What a Curaçao gaming licence costs

Every published fee, in one table

These are the amounts in version 2.0 of the CGA's fee schedule, dated 15 October 2025. Nothing here is an estimate and nothing is an agent's quote.

A qualified interest holder is anyone with ten percent or more of the capital or the votes, directly or indirectly. That definition is what turns a fee line into a real number: a structure with four owners and two holding companies costs more to file than the headline suggests, before anyone has looked at the paperwork.

Two invoices, two bodies, one deadline

The annual fee does not arrive as one bill. The CGA issues its supervisory invoice and the Curaçao National Treasury issues the licence invoice, simultaneously, each payable in full and electronically to the banking details printed on it. Both fall due on 15 January. B2B suppliers receive one invoice, because the treasury half does not apply to them.

Both go to the email address your local director gave the CGA, and both appear in the portal. That makes the local director a cash-flow role, not a formality — the payment clock starts when they are notified, and nobody else is told.

The first invoice is different

Initial annual fees are calculated pro rata for the year the licence is issued, and they are due within 14 days of the CGA notifying your local director of the grant. After that first period you move onto the ordinary 15 January cycle. Plan the first year's cash around a pro-rata bill on short notice rather than around a January date that has not arrived yet.

Nothing is granted until it is paid

Approval and grant are two events, and the invoice sits between them. Once an application is approved the CGA issues the annual invoices, and the licence is not granted — no Green Seal is issued — until they are paid in full. From there the schedule is published and mechanical.

Fifty-seven days from an unopened invoice to a rejected application is short for a company that has already spent months on the file. The failure mode is not insolvency, it is an invoice sitting in one person's inbox while the rest of the team assumes the licence is done.

Money you do not get back

All fees are non-refundable, and the schedule goes further than the usual formula. If a licence is revoked — at your own request or the regulator's — the full fee for the period it relates to remains payable. A six-month provisional period is owed in full whatever month it ends in; an annual period is owed in full whatever month it ends in. Handing back a licence in February does not release you from the year it covered.

Changing an owner costs money, and the CGA's own documents disagree

A share transfer or a new ultimate beneficial owner cannot be executed until the CGA has approved it in writing, and acting first may itself breach the LOK. So a change of control is a licensing event with a fee, not a corporate housekeeping task.

On the amount, the regulator's two published documents do not match. The fee schedule of 15 October 2025 puts a change or addition of a UBO at €128 per person. The Change in Control policy, version 1.1 of June 2025, annexes €150 per person for a B2C operator and €128 for a B2B supplier's qualified interest holders. The fee schedule is the later document and is the one headed "fees", which is why €128 is in our table above — but if you are budgeting a multi-owner restructuring, get the figure confirmed on the invoice rather than from either PDF.

Switching licence type, after you have paid

Operators who applied as B2C and reclassify to B2B do not simply lose the difference. The reclassification policy sets out three cases. If neither invoice has been paid, the CGA voids both and issues a single B2B invoice. If only the CGA's invoice was paid, it voids the National Treasury invoice and bills any shortfall. If both were paid, it bills any outstanding supervisory fee and gives instructions for reclaiming what went to the National Treasury.

That third case is worth reading twice. The reimbursement comes from the treasury, not from the CGA, and it is a process you start rather than a credit that appears.

What the schedule does not contain

The published fees are what you pay the regulator. They are not what the licence costs. The lines below are real and recurring, and we quote them per engagement because they are market prices set by other people, not regulated amounts — anyone publishing a fixed figure for them is quoting their own rate card, not Curaçao's.

• A local director in Curaçao, who receives every invoice and notice.
• A corporate service provider and the Curaçao entity itself.
• A compliance officer who passes the CGA's fit-and-proper review — a statutory role under the NOIS and NORUT ordinances, with a personal history disclosure and due diligence on the individual, not a title you assign internally.
• The policy set: AML and CFT, responsible gaming, complaints, and a crypto policy if you take crypto, each against the CGA's published template.
• Game and RNG certification through a certified independent test house.
• Blockchain analytics tooling, if the cashier takes crypto, plus the wallet-verification process the crypto policy expects.

The cashier is a cost line, not a feature

Curaçao's June 2026 crypto policy turned several cashier decisions into compliance spending. Licensees may not act as an exchange, a payment provider or a VASP themselves, so that function is bought in. Assets from sanctioned wallets, mixers and tumblers are prohibited outright, and wallets connected to the operator's own beneficial owners are prohibited with them. Privacy coins are not banned, but Monero and shielded Zcash have to be addressed explicitly in a policy the CGA holds on file.

In practice that means analytics tooling, a travel-rule process and someone to run them, from launch rather than at the first audit. It is more than Anjouan or Tuvalu require, and it is the reason a Curaçao brand gets a different reception from a payment institution. Which licence that trade-off favours is the question the comparison answers; this page only counts the money.

What we quote

We give one number for the regulator's fees, taken from the schedule above, and a separate number for everything in the list that is not the regulator's — company, director, compliance officer, policies, certification. We keep them apart on purpose, because the first is fixed and checkable and the second is ours to justify. The full picture of the licence, including what it does and does not let you do, is on the Curaçao licence page.