ALBERTA LEGALIZATION
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
17 https://aglc.ca/sites/aglc.ca/files/2026-01/26-01-14%20SRIG.pdf (4.2 Location Requirements) 18 https://www.alberta.ca/system/files/sartr-igaming-phase-3-factsheet.pdf
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IMGL MAGAZINE | MARCH 2026
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