Curaçao’s LOK Reform: What B2B/B2C Licence Reclassification Really Means

Curaçao’s online gaming overhaul has moved from theory to reality.

With the National Ordinance on Games of Chance (LOK) now in force, the old NOOGH + master licence + sub-licence model is being dismantled and replaced by a centralised system run directly by the Curaçao Gaming Authority (CGA). gamingcontrolcuracao.org

A key piece of this shift: some licences that were historically treated as “B2C” (player-facing) are now being re-classified as B2B supplier licences-because, in practice, those companies only provide services to other operators.

At the same time, the CGA has confirmed that the long-familiar “Orange Seal” (Certificate of Operation used under the old sub-licence system) must disappear from operator websites by 15 October 2025, marking the end of that legacy framework. European Gaming

For operators, this isn’t just a cosmetic change. It’s a structural one-and it comes with deadlines.

From NOOGH to LOK: why reclassification is happening

Under the former National Ordinance on Offshore Games of Hazard (NOOGH), a small number of master licence holders could issue sub-licences. Many businesses plugged into that system in whatever way made commercial sense, and the labels (B2B vs B2C) didn’t always perfectly match what they actually did in the market. InsideBitcoins.com

The LOK regime flips that:

• Licences are now issued directly by the Curaçao Gaming Authority (formerly the Gaming Control Board).
• There are clear categories for B2C operator licences (directly serving players) and B2B supplier licences (critical gaming services and platforms provided to operators).
• The goal is to align Curaçao with international standards on transparency, AML/CFT and player protection, and to move away from the lightly supervised sub-licence era.

In that context, the CGA is asking companies to look in the mirror and ensure their licence type matches reality. If you act like a supplier, you need a B2B licence-not a B2C badge that suggests you’re player-facing when you’re not.

What’s changing around seals and symbols

Historically, many Curaçao-licensed sites showed the Orange Seal to signal they operated under a master licence / sub-licence structure.

That era is over:

• The CGA has announced that the transition arrangement for the Orange Seal ends on 15 October 2025. After that date, any operator still displaying the Orange Seal will be in breach of Curaçao law. European Gaming
• Licensed operators are expected to use the Green Seal issued under the LOK framework, which indicates a licence granted directly by the CGA. European Gaming

In parallel, provisional “Green Seal” B2C and B2B licences have been extended to 24 December 2025 for qualifying operators, to give more time for full LOK applications to be processed-though not every operator automatically gets the full extension

So, seals are no longer just branding: they’re signals that must match your underlying licence and category.

The main reclassification scenarios (in plain language)

Different businesses are starting from very different places. In practice, most operators will fall into one of a few buckets.

1. You hold a “B2C” licence but only do B2B work

If you never touch players and instead:

• host platforms for other operators,
• supply games, odds or sportsbook feeds,
• provide back-end services, risk or payment routing only to licensed B2C brands,

then you’re effectively a B2B supplier.

Under the LOK model, these businesses are expected to hold a B2B supplier licence, not a B2C operator licence. The CGA’s portal describes supplier licences for entities providing “gambling-related critical services and goods, such as games and sportsbook software, in or from Curaçao.” portal.gamingcontrolcuracao.org

In practice, that usually means:

• applying to reclassify into the LOK B2B category, and
• updating your documentation (business plan, AML, information security, etc.) to reflect that role.

2. You already function as a B2B licence holder under NOOGH

Some entities were already recognised as B2B providers under the old regime.

For those, the task is more of a formal migration: moving from NOOGH-based approvals into the LOK B2B supplier licence category with updated documentation and policies that match the new law’s standards on AML, player protection (where relevant) and IT security.

Think of it less as a new business model and more as a stricter, modernised wrapper around what you were already doing.

3. You’re shifting from B2C to B2B

Some operators are deciding that direct-to-player activity is too costly or risky, and are pivoting into pure B2B (for example, white-label or platform models only).

Here, the rule of thumb is:

• wind down and terminate your B2C licence under the old framework,
• then apply for a fresh LOK B2B supplier licence that reflects your new business model,
• making sure your contracts, compliance documentation and technical set-up also reflect that you no longer face players directly.

4. You’re moving from B2B to B2C

The opposite move-suppliers going “direct-to-consumer”-is also happening.

If you decide to start operating casinos, sportsbooks or other games directly for players, you’ll need to:

• terminate any legacy NOOGH-era B2B licence that no longer matches your main business, and
• apply for a full LOK B2C operator licence, which comes with additional responsible-gaming duties, RG policies and direct supervision over how you treat end-users.

In practical terms, this can be a heavier lift: you’ll need policies on player-protection tools, self-exclusion, marketing standards and more.

What the CGA expects in your transition file

Whether you’re reclassifying, switching models or applying fresh under LOK, the ingredients are broadly similar.

Through its online portal and public communications, the CGA signals that applicants should be ready to submit:

• A business plan updated for the LOK framework (including structure, markets, products and risk analysis)
• A completed Operator or Supplier licence application form (B2C or B2B)
• Full corporate and ownership documentation, including ultimate beneficial owner (UBO) disclosures
• Information Security Policy, covering infrastructure, access controls, incident response, and data protection
• Certification or test reports for platforms and games (from recognised test labs where required)
• AML/CFT policies and procedures aligned with Curaçao’s role as an AML/CFT supervisor for gaming
• Declarations of good standing and fit & proper information for key personnel

The CGA will then review, ask for clarifications if needed, and-assuming approval and payment of fees-issue new LOK-compliant certificates. Updated fee details for B2C and B2B licence holders have been published in recent policy updates. AGB - Asia Gaming Brief

Deadlines and pressure points to watch

A few dates matter more than others.

• 15 October 2025 – Orange Seal sunsetThe “Orange Seal” Certificate of Operation ceases to be valid. Any operator still displaying it after that date is in breach of Curaçao law and should switch to the Green Seal if properly licensed. European Gaming
• 24 December 2025 – extended provisional Green Seal licencesProvisional B2C and B2B licences under the “Green Seal” system have been extended to this date for certain operators, to give more time for full LOK-compliant applications to be finalised. Operators still need to show real progress towards meeting LOK standards-extensions are not automatic. iGB+2iGaming Express

Beyond those headline dates, Curacao’s broader LOK rollout continues, including:

• new responsible-gaming and consumer-protection requirements for B2C operators,
• stricter AML/CFT expectations for both B2C and B2B,
• and a more assertive regulatory posture as Curaçao aims to elevate its reputation among gambling regulators worldwide.

What operators should do now

If you’re licensed in Curaçao or thinking about applying under LOK, this transition is more than a formality.

Practical steps:

• Audit your business model honestly. Are you really B2C, really B2B, or a hybrid? Does your licence category match what you actually do?
• Map your licences, seals and sites. Make sure every domain displays the correct seal (Green, not Orange) and points to the right underlying licence.
• Update your documentation. Business plan, AML/CFT, information security and responsible-gaming policies should all be LOK-ready.
• Use the CGA portal as your single channel. The Authority expects all licence-related communication via its official portal to ensure traceability and clean records. portal.gamingcontrolcuracao.org

The direction of travel is clear: Curaçao wants a modern, supervised, internationally credible regime, not a loose network of sublicences.

If your licence type, seals and documentation don’t reflect that reality yet, now is the moment to fix it-while the transition window is still open.