Curaçao is the foreign gambling jurisdiction Georgian clients mention most often — and, at the same time, the one about which the most outdated information circulates. At the end of 2024 the island activated an entirely new licensing framework: the old offshore regime was replaced by a new national ordinance (the LOK), and the licensing authority swung over to a direct-licensing model. For a Georgian client this matters on two levels. On the first level sits the regime itself — what it actually is, what the process looks like, and what the licence genuinely grants. On the second level sits the layer of Georgian law, which gives the licence holder nothing on the Georgian market while leaving tax and reporting obligations with the person standing behind the structure. This page works through both levels using only facts verified from official sources, and it separately lists what still has to be confirmed with the CGA.
The New Regime That Entered Into Force With the LOK
On 24 December 2024 the new national ordinance — the LOK — entered into force, replacing the old Landsverordening op de buitenlandse hazardspelen (LBH), the ordinance on offshore games of hazard. The reform had been phased in since November 2023, and licensing had in practice already been administered since March 2020 by the Gaming Control Board (GCB) on behalf of the Ministry of Finance; within the new structure the board was rebranded as the Curaçao Gaming Authority (CGA). For structures operating under the old LBH, transitional provisions apply under article 15.1 of the LOK — though the exact conversion deadlines are not yet officially settled, and this page deliberately treats them as an open question rather than a fact.
From Master Licences to Direct Licensing
The hallmark of the old regime was its two-tier structure: the holder of a master licence granted sub-licences to operators, and it was precisely this mechanism that produced the ambiguity for which Curaçao licences became known as a cheap seal. The LOK dismantles it: the master- and sub-licence system is abolished, and licences are now issued directly by the CGA. The practical effect runs both ways. On one side, a licensed operator now stands in a direct relationship with the regulator instead of going through an intermediary licence holder. On the other, supervisory expectations land on the licensee directly, and the chain of accountability is far shorter. The precise taxonomy of licence categories under the new regime — the B2C, B2B and small-operator categories circulating in discussions — remains to be confirmed at the official level: this page hands it to you as an open question, not as settled fact.
Applying Through the CGA Portal and Verifying a Licence in the Register
Applications and communication with the regulator run through the official portal at portal.cga.cw, while valid licences are found on the public licence register page. For a Georgian client this is the single most important practical instrument: any Curaçao licence an intermediary offers you should first be located in that register — by licence number, holder name and status — before any money or signature changes hands. Application fees and the amount of annual charges must be confirmed with the CGA: figures circulate on agents' sites, but they are blog-sourced, and this page deliberately refrains from repeating them. The same applies to conversion deadlines for existing sub-licences: article 15.1 of the LOK defines the transitional regime, but the operative dates need official confirmation.
What the CGA Does Not Do: Player Complaints and the Limits of the Licence
One boundary matters especially for anyone who reads a Curaçao licence as a guarantee of player protection: the CGA does not accept or resolve complaints from individual players. The regulator supervises its licensees, but a specific dispute between a player and an operator — an unpaid win, a blocked account, bonus conditions — falls outside its competence; our dedicated disputes page addresses that territory. The second boundary is geographic: the licence operates within the Curaçao legislative framework and creates no right of entry into any other state's market — including Georgia's.
The Georgian Cross-Border Layer: Zero Market Access From a Curaçao Licence
This is the central warning of the page: a Curaçao licence gives zero access to the Georgian market. Under article 5, part 1 of the Law of Georgia on gambling, organising gambling games and supplying them into Georgia requires a Georgian permit, and no foreign licence — Curaçao's included — cancels that requirement. Under article 11, part 2, that permit is issued only to an entrepreneur registered in Georgia; managing a Curaçao holding therefore starts with the question of who the Georgian person behind the structure is and what role each Georgian entity plays in the chain.
The tax layer attaches precisely to that person. Under article 80, part 7 of the Georgian Tax Code, the income-tax object of an individual organiser — of a slots hall or of system-electronic gambling — is the margin: stakes received minus winnings paid; article 81 sets the rates, including the 5% line for excess income under a supply permit; and article 8 governs player winnings and the offset of losses — so even for an individual player on a foreign platform, the declaration framework comes from the Georgian Code, as our player-taxation page details. The reporting layer: where a Georgian entity sits in the chain, articles 3, 11 and 12 of the Georgian AML law apply; article 29(b) of the gambling law requires registration of winnings with reporting to the Financial Monitoring Service; and where system-electronic supply into Georgia is in play, the selected-person regime of article 36-1 and integration with the state control system become relevant. Finally, articles 951 and 952 of the Civil Code: claims arising from a game exist only where the game is state-permitted — the no-claim risk in disputes with an unlicensed foreign platform remains.
Frequently Asked Questions
Four questions dominate Curaçao consultations.
Does a Curaçao licence let me serve Georgian players?
No. Article 5, part 1 of the Law of Georgia on gambling requires a Georgian permit for organising or supplying into Georgia, and a Curaçao licence does not change that. The licence provides a legal basis only for activity within the Curaçao framework.
Does the old master-licence system still operate?
No. The LOK entered into force on 24 December 2024 and abolished the master-/sub-licence structure: the CGA now issues licences directly. The fate of rights held under the old LBH is settled by the transitional provisions — article 15.1 of the LOK; the exact conversion deadlines are to be confirmed with the CGA.
How credible is a Curaçao licence to banks and partners?
That is a question of each counterparty's internal policy, not a category of law. What you can verify objectively is whether the licence exists in the CGA's public register, and what the reform actually built — direct licensing reduces intermediary ambiguity, but each partner's requirements are set by that partner's own rules.
Will the CGA help me if an operator refuses to pay my winnings?
No. The CGA does not handle individual player complaints — it is outside the authority's competence. Remedies in a dispute with a foreign operator, including the limits created by Civil Code articles 951 and 952, are analysed on our dedicated disputes page.
How We Help on Legal.ge
Legal.ge takes the Curaçao question off a Georgian client's desk end to end: we establish the current state of the post-LOK regime from official sources, map it against your business model, prepare the documentation frame for the CGA portal application, and in parallel assemble the Georgian layer — identifying the person behind the structure under articles 5 and 11, the tax characterisation of that person's income under articles 80 and 81, and the reporting duties the structure may trigger. The result is a decision file in which every fact is tied to an official source and every open question carries its article. Contact us before you file anything: Curaçao's reformed regime works well for those who use it deliberately, and badly for those who build on an intermediary's promises.