What licences do non-GamStop casinos actually hold?

How has the Curaçao regime changed under the LOK 2024 reform?

Curaçao has been the dominant licensing jurisdiction for non-GamStop operators for over a decade, and December 2024 saw the most consequential reform in its modern history. The Landsverordening op de Kansspelen, abbreviated locally to LOK, was approved by the Curaçao parliament on 17 December 2024 by a vote of 13-6 and came into force on 24 December 2024. It replaced the previous master-licensee model under which a small number of master holders issued sub-licences. Under LOK, the Curaçao Gaming Authority, abbreviated CGA, issues licences directly.

The new regime sets out a fee structure that signals the policy direction. The annual licence fee is EUR 47,450, with a separate EUR 24,490 fee for service-supplier registration and EUR 4,592 at the application stage. The framework also introduces substance requirements that take effect from 1 January 2026, with full enforcement deferred to 1 April 2027. Substance in this context means a degree of local economic presence rather than a pure offshore registration: actual offices, locally hired personnel, and verifiable governance on the island. The deferred enforcement timeline is deliberate, giving operators a transition window to come into compliance.

For a UK player, what changes is the regulatory documentation rather than any direct protection. Curaçao does not offer a UK-binding dispute resolution mechanism, does not enforce GamStop, and does not subject operators to the LCCP framework. What it does do, under LOK, is produce a cleaner audit trail and a single point of regulatory contact. That has a marginal impact on the legibility of complaints, but does not replicate the protective package available within the UKGC perimeter.

What does an Anjouan licence actually permit?

Anjouan is one of the islands of the Union of Comoros, and its licensing framework runs through three connected bodies: the Anjouan Offshore Finance Authority (AOFA), the Anjouan Gaming Board (ABGB), and Anjouan Licensing Services Inc. (ALSI), with ALSI handling the practical issuance and intermediary work. The legal foundation is the Computer Gaming Licensing Act 007 of 2005, supplemented by the Money Laundering (Prevention) Act 008 of 2005. The annual licence fee is approximately EUR 17,000, which is materially lower than Curaçao or Malta, and the framework is correspondingly lighter.

The critical point for any UK reader is set out in the AOFA documentation itself: the United Kingdom is on the explicit prohibited-markets list for Anjouan licence holders. An Anjouan-licensed operator that accepts UK players is operating outside its own licence terms, which is a regulatory red flag that is rarely surfaced in the commercial coverage of the segment. It is also a structural reason why complaints from UK residents to AOFA tend to receive limited engagement: the regulator’s position is that UK residents should not be customers in the first place.

The combination of low fees, light substance requirements, and the UK restriction makes Anjouan licences a marker of regulatory mismatch when they appear on a non-GamStop site serving UK consumers. The fact that some operators present an Anjouan licence as a positive signal in their footers does not change the underlying position. This is part of the wider UK position on offshore licences for UK-targeted advertising.

How does the Malta Gaming Authority compare?

The Malta Gaming Authority (MGA) is the closest of the offshore options to the UKGC in terms of standards. The pre-licensing process includes capital adequacy checks, fitness-and-properness vetting of beneficial owners and key personnel, and a published licensing framework with formal categories. Operators are required to segregate customer funds, which means deposit balances are held separately from the operator’s working capital and ring-fenced in the event of corporate failure. The MGA also operates a binding alternative dispute resolution mechanism for licensed operators, although that mechanism is calibrated to EU/EEA consumers rather than UK residents.

Post-Brexit, UK residents are not the MGA’s intended consumer base, which means an MGA-licensed operator serving UK players is also operating in a grey zone with respect to its own home regulator. The dispute resolution process is still more substantive than what Anjouan or pre-LOK Curaçao offered, but it is not the UKGC’s IBAS-backed ADR with which UK consumers are familiar. The MGA framework matters for context: it is the benchmark against which the other offshore options are typically measured. Primary documentation is published at mga.org.mt.

What about the Kahnawake Gaming Commission?

The Kahnawake Gaming Commission operates from the Mohawk Territory of Kahnawake in Canada and represents a middle ground. The regime requires operators to hold a reserve of player funds, although the exact requirements have been adjusted across the years and are less prescriptive than the MGA’s segregation regime. Dispute resolution is administered by the Commission itself rather than by a third-party ADR, which produces a more constrained complaint pathway than Malta’s binding model.

The sovereignty position of the Kahnawake jurisdiction has historically created some legal ambiguity around enforcement against operators that breach licence conditions, particularly when those operators are not domiciled on the territory. That ambiguity has been a recurring theme in academic discussions of the Kahnawake regime and is worth knowing about even though it rarely surfaces in operator-facing marketing. The Commission’s role in the non-GamStop conversation has narrowed over time as Curaçao and Anjouan have absorbed most of the new licensing activity.

Does Gibraltar still feature?

Gibraltar was historically a major hub for UK-targeting online gambling, with several large UK-facing brands licensed there prior to the 2014 Act. Since the introduction of the point-of-consumption regime, operators serving UK residents have needed a UKGC licence in addition to or instead of their Gibraltar one, and Gibraltar’s role in the non-GamStop conversation has shrunk to near-zero. Where it does still appear, it is usually as a historical badge on long-established platforms that hold multiple licences. For a UK player, a Gibraltar-only licence in 2026 is unusual and worth investigating further before treating it as significant.

How do the four headline regimes compare side by side?

The table below sets out the practical position across the four most commonly seen jurisdictions on non-GamStop sites in 2026. Acceptance of UK players varies in practice between the regulator’s formal position and the operator’s behaviour, and the formal position is given here.

What does all of this mean for a UK player at the operator level?

None of the four regimes replicates the UKGC consumer-protection package. None enforces the GamStop register. None applies the £150 financial vulnerability check that took effect on 28 February 2025. None applies the £5 and £2 slot stake caps that took effect on 9 April and 21 May 2025. None of them allow IBAS access for ADR. The closest in spirit to UKGC standards is the MGA, but the MGA framework is calibrated to EU/EEA consumers rather than UK residents. For a deeper account of what licence holders cannot offer UK players, the dedicated risks-and-protections analysis sets out each gap with date references.

The licensing question is therefore best read alongside the practical operator review and the freshness picture for the segment. The operator comparison by these licences shows how the four regimes map onto the established roster, and the newly licensed sites under post-LOK Curaçao page tracks how recent launches are presenting their licences.

How to read a licence footer on any non-GamStop site

Operator footers typically display a licence number and a regulator name. A reader can cross-check that number against the public register of the named regulator: the CGA, the AOFA via ABGB or ALSI documentation, the MGA’s public licensee list, and the Kahnawake Gaming Commission’s authorised supplier list. A licence that does not appear on the regulator’s own list is either lapsed, fictitious, or attached to a different operating entity than the one displayed in the footer. None of those outcomes is good for the player.

Beyond verification, the more useful question is what the licence actually delivers. The list above is the short answer: an audit trail and a single point of regulatory contact, varying in substance from jurisdiction to jurisdiction, but in none of these cases the UKGC-calibrated protection package. The wider context sits in our non-GamStop UK guide.