Alberta’s new iGaming regulatory framework

Market structure, regulation, and entry considerations

Summary

Key takeaways from this article

Understand Alberta’s new licensing regime and regulatory bodies
How potential operators should apply for a license
Reviewing the infrastructure around gaming, especially payment services

Abstract

The Canadian province of Alberta recently legalized iGaming. In this article we review the market structure, outline the new regulatory framework and consider the likely takeup of license opportunities and the possible operators who will enter the market.

Alberta is poised to become Canada’s second fully regulated private operator iGaming market. Following the enactment of the iGaming Alberta Act and related amendments to Alberta’s gaming legislation, the province is transitioning from a government operated monopoly model to a framework that permits private operators to offer online gaming under regulatory oversight as agents of an Alberta Crown corporation, iGaming Alberta Corporation. This article examines Alberta’s emerging online market from a legal and regulatory perspective. It reviews the economic and cultural context underpinning the market, the statutory and regulatory architecture governing online gaming, the respective roles of provincial institutions, and the practical considerations facing operators and suppliers seeking market entry. The analysis is intended to provide practitioners and industry participants with a structured understanding of how Alberta’s online gaming framework operates in practice and how it compares to other Canadian models.

Introduction

Canada’s regulated online gaming landscape is undergoing a period of rapid development. Following Ontario’s transition to a competitive online gaming market in 2022,[1] Alberta has moved forward with its own model for a competitive regulated online gaming market. With registration now open and market launch expected later in 2026, Alberta represents the most significant new commercial opportunity in Canada for online gaming operators and suppliers.

Alberta’s approach reflects a deliberate policy choice to build on an existing gaming economy rather than introduce online gaming as an entirely new activity. The province has long operated a robust land-based gaming sector, complemented in recent years by a government operated online platform. The move to a competitive online gaming model is designed to expand consumer choice, improve channelization from unregulated grey-market operators, and generate sustainable public revenue, while maintaining strong regulatory oversight and responsible gambling protections.

This article analyzes Alberta’s online gaming market through four lenses. First, it situates the market within Alberta’s economic, cultural, and gaming landscape. Second, it examines the legislative and regulatory framework governing online gaming. Third, it reviews the registration and market entry process for operators, suppliers, and service providers. Finally, it considers key practical and forward-looking issues likely to shape the market as it develops.

Analysis

Alberta’s Gaming and Economic Context

Alberta enters the competitive online gaming space supported by strong underlying economic fundamentals. The province consistently ranks among the highest in Canada for GDP per capita and household income,[2] supported by a diversified economy spanning energy, finance, technology, agriculture, and professional services. Its population is highly urbanized, with the Calgary and Edmonton metropolitan regions accounting for a significant share of residents, disposable income, and economic activity.[3] These fundamentals provide a stable base for discretionary consumer spending, including regulated gaming and entertainment.

Gaming has long been embedded in Alberta’s economic and cultural landscape. The province operates a mature land-based gaming sector comprising destination casinos, racing entertainment centres, and a wide network of video lottery terminals. These operations generate substantial public revenue and have historically supported both provincial programs and First Nations participation in gaming.^[4] Alberta’s gaming model has therefore evolved within an established regulatory and commercial ecosystem rather than emerging in isolation.

In 2020, Alberta expanded this ecosystem by launching a government operated online gaming platform (PlayAlberta),^[5] establishing a regulated digital presence alongside land-based offerings. While that platform demonstrated sustained consumer demand and year over year growth,[6] market data and regulator commentary suggest that approximately 70 percent of online gaming activity in Alberta continued to occur through unregulated grey-market operators.[7] The transition to a competitive online gaming market is intended to address this imbalance by offering regulated alternatives capable of competing on product range, technology, and user experience, while recapturing activity into a supervised environment.

Institutional structure and legislative framework

Alberta’s online gaming framework reflects a deliberate separation of regulatory oversight and commercial operation. This structural choice seeks to balance market openness with regulatory integrity by clearly delineating the roles of oversight, enforcement, and commercial conduct. Two provincial entities play central roles within this framework.

The Alberta Gaming, Liquor and Cannabis Commission (“AGLC”) serves as the province’s primary gaming regulator. Its mandate extends across all gaming activity in Alberta and includes registering market participants, establishing binding standards and requirements, conducting investigations and audits, and enforcing compliance. Importantly, the regulator’s authority is ongoing rather than transactional, allowing it to impose, amend, or revoke registration conditions as market conditions and regulatory priorities evolve.

Commercial operation of online gaming is assigned to the Alberta iGaming Corporation (“AiGC”), a Crown corporation established specifically to conduct and manage online gaming on behalf of the province. The corporation does not perform a regulatory function. Instead, it acts as the commercial counterparty to private operators by entering into operating agreements that establish the commercial terms and ongoing operational relationship with the province.

The statutory foundation for this structure is found in three interrelated legal instruments.

The Gaming, Liquor and Cannabis Act[8] serves as the starting point for all gaming activity in Alberta and is the primary source of regulatory authority for online gaming. It establishes the AGLC and confers broad powers over registration, standards setting, inspections, audits, and enforcement, including the ability to suspend or cancel registrations where integrity, suitability, or public interest concerns arise.

The iGaming Alberta Act[9] builds on this by establishing the AiGC and expressly enabling a competitive online gaming market. In doing so, it amends the Gaming, Liquor and Cannabis Act to include online gaming as a regulated activity while preserving the regulator’s oversight role. Regulatory authority therefore remains centralized with the AGLC, while commercial responsibility is assigned to the AiGC.

Operational detail is supplied by the Gaming, Liquor and Cannabis Regulation.[10] While much of the regulation predates online gaming, recent amendments introduce a specific online gaming division that applies core regulatory concepts to online gaming activity. The regulation implements the statutory prohibition on unregistered gaming by requiring that any person who operates an online gaming site, or provides goods or services in support of such a site, be registered with the regulator. It also establishes distinct classes of registration for operators and suppliers and provides the legal basis for detailed standards governing advertising, inducements, player protection, record keeping, and approved gaming systems.

Taken together, this institutional and legislative architecture implements a centralized but flexible model of oversight that separates regulatory control from commercial execution while maintaining continuous supervision of market participants and gaming systems.

Regulatory standards and compliance obligations

Beyond its core statutes and regulations, Alberta’s online gaming framework relies heavily on regulator issued standards and policy instruments to impose substantive compliance obligations on market participants. In practice, these standards are the primary mechanism through which Alberta translates high-level legislative objectives into enforceable operational requirements.

While the Gaming, Liquor and Cannabis Regulation establishes the legal foundation for regulating online gaming, much of the day-to-day compliance burden arises from the Standards and Requirements for Internet Gaming[11] issued by the AGLC. These Standards address a broad range of operational areas, including game integrity, player identity verification, responsible gambling controls, advertising and inducements, record keeping, information security, and the approval and ongoing monitoring of gaming systems.

A defining feature of Alberta’s approach is that these Standards form conditions of registration and may be amended over time. The governing legislation expressly authorizes the regulator to issue and revise standards, meaning that compliance obligations are not fixed at the point of market entry. Registrants are therefore subject to an evolving regulatory environment shaped by supervisory priorities, emerging risks, and market developments. This standards-based model mirrors approaches adopted in other Canadian jurisdictions and places a premium on continuous compliance, internal governance, and responsiveness to regulatory guidance.

Registration and market entry

Participation in Alberta’s online gaming market is subject to a two-stage process involving regulatory approval and, for operators, a separate commercial authorization. Importantly, the process distinguishes between operators offering games directly to players, suppliers providing critical gaming systems or services, and other ancillary service providers whose activities support regulated operations.

The starting point for all market participants is registration with the AGLC. Registration is required for any person that operates an online gaming site or provides goods or services in support of an online gaming site, subject to limited statutory exemptions.[12] The registration framework is intended to ensure that all participants meet baseline requirements relating to integrity, suitability, financial stability, and operational capability before participating in the regulated market.

Operators are entities that offer online gaming products directly to players located in Alberta. Operator registration is the most comprehensive category and reflects the regulator’s view that operators bear primary responsibility for player-facing activities, wagering, handling of player funds, and compliance with social responsibility and integrity requirements. Registration involves suitability assessments, background checks, corporate and ownership disclosure, review of gaming platforms and products, and demonstration of compliance readiness against applicable standards. However, regulatory approval by the AGLC alone is not sufficient to commence operations. Operators must also complete a separate commercial agreement process with the AiGC that governs their ongoing operational and financial relationship with the province.

Suppliers provide goods or services in support of online gaming operators and are subject to regulatory oversight that varies based on the nature and impact of their services. Specifically, Alberta distinguishes between suppliers that provide platform services or other critical gaming systems and those that provide ancillary or supporting services.[13] This classification affects the scope of regulatory oversight, the depth of due diligence, and the applicable fee structure. Suppliers are required to register with the AGLC but, unlike operators, do not enter into commercial operating agreements as a condition of market participation. While the registration process for suppliers is generally less onerous than for operators, suppliers remain subject to ongoing suitability and compliance obligations, particularly where their services materially affect game outcomes, player accounts, or regulatory controls.

A notable feature of Alberta’s framework is the front-loaded nature of the registration process. Significant due diligence and compliance reviews occur prior to market entry rather than being deferred until after launch. The AGLC has indicated that it will apply a risk-based approach to registration, with the scope and depth of review varying depending on factors such as the applicant’s regulatory history, experience in other jurisdictions, and the complexity of its corporate structure. Applicants with existing registrations in comparable regulated markets may also benefit from a more streamlined review, although Alberta-specific disclosures and confirmations remain required.

Payments, marketing, and ancillary services

Not all entities involved in Alberta’s online gaming ecosystem are subject to direct registration. Nevertheless, the regulatory framework is designed to ensure that functions capable of affecting game integrity, player protection, or financial flows remain within the regulator’s effective oversight, whether directly or indirectly.

Payment service providers demonstrate Alberta’s approach to applying regulatory oversight to financial functions that affect player funds without mandating direct registration in all cases. Consistent with other Canadian models, Alberta generally does not require payment service providers to register unless they provide services that constitute critical gaming systems.[14] In practice, this means that providers offering e-wallet functionality or other services that directly interact with player accounts or wagering activity may be subject to registration, while more traditional payment processors are assessed on a case-by-case basis. The regulator has indicated that the determination will depend on the nature of the services provided and their potential impact on regulatory controls.

Even where registration is not required, payment providers remain subject to indirect regulatory scrutiny. Operators are required to document and obtain approval for their control account management processes, which govern player deposits, withdrawals, and the handling of player funds.[15] As a result, payment arrangements are reviewed as part of the operator’s compliance framework, effectively bringing payment providers within the regulatory perimeter through the operator’s obligations.

Affiliate marketing and advertising are addressed through a combination of statutory requirements, general regulatory expectations, and operator accountability. At present, the advertising and promotion section of the online gaming standards has been intentionally left undeveloped,[16] allowing the regulator to finalize more detailed requirements closer to market launch.

Affiliates and other advertising intermediaries are not currently required to register as online gaming participants, even where they are involved in player acquisition or promotional activity. Instead, regulatory oversight is exercised indirectly through operator obligations. Operators remain responsible for ensuring that marketing conducted on their behalf complies with applicable requirements, regardless of whether that activity is carried out directly or through third parties. Consequently, affiliate and advertising arrangements are typically structured to include contractual controls, monitoring mechanisms, and compliance obligations designed to align third-party conduct with operator regulatory responsibilities.

Following market launch, registered operators will be prohibited from obtaining marketing services from third-party service providers that provide services to unregistered operators that accept bets from persons in Alberta without legal authorization. Accordingly, affiliate marketers and other marketers will, in practice, need to cease “grey-market” marketing activity in order to service registered operators in Alberta.

Other ancillary service providers, including data providers, integrity monitors, and customer support services, may also fall within Alberta’s regulatory scope depending on their role and the degree to which their services affect regulated activity. As with payment services, regulatory treatment is fact specific and benefits from early assessment. Alberta’s approach reflects a broader policy objective of ensuring comprehensive oversight of material functions while avoiding unnecessary regulatory burden on peripheral service providers.

Key issues and future developments

Several issues are likely to shape Alberta’s online gaming market as it matures and as regulatory expectations are tested in practice. While the core framework is now in place, the application and enforcement of key policy areas will be critical to how the market develops over time.

Shared liquidity presents both commercial opportunity and regulatory complexity. Alberta’s framework expressly contemplates the possibility of interprovincial liquidity sharing with other Canadian jurisdictions, provided specific conditions are met and appropriate regulatory agreements are in place. The general rule remains that online gaming activity must be restricted to players physically located in Alberta, subject to a limited carve out permitting games to be conducted in conjunction with another Canadian province.[17] As a result, interprovincial pooled liquidity is not expected to be available at market launch and will depend on coordination between provincial regulators. International pooled liquidity is not permitted, as the regulatory exception applies only to arrangements with other Canadian provinces. Alberta is likely to monitor developments in other jurisdictions closely, including ongoing judicial and policy discussions around pooled liquidity, before providing further clarity.

The transition from unregulated to regulated activity is another important area to watch. Alberta has signaled an intention to support an orderly transition by permitting certain prelaunch activities during the registration period, including advertising and customer sign up, while prohibiting the acceptance of deposits or wagers until market launch.[18] While this approach is designed to facilitate market readiness and channelization, questions remain around its practical application. These include how new versus existing customers will be treated, how cross jurisdictional customer relationships will be managed, and expectations around the wind down of unregulated activity as regulatory oversight increases.

More broadly, Alberta’s regulatory posture suggests a willingness to adapt as the market evolves. Areas such as affiliate regulation, payment service provider oversight, information privacy standards, and technical standards may be revisited over time as the regulator gains operational experience and assesses emerging risks. For market participants, ongoing regulatory engagement and flexibility will be essential to navigating a framework that is designed to evolve alongside the market it governs.

Conclusion

Alberta’s move to a competitive online gaming market represents a significant development in Canada’s gaming landscape and reflects an incremental but meaningful evolution in provincial gaming policy. Rather than treating online gaming as an isolated or exceptional activity, Alberta has chosen to integrate online gaming into its broader gaming framework, aligning digital offerings with long standing regulatory principles that govern land-based gaming.

From a structural perspective, the separation between regulatory oversight and commercial operation mirrors best practices that have emerged in other jurisdictions. By vesting regulatory authority in the AGLC while assigning commercial execution to the AiGC, Alberta seeks to mitigate conflicts of interest while preserving operational flexibility. This design is likely to be of interest to other provinces evaluating potential market expansion.

At the same time, Alberta’s framework places meaningful responsibilities on market participants. Registration is comprehensive, compliance obligations are ongoing, and regulatory standards are designed to evolve over time. For operators and suppliers, market entry is not a one-time event but the beginning of a continuing regulatory relationship that requires sustained investment in governance, compliance infrastructure, and regulatory engagement.

As the market moves toward launch, several areas will warrant close attention, including advertising enforcement, the treatment of affiliates and ancillary service providers, and the practical implementation of transition rules for operators migrating from unregulated activity. The approach taken in these areas will shape the early market environment and influence channelization outcomes.

Overall, Alberta’s online gaming market is best understood not as a simple replication of existing models, but as a distinct regulatory experiment informed by Canadian constitutional, economic, and social considerations. For practitioners and industry participants, understanding the nuances of this framework will be essential to navigating entry, managing risk, and participating sustainably in Canada’s evolving online gaming landscape.

Ron Segev is Managing Partner at Segev LLP and an IMGL member

[1] https://igamingontario.ca/en/news/ontarios-new-igaming-market-launch-april-4-2022

[2] https://businesscouncilab.com/insights-category/economic-insights/albertas-economy-booming-or-treading-water/

[3] https://regionaldashboard.alberta.ca/region/calgary/population/#/?from=2020&to=2024 and https://regionaldashboard.alberta.ca/region/edmonton/population/#/?from=2020&to=2024

[4] https://aglc.ca/gaming/charitablegaming/host-first-nation-casinos

[5] https://playalberta.ca/

[6] https://aglc.ca/news/new-era-begins-play-alberta

[7] https://www.alberta.ca/albertas-igaming-strategy

[8] https://open.alberta.ca/publications/g01

[9] https://open.alberta.ca/publications/i00p2

[10] https://open.alberta.ca/publications/1996_143

[11] https://aglc.ca/documents/standards-and-requirements-internet-gaming