After 18 months of LOK rollout and Anjouan's emergence, the practical answer for new B2C operators is clear. The why.
The LOK reform and what it changed
The Curaçao LOK reform, effective September 2023, replaced the master-sublicence model with a direct-to-regulator framework under the Curaçao Gaming Authority (CGA). Every operator now requires its own direct CGA licence, issued as a Gaming Service Licence (GSL). The practical impact: cost and timeline for a Curaçao licence increased materially. A CGA licence costs EUR 24,000 in annual fees plus an application fee; the review runs 6–8 weeks for a Temporary Operating Licence, with full GSL conversion taking a further 4–6 weeks. The era of the EUR 5,000 sublicence is over.
What Anjouan actually is
Anjouan is one of the three islands of the Comoros archipelago. It has issued gaming licences since 2005 but remained obscure until Curaçao’s reform prompted operators to look for alternatives. The Anjouan Offshore Finance Authority issues interactive gaming licences with a timeline of 3–5 weeks and total first-year costs around USD 15,000–25,000 all-in. Compliance requirements are lighter than post-LOK Curaçao — an AML policy is required but the depth of review is shallower, and there is no platform certification requirement equivalent to the CGA’s technical standards.
Anjouan is a legitimate, functioning jurisdiction — not a flag-of-convenience scam. The question is not whether it is real. The question is whether its recognition profile matches your operator’s needs.GSS Legal internal note — iGaming practice
Practical differences for operators
Curaçao has been accepted by most Tier-2 and Tier-3 payment processors for a decade, with recognition among affiliate networks, B2B platform suppliers, and white-label clients. Anjouan is newer to market and its recognition profile varies significantly by processor, affiliate, and B2B partner. Operators whose business model depends on specific payment processors or affiliate relationships should verify Anjouan’s acceptance with those partners before committing. For B2C operators targeting markets where the licence is used primarily for regulatory signalling to end-users — rather than institutional banking or processor onboarding — Anjouan works well at lower cost.
Banking and payment processor acceptance
Post-LOK Curaçao licences are accepted by the major iGaming-specialist processors. Anjouan is accepted by a growing but narrower processor set — primarily second-tier processors already onboarding high-risk gaming operators. The gap is narrowing as Anjouan’s market share grows and processors update their approved jurisdiction lists, but it remains a real difference in 2026. EMI banking for both jurisdictions is available through iGaming-specialist EMI providers in Lithuania, Estonia, and the UK.
Which to choose in 2026
For cost-sensitive operators whose payment processor and affiliate requirements can be met with Anjouan’s current acceptance profile: Anjouan is the faster, cheaper path and delivers a genuine licence. For operators whose business plan depends on Tier-2 processor acceptance, established affiliate partnerships, or B2B platform supplier relationships requiring Curaçao specifically: post-LOK Curaçao is the right call. For operators who are genuinely uncertain: the engagement starts with a processor and affiliate verification exercise, not a jurisdiction recommendation. We do not recommend by default.
