What a Curacao supplier licence is
A Curacao supplier licence is permission to provide critical gaming services or goods in or from Curacao. The Curacao Gaming Authority issues it under the LOK and supervises the holder. It is the B2B counterpart to the player-facing licence covered in our Curacao B2C gaming licence guide. The B2C licence covers operators that run brands for players. The supplier licence covers the companies that supply those operators with games, software, and betting infrastructure.
The LOK draws a clear line between two obligations: holding a licence and being registered. A licence is the authorisation to supply. Registration is your entry on the public register the CGA maintains of suppliers serving remote gaming licence holders. Whether you need one or both depends on where your company is established.
The 24 December 2026 deadline
The LOK came into force on 24 December 2024 with a transitional period of two years. As a result, that period ends on 24 December 2026. Therefore, the CGA confirmed in its 24 June 2026 announcement that, from that date, the supplier licensing and supplier registration requirements become fully mandatory and enforceable.
Two earlier dates matter as well. The CGA urges Curacao-based suppliers that currently operate without a licence to submit their application no later than 1 September 2026, to give the regulator time to process it before the deadline. The CGA also expects the supplier registration process to open in October 2026 for both local and foreign suppliers. The table below sets out the timeline.
| Date | Milestone |
|---|---|
| 24 December 2024 | LOK enters into force; two-year transitional period begins |
| 1 September 2026 | CGA-recommended deadline for Curacao-based suppliers to file licence applications |
| October 2026 | Supplier registration process expected to open for local and foreign suppliers |
| 24 December 2026 | End of transitional period; licensing and registration fully mandatory and enforceable |
The legal basis under the LOK
Three provisions of the LOK set the rules. Article 1.5(1) prohibits the provision of critical services or goods in or from Curacao without, or in breach of, a supplier licence issued by the CGA. The Article 5.16(4) prohibits a CGA gaming licence holder from obtaining critical services or goods from a supplier that is not registered with the CGA. Article 5.16(1) requires the CGA to maintain a public register of suppliers providing critical services or goods to holders of remote gaming licences.
Read together, these provisions create a closed supply chain. Operators may buy only from registered suppliers, and Curacao-based suppliers may supply only if they are both licensed and registered. The register makes compliance visible to the regulator, to operators, and to the operators’ own banks and payment partners.
Who needs a licence and who needs to register
The single most important distinction is where your company is established. The licensing requirement under Article 1.5(1) applies only to suppliers established in Curacao. Suppliers established outside Curacao do not need a Curacao supplier licence, but they do need to register if they supply Curacao licence holders. The table below summarises the position.
| Party | Supplier licence | CGA registration |
|---|---|---|
| Supplier established in Curacao | Required | Required |
| Supplier established outside Curacao | Not required | Required (by 24 December 2026) |
| B2C gaming licence holder | Not applicable | Must use only registered suppliers |
If your business sits on the border, for example a foreign company considering a Curacao branch or subsidiary, the answer turns on establishment. A Curacao establishment brings the licensing requirement with it. Map which legal entity holds your supply contracts before you decide, because the CGA assesses the requirement against the entity that actually provides the service. Our team can review your structure as part of iGaming company incorporation and corporate planning.
What counts as critical services or goods
The CGA’s current policy framework lists the supplier categories considered to provide critical services or goods. The list is illustrative, and the CGA may expand or amend it. The current categories are:
- RNG game manufacturers
- Live dealer studio providers
- Poker and other peer-to-peer software suppliers
- Lottery providers
- Sportsbook software suppliers
- Bet capture and settlement providers
- Sports betting line and odds providers
- Game aggregators
If your product appears here, treat the requirement as applying to you and confirm your position with the CGA rather than assuming you fall outside it. Game aggregators warrant particular attention, because an aggregator sits between many game studios and many operators, and its registration status affects every operator it serves. Random number generator providers should also note that game fairness testing remains a separate obligation; our guide to RNG testing for online casino games explains how certification fits alongside supplier licensing.
What this means for B2C licence holders
If you hold a Curacao gaming licence, Article 5.16(4) makes your suppliers your compliance problem. From 24 December 2026 you may engage only suppliers that are registered with the CGA. A single unregistered game studio, aggregator, or odds feed in your stack puts you in breach, regardless of how compliant the rest of your operation is.
Start by mapping your supply chain now. List every provider of critical services or goods, identify where each is established, and ask each one for written confirmation of its licensing and registration plan. Build the registered-supplier requirement into new and renewing contracts, with a clause that lets you exit if a supplier fails to register in time. This is the kind of ongoing duty we cover in our guidance on what to do after receiving a gaming licence, and it now sits squarely on the operator.
How to apply for a supplier licence
Application forms and procedures for a supplier licence are already available through the CGA Online Gaming Portal. The CGA encourages Curacao-based suppliers that currently provide critical services or goods without a licence to apply as soon as possible, and no later than 1 September 2026, so the regulator has time to process the application before the deadline.
- Confirm your entity is in scope. Establish whether your supplying entity is established in Curacao and whether your product falls within the critical services and goods categories.
- Prepare corporate and integrity documents. Gather ownership records, source-of-funds evidence, and details of directors and key persons, in line with the CGA’s fit and proper expectations.
- Document your product and controls. Set out the service you provide, your information security arrangements, and your AML and reporting position where relevant.
- File through the CGA Online Gaming Portal. Submit the application and pay the applicable fees on the official Curacao Gaming Authority portal. The CGA may request further information.
- Complete registration. Once the registration process opens, complete your entry on the supplier register so both obligations are satisfied.
The CGA sets supplier licence fees and can change them, and the announcement does not publish a fixed figure. Confirm the current tariff on the CGA portal before you budget, and treat the 1 September 2026 filing date as a planning anchor rather than a soft target. To prepare and submit a clean application, our gaming licence acquisition service manages the documentation and correspondence with the regulator.
How supplier registration works
Registration is separate from licensing and applies to a wider group. Curacao-based suppliers must register in addition to holding a licence. Foreign suppliers must register if they supply Curacao licence holders, even though they need no licence. The CGA expects the registration process to open in October 2026, with the detailed requirements to be published before then.
Because registration opens close to the deadline, the practical window is short. Foreign suppliers should not wait for the licence question to be resolved before preparing, since registration is their main obligation. Gather corporate documents, confirm which Curacao licence holders you supply, and watch the CGA portal for the registration requirements when they publish. The General information on the framework is set out on the Curacao Gaming Authority website.
What happens if you miss the deadline
From 24 December 2026 the requirements are enforceable. A Curacao-based supplier that provides critical services or goods without a licence is acting in breach of Article 1.5(1). A foreign supplier that is not registered cannot lawfully supply Curacao licence holders. The commercial effect can arrive before any formal enforcement: an operator subject to Article 5.16(4) must drop an unregistered supplier to protect its own licence, so an unregistered provider risks losing its Curacao customer base on the deadline.
For operators, the risk runs the other way. Continuing to use an unregistered supplier after the deadline is a breach of the operator’s own obligations and a supervisory matter for the CGA. Neither side benefits from waiting. The supplier loses revenue, and the operator carries regulatory exposure that can affect its standing with the CGA, its banks, and its payment partners.
Action plan before 24 December 2026
The steps differ by role, but the deadline is the same for everyone.
If you are a Curacao-based supplier, file your licence application through the CGA portal as soon as possible and no later than 1 September 2026, then complete registration when it opens in October 2026. Foreign suppliers should prepare their corporate documents now and register as soon as the process opens. If you hold a Curacao gaming licence, audit your supply chain, obtain written confirmation of each supplier’s plan, and add the registered-supplier requirement to your contracts.
Whatever your role, the time to prepare is the second half of 2026, not December. To map your obligations, prepare an application, or audit a supply chain against the new rules, contact the DD Consultus advisory team at contact@licencegaming.com or +356 99408536.
Frequently asked questions
What is a Curacao supplier licence?
It is the authorisation a provider of critical gaming services or goods established in Curacao must hold to supply in or from Curacao. The Curacao Gaming Authority issues it under the National Ordinance on Games of Chance (LOK). It is the B2B counterpart to the player-facing B2C gaming licence.
When does the Curacao supplier licence requirement take effect?
The LOK transitional period ends on 24 December 2026. From that date, the supplier licensing and supplier registration requirements are fully mandatory and enforceable. The CGA confirmed this in its announcement of 24 June 2026.
Do suppliers outside Curacao need a Curacao supplier licence?
No. The licensing requirement under Article 1.5(1) of the LOK applies only to suppliers established in Curacao. Suppliers established outside Curacao do not need a licence, but they must register with the CGA by 24 December 2026 if they provide critical services or goods to Curacao gaming licence holders.
What is the difference between a supplier licence and supplier registration?
A licence is the authorisation to supply, required for Curacao-based suppliers. Registration is your entry on the public register the CGA maintains of suppliers serving remote gaming licence holders. Curacao-based suppliers need both. Foreign suppliers need only registration.
What counts as critical services or goods?
The CGA’s current categories include RNG game manufacturers, live dealer studio providers, poker and other peer-to-peer software suppliers, lottery providers, sportsbook software suppliers, bet capture and settlement providers, sports betting line and odds providers, and game aggregators. The list is illustrative and the CGA may expand or amend it.
When can suppliers apply or register?
Supplier licence application forms are already available through the CGA Online Gaming Portal, and the CGA recommends Curacao-based suppliers apply no later than 1 September 2026. The CGA expects the supplier registration process for local and foreign suppliers to open in October 2026.
What does this mean for B2C gaming licence holders?
Under Article 5.16(4) of the LOK, a CGA gaming licence holder may only obtain critical services or goods from suppliers registered with the CGA. From 24 December 2026, using an unregistered supplier is a breach of the operator’s own obligations, so operators should audit their supply chain and require suppliers to register.
How much does a Curacao supplier licence cost?
The CGA sets supplier licence fees and can change them, and the 24 June 2026 announcement does not publish a fixed figure. Confirm the current tariff on the official CGA Online Gaming Portal before you budget. Beyond the regulator fee, account for corporate, legal, and compliance preparation costs.
Prepare for the supplier licence deadline
The Curacao supplier licensing and registration regime becomes enforceable on 24 December 2026, and the practical work needs to happen in the second half of 2026. Curacao-based suppliers should file by 1 September 2026, foreign suppliers should register as soon as the process opens in October 2026, and operators should clear unregistered providers out of their supply chain before the deadline. To prepare an application, complete registration, or audit your supply chain against the new CGA rules, contact the DD Consultus advisory team at contact@licencegaming.com or +356 99408536.