The AiGC Operator Agreement: Key Commercial Terms Every Alberta iGaming Operator Should Negotiate

Every operator that cleared AGLC registration and paid the CAD $50,000 application fee still cannot take a single bet from an Alberta player until one further document is in place: a commercial agreement with the Alberta iGaming Corporation (AiGC). Under Section 2.3.1 of the AGLC Standards and Requirements for Internet Gaming (SRIG), issued 14 January 2026 and updated 17 March 2026, registered operators must enter into a commercial agreement with AiGC or the Commission before they may provide or operate an iGaming site named on their registration. This is not a formality that runs in parallel with AGLC compliance work. It is a threshold condition to lawful operation, and losing it, for any reason, removes the legal basis for the entire commercial enterprise in Alberta.

The AiGC agreement has attracted less public scrutiny than the SRIG itself, partly because its full text is not published and its terms are negotiated bilaterally between AiGC and each registered operator. Legal counsel and compliance teams approaching the agreement for the first time need to understand its statutory basis, the commercial provisions that are publicly known, and the contractual levers that prudent operators should seek to define or constrain before signing.

What Is AiGC and Why Does It Have Contracting Power?

AiGC is a Crown corporation established by the iGaming Alberta Act (Bill 48, passed third reading 8 May 2025, receiving Royal Assent 2025). Its statutory mandate, derived from the iGaming Alberta Act read alongside section 207(1)(a) of the Criminal Code (Canada) and the Gaming, Liquor and Cannabis Act (GLCA), is to develop, undertake, organise, conduct and manage online lottery schemes on behalf of the Government of Alberta. That mandate is constitutionally significant. Section 207(1)(a) of the Criminal Code makes it lawful for the government of a province to conduct and manage a lottery scheme within that province. AiGC is the entity through which Alberta exercises that authority for private-operator iGaming, the same structural logic that makes iGaming Ontario (iGO) the mandatory commercial counterparty for operators in Ontario.

The practical consequence for operators is that AiGC is not simply a revenue-collection agency or a licensing body. It is the statutory conductor and manager of the scheme. Private operators participate in Alberta’s iGaming market as commercial partners of AiGC, not as independent right-holders. That power asymmetry runs through every clause of the operator agreement.

Revenue Share and Tax-Flow Mechanics

What is the actual revenue split in Alberta?

Alberta has confirmed an 80/20 revenue split between operators and the provincial government, but modelling the economics as a flat 20% government take will produce incorrect projections. Alberta’s iGaming strategy documents specify that operator revenue is allocated from net iGaming revenue after First Nations funding and social responsibility funding have been deducted. Those prior deductions total 3% of gross gaming revenue (GGR), with 2% allocated to First Nations and 1% to social responsibility initiatives. GGR is defined as bets placed, minus winnings paid out, minus eligible deductions. Only after that 3% of GGR is removed does the remaining net iGaming revenue split 80% to operators and 20% to the province, flowing to Alberta’s General Revenue Fund under the GLCA.

The sequencing matters for financial modelling. At scale, the effective government take on gross revenue is meaningfully higher than 20% once the First Nations and social responsibility allocations are factored in. Operators should build a waterfall model reflecting the actual flow: GGR reduced by eligible deductions, then reduced by 3% for statutory allocations, with the 80/20 split applying to the residual. The precise definitions of eligible deductions and the mechanics of the 3% base will be specified in the commercial agreement, this is one of the most critical provisions to negotiate with precision before signing.

Revenue Layer	Recipient	Rate / Basis
First Nations allocation	First Nations communities	2% of GGR
Social responsibility allocation	Provincial social programs	1% of GGR
Provincial share of net iGaming revenue	Alberta General Revenue Fund	20% of net iGaming revenue (post 3% deduction)
Operator share of net iGaming revenue	Registered operator	80% of net iGaming revenue (post 3% deduction)

The financial reporting obligations attached to the revenue share flow through AiGC, not AGLC. The AGLC Go-Live Compliance Guide (January 2026) explicitly routes AML and financial reporting to AiGC, while regulatory notifications and incident reports go to AGLC. Legal counsel should confirm in the agreement whether AiGC’s financial-reporting template is mandatory or operator-designable, and what the cure period is for late or deficient financial submissions.

Platform Integration and Go-Live Authority

AiGC holds the operational switch for market entry. The Application Guide published on the AGLC website is explicit: operators may begin conducting and managing their legally registered iGaming platform in Alberta from 13 July 2026, provided all applications and fees to AGLC have been submitted and contracts with AiGC have been signed by that date. The words “contracts signed” are controlling. AiGC notifies registered operators when the market has launched for their site, a registered operator that has not yet signed the AiGC commercial agreement has no operational authority regardless of the status of its AGLC registration.

Operators negotiating the commercial agreement should seek clear contractual language on three platform-integration points. The agreement should specify what technical integration with AiGC’s systems is required and on what timeline. It should define who bears the cost of integration failures or delays caused by AiGC-side systems. And it should set out the go-live notification mechanism in writing, including a defined maximum period between contract execution and AiGC issuing the go-live notification, to prevent indefinite operational limbo after registration fees have been paid.

The Interlock Between the AiGC Agreement and the AGLC Registration

What happens to the AiGC agreement if an operator loses its AGLC registration?

The SRIG at Section 2.3.1 states that registered operators must maintain a valid registration as an operator for the duration of their commercial agreement, including any renewal periods. This provision creates a hard interlock between the two instruments. An operator that loses its AGLC registration, whether through non-renewal, revocation, or suspension, simultaneously loses the legal basis for its commercial agreement with AiGC, because the SRIG condition to maintain registration runs for the agreement’s entire life.

The reverse flow is equally significant. Because the AiGC commercial agreement is a prerequisite to operation under the SRIG, termination or expiry of the agreement without renewal also removes the operational authority the SRIG would otherwise confer. Operators should therefore treat both instruments as co-dependent. Neither survives the loss of the other in a commercially functional state.

Counsel negotiating the commercial agreement should push for explicit provisions addressing: the notice period AiGC will give before terminating the agreement on grounds connected to regulatory standing, whether AiGC will notify the operator before notifying AGLC of a commercial-agreement breach that could trigger a registration review, and what wind-down protections apply to player balances and pending wagers if the agreement ends mid-cycle. These are not theoretical risks, the SRIG’s enforcement provisions give AGLC broad authority to direct additional compliance measures at its sole discretion, and the AiGC agreement is the natural vehicle through which commercial consequences of regulatory action are felt.

Termination Triggers and Wind-Down Provisions

The iGaming Alberta Act gives the Minister power to issue directives that AiGC’s board must follow in carrying out the corporation’s powers, duties, and functions. This ministerial directive power, set out in section 21 of the Act, means that AiGC’s contracting discretion is ultimately subject to government override. In practice, operators should recognise that commercially negotiated protections in the agreement sit below a layer of statutory ministerial authority that the parties cannot contractually displace.

Commercial-counsel-grade review of the termination provisions should address the following distinctions. The agreement is likely to contain termination-for-cause provisions tied to material breach, insolvency events, changes in AGLC registration status, criminal-code conviction of key officers, and AML failures. It may also contain termination-for-convenience provisions allowing AiGC to exit with notice. Operators should resist pure termination-for-convenience by AiGC without financial compensation for stranded investment, particularly where the operator has incurred significant platform-integration and compliance-readiness costs. At minimum, the agreement should specify an agreed notice period, a run-off period during which active player accounts can be wound down in good order, and the treatment of prepaid annual registration fees.

The SRIG requires operators to ensure that player funds are handled in accordance with applicable accounting standards and that players receive accurate, clear, and specific reasons for any adjustments made to their accounts. A termination scenario must be mapped against these player-protection obligations in the agreement, the wind-down protocol cannot simply close accounts without satisfying the player-notification and funds-return requirements embedded in the SRIG.

Intellectual Property and Brand Usage

AiGC conducts and manages the online lottery scheme under Alberta’s constitutional authority. Operators provide the platform technology and player-facing brand within that scheme. The distinction is operationally consequential for IP ownership. The operator’s software, game content, and proprietary algorithms remain the operator’s property, nothing in the publicly available statutory framework transfers platform IP to AiGC or the Crown.

However, the AiGC commercial agreement will govern how the operator’s brand is deployed within the Alberta-regulated environment. Operators should seek explicit agreement that AiGC has no rights to sublicense, co-brand, or otherwise use the operator’s marks beyond what is strictly necessary for AiGC to discharge its conduct-and-manage mandate. In practice, operators run their own Alberta-facing consumer brands. The agreement should confirm that the operator retains all brand equity, that any co-branded materials (such as responsible gambling messaging that combines operator and AiGC branding) require prior written approval, and that no implied licence to the operator’s IP arises from AiGC’s statutory role.

Operators should also address the assignment of IP developed specifically for Alberta compliance purposes, custom integrations with the AGLC centralised self-exclusion system, Alberta-specific responsible gambling tools, and localised AML workflows. If those integrations are co-developed with AiGC input or funding, the ownership position must be stated clearly rather than left to implication under Alberta property law.

Player Data Ownership and Privacy Obligations

Who owns player data generated through Alberta-registered platforms?

This is one of the most commercially sensitive provisions in the agreement. The SRIG at Section 5 states that player personal information must meet the data collection and protection requirements set out in the pertinent Alberta privacy legislation, primarily the Personal Information Protection Act (PIPA), which came into force on 1 January 2004 and was substantively updated in the amendments introduced following the Office of the Information and Privacy Commissioner’s 31 May 2024 review, and that player personal information must only be used for the lottery schemes conducted and managed respectively by AGLC or AiGC.

That use restriction is statutory, not merely contractual. Player data collected through Alberta-registered iGaming sites cannot be repurposed for cross-border marketing, group-level analytics, or product development outside the Alberta lottery scheme without triggering a breach of the SRIG’s data-governance requirements. Operators with pan-Canadian or international data-lake architectures must build logical separation for Alberta player data to comply with this constraint.

The iGaming Alberta Act section 20 grants AiGC the power to disclose information it has collected, including personal information, to the government of a province or territory of Canada or its agent, for the purpose of administering the Act or for any other purpose authorised by regulation. This statutory disclosure authority is relevant to Alberta’s emerging interprovincial liquidity discussions. AiGC CEO Dan Keene confirmed in May 2026 that AiGC is progressing a memorandum of understanding with Ontario to enable interprovincial player-pool sharing, subject to legal alignment with the Criminal Code framework affirmed in the Court of Appeal for Ontario’s November 2025 ruling in Reference re iGaming Ontario. If that MOU matures into a formal operational arrangement, Alberta player data may flow to Ontario counterparties under section 20, a point operators and their data protection officers should track and address in contractual data-handling provisions now rather than retroactively.

AiGC’s Audit Rights Over Operators

The SRIG at Section 2.3 gives AGLC, its inspectors, and police officers direct access to operator systems, records, books of account, and technical infrastructure. Operators must assist inspectors, provide access on request, submit to interviews about records, and permit such tests as are reasonably necessary. AGLC may direct the operator to retain an independent auditor to carry out audits and provide audit reports, and when AGLC exercises that direction, the auditor retained by the operator reports directly to AGLC, not to the operator’s board.

The AiGC commercial agreement will contain its own financial audit provisions layered on top of the SRIG’s regulatory audit rights. Operators should seek precision in the commercial audit clause on four points: the frequency of scheduled audits, the scope of records accessible to AiGC versus AGLC, the period of advance notice AiGC must give before commencing an unscheduled audit, and the cost-allocation for third-party audit work that AiGC directs but the operator funds. In Ontario, iGO’s operator agreement has established market practice on these points. Operators experienced in the Ontario market are in a stronger negotiating position to push back on AiGC audit clauses that deviate materially from the iGO template.

The SRIG also requires operators to maintain internal and external auditor access to all relevant systems, documentation, and internal controls, and to operate an independent whistleblowing process. These governance obligations feed directly into the commercial agreement: AiGC will rely on the operator’s internal audit infrastructure as part of its own assurance model, and the agreement should not introduce inconsistent or conflicting audit reporting lines that undermine the SRIG’s governance structure.

Performance Commitments and Service Levels

Alberta has confirmed a SOC 2 Type 1 attestation requirement at market launch and a SOC 2 Type 2 or ISO 27001 requirement within two years of market launch, both at the operator level. These are SRIG requirements that flow into the commercial agreement as minimum performance baselines. Operators should treat the two-year Type 2 window as a service-level commitment embedded in the agreement, not just a standalone regulatory deadline, so that a failure to meet the cybersecurity attestation timeline is treated as a breach of both the SRIG and the commercial agreement simultaneously rather than as only a regulatory compliance matter.

The agreement’s service-level framework should address uptime commitments for the Alberta-facing platform, incident-response timescales (including mandatory incident notifications to AGLC under the AGLC Notification Matrix), penetration-testing cadence (required before market launch and annually thereafter under the SRIG), and AML system availability. The SRIG explicitly routes AML and FINTRAC obligations through AiGC rather than AGLC. Operationally this means AiGC will have defined expectations for AML system performance, suspicious transaction detection sensitivity, reporting latency to FINTRAC, and documentation standards, that must be treated as contractual service levels, not merely regulatory guidance.

Obligation	Governing Instrument	Deadline
SOC 2 Type 1 attestation	AGLC SRIG + AiGC agreement	At market launch (13 July 2026)
SOC 2 Type 2 or ISO 27001	AGLC SRIG + AiGC agreement	Within 2 years of market launch
Penetration testing	AGLC SRIG	Pre-launch and annually
AGLC registration renewal	SRIG Section 2.3.1	Annual (per site, CAD $150,000)
AML / FINTRAC reporting	AiGC commercial agreement	Per AiGC reporting schedule
Financial reporting to AiGC	AiGC commercial agreement	Per AiGC reporting schedule

Geographic Exclusivity and Location Constraints

The AiGC commercial agreement operates within a geographically bounded scheme. The SRIG requires operators to ensure that games are provided only within Alberta, unless conducted in conjunction with the government of another province. Where location cannot be verified, operators must block play. This is not a commercial restriction that AiGC has imposed, it is a constitutional and statutory boundary derived from section 207(1)(a) of the Criminal Code, which authorises provincial governments to conduct lottery schemes in their province.

The interprovincial liquidity MOU that AiGC is developing with Ontario, if concluded, would expand the geographic perimeter of play, but only within the Criminal Code framework affirmed by the Court of Appeal for Ontario in Reference re iGaming Ontario (November 2025). That ruling confirmed that Ontario’s proposed pooled-liquidity model would remain lawful provided the scheme is established under provincial legislation and retains a real and substantial connection to the province. Alberta’s equivalent arrangement with Ontario must navigate the same legal analysis. Operators participating in any future interprovincial pool should ensure the AiGC commercial agreement explicitly addresses how cross-provincial play is characterised for revenue-share and reporting purposes, and how player location verification obligations apply at the provincial boundary.

Dispute Resolution and Governing Law

The iGaming Alberta Act section 15 addresses Crown liability in terms that give AiGC the protections of a government entity. Operators cannot assume that disputes with AiGC will be resolved through ordinary commercial arbitration on the same terms as a private B2B commercial contract. The agreement’s dispute-resolution provisions should be reviewed by counsel experienced in Alberta administrative and public law, not only commercial contract law, because AiGC’s status as a Crown corporation means that certain remedies available against private counterparties, injunctions against Crown agencies, for example, are subject to statutory and procedural constraints.

Operators should seek a tiered dispute-resolution clause that provides for escalation through designated senior representatives of AiGC and the operator before triggering formal proceedings. Given AiGC’s ministerial-directive exposure under section 21 of the iGaming Alberta Act, disputes that arise from government policy changes, rather than commercial disagreements, are likely to be non-arbitrable in any event. The agreement should acknowledge this distinction and provide clarity on how operator losses caused by ministerial direction are treated commercially.

The Minister may issue directives that must be followed by the corporation or the board, or both, in carrying out the powers, duties and functions of the corporation or board under this Act.

That statutory position has direct commercial consequences. Any provision in the AiGC commercial agreement that purports to insulate the operator from the effect of a ministerial directive is unenforceable. Operators entering into long-term revenue commitments or capital-investment plans based on the Alberta market should model a scenario in which AiGC’s conduct of the scheme is materially altered by ministerial direction without operator consent.

How the AiGC Agreement Differs from the Ontario iGO Agreement

Operators that entered Ontario through the iGO commercial structure after the April 2022 launch will recognise the broad architecture of Alberta’s model. Both provinces use a dual-entity structure, regulatory oversight by a commission (AGCO in Ontario, AGLC in Alberta) and commercial management by a Crown subsidiary (iGO in Ontario, AiGC in Alberta). Both use an 80/20 revenue split. Both require the commercial agreement as a prerequisite to taking bets.

The material differences are in the fee structure, the compliance intensity, and the early-stage maturity of the counterparty. Ontario’s Registrar’s Standards for Internet Gaming have three years of interpretive practice behind them, with enforcement actions against operators such as PointsBet, FanDuel, BetMGM, Relax Gaming, and Arrise establishing market-precedent compliance expectations. Alberta’s SRIG, issued January 2026 and updated March 2026, has no enforcement history yet. AiGC has no track record of commercial-agreement administration. The Ontario iGO agreement is a known quantity in many respects, the AiGC agreement is being negotiated into a blank slate. That asymmetry slightly favours operators who are willing to push on unfavourable default terms, because AiGC has limited precedent to cite as justification for any given provision.

The fee structure also diverges. Ontario’s per-site fee is CAD $100,000 annually. Alberta charges CAD $150,000 annually per iGaming site, with a one-time CAD $50,000 application fee. For multi-brand operators running multiple sites, each site requires its own separate registration under the SRIG, making the Alberta cost structure materially more expensive at scale than it appears from the headline 80/20 revenue figure. For a detailed comparison of the two frameworks’ structural differences, the AGCO vs AGLC regulatory comparison covers the full side-by-side architecture.

Operators must also enter into a commercial agreement with the Alberta iGaming Corporation (AiGC) and can only take bets and accept deposits after AiGC notifies registered operators that the market has launched.

Practical Negotiation Priorities Before Signing

Given that the full text of the AiGC commercial agreement is not publicly available, operators and their counsel should approach negotiation with a structured list of issues to resolve explicitly in the agreement, rather than accepting AiGC’s initial draft as a baseline that cannot be changed. Crown corporations in Canada do negotiate their standard-form commercial agreements with commercial counterparties, iGO’s agreement evolved materially through the first two years of Ontario’s market, and the relatively early stage of AiGC’s operational history creates more room for bilateral drafting than will exist once the market is established.

Revenue definition is the single highest-value negotiating point. The precise definition of GGR eligible deductions, the mechanism for calculating net iGaming revenue, the frequency and format of the revenue reconciliation, and the cure period for payment shortfalls should all be drafted with the same rigour applied to any major commercial revenue-sharing agreement. The revenue model should not be left to reference a future AiGC policy document that the operator has not reviewed.

Data architecture is the second critical area. The SRIG’s restriction on player personal information use to lottery-scheme purposes, combined with AiGC’s statutory power to disclose that information to other provincial governments, creates a data-governance perimeter that operators must map against their group-level data architecture before go-live. The commercial agreement should confirm the data ownership position, the permitted uses of player data by AiGC, and the notification obligations if AiGC exercises its section 20 disclosure power.

Termination mechanics, specifically the interplay between AGLC registration status and AiGC agreement termination rights, need to be drafted with the co-dependency explicitly acknowledged. Neither party should be able to trigger a unilateral termination cascade that simultaneously destroys both the registration and the commercial agreement without allowing the other party a meaningful cure or transition period. Player protection obligations under the SRIG require an orderly wind-down of player accounts regardless of the cause of agreement termination, and the commercial agreement must provide the time and resources to execute that wind-down properly.

Operators who have completed or are in the process of completing AGLC registration should note that the Go-Live Compliance Guide routes AML and financial reporting separately to AiGC rather than to the AGLC iGaming Compliance Branch. This means the AiGC commercial agreement is, in practice, the primary instrument governing FINTRAC reporting, financial crime monitoring standards, and complaints handling, obligations that in other jurisdictions would sit entirely within the regulatory licence. Operators should engage AML counsel alongside commercial contract counsel when reviewing the agreement, rather than treating the AML provisions as ancillary contract boilerplate.

For operators already registered in Ontario and evaluating Alberta as an incremental market, the AGLC SRIG compliance framework overview provides the technical foundation for understanding which regulatory obligations attach directly to the SRIG and which are governed commercially through the AiGC agreement, a distinction that shapes how compliance programmes should be structured for the Alberta market specifically. Qualified legal counsel with Alberta gaming law experience should be engaged before any commercial agreement with AiGC is finalised.

Key Resources

AGLC Standards and Requirements for Internet Gaming (SRIG), issued 14 January 2026, updated 17 March 2026, the primary technical and compliance instrument governing all registered operators and suppliers in Alberta’s iGaming market. Available at aglc.ca.

iGaming Alberta Act (Bill 48, 2025), establishes AiGC as a Crown corporation, defines its mandate to conduct and manage online lottery schemes under Criminal Code s.207(1)(a), and sets out ministerial directive authority, revenue-to-General-Revenue-Fund provisions, and personal information disclosure powers.

Gaming, Liquor and Cannabis Act (GLCA) Alberta (RSA 2000, c G-1), as amended by Bill 48, the co-enabling statute for the AGLC registration regime and the broader gaming regulatory framework in which the AiGC commercial agreement operates.

AGLC Internet Gaming Go-Live Compliance Guide (January 2026), sets out the dual-track reporting structure routing regulatory notifications to AGLC and AML/financial reporting to AiGC.

Personal Information Protection Act (PIPA) Alberta (in force 1 January 2004, amended 2024), governs the collection, use, and disclosure of player personal information by private-sector organisations, including registered iGaming operators, in Alberta.