Curaçao vs Anjouan License: Which to Choose in 2026?

Curaçao and Anjouan are not interchangeable offshore licences. Curaçao operates a direct regime under the LOK with detailed substance, reporting, player-protection, technical and supplier rules. Anjouan publishes substantially lower licensing fees and offers B2C and B2B licence categories, but operators should also consider an important legal-status issue arising from the 2024 mutual evaluation of the Union of the Comoros published through the FATF network. There is no universal winner. Curaçao costs more and has clearer substance duties; Anjouan costs less but requires enhanced legal and counterparty diligence.

Curaçao vs Anjouan at a Glance

What Changed in 2024?

Curaçao after the LOK reform

The LOK has been in force since 24 December 2024, replacing the old master-licence model with direct CGA applications from Curaçao entities. Definitive online gaming licences are indefinite, subject to supervision, suspension, revocation and future changes in law or CGA policy. Applicants now face a visible compliance baseline covering integrity, financial stability, player-fund segregation, responsible gaming, AML, game certification, incident reporting and access to critical data. From 24 December 2026, a critical supplier established in Curaçao must be licensed and registered with the CGA. A foreign critical supplier serving a CGA operator needs registration but not a Curaçao supplier licence solely on that basis. B2C licensees should identify and review their critical suppliers, including platform providers, game aggregators, RNG game manufacturers, live-dealer studios, poker and peer-to-peer software suppliers, lottery providers, sportsbook software suppliers, bet capture and settlement providers, and sports betting line and odds providers before the deadline.

Anjouan’s 2026 framework and the legal-status question

The 2024 mutual evaluation of the Union of the Comoros, published through the FATF network, states that lottery activity and all other games of chance are prohibited within the Union of the Comoros, with penalties for violations provided under Law No. 20-038/AU. That statement sits uneasily beside the licensing body’s claim that internet gaming licences are validly issued under Anjouan law. The evaluation is not a bespoke opinion on an individual offshore operator, while the licensing website does not independently resolve the Union-level conflict. Before relying on the licence, obtain qualified written advice addressing Anjouan autonomy, Union law, the authorizing instruments, enforceability, activities and markets. Share the analysis with banks, PSPs, game providers and investors during pre-clearance.

Official Fees vs Real Costs

Curaçao license costs

The current CGA fee schedule (version 2.0 dated 15 October 2025) lists:

• B2C application – €4,592, non-refundable;
• each UBO – €150 at application;
• each qualified interest holder – €150 at application;
• listed UBO entity – €2,551;
• annual B2C licence fee – €24,490;
• annual B2C supervisory fee – €22,960;
• total full annual B2C charge – €47,450;
• certificate application – €383.

Initial annual fees are calculated pro rata for the year of issuance; subsequent annual fees are payable in full. A quote describing B2C licensing as only €24,490 omits the €22,960 supervisory fee. For a B2B supplier, the same schedule lists a €4,592 application fee and a €24,490 full annual supervisory fee, with no separate National Treasury licence fee.

Anjouan license costs

The published Anjouan fee schedule lists the same figures for B2C and B2B:

• one-time licence issuance – €17,828;
• annual renewal – €17,828.

Fees are non-refundable and may be revised. Extra charges may apply to amendments, domains, and replacement certificates. A provider proposal should state which licensing cycle is included and when renewal becomes payable.

Total costs

Total cost extends beyond regulatory fees and may include company formation and maintenance, local substance, management and key persons, compliance, accounting and audits, legal support, game and system certification, testing, cybersecurity, hosting, banking and PSP integration, liquidity reserves and additional domains. Curaçao’s substance and compliance requirements generally create a higher operating cost base. Anjouan has lower published regulatory fees, but part of the initial saving may be offset by legal opinions, enhanced bank and PSP due diligence, additional corporate structures or the need to obtain another licence as the business expands. Operators should prepare a three-year budget separating regulatory fees, corporate and substance costs, professional fees, technical and compliance costs, and other third-party expenses.

Company Structure and Local Substance

Curaçao requirements

Only a legal entity established under Curaçao law with its statutory seat in Curaçao may apply. It must be managed by at least one Curaçao-resident natural-person managing director or by a Curaçao legal entity that itself is managed by at least one Curaçao-resident natural person. Under Article 5.12 of the LOK, the local substance framework requires dedicated and functionally separated office space in Curaçao. During the first four years following the LOK’s entry into force, the framework requires at least one additional Curaçao-resident Key Person, other than the managing director, to be permanently and full-time engaged in the licensee’s operations. From the fifth year, the minimum increases to three such Key Persons. However, in January 2026 the CGA announced a general postponement of the Article 5.12 local substance requirements. Operators are not required to comply with these requirements before 1 April 2027, although they may establish local substance earlier. Article 5.12 also provides a limited exemption for qualifying smaller operators, subject to several cumulative conditions relating to recent incorporation, UBO history and gross gaming revenue below ANG 20,000,000. Qualifying licensees must provide periodic confirmation by an independent financial expert. The exemption should therefore not be assumed when preparing the operating budget.

Anjouan requirements

Anjouan’s published materials require corporate documents, a complete ownership chain, personal identification, source-of-funds evidence and evidence of adequate financial standing. Directors, beneficial owners and key persons are subject to fitness and propriety assessment, including identity and background checks, while applicants, key persons and beneficial owners are screened against applicable sanctions lists, PEP databases and adverse-media sources. Unlike Curaçao, the currently published Anjouan materials do not state a general requirement for a resident managing director, fixed local headcount, dedicated local office or a specific numeric minimum-capital threshold. Applicants must nevertheless demonstrate adequate financial resources to support the proposed licensed operations. The absence of a published numeric or substance requirement should not be treated as proof of exemption. Obtain a written requirements schedule before finalising the licensing and operating budget.

Application Process and Realistic Timeline

The CGA aims to complete each of the two application phases within eight weeks once the documentation required for that phase is complete. Each phase may be extended by up to four additional weeks. The two regulatory review phases therefore have a combined target of 16 weeks and may extend to 24 weeks where both extensions are used, excluding company incorporation, document preparation and other pre-application or third-party onboarding work. Anjouan’s licensing body does not publish a fixed or guaranteed processing period. “4–8 weeks” may be used as a service-provider estimate, but it is not an authority-guaranteed timeline and should not be used as the sole basis for setting a launch date.

Ongoing Compliance and Player Protection

AML, KYC, reporting and audits

Curaçao licensees must maintain documented frameworks covering KYC, AML/CFT/CPF, responsible gaming, information security, player accounts and the segregation and management of player funds. CGA licence conditions also impose notification and reporting obligations relating to material changes, incidents, certain transactions, complaints and ADR, together with independent assessments or reports where required. Certain material incidents are subject to a 24-hour notification requirement. Anjouan’s published requirements cover customer due diligence, ongoing monitoring, suspicious-activity reporting, record-keeping, a designated compliance officer, staff training, segregation of player funds, certified RNG systems and regulatory reporting. Audits or independent reviews may also be required. Before proceeding, obtain the current compliance calendar, reporting forms, applicable audit scope and technical standards directly from the licensing body or authorised representative.

Complaints, ADR and enforcement

Curaçao licensees must maintain a documented complaints procedure and provide access to an approved alternative dispute resolution (ADR) mechanism. The licence conditions also impose complaint and ADR reporting obligations to the CGA, while the regulator retains supervisory and enforcement powers where a licensee fails to comply with its obligations. Under Anjouan’s published complaints framework, players must first submit a complaint through the operator’s designated complaint channel. The operator has 30 calendar days to respond. If the dispute remains unresolved, the player may escalate it to an approved independent ADR provider. The licensing authority supervises operator compliance with the complaints framework but does not itself act as the adjudicator of the underlying player dispute. Written procedures alone do not demonstrate enforcement quality. Operators and counterparties should review the current complaints rules, public registers, enforcement information, approved ADR providers and the practical availability of complaint and escalation channels.

Market Access and Restricted Countries

Neither licence grants worldwide market access. It authorizes activity under the issuing framework, but the operator must separately comply with the law of every country in which it targets or accepts players. Curaçao’s definitive licence conditions state this expressly. An EU-facing strategy may require national licences. Great Britain requires UK Gambling Commission licensing for relevant remote gambling, while US legality depends on state and activity. Build a dated matrix for every target country covering advertising, registration, local payments, geoblocking, the legal conclusion and review date. If a market requires a local licence, the offshore licence may support a wider structure but cannot replace domestic authorization.

Banking, Payment Providers and Game Suppliers

A licence does not guarantee onboarding. Banks and PSPs also review UBOs, management, wealth, markets, flows, chargebacks, AML, content, legal opinions and volumes. Two holders of the same licence can receive different outcomes. Curaçao’s detailed rules and verification may ease due diligence, but no bank, acquirer or studio is guaranteed to accept a CGA operator. Anjouan’s crypto-enabled category may suit a crypto-first model, yet the legal inconsistency can trigger extra review or refusal. For crypto operations, Curaçao’s licence conditions allow virtual currencies that are tradable on internationally licensed exchanges. Winnings must be paid in the currency used to play, and the operator cannot provide currency exchange or investment services through the player account. Anjouan lists cryptocurrency-enabled gaming and blockchain platforms among permitted categories, while still requiring AML, CDD and monitoring controls. Before applying, obtain in-principle responses from the intended bank, fiat PSPs, crypto processor, platform, aggregator and material studios using the real entity, UBOs, markets and flows.

Regulatory Reputation and Business Risk

Curaçao provides a direct regulator, formal phases, indefinite licences, detailed conditions and published fee, substance and supplier policies. The trade-off is cost and operational commitment. Anjouan publishes licensing information, registers, regulatory standards, complaints and ADR procedures, and enforcement information at substantially lower regulatory fees. Its central risk is the unresolved legal-status uncertainty created by the inconsistency between the licensing framework presented by the Anjouan authority and the Union-level prohibition on gambling described in the 2024 mutual evaluation. Operators should treat this as a material governance and counterparty risk until it has been assessed by qualified independent counsel and accepted by the relevant banks, PSPs, suppliers and investors.

When Curaçao Is the Better Choice

Curaçao is usually stronger when:

• the operator can fund €47,450 annually and real local substance;
• management values detailed public rules;
• platforms, suppliers and games can meet CGA controls;
• counterparties pre-clear the entity and markets;
• a B2B supplier needs a defined route in the same ecosystem.

When Anjouan Is the Better Choice

Anjouan may be practical when:

• the €17,828 issuance fee materially improves economics;
• the model is crypto-first or uses alternative payments;
• the licence conditions cover the required B2C or B2B activities;
• market counsel confirms legality;
• counsel resolves the Anjouan and Union issue;
• critical counterparties accept the licence, entity, UBOs and markets.

Frequently Asked Questions

Which licence is cheaper in 2026? Anjouan lists €17,828 for issuance and €17,828 for annual renewal. Curaçao lists €4,592 to apply and €47,450 annually, plus other charges. Legal, payment, compliance or restructuring costs can reverse the savings. Which licence is faster to obtain? Curaçao uses a two-phase review process. The CGA aims to complete each phase within eight weeks once the required documentation for that phase is complete, with a possible extension of up to four additional weeks per phase. Anjouan publishes no fixed window. “4-8 weeks” may be a provider estimate, but it is not an authority guarantee. Which is better for a crypto casino? Both can support crypto gaming. The choice depends on market legality, AML, exchange and processor acceptance, liquidity and the structure’s legal basis. Curaçao permits qualifying virtual currencies subject to specific licence conditions, while Anjouan lists cryptocurrency-enabled and blockchain-based gaming among its published licence categories. The better option depends on target-market legality, AML controls, exchange and processor acceptance, liquidity and the legal and corporate structure. Which offers stronger player protection? Both publish player-protection and complaints requirements. Curaçao’s definitive licence conditions provide a more detailed framework covering player accounts, fund segregation, responsible gaming, complaints and ADR. Anjouan also publishes a complaints and ADR framework, including an initial operator complaint stage. Published rules alone, however, do not establish the practical quality of supervision or enforcement. Can either licence be used in the EU, UK or US? Not as a universal authorization. Many European countries require national licences, the UK has its own licensing regime, and the US legality depends on state and activity. Obtain country-specific advice and geoblock markets where the required authorization is absent. Which licence provides better banking access? Neither provides a universal advantage. Curaçao’s more detailed public framework may be easier for some counterparties to diligence, while Anjouan’s legal-status question may create extra review. Actual approval depends on the entity, UBOs, markets, products, payment flows and the individual institution’s risk policy. Can an operator migrate from Curaçao to Anjouan? There is no automatic licence-transfer process between the two regimes. An operator may apply separately for an Anjouan licence and restructure or migrate its operations if the resulting structure is lawful and its counterparties agree. Existing Curaçao approvals, contracts, player accounts, banking arrangements and supplier relationships should not be assumed to transfer automatically.

Final Verdict

Curaçao is the more structured choice for operators that can support its higher regulatory cost base and ongoing compliance requirements and that value a detailed, direct regulatory framework. Operators should also budget for the local substance requirements scheduled to become applicable from 1 April 2027, unless a relevant exemption or further regulatory change applies. Anjouan has substantially lower published regulatory fees and may appeal to lean or crypto-first projects. However, the legal-status uncertainty identified in the 2024 mutual evaluation, target-market legality and acceptance by banks, PSPs, gaming suppliers and other counterparties should be independently assessed before relying on the licence. The decision should be made in this order: target-market legality, banking, payment and supplier acceptance, regulatory and legal risk, operational requirements, and total three-year cost. Choosing a jurisdiction based primarily on the advertised licence fee is the weakest approach. GamingLicensing can help operators compare the Curaçao and Anjouan routes, structure the applicant, coordinate licensing documentation and identify banking, payment, supplier and compliance dependencies before filing.