The licence application is not the first step — the corporate entity is. Both main offshore regimes require the applicant to be an entity rather than a person, and Curaçao requires that entity to be incorporated locally before an application can be made at all.
This page sets out what each regime requires of an applicant, what the regulator examines, what happens after a licence is granted, and where applications typically stall. It is part one of three; parts two and three cover platform and payments and acquisition.
The applicant must be an entity
Neither regime licenses individuals. The licence attaches to a company, and the company's permitted form is set by the jurisdiction.
Curaçao requires a legal entity established under Curaçao law with its statutory seat on the island. The entity must be managed by at least one natural person resident in Curaçao — or by a corporate entity incorporated under Curaçao law that itself has a resident managing director.
Anjouan requires a registered legal address in the jurisdiction. No local incorporation, no resident director, no minimum capital.
This single difference propagates through everything downstream. A Curaçao licence carries an ongoing corporate cost that an Anjouan licence does not, and it requires finding and retaining a resident director — a role that carries legal exposure and is priced accordingly.
It also affects banking. A company with genuine local substance is a different proposition to a bank than a company with a registered address, and banking availability is a constraint that surfaces later in the process than most applicants expect.
What the regulator examines
Curaçao conducts its own investigations into ultimate beneficial ownership rather than relying on documentation supplied by the applicant.
This is a substantive change from the framework it replaced. Under the pre-2024 system, four private master licence holders sold sub-licences onward. The regulator had no direct relationship with the operators running on those sub-licences, held no record of who owned them, and had no practical means of enforcement against them. Dismantling that arrangement was a condition the Dutch government attached to pandemic financial assistance.
Licences issued under the current framework are recorded in a public register.
Anjouan applies fit-and-proper standards through the Anjouan Offshore Finance Authority, alongside sector-specific oversight from the Anjouan Betting and Gaming Board, with licensing administered by a third party since May 2023. No public register is published.
For an applicant, the practical difference is disclosure. A Curaçao licence makes ownership verifiable by anyone who looks. Whether that is an asset or a cost depends on the operator — a verifiable licence carries weight when acquiring players and when negotiating with payment processors.
What documentation is required
Both regimes require broadly the same categories, and assembling them is where most of the elapsed time goes.
Beneficial ownership. Identity documentation for every natural person holding a qualifying interest, together with the ownership chain if the holding is indirect. Nominee structures do not remove the requirement; they add a layer to it.
Source of funds. Documentation of where the capital originates. This is routinely the slowest element to assemble, particularly where funds have moved between jurisdictions or where the applicant's earlier business activity is not straightforward to evidence.
Business plan and financial projections. Intended markets, product mix, projected volumes, capitalisation.
Technical documentation. Platform architecture, game certification, RNG testing where applicable, data handling.
Compliance framework. AML policy, KYC procedures, responsible gaming measures, and a named compliance officer.
Criminal record certificates. For directors and qualifying shareholders, typically from every jurisdiction of residence over a defined period.
Licence categories
Curaçao operates three:
| Category | Covers |
|---|---|
| B2C Gaming Licence | Operators serving players directly |
| B2B Supplier Licence | Software, platform and payment providers |
| Non-profit Game Licence | Charitable gaming |
An operator building on a third-party platform needs the B2C licence; the platform provider needs the B2B licence in its own right.
Anjouan issues one comprehensive licence covering online casino, sports betting, poker, bingo, lottery, eSports and blockchain-based gaming, for both B2C and B2B activity, across up to two web addresses.
Since July 2025, B2B providers serving Anjouan licensees must hold their own licence. This extends supervision along the supply chain rather than stopping at the operator — and it means an operator contracting with an unlicensed platform provider carries the exposure even though the obligation sits with the provider. Verify licence status before signing, not after.
Substance requirements
This is where the two regimes have diverged most sharply, and it is the change most often missed by applicants working from older guidance.
From 1 January 2026, Curaçao licence holders must maintain a physical presence on the island. The requirement forms part of the National Ordinance on Games of Chance, which came into force on 24 December 2024 and replaced the framework in place since 1993.
Anjouan imposes no substance requirement. A registered address is sufficient; there is no obligation to maintain staff, premises or to travel to the jurisdiction.
Substance is not administrative detail. It determines ongoing cost, affects tax position, and in some cases determines whether a banking relationship is available at all. An entity with no presence in its jurisdiction of incorporation is a harder banking proposition than one with an office and staff.
Anti-money laundering obligations
Both regimes impose AML and counter-terrorist-financing obligations aligned with FATF recommendations.
Curaçao published its AML, CFT and CFP regulations in May 2024. They took effect on 20 May 2024 with a three-month transitional period, making full compliance mandatory from 1 September 2024 — four months before the licensing framework itself came into force.
The sequencing is worth noting: obligations were imposed on the sector before the regime that would enforce them existed.
Anjouan applies AML/CFT supervision through the Offshore Finance Authority and requires quarterly compliance reporting. Q1 2026 reports were due by 30 April 2026.
In operational terms both mean the same thing: identity verification at onboarding, ongoing transaction monitoring, enhanced due diligence for higher-risk customers, suspicious activity reporting, record retention, and a named compliance officer with actual authority. Anjouan charges approximately €2,000 annually per authorised key person, which includes that role.
The compliance officer is not a formality. Both regimes examine the function when something goes wrong, and an officer who exists on paper but has no authority to halt a transaction is a finding rather than a defence.
Cost and processing time
| Curaçao | Anjouan | |
|---|---|---|
| Application, year one | Not verified | ~€17,828 |
| Annual renewal | Not verified | ~€13,300 |
| Per key person, annually | — | ~€2,000 |
| Gaming tax | Not verified | None |
| Processing | Months | Reported at two to eight weeks |
The Anjouan figures come from the licensing administration's published schedule. The Curaçao figures are absent because we have not verified current fees or the gross gaming revenue rate against the authority's own publications, and we do not publish figures we cannot source. See how we handle sources.
Sequence
1 · Choose the jurisdiction. This determines corporate form, cost base, substance obligation and market reach. A licence that excludes the target market is not a cheaper licence; see market access for offshore licensees.
2 · Incorporate. Weeks. Must complete before application, since the applicant is the entity.
3 · Assemble documentation. Beneficial ownership, source of funds, business plan, technical and compliance material. This runs longer than applicants expect and can begin before incorporation completes.
4 · Submit and respond. Both regulators return with questions. Response time is largely within the applicant's control and is the most common cause of delay.
5 · Grant. The licence enables the next steps — most importantly payment processing, which cannot be arranged without it.
After the grant
A licence is a continuing relationship, not a permission obtained once.
Renewal. Annual, with fees payable and compliance status reviewed.
Reporting. Anjouan requires quarterly compliance reports. Curaçao's regulator supervises on an ongoing basis and can request information.
Notification of change. Changes to ownership, directors, platform provider or markets served generally require notification and in some cases prior approval.
Suspension and revocation. Both regulators hold these powers. Curaçao's authority also coordinates with international regulators and handles dispute resolution between players and operators — which means player complaints can become a supervisory matter.
The transition period demonstrated what falling outside a regime means in practice. Operators still trading on expired Curaçao sub-licences after 15 October 2025 were, in regulatory terms, unlicensed — regardless of what their sites displayed.
What delays applications
Incomplete beneficial ownership disclosure. Curaçao investigates independently. Discrepancies between what is declared and what is found stop the process, and they are difficult to recover from.
Source of funds documentation. Consistently the slowest element.
Corporate formation started too late. The entity must exist first, and in Curaçao it must have a resident director in place.
Slow responses to regulator queries. Both regimes come back with questions. Weeks spent assembling an answer are weeks added to the timeline.
Reliance on outdated guidance. A substantial volume of material published online describes Curaçao's pre-2024 master licence system — including material still ranking in search. Applications prepared against it are prepared against a framework that no longer exists.
Further detail on each regime
We document the two frameworks in full: Curaçao and Anjouan.
Page last reviewed: 2 August 2026