AGCO vs AGLC: Key Differences in Ontario and Alberta Internet Gaming Regulation

Two Provinces, Two Frameworks

Canada’s constitutional structure places gambling regulation firmly within provincial jurisdiction. The result is that operators seeking to participate in regulated online gaming across more than one Canadian province face not a single national framework but a set of distinct provincial regimes, each with its own enabling legislation, regulator, commercial structure, and compliance obligations. Ontario and Alberta are the two provinces that have opened their markets to private operators at scale, and the differences between them are operationally significant.

Ontario’s framework is administered by the Alcohol and Gaming Commission of Ontario (AGCO), operating alongside iGaming Ontario (iGO), a subsidiary of the Ontario Lottery and Gaming Corporation. The primary compliance document is the AGCO Registrar’s Standards for Internet Gaming. Alberta’s framework is administered by the Alberta Gaming, Liquor and Cannabis Commission (AGLC), working in conjunction with Alberta’s iGaming Corporation (AiGC). The primary compliance document is the AGLC Standards and Requirements for Internet Gaming, the most recent version of which carries an issue date of January 14, 2026, signed under authority of the AGLC Board Chair.

Compliance officers should consult qualified legal counsel for jurisdiction-specific application of both frameworks before making operational decisions.

Enabling Legislation and Regulatory Authority

The structural difference between the two regimes begins at the legislative level. In Ontario, AGCO derives its gaming oversight authority from the Gaming Control Act, 1992 and the broader mandate of the Alcohol and Gaming Commission of Ontario Act, 2019. The Registrar’s Standards are issued under this statutory framework and carry the force of regulatory conditions attached to registration.

In Alberta, the AGLC Standards and Requirements for Internet Gaming reference two distinct pieces of legislation as the basis for operator and supplier obligations: the iGaming Alberta Act and the Gaming, Liquor and Cannabis Act (Alberta). The January 2026 standards make clear that registered operators and registered goods or services suppliers must cease all unregulated gaming activities in Alberta’s iGaming market if those activities would otherwise require registration under either statute. This dual statutory anchor is a distinctive feature of the Alberta architecture and has practical consequences for how operators structure their compliance programmes when operating across both provinces.

Commercial Agreement Requirement

One of the most operationally significant structural differences between the two regimes is the commercial agreement requirement. In Alberta, the AGLC Standards and Requirements for Internet Gaming state explicitly that registered operators must enter into a commercial agreement with AiGC or the Commission in order to provide or operate an iGaming site named on their registration. This agreement is a precondition to operation, not a parallel compliance obligation.

In Ontario, the equivalent commercial relationship runs through iGaming Ontario. Operators entering the Ontario market are required to execute an agreement with iGO before launching. The AGCO Registrar’s Standards govern the technical, responsible gambling, and operational compliance obligations, while the iGO commercial agreement governs revenue share, brand approval, and market access terms. The dual-layer structure in Ontario, with AGCO setting standards and iGO managing the commercial relationship, differs from Alberta’s approach, where AGLC and AiGC together hold both roles but the agreement obligation is stated directly within the standards document itself.

In practice, operators should treat the commercial agreement and the regulatory standards as interdependent instruments in both provinces, but the sequencing and governance of those instruments differs and should be mapped separately in each jurisdiction’s project plan.

Registration and Supplier Obligations

Both frameworks extend registration obligations beyond operators to encompass goods or services suppliers, but the scope and detail of those obligations differ in ways that matter for third-party vendor management programmes.

The AGLC Standards and Requirements for Internet Gaming set out that registered operators and registered goods or services suppliers must not enter into agreements or arrangements with any unregistered person who is providing goods or services that would otherwise require registration in Alberta. The standards further require that a personnel security screening process be in place for any director, officer, employee, agent, or consultant, at a level appropriate for that individual’s role in the organisation.

The AGCO Registrar’s Standards address a comparable concern. The relevant code provision states that operators shall not contract with any operator or gaming-related supplier if, to provide those goods and services in iGaming Ontario’s regulated online lottery scheme, it would require registration under the Gaming Control Act. A note accompanying this standard clarifies it applies to and governs applicants, not only active registrants, which has implications for pre-launch vendor due diligence.

Registered Operators and registered Goods or Services Suppliers must not enter into any agreements or arrangements with any unregistered person who is providing any goods or services that would otherwise require registration in Alberta.

Notification and Change Management

Both regulators maintain formal notification matrices that govern how and when registrants must report changes to their systems, personnel, corporate structure, and operations. These matrices are operationally critical documents because they define the triggers, timelines, and channels for proactive disclosure.

In Ontario, the AGCO Notification Matrix (currently version gaming-notification-matrix-en-2026-v1-9) is the operational control document for regulated gaming change management. It functions as a companion to the Registrar’s Standards and sets out specific notification categories, required notice periods, and the method of submission. Changes to the matrix are themselves subject to version tracking, and operators are expected to maintain awareness of updates.

AGLC maintains an equivalent notification structure referenced within the AGLC Standards and Requirements for Internet Gaming and supported by a separate notification matrix. While both matrices share a common design philosophy in that they use tiered notification categories tied to risk level, the specific triggers, timelines, and procedural requirements differ between the two documents. Compliance teams managing both jurisdictions should not assume that a change event categorised as a standard notification in Ontario carries the same classification or timeline in Alberta.

Industry consensus is that operating a single change-management workflow across both provinces, without jurisdiction-specific mapping, is a common source of notification failures in multi-province compliance programmes.

Responsible Gambling Standards

Responsible gambling is a stated priority in both frameworks, and both regulators have constructed their standards around a risk-based model that requires operators to integrate player protection controls into their operational environment rather than treating them as a separate compliance layer.

The AGCO Registrar’s Standards identify responsible gambling as a key AGCO priority and central to the public interest. The intent, as stated in the relevant code provision, is to ensure that gaming is provided in a way that seeks to minimise potential harm and promote a responsible gaming environment. Standard 2.01 requires operators to implement and follow policies and procedures that identify, prevent, and minimise the risks of harm from gaming to players. Those policies must be reviewed and evaluated regularly for effectiveness, must reflect industry best practices, and must be the subject of staff training at the time of retention and at regular intervals thereafter.

Policies and procedures for responsible gambling must be integrated into the control activities, forming a part of the control activities.

Standard 2.02 in the AGCO framework specifically addresses the obligations of OLG and iGaming Ontario, distinguishing between operator-level obligations and the provincial agency’s own programme responsibilities. This reflects Ontario’s layered model, where iGO carries its own responsible gambling obligations alongside the operator’s.

The AGLC Standards and Requirements for Internet Gaming address responsible gambling through comparable provisions. The AGLC framework also includes Attachment 3.3, which sets out additional requirements for identifying and supporting players who may be experiencing harm. This attachment structure is a distinguishing feature of Alberta’s document architecture. Compliance teams should treat Attachment 3.3 as primary source material rather than supplementary guidance, given that it carries specific operational requirements not replicated in the main body of the standards.

Both frameworks require operators to consult with stakeholders, including players and responsible gambling practitioners and researchers, as part of regular policy review. This consultation obligation is explicit in the AGCO Registrar’s Standards at the relevant code provision under Section 2.01 and carries through to the AGLC standards as well.

Notification of Offences and Ongoing Disclosure

The AGLC Standards and Requirements for Internet Gaming contain a detailed and specific list of offences that trigger an immediate notification obligation. Registered operators and registered goods or services suppliers must notify AGLC immediately if any officer, shareholder, director, or owner is charged with or convicted of an offence under a defined list of Canadian statutes, including the Criminal Code, the Excise Act, the Income Tax Act, the Controlled Drugs and Substances Act (with a carve-out for minor possession under section 4(1) for Schedule II substances), the Proceeds of Crime and Terrorist Financing Act, the Gaming, Liquor and Cannabis Act (Alberta), and the Gaming, Liquor and Cannabis Regulation (Alberta). The standards also extend this obligation to substantially similar offences under foreign legislation.

The AGCO framework addresses ongoing suitability and disclosure through the relevant code provisions of the Registrar’s Standards, but the specific statutory list and the “immediately” notification standard reflect Alberta’s particular approach to ongoing fitness obligations. Compliance officers managing both provinces should note that the offence categories and the immediacy of the disclosure obligation may differ, and that Alberta’s explicit statutory list creates a defined compliance checklist that Ontario’s framework does not replicate in the same form.

Inspection and Cooperation Obligations

Both frameworks require registrants to cooperate fully with regulators. The AGLC Standards and Requirements for Internet Gaming state that registrants, at the request of an inspector, AGLC, or an employee of AGLC, must assist the inspector in carrying out an inspection, provide access to systems and system information, records, documents, books of account, and receipts, provide a place where those materials may be inspected, audited, examined, or copied, and make representatives of the iGaming supplier or agent available for interview. The obligation extends to registered operators, registered goods or services suppliers, and their employees.

The AGCO Registrar’s Standards carry equivalent cooperation obligations. In practice, operators should ensure that their incident response and inspection-readiness procedures are calibrated to each province’s specific procedural requirements, because the documentation access and personnel cooperation obligations, while philosophically aligned, may differ in procedural detail.

Key Resources

AGCO Registrar’s Standards for Internet Gaming, Alcohol and Gaming Commission of Ontario. Available at agco.ca.

AGCO Notification Matrix (version gaming-notification-matrix-en-2026-v1-9), Alcohol and Gaming Commission of Ontario. Available at agco.ca.

AGLC Standards and Requirements for Internet Gaming, issued January 14, 2026, authority: AGLC Board Chair. Available at aglc.ca. Includes Attachment 3.3 Additional Requirements for Identifying and Supporting.

AGLC Standards for Internet Gaming (legacy version referenced as AGCL Standards for Internet Gaming). Available at aglc.ca.

iGaming Alberta Act and Gaming, Liquor and Cannabis Act (Alberta), Province of Alberta. Available through Alberta Queen’s Printer.