Short answer
Choose Anjouan to launch a crypto-first or proof-of-concept product quickly: one license for every online vertical at a flat €17,828 a year, with no published residence or local-office rule. Choose Curaçao if you can fund a Curaçao NV or BV with a resident director, an office and compliance officers: €47,450 a year in B2C government fees (about €125,000–€233,000 in year one with substance), a published statute, a public register and generally wider payment acceptance. Neither license opens the US, the UK or the regulated EU markets.
Side by side
| Anjouan | Curaçao | |
|---|---|---|
| Regulator | Anjouan Offshore Financial Authority (AOFA); applications through Anjouan Licensing Services Inc. (brand: Anjouan Gaming) | Curaçao Gaming Authority (CGA), licensing directly; Ministry of Justice responsible since 19 August 2025 |
| Legal basis | Computer Gaming Licensing Act 007 of 2005; binding License Conditions v5 (October 2026) and KYC and AML Code of Conduct (13 October 2026) | National Ordinance on Games of Chance (LOK), P.B. 2024 no. 157, in force 24 December 2024 |
| Government cost, year 1 | €17,828 issuance, B2C or B2B, non-refundable; €500 per extra B2C domain; €2,000 per Key Person a year; recognition certificate €9,500 a year (suppliers licensed elsewhere). Due-diligence fee: not published | €4,592 application; €150 per UBO and €150 (B2C) or €128 (B2B) per 10%+ holder; €250 per domain; annual fees pro rata in the year of grant (LOK arts. 5.18–5.19, 6.1) |
| Government cost, year 2+ | €17,828 annual renewal, B2C or B2B; €2,000 per Key Person; €500 per extra B2C domain | €47,450 B2C (€22,960 supervisory fee + €24,490 license fee) · €24,490 B2B (art. 5.19) |
| GGR or gaming tax | 0% GGR tax; flat fees only | No GGR tax in the LOK; profit tax 15% on the first XCG 500,000 and 22% above |
| Guarantee or capital | None published; source of funds is verified in due diligence | No fixed amount in the fee articles; B2C licensees pay guarantee-fund premiums for player balances (art. 5.7); phase 1 tests financial standing (art. 5.1(2)) |
| Time to license | No official processing time; typically a few weeks on a complete file in our experience | Statutory stages of about 22–30 weeks (art. 5.1), plus remedy time; the CGA publishes no overall processing time. Provisional license possible in phase 2 |
| Local substance required | No residence or local-office condition published. Key Person and Compliance Officer (§8), MLRO and deputy (§7); none has to live in Anjouan | Curaçao NV or BV with a resident managing director (art. 2.1(4)), own premises (art. 5.12(1)(c)) and compliance officers; a full-time key person from 1 April 2027; Tier-IV hosting in Curaçao for B2C |
| EU passporting or recognition | None. Excluded markets include Austria, France, Germany, the Netherlands, Spain and the UK (License Conditions §2) | None. The CGA is not an EU/EEA regulator, so its license cannot obtain an MGA Recognition Notice. Licensees must comply with each target market's law (conditions art. 3.1) |
| Banking and PSP acceptance | In our experience crypto processors and some tier-two acquirers accept it case by case; tier-one EU card acquiring and high-street banking do not. No real-money app-store listing on this license alone | The CGA publishes no statement on banking; acceptance is each bank, EMI or PSP's own risk decision. Widely used offshore and accepted by a number of payment providers |
| Reputation with B2B partners | Entry-level. Michigan's Gaming Control Board named Anjouan among offshore bases in its cease orders of 9 April 2025; press reports in October 2026 described a dispute with the Union of the Comoros authorities (no primary document at review) | Direct licensing under a published statute since 24 December 2024, a public register and green (B2C) or blue (B2B) seals; the sub-license system ended and the orange seal lapsed on 15 October 2025 |
| Best for | Crypto-first casinos and sportsbooks, proof-of-concept launches and suppliers to Anjouan licensees | International casinos and sportsbooks, and Curaçao-based critical suppliers, that can fund real local substance |
Year-one total
Anjouan
| Item | Year 1 | Year 2+ |
|---|---|---|
| Issuance, then renewal (government) | €17,828 | €17,828 |
| Extra domains (government) | €500 × n | €500 × n |
| Key Person Authorization (government, per person) | €2,000 × n | €2,000 × n |
| Licensee company: existing company, or optional Anjouan IBC with registered agent (indicative) | €0 or ≈ €3,750 | €0 or agent fee |
| ADR provider (operator pays, §10) | Provider tariff | Provider tariff |
| RNG and game certification (approved test lab, §3) | Lab quote | New games |
| Total | €19,828 + third-party items | €19,828 + third-party items |
B2C, one domain, one Key Person. A B2B license costs the same €17,828 to issue and renew (plus Key Person fees) and needs no ADR provider; a supplier licensed elsewhere can instead hold a recognition certificate at €9,500 a year. Third-party figures are indicative and vary by provider.
Curaçao
| Item | Year 1 | Year 2+ |
|---|---|---|
| Application fee (LOK art. 5.18) | €4,592 | — |
| Due diligence (example: two UBOs who are also 10%+ holders) | €600 | — |
| One domain or software application | €250 | — |
| Annual fees, B2C (pro rata in the year of grant) | up to €47,450 | €47,450 |
| Resident managing director (typical market cost) | €10,000–€30,000 | €10,000–€30,000 |
| Compliance officers, one full time in Curaçao as the art. 5.12 key person (typical market cost) | €35,000–€70,000 | €35,000–€70,000 |
| Dedicated office in Curaçao (typical market cost) | €6,000–€15,000 | €6,000–€15,000 |
| Tier-IV data center hosting in Curaçao (typical market cost) | €10,000–€30,000 | €10,000–€30,000 |
| RNG, platform and game testing (typical market cost) | €5,000–€20,000 | €2,000–€8,000 |
| Statutory audit and information-security assessments (typical market cost) | €6,000–€15,000 | €6,000–€15,000 |
| Total | ≈ €125,000–€233,000 | ≈ €116,000–€215,000 |
B2C, assuming a full year of annual fees in year 1; pro rata billing lowers it. A B2B supplier pays €24,490 a year, about €92,000–€180,000 in year 1 excluding hosting. Third-party figures are indicative market ranges, not statutory amounts.
Statutory and typical third-party costs only; plus professional fees, quoted on request.
Choose Anjouan if…
- You want one license for casino, sports betting, poker, bingo and crypto-enabled gaming at a flat €17,828 a year
- You want to prove a product before funding Curaçao or EU-level substance
- You do not want to place a director, an office and staff on the island
- Your payment set-up is crypto-first or relies on tier-two acquirers
- You supply Anjouan licensees and need a B2B license or recognition certificate under License Conditions §14
Choose Curaçao if…
- Your payment providers already onboard Curaçao licensees and want a regulator with a published statute and public register
- You can fund a Curaçao NV or BV with a resident director, premises, compliance officers and, from 1 April 2027, a full-time key person
- You want fixed government fees whatever your GGR, with no gaming tax in the LOK
- You are a critical supplier established in Curaçao: from 24 December 2026 you need a CGA B2B supplier license
- You can work to a statutory review of about 22–30 weeks, with a provisional license possible in phase 2
Switching, holding both, and the supplier rules
No conversion route. Neither regulator converts or recognizes the other's license. Moving from Anjouan to Curaçao means a Curaçao NV or BV and a full LOK application. The statutory clock starts only once the file is complete and the application-stage fees are paid (LOK art. 6.1(2)), and the art. 5.12 substance applies from 1 April 2027, so budget the director, office and compliance officers before you file.
Holding both. Use separate companies. The CGA licenses only a Curaçao NV or BV with its statutory seat in Curaçao. The Anjouan regulator does not state whether a non-Anjouan company may hold its B2C license, so we confirm the company before filing. Plan geo-blocking to the stricter list: Anjouan excludes named markets (License Conditions §2), and Curaçao requires compliance with every target market's law (conditions art. 3.1), with a foreign regulator's final decision a ground for revocation (LOK art. 2.4(1)(j)).
Suppliers to Anjouan licensees. Under License Conditions §14 an Anjouan licensee must satisfy AOFA that its platform and content suppliers are fit and proper and hold an Anjouan B2B license or a recognition certificate. The B2B license costs the same €17,828 as B2C and needs no ADR provider; in our practice any company can hold it. The regulator has not published the start date of §14, the recognition fee or the list of recognized jurisdictions.
Suppliers to Curaçao licensees. From 24 December 2026 a critical supplier established in Curaçao needs a CGA B2B supplier license (€24,490 a year), and licensees may not obtain critical services or goods from suppliers that are not on the public supplier register (LOK art. 5.16(4)). The CGA had not published registration rules for foreign suppliers at our review date. One company cannot hold both a CGA B2C and a CGA B2B license (License Reclassification policy), so a group that runs its own casino and supplies others needs two Curaçao companies.
Reviewed by Alex Szilaghi
Founder of Szilaghi Consulting, licensing gambling businesses since 2004 across EU, UK, Canadian and offshore jurisdictions, based in Romania and working before ONJN on Class 1 and Class 2 files. We act as Romanian representative and local director for foreign ONJN licensees and file their monthly regulatory reports, so these guides reflect how the rules are applied in practice, not only how they read. Szilaghi Consulting’s in-house lawyers are Romanian avocați practicing under Law 51/1995.
Last legal review . Current to both regimes as of the review date. General information, not legal advice.
Questions
Is Anjouan cheaper than Curaçao?
Yes, in government fees. Anjouan charges €17,828 to issue and €17,828 a year to renew, B2C or B2B, plus €2,000 a year per Key Person and €500 per extra B2C domain. Curaçao charges €4,592 to apply plus due-diligence fees, then €47,450 a year for B2C or €24,490 for B2B. With the local substance the LOK requires, a realistic Curaçao B2C year one is about €125,000–€233,000 before professional fees.
Which is faster to get, an Anjouan or a Curaçao license?
Anjouan publishes no processing time; in our experience a complete file typically takes a few weeks. The CGA publishes no overall time either, but the statutory stages in LOK art. 5.1 add up to about 22–30 weeks, plus any remedy time. Curaçao can grant a provisional license during the second review phase.
Do I need a local office or director for Anjouan or Curaçao?
Anjouan publishes no residence or local-office condition; you appoint a Key Person, a Compliance Officer and an MLRO with a deputy, none of whom has to live there. Curaçao requires a Curaçao NV or BV, a resident managing director, your own premises and compliance officers, with a full-time key person from 1 April 2027.
Which is better for banking, Anjouan or Curaçao?
Neither regulator guarantees banking. Curaçao is widely used offshore and accepted by a number of payment providers, each on its own risk assessment. In our experience Anjouan is accepted case by case by crypto processors and some tier-two acquirers, but not by tier-one EU card acquirers or high-street banks.
Can one company hold both an Anjouan and a Curaçao license?
Plan on separate companies. The CGA licenses only a Curaçao NV or BV, and the Anjouan regulator does not state whether a non-Anjouan company may hold its B2C license. Within Curaçao, one company cannot hold both a B2C and a B2B license.
Do game providers need a license to supply Anjouan or Curaçao operators?
For Anjouan, yes: an Anjouan B2B license or a recognition certificate (License Conditions §14). For Curaçao, a B2B supplier license is required from 24 December 2026 for critical suppliers established in Curaçao, and from that date licensees may only use critical suppliers on the CGA supplier register (LOK art. 5.16).
Is there a gaming tax in Anjouan or Curaçao?
Neither charges a tax on GGR. Anjouan's GGR tax is 0%; it charges flat fees only. The LOK sets only flat supervisory and license fees; a Curaçao company pays profit tax at 15% on the first XCG 500,000 and 22% above.
Can I move from an Anjouan license to Curaçao later?
Yes, but only by a new application. There is no conversion or recognition between the two, so you form a Curaçao NV or BV, put the local substance in place and file the full LOK application.
Sources
Primary sources only, checked on 10 November 2026: the Anjouan regulator's own pages and License Conditions, the LOK as published and its official translation, CGA publications and foreign regulators' own pages. Where the Anjouan regulator publishes no figure or timeline we say so; "in our experience" and "in our practice" mark our own experience, not a published rule.
- Anjouan Gaming — License fees (1 April 2026)
- Anjouan Gaming — License Conditions v5 (PDF, October 2026)
- Anjouan Gaming — License types
- Anjouan Gaming — Regulatory notices (September 2026)
- Anjouan Gaming — International cooperation (governing acts)
- LOK, National Ordinance on Games of Chance (official English translation)
- LOK, Landsverordening op de kansspelen, P.B. 2024 no. 157 (Dutch text)
- CGA, License Fees under the LOK, version 2.0 (15 October 2025)
- CGA, License Reclassification policy (15 October 2025)
- CGA, Local Substance policy v1.0 (10 September 2025)
- CGA, Postponement of local substance requirement under art. 5.12 (23 January 2026)
- CGA portal, FAQ
- Belastingdienst Curaçao, Succesvol Ondernemen (profit tax rates)
- Michigan Gaming Control Board (9 April 2025)
- MGA — Recognition Notices (EU/EEA authorizations only)
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