Comparison

UKGC vs Curacao licence

The UK Gambling Commission (UKGC) and the Curaçao Gaming Authority (CGA) regulate online casinos under different laws. Each is set out here in its own wording.

Regimes compared
2

The short answer

Each regime asks more of a casino on different points, and the two sections below set them out. The biggest difference is territory: the Commission's remit is gambling offered to consumers in Great Britain, while the CGA licenses and supervises gaming in and from Curaçao.

Side by side

Our team tests casinos under both regimes and checks every point here against each regulator's own pages.

PointUKGCCuracao
RegulatorGambling Commission, an executive non-departmental public body sponsored by the Department for Digital, Culture, Media & Sport, working under the Gambling Act 2005Curaçao Gaming Authority, an independent administrative authority for online gaming since 24 December 2024, working under the National Ordinance on Games of Chance (LOK)
Who is licensedOperating licence for most gambling facilities in Great Britain; personal licences for individualsB2C operating licence; B2B supplier licence for platforms and software; a company holds one type, not both
Player fundsEach business states its protection level; online licensees keep funds in a separate accountCrypto held in segregated wallets
Complaints routeThe business first, then an ADR providerThe operator first, then independent ADR
Self-exclusionListed among player tools; assessment principles for multi-operator schemesExclusion from all of one operator's domains for 1, 3, 5 or 10 years, or for life
Public registerBusiness register, searchable by name or account number; also individuals, regulatory actions and premisesOnline gaming licence registry, a register page and an enforcement register
UK player coverageRemote gambling offered to consumers in Great Britain-

Where UKGC asks more

The Commission's pages set the following requirements on licensees and rights for players.

Reach and key equipment

Key equipment is the equipment used to store a person's gambling information, present virtual games or races, determine results or store result information. The Commission's remit also covers remote gambling, online or by phone, that uses key equipment within Great Britain.

Northern Ireland sits outside this. The Commission does not regulate remote gambling there, but advertising remote gambling to Northern Ireland consumers without a Commission licence is an offence under the Gambling Act 2005.

A licensee's conduct abroad counts. The Commission can assess ongoing suitability where there is evidence of misconduct abroad, and can refer cases to authorities in other countries.

Player funds

Money staked or deposited with a gambling business is not protected by the Commission or the government the way a bank account is. Those using gambling businesses do so at their own risk. What the Commission requires is disclosure: every business must say whether a player's money has any protection if the business becomes insolvent, and must give the level in its terms and conditions, online or in a venue.

There are three levels:

  • No protection: account money counts as part of the company and would be lost.
  • Medium protection: the business has arrangements such as insurance, but getting money back is not absolutely assured.
  • High protection: money sits in a legally separate account, controlled by an independent trustee and checked by an external auditor, which gives the best chance of getting it back.

A separate account alone is no guarantee. Since 31 October 2025 a business holding unprotected funds must remind the player every 6 months, and the player must acknowledge the notice before using funds held for gambling.

Withdrawals and ID checks

Online players can withdraw their money at any time without unreasonable delay or restriction, and need not take it in instalments.

ID is meant to come early. Every online gambling business must ask players to prove age and identity before they gamble, and a customer cannot place a bet until verified. A business cannot make age and ID proof a condition of withdrawal if it could have asked earlier, and a withdrawal delayed over insufficient ID may breach Licence Condition 17. Unusual account activity can still stop a withdrawal, though a business should not hold on to money unnecessarily.

The Commission does not say which documents a business must ask for. Passports, driving licences and household bills are examples, a selfie can be requested if fraud is suspected, and bank statements can help check that funds are legitimate. Affordability checks use deposit or loss thresholds based on income. No timescale is set, and electronic verification may be instant.

Payments, stakes and high value customers

Funding gambling with credit cards has been banned. The Commission has issued guidance on online slots stake limits and a consultation response on online games design and reverse withdrawals. It has also issued industry guidance on High Value Customers and changed its licence conditions on them after consultation.

Technical standards and game testing

Gambling software and remote operating licence holders must comply with the Commission's remote technical standards (RTS). Data requirements cover game test reports, annual game audits and security audit reports, and a published testing strategy covers compliance with the standards.

Licence conditions

Every licensee must meet the Licence Conditions and Codes of Practice (LCCP). The current version took effect on 29 July 2026, with extracts for sectors such as casino. Where possible the Commission sets outcomes and lets licensees choose their own way to meet them, with particular rules in some areas, and it consults widely on changes. Licensees must display their licensed status, and the Commission publishes technical requirements with example formats for doing so. They must also follow advertising rules, including keeping marketing away from self-excluded customers.

Enforcement records

A register of regulatory actions records what the Commission has done against licensees, and public statements follow enforcement action. Recent items include the suspension of Targetlocal Ltd's licence (21 September 2026) and £5m to be paid by land-based casino operators for regulatory failures (7 October 2026).

Where Curacao asks more

The CGA's policies set the following requirements on licensed operators.

Complaints and ADR

The complaints policy follows Article 5.3 of the LOK. Each operator's policy must be included or referenced in its terms and conditions, covering every stage, and an official Complaint Submission Form must be available. Only the registered player can complain, and Article 1.3 section c of the LOK bars players from selling, giving away or pledging their claims against a licence holder.

The timetable is written down:

  • Players can complain free of charge up to six months after the bet is settled or the incident happened.
  • Complaints about responsible gaming, such as targeting vulnerable players or the timely use of self-exclusion and cooling-off, get best efforts to resolve within five business days.
  • Other complaints are answered within four weeks, extendable once by another four weeks with prior written notice.
  • The player always receives a final decision in writing.

A player who remains unhappy must be told they can escalate to an independent ADR entity. ADR is free for the player and the operator bears all its costs. Offering it is mandatory, although an operator may set anti-abuse parameters: ADR before court action, a binding outcome, or a minimum claim value. Apart from what is agreed under those ADR terms, an operator must not restrict the player's right to take legal action. Certified providers include Resolvo Curaçao N.V, ADR Curaçao B.V., Cadre BV and IBAS. Operators report their complaints to the CGA on January 15th and June 15th.

The CGA itself will not resolve or rule on individual player complaints, and it will not review or overturn an operator's or ADR provider's decision unless the complaint was handled inadequately. Operators must not stop players contacting it directly about malpractice, breach of licence conditions or whistleblowing.

Self-exclusion, cooling-off and limits

Self-exclusion must be possible fully online, with no email and no operator approval, and the steps must take no more than 15 minutes. A player who excludes must be excluded from all of that operator's domains and should be encouraged to exclude from other gambling sites. Once confirmed, the exclusion cannot be revoked by the player before it ends. Remaining funds, apart from any frozen under the anti-money laundering policy, go back to the original payment method within two business days. If a self-excluded person or a minor gambled anyway, the operator must refund all deposits within two business days, again except frozen funds.

Direct marketing, including emails, messaging, bonuses or incentives, is prohibited during an active cooling-off or self-exclusion period.

Cooling-off periods of 24-hour, 7-day, 1 month or 3 month must be on offer. Deposit limits can be daily, weekly or monthly: lowering a limit takes effect immediately, raising one only after a seven-day wait. A player must not be able to deposit or bet unless the operator is satisfied they are 18 or older, and age verification should at minimum include a valid government-issued ID check. Article 1.4(e) of the LOK bars an operator from letting anyone who must reasonably be assumed vulnerable play.

Site disclosure and terms

The footer of a licensed site must carry a clear sign that under-age gambling is prohibited, the licence holder's name and registered address, the official CGA licence number, a statement that the CGA oversees the operations and the operator's CGA digital seal. It must also link to gambling support resources, for example GamCare, Gamblers Anonymous and GambleAware, plus local services where available.

The terms carry their own rules. They must be reachable within one click from the homepage, the registration page and the player account area, and a player must actively accept them at registration, for example by ticking a box. "By using the site you accept" is not enough. They must give the licensee's legal name, registered address, Chamber of Commerce number, licence number and issue date. Under Article 5.5 of the LOK they must also provide that the player agreement is governed by Curaçao law and that disputes go to a competent court of Curaçao.

They must also state the withdrawal conditions, particularly identity checks once cumulative deposits and withdrawals exceed XCG 4,000 (circa EUR 2,000), and set out when winnings may be confiscated or payouts limited or refused. As a general rule funds go back only to the account they came from. Terms must state that games are fair and use certified RNGs. At account closure a licensee may refresh KYC but should not ask for more than it asked when the account was opened. Sanctions for faulty terms are directives to correct them by a deadline, administrative fines, and suspension or revocation of the licence.

The operations manual must describe the operator's maximum payout and/or maximum withdrawal policy, including any per-bet, per-event or per-period caps, and be made available to the CGA within five working days of a first request.

Crypto payments

Licensees may accept crypto for gambling services only, must not act as an exchange, payment services provider or virtual asset service provider, and must make clear to players that they are not responsible for any exchange used to buy or sell crypto. The CGA treats crypto as high risk and prefers fiat-backed regulated stablecoins. Assets linked to sanctioned mixers or tumblers are prohibited. By default, withdrawals go to the same wallet and in the same asset as the deposit. Wallets must be segregated between player-flow, operational and treasury purposes.

Bans on sanctioned wallets, prohibited assets and personal or owner-linked wallets took immediate effect. Within 12 months (June 2027) licensees must also have blockchain analytics, reconciliation, withdrawal whitelisting and audit-ready records in place.

Testing and suppliers

The CGA has not established its own technical standards at present. Its testing policy accepts the online gaming standards of New Jersey and Pennsylvania in the United States, Ontario and British Columbia in Canada, the United Kingdom and Malta.

Test houses must hold current accreditation under BS EN ISO/IEC 17025, from a body that signs the ILAC Mutual Recognition Arrangement or another such as UKAS, and must give a signed declaration that they operate independently of gaming operators and software suppliers. Being on the CGA's list is not an endorsement or guarantee. GLI, eCOGRA and BMM Spain Testlabs hold test lab certificates. B2C licensees must keep a game supplier register and check all third-party game content against the official CGA supplier list.

Licence structure and owner checks

The CGA runs probity checks up to ultimate beneficial owners, meaning a natural person who ultimately owns or controls a company by directly or indirectly holding more than ten percent of the shares, voting rights or ownership interests. Its fit-and-proper test also looks at expertise, planning and sources of funding.

The Orange Seal (Certificate of Operations) expired on 15th October 2025, ending the former sublicence system, and a B2B licence is not mandatory until 24th December 2026. A B2C licence being wound down stays active until every player has been paid.

A non-refundable B2C application fee of EUR 4,592 is due before processing. Annual B2C fees are a EUR 24,490 licence fee to the National Treasury plus a EUR 22,960 supervisory fee to the CGA, EUR 47,450 in total, due by 15th January. An invoice alone does not confirm a licence continuation or extension: only written CGA confirmation does.

Operators must name the Tier-IV certified data centre registered in Curaçao that hosts critical player records, and the local substance requirement under Article 5.12 is postponed to no earlier than April 1, 2027. Offering gaming without a valid licence in or from Curaçao is a felony, punishable by up to two years in prison or a fine of NAf 25,000.

Enforcement register

The CGA's enforcement register covers only actions that change a licence's status (revoked, suspended or not extended), not every measure. It carries a warning that it may not be fully accurate or up to date, and its entries show licence number, licensee, company registration, effective date and status.

What changes for a UK player

Before choosing a casino, find the licence number on its site and match it to the issuing regulator's own register: the Commission's business register for Great Britain, the CGA's registry for Curaçao. The full explainers are UK Gambling Commission licence explained and Curacao gaming licence explained.

Complaints and disputes

Under the UK regime a bet is a legally enforceable contract with the business. The Commission has no access to customer accounts and cannot see what happened when a player has a problem, so a complaint goes to the business first. It also keeps a list of approved ADR providers.

Checking a licence

The CGA's registry entries show licence number, licensee, company type, company registration number, issue date, expiry date and status, and statuses include Assessment in progress, Expired and Indefinite. Some entries still read Assessment in progress after their expiry date, and one number, OGL/2024/1397/0784, appears against two companies, Grrr Tech B.V. and Olympus Holdings N.V. Register overviews do not guarantee that a licence is currently valid, because status can change.

The CGA's online gaming portal will not be returned to service (announcement of 7 October 2026), and the availability of the current digital seal is affected. Existing licences remain valid, and an alternative way to show that a domain is licensed is promised. The steps are in how to check a casino licence, and fake and cloned casino licences covers what a false badge looks like.

Help for UK players

The National Gambling Helpline for England and Scotland is 0808 8020 133 and the NHS Wales helpline is 0808 2819 265, both free and open 24 hours a day, 7 days a week. The CGA's own advice to foreign players harmed by gambling is to contact a helpline or treatment service in their country of residence. More support is on the responsible gambling page.

Casinos by licence

Casinos are grouped by licence on these pages:

Questions

Is UKGC stricter than Curacao?

Not across the board. The Commission sets particular rules on ID timing and withdrawals, and the CGA on complaint deadlines and self-exclusion mechanics.

Which gives players more protection?

They protect in different forms. The Commission requires each business to say whether player money is protected if it goes insolvent, and the CGA requires free ADR for players.

Which can UK players use?

The Commission regulates remote gambling offered to consumers in Great Britain, wherever the casino's equipment sits. A Curaçao licence is the CGA's permission for gaming in and from Curaçao, and it is not a Commission licence.

Which has the better complaints route?

Both start with the operator, and neither regulator decides individual disputes. The CGA sets four weeks as the reply time for most complaints.

Does one licence beat the other?

A licence records permission under one regulator's rules. The two sets of rules differ on the points above, so neither licence can be read as a stand-in for the other.

If you think we are wrong

When a regulator changes a rule, or a fact on this page is wrong, our team reads the regulator's own page or register again and corrects the page. Send corrections to info@biglicence.co.uk. Name the line you doubt and the regulator page that shows otherwise.

Sources

  • Big Licence team checks of the licences we cover
  • gamblingcommission.gov.uk Used for the UK Gambling Commission's own pages and public register.
  • cga.cw Used for the Curacao Gaming Authority's own pages and register.
  • spin-cdn.com Used for complaints.