The Curacao Gaming Authority (CGA) has issued new policy guidelines governing player-facing Terms and Conditions (T&Cs). This marks a major tightening of compliance standards under the island’s evolving LOK framework, Curacao’s updated gaming law and licensing regime.
The guidance introduces detailed requirements for how licensed operators must draft, publish, and maintain their T&Cs. It has a strong focus on eliminating ambiguity and strengthening transparency, enforceability, and player protection.
New Rules Require Clearer and More Accessible T&Cs
Under the new policy, operators must ensure that T&Cs are easy to read, clearly written, and accessible within one click across all platforms. This includes mobile interfaces and player accounts. The CGA also requires operators to align contractual terms with actual business practices. This ensures consistency across payments, promotions, and product mechanics.
Importantly, the regulator has moved to restrict retrospective amendments. Operators will generally be prohibited from making changes that disadvantage players, except where updates correct clear errors or improve fairness. This addresses long-standing criticism of Curacao-licensed operators altering contractual terms after player activity has already taken place.
The policy will take effect within six months of publication and applies to all B2C licensees. Therefore, operators have a limited window to review and overhaul their existing T&Cs.
Explicit Player Consent Now Mandatory
A major operational change is the shift away from passive acceptance models. Operators must now collect explicit player consent at registration, typically through a checkbox confirmation. Material updates to T&Cs will also require active re-acceptance, rather than simply notifying players.
Operators must maintain verifiable records of consent, including notification history. This creates an auditable trail that strengthens enforceability and supports dispute resolution.
Stronger Disclosure Requirements for Licensing and Brand Structure
The CGA has expanded disclosure obligations, requiring operators to prominently display their legal identity, registration details, and licensing credentials in their T&Cs. Moreover, operators must clarify which products fall under the CGA licence and disclose when they redirect players to entities outside CGA oversight.
This targets regulatory concerns around multi-brand structures, outsourcing arrangements, and jurisdictional arbitrage.
Player Obligations and Compliance Controls Highlighted
The policy also demands clearer definitions of player eligibility rules, account usage terms, and prohibited conduct such as fraud, collusion, and misuse of communication tools. Operators must explicitly reference KYC and AML/CFT obligations, including warnings that they may monitor transactions, screen activity against sanctions lists, and report suspicious behaviour to authorities.
While the CGA reinforces compliance expectations, it also addresses user experience concerns by discouraging unnecessary KYC friction. This is particularly important where verification delays are used to slow withdrawals under the guise of compliance.
Tighter Rules on Account Closures, Dormancy, and Player Funds
The framework now tightly regulates account lifecycle management, covering suspension, termination, and dormant accounts. Operators must clearly explain how they will handle player funds, including timelines, escalation processes, and any applicable fees. If operators apply dormancy fees, they must ensure the charges remain fair, proportionate, and communicated in advance.
T&Cs must also provide detailed information on deposits and withdrawals, including payment methods, expected processing times, and withdrawal conditions. Furthermore, a specific threshold of XCG 4,000 (around $2,200) is referenced as a trigger for enhanced verification. This aligns operator processes with AML standards.
Crypto transactions receive dedicated attention, including obligations to address issues such as lost wallets, chain forks, and sanctioned blockchain addresses.
Bonuses, Disputes, and Errors Must Be Clearly Defined
The CGA is also standardizing how operators handle disputes and operational errors. T&Cs must include clear procedures for voiding bets, correcting odds mistakes, and handling software or live dealer issues. This includes refund mechanisms.
Bonus terms—frequently cited as a major source of player complaints—must be disclosed in full, clearly presented, and explicitly accepted. Operators must ensure players can review full bonus conditions without obstruction.
The policy further requires operators to state explicitly that they are not financial institutions and do not pay interest on player balances. This reinforces the legal distinction between gaming accounts and banking services.
Responsible Gaming and Fairness Requirements Strengthened
Operators must embed or clearly link responsible gaming tools and dispute resolution frameworks within their T&Cs. In addition, fairness provisions must also explain how game outcomes are determined, including the use of certified RNGs and mechanisms for handling disputes related to game results.
Enforcement Measures and Regulatory Oversight
The CGA signaled stronger enforcement under the LOK regime, warning that non-compliance will constitute a breach of licence conditions. Penalties may include corrective directives, administrative fines, or licence suspension and revocation.
Operators will also be required to upload both current and historical versions of their T&Cs to the CGA portal. This ensures ongoing regulatory visibility and accountability.
Overall, the new T&Cs policy represents a significant shift for Curacao licensing. It reflects the regulator’s broader push to modernize its framework and move toward higher international standards in consumer protection and compliance.
