Offshore gaming jurisdictions

The offshore licensing landscape changed more between December 2024 and January 2026 than in the three decades before it. Curaçao — for most of that period the cheapest and most permissive route to market — abolished its master licence system, established a direct regulator with investigative and revocation powers, and introduced local substance requirements. Anjouan, which asks for no minimum capital and no physical presence, has taken over the entry segment Curaçao vacated.

This page sets out how the regimes differ. Each jurisdiction has its own page with the detail.

What changed, and why

The reform in Curaçao was not voluntary. The Dutch government made an overhaul of the island's gaming framework a condition of the pandemic financial assistance Curaçao required as an autonomous country within the Kingdom of the Netherlands. The result was the National Ordinance on Games of Chance — the LOK — passed by parliament on 17 December 2024 and in force from 24 December 2024.

What it replaced had been in place since 1993. Under the old NOOGH framework, four private master licence holders sold sub-licences to operators. The regulator did not deal with operators directly, and the practical barrier to entry was the price a master licence holder chose to charge.

That system is gone. All legacy sub-licences expired in January 2025. The orange transitional seals that marked in-process applications expired permanently on 15 October 2025. From 1 January 2026, licence holders must maintain a physical presence on the island. Our page on the Curaçao licence after the LOK covers the framework in detail.

How the regimes compare

The Anjouan regime sits at the opposite end of the same market: one licence covering every vertical, no capital requirement, and no presence in the jurisdiction beyond a registered address.

What a licence does and does not guarantee

A licence is a supervisory relationship, not a warranty. It means an authority has examined the applicant, holds records on its beneficial owners, and can act if conditions are breached. It does not mean the operator is solvent, that a particular withdrawal will be paid, or that a dispute will be resolved in the player's favour.

What differs between regimes is how much examination happens and what the authority can do afterwards. The CGA conducts its own investigations into ultimate beneficial ownership, maintains a public register, and holds suspension and revocation powers. Anjouan applies fit-and-proper standards and AML obligations through a two-tier structure, but does not publish a register of licensees.

We set out what this means in practice for a player in what an offshore licence means for players, and the wider context in our reference guide to offshore casinos. From the operator's side, the same requirements determine what launching under one of these regimes involves. There is also en dansk gennemgang af de samme regimer, written for players rather than operators.

Verifying a licence

Every jurisdiction publishes some means of confirming that a seal displayed on an operator's site corresponds to a real authorisation. Forged seals are not hypothetical: in February 2026 the CGA issued a public warning about a site displaying a fabricated digital authorisation.

Our licence verification checklist sets out how to check a seal against the issuing authority's own records.

Page last reviewed: 1 August 2026