Curaçao Makes ADR a Licence Condition, Not a Policy Choice
The Curaçao Gaming Authority has turned its alternative dispute resolution policy into an active licensing requirement under the LOK framework. Operators must offer players a free, independent route to resolve complaints that customer service cannot settle, and noncompliance can trigger regulatory audits or sanctions.
The Curaçao Gaming Authority opened its alternative dispute resolution consultation on February 24, 2025, and closed it on March 8, according to iGaming Business. The policy emerged from the BC Game case, where players pursued unpaid winnings through bankruptcy proceedings after both the original operator and the business that later acquired it collapsed financially. BC Game was licensed under the old master licence system, which the LOK framework has since replaced.
Per the CGA’s consultation document, approved ADR providers must operate as separate legal entities from any B2C operator. Each must run an independent website, be based in Curaçao, employ a qualified lawyer, and staff at least three people with gambling sector experience. Providers cannot be paid per case, which removes the incentive to favor the operator in a ruling.
ADR decisions are binding once issued. Providers can request evidence and documentation from both sides of a dispute but cannot investigate beyond what the parties submit, iGaming Business reported. That limit puts the burden on operators to keep clean records ready for review, including withdrawal histories, KYC logs, bonus term documentation, and customer service notes. A weak or incomplete file makes a dispute harder to defend once it reaches an ADR provider.
Cost sits entirely with the operator. The CGA requires licence holders to fund the full ADR process so players pay nothing to file or pursue a complaint. Standard complaints must be resolved within four weeks, extendable by another four weeks with notice to the player, while complaints tied to responsible gambling carry a tighter five day deadline.
The July 2025 compliance deadline has now passed. Operators who fail to handle a complaint through the proper channel face regulatory audits and possible licence sanctions, a clear escalation from a voluntary best practice to an enforceable licence condition.
The shift fits a broader reset for Curaçao’s reputation. The CGA moved from the old master licence model, where four licensors distributed sub-licences to roughly a thousand operators with little direct oversight, to a single-authority structure with separate categories for B2C, B2B, and B2B2C activity.
Malta, the UK, Anjouan, and Nevis are moving in the same direction, AGBrief reported, pushing operators toward independent complaint handling rather than internal resolution alone.
💡TGJ Take
This closes a real gap, not a procedural one. Curaçao spent years competing on speed and low friction, but BC Game showed what that costs when a licence holder cannot pay out. Binding ADR removes the operator’s ability to sit on a complaint until a player gives up. The audit risk is the part operators will underestimate. A messy KYC file or inconsistent bonus terms no longer just costs a chargeback fight, it now creates a paper trail a regulator can act on. Anyone still treating their Curaçao licence as a low cost wrapper needs to budget for ADR compliance as core operating cost, not an afterthought.
