The Curaçao Gaming Authority (CGA) has issued binding new requirements for the terms and conditions of licensed online gambling operators, giving the industry until October 8, 2026 to comply.
Announced on April 8, 2026, the policy mandates that operators revise their T&Cs to cover account closures, dormant accounts, payouts, refunds, bonus conditions, and cryptocurrency transactions in explicit and accessible detail. Non-compliance will be treated as a breach of licensing conditions, with sanctions that include suspension or revocation of licences.
What the New Policy Requires
The CGA’s updated guidance is framed around transparency and enforceability. T&Cs must be available to players at all times in a clear and readable form across all platforms, including websites, mobile apps, and any other delivery medium.
On account management, operators must clearly define the steps, processing times, and confirmation procedures for account closures. Dormant account obligations are also tightened. Operators must specify inactivity criteria, the consequences of dormancy such as suspension or closure, and how players will be notified before any action is taken. Fees associated with dormant accounts must be transparent and proportionate.
Financial disclosure requirements are substantive. Operators must publish a full overview of available deposit and withdrawal methods, including expected processing times. Where withdrawals exceed €2,000, identity verification requirements must be explicitly stated.
The policy devotes considerable attention to cryptocurrency. Operators must address scenarios including token delistings, blockchain forks, and restricted wallet addresses. Refunds must generally be processed via the same payment method used for the original deposit. Where that is not possible, operators must document and disclose an alternative process.
Bonus terms must be clear, accessible, and accepted before players can participate. Operators must also specify the circumstances under which winnings can be withheld or payouts denied. Any non-withdrawable funds, including bonus balances, must be explicitly labelled as such.
The guidance further requires operators to define procedures for resolving betting errors, software failures, and event cancellations, including how refunds are determined and processed in each scenario.
Consent and Contractual Enforceability
A significant shift in the CGA’s approach is the move away from passive acceptance of T&Cs. The regulator now requires explicit, recorded consent from players, and re-acceptance where material changes are made to existing terms. This creates an auditable compliance trail that the CGA can review during inspections or enforcement proceedings.
Operators must also ensure that their T&Cs make their regulatory status and business identity clear to players, a requirement that addresses longstanding concerns about opacity in Curaçao-licensed operations.
The new policy applies to all current CGA licence holders and is not limited to new applicants. Operators with existing licences must bring their public-facing terms and internal processes into alignment by the October deadline.
Context: LOK Reform in Progress
The updated T&C policy is part of the broader regulatory overhaul that followed the passage of the National Ordinance on Games of Chance, known as the LOK, in December 2024. The LOK replaced Curaçao’s previous master and sub-licence structure with a direct licensing regime supervised by the CGA. It introduced mandatory local presence requirements, AML obligations aligned with FATF standards, and more rigorous due diligence on beneficial owners and directors.
For what has historically been regarded as a lighter-touch licensing jurisdiction, the T&C guidance represents a deliberate effort to bring Curaçao’s compliance expectations closer to those of regulated European markets. The CGA has been under scrutiny since allegations emerged in late 2025 regarding internal integrity issues at the authority, though those were formally retracted in December 2025 by the Board of Financial Supervision for Curaçao and Sint Maarten, which acknowledged relying on unverified information.
The T&C mandate, taken alongside earlier LOK implementation steps, signals that the CGA is continuing to build a compliance infrastructure capable of withstanding external scrutiny. Operators using the Curaçao licence to access markets where it is recognised will face tighter documentation and operational obligations as a result. The October 8 deadline leaves six months for what the CGA has described as a comprehensive review and restructuring of public terms and internal processes.
For context on how non-compliance is treated across other regulated jurisdictions, see Three markets, one message: comply or face consequences and the Netherlands KSA’s approach to AML compliance enforcement against ComeOn’s parent company.
Source: Curaçao Gaming Authority
