Anjouan vs Curaçao Gaming License
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Choose between Anjouan and Curaçao by what your project does, where it sells, what partners require and its compliance capacity. Neither licence opens every market. Do not pick either on an advertised fee or launch time alone.
Compare Curaçao under the CGA's current LOK framework, not as an old master-licence sales package. Anjouan issues separate operator and supplier licence types.
Research checked: 1 October 2026. Every project needs its own regulatory, tax and market-access review.
What are the decision-relevant differences?
Curaçao's LOK sets explicit requirements for the applicant and its local management. The issuer’s October 2026 application guidance asks for a legal entity in Anjouan or in another jurisdiction it accepts for the application. A foreign entity’s eligibility must be confirmed under current programme policy. The licence conditions set no local staff or premises rule. Confirm the entity with the issuer before you apply, then compare price.
Factor | Anjouan | Curaçao under LOK |
|---|---|---|
Approval model | B2C and B2B categories; supplier recognition is a separate question | CGA operator licences and, for Curaçao-based suppliers, supplier licences (Article 5.13); old master-licence packages no longer describe the model |
Applicant structure | Certified incorporation documents and the full ownership chain for group companies; an entity in Anjouan or another jurisdiction the issuer accepts, with foreign-entity eligibility confirmed per application | Article 2.1 specifies a Curaçao-incorporated NV or BV with its statutory seat there |
Management | Key Person Authorisation for designated roles; no residency rule in the licence conditions we checked | Article 2.1 requires resident management, directly or through the specified local corporate-director structure |
Licence duration | Check the validity and renewal terms on the issued licence | Indefinite under Article 2.1 unless the LOK provides otherwise; a provisional licence runs up to six months, extendable by six (Article 5.1) |
Local operations | No local staff or premises rule in the licence conditions. Every licensee must show a commercial and economic rationale for its software, marketing, consultancy and technology contracts. Its platform and content suppliers must hold an Anjouan B2B licence or recognition certificate | Article 5.12 requires key persons registered in Curaçao and dedicated local premises; some new, smaller operators qualify for an exemption |
Fees | Separate published issuance and renewal charges | Annual charges apply even though the authorisation has no end date |
Sources: Anjouan categories and the official Dutch LOK text, Articles 2.1 and 5.12. The enacted text is in Dutch; check any English summary against it with counsel.
LOK entered into force on 24 December 2024, according to the CGA. If you already operate, check your own transition position. Do not assume an old document is current, or that it is invalid. The CGA says the old LBH ordinance still matters through the LOK transitional provisions.
On 23 January 2026 the CGA announced that operators do not have to meet the Article 5.12 substance requirement before 1 April 2027. The Ministerial Decree that is to formalise this had not appeared on the CGA publications page by 1 October 2026.
Can your company and operating model fit Curaçao's requirements?
Only if you will set up and keep the Curaçao entity and management that LOK requires. If you will not, resolve that before you commission an application. Anjouan needs its own check of entity, legal basis and operating requirements.
Take an overseas company that wants to keep its current legal entity. For Curaçao, the NV/BV requirement is structural. The company can assess a compliant local applicant structure or reconsider the route.
Operators and critical suppliers can only apply through the CGA portal, according to its information page. On 7 October 2026 the CGA said its online gaming portal would not return to service. It announced a new interim portal for 19 October; by 23 October it had not confirmed that the portal is live or published new filing deadlines. Confirm current submission arrangements with the CGA before you set a filing date. Whether the portal works says nothing about the standing of an existing licence.
For Anjouan, have counsel also cover the separate licensing legal-basis question. A working portal or a register listing does not settle the full legal analysis.
Which scenarios support assessing each route?
Look at Anjouan for a new operation whose providers will work with an Anjouan-licensed entity. Keep Curaçao under review for an existing operation that can meet LOK. These scenarios do not predict approval or rank the routes.
Project scenario | Route to investigate | Condition before committing |
|---|---|---|
Existing Curaçao operation with a current approval and supported suppliers | Keep or adapt the Curaçao structure | Check transition status, obligations and whether partners stay on |
New operation with counterparties willing to assess an Anjouan-licensed entity | Anjouan | Confirm approval scope, each market and provider contracts |
Supplier serving several operator jurisdictions | Separate supplier and recognition assessments | A consumer licence does not answer the supplier question |
Business looking to replace a required domestic licence | Neither | Check what the target market's law requires first |
Urgent launch that depends on online filing | Test both routes against real dependencies | Confirm filing access works; do not plan around a guaranteed date |
Game studios and platform vendors need a different comparison: the Anjouan B2B gaming license against supplier recognition. The operator comparison on this page does not fit them.
How should you compare fees and total operating cost?
Compare Anjouan and Curaçao budgets for the same entity role, products, domains and operating period. The licence fee is only one line of that budget.
Anjouan's published fee schedule lists €17,828 for issuance and €17,828 for annual renewal, for either a B2C or a B2B licence. Each extra B2C domain costs €500 per licensing cycle. These are separate charges, not an all-in launch quote.
For Curaçao, the original LOK text, Articles 5.18 and 5.19, sets a €4,592 operator application fee. Add €150 for each ultimate beneficial owner and each qualified holder, and €2,551 for each ultimate beneficial owner that is a stock-exchange-listed company. Adding each domain to the licence costs €250. An operator pays €22,960 a year to the CGA and €24,490 to the Treasury, €47,450 in total; a supplier pays €24,490. The law allows all of these to change by decree, and the annual fees can follow consumer prices. Get the current CGA fee schedule and a dated quote before you budget on them.
Price both routes on the same lines:
Cost component | What each route's budget must show |
|---|---|
Authority charges | Application, issuance, recurring fees, scope changes and due diligence |
Company and governance | Incorporation, management, senior roles and ongoing administration |
Technical compliance | Testing, certification, hosting, security and monitoring |
Operations | Compliance staff, complaints, accounting and reporting |
Commercial stack | Platform, games, payments, reserves and minimum commitments |
Transition and exit | Ending existing contracts, migration and parallel running |
Build the budget as two separate years. Year one covers setup, the application and the recurring services due in that year. Year two covers renewal or annual charges plus ongoing governance, technology and compliance. Price variable charges on the same forecast volume for both routes. Until every line has an amount, treat the table as a checklist.
Keep refundable reserves, working capital and restricted cash out of operating expenses. Ask a tax adviser to model your actual entity, place of management and customer locations. A "0%" gaming-tax headline does not settle the tax bill of the whole business.
MGL's Anjouan gaming license service covers application requirements, documents, costs and support packages. MGL also handles Curaçao gaming license applications under LOK.
What determines a realistic launch timetable?
Launch on either route depends on approval, domain coverage, supplier acceptance, payments and operational testing. A fast licensing estimate does not mean the rest finishes at the same time.
Under Anjouan's application process, progress depends on complete documents and due-diligence review. For Curaçao, LOK Article 5.1 gives the CGA eight weeks for each of two review phases, each extendable by four weeks, counted from complete documents. Confirm current submission arrangements and the start of the applicable review period with the CGA before scheduling filing. For each dependency, get a date, the evidence needed to start it and the party responsible.
Before you rely on an Anjouan counterparty, run the licence and domain verification workflow. For both routes, run the market-access review with advice on each target market.
Can you move an existing business from one licence to the other?
A move needs a transition plan: a new licence does not carry over the old operator's contracts, funds or data. Run regulatory approval, operational migration and customer communication as separate workstreams.
Write down which entity will contract with players after the change and how it will handle balances and complaints. List the supplier consents you need and the date domain and legal notices change. A provider's standard migration timetable is not permission to move customer accounts.
Compare your project with MGL
To request a jurisdiction comparison with MGL, send your entity structure, products, target markets, existing approvals and supplier requirements. Ask for an itemised scope and a plan built around your dependencies. Regulatory approval and bank or PSP acceptance are not guaranteed.
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