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Ontario’s Gaming Regulator Ends Transition Period for Unregulated iGaming Operators and Suppliers

By Bryson A. Stokes, Mike Maodus, Alex MacMillan and Amrit Toor (Articling Student)
October 12, 2022

The Alcohol and Gaming Commission of Ontario (AGCO) has issued new gaming standards (New Standards) to end the “transition period” for operators and gaming-related suppliers active in the unregulated market and to address specific risks related to live dealer games. The associated AGCO Information Bulletin, issued on October 4, 2022, provides that the New Standards will come into force on October 31, 2022.


Since the launch of Ontario’s internet gaming market, a key objective of the AGCO has been transitioning operators and gaming-related suppliers (suppliers) from the unregulated market to the regulated market.

To accomplish this objective the AGCO began accepting applications for registration in September 2021, in advance of Ontario’s internet gaming market launch on April 4, 2022. As part of the launch, operators and suppliers active in Ontario’s unregulated market were not precluded from applying for registration, however if such operators and suppliers did not submit applications for registration to operate in the regulated market prior to its launch, they risked having their applications denied by the AGCO.

Through the enactment of the New Standards, and specifically New Standard 1.22, the AGCO is now taking steps to formally end this “transition period” for unregistered operators and suppliers by mandating that operators and suppliers active in the unregulated market in Ontario (or that have agreements or arrangements with those in the unregulated market) must end their activities in the unregulated market.

To provide affected operators and gaming-related suppliers additional time to comply, New Standard 1.22 will come into force on October 31, 2022. Standard 1.22 provides that:

Operators and gaming-related suppliers must cease all unregulated activities if, to carry out those same activities in iGaming Ontario’s regulated online lottery scheme, it would require registration under the GCA.

Operators and gaming-related suppliers shall not enter into any agreements or arrangements with any unregistered person who is providing the operator or gaming-related supplier with any goods or services if, to provide those goods and services in iGaming Ontario’s regulated online lottery scheme, it would require registration under the GCA.

Importantly, the AGCO has also clarified that in addition to registrants in Ontario’s internet gaming market, Standard 1.22 will also apply to and govern applicants for registration as well.

Current registrants who have agreements and arrangements with those in the unregulated market in Ontario, will need to cease all unregulated activity (including activities with unregulated participants) by October 31, 2022. Applicants proceeding through the registration process who are currently active in the unregulated market will similarly need to cease all unregulated activities. The AGCO has indicated that, as with any instance of non-compliance, the AGCO will take appropriate regulatory action against any registrant that does not meet Standard 1.22 once in force.


The New Standards will also amend the Registrar’s Standards for Internet Gaming to address the specific risks present in live dealer games, which are games that use live presenters or dealers on igaming sites. The New Standards in respect of live dealer games seek to address potential risks related to the use of physical gaming equipment (including, among others, roulette wheels and playing cards) and risks related to the use of live presenters.

As part of the measures to address these risks, the AGCO will require that, as of October 31, 2022, operators have controls in place to prevent live dealers from compromising the integrity of a game and that they restrict access to gaming supplies to only those individuals with a business need.

Further measures will be put in place as of April 4, 2023, that will require certain gaming equipment used in live dealer games be approved by the Registrar or certified by an approved independent testing laboratory prior to being utilized in connection with live dealer igaming sites.

For further information, please contact:

Bryson Stokes           +1-416-863-2179
Mike Maodus            +1-416-863-4193
Alex MacMillan         +1-416-863-5844

or any other member of our Gaming group.