
there is little evidence. Winna is the example in our table.

What the new order requires of an operator

The list is useful, because these are exactly the things whose absence you can notice yourself.

Clear and accessible terms. A bonus's wagering requirement,
max bet, deadline and withdrawal cap have to be readable. An operator
who does not show the terms before registration works against that spirit — that is one reason why
BC.Game's bonus score is the lowest in our table.

Responsible gambling tools. Deposit and loss limits, a session time limit,
a reality check, a temporary account closure and self-exclusion have to be present on the account. Check that
before you start with a larger amount — if they are not there, that is a breach of the rules, not a design choice.

AML procedures. The anti-money-laundering obligation is why
no-KYC cannot be unlimited. Every licensed casino has to verify identity
when withdrawals exceed its own threshold. A casino that promises "we never ask for a document" is either
lying or operating without a licence.

A complaints handling procedure. A written process and a deadline. Find it in the terms before you
need it.

Auditability of the games. Independent testing of the random number generator. At crypto casinos there is additionally the
provably fair mechanism, which lets you check the result of every single round
mathematically yourself — that is a technically stronger guarantee than any audit.

Provably fair: what it adds to a licence

Worth noting separately, because it is the one area where crypto casinos are ahead of traditional
casinos.

At an ordinary casino you have to trust that the random number generator is honest, and the proof is an auditor's stamp.
In a provably fair system the casino publishes a cryptographic hash of its seed before the round, you add
your seed, and after the round you can check that the result was derived exactly from those inputs.
The casino cannot change the result afterwards without the hash failing to match.

It does not replace a licence. Provably fair proves that a single round was fair — it does not prove that a casino
pays a win out, does not freeze an account or does not change the terms. That is exactly why we score the licence and
provably fair separately: the first covers business risk, the second the integrity of the game.

Stake, Roobet and BC.Game offer it in their Originals games.
In third-party slots — Pragmatic, Play'n GO and others — it does not apply, because those games are not
run by the casino.

What to do before a first deposit at a new casino

A practical list that sums up the whole article.

1. Find the licence number in the footer. If there is none, do not continue.
2. Check it in the register. For Curaçao on the regulator's page.
3. Check the operator's name. The licence holder in the register must be the same legal entity

as the one in the casino's footer.

1. Find the complaints handling procedure in the terms and read what the deadline is.
2. Open the responsible gambling settings and set the limits immediately, not later.
3. Read the bonus small print if you intend to take an offer — wagering,

the max bet, the deadline.

1. Make a small test withdrawal before you start playing with a larger amount. That is the only way to find

out how fast the house really pays and when KYC triggers.

Point 7 is what we do with every casino and whose results are in the
ranking and in the measurement statistics.

What will probably change next

Two trends are visible.

Curaçao tightens further. The LOK's implementing acts are still forming and pressure from the EU on AML requirements
is growing. The practical consequence for a player: document-free thresholds are more likely to fall. Today's
"no-KYC up to ten thousand dollars" is not a promise to build on in the long term.

Switching jurisdictions continues. Every tightening creates movement towards a weaker regime.
That means the licence you checked a year ago may not be the one the casino operates
under today. BC.Game is an example and probably not the last.

That is why we recheck licences with every test cycle and note changes in the
change log. A licence is not a permanent property — it is a snapshot.

The eleven houses in our table by licence

This is what the reform looks like on specific casinos. The numbers are from the operators' footers and registers,
checked in August 2026.

Five houses out of eleven are under the new Curaçao regime. Four are in Anjouan, one in Tobique and one
still in the old Curaçao eGaming system. That distribution is the reform's real picture: most of the larger
operators came along, some did not.

Note one pattern too: those five Curaçao CGA houses are also at the top of our trust score. That is not
chance or our prejudice — the choice of licence correlates with how much an operator is prepared
to pay for transparency and supervision.

Three myths about the Curaçao licence

Myth 1: "A Curaçao licence means nothing."
That was true of the old system and is still widely repeated. For the new CGA licence it is
no longer correct: the register is public, a complaints procedure exists and the background check is substantive. The honest wording
is that it means less than Malta and more than nothing.

Myth 2: "If a casino has a licence, my money is protected."
It is not. Curaçao does not require the segregation of deposits and offers no guarantee fund. If an operator goes bankrupt,
your balance is an ordinary debt claim. That is why the rule of thumb is simple: **do not keep money on a casino account
that you are not playing today.** Withdraw a win immediately.

Myth 3: "Checking a licence is too complicated."
Three minutes and two pages. The licence number from the footer, the operator's name from the footer, both into the register.
Most people spend more time reading bonus terms — and the licence more often decides
whether you get your money.

How a licence affects KYC and withdrawals

Here is a connection many do not see: **the licensing regime determines how aggressively a casino asks for
documents.**

Under the new Curaçao order the AML requirements are clear and an operator has an obligation to verify
identity at certain thresholds. That means houses with a CGA licence are more predictable on
KYC: a threshold exists, the policy is written down and the check triggers by rule.

In jurisdictions with weaker supervision there are two opposite consequences. On the one hand the
document-free threshold may be higher — that is the part that attracts players. On the other hand the check is
less predictable: since there is less external pressure, it depends more on the operator's own decision at a particular
moment. That is exactly where the stories come from in which a document is asked for unexpectedly, only at a big win.

In our no-KYC ranking every house's threshold is listed separately and the licence is
beside it — because those two have to be read together. A high threshold under a weak licence is not the same as a high
threshold under a strong one.

What the reform means for bonus small print

The new order requires terms to be clear and accessible. In practice that has played out as three
things.

Wagering requirements have become better documented. The calculation base — whether the requirement is calculated on the bonus
alone or on the deposit too — is now more often written out. That is one number that
doubles the real size of the wagering or does not.

The maximum bet is presented more visibly. Previously it was often buried in the middle of the terms;
now it is more often beside the bonus description. That is good, because exceeding the max bet
is the single most common reason a win is voided.

Unpublished terms have become the exception. And therefore those who still do it stand out
more sharply. BC.Game is the only one in our table whose welcome package cannot be read before
registration — and that is why its bonus score is 6.6, the lowest in the whole table.

The whole topic is unpacked in a separate story:
how a wagering requirement really works.

An Estonian player's practical position

Let us put together what all this means for an Estonian player.

You are not breaking the law. Estonian gambling law punishes the operator, not the player. Playing at a foreign
casino is not a crime for you. At greater length:
is a no-KYC casino legal for an Estonian player.

You lose three things. Estonian consumer protection, the Tax Board's supervision and
HAMPI self-exclusion. The last is the most serious, because it is
a tool meant to work precisely when you no longer have control yourself. How to replace it
at a foreign casino is set out in the
limits guide.

Your complaints route depends on the licence. Under Curaçao CGA it exists. Under Anjouan and Tobique
practically not. Under an Estonian licence you additionally have the Tax Board and Estonian consumer protection — those are covered on the
freespin.ee, pangakasiinod.ee and
kiiredvaljamaksed.ee pages, and valid licences can be checked in the
Tax Board's register.

On tax questions the official information is
on the Tax and Customs Board's page. This
article is not tax advice.

And when play stops being entertainment, help is available regardless of which licence you
played under: 15410, free, around the clock.

What a licence does not cover: five risks that remain

Even under the strongest licence, risks remain for a player that no regulator removes. It is worth knowing
them so as not to rely on a licence more than it can bear.

The operator's insolvency. Curaçao does not require the segregation of deposits. If a house goes bankrupt, your
balance is an ordinary debt claim against a vanished company. The only protection is not keeping money on the account.

Changes to the terms. An operator may change the terms and does. A licence requires changes
to be published — not that they be favourable to you. A bonus you took yesterday applies on yesterday's
terms; a player registering tomorrow gets different ones.

Account closure under the terms. Every casino reserves the right to close an account. The reasons
range from using a VPN to "irregular play", whose definition is deliberately broad. A licence does not
give you the right to be a customer.

Game provider problems. If there is a bug in a slot provider's software, the dispute is between the casino and the provider —
you are a third party. Provably fair covers only the house's own
games, not third-party slots.

Your own mistakes. Exceeding the max bet, using the wrong network, a forgotten
wagering deadline. Those are not disputes — they are rules whose breach
a regulator does not contest.

None of these is an argument against a licence. They are an argument for the fact that a licence is one
layer of protection among several, and the most practical layer is you yourself: read the terms, withdraw the win, keep
a record.

How we track licences

A licence is not a permanent property. BC.Game showed that: a house that was for years under a Curaçao
licence is today in Anjouan.

That is why in every test cycle we recheck three things: whether the licence number in the casino's footer has
changed, whether the entry in the register is still active, and whether the operator's legal entity is the same.
Changes go into the change log and affect the trust score in the
ranking.

If you notice a change before we do, write via the contact page — several of our
corrections have come from readers.

Licensing terms that recur in the terms and conditions

While reading terms you repeatedly bump into the same concepts. A short glossary, because they are not
self-evident.

Master licence / sublicence. The old Curaçao model: a master licence and sub-licences sold
under it. If you see those words in 2026, the operator is working in a legacy regime.

B2C and B2B licence. B2C is an operating licence aimed at players, B2B at a software or platform provider.
Some sites refer to a B2B licence as if it were an operating licence — it is not.

Beneficial owner. The actual beneficiary. The new Curaçao order requires this to be disclosed to the regulator.
For you it means there is an identified person behind the operator, not just a letterbox company.

Segregated funds. Keeping players' money separate from the operator's own assets. Malta requires it,
Curaçao does not. It is one of the most important differences and the reason a balance is not worth keeping on an account.

Dispute resolution / ADR. Out-of-court dispute resolution. Find it in the terms and see
whether a specific body is named or only the operator's own support.

Terms of service governing law. The applicable law. Usually the operator's country of registration. It determines
whose laws a dispute would be judged by.

Three things the new order did not change

For the sake of an honest picture.

Advertising and affiliate marketing. Curaçao does not regulate it as strictly as the United Kingdom or
Estonia. That is why you see crypto casino advertising in places where a casino with an Estonian licence would not be
allowed to — and why a comparison site's own transparency (like our
methodology) matters more here than on a regulated market.

The aggressiveness of bonuses. Wagering requirements of 40× and four-part packages are still
allowed under Curaçao. The reform required clarity, not moderation. See the
wagering article.

Credit card payments. The United Kingdom banned them in gambling; Curaçao has not. At crypto casinos that is
partly academic, because most payments go in crypto anyway.

The reform dealt with the structure of supervision, not with product policy. That is an important difference: a casino can
fully comply with the new order's requirements and still offer terms unfavourable to a player.
A licence protects you against an operator's conduct, not against its price list.

How the reform actually came about

A short background helps to understand why the change came just now and why it is more serious than earlier
cosmetic attempts.

Curaçao's gambling sector was for decades built on a 1993 decree that created four
master licences. The system was meant for an era in which there were tens of online casinos, not thousands.
In twenty years the number of sub-licences grew into the hundreds and supervision stayed put.

Pressure came from two directions at once. The Netherlands, of whose kingdom Curaçao is part, made
reform of the gambling sector a condition of post-COVID financial aid — that was a concrete financial lever that
earlier attempts lacked. At the same time the international AML framework tightened requirements on
jurisdictions wanting to stay off risk lists.

The result was the LOK and the Curaçao Gaming Authority. And unlike earlier promises, it happened:
new licences began to be issued in 2024 and the old master licences were put on the path to termination.

Why does that matter for a player? Because the reform did not arise from the sector's own wish but from external pressure. That
means the pressure continues — and that a reversal is less likely than with earlier, internally
initiated attempts.

How to read a casino's footer

A practical skill that takes two minutes to learn and pays for itself endlessly.

A typical correct footer looks roughly like this:

*Medium Rare N.V., registered in Curaçao, operates under Curaçao Gaming Authority licence
OGL/2024/1451/0918.*

Four things have to be present:

1. The legal entity — a name, not a brand. "Stake" is not a legal entity; "Medium Rare N.V."

is.

1. The registered address.
2. The licensor's name.
3. The licence number.

Warning signs worth knowing:

• Only a brand, without a legal entity. You do not know who you are contracting with.
• An old master licence number (1668/JAZ, 8048/JAZ and the like) in 2026. It indicates the

operator has not moved to the new order.

• "Licensed" without a licensor. An empty claim.
• A licensor that does not exist. They occur. Search for the name, not only the number.
• A discrepancy between the footer and the register. If the register shows a different legal entity as the licence holder,

ask support for an explanation before depositing.

In our ranking all four are listed separately for every house, precisely so that you do not have to
do it yourself every time.

How much a licence really costs a player

Let us finish with an honest assessment, because exaggeration in either direction does not help.

In everyday play a licence changes nothing. The deposit arrives, the games work, the withdrawal
comes. A casino with a weak licence does those things exactly as well as one with a strong licence.
Most of the Anjouan houses in our table pay out faster than some Curaçao ones.

A licence becomes important in exactly three situations. When you have an unusually large win. When
a casino voids a win citing the terms. When an operator ceases activity or freezes an account.
Those cases are rare — but in them your whole balance is at stake, and it is exactly there that
Curaçao CGA and Anjouan diverge completely.

The practical conclusion. For small amounts and occasional play you can lower the weight of the licence and
choose by speed, bonus or game selection. For larger amounts raise the weight of the licence and choose
Curaçao CGA or stronger. And keep a win on the account for as little time as possible — that is the only protection that
works regardless of the regulator.

In summary

Curaçao's reform is real. A direct licence, a public register and a complaints procedure are three things the old
system did not have, and they turn the claim "a Curaçao licence" into a verifiable fact.

But the reform also brought stratification: some operators adapted, some moved on to Anjouan and
Tobique. For a player that means **reading a licence matters more today than five years
ago** — because the difference between two of today's choices is larger than the difference between two of yesterday's ever was.

Three minutes in a register before a first deposit. And the win off the account as soon as it comes. Those two
habits cover more risk than any choice of licence.

In summary

Curaçao's reform is real and the situation improved for a player. A direct licence, a public register and
a complaints procedure are three things the old system simply did not have.

But the reform also created a side effect: some operators moved to jurisdictions with weaker supervision
instead of adapting to the new requirements. For a player that means **reading a licence has
become more important, not less** — because the difference between Curaçao CGA and Anjouan is now
larger than the difference between two old sub-licences ever was.

Three minutes in a register before a first deposit. That is all the work it asks of you.