Curacao Enforces Stronger T&Cs Gaming Regulations Through New LOK System

The new framework sets out comprehensive requirements for how licensed operators must draft, present and maintain their T&Cs, with a clear emphasis on eliminating ambiguity and ensuring alignment with Curacao law and regulatory expectations. The regulator aims to reinforce a broader shift toward transparency, enforceability and player protection.

The policy requires that T&Cs be accessible, readable and available within one click across all platforms, including mobile and account interfaces. Operators must also ensure consistency between their T&Cs and their actual business practices, covering everything from payment methods to promotional mechanics. Importantly, retrospective changes are largely prohibited unless they do not disadvantage players or correct clear errors, addressing a long-standing industry criticism around shifting contractual terms.

The policy will come into force within six months of publication and will apply to all B2C licensees, giving operators a defined but relatively tight window to review and overhaul their existing T&Cs.

A key operational shift comes in how player consent is handled. Passive acceptance mechanisms are no longer sufficient, with operators now required to obtain explicit acknowledgment during registration, typically via a checkbox. Material changes to T&Cs will also require active re-acceptance, while operators must retain verifiable records of player consent and notification history. This effectively creates an auditable trail of contractual agreement between player and operator, something that has often been lacking in legacy Curacao setups.

The CGA has also tightened disclosure requirements, mandating that T&Cs prominently display core licensee information, including legal identity, registration details and license credentials. Operators must clearly distinguish which products fall under CGA regulation and flag any redirection to non-CGA entities, addressing concerns around multi-brand structures and regulatory arbitrage.

Player obligations are a major focus

The policy requires operators to clearly define eligibility criteria, account usage rules and prohibited behaviors, including fraud, collusion and misuse of communication tools. There is also a strong compliance overlay, with explicit references to KYC and AML/CFT requirements. Players must be informed that their transactions are monitored, that data may be screened against sanctions lists, and that suspicious activity will be reported to authorities.

Notably, the guidance attempts to balance compliance with user experience, particularly around KYC. While operators can request refreshed verification at account closure, they are discouraged from introducing additional friction unless strictly required under AML/CFT obligations, a direct response to industry complaints about withdrawal delays being disguised as compliance checks.

Account lifecycle management is covered in detail, with prescriptive requirements on suspension, termination and dormant accounts. Operators must clearly define what happens to player funds in each scenario, including timelines, escalation procedures and any applicable fees. Dormancy fees, where applied, must be fair, proportionate and transparently communicated in advance.

The treatment of player funds is another area of increased scrutiny. T&Cs must outline all deposit and withdrawal methods, expected processing times and any conditions attached to withdrawals. There is also a specific threshold reference of XCG4,000 ($2,200) for enhanced verification triggers, aligning operational practices with AML expectations. Crypto transactions receive dedicated attention, with requirements to address scenarios such as lost wallets, chain forks and sanctioned addresses.

The CGA has also moved to standardize how operators handle errors and disputes. T&Cs must clearly outline procedures for voiding bets, correcting odds errors and handling software or live dealer mistakes, including refund mechanisms. Bonus terms, long a source of player complaints, must be clearly disclosed, explicitly accepted and structured in a way that does not prevent players from reviewing full conditions.

In a notable clarification, operators are required to state explicitly that they are not financial institutions and do not pay interest on player balances, reinforcing the legal distinction between gaming accounts and banking services.

Responsible gaming and dispute resolution frameworks must also be embedded or clearly linked within T&Cs, while fairness provisions must explain how game outcomes are determined, including the use of certified RNGs and dispute handling mechanisms.

From an enforcement perspective, the CGA has signaled a more assertive stance. Non-compliance with the policy constitutes a breach of license conditions and may result in corrective directives, administrative fines or even license suspension or revocation. Operators will also be required to upload current and historical versions of their T&Cs to the CGA portal, ensuring ongoing regulatory visibility.