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Even The World's Biggest Crypto Casino Is Stuck Waiting on a Curaçao License

The Curaçao Gaming Authority (CGA) aims to complete each of its two review phases within eight weeks, with a four-week extension possible if needed. In my practice, that target holds loosely at best: cases have moved in as little as two months and dragged past a year, with no consistent pattern explaining why one clears quickly and another doesn't. The regulator's own public register backs that up: of 661 licenses tracked since the reform took effect, 314 are still marked "assessment in progress," and 91% of those have already passed their own listed expiry date. Stake — the world's largest crypto casino — is one of them. 

Curaçao replaced its old master-license system with direct CGA licensing in December 2024, converting existing sub-licenses into temporary ones with a maximum window of twelve months. For the largest conversion cohort, from mid-2025, that window closed around June 2026 — already behind us. There's enough of a track record now to check the reform's promises against what actually happened: what held up, and what turned out to be an inflated expectation.

Eight Weeks, on Paper 

The CGA runs that eight-week review in two phases: an integrity and financial-standing check, then a technical and operational one. Here's what actually happens once an application enters that process.

The CGA's public register, last updated 27 August 2026, lists every application filed since the portal opened. 286 of those 314 stalled applications have already passed their own listed expiry date — 123 by up to three months, 118 by three to six months, and 45 by six months to a year. And the pattern isn't confined to the legacy conversion wave: 109 of those stalled applications were filed fresh in 2026, well after that wave had cleared.

The regulator has confirmed as much itself. On 23 December 2025, one day before a legally mandated decision deadline under Article 5.1 of the LOK, the CGA published a notice stating it had "not yet reached a final decision on the indefinite license for a group of operators," citing "the high amount of information collected from the operators and the time needed for proper vetting thereof." The same notice confirmed that affected operators keep operating under their existing status until a final decision arrives — a stalled application keeps the business running, just without a resolution. Ten weeks earlier, the CGA's own PR advisor had told trade outlets there was "no delay or deviation in the rollout." The two statements track how the picture changed over those ten weeks: confident in October, before the scale of the review was fully visible; candid about the workload once it was. 

Scale doesn't buy an exception. Stake holds its Curaçao license through Medium Rare N.V., one of the more compliance-conscious names in the industry. As of the same August register, that license also shows "assessment in progress" — the same status carried by hundreds of operators nobody outside the industry has ever heard of. 

If the biggest, best-resourced operator in the market can't move faster through the queue, the question that matters is whether the queue has a guaranteed end at all. Under the LOK, a rejected applicant has six weeks to object to the CGA or appeal to Curaçao's Court of First Instance. Nothing in the ordinance, or in anything the CGA has published, describes what happens if the regulator simply never reaches a decision — no rejection to appeal, no license to operate under a fixed term, just a file that stays open. Right now, "assessment in progress" is a status with no expiry date of its own, and no test case has yet forced the question of what happens if it stays that way indefinitely.

What You're Actually Paying Now 

Under the old system, a sub-license cost $17,000 to $35,000, with almost no scrutiny attached. The price rose because the CGA built out real oversight — investigations into who actually owns and controls an operator, enforcement powers up to suspension and revocation — and billed the cost directly to license applicants.

Now take a jurisdiction that runs similarly real checks — Malta — and see how the price actually holds up. Here's how the two compare, split by license type since B2C and B2B run on different terms in both places:

 

 

Curaçao B2C

Malta B2C

Curaçao B2B

Malta B2B

Application (one-off)

€4,592

€5,000

€4,592

€5,000

Annual government fee

€47,450

€25,000

€24,490

€25,000–35,000

Revenue-linked add-on

€8,565/yr past NAF 20M GGR

€15,000–600,000/yr compliance contribution

€8,565/yr past NAF 20M GGR

none — already priced into the annual fee tiers above, capped at €35,000

Gaming tax

0%

5%, on Malta-based players

0%

0%, exempt

Realistic year-one total

~€77,800

€80,000+

€54,882

~€65,000–80,000, built from components

Second year onward

~€60,400/yr

~€75,000/yr — recurs yearly regardless of the 10-year license term

€37,435/yr

~€60,000–75,000/yr — same, recurs yearly regardless of license term

At the scale of a first-year operator with modest revenue, Curaçao and Malta cost about the same on B2C, within a few thousand euros of each other. But Malta's compliance contribution grows with revenue. For Type 3 games like poker and bingo, it runs 4% of the first €2,000,000 alone — an operator clearing just €2 million already owes roughly €80,000 in compliance contribution, before the annual fee or the 5% tax are even added. Curaçao's only revenue-linked cost is capped at €8,565 a year, no matter how large the operator gets. 

In practice, that means a small operator sees almost no price difference between the two. A large one sees a very large difference — Curaçao's flat structure holds its price where Malta's keeps climbing.

B2B is harder to call: Curaçao's €54,882 lands in the same rough range as Malta's, once local substance and legal costs are added on both sides. Unlike B2C, Curaçao doesn't hold a clear price edge here.

Banking Never Got Easier 

Part of the pitch for the LOK reform was that real oversight would translate into better banking access. The argument got repeated throughout 2025: a jurisdiction with an actual regulator, a public register, and enforcement powers would stop being flagged as high-risk by acquirers and payment processors the way the old sub-license system was.

That upgrade hasn't materialized, and it was never fully within the CGA's power to deliver. Card networks classify all gambling merchants — regardless of license, regardless of jurisdiction — under merchant category code 7995, the same high-risk bracket that applies to a Malta-licensed sportsbook or a UK Gambling Commission operator. Visa and Mastercard's risk pricing for an entire industry category sits outside any single regulator's reach — Curaçao's reform included. Operators still route around the friction the way they always have: specialist processors, electronic money institutions (EMIs), and increasingly stablecoin rails. For anyone weighing Curaçao specifically to escape that friction, the reform bought nothing — the friction was never Curaçao's to fix.

What Stayed the Same 

Two structural features of the old system made it into the new one without erosion, and they're worth weighing against everything above.

Curaçao still issues one license for casino, sports betting, poker, bingo, and lottery products — an operator launching all five doesn't file five applications or pay five sets of fees. Most major regulated jurisdictions don't work that way:

  • UK Gambling Commission: separate operating license per activity — a typical operator running casino, sportsbook, and its own software needs three
  • Sweden's Spelinspektionen: separate licenses for casino games and for betting
  • Gibraltar: licensed and charged per vertical — a casino-and-sportsbook operator pays for both separately, currently around £200,000 a year combined
  • Malta: one license nominally, but each "game type" inside it carries its own share capital requirement, from €40,000 to €100,000

Only a few regulators bundle everything into one license the way Curaçao does. The Isle of Man is the clearest match: a single five-year license covering casino, sportsbook, poker, bingo, esports, and B2B supply together.

The tax range tells a similarly broad story. A 2026 survey of 30 jurisdictions' GGR tax rates puts Curaçao at the low end: 

  • New York: 51%
  • UK: 40% (Remote Gaming Duty, just doubled from 21% on 1 April 2026)
  • Netherlands: 37.8%
  • Malta: 5%, on Malta-based player revenue only
  • Isle of Man: 0.1%–1.5%, banded by revenue
  • Curaçao: 0%

None of these are optional; they scale directly with how much money an operator actually makes. Curaçao's 0% stays exactly that at any revenue level.

The Bottom Line

Curaçao's flat fee structure and its undated queue add up to the same effect: they reward operators who are already large. A company running enough volume that Malta's compliance contribution would hurt gets Curaçao's flat fee as genuine savings — and can afford to wait out the queue to get there, the way Stake has. A smaller operator faces the identical wait for a fee that barely beats what Malta would have charged anyway.

Only one half of that combination is likely to change. As the CGA works through its backlog — the authority's own Q2 2026 bulletin still describes it as "building a robust organization capable of meeting the evolving needs" of the sector, eighteen months after the reform took effect — the queue delay should ease over time. The flat fee is a different kind of fact: a feature of the law itself, independent of how quickly the CGA works through its current backlog. 

In my view, that leaves Curaçao making the most sense for one kind of operator: large enough for the flat fee to matter, and running more than one vertical under Curaçao's single license. Recognize that profile, and the numbers here work in your favor regardless of the queue. If you don't, a narrower, faster jurisdiction is likely the more useful place to look before committing to Curaçao.

 

Published September 11, 2026 by Brian Oiriga
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