How to Check a Curaçao Licence Before You Buy
A Curaçao casino marked "Assessment in progress" does not hold an indefinite licence, but it has not been refused one either. The Curaçao Gaming Authority (CGA) simply has not finished its review, and that open decision passes to whoever buys the business.
Buyers should check the register themselves, treat the status as an open condition and tie part of the price to the outcome. Three checks decide most files: the licence status, whether critical suppliers are registered by 24 December 2026, and whether the CGA approves the new owner before any shares move.
This guide walks through each check and shows how the result should change price and closing conditions.
Why this check matters now
Nearly half of the entries on the CGA register are still unresolved, and two hard rules now sit around them. The register dated 2 November 2026 lists 666 entries. By our count, 298 read "Assessment in progress" (about 45%) and 206 read "Indefinite" (about 31%).
Every one of those 298 entries shows a printed expiry date that has already passed. The oldest date back to November 2025. That does not prove any operator is unlicensed. Curaçao Chronicle makes the same point: the register does not explain what legal effect a passed date has while an assessment is pending.
Date | What happened | Why a buyer should care |
|---|---|---|
Sep–Oct 2026 | The CGA took its licensing portal offline after unauthorised access, then dropped it and scheduled a temporary replacement for 19 October. | Licensee data was exposed, and filings may run slower or through new channels. |
Jul 2026 | The CGA published wind-down rules. A company refused a second provisional or indefinite licence gets six weeks to close in an orderly way. | A refusal can end trading quickly, and player claims and other debts must still be settled. |
Jun 2026 | The CGA confirmed supplier rules become fully enforceable on 24 December 2026. | A licensee may only use critical suppliers registered with the CGA. |
Dec 2025 | The CGA said an operator's status stays unaffected until a final decision is made, and said affected operators would receive individual letters. | That letter is a key document. Ask for it. |
Dec 2024 | The National Ordinance on Games of Chance (LOK) took effect. | Direct CGA licensing replaced the old sub-licence model. |
One more date matters for 2027. Local staffing rules are reported to apply from 1 April 2027, so a buyer should cost that into the first year of ownership.
How to check a Curaçao licence, step by step
Check the licence yourself from the CGA's own records, and do it at three points: before the offer, at signing and at closing. A seller's screenshot proves little, because the CGA says its overviews do not guarantee current validity and that no rights can be derived from them.
Get the legal details. Ask for the licensee's legal name, company registration number, licence number and every domain in the sale. The register lists companies, not brands, so a brand name alone will not find the entry.
Open the latest register edition. The register is a dated PDF that changes often, so note the "Last updated" date on your copy. Search by licence number, then confirm the company name and registration number match.
Read the whole row. Check the licence type, issue date, expiry date and status. A B2B entry covers supplier activity, not taking players. Numbers beginning OGL mostly come from the transition, while CGA numbers are newer applications.
Compare the expiry date with the file date. A passed date beside "Assessment in progress" is common, so treat it as a question to answer. A passed date beside "Expired" is a much bigger problem.
Check each domain. Click the seal on the live site and confirm it opens on cert.cga.cw and names that exact domain. The certificate site has no public search, and some certificates read Active while the register shows an unfinished assessment. Record both results.
Check the enforcement register. This is a separate list, and one review says it covers only actions affecting licence status. Search the licensee and any related companies.
Ask the seller for the CGA file. Request the licence documents, the individual letter on continued status, open queries, audit findings and any notices. Ask directly whether the CGA has raised deficiencies.
Save the evidence. Keep the PDF, certificate screenshots and date of each check in the data room.
The seal needs extra care right now. It was affected by the portal closure, so a missing seal alone does not prove a licence is invalid. If one is missing, ask the seller why and get the answer in writing.
Register rows also do not show which domains they cover. One company can run several sites, so a clean entry does not confirm that the brand you are buying sits under that licence.
What each status means for price and closing
The status decides how much of the price should be paid at closing, and how much should wait for an answer from the CGA. The register does not define its status wording, so the middle column is our commercial reading rather than the regulator's. The counts are our tally of the 2 November edition.
Status on the register | Entries | What it tells a buyer | Effect on price | Closing condition |
|---|---|---|---|---|
Indefinite | 206 | The full licence, with no expiry date. It can still be suspended or revoked. | No status discount. Price on the business and its compliance record. | CGA approval of the new owners. |
No status printed | 51 | Almost all show a future expiry date, which points to a provisional term still running. | Price the remaining term and the risk of no extension or refusal. | Confirm the term covers closing, and treat any later gap as an open licence risk. |
Assessment in progress | 298 | The CGA has not finished its review. Every entry shows a past expiry date. | Model a refusal case and hold back part of the price. | CGA letter on status, plus a holdback released by the final decision. |
Assessment in re-evaluation | 4 | The wording suggests a second look, but the register does not explain it. | Do not price until the reason is explained in writing. | Written explanation before signing. Consider walking away if none comes. |
Expired | 54 (one in administrative appeal) | The register no longer shows a live licence. | Value as non-licensed assets only, unless the status is formally reversed. | New licence or a different structure, on legal advice. |
Revoked at the operator's request | 53 | The operator gave up the licence. | No licence value. Ask why it was surrendered. | Proof that wind-down is complete and all player claims are paid. |
Revocation as an enforcement measure appears in the separate enforcement register, and it should stop most deals. An operator in that position must stop taking business and wagers immediately.
How to read "Assessment in progress"
This status is the most common one on the register, so it cannot be treated as a red flag on its own. The CGA said in December 2025 that status remains unaffected until a final decision is communicated. It also cannot be treated as the same thing as an indefinite licence, because the review may still end in refusal.
The price should reflect what a refusal would actually do. The six-week period is for closing the business, not for trading through it. Under the wind-down rules, a refused company cannot take new business, onboard players or let existing players keep wagering during that period. It must also settle player claims and other debts.
So a refusal stops revenue on the day it arrives, while costs and liabilities continue. A buyer should model that case directly and test how much cash would be needed to pay every player balance. There is a six-week window to object or appeal, according to one review, and your lawyer should confirm how that interacts with the wind-down.
Three questions separate a routine pending file from a weak one:
Why is it still open? Ask whether the CGA is simply behind or has asked the company to fix something.
What has the CGA requested? Open queries on ownership, AML or local substance matter more than the age of the file.
How would the business pay out? Check that player funds are held separately and cover balances in full.
The supplier check before 24 December 2026
From 24 December 2026, a CGA licensee may only use registered suppliers of critical services or goods. A casino can therefore have a clean licence entry and still inherit a problem through its game or sportsbook stack.
The rule depends on where the supplier is established. A supplier in Curaçao needs a CGA supplier licence and registration. A foreign supplier needs registration only. The exposure sits with the licensee as well, because Article 5.16(4) of the LOK bars it from obtaining critical services from an unregistered supplier.
Supplier type | Status under the CGA notice | What a buyer should do |
|---|---|---|
RNG game manufacturers | Named as critical | List each studio and contracting entity. Get proof or a dated commitment. |
Live dealer studios | Named as critical | Measure the share of GGR, as this is often hard to replace quickly. |
Game aggregators | Named as critical | Check the aggregator and the studios behind it. |
Sportsbook software, odds and settlement providers | Named as critical | Confirm each one separately, as one sportsbook can rely on several. |
Poker, peer-to-peer and lottery providers | Named as critical | Confirm registration where the product is live. |
Platform, payment orchestration, KYC and affiliate technology | Not named, but the list is illustrative | Ask the supplier for its position, and take advice rather than assume it is excluded. |
The CGA expected registration to open in October 2026. As of 6 November, we could not confirm from public sources that it has opened, and the portal disruption may have affected timing. Buyers should therefore ask for evidence, not rely on a promise that registration is coming.
Five steps keep this manageable:
Map the stack. Get a full supplier list from the seller, with contracting entities and country of establishment.
Measure dependence. Show GGR by supplier for 12 months, so you can see which gaps would hurt.
Collect the evidence. Ask for registration confirmation, or a written commitment with a date, from every critical supplier.
Update the contracts. Add registration warranties, notice of status changes and a right to suspend or exit.
Plan replacements. Line up alternatives for any supplier that is not registered. Advisers also report that adding a new supplier needs prior CGA consent, so allow time.
If closing falls after 24 December, make supplier compliance a closing condition. If closing falls before it, keep part of the price back until the critical suppliers are confirmed.
Change of control: what a sale needs from the CGA
A sale of a Curaçao licensee should not complete until the CGA has approved the new owners in writing. Changes to ultimate beneficial owners (UBOs), qualified interest holders or statutory directors need prior written approval, and share transfers or appointments may not take place before it. Doing so may be treated as a violation of the LOK.
A qualified interest is described as a holding of at least 10% of capital or voting rights, or comparable control. Any buyer group should map every person who crosses that line, including investors behind a holding company.
Item | What to expect |
|---|---|
Company documents | Draft share transfer agreement, updated share register and new structure chart |
Personal documents | Disclosure form, certified passport, birth certificate and proof of address, a criminal record check from the last six months, and evidence of source of wealth |
Fees | Low. Sources quote €128 to €150 per person, and more for a listed UBO |
Timing | No review period found. One source says review starts only after the invoice is paid |
These document and fee details come from adviser summaries, so check them against the current CGA guidance before filing.
Asset deals are harder here. One adviser says a licence cannot be transferred, assigned or sub-licensed in any form. A buyer of brands and domains alone should therefore not assume the licence comes too. Letting a seller's licence keep covering a sold brand is also a risk, because allowing another business to use a licence is listed as a breach of licence conditions.
Share deals keep the licence but bring the history. The buyer takes the company with its tax, player, AML and regulatory record. A new owner should expect that record to follow it into the CGA's review.
Do not change everything at once. One adviser reports that a new application may be needed when a sale also changes the business plan or gaming platform. Plan migrations for after approval, and confirm the position first.
Ask about the open assessment. We found no published rule on how the CGA treats a change of control while an assessment is pending. A new owner could add a further review to an already open file. Ask the CGA, through the licensee and your lawyer, before you fix a timetable.
A practical order is LOI, due diligence, an agreed draft SPA, CGA filing, approval, then completion. Your lawyer should confirm whether the SPA can be signed subject to approval or must wait. One Curaçao firm warns that completing a deal before consent can raise regulatory concerns and delay approval.
Contract protections for a pending licence
A pending licence can be bought safely only if the contract says what happens when the CGA decides. Most of the protection comes from three tools: closing conditions, specific warranties and a holdback tied to the outcome.
Closing conditions should normally include:
Written CGA approval of the new UBOs, qualified interest holders and directors.
No adverse change in register status, and no refusal, suspension or revocation notice.
A fresh register, certificate and enforcement check dated close to completion.
Registration evidence for the agreed critical suppliers.
Player funds reconciled to the balances owed.
Warranties should cover the facts the buyer cannot see. Ask the seller to warrant that all CGA correspondence has been disclosed, no deficiencies are unresolved except those listed, and all approved domains and suppliers are as stated. Add specific indemnities for pre-closing player claims, regulator penalties, tax and unpaid CGA fees.
A holdback bridges the gap between the seller's view and the buyer's. The example below uses invented figures for a €1,000,000 price and is not a market benchmark.
Part of the price | Amount (€) | When it is paid | Condition |
|---|---|---|---|
Paid at closing | 700,000 | Completion | CGA change-of-control approval and other closing conditions met |
Licence holdback | 200,000 | When the CGA decides | Indefinite licence granted before an agreed long-stop date |
Supplier holdback | 100,000 | 90 days after 24 December 2026, or later if closing is later | Agreed critical suppliers registered, or replaced at the seller's cost |
Total | 1,000,000 |
Four drafting points prevent disputes later:
Set a long-stop date. Decide what happens if the CGA has still not decided by then, as many files have already run for months.
Say what a refusal triggers. Spell out the return of escrow, who funds the wind-down and who pays player balances.
Control the file. Agree who speaks to the CGA, and require the buyer to keep the file moving after closing.
Cover appeals. State whether an objection pauses the holdback, and for how long.
Put the structure in the letter of intent, so it does not reopen the price later. For the standard workstreams, see our due diligence protocols and escrow guide.
What sellers should do now
A seller with a pending licence protects the price by answering the buyer's questions before they are asked. Most buyers will run these checks anyway, and an unexplained status invites a lower offer.
State the status accurately. Quote the licence number, status and register date in your listing. Do not describe an assessment as a full licence.
Prepare the CGA file. Gather the licence documents, status letter, audit results and any open queries.
Align the records. Make sure the register, certificates, company documents and site terms all show the same entity.
Close the supplier gaps. Collect registration evidence now, and record who is still outstanding.
Check local substance. Confirm your director, key persons and office position against the rules applying from 1 April 2027.
Reconcile player funds. Show that player balances are covered and held separately.
Offer a structure. If you expect the indefinite licence, accept a holdback that pays you when it arrives.
A buyer will also ask about timing. Allow for the CGA's change-of-control review when you plan the sale, and start early if you want to close in the first quarter of 2027. Our seller guide covers how to prepare a listing, and our valuation tool gives a starting estimate.
Frequently asked questions
What does "Assessment in progress" mean on the CGA register?
It means the CGA has not reached a final decision on an indefinite licence. The register itself does not define the phrase. In December 2025, the CGA said status stays unaffected until a final decision is communicated.
Is a Curaçao casino illegal if its register expiry date has passed?
Not automatically. A passed date beside "Assessment in progress" is common, and it does not by itself show the operator is unlicensed. Ask for the CGA's letter on continued status, and get legal advice on the entity you are buying.
Can you buy a casino with an assessment still in progress?
Yes, but pay for it in stages. Require CGA approval of the new owners, test the file behind the status and hold back part of the price until the CGA decides.
How long can a refused operator keep trading?
It effectively cannot. The six-week period is for an orderly wind-down, and new business, new players and further wagers are not allowed during it.
Does a Curaçao licence transfer to a buyer?
Advisers say a licence cannot be transferred or assigned, so most buyers acquire the licensed company. That needs prior CGA approval of the new owners, directors and qualified interest holders.
Do foreign suppliers need a Curaçao licence?
No, but foreign suppliers of critical services or goods must register with the CGA by 24 December 2026. Suppliers established in Curaçao need both a supplier licence and registration.
Where can I check a Curaçao licence?
Use the latest register on the CGA's website, the certificate opened from the site's seal and the separate enforcement register. Search by licence number and keep a dated copy of each result.