ALBERTA LEGALIZATION
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,
13 https://aglc.ca/sites/aglc.ca/files/aglc_files/Internet%20Gaming%20Go-Live%20Compliance%20Guide_0.pdf 14 https://aglc.ca/sites/aglc.ca/files/aglc_files/Internet%20Gaming%20Go-Live%20Compliance%20Guide_0.pdf 15 https://aglc.ca/sites/aglc.ca/files/aglc_files/Internet%20Gaming%20Go-Live%20Compliance%20Guide_0.pdf 16 https://aglc.ca/sites/aglc.ca/files/2026-01/26-01-14%20SRIG.pdf (4.1 Advertising and Promotions)
IMGL MAGAZINE | MARCH 2026
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