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Gambling Act 2003 + Online Casino Gambling Act 2026 + AML/CFT Act 2009 + Racing Industry Act 2020 — New Zealand's online casino licensing regime - 15 licences awarded by ascending-clock auction, 16% Offshore Gambling Duty with 4 ppt community ringfence, DIA as regulator. Royal Assent 27 April 2026, in force from 1 May 2026; full operational regulations expected mid-2026 to December 2027.
All 32 New Zealand standards, organised by Theme
New Zealand passed the Online Casino Gambling Act 2026 (No. 14) on 23 April 2026; it received Royal Assent on 27 April 2026 and came into force on 1 May 2026. The Act creates a tightly-capped online casino licensing regime - up to 15 licences awarded through an ascending-clock auction process - supervised by the Department of Internal Affairs. A 16% Offshore Gambling Duty (4 percentage points ring-fenced for community returns) replaces the 12% rate that took effect 1 July 2024. Operational regulations covering fee schedules, trust-account architecture, game certification, self-exclusion register design and detailed advertising rules are expected progressively from mid-2026 with self-exclusion regulations due by December 2027.
Editorial summary, not legal advice. Every card on this page is a plain-English summary of the regulator's own rule, cross-checked against the primary source. Always verify against the published text before filing, launching, or advising.
Before the Online Casino Gambling Act 2026 commenced on 1 May 2026, all gambling in New Zealand was governed by the Gambling Act 2003 (Class 1-4 + Casino + Lotto/TAB), with offshore online gambling neither conducted lawfully nor lawfully advertised within New Zealand. These provisions remain in force AND continue to govern everything outside the new online casino regime.
5 standards3 operator-action
60%
operator-action
Headline operator risks
Treating the Online Casino Gambling Act 2026 as extending to sports or racing wagering - it does not; TAB NZ's monopoly under the Racing Industry Act 2020 is preserved
Operating any non-casino online gambling product (lottery, bingo, sports, racing) under a future online casino licence - those verticals remain outside the new regime
Continuing to publish overseas-gambling advertising within New Zealand after 1 May 2026 at pre-2024 penalty levels - penalties were uplifted at commencement
General prohibition 3
GA 2003 s.9
[IN FORCE] General prohibition on gambling
In force
Section 9 of the Gambling Act 2003 provides that gambling is unlawful unless authorised by or under the Act. The general prohibition is the anchor on which every authorised gambling activity rests; everything not expressly authorised - including conducting online casino gambling without a licence under the Online Casino Gambling Act 2026 - is unlawful.
Requirements
Operate only inside an exception expressly authorised by the Gambling Act 2003 or the Online Casino Gambling Act 2026
Document the statutory basis for every gambling activity in the operator compliance file
Treat unlicensed product offerings as criminally prohibited
Source: legislation.govt.nz/act/public/2003/0051/latest/whole.html · Status: in force.
GA 2003 s.16
[IN FORCE] Prohibition on overseas-gambling advertising within New Zealand
In forceAdvertisingOperator action
Section 16 of the Gambling Act 2003 prohibits publishing, or arranging the publication of, advertisements for overseas gambling within New Zealand. From 1 May 2026 (commencement of the Online Casino Gambling Act 2026) the penalty structure was uplifted: individuals face pecuniary penalties up to NZD 300,000 and bodies corporate up to NZD 5,000,000 for unlicensed advertising - an order-of-magnitude increase from the original NZD 10,000 / NZD 50,000 ceiling.
Requirements
Cease all New Zealand advertising of any offshore (unlicensed) online casino product from 1 May 2026
Audit affiliate and influencer channels for incidental NZ exposure
Withdraw any sports-broadcast / streaming sponsorships visible to NZ audiences
Source: legislation.govt.nz/act/public/2003/0051/latest/whole.html; penalty uplift per Online Casino Gambling Act 2026. Status: in force with uplifted penalties.
GA 2003 Part 10
[IN FORCE] DIA enforcement powers under Gambling Act 2003 Part 10
In force
Part 10 of the Gambling Act 2003 vests the Secretary for Internal Affairs (through DIA) with licensing, inspection, search-warrant, document-demand, injunction and prosecution powers across all classes of authorised gambling. These powers extend by operation of the Online Casino Gambling Act 2026 to the new online casino regime - DIA is the single supervisor across all NZ-licensed gambling.
Requirements
Maintain operator records readily producible to DIA inspectors on demand
Respond to formal document requests within statutory windows
Treat DIA's enforceable-undertaking, formal-warning and take-down-notice tools as escalation pathways before pecuniary penalty proceedings
Source: legislation.govt.nz/act/public/2003/0051/latest/whole.html Part 10. Status: in force.
Adjacent statutes preserved 2
Racing Ind Act 2020
[IN FORCE] TAB NZ racing & sports-betting monopoly
In force
The Racing Industry Act 2020 - as amended by the Racing Industry Amendment Act 2024 (commencement 27 June 2025) - confers exclusive rights on TAB NZ for fixed-odds and totalisator wagering on NZ-licensed racing and approved sports events. The Online Casino Gambling Act 2026 does NOT extend to sports or racing betting; TAB NZ's monopoly is preserved unaltered. Operators applying for online casino licences cannot use those licences to accept sports or race wagers.
Requirements
Do NOT include sports or racing wagering in online casino licence applications - those verticals are not within the Act
If operating dual-vertical product elsewhere, ring-fence the NZ-facing offering to casino-class games only
Track TAB NZ enforcement of the 27 June 2025 monopoly against unlicensed sports operators as a leading indicator of DIA appetite
Source: legislation.govt.nz/act/public/2020/0028/latest/whole.html. Status: in force as amended. News context: Yogonet/Spinoff coverage of the 27 June 2025 commencement.
GA 2003 Part 5
[IN FORCE] NZ Lotteries Commission (Lotto NZ) monopoly on lotteries
In force
Part 5 of the Gambling Act 2003 constitutes the New Zealand Lotteries Commission (Lotto NZ) as the statutory monopoly operator of lotteries, instant kiwi and Keno. The Online Casino Gambling Act 2026 does not disturb this monopoly. Online lottery-style products served to NZ residents by any party other than Lotto NZ remain unlawful.
Requirements
Exclude all lottery-class products from any NZ-facing offering, even under a future online casino licence
If operating bingo or other lottery-adjacent product, seek New Zealand legal advice on Part 5 boundary
Source: legislation.govt.nz/act/public/2003/0051/latest/whole.html Part 5. Status: in force.
2
DIA 2
Online Casino Gambling Act 2026 - the licensing architecture
The Online Casino Gambling Act 2026 (No. 14) is the first dedicated New Zealand online casino statute. It creates a hard-capped, auction-awarded licensing regime under DIA supervision, with detailed operational requirements deferred to secondary regulations expected mid-2026 to December 2027.
6 standards5 operator-action
83%
operator-action
Headline operator risks
Treating the headline figures (15 licences, 3-licence cap) as static - Cabinet may revisit the cap in light of auction demand
Assuming licence eligibility transfers from existing Malta / Curaçao / UK licences - DIA fit-and-proper is independent
Underestimating the impact of pending civil/criminal proceedings on a fit-and-proper assessment (see April 2026 class-action context)
Capped licensing regime 5
OCGA 2026 §15-cap
[ACT - phased commencement] Up to 15 online casino licences via ascending-clock auction
Act - phased commencementOperator action
The Online Casino Gambling Act 2026 caps the number of online casino licences at 15. Awards are made through a three-stage process: (i) Expression of Interest with probity assessment (July 2026), (ii) ascending-clock auction (September 2026), (iii) full licence application against published criteria (October 2026 - 1 December 2026 deadline). The ascending-clock mechanism is unusual globally - Denmark and Sweden use capped licences but without ascending-clock auctions; only Greece's HGC and certain US state casino tenders have used analogous auction-style awards.
Requirements
Register for the GETS (Government Electronic Tenders Service) notification list to receive the EOI invitation in July 2026
Prepare probity disclosures covering the operator, parent group, beneficial owners and key personnel
Treat the 1 December 2026 application deadline as binding - pending applications submitted after this date are time-barred
Source: DIA Online Gambling Regulatory Implementation page (dia.govt.nz/Online-Gambling-Regulatory-Implementation). Cabinet Paper 9 September 2024 confirms the 15-licence model. News context: iGB, AGB Brief, Yogonet coverage of June-July 2025.
OCGA 2026 §3-cap
[ACT - phased commencement] 3-licence concentration cap per group
Act - phased commencementOperator action
No person may have 'significant influence over more than three licences'. The cap operates at the beneficial-ownership level: corporate groups, common-control structures and parties acting in concert are aggregated. Entain plc has publicly stated (CEO Stella David, full-year 2025 earnings) that it will seek the maximum three licences. SkyCity Entertainment Group is publicly preparing at least one licence application.
Requirements
Map your group's ultimate beneficial ownership against the 'significant influence' threshold before submitting multiple bids
Disclose all affiliated bidders in EOI submissions; failure to disclose is a probity flag
Plan no more than three bids per group; reserve concentration for highest-value licences
Licences are issued for an initial 3-year term with a single renewal option extending up to a maximum of 5 years' further tenure (8 years total). To prevent licence-warehousing, operators must commence operations within 90 days of licence issue AND remain active for a minimum of 270 days in any rolling 12-month period. Failure to meet either trigger entitles DIA to commence revocation proceedings.
Requirements
Plan operational launch within 90 days of licence award - full marketing, KYC, payments and content must be live
Maintain continuous operational uptime (270-day rolling threshold) - extended outages are a revocation risk
Begin renewal preparation 6-9 months before the initial 3-year term expires
Source: ICLG briefing on Online Casino Gambling Bill (post-Royal-Assent equivalent). Status: in force from 1 May 2026.
OCGA 2026 §regulator
[ACT - phased commencement] DIA is the licensing & supervisory regulator
Act - phased commencement
The Online Casino Gambling Act 2026 designates the Department of Internal Affairs (through the Secretary for Internal Affairs) as the licensing authority and ongoing regulator. The internal team is the 'Online Gambling Regulatory Implementation' (OGI) unit. No new specialist body has been created. The Gambling Commission retains an appellate role for licensing decisions only.
Requirements
Channel all communications through the DIA OGI team via the contact pathway published on dia.govt.nz
Distinguish first-instance DIA decisions (challengeable to the Gambling Commission) from supervisory enforcement (challengeable to the District Court)
Track DIA's Statement of Performance Expectations annual cycle for resourcing signals
Source: DIA Online Casino Gambling landing page (dia.govt.nz/Online-Casino-Gambling). Status: in force.
Unlicensed conduct and unlicensed advertising attract civil pecuniary penalties up to NZD 300,000 for an individual and NZD 5,000,000 for a body corporate - a substantial uplift from the Gambling Act 2003's NZD 10,000 / NZD 50,000 caps. DIA may pursue these via formal warnings, enforceable undertakings, take-down notices and ultimately civil-penalty proceedings in the High Court.
Requirements
Map maximum-exposure scenarios across each NZ-facing campaign, page, broadcast spot and affiliate channel
Track DIA's first 2026-27 enforcement actions as the proportionality reference
Source: Senet Group / Buddle Findlay analyses of the Act. Status: in force from 1 May 2026.
Eligibility and probity 1
OCGA 2026 §fit
[ACT - phased commencement] Fit-and-proper test for operators, key personnel, beneficial owners
Act - phased commencementOperator action
Licence applicants must satisfy DIA's fit-and-proper test across the operator entity, parent group, beneficial owners with significant influence, and key personnel (directors, CEO, Compliance Officer, Money Laundering Reporting Officer). Specific test criteria will be published in regulations expected mid-2026; the core test mirrors DIA's existing standard for land-based casino licensing.
Requirements
Compile fit-and-proper packs in advance: criminal-record checks, financial integrity disclosures, regulatory-history disclosures across every prior jurisdiction
Disclose any pending civil or criminal proceedings against the entity OR key personnel - the April 2026 NZ class action against bet365 (Denise Coates personally), Super Group + SkyCity is a live licensing-eligibility wildcard
Pre-vet supplier and white-label arrangements; DIA scope reaches material commercial counterparties
Source: DIA Online Casino Gambling guidance + Russell McVeagh implementation briefing (April 2026). News context: NBR + SBC News + Casino Beats coverage of April 2026 class actions.
3
DIA 3
Fiscal framework - Offshore Gambling Duty, Problem Gambling Levy, GST
The Offshore Gambling Duty was introduced at 12% on 1 July 2024 and was raised to 16% by select-committee amendment to the Online Casino Gambling Bill (with 4 percentage points ring-fenced for community returns). Operators face additional layered obligations: the 1.24% Problem Gambling Levy under Gambling Act s. 319 and 15% GST under the remote-services rules.
4 standards4 operator-action
100%
operator-action
Headline operator risks
Misreading the 16% Offshore Gambling Duty as a comprehensive 'all-in' rate - GST and the 1.24% PG levy stack
Failing to register for OGD by the applicable deadline (1 July 2024 for existing offshore operators; pre-licence for new entrants)
Confusing the OGD base (NZ-resident wagers minus NZ-resident prizes) with GGR - they are similar but not identical
Direct duties on operators 3
OGD 12 → 16
[IN FORCE] Offshore Gambling Duty raised from 12% to 16%
In forceTax & leviesOperator action
The Offshore Gambling Duty (Gaming Duties Act 1971, Part 2C, inserted by the Taxation (Annual Rates) Act 2024) took effect 1 July 2024 at 12% of offshore gambling profits (NZ-resident wagers minus NZ-resident prizes). The rate was raised to 16% by select-committee amendment to the Online Casino Gambling Bill - 4 percentage points ring-fenced for community returns (grassroots-sport and community-organisation grants), funded through to the Lottery Grants Board distribution pathway. Quarterly returns are filed to Inland Revenue (IRD), aligned to the GST cycle.
Requirements
Calculate OGD quarterly on the NZ-resident wagering base (not aggregate GGR)
File OGD returns to IRD on the GST-aligned cycle (28 October, 28 January, 28 April, 28 July)
Track the 4 percentage point community-returns ring-fence separately - applies to all licensees from the higher-rate commencement
Source: ird.govt.nz/duties/offshore-gambling-duty + IRD Special Report April 2024. News context: NEXT.io 16% rate hike coverage; Buddle Findlay community-returns analysis.
PGL 1.24%
[ACT - phased commencement] Problem Gambling Levy at 1.24% of profits
Section 319 of the Gambling Act 2003 authorises a sector-funded Problem Gambling Levy that funds Te Whatu Ora and accredited providers (PGF NZ, Hāpai te Hauora, Salvation Army Oasis). For online casino licensees, the levy is set at 1.24% of profits and applies from licence commencement. The levy is in addition to the Offshore Gambling Duty and to GST.
Requirements
Reserve 1.24% of post-prize revenue alongside the OGD reserve for quarterly settlement
Anticipate triennial levy reviews - the rate is set by Order in Council and historically adjusts every 3 years
Treat the levy as a structural cost of NZ market entry, not an optional CSR contribution
Source: legislation.govt.nz/act/public/2003/0051 s.319 + Online Casino Gambling Act 2026 Schedule. Status: in force from licence commencement.
GST 15%
[IN FORCE] GST at 15% on remote services to NZ residents
In forceTax & leviesOperator action
Under the remote-services rules in force since 1 October 2016 (Goods and Services Tax Act 1985), GST at 15% applies to remote gambling services supplied to NZ residents where the operator's NZ-sourced taxable supplies are at least NZD 60,000 in any 12-month period. The Online Casino Gambling Act 2026 does not displace this obligation; licensed operators face GST + OGD + PGL stacking, producing an effective tax load materially higher than the OGD figure alone.
Requirements
Register for NZ GST as soon as projected annual NZ-resident supplies cross NZD 60,000
Apply GST to all NZ-resident remote services including in-play wagering, tournament entries and ancillary services
Model the effective tax burden as OGD + PGL + GST (with operator-incidence rules) when scoping NZ entry economics
Source: ird.govt.nz GST on remote services guidance; EY Tax Alert 2024 on stacking with OGD. Status: in force.
Fee schedule 1
OCGA 2026 §fees
[REGULATIONS - pending] Application fee and annual licence fee
Regulations - pendingOperator action
Application fee and annual licence fee are NOT YET PUBLISHED. The Online Casino Gambling Act 2026 empowers regulations to prescribe the fee schedule; DIA has indicated the fee regulations will be made in mid-2026 ahead of the auction process. Until publication, fee figures should NOT be quoted - any consultancy, brokerage or compliance vendor citing specific NZ application or annual fees is inferring, not citing.
Requirements
Do NOT plan budgets around invented NZ fee figures - wait for the DIA fee regulation publication mid-2026
Allocate provisional budget tagged 'pending DIA fee schedule' for board / investor briefings
Subscribe to the DIA Online Gambling notification list for the regulation drop
AML/CFT framework - Act 2009 extension to online casino operators
The Anti-Money Laundering and Countering Financing of Terrorism Act 2009 already captures land-based casinos as reporting entities; the Online Casino Gambling Act 2026 brings online casino licensees within the same regime. DIA is the AML/CFT supervisor for casinos (from 1 July 2026 as sole supervisor for online operators). SkyCity's NZD 4.16m DIA civil penalty (September 2024) and AUSTRAC's AUD 67m penalty against SkyCity Adelaide (June 2024) demonstrate the regulator's enforcement posture.
5 standards4 operator-action
80%
operator-action
Headline operator risks
Treating the AML/CFT Act 2009 as separate from the Online Casino Gambling Act - they are explicitly cross-referenced; non-compliance with the 2009 Act is a licensing breach
Underestimating the 5-year retention obligation - DIA inspection requests reach historic records
Failing to file annual AML/CFT programme reports to DIA on the statutory cycle
Section 9.6 of the AML/CFT Act 2009 requires every reporting entity to establish, implement and maintain a written AML/CFT programme grounded in a documented risk assessment. The programme must cover customer due diligence, ongoing monitoring, suspicious-activity reporting, record-keeping, vetting and training. From licence commencement, online casino operators must produce the programme on demand and refresh the underlying risk assessment at least annually.
Requirements
Document the risk assessment in writing, signed off by the operator's board
Refresh the risk assessment annually AND on every material change (new product, geography, payment method)
Retain risk-assessment files for the AML/CFT Act statutory period
[IN FORCE] Customer due diligence at NZD 10,000 threshold + enhanced measures for PEPs
In forceAML/CFTOperator action
Reporting entities must conduct standard customer due diligence for occasional transactions at or above NZD 10,000 and for establishing a business relationship (every account opening at an online casino). Enhanced due diligence applies for politically exposed persons (PEPs), trusts, complex corporate structures and high-risk jurisdictions. Verification must be conducted before establishing the business relationship - i.e. before the player can deposit and play.
Requirements
Verify identity, address and date of birth before the first deposit (pre-deposit KYC)
Screen all new customers against PEP, sanctions and adverse-media lists at registration AND on a rolling basis
Apply EDD with documented sign-off for PEPs and high-risk-geography customers
Source: AML/CFT Act 2009 + DIA AML/CFT supervisory guidance. Status: in force.
AML/CFT SAR
[IN FORCE] Suspicious Activity Reports to NZ Police Financial Intelligence Unit
In forceAML/CFTOperator action
Reporting entities must file Suspicious Activity Reports (SARs) to the NZ Police Financial Intelligence Unit (FIU) without unreasonable delay where the entity has reasonable grounds to suspect that a transaction may relate to money laundering, terrorism financing or other serious offending. Failure to file or to file timely is enforced as a breach of the AML/CFT Act.
Requirements
Maintain a documented escalation process from front-line staff to MLRO for SAR triggers
Establish secure FIU lodgement workflow + audit trail of every filing
Track SAR-filing volumes and trends as an internal compliance KPI
Reporting entities must retain customer-identification records, transaction records, training records and SAR-filing evidence for at least 5 years from the end of the customer relationship (for identification records) or 5 years from the transaction (for transaction records). DIA inspection rights reach the full retention period.
Requirements
Establish a 5-year retention scheme for KYC, AML and SAR records that survives account closure
Implement legal-hold tooling for records linked to active SARs or investigations
Test retrieval response time - DIA inspection requests typically expect production within 30 days
SkyCity Entertainment Group's 2024 AML enforcement is the most-cited recent precedent for the regulator's posture. The Federal Court of Australia approved a AUD 67m AUSTRAC penalty against SkyCity Adelaide on 7 June 2024 for serious and systemic AML/CTF non-compliance December 2016 - December 2022. In September 2024 the NZ High Court imposed a NZD 4.16m civil penalty on SkyCity. Separately, SkyCity Auckland was suspended for 5 days (9-13 September 2024) over host-responsibility breaches dating to 2018-2023.
Requirements
Read the AUSTRAC + DIA cases as the regulator's 'enforcement risk appetite' template for casino-AML failures
Anticipate that DIA's first online casino AML enforcement actions will signal proportionality against the SkyCity baseline
Factor pending AML enforcement against operator/parent into fit-and-proper applications
Sources: NZ Herald + iGB + NBR coverage June-September 2024. Status: news-confirmed; not a statutory provision but a regulatory-posture indicator.
5
DIA 5
Player protection, age & responsible gambling
The Online Casino Gambling Act 2026 sets minimum statutory standards (age, harm-minimisation strategy filing) and defers detailed operational rules - deposit limits, reality checks, affordability checks, self-exclusion register architecture - to regulations expected progressively mid-2026 to December 2027 (when self-exclusion regulations are due).
5 standards5 operator-action
100%
operator-action
Headline operator risks
Assuming AGCO-style or UKGC-style operational defaults will apply - NZ regulations will be NZ-specific and may diverge
Treating the 18-year minimum age as aligned with land-based - it is NOT (land-based remains 20)
Marketing to self-excluded persons during the regulation-drafting window before the central register is operational
Statutory minimum protections 2
OCGA 2026 §age18
[ACT - phased commencement] Minimum age 18 for online casino (vs 20 land-based)
The Online Casino Gambling Act 2026 sets a statutory minimum age of 18 years for online casino gambling - notably LOWER than the 20-year minimum at New Zealand's land-based casinos under s. 175 of the Gambling Act 2003. Operators must implement an age-verification system to prevent under-18s from registering, depositing or wagering. Technical standards for the verification system will be set in regulations expected mid-2026.
Requirements
Configure age-verification to fail-closed: no deposit accepted until age is confirmed against an authoritative source
Audit the registration funnel for any 'play before verify' path
Track the regulation drop for accepted ID document types and identity-proofing standard
Licence applicants must file a harm-minimisation strategy as part of the application. The strategy must address the operator's approach to player monitoring, intervention triggers, self-exclusion handling, advertising restraint, staff training and contribution to the Problem Gambling Levy. The Problem Gambling Foundation NZ, Hāpai te Hauora and Salvation Army Oasis have argued the statutory framework is insufficient and that additional advertising bans and inducement prohibitions should be added at regulation stage.
Requirements
Draft the harm-minimisation strategy in NZ-appropriate framing (Te Tiriti o Waitangi, Māori health perspectives, Hāpai te Hauora guidance)
Map the strategy against PGF NZ + Hāpai + Salvation Army public submissions to anticipate regulator scrutiny
Include measurable intervention KPIs (not just policy statements) - DIA will want evidence on inspection
Sources: Act 2026 + advocacy-sector submissions to Governance and Administration Committee. Status: filing in force from licence application; regulations to follow.
Deferred to regulations 3
Regs §SE-register
[REGULATIONS - pending Dec 2027] National cross-operator self-exclusion register
The Online Casino Gambling Act 2026 contemplates a national self-exclusion register that all licensees must consult and honour. The architectural specifics - query model (pre-session vs nightly re-screen), minimum duration, identity matching standard, operator funding model - are deferred to regulations with a STATUTORY deadline of December 2027. Land-based casinos already operate a Multi-Venue Exclusion programme; the online register is expected to interoperate.
Requirements
Design the registration funnel to support either pre-session real-time query OR nightly batch re-screen - the regulation may mandate either
Plan operator-funded contribution to register operation (likely mechanism: per-licence or per-active-account levy)
Track DIA consultation rounds in 2026-2027 for participation in design
Do NOT market to self-excluded persons in the interim - Gambling Act s. 16 + advertising provisions of the new Act still apply
Source: Online Casino Gambling Act 2026 framework provisions; ICLG briefing; DIA Implementation page. Status: regulations pending, deadline December 2027.
Regs §limits
[REGULATIONS - pending] Mandatory player limits (deposit / loss / time)
Mandatory player-protection limit tooling (deposit, loss, wager, time-on-site, reality checks) will be set by regulation expected mid-2026. Whether statutory defaults apply (Spain-style) OR purely player-set (UKGC-style) is not yet confirmed. PGF NZ, Hāpai te Hauora and the Salvation Army Oasis advocated for statutory defaults and explicit affordability checks in their submissions.
Requirements
Engineer the full limit-tool suite to be regulator-toggleable at the platform layer
Build a switchable 'statutory default' module - if regulations impose defaults, you can flip them on per market
Track DIA's December 2025 select-committee report response for cues on default-imposition appetite
Affordability and source-of-funds check requirements are not in the Act and are expected to be set in regulation. The UK has moved to a tiered affordability-check regime (UKGC 2024-2025); NZ regulations have not yet signalled whether they will mirror, exceed or undercut that standard. PGF NZ has advocated for an explicit affordability-check framework.
Requirements
Build configurable thresholds: net deposit, net loss, wager velocity - all toggleable per market
Pre-build source-of-funds evidence collection workflow even if not yet mandated
Maintain awareness of UK vs Australian state divergence - NZ may pick either model
Source: PGF NZ submission to Governance + Administration Committee. Status: regulations pending; not in primary Act.
Only NZ-licensed operators may advertise online casino gambling within New Zealand from 1 May 2026. The advertising regime is notable for its explicit prohibition on affiliate marketing - a structural divergence from UKGC, MGA and AGCO regimes - and uplifted penalties for unlicensed advertising. Detailed advertising regulations (content, sponsorship, broadcast, watershed, inducement specifics) are due mid-2026.
3 standards3 operator-action
100%
operator-action
Headline operator risks
Continuing affiliate-driven acquisition campaigns into NZ post-1 May 2026 - affiliate marketing is prohibited under the new regime
Operating sports-broadcast or streaming sponsorships visible to NZ audiences without a licence
Relying on UKGC-style operator-affiliate-accountability framing - NZ has gone further with a flat affiliate ban
Licensee-only advertising window 3
OCGA 2026 §ad-licensee
[ACT - phased commencement] Advertising allowed only by NZ-licensed operators
From 1 May 2026, only operators holding a New Zealand online casino licence may advertise online casino gambling within New Zealand. Advertising by unlicensed offshore operators is prohibited under the uplifted s. 16 Gambling Act 2003 regime (NZD 300,000 individual / NZD 5,000,000 body corporate penalties). The licensee-only window applies across all media: broadcast, digital, programmatic, social, sponsorship, sports broadcast and OOH.
Requirements
Audit and cease all NZ-targeted advertising from 1 May 2026 if not yet licensed
Implement geo-fencing and IP-geolocation at the ad-serving layer to suppress NZ exposure
The Online Casino Gambling Act 2026 prohibits affiliate marketing for online casino - a structural divergence from UKGC, MGA, AGCO and most international regimes (which treat affiliates as the operator's accountability with vetting + monitoring requirements but do not ban them). NZ's affiliate ban means operators cannot acquire NZ players through revenue-share or CPA affiliate channels, materially affecting acquisition economics.
Requirements
Strip NZ targeting from every affiliate, content-marketing and influencer arrangement
Build owned-channel and direct-marketing capacity to replace affiliate-driven acquisition for NZ
Notify affiliate partners contractually of the NZ exclusion to manage attribution and dispute risk
Sources: NZ Police University-students-promoting-offshore-gambling enforcement signal (RNZ 2025); Russell McVeagh implementation guidance. Status: in force from 1 May 2026; detailed regulations mid-2026.
Detailed advertising content restrictions - sponsorship rules (sport, cultural events), broadcast watershed, prohibition on inducements / welcome bonuses in unsolicited communications, mandatory RG warnings - are deferred to regulations expected mid-2026. The Advertising Standards Authority's Gambling Code interacts; operators should track both the DIA regulation drop and ASA Code amendments.
Requirements
Pre-build inducement-suppression toggles at the campaign-creative level
Map ASA Gambling Code requirements alongside DIA regulation development
Plan watershed-compliant broadcast schedule even if not yet mandated - Newsroom + The Spinoff coverage signals strong public-health expectation
Standards-explorer entries are statutory by default; this theme captures structural market-context items that materially affect compliance posture and licensing eligibility. All entries are explicitly news-source-cited and flagged as such; none represent legal obligations.
4 standards
0%
operator-action
Headline operator risks
Misreading market-context items as legal obligations - these are framing facts, not statute
Treating Entain's public 3-licence statement as locking out competitors - auction outcomes are open until awarded
Underestimating the licensing-eligibility impact of pending April 2026 class-action proceedings
DIA analysis (using DOT Loves Data) reported NZD 1.36 billion in NZ-resident deposits flowing to mostly-offshore online operators over October 2023 - September 2025; over NZD 100 million per month. Casino-style platforms drove a +38% year-on-year spend increase; sports betting spend fell -37% (consistent with TAB NZ's 27 June 2025 monopolisation). Operators based in Cyprus, Gibraltar, Great Britain and Malta accounted for >96% of identified offshore spend.
Requirements
Use the NZD 1.36B figure as the addressable-market baseline for NZ licence economic modelling
Note the Cyprus/Gibraltar/UK/Malta geographic origin pattern - these are the operators DIA's enforcement is likely to prioritise
Track the -37% sports-betting decline as evidence that licensing/monopolisation can quickly repatriate offshore spend
Sources: Casino.com industry reporting + iGaming Today coverage of DIA analysis. Status: news-confirmed; structural framing not legal obligation.
Market §entain-3
[NEWS-CONFIRMED] Entain plc publicly stated intent to seek the maximum 3 licences
News-confirmed only
Entain plc CEO Stella David stated at the company's full-year 2025 earnings that Entain will seek three online casino licences in New Zealand - maxing the 3-licence per-group concentration cap. Entain already operates 'betcha' jointly with TAB NZ for sports/racing under the monopoly. Bet365, Super Group and 888 Holdings / Evoke have been named in industry coverage as expressing interest.
Requirements
Read Entain's 3-bid signal as a baseline auction-demand indicator; cap pressure may produce competitive bid intensity
Track Entain Q2 2026 trading updates for further NZ-specific commentary
Sources: iGB coverage of Entain Q1 2026 earnings; iGB roundup of confirmed-interested operators. Status: news-confirmed.
Market §class-action
[NEWS-CONFIRMED] April 2026 NZ class action against bet365 (incl. Denise Coates personally), Super Group + SkyCity
News-confirmed only
In April 2026, coordinated NZ High Court class-action proceedings were filed against Hillside Gaming ENC + Hillside Sports + CEO Denise Coates personally (bet365); against Super Group with CEO Neal Menashe and subsidiaries (Betway / Spin); and against SkyCity. Causes of action include Gambling Act 2003, Financial Markets Conduct Act, Contract and Commercial Law Act and Fair Trading Act breaches. SkyCity exposure is estimated at NZD 64.5 million in online revenue (Feb 2020 - Feb 2026 player-loss window). Bet365 has formally objected to NZ jurisdiction (NBR).
Requirements
Treat the class action as a live licensing-eligibility wildcard - pending civil proceedings against the operator OR named directors are typically material to fit-and-proper assessments
If your group is named, prepare an explanatory submission for the EOI / fit-and-proper stage in advance
Track the bet365 jurisdictional challenge outcome - a successful jurisdictional bar would change the landscape materially
Sources: SBC News + Casino Beats + NBR + Casino.com April 2026 coverage. Status: news-confirmed; live proceedings.
The select committee process - driven by >5,000 submissions (3,966 raising community-returns concerns from grassroots-sport and community-organisation backers) - produced a structural compromise: the Offshore Gambling Duty was raised from 12% to 16%, with the 4 percentage point uplift ring-fenced for community returns through the Lottery Grants Board distribution pathway. DIA estimates NZD 10-20 million in community returns in the first 12 months from 1 January 2027.
Requirements
Treat community-funding as a structural fiscal cost, not a CSR election
Anticipate ongoing select-committee scrutiny of community-returns delivery as a 'social licence' KPI
Track Lottery Grants Board distribution announcements 2027+ as a regulator-relationship signal
Sources: Buddle Findlay select-committee analysis; Mirage News; Tribuna 5,000-submission coverage; RNZ 'Communities to get a cut from online gambling after backlash'.
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